Wrongheaded complaints

On September 2, 2015, the Boulder Daily Camera published an article of mine entitled “Prohibit Public Access to Rocky Flats.” It is available on this blog at https://leroymoore.wordpress.com/category/nuclear-guardianship/ My article said public access to Rocky Flats should be prohibited because visiting the site (now the Rocky Flats National Wildlife Refuge) could expose one to plutonium remaining in the environment at the site, possibly wrecking one’s health. Plutonium is highly toxic for roughly 500,000 years. Tiny particles can be inhaled. Keeping the site closed will help protect wholly innocent people.

Here I will comment on two responses to my article that the Camera published. The first, by Dean Rundle, former Manager of the Rocky Flats National Wildlife Refuge, challenged my analysis of public comments on the Environmental Impact Statement prepared for the Refuge in 2004. It shows that 81% of those commenting opposed public access at the Wildlife Refuge. Rundle dismisses this number because many of these people signed a petition and their identity is unknown. He says if one counts only local identifiable people, the division was about half for and half against public access. This is wishful thinking. Had he actually analyzed the comments of only identifiable individuals, he would have found that 64% opposed public access and 32% — or exactly half – favored it. My analysis is on line at http://media.wix.com/ugd/cff93e_a9cff9a4c30b4ac5bbfa27e93b91a9bf.pdf

The second response was written Reed Bailey, a former Rocky Flats worker. He says I have never “written a peer reviewed research paper on the physical effects of radiation on the human body, or any other scientific subject.” In fact, I published two peer reviewed articles in the Bulletin of the Atomic Scientists, on in 2002 on setting standards for permissible exposure to radiation, the other in 2005 on the Rocky Flats Superfund cleanup. I was co-author with two colleagues of a paper on radiation exposure standards published in 2004 in Health Physics. A further peer-reviewed article by me, “Democracy and Public Health at Rocky Flats,” appeared in Tortured Science (2012). I also was the principal author of the Citizens Guide to Rocky Flats (1992). Most of these writings can be found on line at http://www.rockyflatsnuclearguardianship.org  In addition to actual publications, for four years I was a member of two committees of the National Council on Radiation Protection and Measurements, the principal U.S. organization that studies radiation health effects and makes recommendations regarding standards for permissible exposure to radiation.

Bailey also in effect accused me of lying when I mentioned a Columbia University study showing that taking a single plutonium particle into a lung could result in physical harm. In fact, there were two studies done by a team headed by Tom K. Hei of Columbia, both published in Proceedings of the National Academy of Sciences, in 1997 and 2001. Both refer to possible harm, one from direct exposure to a single plutonium particle, the other from indirect exposure. Were Mr. Bailey more careful, he would have found what could be found. Instead he spoke from ignorance.

Plutonium at Rocky Flats: Who is protected?

(Talk given at Naropa University, July 30, 2015)

The Rocky Flats National Wildlife Refuge came into existence in 2006 after completion of the Superfund cleanup at the nuclear weapons plant site. The Department of Energy transferred almost three-quarters of the roughly 10-square-mile Rocky Flats site to the U.S. Fish & Wildlife Service, the agency that would manage the Refuge. Recent additions to the Refuge bring its size to 9.75 square miles. The Refuge surrounds the former industrial area of slightly more than 2 square miles which has been retained by the DOE (Figure 1).

Today I will address one question about Rocky Flats: Who is protected by the Superfund cleanup completed in 2005? Stated differently, who did the government agencies responsible for the cleanup decide to protect? Did they pick the right person?

