09/01/2026
𝗦𝗧𝗔𝗧𝗘𝗠𝗘𝗡𝗧 𝗜𝗡 𝗦𝗨𝗣𝗣𝗢𝗥𝗧 𝗢𝗙 𝗩𝗘𝗧𝗘𝗥𝗔𝗡𝗦 𝗪𝗛𝗢 𝗦𝗘𝗥𝗩𝗘𝗗 𝗔𝗧 𝗧𝗢𝗡𝗢𝗣𝗔𝗛 𝗧𝗘𝗦𝗧 𝗥𝗔𝗡𝗚𝗘, 𝗡𝗘𝗩𝗔𝗗𝗔
𝗗𝗼𝗰𝘂𝗺𝗲𝗻𝘁𝗲𝗱 𝗜𝗼𝗻𝗶𝘇𝗶𝗻𝗴 𝗥𝗮𝗱𝗶𝗮𝘁𝗶𝗼𝗻 𝗛𝗮𝘇𝗮𝗿𝗱𝘀, 𝟭𝟵𝟲𝟯 – 𝟭𝟵𝟵𝟮
Prepared by Mark Ely, VA-Accredited Claims Agent (No. 58349), National Institute for Veterans
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𝗜. 𝗣𝗨𝗥𝗣𝗢𝗦𝗘
This statement sets out, from the government's own records, the ionizing radiation hazards that existed at Tonopah Test Range (TTR) throughout the period when Air Force personnel were assigned there. Every fact below is drawn from Department of Energy, Sandia National Laboratories, Environmental Protection Agency, Energy Research and Development Administration, or Air Force Safety Center documents. None of it rests on veteran recollection alone. The purpose is to establish, for adjudication under 38 C.F.R. § 3.311 and for direct service connection under Combee v. Brown, that veterans who served at TTR served in a documented radiological environment created by the United States Government, that the government knew it, and that the government has never measured what those veterans actually inhaled.
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𝗜𝗜. 𝗦𝗨𝗠𝗠𝗔𝗥𝗬
In May and June 1963, the Atomic Energy Commission and the Department of Defense deliberately detonated nuclear weapon assemblies with conventional high explosives at three sites on Tonopah Test Range, dispersing kilogram quantities of weapons-grade plutonium across the desert floor. The three TTR sites, Clean Slate 1, 2, and 3, were left with a combined plutonium inventory that DOE later placed at roughly 64 curies. A fourth shot, Double Tracks, was fired just beyond the TTR boundary. DOE counts all four among the 1,054 United States nuclear tests and records that three of them released radioactivity detected beyond the range boundary. The contamination was never removed. It was fenced, bladed over, and studied. In the 1970s, DOE's own environmental assessment concluded that the correct course was to "leave them alone but keep track of them." Remediation of the last Clean Slate site was not completed until 2019, fifty-six years after the plutonium was scattered and twenty-seven years after the last veteran in the claim period left the range.
During the same period, TTR was used to fire gun projectiles containing plutonium, depleted uranium, and beryllium; depleted uranium mu*****ns were tested and recovered across the range; radioactive waste was drummed on site; a radium-contaminated trailer sat in an uncontrolled area for approximately five years; and security personnel handled ri**es with leaking tritium sights. From 1977 the range hosted the 4477th Test and Evaluation Squadron, which maintained Soviet-built MiG aircraft carrying radium-luminous cockpit instruments outside every Air Force radioactive-material control, and from 1979 the 4450th Tactical Group, whose F-117A personnel lived on the range for years while its infrastructure was built out across contaminated ground. Radioactive debris clouds from at least thirty Nevada Test Site nuclear and reactor tests were detected at TTR and its neighboring installations, including a 30 milliroentgen exposure from the Baneberry containment failure in December 1970.
The record contains no personnel dosimetry and no bioassay for Air Force members assigned to TTR during any of this. Every dose figure the government now cites is a reconstruction from environmental monitoring stations, not a measurement of a human being.
