Have you seen the horse? It’s a tribute to and a warning about Rocky Flats. Check it out.
Have you seen the horse? It’s a tribute to and a warning about Rocky Flats. Check it out.
Science Compromised in the Cleanup of Rocky Flats, By LeRoy Moore, Ph.D.
Rocky Mountain Peace and Justice Center (October 2006; as revised, July 18, 2013)
“Science-based cleanup of Rocky Flats,” an article published in Physics Today in September 2006, describes the work of a team of scientists who spent several years researching how and to what extent plutonium and other radionuclides migrate in the Rocky Flats environment. Their study, the Actinide Migration Evaluation (AME), produced information used in setting the cleanup levels for the badly contaminated Rocky Flats site. Accordingly, David L. Clark and his co-authors claim for themselves and their colleagues on the AME team a big share of the credit for the cleanup of the defunct Rocky Flats nuclear bomb plant that was completed in 2005. Their claim is apt, but the “science-based cleanup” they celebrate is, as this article demonstrates, an instance of science compromised.
The article by Clark et al. describes the methods and results of the AME project. It is a story familiar to me, because I co-chaired a panel that provided citizen oversight of the AME work. The story as they tell it contains omissions and problems, starting with the scandal with which the AME project began.
A momentous finding
The AME work was preceded by the totally unexpected detection in the exceedingly wet spring of 1995 of substantial movement of plutonium in the near surface soil (vadose zone) at Rocky Flats. This surprising find was made with real-time remotely controlled monitoring instruments set up in the soil on the site by environmental engineer M. Iggy Litaor. An adjunct professor at the University of Colorado, Litaor had for some years worked as a senior soil scientist at Rocky Flats studying actinides in the environment. Over the years he had published more than a dozen articles reporting his findings in leading technical journals.
Litaor estimated that on May 17, 1995, the wettest day of that very wet spring, a quantity of plutonium ranging from 10 millionths of a curie to one-half of a curie was “remobilized overland” and traveled more than 100 meters down slope. This finding, he said, “challenges the framework of the suggested accelerated cleanup,” because the plutonium migration he detected “was not envisioned under any environmental condition or hydrogeochemical modeling scenarios considered for Rocky Flats.” Indeed, his finding countered the dogma heard often by the public from Rocky Flats officials, namely, that once in the environment plutonium stays in place. Litaor himself had previously supported this concept, until, as he admitted in a public forum, “Mother Nature” proved him wrong.
When Kaiser-Hill took over as cleanup contractor at Rocky Flats on July 1, 1995, barely five weeks after Litaor’s surprising finding, one of the company’s first acts was to terminate him. Asked at the October 1995 Rocky Flats Citizens Advisory Board meeting if Litaor had been dismissed, Kaiser-Hill official Christine S. Dayton said, “No.” At its next meeting the board learned that she had not told the truth. In response to public outcry over Litaor’s dismissal, Kaiser-Hill retained his services for a brief period, but by this time his research team of graduate students had been dispersed and his field instruments dismantled. Meanwhile, Ms. Dayton was named director of the Actinide Migration Evaluation, a post she would hold for the nearly ten years of the project’s existence.
The foregoing was only the most visible part of the scandal surrounding Litaor and the creation of the AME. Behind the scenes during its first weeks as the new cleanup contractor Kaiser-Hill commissioned a review of Litaor’s work by five scientists, among them Bruce D. Honeyman of the Colorado School of Mines and David L. Clark from DOE’s Los Alamos Lab (lead author of “science-based cleanup” article). Their 33-page critique of Litaor’s work faulted him most pointedly for failing “to address the question of the chemical form, i.e., speciation, of plutonium in the environment.” Speciation is the study of the range of chemical forms an element like plutonium may take under varied conditions (e.g., whether liquid, solid or gas). Clark and Honeyman, who are speciation specialists, in effect were criticizing Litaor for not being themselves. Both, not incidentally, were soon identified as members of the new AME group.
Litaor learned about this dismissive review of his work, which was never made available to the public, only after it was completed. In a written response he said that the main objectives of his work had been “characterization and quantification of the physical processes that control plutonium mobilization.” It was with a “real-time in-situ remotely controlled monitoring system” that he observed the “unexpected phenomenon” of plutonium migration under exceptional meteorological conditions, something that would never have been achieved with speciation analyses that in his view “merely study the beaker environment.”
