Epidemiologic Studies

Rocky Flats Plant Site

INTRODUCTION

Overview
This is the fifth in a series of seven volumes which constitute a guide to records of the Rocky Flats Plant useful for conducting health-related research. The primary purpose of Volume V is to describe record series pertaining to waste management activities at the Department of Energy's (DOE) Rocky Flats Plant, now named the Rocky Flats Environmental Technology Site, near Denver, Colorado. History Associates Incorporated (HAI) prepared this guide as part of its work as the support services contractor for DOE's Epidemiologic Records Inventory Project.

This introduction briefly describes the Epidemiologic Records Inventory Project and HAI's role in the project, provides a history of waste management practices at Rocky Flats, and identifies organizations contributing to waste management policies and activities. Other topics include the scope and arrangement of this volume and the organization to contact for access to these records. Comprehensive introductory and background information is available in Volume I.

Other volumes in the guide pertain to administrative and general subjects, facilities and equipment, production and materials handling, workplace and environmental monitoring, and employee health. In addition, HAI has produced a subject-specific guide, titled The September 1957 Rocky Flats Fire: A Guide to Record Series of the Department of Energy and Its Contractors, which researchers should consult for further information about records related to this incident.

The Epidemiologic Records Inventory Project
The Epidemiologic Records Inventory Project is indicative of DOE Secretary Hazel R. O'Leary's efforts to support openness initiatives in the areas of environment, safety, and health. In view of the importance of various administrative, organizational, and operational records to epidemiologic and health-related studies, a moratorium on the destruction of such records has been in effect since 1989.

In May 1992, the DOE Office of Epidemiology and Health Surveillance (EH-42), responsible for the coordination of all health-related activities throughout the DOE complex, directed each DOE and DOE contractor site to prepare an inventory of all records useful for worker or community health-related studies. EH-42 prepared and furnished each site with guidelines that defined epidemiologic records, provided instructions for describing record series, outlined the sites' role in inventorying epidemiologic records, and discussed the relationship of the epidemiologic inventory to DOE's comprehensive records inventory. The epidemiologic inventories should be completed in 1995. It should be noted, however, that some of the information contained in the site records inventories, such as the location of active (still in use) records or the volume of the records, may change over time. The continued usefulness of the inventories and this guide depends on their systematic update.

Role of HAI
In August 1993, DOE selected HAI as its support services contractor for the Epidemiologic Records Inventory Project. HAI, a professional records management, archives, and historical research services firm incorporated in 1981, has provided records management, historical research, and technical support for a number of DOE projects. HAI's role in the project includes verifying the accuracy, comprehensiveness, and quality of existing inventories, providing guidance to site records management teams, and, in some cases, performing additional records inventories.

BACKGROUND

History of Waste Management
Historically, defense-related production activities at Rocky Flats resulted in liquid, solid, and sanitary wastes. Waste management and disposal practices changed over time due to periodic shifts in the plant's production responsibilities, technological innovations, and the application of regulatory standards by federal and state agencies. Although the production of defense materials took priority from the beginning of operations, Rocky Flats has always conducted routine monitoring for environmental contaminants.

Scientists involved with the Manhattan Project, administered by the Manhattan Engineer District (MED), knew the potential hazards of radiation early in the atomic energy program's development. When the MED's facilities and programs were transferred to the civilian Atomic Energy Commission (AEC) in 1947, scientists, commissioners, and staff alike acknowledged the importance of minimizing exposure to radiation. Methods of radioactive waste management and disposal remained a subject of debate throughout the subsequent history of the atomic energy program.

In 1949, the AEC issued a report that discussed the handling of wastes generated by nuclear materials production which sparked intense discussion within the scientific community.(1) In this document, titled Report on the Handling of Radioactive Waste Materials, the AEC addressed a range of factors to be considered when dealing with radioactive wastes in the areas of production operations and medical research. The AEC also focused on the "handling" rather than the "disposal" of wastes, since a large volume of waste did not exist at that time. (2)

Rocky Flats began operations in 1952. Its primary mission was the fabrication of plutonium pits, or triggers, for nuclear weapons from such materials as plutonium, uranium, beryllium, and stainless steel alloys. The facility subsequently played a key role in the recovery of plutonium from dismantled weapon components and from process scrap. As the only production facility in the United States to perform this function, Rocky Flats was a vital part of the nuclear weapons complex. (3)

Between 1952 and 1989, Rocky Flats used and managed hazardous and radioactive materials, producing large amounts of hazardous and radioactive waste, including transuranic, high-level, low-level, and mixed wastes. Transuranic (TRU) wastes are defined as "radioactive waste containing alpha-emitting radionuclides having numbers greater than 92 and half-lives greater than 20 years in concentrations above 100 nCi [nanocuries] per gram" and include substances such as americium and plutonium. (4) Wastes generated by reprocessing spent fuel and irradiated targets are classified as high-level. Short-lived, highly radioactive fission products; long-lived isotopes; hazardous chemicals; and toxic heavy metals may be found in these wastes. Low-level radioactive wastes are those which contain a small level of radioactivity within a large volume of material. Typical disposal methods for low-level wastes include surface burial and storage in boxes or drums. Mixed wastes include both radioactive and chemical materials. Some low-level waste and all TRU and high-level wastes are handled as mixed wastes. (5) Other wastes which the plant produced as part of daily operations include medical, sanitary sewage, and laundry wastes. Rocky Flats adopted several different practices to manage its waste, including the use of burial pits and trenches, evaporation ponds, drum storage, and onsite landfills. (6)