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𝗜𝗜𝗜. 𝗢𝗣𝗘𝗥𝗔𝗧𝗜𝗢𝗡 𝗥𝗢𝗟𝗟𝗘𝗥 𝗖𝗢𝗔𝗦𝗧𝗘𝗥: 𝗣𝗟𝗨𝗧𝗢𝗡𝗜𝗨𝗠 𝗗𝗘𝗟𝗜𝗕𝗘𝗥𝗔𝗧𝗘𝗟𝗬 𝗗𝗜𝗦𝗣𝗘𝗥𝗦𝗘𝗗 𝗢𝗡 𝗧𝗧𝗥
Operation Roller Coaster was a joint United States–United Kingdom series of four "safety shots" conducted from 15 May to 9 June 1963. Each test detonated a plutonium-bearing nuclear weapon assembly with conventional explosives to measure how far plutonium would spread in a storage or transportation accident. Three of the four shots, Clean Slate 1 (25 May), Clean Slate 2 (31 May), and Clean Slate 3 (9 June), were fired on Tonopah Test Range. Double Tracks (15 May) was fired on the adjacent Nellis range immediately west of the TTR boundary. The 1975 ERDA Environmental Assessment for TTR states plainly that "the amount of plutonium involved in each test was in the low kilograms."
DOE's official register of United States nuclear tests, DOE/NV-209, lists Double Tracks and Clean Slates I, II, and III as tests 319, 323, 325, and 329, with the purpose "Storage-Transportation" and the notation "plutonium dispersal." Three of the four, including Clean Slates I and III on TTR, are annotated "Radioactivity detected offsite," an affirmative finding under the document's own rule that tests after September 1961 are presumed contained unless specifically noted. The plutonium dispersed on TTR crossed the range boundary on the day it was released.
Sandia National Laboratories' 1988 Environmental Monitoring Report for TTR, citing REECo data, lists the residual plutonium inventories as 5.2 curies at Clean Slate 1, 29 curies at Clean Slate 2, 30 curies at Clean Slate 3, and 5.0 curies at Double Tracks, with contaminated areas of 0.22, 0.81, 1.38, and 0.30 square kilometers respectively. Sandia's 1994 Site Environmental Report, relying on a 1977 EG&G aerial radiological survey, put the total Clean Slate contaminated footprint at approximately 20 million square meters, and recorded that the survey "showed the extent of the transuranic contamination, both inside and outside the two control fences."
The initial "cleanup" in 1963 consisted of blading test debris into a hole at ground zero and covering it with dirt. Sandia's 1988 report acknowledges that the Clean Slate areas were bladed to cover hot spots and that "no other stabilization has been done." Annual soil sampling was discontinued in the 1970s. By 1988, Sandia reported that "currently there is no soil sampling or surveying done at the test areas"; the sites were merely inspected visually twice a year for fence repairs. Air Force personnel were living and working on this range throughout that period.
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𝗜𝗩. 𝗧𝗛𝗘 𝗚𝗢𝗩𝗘𝗥𝗡𝗠𝗘𝗡𝗧 𝗞𝗡𝗘𝗪 𝗧𝗛𝗘 𝗖𝗢𝗡𝗧𝗔𝗠𝗜𝗡𝗔𝗧𝗜𝗢𝗡 𝗪𝗔𝗦 𝗟𝗔𝗥𝗚𝗘𝗥 𝗔𝗡𝗗 𝗠𝗢𝗥𝗘 𝗠𝗢𝗕𝗜𝗟𝗘 𝗧𝗛𝗔𝗡 𝗜𝗧 𝗛𝗔𝗗 𝗔𝗦𝗦𝗨𝗠𝗘𝗗
In June 1996, the Desert Research Institute published DOE/NV/10845-57, a treatability study of plutonium-contaminated soils from three safety-shot areas, including Area 52 on TTR. When the TTR soil was actually analyzed, it "had a specific activity of 298 pCi/g, significantly higher than the original estimate of 53.5 pCi/g for this area," a factor of roughly five and a half. The same report documents that in the TTR soil, three percent of particles by weight, those smaller than 125 microns, accounted for 93 percent of the total plutonium activity. In other words, the plutonium was concentrated in exactly the fine fraction that wind, vehicles, and aircraft resuspend and that human lungs retain. The report further states that the plutonium at TTR may have been deposited as a fused plutonium-silicate, an insoluble form that, once inhaled, is cleared from the lung slowly and delivers its dose over years.
