Dear Dr. Conway:

In the recent past as well as at present plutonium and plutonium-bearing materials on site at Rocky Flats have been prepared for shipment to and storage at the Savannah River Site or for shipment to and disposal at the Waste Isolation Pilot Plant (WIPP).

Recent research regarding the oxidation states of plutonium shows that plutonium oxide is less stable than formerly believed. Plutonium oxide may advance to a higher oxidation state in which a significant portion becomes soluble and therefore more readily mobile in the environment. Moreover, as the material undergoes continued oxidation, a higher-than-previously-expected level of hydrogen gas generation occurs, with a resultant greater potential for rupture of containment vessels (see John M. Haschke et al, "Reaction of Plutonium Dioxide with Water: Formation and Properties of PuO2+x," Science, vol. 287, 14 January 2000, pp. 285-287). This research has implications for plutonium in transport, in storage, and in disposal cells.

We call on the Defense Nuclear Facilities Safety Board (DNFSB) to determine whether current and past plutonium preparation operations at Rocky Flats ensure that plutonium or plutonium-bearing material intended for transport, storage, or disposal is sufficiently free of moisture or other oxidizing agents to guarantee non-generation of hydrogen gas while the material is in transit or in storage or disposal.

As an example of the sort of problem that may exist, we note that according to the DNFSB Savannah River Site (SRS) report of May 21, 1999, shipments of plutonium-bearing residues from Rocky Flats to SRS were halted because of problems with the 9975 shipping containers and because hydrogen-generation rates were high enough to lead to "a postulated detonation scenario." How are these problems identified by DNFSB last May related to the new findings reported in the aforementioned Science article? The DNFSB report suggested that the problems then identified might be solved by sending the residues not to SRS but to WIPP. What are the implications for putting such material on the road and in the disposal cells at WIPP? Does this really solve the problem? What decision was finally made in response to this DNFSB suggestion?

If DNFSB finds that hydrogen gas production may result from past or present operations at Rocky Flats, what corrective action does DNFSB recommend for material already transported or to be transported? Would any corrective measures proposed by DNFSB pose adverse health risks to either the workforce or the nearby public at Rocky Flats, SRS, WIPP, or along transport routes? If so, what measures will be taken to provide maximum protection to affected persons?

Thank you very much for considering our request. We would appreciate receiving a response at the earliest possible date. Please provide a detailed report of any analyses DNFSB may conduct or may have already conducted in response to the questions here raised. Address communications to LeRoy Moore, P. O. Box 1156, Boulder, CO 80306; phone 303-444-6981; fax 303-444-6523; leroymoore@earthlink.net. Yours sincerely,

LeRoy Moore, Ph.D.
Rocky Mountain Peace and Justice Center
P.O. Box 1156
Boulder, CO 80306

Harry Rogers
Carolina Peace Resource Center
305 S. Salvda Ave.
Columbia, SC 29205

Mary Terrell
Atlanta Chapter, Women's Action for New Directions
464 Cherokee Ave., SE
Atlanta, GA 30312

Adele Kushner
Action for a Clean Environment
319 Wynn Lake Circle
Alto, GA 30510

Sara Barczak
Campaign for a Prosperous Georgia
3025 Bull Street, Suite 101v Savannah, GA 31405

Lewis E. Patrie, M.D., M.P.H.
Western North Carolina Chapter, Physicians for Social Responsibility
99 Eastmoor Drive
Asheville, NC 28805

David L. Swain
Haywood County Peace Fellowship
P.O. Box 914
Lake Junaluska, NC 28745

Don Hancock
Southwest Research and Information Center
P.O. Box 4524
Albuquerque, NMm 87106

Jay Coghlan
Nuclear Watch of New Mexico
712 Camino Militar
Santa Fe, NM87501

Joni Arends
Concerned Citizens for Nuclear Safety
107 Cienega St.
Santa Fe, NM 87501

Greg Mello
Los Alamos Study Group
212 East Marcy St.
Santa Fe, NM 87501

Don Moniak
Serious Texans Against Nuclear Dumping
7105 W. 34th Ave., Suite E
Amarillo, TX 79109

Peggy Prince
Peace Action New Mexico
227 Fiesta Street
Santa Fe, NM 87501

Pat Ortmeyer
WAND Field Director for Nuclear Waste Issues
2350 Harve Ave.
Missoula, MT 59801

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