Summary of Rocky flats soil contamination

Studies of Rocky Flats Offsite Soil Contamination & Public Health Impact Randy Stafford, March 2019

Introduction


In the 50 years since the public became aware of plutonium releases into the environment by the former Rocky Flats Nuclear Weapons Plant, ten studies of offsite plutonium soil contamination, and six studies of public health impact, have been conducted.  This summary recaps those studies’ findings.


Soil Studies


PhD. Radiochemist Dr. Edward Martell was first to study offsite soil contamination, collecting samples in 1969 and publishing findings in 1970 to the US Atomic Energy Commission (USEAC).  He measured background radiation at 0.0434 dpm/g in Loveland, CO, and found 311X background at Indiana Street and Woman Creek.


The USAEC sent P.W. Krey and E.P. Hardy in 1970 to investigate Martell’s findings.  They produced the widely-circulated “Krey-Hardy map” and confirmed 171X background east of Indiana Street, and south to 88th Avenue.  See Figure 1. Plant operator Dow Chemical appointed a committee of employees chaired by Robert Seed to confirm Martell’s and Krey & Hardy’s findings. The 1971 “Seed Report” produced a contour map with a          171-341X background band across Indiana.


In 1976 Jefferson County Public Health Director Dr. Carl Johnson published a soil study in Science magazine which found 325X background between Indiana and Alkire north of 96th Avenue, which caused a rezoning denial and the Church lawsuit. The defense in that lawsuit commissioned a 1979 study by employees Illsley and Hume of Plant operator Rockwell, which sampled at 71 offsite locations and found a 174X background hotspot east of Indiana just north of East Gate Road.


In 1979 former Plant engineer and whistleblower, Jim Stone, teamed with CSU professor Dr. Ward Whicker to conduct a study which found 211X background on the southwest corner of Indiana and East Gate Road, and 100X further south.


PhD Soil Geochemist, Dr. Iggy Litaor, studied offsite plutonium in 1999 and found Rocky Flat's had specific isotope ratios in soil east of Indiana Street across from East Gate Road at levels representing 111X background.


Written in 2010, the CDC’s Agency for Toxic Substances and Disease Registry’s Toxicological Profile for Plutonium document about Rocky Flats states: “The highest offsite concentration of 239,240 Pu observed … was 6,500 pCi/kg [332X background].”


 An independent 2012 study by Marco Kaltofen found 81x background just west of Indiana at 96th, and said “There was no statistically significant difference between this data set and the 1970 [Krey-Hardy] data set. Plutonium losses appear to be approximately equal in magnitude to plutonium inputs in the Indiana St. area.”


Finally CDPHE presented to the Rocky Flats Stewardship Council in 2013 another plutonium contour map, with a 256x-background band east of Indiana, and a 512x-background band just west of Indiana at East Gate Road.

Figure 1: The Enhanced Krey-Hardy map. 1850Bg/m2 is 171X background

Figure 1: The Enhanced Krey-Hardy map. 1850Bg/m2 is 171X background

Rocky flats plutonium levels

Public Health Studies

Dr. Carl Johnson was first to study cancer incidence in the downwind population, and the only investigator to publish an epidemiological study in a peer-reviewed medical journal.  In 1981 he reported 24% more radiosensitive cancers closer to the Plant than farther away, and surprisingly high testicular and ovarian cancer nearby.


Plaintiffs’ counsel in the Church lawsuit hired physicist Stephen Chinn to conduct a multiple regression analysis of the most important factors in the increased cancer incidence Dr. Johnson discovered.  Chinn’s 1981 analysis found downwind direction from the Plant (east-southeast), and proximity, to be the most important factors.

A DOE-funded study in 1984 by Kenny Crump et al. exactly replicated Dr. Johnson’s findings, then applied an “urbanization adjustment” which negated Johnson and Chinn’s findings.  The “urbanization adjustment” was later sharply criticized by expert witness Dr. Richard Clapp in Cook vs. Rockwell as “highly unorthodox.”