Sandia's 1994 report calculated that 0.32 curies of plutonium-contaminated material were being resuspended from the Clean Slate sites every year, and that the maximum exposed individual under the NESHAP analysis was located at the 554th Range Squadron Operations and Maintenance Complex, an Air Force facility. Soil sampling that year found plutonium-239/240 and americium-241 above off-site background at the Range Operations Center, near the Site 1 gate, at the Roller Coaster Decontamination Area, and in the South Plume Area beyond the mapped contamination boundary. The 1993 aerial survey had been discontinued before it reached the downwind end of the Clean Slate 1 plume.
The same 1994 report records that on 1 December 1994 a wind radar antenna pedestal bearing radioactive-material stickers was discovered on a trailer in an uncontrolled area of TTR. Radiological staff identified radium-226 reading 2.5 milliroentgens per hour on contact with 34,000 disintegrations per minute of alpha contamination per 100 square centimeters. A telemetry engineer recalled that the trailer had been identified as contaminated approximately five years earlier and slated for disposal at the Nevada Test Site. It had instead remained on the range, unposted, for the intervening years.
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𝗩. 𝗢𝗧𝗛𝗘𝗥 𝗥𝗔𝗗𝗜𝗢𝗟𝗢𝗚𝗜𝗖𝗔𝗟 𝗦𝗢𝗨𝗥𝗖𝗘𝗦 𝗢𝗡 𝗧𝗧𝗥 𝗗𝗨𝗥𝗜𝗡𝗚 𝗧𝗛𝗘 𝗖𝗟𝗔𝗜𝗠 𝗣𝗘𝗥𝗜𝗢𝗗
The 1975 ERDA Environmental Assessment documents that TTR conducted about 150 gun firings per year and that some projectiles contained "depleted uranium, plutonium, or beryllium," with impact areas 7,000 to 40,000 feet from the Area 9 firing points. It further records that in a gun-barrel failure, "any plutonium in a projectile that fails in the gun barrel will burn and be distributed downwind as plutonium oxide," and that the maximum plutonium in such a test was "in the order of a few kilograms."
Sandia's 1997 Site Environmental Report lists corrective action sites across TTR including the "Cactus Spring Ranch Pu and DU Site," depleted uranium impact sites at Main Lake and Antelope Lake, buried depleted uranium artillery rounds, joint test assembly DU sites, and an inventory of 55-gallon drums of uranium-238 contaminated soil and radium-226 contaminated equipment awaiting disposal. The Air Force Safety Center's 2026 report acknowledges that Sandia security personnel in 1991 handled M-16 ri**es with leaking tritium sights requiring urine bioassay, and that personnel who handled depleted uranium or worked on the Clean Slate sites, including remedial action, had exposure potential that must be assessed "on an individual basis."
From 1977 into the late 1980s, TTR was also the operating base for the 4477th Test and Evaluation Squadron under CONSTANT PEG, which flew and maintained Soviet-built MiG-17, MiG-21, and MiG-23 aircraft, as the Air Force Safety Center's 2026 report acknowledges. Soviet aircraft of that generation used radium-226 luminous compounds on cockpit instruments, switches, and placards. These aircraft entered service at TTR with no manufacturer documentation, no radioactive-material inventory, and outside every Air Force radioactive-material permit, radium-dial identification, and leak-test program that governed the United States inventory. Squadron maintenance personnel disassembled, repaired, and fabricated parts for them for a decade. Sandia's 1997 report confirms that radium dial switches and radium-contaminated altimeter equipment were among the radioactive materials drummed for disposal on the range, and its 1994 report documents a radium-226 source that sat unposted in an uncontrolled area for approximately five years. No radiological survey, wipe test, or bioassay of 4477th personnel appears in the record.