I invite you to consider ten truths regarding the cleanup done at Rocky Flats:

1. Of all the contaminants released into the environment from the Rocky Flats plant when it was operating, plutonium-239 is of greatest concern, because it is highly toxic, endangers human health and was repeatedly dusted across the whole site.[1]
2. Those responsible for the cleanup knowingly left some plutonium-239 in the environment when the cleanup was finished.[2]
3. The plutonium left behind is in the form of particles too small to see.[3]
4. Though plutonium particles may be too small to see they are not too small to do harm, especially if blown about by the winds common at Rocky Flats.
5. The worst way to be exposed to plutonium – and also the easiest way – is to inhale one or more of these tiny particles.
6. If you inhale plutonium or take it into your body through an open wound it is likely to lodge within your body; once this happens, the plutonium will constantly irradiate surrounding cells in a very small area for the rest of your life,
7. This constant irradiation may in time lead to cancer, a compromised immune system or genetic harm to future generations.[4]
8. Taking only one particle of plutonium into your body may produce the bad health-effects just mentioned.[5]
9. Plutonium in soil does not stay in place; it migrates. From time to time tiny particles will be brought to the surface where they can be picked up by the wind.[6]
10. Plutonium-239 in the environment is not a temporary problem, because it remains radioactive for a quarter-million years, or roughly 20 times the 12,000 years of recorded human history. Rocky Flats, thus, is a local hazard forever.

If you have lived in the area for several years and have been paying attention, you already know some or all of these truths. If so, you didn’t learn them not from federal and state agencies responsible for Rocky Flats. You learned from people who, like yourself, were paying attention. If, on the other hand, these truths are new to you, it’s not too late to join those paying attention.

As for personnel at the government agencies responsible for Rocky Flats, most of them say and do what others in the government strata say and do. If they want to keep their jobs, they have to go with the flow. They can’t go against the current. Collectively, they’re out of touch with reality.

A crucial example of their lack of realism is how they handled the Superfund cleanup. Superfund is a federal program to ensure that contaminated industrial sites are not simply abandoned when a plant is shut down but are cleaned up. When production ended at Rocky Flats, the site was regarded as one of the most contaminated in the country. Superfund requires that the cleanup of a given site protect future people from exposure to toxins that remain in the environment.

To do this, those responsible for a cleanup must identify the “reasonably maximally exposed individual.” The idea is that if you know who can reasonably be expected to be the most exposed individual at a site and the cleanup protects this person, others who would receive less exposure will be protected. At Rocky Flats, those responsible for the cleanup – DOE, EPA and CDPHE – together decided that the “maximally exposed individual” would be a wildlife refuge worker, a person who works outdoors at the site for 20 hours a week for 30 years.

U.S. Fish & Wildlife Service, which manages the Rocky Flats National Wildlife Refuge, intends eventually to open the Refuge for public recreation. Allowing public access would very likely mean radiation exposure to wholly innocent people. The agencies responsible for the cleanup regard this as an acceptable risk, since the occasional visitor to the Refuge would be at the site only a fraction of the time spent there by the wildlife refuge worker. In theory, if the refuge worker would be protected, anyone who simply visits the refuge would also be protected.

The refuge worker scenario also had an economic aspect. Cleaning the site to protect a wildlife refuge worker would cost far less than cleaning it to protect, for example, someone living on the site. Turning most of the site into a wildlife refuge and protecting a wildlife refuge worker, thus, became the operating rationale for a quicker and cheaper Rocky Flats cleanup.

But cleaning the site to protect a wildlife refuge worker was unrealistic. It failed to take into account the toxicity and long half-life of the plutonium-239 left in the environment. When the Refuge is gone, when fences fall and memories fade and people move onto the site, who will be protected? Steve Gunderson of CDPHE said in a public meeting that the Rocky Flats cleanup was meant to take care of things for 200 years. But deciding to use the wildlife-refuge-worker scenario to establish the site’s legally binding cleanup standards in effect consigns some people to a slow and untimely death. This is a crime against humanity for which there is no statute of limitation. If Superfund law literally requires protection of the “maximally exposed individual,” shouldn’t the legality of the Rocky Flats decision be challenged in court?

An alternative was proposed. In 2001 the Rocky Mountain Peace and Justice Center and the Institute for Energy and Environmental Research proposed a cleanup that would protect a farming family that lives on what is now the Rocky Flats site from birth to death, generation after generation, eats only food grown there and drinks local water. This proposal was realistic about the future, but it was rejected by the powers that be. They favored the cheaper, quicker, shortsighted cleanup that left us with a permanent danger.

