For the VTR scoping issues:

Environmental Impacts for this VTReactor and related projects need to include: (Details below after outline)
1) The VTR and related projects, like the HALEAU fuel rod production underway at INL, relies on HEPA filters to contain radioactive particles. I submit DOE documents on "alpha recoil" that show HEPA filters can NOT contain uranium or plutonium particles! For an honest EIS, the true amount of exposure to plutonium and uranium must be revealed.

2) I have a FOIA that is 100 days overdue requesting the updated studies of this fatal flaw of HEPA filters, done at ORNL. In order to do the FIRST honest EIS ever, we need to know how many millions of radioactive particles leave the last filter into Idaho's air, lungs, crops and water.

3) The VTR and related projects,are subject to terrorism from disgruntled employees, including the cyber hacking experts at INL.. Presently DOE has refused my scoping questions on employee terrorism, claiming it simply will not happen! This denial must stop so include the damage they could do to so many families. A lover's triangle gone bad caused the first meltdown at INL. In recent times, INL has had armed guards barricade themselves, and an employee intentionally placed a plutonium laden HEPA filter in a public trash can! They walked this serious exposure inhalation threat from their building, into the public exposure! To pretend it won't happen is hiding the realistic danger of INL projects.

4) DOE admits it's sites face daily outside cyber attacks and recently ordered updating security to TRY to stop a drone attack. Please include environmental impacts if the defense fails. and terrorists succeed. Please look at a terrorist using a crop duster loaded with explosives. We need 24 hour radar and anti-aircraft missiles ready to launch, if we want to pretend these projects are safe, not just targets for our enemies. While sites use a "safer" INTRAnet, to avoid outside hackers, this is not foolproof, as seen in 2003 at Davis-Besse plant, where the SLAMMER worm broke through there safety. Luckily caught in time but this is a true potential impact. See the drone threat at

5) Present EIS's ignore the hidden DOE documents on the seriously worse exposure to nanoparticles of plutonium and uranium. Below I present for scoping issues, the details of the bad news from NIIOSH that says the tiniest particles behave totally worse, absorb into our bodies faster, and do more damage. DOE's Dr Soderholm work is also ignored, despite me entering it in previous EIS's. Dr Soderholm shows plutonium nanoclusters are why plutonium defies present belief it will not move with water. This impact is vital to the present EIS's approving shallow burial of plutonium particles, onsite in Idaho's flood zone, over our water supply!

6) Please scope the impact of orphaned high-level waste. If forced open, Yucca Mt dump will be full to capacity from the present backlog of high level spent fuel. Sites will be stuck with this new waste VTR creates, probably forever.

7) Please scope the biological impact of inhaling the real radioactive particles leaving the sites. Specifically study the real particles, with a thousand atoms or so, not hypothetical single atoms of exposure, if inhaled.
I detail below how present EIS's, like the draft plutonium-238 production, falsely analyzed the millions of pu-238 particles that will leave the last HEPA filter into Idaho's air. The real particles have high doses from the thousand atoms or so in each particle. If inhaled, it can provide an ongoing multiple strike of alpha particles. The DOE presently pretends those dangerous particles dissolve into single atoms, so they can claim a tiny exposure, to falsely meet safety limits of public exposure. Be honest!

8) Please analyze related radioactive liquid waste ponds for the duck doses and exposure to humans they create. In our defunded CDC dose reconstruction study, ducks visited and sometimes nested on these warm ponds. A pregnant women who eats a later hunted duck, got a potential high dose of 53 mrem, with the average duck giving her fetus a 12 mrem dose, over the legal 10 mrem limit. The duck excrement actually would qualify for disposal at WIPP, but instead was crapped all over Idaho's farms, playgrounds and lakes.

9) Present EIS's only study cancer rates from exposure and deny autoimmune diseases are related to radiation exposure. Please see the declassified animal studies I include in my correction of how autoimmune diseases are excluded at For example, when beagle dogs inhaled plutonium-238, they got autoimmune Addison's Disease, not lung cancer. Please detail a response to my autoimmunity documents in your EIS, if you still believe the myopic focus on just cancer is acceptable.

10) Present EIS studies do not use correct wind re-suspension rates. They pretend the particles are heavy and hard to resuspend in the wind. The alpha recoil documents state larger particles fragment off smaller particles that easily resuspend in the wind. Adopt honest impact information.

11) I provide NRC documents on the potential disaster of Alloy-600 stress cracks in the present fleet of US reactors. This Alloy-600 was tested and APPROVED at the neutron tester this VTR is replacing, Idaho's ATR. While rapid neutron bombardment is a clever way to TRY to see the future durability, in reality, it failed. Your EIS study must examine the failures of this technology which had the potential to "break off during operations" and "would compromise the integrity of the reactor coolant system pressure boundary – one of three primary barriers that protect the public from exposure to radiation."
I share 2 NRC statements here
Generic Activities on Alloy-600 Cracking
Alloy 600 is used to fabricate various parts in nuclear power plants, including reactor vessel top head penetrations for control rod drive mechanism (CRDMs), control drive element mechanisms (CEDMs), in-core instruments (ICIs) and thermocouples, reactor vessel bottom head bottom mounted instruments (BMIs), pressurizer heater sleeves, and various other instrumentation ports.
Primary Water Stress Corrosion Cracking of Upper Reactor Vessel Head Penetration Nozzles in PWRs
Control rod drive mechanism nozzles and other vessel head penetration nozzles welded to the upper reactor vessel head are subject to another phenomenon – primary water stress corrosion cracking. The issue is a potential safety concern because a nozzle with sufficient cracking could break off during operation. This would compromise the integrity of the reactor coolant system pressure boundary – one of three primary barriers that protect the public from exposure to radiation. The break may also result in the ejection of a control rod, which could damage nearby components.