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𝗩𝗜. 𝗧𝗛𝗘 𝗙-𝟭𝟭𝟳𝗔 𝗣𝗥𝗢𝗚𝗥𝗔𝗠: 𝗪𝗛𝗢 𝗪𝗔𝗦 𝗢𝗡 𝗧𝗛𝗘 𝗥𝗔𝗡𝗚𝗘, 𝗛𝗢𝗪 𝗟𝗢𝗡𝗚, 𝗔𝗡𝗗 𝗪𝗛𝗔𝗧 𝗧𝗛𝗘𝗬 𝗗𝗜𝗦𝗧𝗨𝗥𝗕𝗘𝗗
The Air Force Safety Center's report records that Air Force operations on TTR began in 1974 with the 554th Range Group, that TTR infrastructure was "greatly expanded in 1979" under Holmes and Narver and REECo, and that the 4450th Tactical Group began F-117A operations at TTR in 1979, a mission that remained on the range until its transfer to Holloman Air Force Base in 1992. The F-117A program does not add a new isotope to this record. What it adds is people, time, and disturbance, the three variables the government's dose reconstruction treats most lightly.
The 1979 build-out meant grading, trenching, earthmoving, and heavy vehicle traffic across a range whose plutonium contamination the 1977 aerial survey had just shown extended outside both control fences, and whose downwind plume the 1993 survey still had not fully mapped. Sandia's 1994 report identified the 554th Range Squadron Operations and Maintenance Complex as the maximally exposed location for Clean Slate resuspension, and found plutonium above off-site background at the Range Operations Center and near the Site 1 gate, the working heart of the F-117A operation.
Because the program was compartmented, its personnel did not commute from Las Vegas. Published Air Force histories of the 4450th record that aircrew, maintainers, security police, and support personnel were flown to TTR at the start of each work week and lived in dormitories on the range until the weekend, for years at a time. Security police patrolled the perimeter on unpaved roads at night. Maintenance was performed on open ramps in a desert where the 1996 DRI analysis later found 93 percent of the plutonium activity concentrated in the fine, wind-borne fraction. The Air Force Safety Center's inhalation estimate assumes a 2,000-hour occupational year at an air sampler eight kilometers from the nearest Clean Slate site, measured in 1996 after three decades of weathering. A 4450th airman who lived on TTR five days a week from 1980 to 1988 fits none of those assumptions. The secrecy that surrounded the program also meant that the people living on the range were told nothing of the Clean Slate sites, the plutonium and depleted uranium firings, or the radium sources around them.
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𝗩𝗜𝗜. 𝗙𝗔𝗟𝗟𝗢𝗨𝗧 𝗙𝗥𝗢𝗠 𝗡𝗘𝗩𝗔𝗗𝗔 𝗧𝗘𝗦𝗧 𝗦𝗜𝗧𝗘 𝗡𝗨𝗖𝗟𝗘𝗔𝗥 𝗧𝗘𝗦𝗧𝗦 𝗥𝗘𝗔𝗖𝗛𝗘𝗗 𝗧𝗧𝗥
The Air Force Safety Center's August 2026 report, Ionizing Radiation Exposures to Air Force Personnel with Duties in Vicinity of the Nevada Test Site, identifies 82 Nevada Test Site events between 1959 and 1992 with off-site detection of radiological effluents, and 30 of those with detections at Groom Lake, TTR, Tonopah, or Indian Springs. For the Baneberry containment failure of 18 December 1970, the report tabulates a peak external exposure rate at TTR of 3.5 milliroentgens per hour and a net infinity external gamma exposure of 30 milliroentgens, with positive air-sample results. The report concedes that the TTR airport was "likely" impacted by the 1965 Palanquin cratering shot and sat on the western fringe of the 1968 Schooner plume, which produced a 165 millirem personal dosimeter reading in a nearby off-site area. It further concedes that no noble-gas detection network existed around the Test Site until 1970 and that, had one existed earlier, "there would have been many more positive detections of off-site radiological emissions."