Dr. Clapp is a PhD. epidemiologist and former director of the Massachusetts Cancer Registry.  In 1996 he admitted an epidemiological study into evidence in that landmark case which found 29% more lung cancer and 90% more bone cancer closer to Rocky Flats than farther away in the Denver metropolitan area.


CDPHE conducted DOE-funded studies in 1998 and 2016 which found cancer incidence not higher than expected in areas selected for proximity to Rocky Flats than the remainder of the Denver metro area.  However the CDPHE studies have serious methodological flaws.  Areas it considered “near” Rocky Flats are north of Highways 128 and 36, and east of I-25.  Those areas are not downwind and not exposed to Rocky Flats contamination, therefore cancer incidence is lower.  It worked with Regional Statistical Areas which are too large-grained for contrast, whereas Dr. Johnson worked at census tract, and Dr. Clapp at zip code, granularity.

The 2016 Metropolitan State University Rocky Flats Downwinders health survey found 49% of Arvadans’ reported cancers to be rare (15 cases per 100,000 people) whereas the national rate is 25%.  It also found thyroid cancer to be the second-most prevalent in the survey whereas nationally it’s ninth-most prevalent, and the thyroid is a radiosensitive organ.


Works Cited


Agency for Toxic Substances and Disease Registry (ATSDR), US Department of Health and Human Services. 2010. Toxicological Profile for Plutonium. www.atsdr.cdc.gov/toxprofiles/tp143.pdf   Accessed March 7, 2019.

Chinn, Stephen. 1981. “The Relation of the Rocky Flats Plant and Other Factors to 1969–1971 Cancer Incidence in the Denver Area.” Fairfield and Woods.

Clapp, Richard. 1996. “Report of Dr. Richard W. Clapp.” Berger & Montague, P.C. November 13.

Colorado Department of Health. “Rocky Flats Cancer Study.” 1998. www.colorado.gov/pacific/cdphe/cdphe-rocky-flats-cancer-study   Accessed March 7, 2019.

Crump, Kenny S., Tie-Hua Ng, and Richard G. Chuddihy. 1984. “Statistical Analysis of Cancer Incidence Patterns in the Denver Metropolitan Area in Relation to the Rocky Flats Plant.” Inhalation Toxicology Research Institute.

Illsley, C. T., and M. W. Hume. 1979. “Plutonium Concentrations in Soil on Lands Adjacent to the Rocky Flats Plant.” Rockwell International Energy Systems Group, Rocky Flats Plant. 

Jensen, Carol. 2016. “Rocky Flats Downwinders Health Survey, Metropolitan State University of Denver.” Rocky Flats Downwinders. rockyflatsdownwinders.com/wp-content/uploads/2016/05/RFD-Health-Survey-Executive-Summary-Final.pdf. Accessed March 7, 2019.

Johnson, Carl. 1981. “Cancer Incidence in an Area Contaminated with Radionuclides Near a Nuclear Installation.” Ambio 10, no. 4: 176–182.

Johnson, Carl J., Ronald R. Tidball, and Ronald C. Severson. 1976. “Plutonium Hazard in Respirable Dust on the Surface of Soil.” Science 193 (August 6): 488–490.

Kaltofen, Marco. 2012. “Field Investigation and Laboratory Report for LeRoy Moore, PhD.” Boston Chemical Data Corp.

Krey, P. W., and E. P. Hardy. 1970. “Plutonium in Soil Around the Rocky Flats Plant.” US Atomic Energy Commission, Health and Safety Laboratory. HASL-235.

Litaor, Iggy. 1999. “Plutonium Contamination in Soils in Open Space and Residential Areas Near Rocky Flats, Colorado.” Health Physics 76, no. 2: 171–199.

Marcus F. Church v. United States of America. 1978. US District Court for the District of Colorado.

Martell, Ed. 1970. Letter to Dr. Glenn T. Seaborg, chair, US Atomic Energy Commission, January 13.

Seed, Robert R, K.W. Calkins, C. T. Illsley, F. J. Minor, and J. B. Owen. 1971. “Committee Evaluation of Plutonium Levels in Soil Within and Surrounding USAEC Installation at Rocky Flats, Colorado.” Dow Chemical Company, Rocky Flats Division, RFP-INV-10.

