Prepared for Sustainability in Technologies, Agriculture and Nature’s Diversity (STAND)
September 20, 2004
by Brice Smith, Ph.D., and Arjun Makhijani Ph.D.
Institute for Energy and Environmental Research (IEER)
Takoma Park, Maryland
The following are supplemental 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 STAND (Sustainability in Technologies, Agriculture and Nature’s Diversity) pursuant to a Technical Assistance Grant made to STAND by the U.S. Environmental Protection Agency. When our original comments were prepared in June 2004 we did not have a copy of the CD containing Appendix D: Final Radiological Data Sets. This was provided to us by Camille Hueni, the Remedial Project Manager, Region 6 Superfund Division at the U.S. Environmental Protection Agency (EPA). These comments address issues relating to the information contained in this appendix.
Main Findings and Recommendations:
Our examination of the Final Radiological Data Sets used in the RI Report to characterize the Pantex site has not allayed our concerns regarding the adequacy of the sample collection or data analysis procedures as raised in our revised comments of June 9th in relation to the determination of background. We are pleased that in the July 6, 2004 additional comments from the EPA to BWXT Pantex that our recommendation for a complete review of the laboratory’s Quality Assurance/Quality Control program has been incorporated. Our analysis of the Final Radiological Data Sets for the soil and groundwater measurements has shown the same inconsistent and physically unreasonable uranium isotopic ratios as was found in the background samples. Thus we continue to recommend that the QA/QC program for all data samples be scrutinized and that the RI Report be redone using new samples that are analyzed in laboratories recently certified by the Environmental Measurements Laboratory for the appropriate isotopes of uranium, plutonium, thorium, and tritium.
In addition, the sampling for tritium in the ground and surface water must be done with a lower limit of detection than currently reflected in the data. As recommended in our June 9th revised comments, the background for tritium in ground and surface water should be determined from sampling techniques with a minimum detection limit of less than 5 picocuries per litre. The concerns we have discussed in regards to the uranium and tritium measurements raise questions as to the non-detection of plutonium in 75% of soil samples and 88% of ground and surface water samples taken from the Pantex site. We continue to recommend that a suitable background for plutonium be determined from measurements with a lower limit of detection less than 0.001 to 0.01 pCi/gm given that releases to the environment cannot be ruled out from a historical analysis of Pantex operations.
Finally, we recommend that BWXT Pantex re-evaluate and seek external review for their Quality Assurance/Quality Control program used in the selection process of the laboratories to analyze the soil and water samples. We also recommend that they similarly re-evaluate and seek external review for their program to ensure an adequate examination and review of the resulting measurements in order to prevent, at a minimum, the use of data which violates basic physical laws and elementary principles of radiochemistry such as that presented in the Final Radiological Data Sets from the RI Report.
 Our original comments on the RI Report were presented on June 7, 2004, in a STAND meeting in Panhandle, Texas. A revised version of our comments was sent electronically to Camille Hueni at EPA on June 9, 2004.
 EPA 2004b (Camille D. Hueni, Letter to Mr. Jerry S. Johnson “Re: Additional Comments – Final Pantex Plant Radiological Investigation Report for the U.S. Department of Energy (DOE)/National Nuclear Security Administration, Pantex Plant, Amarillo, Texas, January 2004”, July 6, 2004)
Download the complete comments for a detailed basis for these statements and point-by-point recommendations.