Could Building the Jefferson Parkway Disturb Rocky Flats Contamination?

Randy Stafford’s 2018 position paper brought decades of Rocky Flats soil and health research into the debate over construction along Indiana Street.
In May 2018, Randy Stafford, then a member of the Jefferson Parkway Advisory Committee (JPAC), submitted a detailed position paper examining a question that has remained important in discussions surrounding Rocky Flats: What could happen if construction disturbs soil in areas historically contaminated by releases from the Rocky Flats nuclear weapons plant?
Stafford’s 26-page paper, The Public Health Risk of Disturbing the Soil Along Indiana Street for Jefferson Parkway Construction, was prepared for consideration by fellow JPAC members as the committee began discussing the issue.
Stafford stated that his conclusions followed approximately a year of research into off-site soil contamination and possible health effects among people living downwind of Rocky Flats. His research included historical studies and records obtained through archives, Freedom of Information Act requests, federal records, and court files from Church v. United States and Cook v. Rockwell.
Decades of Soil Studies
A major portion of Stafford’s paper brings together historical studies of plutonium contamination outside the former Rocky Flats plant. Stafford reviewed studies and sampling work spanning several decades, including research associated with Edward Martell, P.W. Krey and E.P. Hardy, the Seed Report, Carl Johnson, Illsley and Hume, Ward Whicker and colleagues, Iggy Litaor, citizen environmental sampling, Marco Kaltofen, and CDPHE.
His central argument was that these separate investigations repeatedly documented elevated plutonium concentrations in soil along or near the Indiana Street corridor east of Rocky Flats.
The maps Stafford compiled make that history particularly visible. His Figure 1, for example, places sampling results from multiple studies on a single map of the Indiana Street corridor. Later figures reproduce the historic Krey-Hardy contamination contours and other sampling maps. Stafford argued that this history mattered because plutonium-239 has a half-life of approximately 24,100 years. In his view, the question was therefore not simply what was released decades ago, but what contaminated soil might still be present and what could happen if that soil were disturbed.
The Health Evidence Is More Complicated
Stafford also devoted a substantial section of the paper to studies of cancer incidence and other health evidence involving communities around Rocky Flats. He discussed Carl Johnson’s 1981 epidemiological study, Stephen Chinn’s analysis, a later study led by Kenny Crump, Richard Clapp’s work, and cancer-incidence studies conducted by the Colorado Department of Public Health and Environment. Importantly, these studies did not all reach the same conclusions.
Stafford emphasized studies that reported increased cancer incidence nearer or downwind of Rocky Flats and criticized methodological choices in studies that did not find an overall increase. The CDPHE studies he discusses, however, reported that for the geographic areas and cancers they examined, overall cancer incidence was not higher than expected compared with the remainder of the Denver metropolitan area. Stafford then presented his own critique of those studies' geographic design, cancer categories and other methodological choices.
The Rocky Flats Downwinders Health Survey
Stafford also discussed the community health survey conducted through Metropolitan State University in collaboration with Rocky Flats Downwinders. At the time of his paper, preliminary survey results included 848 reported cancer cases, 414 of which had been categorized as rare cancers. Stafford included maps plotting survey respondents who reported cancer against historical Rocky Flats contamination and plume information.
Those maps are visually striking, but the survey was not an epidemiological study and cannot establish that Rocky Flats caused an individual's cancer. Stafford himself described the survey as evidence supporting the need for additional epidemiological research.
That remains an important distinction for Rocky Flats Downwinders: community reports can identify questions and patterns worthy of investigation without, by themselves, establishing causation.
Why Stafford Was Concerned About Construction
The central issue for Stafford was not simply that historical contamination existed. It was the possibility of resuspending contaminated soil as airborne dust during construction.
He cited the federal Agency for Toxic Substances and Disease Registry's toxicological profile for plutonium and historical Rocky Flats research in discussing inhalation as an important exposure pathway.
Stafford argued that excavation, grading, heavy equipment and wind could put contaminated soil particles into the air. To illustrate the issue, the paper includes a photograph of visible dust generated during highway construction on C-470 on a windy April day in 2018.
For Stafford, that raised a straightforward public-health question: Before disturbing historically contaminated soil, how thoroughly should the contamination and potential exposure pathways be understood?
What Stafford Recommended
Stafford concluded by recommending several steps before construction proceeded. Among them were an independent review of previous contamination and health studies, new testing of soil that could be disturbed, a more comprehensive review of historical contamination records, consideration of an alternate highway alignment, and—if construction proceeded along Indiana Street—strong measures to control dust and limit construction during windy conditions.
Why This Paper Matters
Stafford’s paper is valuable as a historical document because it pulls together many different strands of the Rocky Flats story in one place: decades of soil sampling, historical contamination maps, epidemiological studies, government reports, litigation records, community health concerns and questions about what happens when contaminated land is disturbed. It also captures a recurring issue surrounding Rocky Flats. The plant closed decades ago, but decisions about land use, construction, development and soil disturbance continue to raise questions about how Rocky Flats' environmental history should inform decisions being made today. For Rocky Flats Downwinders, that is one reason the story didn't end when the plant closed.
Read the Original Paper
Randy Stafford — The Public Health Risk of Disturbing the Soil Along Indiana Street for Jefferson Parkway Construction
Jefferson Parkway Advisory Committee, May 17, 2018
View the full 26-page position paper →
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