Spreng, Carl. 2013. “Operable Unit 3 Offsite Areas.” Presentation to the Rocky Flats Stewardship Council (RFSC), February 4. www.rockyflatssc.org/OU3-RFSC-4Feb13.pdf. Accessed March 7, 2019.

Webb, Scott B., James M. Stone, Shawki A. Ibrahim, and F. Ward Whicker. 1994. “The Spatial Distribution of Plutonium in Soil Near the Rocky Flats Plant.” Colorado State University Department of Radiological Health Sciences.y policies, executive profiles, company awards/distinctions, office locations, shareholder reports, whitepapers, media mentions and other pieces of content that don’t fit into a shorter, more succinct space.


Figure 2. Maps the location of studied samples showing high multiples of background contamination.

Figure 2. Maps the location of studied samples showing high multiples of background contamination.

What Really happened?

A Caring Government or the Developers Best Friends?

 What constitutes good government? In this age of alleged fake news, reality can be confusing. The principles of good government should be as true today as they were in our parent’s time. We expect government to represent our best interests, be truthful, open and willing to communicate with our citizens. Good government should consider the needs of both the majority and minority and should not be influenced by the special interests. At the end of the day, our government must do more than just try to do what’s in our best interests, they are obligated to protect us and our rights. 


Many years ago, local governments correctly decided that there was a need for a Denver Beltway that would funnel traffic around the Denver metropolitan area to decrease congestion on local roads. It was a great idea but as of today, there is no completed Denver Beltway. Competing projects and differing views on what was needed has prevented the idea from becoming reality. Along the way, another group identified potential beltway routes. Most were rejected for one reason or another. Chief among these reasons was the danger associated with running a highway near homes. Ultimately the Jefferson Parkway route was selected. Unlike many of the other options at the time, this route was free of homes and passed through undeveloped land. The idea was that the Jefferson Parkway would connect with C470 to the south in Golden and with the Northwest Parkway in Broomfield. It seemed like a great plan but then the plan began to unravel.


The first failure came when Golden opposed and successfully defeated the planned connection to C470. Golden did not support the planned toll road because road would split the historic town in half. Golden was concerned about its citizens. Arvada and Broomfield revised the route so that the toll road would exit onto Hwy 93 north of 64th avenue, and south of 82nd. This route would add another traffic signal that would slow traffic on route Hwy 93. The City of Arvada and Broomfield with Jefferson and Broomfield county would need to acquire all the property necessary to construct the toll road. A developer, who owned the Leyden Rock area wished to develop his property into a residential community, so he requested that Arvada annex his property to acquire city services for the development. The City of Arvada agreed, but with a catch. Arvada demanded that land be donated for the Jefferson Parkway. The developer agreed, though the condition was not viewed as desirable or advantageous. 


The developer and the City of Arvada signed an annexation agreement on 09/29/2011. The document defined the rights and obligations of the developer and two items were of interest. The first provision required the developer to post proposed tollway right of way signs every 500 feet along the roadway path. This would ensure that there would be no confusion about the certainty of the toll road becoming reality. The second provision required that fencing be installed on both sides of the proposed toll road. The fencing was necessary to protect the children and residents of Leyden Rock from the expected tollway traffic. Arvada did not require or request that signs be posted at the entrances to Leyden Rock or at the entrances of the builder’s sales centers. Essentially the signs were invisible to interested clients unless they hiked up to the proposed roadway. It certainly caused many to wonder why Arvada would not require signage that could be seen by all. It makes you wonder what Arvada’s actual motive.


At this time, Arvada still had not approved the development. Arvada could have required that commercial development occur in Leyden Rock. Commercial properties usually do not object to a nearby roadway and many would embrace proximity to major roads as a benefit that would be an asset to commercial ventures. Arvada did not consider commercial development near the tollway as was suggested. A caring government would have protected potential residents by preventing house construction near the toll road. Another option Arvada could have required was a buffer zone with natural barriers between homes and the roadway. Arvada neither requested or required either option. What the City of Arvada allowed was mass development of homes within 65yards of the proposed toll road. Politicians could have protected the future residents while acquiring the property, but they took no action. The desire to obtain their precious roadway was all consuming and blinded them to the dangerous road they were about to build.