In several places throughout the site, Rocky Flats buried waste in unlined pits. The most contaminated of these sites is the 881 Hillside, which extends south and east from Building 881. Wastes buried, dumped, and released at this site include plutonium-contaminated soil, fuel, oil, oil sludge, solvents, and unknown hazardous chemicals. (7)

From 1953 to 1986, solar evaporation ponds were used to store and treat low-level radioactive process wastes that contained nitrates and neutralized acidic wastes containing aluminum hydroxide. The solar ponds also received sanitary sewage sludge and wastes containing lithium metal, sodium nitrate, ferric chloride, lithium chloride, sulfuric acid, ammonium persulfates, hydrochloric acid, nitric acid, hexavalent chromium, and cyanide solutions. Although the ponds were lined, leakage and seepage occurred as early as the 1960s. (8)

Rocky Flats developed a method of pond sludge solidification in 1985 to deal with waste which ultimately led to serious problems. The sludge was removed from the pond and mixed with Portland concrete to make solidified "pondcrete" blocks, which were then placed in tri-wall cardboard boxes and shipped to the Nevada Test Site (NTS). The next year, The Resource Conservation and Recovery Act (RCRA) went into effect. RCRA established national standards requiring the reduction or elimination of hazardous waste and the treatment, storage, or disposal of waste to minimize harm to the environment. As a result, pondcrete shipments stopped in late 1986, because NTS did not have a RCRA permit. The production of pondcrete blocks continued, but they remained in temporary storage at Rocky Flats. During storage, which consisted of stacking the blocks outside on asphalt pads under canvas tents, some of the pondcrete began to seep. In response to the seepage, workers changed the recipe for the blocks, with limited success. (9)

Unprotected drum storage was also an accepted waste handling practice during the 1950s and 1960s at Rocky Flats. From 1958 to 1967, 5,240 drums of plutonium- and uranium-contaminated machining oils were stored at an oil drum storage field in the 903 Area. During outdoor storage, corrosion of the drums caused the contamination of soil in the immediate vicinity. Leakage was first detected in 1959, prompting the addition of a rust inhibitor to drums prior to storage. By 1964, however, workers found further soil contamination. The drums were removed to a processing facility during 1967 and 1968. In 1969, Rocky Flats covered the area with an asphalt pad to halt the migration of contaminated soil offsite. (10)

The plant also generated TRU waste which was sent to the Idaho National Engineering Laboratory (INEL) for permanent burial until 1970. After 1970, this waste was sent to INEL for interim storage, pending the development of a permanent disposal facility. As a result of delays in the opening of the Waste Isolation Pilot Plant, located in Carlsbad, New Mexico, in September 1989, the State of Idaho closed its borders to TRU waste shipments from Rocky Flats. Rocky Flats now stores TRU waste onsite. (11)

In 1973, the AEC initiated a study that focused on potentially contaminated soils onsite. The study directive asked for a plan of action for locating and investigating the contaminated soils and developing cost estimates and schedules for remediation. In 1975, the AEC's successor agency, the Energy Research and Development Administration, asked for an environmental assessment of Rocky Flats. The end result was the Final Environmental Impact Statement (EIS), produced by DOE in April 1980. The EIS contained descriptions of the facility, environs, and operations.

The methods of managing radioactive waste outlined above were standard practices for this time period. Since the 1950s, the AEC and its successor agencies have sponsored research into technologically different methods of dealing with waste generated from defense materials production but failed to adopt uniform processes and procedures for all site operating contractors. According to historian Richard G. Hewlett, the AEC's "rationale was that the waste disposal requirements at each site were in many ways unique and that processes and procedures should be designed to meet those requirements." Until the mid-1980s, the Atomic Energy Act of 1954 governed site waste management practices. After that time, a growing body of federal regulations determined waste management activities at Rocky Flats. (12) In addition to RCRA and the Comprehensive Environmental Response, Compensation, and Liability Act, (13) site-specific agreements were signed. One of these, the 1986 Compliance Agreement, signed by DOE, the Environmental Protection Agency, and the Colorado Department of Health (now the Colorado Department of Public Health and Environment), defined roles and established milestones for environmental operations and remedial investigations at Rocky Flats. These efforts are continuing at present. (14) In November 1989, by order of the Secretary of Energy, all production activities ceased and the plant's focus shifted to decontamination and decommissioning activities.