Over a period of at least two years after termination of his Rocky Flats contract, Professor Litaor, having returned to his native Israel to assume an academic post, sought crucial geological data needed to complete a detailed account of his plutonium-migration findings. Neither Kaiser-Hill nor the DOE would provide him with what he sought. I and others petitioned the site on his behalf, to no effect. A full report on Litaor’s important finding thus has never been published. The very wet spring of 1995, when Litaor detected plutonium migration, has been called the equivalent of a hundred-year storm. This means that, on average, the conditions he encountered are likely to be repeated once each century. Due to Litaor’s dismissal, how it happened and how he was subsequently treated, the AME work celebrated by Clark et al. began under a cloud. For some in the engaged public this cloud never lifted.
The question of plutonium solubility
As the AME team began their work, they faced a barrage of questions about plutonium migration at Rocky Flats. Clark et al. say in their article that “researchers hypothesized” that migration happened because plutonium “was soluble in surface and groundwater,” but “the initial models of contaminant transport – ones based on soluble forms of plutonium – were flawed and indefensible.” They never, however, identify the “researchers” or the “models” to which they refer. Litaor, in his numerous public presentations regarding his finding of plutonium migration, never spoke of solubility.
In the context of the AME work, the only person to claim that plutonium moved in the Rocky Flats environment because it became soluble was AME team member Bruce Honeyman of the Colorado School of Mines. At a public meeting on August 20, 1997, he said he had concluded from his speciation studies that up to 90% of the plutonium in the environment at Rocky Flats could become soluble. Asked if this meant it would eventually migrate off the site, he said, “Yes, but additional work is needed to determine the rate of movement.” He never spoke this way again, and efforts to get him to explain what he had said were brushed aside by those involved with the AME project. Had his exact words not been recorded in minutes of that particular meeting, they might be forgotten by all but a few people with very acute hearing. Honeyman soon stopped attending AME public meetings.
In an unprecedented 1996 study, ecologist Shawn Smallwood revealed how burrowing animals redistribute contaminants left in the soil at Rocky Flats. He identified 18 species of burrowing creatures at Rocky Flats, all constantly moving soil and any adhering contaminants. They take surface material down and bring buried material up. Major diggers, like pocket gophers, harvester ants, and prairie dogs, burrow to depths of 10 to 16 feet and disturb very large areas on the surface, while coyotes, badgers, rabbits, and other animals move additional soil. Plants loosen soil and create passages animals can use. Smallwood estimated that burrowing animals disturb 11 to 12% of surface soil at Rocky Flats in any given year. Undisturbed soils do not exist at this site. The plutonium, which at Rocky Flats is only partially remediated down to a depth of 6 feet and is not remediated at all below that level, is being constantly re-circulated in the environment. What is now buried is likely some day to be brought to the surface for wider dispersal by wind, water, fires or other means. In his research Smallwood, who is located in Davis, CA, went onto the Rocky Flats site on three separate occasions in the summer and fall of 1996, each time accompanied by Rocky Flats personnel. He finished his report before the end of that year and two years later published results in a technical journal. But his findings were totally ignored by the AME scientists. Their final report issued in 2004 states that data on highly mobile species that might transport actinides “are not available and would be difficult and in some cases logistically nearly impossible to obtain.” Smallwood’s study had been completed eight years earlier.
Uptake of plutonium in grass
An eleven-year study done at DOE’s Savannah River Site in South Carolina demonstrates that plutonium in subsurface sediments at that site moved upward from the buried source material. The authors of this study conclude “that the upward movement was largely the result of invading grasses taking up the plutonium and translocating it upward,” producing a “measurable accumulation of plutonium on the ground surface.” By contrast, the AME study at Rocky Flats concluded that “uptake into plant . . . tissues is minor.” The Rocky Flats site consists for the most part of prairie grassland. If grass at the Savannah River Site brings plutonium up to the surface, should we not expect something similar to happen at Rocky Flats? Very likely the grasses at Rocky Flats have roots that run deeper into the soil than those at Savannah River, due to the comparably drier climate at Rocky Flats. The question whether the grass at Rocky Flats brings plutonium to the surface presents an uncertainty worth detailed exploration.