12) I sat through the DOE's Complex 21 EIS, which aims to cluster all nuclear work into one supersite (National Sacrifice Zone). The final Record Of Decision is temporarily suspended, but looms tightly related to the infrastructure of this VTR. The NEPA law requires all related projects and impacts be included in an EIS, ie, piecemealing is forbidden. Idaho's governor Andrus was in Court with his FOIA request to know the DOE's full plans for Idaho, when he passed away. Importantly, the DOE was refusing to reveal the real plans for Idaho. Andrus questioned why the Nuclear Navy was already docked in Idaho, and so do I. The VTR EIS needs to examine the impact of a terrorist strike at the cluster acknowledged in the Complex 21 goals. Compare how many million downwind families are there from a meltdown in Idaho than Savannah River Site? An Idaho meltdown exposes every state to the east of us, where a SRS meltdown might blow out to the ocean. These true impacts must be in any honest EIS.

13 The No Action alternative should clearly state if we do not use nuclear power the DOE renewable lab (RENL) says we can out power the USA with safer renewable power. RENL agrees with Stanford that documented in reality, wide spread wind power is as steady a baseload as coal, and cheaper. Financing rooftop solar offsets peak summer use and pays for itself in 7 years, probably lasting 25 years! If No Action on nuclear power there will NEVER be a meltdown and never have evacuations.of downwind states.

Below are technical scoping questions based on documents from the DOE that contradict present claims of safety. In my 30 years of documentation at official scoping hearings for deadly projects planned for INL, the issues are either ignored or their speech teams tell a different version of the buried details.
It is illegal and immoral to intentionally avoid revealing the very real Environmental Impacts
Let's start with HEPA filters' inability to contain plutonium particles they are alleged to safely filter. Below are my initial official comments on the draft EA for nuclear fuel fabrication. The EA lists plutonium-238 PRODUCTION as an upcoming plant, and lists a tiny "maximum dose" from normal operations. Indeed, I went to all the plutonium-238 production hearings for an EIS that blatantly lied about HEPA filters and pu-238 emissions. That EIS is only postponed, and obviously still planned for Idaho.
The pu-238 PRODUCTION is delayed only because of activists like me filing FOIA's to reveal how the ATR building was literally falling apart. When I walked out of the Idaho Falls pu-238 hearing 2 INL workers approached me and quietly said "Check the Daily Operations Briefs for ATR last week." I asked, "What are Daily Operation Briefs?" They just whispered "Check them" and walked away.
So I filed a FOIA for this mystery term and wow, DOB's are reports of accidents or odd things. So workers found 2 bolts on the floor. When they investigated, the bolts had fallen out of the EARTHQUAKE support beams! Oops, the speech team, like John Kotek, claimed "ATR is safe and the crown jewel of the DOE." Smiling John Kotek went on to join Cecil's lobby team at Gallatin Group, to sell nuclear projects to trusting Idahoans who don't know better.
So then, EDI from Moscow, Idaho filed a full FOIA, and found that was the tip of the iceberg able to sink Idaho. This all brought the delay, to slap on some bandaids to prop up ATR. But even a brand new facility will rely on HEPA filters, which burn in fires, oops, and simply delay the release of untold amounts of pu-238 to inhale from Idaho's air. That's not fairy dust they are sprinkling on our families. So let's get to the science.
Plutonium-238 for space batteries is 275 times more radioactively dangerous to inhale, than weapons grade plutonium-239. So while space batteries were made to sound fun and safe, the pu-238 particles that escape through HEPA filters shred the DNA of lungs 275 times faster than inhaling pu-239.
That hyper-active disintegration emitting strong alpha particles, also means it knocks itself off the production plant's HEPA filters, 275 times faster than pu-239.
All the million dollars EIS's never mention my scoping questions on "alpha recoil" or the McDowell studies from DOE Oak Ridge, that I quote and share in my comments, like below.
The comments below are in response to my Oct 31 notice from INL of this 30 day comment period. I paste the brief notice snippet for your reference.
Sincerely...Peter Rickards
The 30-day public comment period on the draft environmental assessment will conclude on November 30, 2018. Comments can be submitted by mail to David Herrin, 1955 Fremont Ave., 83415-1222 or by email to
The U.S. Department of Energy (DOE) invites the public to review and comment on a draft environmental assessment for a proposal to fabricate fuel at Idaho National Laboratory’s Materials and Fuels Complex (MFC) and/or the Idaho Nuclear Technology and Engineering Center (INTEC) to support efforts by U.S. companies to develop and deploy new reactor technologies.
---------- Forwarded message ---------
From: Peter Rickards <>
Date: Thu, Nov 1, 2018 at 12:04 PM
Subject: Federally forced abortions from nuclear fallout is an unmentioned "environmental impact" of the clustering at INL. Call for FULL Impact Statement at INL, INL's EA is incomplete & incorrect: My Initial official public comment on corrections needed to draft EA to fabricate nuclear fuel at INL, for the use of DOE-owned High Assay Low-Enriched Uranium Stored at INL
To: <>
Cc: <>, <>, <>, <>, <>