What should be done? The Rocky Flats Nuclear Guardianship came into being to deal with questions like this. Some day perhaps the cleanup can be redone. But for now, the most straightforward move is to keep the Rocky Flats site closed to the public. We plan soon to ask Congress to enact legislation that will keep all DOE nuclear weapons production sites that undergo Superfund cleanup closed to the public for at least 250 years after completion of the cleanup. This would save some from being exposed to radiation. And it would provide time for all of us to find better solutions to the problem of plutonium in the environment. In the words of Terry Tempest Williams, “The eyes of the future are looking back at us, and they are praying for us to see beyond our own time.”

[1] Harvey Nichols, a specialist on airborne pollen, was hired by the federal government in 1974 to study airborne particles at Rocky Flats. He found that routine operations at the plant deposited “tens of billions of plutonium particles per acre” across the site and that the air monitors around the site were deficient and did not measure what was being released. Nichols, Assessment of the Official Air Sampling Equipment at Rocky Flats during 1974 to 1976, 2-18-12.

[2] Final revisions of the Rocky Flats Cleanup Agreement allowed the following amounts of plutonium to remain in soil after the cleanup (plutonium is measured in picocuries per gram of soil, abbreviated as pCi/g. A picocurie is a measure of radiation.

• Top 3 feet of soil: up to 50 pCi/g allowed to remain in soil.
• Soil 3 to 6 feet below the surface: 1,000 to 7,000 pCi/g allowed to remain, the amount dependent on the size of the contaminated area.
• Soil 6 or more feet below the surface: no limit on amount of plutonium that may remain in soil.

Cleanup of plutonium elsewhere was more protective, ranging from a low of 8 pCi/g at Fort Dix, NJ, to 40 pCi/g at Enewetak Atoll bomb test site, with 200 pCi/g at a small portion of Nevada Test Site, all without respect to depth. For another comparison, average background deposit of plutonium from global fallout locally is 0.04 pCi/g. The 50 pCi/g allowed in top 3 feet is 1,250 times 0.04 pCi/g; 1,000 to 7,000 pCi/g is 25,000 to 175,000 times 0.04 pCi/g. Plutonium is not a part of natural background radiation. Natural background has been altered globally by the addition of fallout of plutonium and other radionuclides from the human activity of detonation of nuclear bombs.

[3] Meteorologist W. Gale Biggs found that the average size of plutonium particles released in routine operations at Rocky Flats was 0.045 microns. The average size of a human hair is 50 microns. Biggs, , Airborne Emissions and Monitoring of Plutonium from Rocky Flats (March 17, 2011).

[4] Herman J. Muller received the Nobel Prize in 1946 for showing that radiation produced genetic mutations. He later revealed that exposure to a very low level of radiation will eventually harm and prove lethal to future generations. This could result in extinction of the human species. See http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1254569/?page=9

[5] Tom K. Hei and colleagues at Columbia University demonstrated that a single plutonium alpha particle induces mutations in mammal cells. Cells receiving very low doses were more likely to be damaged than destroyed. Replication of these damaged cells constitutes genetic harm, and more such harm per unit dose occurs at very low doses than would occur with higher dose exposures. “These data provide direct evidence that a single alpha particle traversing a nucleus will have a high probability of resulting in a mutation and highlight the need for radiation protection at low doses.” Proceedings of the National Academy of Sciences, vol. 94, April 1997, pp. 3765-3770.

[6] In 1995 environmental engineer Iggy Litaor discovered rapid migration of plutonium in subsurface soil at Rocky Flats. In 1996 ecologist Shawn Smallwood identified 18 species of burrowing animals on the Rocky Flats site that dig down to as much as 16 feet and can bring soil and their contents, including plutonium, to the surface. For full discussion, see Moore, “Science compromised in the cleanup of Rocky Flats.” On line at http://media.wix.com/ugd/cff93e_1ae76276c5814bf8aa21dc530da95857.pdf

Pope Francis supports the Iran deal as a step toward nuclear abolition

WASHINGTON — The Vatican endorsed the Iran nuclear accord Monday as a positive step towards its broader goal of a world free of nuclear weapons.