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𝗩𝗜𝗜𝗜. 𝗥𝗘𝗠𝗘𝗗𝗜𝗔𝗧𝗜𝗢𝗡 𝗖𝗢𝗡𝗙𝗜𝗥𝗠𝗦 𝗧𝗛𝗘 𝗛𝗔𝗭𝗔𝗥𝗗 𝗣𝗘𝗥𝗦𝗜𝗦𝗧𝗘𝗗 𝗧𝗛𝗥𝗢𝗨𝗚𝗛 𝗧𝗛𝗘 𝗘𝗡𝗧𝗜𝗥𝗘 𝗖𝗟𝗔𝗜𝗠 𝗣𝗘𝗥𝗜𝗢𝗗
DOE did not begin removing Clean Slate soil until 1996 (Double Tracks) and 1997 (Clean Slate 1). Clean Slate 2 was not remediated until 2017 and Clean Slate 3 not until 2018–2019, when 6,300 cubic meters of soil were excavated to meet a 25 millirem-per-year worker criterion. The Air Force Safety Center's report acknowledges that even after the Clean Slate 1 action, "the total surface soil source term was only reduced by perhaps a factor of 2 to 4," because most soil above 50 picocuries per gram was left in place. Every veteran who served at TTR between 1963 and 1992 served while all four Roller Coaster sites were entirely unremediated.
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𝗜𝗫. 𝗧𝗛𝗘 𝗚𝗢𝗩𝗘𝗥𝗡𝗠𝗘𝗡𝗧'𝗦 𝗣𝗢𝗦𝗜𝗧𝗜𝗢𝗡 𝗔𝗡𝗗 𝗪𝗛𝗬 𝗜𝗧 𝗗𝗢𝗘𝗦 𝗡𝗢𝗧 𝗥𝗘𝗦𝗢𝗟𝗩𝗘 𝗧𝗛𝗘𝗦𝗘 𝗖𝗟𝗔𝗜𝗠𝗦
The Air Force Safety Center estimates that annual effective doses at TTR from Nevada Test Site fallout were below 100 millirem and that inhalation exposure from Clean Slate resuspension was negligible. That report deserves to be read carefully, because its own text defines the limits of its conclusions.
𝗙𝗜𝗥𝗦𝗧, it is a reconstruction from environmental monitoring stations, not from personnel monitoring. The record reflects no film badge, thermoluminescent dosimeter, or bioassay program for airmen assigned to TTR; the Air Force report tabulates personnel dosimetry only for those with duties on the Nevada Test Site itself. The report's characterizations of TTR impacts as "likely," "expected," and "assumed" appear throughout Section 3.3.
𝗦𝗘𝗖𝗢𝗡𝗗, the report expressly excludes from its environmental analysis the personnel most at risk. It states that exposure potential for those who handled depleted uranium, worked on the Clean Slate sites, performed remedial action, or handled the tritium-sight ri**es "would have been on an individual basis." It offers no dose for any of them. Fence repair crews, security patrols, range maintenance, explosive ordnance disposal, salvage yard workers, mu*****ns recovery personnel, 4477th maintainers who worked inside radium-luminous Soviet cockpits, and 4450th personnel who lived on the range through the 1979 construction and the decade that followed all fall in that gap.
𝗧𝗛𝗜𝗥𝗗, the report's plutonium inhalation estimate rests on air sampling conducted in 1996 at the TTR airport, more than eight kilometers from the nearest Clean Slate site and after three decades of weathering had reduced resuspension by the report's own account by four orders of magnitude. It does not measure what a veteran breathed at a Clean Slate fenceline in 1975, in a dust storm, or behind a vehicle on an unpaved range road.