Hi DOE, INL, and David Herrin,
I just received my notice from INL, asking for public comment on the unfortunately superficial Environmental Assessmen (EA) done on the proposal to fabricate nuclear fuel for US businesses, to experiment with at INL.
I share the documentation below, but the simple version is:
The EA is incomplete and the neglected issues demand a full environmental impact statement for the plans to cluster nuclear dirty work in Idaho, listed in this EA. INL pretends a criticality from a disgruntled worker does not need analysis. Even in normal operations, the dose from hyper-active plutonium-238 (pu-238) is dismissed incorrectly. Plutonium, especially, Pu-238, knocks itself off the filters and creeps through even 4 HEPA filters in a row, into Idaho air to breath. If inhaled, just one lone particle of pu-238 exceeds the legal limit of 10 mrem, but you claim the maximum dose is 0.00000026 mrem. Hmm...
I AGAIN submit the DOE document below on HEPA filter's inability to contain plutonium-238, and the peer reviewed plutonium-238 inhalation study published in the Radiation Protection Dosimetry journal, by the National Academy of Sciences consultant, Dr Bobbi Scott, who is well published, and actually very pro-nuclear. But Dr Scott is honest about the high dose from inhaling just one, two, or three microscopic particles of plutonium-238, the space battery isotope.. Both these documents contradict this flimsy EA. Both also document and contradict the so-called full Environmental Impact Statement (EIS), done in 2000, that this EA is based on. I actually called Dr Scott to be sure I understood his important paper correctly.
These documents implore the need for an accurately documented REAL new FULL EIS to reveal ALL the REAL "environmental impacts" of the clustering of DOE dirty work here, instead of your EA Red Carpet welcome for nuclear businesses to abuse Idaho's air, water and children..
Issue 1) Your EA admits a huge criticality could occur but refuses to reveal the dose to Idahoans. While a disgruntled employee caused INL's first criticality at SL-1, you simply claim that accident criticalities won't happen because of your rules. Disgruntled workers are a real threat, as are accidents, so tell Idaho the truth about bad accidents. I attach the official dose reconstruction map of the fallout plume from the SL-1 criticality. The wind blew the deadly plume across southern Idaho, for a solid week, during an inversion layer. This would force the evacuation of large parts of Idaho, so stop lying to Idaho and analyze the criticality. Japan had a criticality at their uranium plant in recent times, with well trained workers, so don't pretend it won't happen. I paste parts of your accident analysis on web page(WP) 36/47, at the bottom of these comments for easy reference.
While you just analyze a spill, the worker dose is huge, 8.81 rem per MINUTE. The dose to a worker in another area, 100 meters away is 997 mrem. Isn't that the dose school children and citizens on your "tours" potentially receive at INL?
Question: If a pregnant women was on tour, or changing a flat tire on nearby Route 20, during an inversion layer, what would the dose to the fetus be? Don't doctors recommend zero or as little man made radiation exposure as possible for pregnant women, right? The infant mortality increase from Fukushima is like a federally forced abortion.
Why risk a nuclear criticality that can evacuate Idaho, when we can outpower the state and coutry with renewable power, according to DOE's lab?
First politicians fabricate the fantasy INL removed all the buried plutonium, when they ALL lied and left 90% buried. Now they want to fabricate fuel for nuclear businesses? Ask not what your country can do to remove the plutonium promised, ask what Idaho can do for nuclear businesses that donate to our lying politicians.