“We hope that the full implementation of [the nuclear deal] will ensure the peaceful nature of Iran’s nuclear programme under the [Non-Proliferation Treaty] and will be a definitive step toward greater stability and security in the region,” Archbishop Paul Gallagher, the Vatican’s foreign minister, said in a statement delivered at the International Atomic Energy Association in Vienna.

“The way to resolve disputes and difficulties should always be that of dialogue and negotiation,” he said, a possible allusion to opponents of the nuclear agreement who have called for military strikes to destroy Iran’s nuclear sites.

Pope Francis’ vote of confidence for the Iran nuclear deal comes the week before he is scheduled to visit Washington, where he will address a joint session of Congress at the invitation of House Speaker John Boehner (R-Ohio).

After a two-month debate, Republican lawmakers — all of whom opposed the nuclear accord — lost their fight last week to block the implementation of the agreement. Faced with defeat, Republicans have zeroed in on a set of confidential agreements between Iran and the IAEA, which detail the agency’s process for investigating possible past nuclear weapons development sites in the country.

House Republicans voted last week to pass a nonbinding resolution charging President Barack Obama with violating the law for failing to provide lawmakers with the text of confidential documents that only Iran and the IAEA are privy to. And Sen. Lindsey Graham (R-S.C.) is pushing to cut off funding to the IAEA until Congress gets copies of the agency’s secret agreements.

Without specifically targeting U.S. lawmakers, Gallagher noted on Monday that the success of the Iran nuclear accord depends on the international community’s willingness to implement the deal and the IAEA’s ability to hold Iran accountable to its obligations to curtail its nuclear activity.

“It is clear that the agreement requires further efforts and commitment by all the parties involved in order for it to bear fruit,” Gallagher said. “For its part, the IAEA’s indispensable role in nuclear safety and waste disposal, verification and monitoring will become ever more important as the use of peaceful nuclear energy expands and as the world moves toward nuclear disarmament.”

The distance between Pope Francis and the GOP on the Iran deal is not the only issue that could make Republicans squirm during the upcoming papal address. The pope is likely to push for greater action on climate change and call on lawmakers to address the rampant economic inequality in the U.S. But the Pope’s opposition to abortion could also bolster Republicans, particularly the 28 men who have vowed to shut down the government before allowing federal funding to go to Planned Parenthood.

Lawmakers have promised to keep partisan politics under wraps during the papal address and refrain from cheering the Pope for statements that reinforce their political preferences.

In addition to expressing support for the diplomatic solution to Iran’s nuclear program, the Vatican pushed nuclear weapons states to recognize their own responsibility to downsize their arsenal.

“The discriminatory nature of the NPT is well known. The status quo is unsustainable and undesirable,” Gallagher said, referring to the 1968 treaty aimed at preventing the spread of nuclear weapons. The NPT allows members to maintain civil nuclear programs, but requires states that have nuclear weapons to work towards disarmament and prohibits other states from developing weapons. Iran and India have charged in the past that the treaty is inconsistently implemented, noting that the U.S. and Russia have been slow to downsize their massive nuclear arsenals.

“Just as wealthy nations have incurred an ‘ecological debt’ that demands more from them in addressing the environmental crisis, nuclear weapons states have incurred a nuclear debt,” Gallagher said. “Because of the risks their nuclear arsenals pose to the world, nuclear weapons states bear a heavy moral burden to ensure that their nuclear weapons are never used and to reduce their stocks substantially while taking the lead in negotiating a nuclear ban.”