The AME conclusion: Plutonium “relatively immobile”
Despite the never explained interlude with Honeyman about plutonium solubility, the AME researchers concluded in their final report that virtually all plutonium in the Rocky Flats environment is in the form of non-soluble plutonium-oxide particles that can be moved by wind or water, that is, by the physical processes of erosion and sediment transport. This conclusion, based mainly on computer modeling, is very close to what Litaor had said a decade earlier. But the AME researchers differed strongly from Litaor as well as the from the findings of Smallwood and the grass research at the Savannah River Site in concluding that plutonium and americium left behind at Rocky Flats “are relatively immobile in the soil and groundwater because of their low solubility and tendency to sorb [attach] onto soil.”
On the basis of this conclusion, Clark and his colleagues can rightly claim that the AME contributed substantively to the final legally binding Rocky Flats Cleanup Agreement (RFCA) adopted in June 2003. RFCA requires cleanup of concentrations of plutonium and americium in the top three feet of soil in excess of 50 picocuries per gram (a picocurie is one trillionth of a curie). But it allows concentrations of 1,000 to 7,000 picocuries per gram at levels 3 to 6 feet below the surface, and puts no limit on the quantity allowed below 6 feet. In adopting these standards for cleanup, DOE and the regulators relied on the AME conclusion that plutonium left in soil at Rocky Flats would remain “relatively immobile” and thus posed no significant public-health risk.
But plutonium at Rocky Flats does move
The AME team’s conclusion of inconsequential plutonium migration at Rocky Flats flies in the face of one of their own reports. This report maintains that cleanup of plutonium in the soil at Rocky Flats even to citizen-recommended 10 picocuries per gram, rather than the 50+ actually adopted, would result in conditions of either a 10-year or a 100-year storm in failure at certain downstream areas to meet the Colorado State standard for plutonium in surface water of 0.15 picocuries per liter. This contradictory report, though it was part of the AME work, is not even cited in the final summary report of the AME project.
Twice in 1997, before this wayward report was written, the quantity of plutonium in Walnut Creek at the downstream boundary of the Rocky Flats site exceeded the state standard. This occurred on several subsequent occasions. The exact source of this plutonium was never identified. The problem is being handled with engineered controls that divert and dilute the water. Can maintenance of such controls be expected to outlast the plutonium?
Research done elsewhere counters the AME “relatively immobile” conclusion
The AME conclusion that migration of plutonium oxide at Rocky Flats would be insignificant is countered by findings at other locations. A report on plutonium transport at the site of the then-proposed Yucca Mountain nuclear waste repository asserts that plutonium “in oxidized form . . . can be quite mobile.” Important recent research has focused on the propensity of minuscule plutonium oxide particles to attach to submicrometer-size colloids consisting of organic or inorganic compounds. Such colloids can transport the plutonium considerable distances in groundwater. Annie B. Kersting et al. reported that plutonium released from an underground bomb test at the Nevada Test Site moved at least 1.3 kilometers (0.8 mile) in 30 years, with “colloidal groundwater migration” the likely means of transport. A recent study concludes that colloidal transport accounts for the migration of plutonium more than 4 kilometers (2.5 miles) in about 55 years in the subsurface environment at the Mayak facility in Russia. Other studies show similar long-distance plutonium transport in the subsurface environment at DOE’s Los Alamos and Savannah River sites. Kersting says regarding the Mayak findings, “we need to get away from this idea that plutonium doesn’t move, because it does.”
Mayak and Savannah River are very wet environments, the Nevada Test Site and Los Alamos very dry ones. Rocky Flats resembles the latter two more than the former. If plutonium attached to colloids can move long distances quickly at all these locations, cannot the same thing happen at Rocky Flats? The AME team thinks not, because, in Honeyman’s words, “the very properties that make some compounds good candidates for colloidal transport – low solubility and high particle reactivity – limit the amount of contaminants that can be transported.”
Another location where plutonium may be migrating rapidly is at DOE’s Idaho National Laboratory. From 1954 until 1988 large volumes of waste highly contaminated with plutonium were sent from Rocky Flats to the Idaho facility where the waste was dumped in shallow pits on the assumption that many millennia would elapse before the plutonium could percolate down the 600 feet to the Snake River Plain aquifer, the principal water source for large agricultural areas in Idaho. However, a graph published in a National Academy of Sciences report shows dramatic changes in estimates of how long it will take for the plutonium to reach the aquifer, from an estimate of 80,000 years in 1965 to one of 30 years in 1997. Asked about this, the AME researchers said two things: First, they assert but don’t demonstrate that the National Academy’s graph “was developed to refer to contaminants in general, and not plutonium in particular.” The burden of proof rests with them. Second, they say that knowledge about actinide migration at INL is deficient because that site has not had the benefit of the kind of work done at Rocky Flats by the AME project.