To the north of Leyden Rock, the Jefferson Parkway would parallel Indiana Street on 106 acres of land that was on the Rocky Flats site. Plutonium testing in the toll road right of way indicated the presence of contamination hot spots. Of more concern, the testing was so sporadic that no one knew how many hot spots present or how much contaminated soil are is present. For some unexplained reason, an area that was considered contaminated for many years is now considered safe for use. No Arvada official can explain the reason behind the change of heart other than to say that CDPHE indicates the area is safe. There is no mention that the two prior administrators of CDPHE and the Jefferson County Health Director disagreed with this assertion. Could profit be a factor? Quite inexplicably, the Jefferson Parkway Public Highway Authority (JPPHA) announced that they would now indeed conduct soil testing though they have not provided the testing plan or whether they will abide by the action limits set by the state and federal government. The action (exposure) limits are much higher for federal contaminated land than for contaminated land under state control and the JPPHA is claiming they can use the less safe federal action limits because the land was federal property. This is something that residents should be particularly concerned and worried about.


The Jefferson Parkway toll road, if built, will discharge traffic onto two large undeveloped areas by Candelas and the Rocky Mountain Metropolitan Airport. Both sections have been approved for development and will generate considerable traffic once construction is complete. We know that development will occur over time, but the toll road’s construction will accelerate the development and cause increased traffic and congestion. In addition, Indiana Street will be realigned and a roundabout will be added. We expect that the roundabout will reduce traffic speeds on Indiana Street and quite "coincidentally" encourage use of the toll road. Is it possible the road’s sole purpose is to assist developers make millions of dollars while taxpayers fund the construction of the toll road, endure increased traffic, congestion and longer commute times? Could a caring government believe that more traffic, longer commutes, increased accidents, more injuries and fatalities and more congestion be in the best interests of our citizens? We like to believe that most reasonable individuals, who do their own research to confirm our views, will conclude that the Jefferson Parkway toll road is not a parkway but a "Pork Way".

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Arvada City Council Meeting March 4th, 2019

Mike Raabe Addresses Arvada Mayor and City Council

  

Mr. Mayor and Council Members. My name is Mike Raabe and I am with the Movement to Stop Jefferson Parkway. I’m here to encourage you to vote no on the $2 million budget request for the Parkway on April 1. Let’s go back 8 years to 2011. The property that became known as Leyden Rock was just open space--no houses, and not yet part of Arvada at that time. In September of that year, the Arvada City Council signed an agreement to a developer to annex the property in Arvada to develop an impressive, beautiful residential community that was designed, unfortunately, with a right of way for a four-lane tollway. We were told by the developer that the City required them to set aside the path for the tollway through the community in order to get approval for the annexation.

The Council felt the need to include a few things in the agreement so there would be transparency to future homeowners that this tollway was going through the heart of the community. The Council knew this would be an issue, so one of the things in the agreement was a requirement for signage throughout the community. The agreement required that immediately upon completion of the rough grading of the Parkway, the Developer was to, at their sole expense, install and maintain signs on each side of the Parkway ROW (Right Of Way),at a minimum of every 500 feet, notifying the public of the future construction of the Parkway. At the same time, the Developer shall, at their sole expense, install and maintain fencing on each side of the Parkway ROW for the entire length of the Parkway through Leyden Rock.

The signers of this Agreement, including the city of Arvada, while understanding the importance of this language, have NEVER been in compliance with it.

When I came to Leyden Rock to look at homes in the summer of 2016—there were NO signs and NO fences up. You will find my experience is not dissimilar from many other home buyers. It was a year later before some signs were installed. Those are the signs that are there today; in some cases now blown down; in many cases just not visible.

In looking at pictures I recently took (shown below). If you saw the CBS 4 video that ran this weekend covering our opposition to the Parkway, you can clearly see there are no signs every 500’ and no fencing. The council did not get the transparency they were seeking in 2011.