Waste Management Organizations

Dow Chemical Company (1952-1975)
Although waste management is not specifically mentioned in the organizational charts for the Dow Chemical Company, Rocky Flats produced a number of records related to waste management from 1952 through 1975 under the auspices of various organizations, including Operations (1951-1966), Waste Operations (1951-1967, 1969-1974), and Waste Disposal (1974). The Process Waste Disposal, Waste Disposal Coordination, Waste Management, Waste Treatment, and Health Physics organizations handled a wide variety of waste-related functions and reported to the Waste Operations Organization. The Radiation Monitoring Organization, although not directly responsible for waste management activities, provided support services for waste programs.

Rockwell International (1975-1989)
Rockwell International's Waste Processing Organization handled waste management at the Rocky Flats site from 1975 until 1979. In 1979, Waste Processing became known as Waste Operations and instituted subbranches to handle solid and liquid waste. According to organizational charts, Waste Compliance and Planning was added in 1986 to handle federal compliance programs, and Waste Programs was added in 1988 to manage hazardous waste and waste minimization programs. Starting in approximately 1986, Rocky Flats generated records that document compliance with RCRA. Other organizations involved in waste management under Rockwell were Liquid Waste Processing (1980-1986), Waste Regulatory Programs (1989), and Waste Certification (1986-1989). Supporting organizations include Industrial Hygiene, Technical Writing, Water Chemistry Laboratory, Tank Surveillance, Auditing and Strategic Planning, and Traffic.

EG&G (1990-1995)
EG&G created the Environmental Restoration and Waste Management Organization to handle waste management in 1990. The organizational name was changed to Environmental Waste Management in 1991. Waste Programs, a branch of Environmental Waste Management, includes subbranches for RCRA Regulatory Programs, Waste Regulatory Programs, Radioactive Waste Programs, Waste Minimization, Waste Technical Support, Waste and Environmental Management System Program, Waste Program Plans, and Waste Identification and Characterization. Organizations providing support to waste management programs include Land Disposal Requirements, Building 664 Operations, Occupational Health, and Nuclear Materials Control. DOE also began providing supporting services through its Occupational Health Division in 1988.

ACCESS

For more complete information regarding access to the records, please refer to Volume I. The Department of Energy's Rocky Flats Plant: A Guide to Record Series Useful for Health-Related Research.

For specific information or permission to review Rocky Flats records, contact:

U.S. Department of Energy
Records Management Department
Contracts and Services Division
Rocky Flats Office
P.O. Box 928
Golden, CO 80402-0928
Telephone Number: (303) 966-6177

SCOPE

Record series found under this volume relate to the storage, handling, treatment, and disposal of radioactive, chemical, or mixed materials produced or used at Rocky Flats. Included are descriptions of worksheets documenting the production of waste, contamination monitoring records, hazardous waste procedures manuals, sampling records, waste tank radiation monitoring records, waste shipment records, and specifications for chemical storage.

This volume reflects information collected from research conducted during site visits from March 1994 through January 1995. Users of this volume should note that omissions are likely due to the nature of the records targeted for research. For example, the June 6, 1989, seizure of records by the Federal Bureau of Investigation rendered an unknown quantity of records unavailable for review by HAI staff. Moreover, HAI team members did not inventory records stored in radiation-controlled areas.

HAI relied on existing finding aids prepared for Rocky Flats records. HAI was unable to verify that these research tools include all records that may exist. In addition, researchers should note that records at all of the repositories listed in this guide may be moved, transferred to a different location, reviewed for changes in disposition authority, and changed to a different format (i.e., from paper to microfilm).

ARRANGEMENT

1. Richard G. Hewlett, "Federal Policy for the Disposal of Highly Radioactive Wastes From Commercial Nuclear Power Plants: An Historical Analysis" (March 9, 1978), 5.
2. Ibid., 6.
3. Jill G. Paukert, Final Rocky Flats Plant Community Relations Plan: Environmental Restoration Program (Rocky Flats Plant, December 1991), 7; A Closer Look At Rocky Flats (EG&G Rocky Flats, Inc., January 1992), 5.
4. The Rocky Flats Dictionary, second edition (EG&G Rocky Flats, July 1991).
5. United States Department of Energy, Office of Environmental Management, Closing the Circle on the Splitting of the Atom (Washington, DC: United States Department of Energy, January, 1995), 24.
6. Michelle A. Hanson, "Site History of Rocky Flats" (Washington, DC: United States Department of Energy, History Division, January 1993), 8-9.
7. Ibid., 8-9.
8. Ibid., 8.
9. Ibid., 10-11; Resource Conservation and Recovery Act of 1976 [Public Law 94-580 (Title 42 U.S.C. 6901)].
10. Hanson, "Site History of Rocky Flats," 8.
11. Ibid., 9.
12. Hewlett, "Federal Policy for the Disposal of Highly Radioactive Wastes," 10; Hanson, "Site History of Rocky Flats," 9.
13. Comprehensive Environmental Response, Compensation, and Liability Act, December 11, 1980 [Public Law 96-510 (94 STAT 2767)]. There have been multiple amendments to this law.
14. Hanson, "Site History of Rocky Flats," 10.