Issue 2) The EA states on WP 40/47 "There are several proposed projects at the INL Site that DOE considers reasonably foreseeable that would include radiological emissions that could contribute to cumulative impacts. Those that DOE reviewed include:
• DOE Idaho Spent Fuel Facility
• Remote-Handled LLW Disposal Facility
• Plutonium-238 Production for Radioisotope Power Systems
You calculate the MAXIMUM dose incorrectly, from this pu-238 PRODUCTION facility planned for INL., stated here:
WP 41/47 From Table 8 Estimated annual air pathway dose (mrem) from normal operations to the maximally exposed off-site individual from the above proposed projects
Plutonium-238 Production for Radioisotope Power Systems (DOE/EIS 2013) 0.00000026b
A chest x-ray is about 8 mrem. Then legal limit of INL is 10 mrem each year to citizens, and 100 mrem to workers..
The uranium plant will produce pu-238, but as usual, you dismisspu-238t as a minority element not needing analysis. Please explain the contradiction between the so-called "maximum dose" from pu-238 production listed, of the tiny 0.0000025 mrem dose INL claims, and the Dr Scott paper, that says inhaling 3 particles of pu-238 can exceed the 100 mrem ALI of DOE workers.(ALI- Annual Limit of Intake) I asked Dr Scott if he really meant 3 particles by "few" and if that meant just one pu-238 particle inhaled could exceed the citizen limit of 10 mrem. Dr Scott said I was correct in my understanding. So, how dare you repeat this BS? I have entered these science based scoping questions at all EIS' scoping hearings, for decades, always unanswered.
The alpha-emitting isotopes 238Pu, 239Pu, 240Pu and 242Pu are found at Rocky Flats. Although 238Pu is thought to be present in relatively small amounts there, intake via inhalation of only a few 238PuO2 particles could greatly exceed the ALI.
Variability in PuO2 Intake by Inhalation: Implications for Worker Protection at the US Department of Energy
B.R. Scott A.F. Fencl
Radiation Protection Dosimetry, Volume 83, Issue 3, 1 July 1999, Pages 221–232,
Published: 01 July 1999
Issue 3) All DOE calculations pretend HEPA filters are 99.97% efficient and claim 4 filters in a row even more efficient. However the McDowell studies from DOE proved "alpha recoil" allows plutonium to creep through filters, into the air we breath, way above the legal limit. Here is another DOE document on alpha recoil I pulled from the OSTI archives, and share to deaf ears & averted eyes, in these public comments.
Snippet: Operational experience at PuFF indicates that the Pu-238 contamination was observed to move along surfaces and through High Efficiency Particulate Air (HEPA) filters over time. Recent research into the phenomenon known as alpha recoil offers a potential explanation for this observed behavior. Momentum is conserved when an alpha particle is ejected from a Pu-238 atom due to radioactive decay. Consequently, the entire particle of which that Pu-238 atom is a constituent experiences a movement similar to the recoil of a gun when a bullet is ejected. Furthermore, the particle often fractures in response to Pu-238 atom disintegration (yielding an alpha particle), with a small particle fragment also being ejected in order to conserve momentum. This process results in the continuous size reduction and transport of particles containing Pu-238 atoms, thus explaining movement of contamination along surfaces and through HEPA filters.

Issue 4) The 1995 settlement agreement allows up to 200 acres of plutonium particle dumping. Your EA claims the waste will go offsite, but when it is legal and cheaper to dump onsite, that is required to be the actual destiny, dumped in Idaho. While the goal is to make new fuel rods, which will turn into high level waste, Yucca Mt is not open, but you never analyze the destiny of that waste in your dismissive EA.
This all calls for a full EIS on HEPA filters and ALL the clustering of deadly nuclear dirty work. Peter Rickards Twin Falls, Idaho

Here is your EA tiny incomplete accident section: While you just analyze a spill, the worker dose is huge, 8.81 rem per MINUTE. The dose to a worker in another area, 100 meters away is 997 mrem. Isn't that the dose school children and citizens on your "tours" potentially receive?
Question: If a pregnant women was on tour, or changing a flat tire on nearby Route 20, during an inversion layer, what would the dose to the fetus be?.
WP 36/47 Accident types considered included thermal stress of fire on 50 kg uranium solids, spill or free-fall drop of molten metal, and accidents resulting in solid ingot free-fall drop or impact (ECAR-4310). The potential for nuclear criticality exists due to the quantity and form of material being processed. However, engineered and administrative controls would be incorporated into the facility and process operations to prevent and mitigate worker risk associated with this hazard.
... The handbook further states that release fractions for disturbed molten metal surface under dynamic conditions such as a spill or free-fall drop are higher than that for pieces or powder under thermal stress (fire). Therefore, the bounding and most severe postulated accident for the proposed action is a spill or free-fall drop of molten uranium during material processing. This accident could occur from an initiating event such as natural phenomena occurrence (i.e. severe seismic event), operator error, or from unspecified facility structural failures.
WP 38/47 Table 7 Summary of dose impacts for the highest consequence events for Alternative 1.
Facility Worker(1,700 m3 building) 8.81 (rem/min)b
Collocated Worker (100 m downwind) 997(mrem)c Peter: This would also be the dose to innocent schoolchildren and citizens taking a tour of INL that day.
Offsite Member of the Public (5,000 m downwind) 29.4E(mrem)c
Offsite Member of the Public (14,000 m downwind) 9.10(mrem)c


Here are the DOE documents on alpha recoil problems, as I sent to the deaf ears of the so-called Inspector Generals and media intro (NIOSH & Dr Soderholm at the end. Dr Scott is repeated but left in for context)