In the CBS4 story, Bill Ray stated, "There are signs placed every 500’ along the edge of the right of way”.


Others, including this council and on the Parkway Authority Board, have made similar statements. Clearly, those making these statements have not taken the time to visit our community, even eight years after the Annexation Agreement was signed. 


The statements they have made are not true and must stop. Our offer to tour our community still stands and they are welcome to contact us to schedule one.


This Council should care for our citizens--all of our citizens. In Leyden Rock and Candelas, those include homeowners and families with children only a few dozen yards from a high-speed tollway. It also includes those who live in communities around and downwind of Indiana Street and Rock Flats. Many of these citizens are stressed, anxious, angry, concerned and afraid. 


You can help them. You can stop it now by not approving the additional $2 million for the 2019 Parkway Authority budget. 


An example of the attempt to include signage to educate future homeowners

An example of the attempt to include signage to educate future homeowners

It's Time To Step Up and Be Recognized! Hear Our Voices!

REPRESENT, WE NEED YOU!

The next Arvada City Council meeting is April 1st, 2019 at 6:00 pm, in the Council Chambers at 8101 Ralston Road, Arvada. 

This could be the the most important meeting as the Council is set to vote on adding $2 Million to the JPPHA budget. We need to show the community backing to our Movement to Stop Jefferson Parkway! 

Sign up if you will attend this very important step to stop the jefferson Parkway

We Need Accountability

The Arvada City Council have not approved the JPPHA 2019 Budget as of yet. It is critical that we show up and OVERFLOW the Council Chambers. We need to show the council that approving the 2019 Budget is unacceptable! We cannot watch our tax dollars be flushed down the JPPHA drain. Enough is Enough! It is time for the Council to represent Arvada taxpayers, not Private Enterprises!

Can You Attend? We Need You

This meeting is CRUCIAL! The more Arvada citizens that come to this meeting will help to send a message to the Council that we don't want the Jefferson Parkway to route through our communities in the best interests of private enterprises from foreign investors. If this is what the Council wants, the least they could do is protect the citizens of Arvada by making sure that Safety, Sound, Light and Environmental measures are taken to protect the citizens they are supposed to represent. Stop wasting our tax dollars! There are other route possibilities that could eliminate dividing communities in half and reducing Plutonium risks by digging up Rocky Flats. We know that the largest interest of the JPPHA is to advance commercial growth along the toll road. We the taxpayers are the reason you are in your positions. Try thinking about our interests FIRST! 

Broomfield City Council Meeting

Letter to the Broomfield City Council

  

On February 12th 2019, Mike Raabe, a member of our Movement to Stop Jefferson Parkway addressed the Broomfield City Council during the public comments time allowed during the Council Meeting. This letter was sent by Mike Raabe to the Broomfield City Council the next day.


Honorable Broomfield City Council Members


Thank you for allowing me to make a public comment last night. As I was given limited time to speak, I am sending my complete comments via email. Thank you for listening to me last night and for reading this.


I am an Arvada citizen and part of a group recently formed called The Movement to Stop Jefferson Parkway. You have been asked to approve an additional $2.1 million to support the Parkway Authority for 2019. We strongly urge you to vote NO when that request comes up for a vote soon.


While many of us do support a true completion of the Denver Beltway, we strongly disagree with the proposed alignment of the Toll Road. When our group explained the reasons why we disagree with the proposed alignment, we were referred to a study done in the early 2000’s, the (CDOT Northwest Environmental Impact Study). 


This study analyzed over 70 alternatives to complete the Northwest Beltway and selected the current alignment as the preferred alternative.


We were then told to accept this conclusion as fact. But we disagree with this study of the alternatives and its final recommendation for the following reasons:


1) The EIS study was never completed. It was cancelled in 2008 after running out of money and no further budget money was available. A truncated planning document was then released, however, it’s critical to note that this report never had consensus from all the players in the Northwest Quadrant.