𝗙𝗢𝗨𝗥𝗧𝗛, the report's author acknowledges that the government's own contamination estimates for TTR were repeatedly revised upward: the 1963 field integration underestimated Clean Slate 2 and 3 inventories by roughly half compared to later REECo figures, the 1977 aerial survey found contamination outside both control fences, the 1996 DRI soil analysis found activity more than five times the prior estimate, and the 1993 aerial survey never reached the end of the Clean Slate 1 plume. An environment whose extent the government could not fix for thirty years is not an environment whose dose to any individual can be stated with the confidence the report projects.
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𝗫. 𝗖𝗢𝗡𝗖𝗟𝗨𝗦𝗜𝗢𝗡
The United States Government scattered kilograms of weapons-grade plutonium across Tonopah Test Range in 1963, left it in place for the next three to five decades, fired plutonium and depleted uranium projectiles over the same ground, allowed radium-contaminated equipment to sit unposted, put maintainers to work inside Soviet cockpits it had never surveyed, housed an entire fighter group on the range for a decade, and stationed Air Force personnel there without dosimetry, without bioassay, and without notice. The documents cited here were written by DOE, Sandia, ERDA, EPA, and the Air Force itself. They establish beyond reasonable dispute that TTR was a radiological environment throughout the claim period, that the plutonium was concentrated in the respirable fraction, and that the government's present dose estimates rest on assumptions rather than measurements of the veterans who served there.
Under 38 C.F.R. § 3.311, a veteran who served at TTR and who has a radiogenic disease has established the exposure predicate and is entitled to a dose estimate that accounts for his actual duties, not a range-wide average built from a distant air sampler. Under Combee v. Brown, 34 F.3d 1039 (Fed. Cir. 1994), he is entitled to have a competent medical opinion weighed on its merits. The facts recited above are the foundation for both. These veterans do not ask the Department of Veterans Affairs to presume anything. They ask it to read what the government wrote about the ground they stood on.
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𝗦𝗢𝗨𝗥𝗖𝗘𝗦
• Rademacher, S.E., Ionizing Radiation Exposures to Air Force Personnel with Duties in Vicinity of the Nevada Test Site, Headquarters Air Force Safety Center, Final, 17 August 2026.
• U.S. Department of Energy, Nevada Operations Office, United States Nuclear Tests, July 1945 through September 1992, DOE/NV-209 Rev. 15, December 2000.
• Energy Research and Development Administration, Environmental Assessment, Tonopah Test Range, EIA/MA/76-2 (ERDA 79-2), 1975.
• Sandia National Laboratories, 1988 Environmental Monitoring Report, Tonopah Test Range, SAND89-1367, May 1989.
• Sandia National Laboratories, 1994 Site Environmental Report, Tonopah Test Range, SAND95-1954, September 1995.
• Sandia National Laboratories, 1997 Annual Site Environmental Report, Tonopah Test Range, SAND98-1832, August 1998.
• Papelis, C., et al., Evaluation of Technologies for Volume Reduction of Plutonium-Contaminated Soils from the Nevada Test Site, DOE/NV/10845-57, Desert Research Institute, June 1996.
• U.S. Environmental Protection Agency, Offsite Environmental Monitoring Report: Radiation Monitoring Around United States Nuclear Test Areas, Calendar Year 1993, EPA/402/R-96/007, June 1996.
• Air Force Historical Research Agency, unit histories of the 4477th Test and Evaluation Squadron (CONSTANT PEG) and the 4450th Tactical Group, as cited in Rademacher (2026); National Museum of the United States Air Force, CONSTANT PEG fact sheet.
• Torrao, G., et al., Characterization of Plutonium Contaminated Soils from the Nevada Test Site in Support of Evaluation of Remediation Technologies, WM'03 Conference, February 2003.