I use hidden DOE documents to show plutonium knocks itself off and through even 6 HEPA filters in a row. That is NOT supposed to happen!
Read to the end, and 2017 NIOSH says the nanoparticles are MUCH worse and the animal studies are bad news.
Nuclear power is not the answer blowing in the wind. That's plutonium blowing in the wind. Trump is teaming with Sen Booker to fast track nuclear energy.
Please consider reporting this fatal flaw and backing my call for a full EIS on HEPA filters inability to contain plutonium. This "alpha recoil" problem effects all nuclear power and weapons facilities, like Savannah River and Oak Ridge. I use obscured DOE documents to show DOE is lying on present Air Permits and EIS's, claiming fantastic filtering efficiencies.
While the below documents prove DOE is lying on state Air Permits, there are 4 newer studies at Oak Ridge on alpha recoil still hidden. I filed a FOIA on April 11th. Now 50 days later and overdue, the FOIA officer balked and re-asked what info I wanted!
Our Idaho politicians and media sold out Idaho long ago, but if you help pull this thread, it can unravel all the wool pulled over America's eyes.
The clustering of 10 or more private nuclear power plants is underway in Idaho. Renewables are ready to power the country, if we can delay this disaster.
Here is what I sent both DOE & NRC IG's but foxes guarding hen houses tend to silently keep their job,...Peter Rickards

Below is what you submitted to the NRC Office of the Inspector General on Friday, April 05, 2019 at 06:57:13
Complaint: Dear Inspector General, I was trying to get this information to the DNFSB, concerning the INL and all DOE sites. Can you please forward it to them before their May public meeting on the April 2018 accident? I would also like you to address this serious threat to public safety & workers, too. The issue is on the safety threat of alpha recoil and the inability of HEPA filters to contain plutonium, especially pu-238, that we work with in Idaho, and other sites. Thank you, Dr Peter Rickards, Twin Falls. Here is the documentation:
To the DNFSB,
I see you are investigating the April 2018 accident at INL, where 4 tru waste containers unexpectedly blew their lids, with an upcoming public meeting in May.
I am a retired podiatrist in Twin Falls, Idaho, who has worked 30 years on nuclear issues here. I was on the CDC Citizen Advisory Panel and collected many problematic documents over the years, including HEPA filter flaws.
I am asking DNFSB to please address the issues below, to see if the State Air Permit's limit for public exposure has been violated by this accident, by the 2011 ZPPR plutonium accident, and actually by normal operations for current and proposed projects at INL and all DOE sites, like Savannah River Site. This seems well within your Mission Statement goal of "protection of public health and safety", as well as protecting workers.
The main problem is HEPA filters inability to contain alpha emitters, like plutonium 239, and especially hyperactive pu-238. According to obscured DOE documents, the phenomena called "alpha recoil" is "similar to the recoil of a gun" and knocks plutonium off filters, back into the exiting air stream, through even 6 filters in a row!.This makes the important amount of pu-238 particles leaving the building, from the last filter, a factually unknown amount. This is not honest science, especially when Idaho is about to cluster nuclear work here, producing fuel rods and producing plutonium-238.
I will document below how the DOE covers up that fatal flaw, in the EIS for plutonium-238 production planned for Idaho, and how that relates to the many accidents at INL, as well as normal operations at every site.
The secondary problem that needs DNFSB's public scrutiny and documentation, is what is the actual dose to the public and workers, from the millions of actual pu-238 particles that leave the last filter, into Idaho's air.
The EIS for pu-238 production claims, using the present analysis methods, that normal operations filtering is so darn efficient the maximum public dose would be 0.00000026 mrem, well below the 10 mrem public limit. I will document below how inaccurate this dose estimate appears, citing a peer reviewed paper on Rocky Flats workers, from Radiation Protection Dosimetry, which reveals a much higher dose.
I am asking DNFSB to check when, or if, INL changes the HEPA filters on the buildings for this accident, and the 2011 ZPPR plutonium accident. If not exchanged for new filters, it is possible that INL is still emitting plutonium-238 & pu-238.
All DOE calculations claim HEPA filters are 99.97% efficient and claim 4 filters in a row even magnitudes more efficient. However, the McDowell studies from DOE proved "alpha recoil" allows plutonium to creep through 4 filters, into the air we breath. Here is another DOE document on alpha recoil I pulled from the OSTI archives, and share to deaf DOE ears & averted eyes, at official scoping hearing for new plutonium-238 production plans' EIS..
Snippet: Operational experience at PuFF indicates that the Pu-238 contamination was observed to move along surfaces and through High Efficiency Particulate Air (HEPA) filters over time. Recent research into the phenomenon known as alpha recoil offers a potential explanation for this observed behavior. Momentum is conserved when an alpha particle is ejected from a Pu-238 atom due to radioactive decay. Consequently, the entire particle of which that Pu-238 atom is a constituent experiences a movement similar to the recoil of a gun when a bullet is ejected. Furthermore, the particle often fractures in response to Pu-238 atom disintegration (yielding an alpha particle), with a small particle fragment also being ejected in order to conserve momentum. This process results in the continuous size reduction and transport of particles containing Pu-238 atoms, thus explaining movement of contamination along surfaces and through HEPA filters.