 

2) The four final alternatives all assumed completion of the beltway from the Northwest Parkway to C470. However, this proposed Toll Road does not complete the beltway and as far as we know, there is no money to do so. At its southern terminus, it will dump traffic onto Highway 93 in West Arvada. It is still over 10 miles to C470 with 8 traffic lights along the way. On the north, it will dump traffic onto Hwy128 in Broomfield. It is still about 3 miles with 7 traffic lights to the Northwest Parkway. How does this improve traffic? Instead it will add to congestion along Highway 93 and in the Interlocken area. In addition, traffic will also back up along the Tollway as vehicles come to a dead stop since the Tollway terminates on both ends at a traffic light. How does this plan and this alignment make sense? 


3) The study completely ignores the potential release of plutonium contaminants in the air and moving downwind if construction occurs along the Indiana corridor right of way. The data clearly shows there is plutonium from Rocky Flats in the soil along Indiana. This contamination is hundreds of times the acceptable background radiation. In addition, hotspots have been found with much more than 500x background radiation. Many more areas along Indiana have never been tested. The plutonium levels have remained at essentially the same level between 1970 through 2012 based on eleven different studies that have been conducted by experts from across the country. The construction plan calls for cut and fill to try to level the Tollway along the rolling terrain. The EIS study completely ignores this threat along Indiana Street. The study talks more about wetlands, wildlife and prairie dogs than the potential safety risk to thousands of citizens around and downwind of Indiana. We feel that totally ignoring this safety risk is a glaring flaw.


4) One aspect of the study we do agree with, is that it did not advance ANY alternatives that impacted high population residential areas. When the study was in process, there were no homes in the Leyden Rock and Candelas areas. The study notes this part of the alignment was mostly open space at that time. Had the housing developments in Leyden Rock and Candelas been on their radar, this alignment that now cuts around and through these communities would never have been made as a final alternative.  To quote from the report about several alternatives that were eliminated “the introduction of a four-lane freeway thru the established residential neighborhood would have unacceptable visual, noise and right of way impacts to the community.”  


5) This recommended alternative also provided for improvements to Indiana and McIntyre streets in Arvada, and a new interchange at 64th Parkway and Highway 93. This would be paid for by collected tolls. These were important improvements to assist with traffic congestion in this area. However, none of these improvements are part of the current project. All the toll money collected will be retained by the private enterprise that operates the Toll Road. These are some of the reasons why Toll Roads are a bad idea as communities give up tax dollars for 30 years or more that could be used for other projects and improvements.


6) We believe the selection process to get to the final four alternatives is flawed. The Study team was aware there was no money for most of the alternatives. Cost is why most of the alternatives were eliminated and why two of the final 4 alternatives had toll revenues as a primary funding source.


7) Finally, this is all about development along this alignment. It is about money that would go to landowners, developers and the municipalities from increased sales and tax revenues. This alignment east of Rocky Flats was always preferred over the west alignment along Highway 93 and 128 because as stated in the report, the three planned interchanges (at Highway 72, near what is now Candelas, and near the Great Western Reservoir) were all put in place to support the planned development.

 

Unfortunately, the JPPHA did accept this study as fact and has moved to acquire all the rights of way along the recommended alignment, while ignoring the growth that has occurred in Leyden Rock and Candelas and has been known since 2011, not to mention the studies that proved plutonium contamination from Rocky Flats along Indiana Street.


We do not accept as fact a recommendation that fails on so many levels, and never was agreed to by several northwest communities.

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Tell the Truth JPPHA!

In this interview with Denver 7 in December 2018, the JPPHA continues to convince the public that the Jefferson Parkway will complete the Denver Beltway. They also claim that everything is a go to break ground on the project. As of today, the JPPHA website continues to tell the public that the project will complete the Denver Beltway!

Arvada City Council Meeting on March 4th, 2019

  

Mike Raabe Addresses the Arvada Mayor and City Council.

Mr. Mayor and Council Members. My name is Mike Raabe and I am with the Movement to Stop Jefferson Parkway. I’m here to encourage you to vote no on the $2 million budget request for the Parkway on April 1. Let’s go back 8 years to 2011. The property that became known as Leyden Rock was just open space--no houses, and not yet part of Arvada at that time. In September of that year, the Arvada City Council signed an agreement to annex the prop