Prohibit Public Access to Rocky Flats National Wildlife Refuge

Prohibit public access to Rocky Flats

By LeRoy Moore

Boulder Daily Camera, September 2, 2025

 

U.S. Fish & Wildlife Service (FWS) did a “soft opening” to the Rocky Flats National Wildlife Refuge. One can now join a group of 10 or fewer for a three-mile hike to see plants, wildlife and birds. To the aware public, the “soft opening” is an insult. It catches us unawares and preempts public input before the full opening mentioned in official documents. It flies in the face of broad opposition to public access expressed in 2004 when FWS sought public comments on its Environmental Impact Statement for the future refuge. Eighty-one percent of commenting parties opposed public access.

Refuge visitors could be exposed to radioactive plutonium-239 in the environment at the refuge and the Department of Energy (DOE) land that surrounds it. The two-square-mile DOE plot is the former industrial area of the Rocky Flats nuclear bomb plant, which for 37 years produced the explosive plutonium core of nuclear warheads. Fires, accidents and routine operations released billions of tiny, highly toxic particles of plutonium-239 into the environment.

For reasons known to the concerned public, FWS should not allow public access to the refuge — reasons also known to officials at DOE and the agencies that regulated the Rocky Flats Superfund cleanup: the EPA and Colorado Department of Public Health and the Environment (CDPHE). DOE has routinely denied the scientific and medical reality at Rocky Flats. EPA and CDPHE went along, perhaps because they are paid by DOE to regulate DOE, a little noticed conflict of interest.

Key reasons for prohibiting public access to the refuge:

• Plutonium-239, with a half-life of 24,110 years, is present in the environment at Rocky Flats in the form of particles too small to see.
• The radiation from plutonium cannot penetrate skin, but if plutonium is inhaled or otherwise internalized it lodges in the body and constantly irradiates nearby tissue, endangering one’s health.
• Columbia University researchers found that a single particle of plutonium taken into the body induces genetic mutations that may produce cancer or other ailments.
• Those responsible for the cleanup assumed plutonium left in soil would remain in place, despite Dr. Iggy Litaor’s discovery in 1995 that plutonium migrates during rain events and Dr. Shawn Smallwood’s finding in 1996 that burrowing animals bring plutonium to the surface, where it can be redistributed by the wind common at Rocky Flats.
• Plutonium on DOE land will migrate onto the refuge. This probably happened in the September 2013 flood, but DOE’s streambed monitors failed during the storm, leaving us in the dark about whether and how far the plutonium traveled. Sheet flooding, present in 2013, has never been monitored at Rocky Flats.
• The Rocky Flats Superfund cleanup was designed to protect a wildlife refuge worker. But plutonium will far outlive the refuge. The greatest harm will be to future generations.
• Genetic effects of plutonium on wildlife are poorly understood. There have been no genetic studies of wildlife at Rocky Flats.
• The FBI raided Rocky Flats in 1989 to collect evidence of environmental law-breaking at the site. The documents were sealed. EPA and CDPHE were given the opportunity to review the evidence during the cleanup, but they declined. In the raid EPA took environmental samples that have never been revealed.
• Although children are especially vulnerable to radiation, FWS expects them at the refuge.

Of the more than 600 national wildlife refuges, Rocky Flats is the only one on the radioactive site of a former nuclear weapons factory. To FWS, this doesn’t matter, as evidenced by the “soft opening.”

In the face of all this uncertainty, biology professor Harvey Nichols and former county commissioner Paul Danish generated a very sensible proposal. Congress should enact legislation requiring that all DOE nuclear weapons sites that undergo Superfund cleanup remain closed to the public for at least 250 years after completion of the cleanup.

Enactment of this proposal would protect the innocent and bring praise for supporting legislators. It would introduce into the nuclear realm the precautionary principle that where uncertainty regarding harm to public health and environmental integrity exists, as it does at Rocky Flats, caution should prevail over carelessness. People of future generations will be grateful. I strongly suggest that our current state and congressional delegations support this concept. By the time a site has been closed for two-and-a-half centuries, whether visiting it poses a danger or not should be known. Any questionable site could be kept closed permanently.

 

LeRoy Moore works with the Rocky Flats Nuclear Guardianship of the Rocky Mountain Peace and Justice Center.