Here is the url I found for a 2005 paper on alpha recoil from Oak Ridge Natl Lab that is beyond alarming, but never addressed in any EIS.
I paste key quotes with the web page to verify them:
web page 9/27
These studies have been motivated by concerns about the containment of radioactive material and the increased potential for uptake of material by humans.
Webpage 12/27
Fleischer (1975), and Fleischer and Raabe (1977) examined the solubility of PuO2 in simulated lung fluid. Here solubility refers to the “conversion of plutonium in the extremely insoluble particles of PuO2 to more dispersed forms.” These authors observed that 238PuO2 dissolves at a rate that is about 200 times faster than 239PuO2, which has a much lower specific activity (17 Ci/g for 238Pu versus 0.062 Ci/g for 239Pu)
webpage 13/27
Clinard and Rohr (1981) studied fragmentation of PuO2 from the perspective of the potential for the release and leaching of plutonium from waste forms. They observed that 238PuO2 undergoes spontaneous fragmentation and that the relatively short-lived 238PuO2 is more prone to fragmentation than is 239PuO2. For their experiments, Clinard and Rohr prepared samples by hot pressing at 1530°C and then firing in an oxidizing atmosphere at 1440°C. They measured the fragmentation rate of 238Pu samples, which was defined as the rate at which −420 mesh (<34-µm) fines were produced. From the data presented, this rate is about 0.001%/day. Fragmentation was found to continue into submicroscopic particles (i.e., 10-µm particles continued to break up). Clinard and Rohr determined by calculation that thermal stresses were not responsible for the fragmentation. They concluded that lattice damage by recoil nuclei and alpha particles, as well as radiolytic effects (e.g., the production of species that attack the lattice) may play a role in fragmentation.
15/27 Peter: This seems to actually calculate how fast it leaves the filter and say 5% to 0.1% by weight of pu-238 is released PER MONTH. It was 0.02% for pu-239 via Table 1. Back to the paper quotes:
The recoil energy resulting from alpha decay is sufficient to resuspend nanometer-sized particles from a filter fiber. Particles with densities of 10 g/cm3 and up to 20 nm in diameter can be dislodged. While alpha-recoil energy is not sufficient to resuspend micron or submicron particles, fragmentation can lead to the production of even smaller particles that can be resuspended. Bierman, da Roza, and Chang (1991) provide a formulation for the mass percentage release per unit time (M %) that results from alpha recoil:
17/27 Peter: WOW pu-238 is reported as "lifelike" that can "walk" and "flys'! This is key when a later 2011 denial paper later only looks at pu-239, NOT pu-238, and only certain sizes. Back to quotes:
Congdon (1996) described significant evidence of high 238Pu mobility. The number of contamination incidents involving 238Pu was 3.5 times those for 239Pu. However, more than 100 times the quantity of 239Pu was processed. The incident rate is close to the ratio of the specific activities and the amount of material processed [i.e., (17 Ci/g) × 1 g /(0.062 Ci/g) × 100 g = 2.7]. Clearly, the 238Pu was more difficult to control and contain than the 239Pu. Personnel involved with processing 238Pu indicated that it had “lifelike” characteristics, as the fines appeared to “fly” through the air or “walk” along pipes. Congdon states that “in some cases, the fine particles appear to behave more like a gas than a solid.” Additionally, “alpha decay and heat cause numerous failures of 35 mil thick rubber gloves,” even in a matter of days. When 238Pu particles got outside of containment, they sometimes traveled for hundreds of feet, rather than directly settling. According to Congdon, “other types of radioactive materials do not appear to be nearly as mobile as 238Pu and are usually spread by physically spreading the material from one surface to another.” Such surfaces were difficult to decontaminate. Fine particles of 238Pu were easily dispersed (resuspended) into the air, and previously decontaminated surfaces were found to be recontaminated after several hours or days. Because of self-heating, 238Pu oxide does not tend to absorb water. Furthermore, 238Pu tends to remain as individual particles rather than forming agglomerates. (Note that one cause of agglomeration would be adsorption of water, thereby causing the particles to stick together.) Additionally, alpha emissions and the concomitant recoil may act to break up agglomerates. Such small particles are then easily dispersed, especially since the dry 238Pu particles do not adhere to surfaces. A recent assessment of the contamination problem and the mobility of 238Pu particles is also provided by Reichel (2004).
19/27 Peter: This says Oak Ridge has studies planned. The ORNL website list 4 alpha recoil papers but denies me access as unauthorized! Will DNFSB please demand them (and share so I can critique for flaws). I have to guess that IF the forbidden reports had found fantastic efficiency, they would have shared and bragged... But Quotes and their conclusion:
To further quantify the movement and dispersion of initial deposits of high-specific-activity alpha materials, experiments have been designed at ORNL to measure such movement.
Alpha decay can result in the fragmentation of particles into smaller respirable fractions. Additionally, recoil nuclei can cause the movement or resuspension of radioactive material. Such movement must be considered when modeling the release of such material. Studies, especially with filtration media, have shown that the effects of aggregate recoil transport should be considered in response to and cleanup of release events. Aggregate recoil increases the penetration of filtration media, thereby lowering its effectiveness.

