Prepared for Serious Texans Against Nuclear Dumping
revised June 9, 2004
by Brice Smith, Ph.D. and Arjun Makhijani Ph.D.
Institute for Energy and Environmental Research (IEER)
Takoma Park, Maryland
The following are the comments prepared by the Institute for Energy and Environmental Research on the January 2004 Pantex Plant Radiological Investigation Report, henceforth referred to as the RI report. We have prepared this analysis for Serious Texans Against Nuclear Dumping (STAND) pursuant to a Technical Assistance Grant made to STAND by the U.S. Environmental Protection Agency.
Main findings and recommendations
There is a substantial amount of evidence in the RI report that measurement protocols or analysis or laboratory techniques, or some combination of these factors have led to many of the reported measurements being anomalous or at odds with basic, established principles of uranium radiochemistry. Specifically, the isotopic ratios of U-235 to U-238 in soil samples and in groundwater samples appear to have significant errors. The tritium analysis is also unsatisfactory. The lack of a valid background for uranium, tritium, and plutonium for the Pantex site contributes to the fundamental deficiencies of the RI report. The RI report even provides soil screening results that violate basic physics. The RI report provides screening results that are literally incredible. The RI report screening levels imply that dumping vast amounts (millions or billions of tons) of pure plutonium, uranium, or tritium on the site would not threaten the groundwater. We find that the contractor and the DOE have failed to provide credible data or a credible analysis in this RI report. The RI report’s authors review of process information complemented by worker interviews is an important part of producing a sound RI; however, despite the considerable effort, the final product is not scientifically sound in many essential aspects.
Our principal recommendation regarding the RI report is that this report needs to be redone with new field data based on samples that are properly analyzed by laboratories that have recently be certified by the Environmental Measurements Laboratory for the specific radionuclides at issue: uranium and plutonium isotopes, tritium, as well as some fission products that may have been used in experiments. Reliable background values for the Pantex site for uranium and plutonium should be established and published as part of the new RI report. A reliable background for tritium in groundwater in the general area of the plant needs to be established for both perched aquifers and the Ogallala aquifer. The active oversight of the EPA in this process is needed. The fact that this final RI report that is so flawed could have been published, without the basic errors having been eliminated at the draft stage, indicates a failure of the quality assurance and quality control procedures. This means that far more active EPA oversight is needed in the preparation of a valid RI report. The EPA should require that the new RI report be published in draft form for public comment so that the kinds of severe problems that are in the current version do not recur in the new final Report. DOE and its contractors also need to strengthen their internal review procedures and their quality assurance and quality control processes.
Download the complete comments for a detailed basis for these statements and point-by-point recommendations.