in Discharge from Lowry Landfill That Would Impact Recycled Water

Response to Allegations Regarding Possible Radioactivity

in Discharge from Lowry Landfill That Would Impact Recycled Water

Updated 11/17/03

Recently, the Board has heard allegations that recycled water might be unsafe. The theory behind the allegations appears to be that Lowry Landfill received radioactive waste, that the groundwater collected at Lowry and treated at Metro is radioactive, that effluent leaving the Metro plant is radioactive, and that our recycled water will be radioactive as a result.

Complaints based on these same allegations were raised to the proper authorities several years ago and were disproved at various times, most conclusively last December. Nevertheless, the allegations persist.

Documents from the U. S. Environmental Protection Agency dated December 2002 explain why EPA has determined not to proceed any further with a plan for additional monitoring of radionuclides in Lowry discharges to Metro. Max Dodson, EPA Assistant Regional Administrator, stated, “The current groundwater monitoring data simply does not support the need to go forward with the plan at this time.”

Here are a brief history and highlights gleaned from an EPA technical report dated December 5, 2002 , and Max Dodson’s decision letter dated December 13, 2002 .

From 1985-1993 EPA and responsible parties studied Lowry Landfill to characterize the contamination at the site.
In 1991, a consultant at the site issued a report of levels of americium and plutonium at Lowry that were higher than at Rocky Flats.
In 1992, the same consultant issued another report after most of the samples were re-analyzed. “There was NO CASE in which the presence of transuranics was positively confirmed.”
In 1994, EPA issued its Record of Decision (ROD) on Lowry Landfill, requiring containment and treatment of groundwater on site. Despite the poor quality of the 1991 data, EPA used the data in its risk assessment. The risk assessment concluded that the total risk from naturally-occurring and transuranic radionuclides at Lowry was less than the risk from estimated national background exposure.
In 1996 the Colorado Citizen Action Network (CCAN), Stop the Sludge Campaign – expressed concern that plutonium from Rocky Flats had been disposed of at Lowry.
In 1997, EPA amended the ROD to allow pretreatment of groundwater at Lowry, followed by conveyance to Metro for further treatment. The pretreatment permit requires that the discharge at Lowry be sampled twice a month for plutonium, americium, gross alpha and gross beta. In over 400 samples from March 2000 to December 2001, there was only one exceedance for gross alpha and gross beta (none for plutonium and americium), and those exceedances were not repeated. “The preponderance of the data suggests that there is no plutonium or americium in the discharge to Metro that would render a risk to the worker.”
The 1997 amendment of the ROD “created a surge of concern” from the CCAN, leading to a two-year audit by EPA’s Inspector General.
CCAN alleged that high levels of radionuclides were present at Lowry; groundwater contaminated with plutonium would be pumped to Metro; and EPA Region 8 and others had conspired to cover-up radionuclides at Lowry.
In 2000, the Inspector General issued a formal report, which “found no apparent credible evidence that any of these conditions existed.”
In addition to monitoring the discharge from Lowry to Metro, EPA has early warning wells at Lowry located upstream of the groundwater collection point, which monitor water quality six months prior to collection. In samples collected once a quarter, none showed problems.
The wells that the 1991 consultant reported being radioactive were resampled (in 2001 or 2002). “All render results of americium and plutonium near zero activity.”

“In conclusion, [EPA has] found no evidence to support the need to launch an intensive study to determine the level of man-made radionuclides off-site as there is no current risk from the levels of activity detected on-site and within the discharge waters.”

THEREFORE - There’s no risk from the groundwater before pretreatment at Lowry itself; there’s no risk in the water being discharged to Metro after pretreatment; there’s no risk in the much diluted effluent being discharged from Metro into the Platte River ; and there will be no risk from effluent diverted and treated at the recycle plant.