This brings us to the issue of calculating the dose to the public, the workers even with HEPA masks, the dose to other onsite workers. Please remember school kids and pregnant women are taken on tours of the site, and they are even more sensitive to radiation exposure, from the particles emitting from HEPA filters. Rt 20 also runs right by the site, possibly with women truck drivers on daily routes, possibly pregnant.
From the above paper, is also contradicting problems on the wind resuspension rates usually used in dose calculations.of leaked particles. I would need to double check, but memory says a rate of 1 in 1,000,000 is used for windy days, since pu is known as a heavy metal. This does not incorporate the ability of pu, especially pu-238, to fragment into smaller particles, which easily move with wind. Here is the quote::
Johnston et al. (1993) studied the resuspension of plutonium and americium particles in an Australian desert. They quantified the resuspension in terms of a “resuspension factor,” which is defined as the airborne activity concentration divided by the surface activity density (i.e., activity per unit area). The studies were performed over a 1-year period, and an average resuspension factor of 4 × 10−10 m−1 was measured. The resuspension can increase by up to 3 orders of magnitude for winds greater than 10 m/s. The authors did not assess the effects of alpha recoil on resuspension. However, they do assume that only particles less than 75 µm can be resuspended. Therefore, fragmentation by alpha recoil can increase the amount of material available for resuspension.
The DOE speech teams claim inhaling plutonium is less of a dose than eating a banana. I understand natural potassium-40 decay has a high energy, but it seems the less pu one inhales, the less chance the repair mechanism has of malfunctioning. The CDC doctors told me, "Sure, the alpha particle is more destructive to lung tissue than gamma. But it kills the cells, and dead cells don't cause cancer". That did not make me breath easier so I looked further for the science.
What I found was a peer reviewed paper from the very pro-nuclear Dr's Scott below. He analyzed inhalation of PuO2 by Rocky Flats workers and reported the minority pu-238 gave the majority dose, and a much higher dose than what the DOE pu-238 EIS claims.
Dr Scott consults for the NAS and is even published on hormesis. I called Dr Scott to confirm I understood his papers' wording. Indeed, he looked at the dose when actual particles were inhaled and agreed he meant just 3 particles of pu-238 would exceed the workers 100 mrem limit. Dr Scott agreed that just one lone pu-238 particle would exceed the publics 10 mrem limit, with about a 30 mrem dose. Here is the key quote and source:
The alpha-emitting isotopes 238Pu, 239Pu, 240Pu and 242Pu are found at Rocky Flats. Although 238Pu is thought to be present in relatively small amounts there, intake via inhalation of only a few 238PuO2 particles could greatly exceed the ALI.
Variability in PuO2 Intake by Inhalation: Implications for Worker Protection at the US Department of Energy
B.R. Scott A.F. Fencl
Radiation Protection Dosimetry, Volume 83, Issue 3, 1 July 1999, Pages 221–232,
Published: 01 July 1999
So how can the DOE claim the maximum dose to the public from normal pu-238 production, or any effluent, is a tiny 0.00000026 mrem, when Dr Scott finds one lone particle would be about 30 mrem?
The DOE impact statements appear to unrealistically break their analysis into single ATOMS of pu-238, while Dr Scott models actual Rocky Flats particles, with thousands of atoms.
These pu fragments are the exact fragmenting particles dumped at INL, that were involved in the April 2018 accident.
They are not single atoms, with mathematically no consequences. Pu-238 particles in your lungs are perpetual points of direct DNA damage, that shred DNA 275 times faster than pu-239. That is extra important for pu-238 production, where it is the main element.
DOE admits in the EIS that about 0.00000000001% release through the 4th filter. DOE then takes that total weight and divides it into single atoms, like radon gas is. DOE actually then spreads that release amount around the 50 mile circle required, divides by the population, then divides by the chances it will fall elsewhere than a human, then divides by the chance you will exhale it, if comes into your airspace! This ignores the reality of the actual multi-atom pu-238 particles that resuspend every windy day in windy Idaho!
So this leaves DNFSB with the questions:
1) "Even though pu-238 is a minority element", how fast dose it REALLY move through HEPA filters at the 2 INL accidents?
2) How often does INL change filters? Are the same filters at the ZPPR building, still emitting pu-238 & 239 from the 2011 ZPPR accident? Since pu-238 has an hourly progression through HEPA filters, have those filters from the April 2018 barrels already released hundreds or thousands of multi-atom pu-238 particles?
So the DOE impact statements ignore the particle size problem, despite me raising the issues at every EIS scoping hearing since 1988. Like the FL Horn experiment, from DOE's PNL, available on microfiche,and I have a paper copy, it is so old. INL gave me the paper to prove particles were so big and chunky, the filters worked great. They claim 0.3 um are the hardest to filter, and smaller ones are supposedly filtered better than the 99.97% of the 0.3 um. I was amazed when I read the paper because it said the opposite. Dr Horn tried to imitate a criticality in a closed, windless chamber. Most the particles actually were under 0.3 um and were actually SO light, they were floating on the Brownian Motion of the air molecules days later, in this windless chamber!
In searching for obscured updates, I located a 2011 ORNL HEPA experiment with interesting but questionable information at
Direct Determination of Ultra-trace Plutonium Nanoparticles in Downstream of a Six-Stage HEPA Filter by Inductively-Coupled-Plasma Mass Spectrometry: A Field Application
Through on-line monitoring of particle number concentration above 10 nm by CPC and off-line monitoring of 239Pu activity concentration by 242Pu ID-ICP-MS, it is confirmed that HEPA filter works properly during field operation. Direct introduction and rapid determination of ultra-trace plutonium aerosol in downstream of the HEPA filter have been conducted using ELEMENT ICP-MS and Nu MC-ICP-MS. The results show that the DLs of ELEMENT and Nu for plutonium are 5.0 × 10−3 Bq/m3 and 5.5 × 10−4 Bq/m3, respectively. Concentrations in the filtered gas are of the order of 10−2 Bq/m3 while the blank value is 5.7 × 10−3 Bq/m3. Some plutonium nanoparticles have penetrated the six-stage HEPA filter and the plutonium concentrations after filtration are nearly stable at different sampling periods. These phenomena could not be observed by traditional on-line and off-line monitoring methods. The size of penetrated plutonium nanoparticles was investigated with single particle detection method using ELEMENT. Preliminary results indicate that the plutonium nanoparticle would be below 10 nm assuming the form of 239PuO2.
The red flag to me is this was done for only one week and only used slow pu-239 & 242! This seems typical of what I call Intentional Tunnel-Vision. When they KNOW pu-238 "flys" through the filters, why avoid the KNOWN Beast Of Another Nature, pu-238?
Why only test for one week, when filters are sometimes left for decades, not changed weekly? Then, when they are surprised by the pu nano particles escaping from the (never implemented in real life) 6th filter, they dare declare they successfully "confirmed that HEPA filter works properly during field operation."!
NO, it did NOT confirm the the filters worked at the expected efficiency in normal field use. It actually confirmed the DOE has no idea how many millions of pu- 238 or 239 is being released, nor resuspended in wind. That is not Fairy Dust nor banana powder they are sprinkling on our families.
So let me share NIOSH 's view of how nano particles are are greater problem , weight for weight.
This is a quote from NIOSH but I found it on the Canadian Health Dept url at
Do nanoparticles behave the same way as regular sized particles?
Nanoparticles are those particles that range in size from 1 to 100 nanometres (nm). As stated by NIOSH (the National Institute for Occupational Safety and Health):

