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S n~ <br />~~ • ~IIIII~II~I~~~~~~I~ • <br />999 ,}\~ ~~~ ~~ <br />To: Rob Helmick Boulder County Staff Planner <br />Re: SU-93-24: DOWE Flats Mining & Reclamation Project VIII 2 11983 <br />Fr: C1'iff Myers, Boulder County Health Department '~'4~-D (SSE <br />DEpT. <br />Dt: Jul 23, 1993 <br />My review of this proposal for the Boulder County Health <br />Department (BCHD) focuses on the Environmental Impacts of <br />Radiation, Air Quality, and Reclamation. (Referral # 1) <br />Radiation: Overview: The Southwestern Portland Cement Plant <br />in Lyons, Colorado was one of 15 cement plants that voluntarily <br />participated in a USEPA study of cement kiln dust (CKD). Samples of <br />CKD and clinker were collected and analyzed. Minute quantities of <br />plutonium 238 were found in these samples. The measured <br />concentrations were below conservative risk screening criteria and <br />are believed to be too insignificant to cause public health <br />concerns. However, the fact that plutonium 238 was detected raised <br />questions about the source of contamination. <br />On December 31, 1992 this Department met with the Colorado <br />Department of Health, Environmental Protection Agency and <br />Southwestern Portland Cement for interpretation of the E.P.A study <br />and to solicit guidance in following up on the initial EPA results. <br />A number of issues were discussed at that time. In regard to the <br />samples that were collected, the E.P.A was currently evaluating the <br />data. This evaluation took place at E.P.A. laboratories located in <br />Montgomery Alabama. U.S.E.P.A Region 8 requested the entire data <br />composite which would provide insight as to how the decision was <br />made that plutonium 238 was above Non-detectable levels. There was <br />the possibility that the plutonium detected wasn't a real number as <br />an error in the measurement techniques could make the levels found <br />in the dust Non-detectable. Additionally, plutonium -238 activity <br />could have been mistaken for one or more of the natural alpha <br />emitters found in coal burned at the cement plant. The presence of <br />these isotopes in coal is documented in scientific literature. <br />Of the 15 cement kilns tested, low levels of plutonium 238 <br />were found in the dust from two other kilns, one in South Carolina <br />and one in New Mexico. Like the Lyons plant, those kilns are near <br />DOE nuclear facilities. BCHD was informed that these three kilns <br />were the only kilns that were sampled for the presence of <br />radionuclides. If only these facilities were sampled for <br />radionuclides the validity of this sampling event was questionable. <br />On January 22, 1993 BCHD requested that the EPA resample <br />Southwestern Portland and the surrounding area and submit the <br />samples to at least two independent and certified laboratories for <br />analysis. <br />