At this size, materials begin to exhibit unique properties that affect physical, chemical, and biological behavior. ... Studies have indicated that low solubility nanoparticles are more toxic than larger particles on a mass for mass basis. There are strong indications that particle surface area and surface chemistry are responsible for observed responses in cell cultures and animals. Studies suggests that some nanoparticles can move from the respiratory system to other organs. Research is continuing to understand how these unique properties may lead to specific health effects.


Nanomaterials that can be inhaled, ingested or can penetrate skin indicate a potential for exposure and present the possibility of potential health effects. Processes that lead to airborne nanometer-diameter particles, respirable nanostructured particles (typically smaller than 4 micrometers) and respirable droplets of nanomaterial suspensions, solutions and slurries are of particular concern for potential inhalation exposures.


Results from experimental animal studies with engineered nanomaterials have provided evidence that some nanoparticle exposures can result in serious health effects involving pulmonary and cardiovascular systems and possibly other organ systems.

From: NIOSH (2017) Nanotechnology

I will share the DOE's awesome Dr Soderholm's work on plutonium nanoclusters discovery, on why pu moves easily with water, defying the expectation it will bind to clay and never move. This adds to the discovery of mobile plutonium colloids by DOE's Dr Kersting. Dr Kersting found plutonium had already migrated one mile, in the Nevada sluggish slow aquifer, like we have here in Idaho, under the dumped Rocky Flats waste, in a flood zone that feeds southern Idaho's aquifer.
Here is the abstract for Dr Soderholm:
Scientists discover how the structure of plutonium nanocluster contaminants increases risk of spreading
ARGONNE, Ill. — For almost half a century, scientists have struggled with plutonium contamination spreading further in groundwater than expected, increasing the risk of sickness in humans and animals.
.It was known nanometer-sized clusters of plutonium oxide were the culprit, but no one had been able to study its structure or find a way to separate it from the groundwater.
Scientists at the U.S. Department of Energy’s Argonne National Laboratory, in collaboration with researchers from the University of Notre Dame, were able to use high-energy X-rays from the Advanced Photon Source (APS) at Argonne to finally discover and study the structure of plutonium nanoclusters.
When plutonium forms into the clusters, its chemistry is completely different, and no one has really been able to assess what it is, how to model it or how to separate it,” said Argonne senior chemist Lynda Soderholm. “People have known about and tried to understand the nanoclusters, but it was the modern analytical techniques and the APS that allowed us understand what it is.”

In conclusion, I hope DNFSB will flush out these issues. Please consider joining my call for a full EIS on HEPA filters, especially their inability to actually contain plutonium. It is important information that should have been revealed long ago.
Sincerely...Peter Rickards, Twin Falls, Idaho