The AME group’s claim at being at the cutting edge of science is refuted by the ongoing work of Annie B. Kersting, whose finding of rapid transport of plutonium in groundwater at the Nevada Test Site was mentioned above. Since reporting that finding in 1999, Kersting, a geochemist at DOE’s Lawrence Livermore Laboratory, has intensified her research on actinide migration because of its significance at various sites worldwide, including Rocky Flats. According to a recent article about her work, it is driven by the recognition that, despite very low concentrations of actinides transported from the original source, their “long half-lives combined with their high toxicity make them of particular concern.” Thanks to her team’s research on plutonium, “the most perplexing element on the periodic table is slowly losing some of its mystery about how it travels underground faster and further than anyone at first expected.”
What about the long-term?
Given the 24,110 year half life of plutonium-239 and the danger it poses if minuscule particles are taken into the body, the cleanup at Rocky Flats, based as it is on the work of the AME team and done with their imprimatur, looks like a short-term solution to a long-term problem. The AME researchers, with all their confidence in modeling, made no effort to predict conditions at Rocky Flats 500 years from now, much less 10,000 or 100,000 years from now.
The most persistent criticism of the AME work is that the researchers relied mainly on computer modeling to reach their conclusion that plutonium left in the environment at Rocky Flats will be relatively immobile. Future sampling could show whether the modeling was correct or flawed. But adequate future sampling is not likely. The affected public thus may never know the validity or invalidity of the AME work. The consequences are not minor, since the government intends to allow public recreation on the Rocky Flats site.
The authors of “Science-based cleanup of Rocky Flats” write with certitude about realms of knowing that are replete with uncertainties. People of the future, whether near or distant, are not well served by the kind of cleanup done at Rocky Flats, even if it is “science-based.” In a situation like that at Rocky Flats, what is the measure of good science? What would responsible science look like? One doesn’t have to be a certified scientist to venture an answer to this question.
 David L. Clark, David R. Janecky, and Leonard J. Lane, “Science-based cleanup of Rocky Flats,” Physics Today (September 2006), pp. 34-40.
 One curie is the quantity of any radioactive material that emits 37 billion bursts of radiation per second.
 M. Iggy Litaor, The Hydrogeochemistry of Pu in Soils of Rocky Flats, Colorado: Summary,” Public Presentation, Denver, May 15, 1996; and Litaor, “Open Letter to the U.S. Fish & Wildlife Service concerning its draft plan for the Rocky Flats National Wildlife Refuge,” March 10. 2004.
 “Technical and Peer Review” of M. Iggy Litaor’s work by Bruce D. Honeyman et al. (Subcontract No. KH 353044ED3), September 22, 1995.
 M. Iggy Litaor to Bruce D. Honeyman, November 1, 1995.
 Record of Meeting Notes, Actinide Migration Status Report, August 20, 1997.
 This author once sent a letter to Mr. Honeyman seeking documentation of misleading remarks he had made in an AME public meeting. A reply came not from him but from John Rampe, a DOE official, saying that in the future any concerns regarding things said by AME team members should be addressed not to them but to Mr. Rampe or to Christine Dayton, the AME supervisor at Kaiser-Hill. The documentation I sought was thus never provided, and Mr. Honeyman was allowed to duck his responsibility to be forthcoming with the public.
 Shawn Smallwood, “Soil Bioturbation and Wind Affect Fate of Hazardous Materials that Were Released at the Rocky Flats Plant, Colorado” (November 23, 1996), Report submitted for plaintiff’s counsel in Cook v. Rockwell International, United States District Court, District of Colorado, No. 90-CV-00181; see also the transcript of Smallwood’s appearance in court in this case, pp. 3912-4130. Arnie Heller, “Plutonium Hitches a Ride on Subsurface Particles,” Science & Technology Review, Lawrence Livermore National Laboratory, October/November 2011, pp. 16-18.
 Smallwood et al., “Animal Burrowing Attributes Affecting Hazardous Waste Management,” Environmental Management, vol. 22, no. 6, 1998, pp. 831–847.
 Kaiser-Hill Co., Actinide Migration Evaluation Pathway Analysis Summary Report, ER-108 (April 2004), p. 23.
 D. I. Kaplan et al., “Upward Movement of Plutonium to Surface Sediments During an 11-Year Field Study, SRNL-STI-2010-00029, January 25, 2010. http://sti.srs.gov/fulltext/SRNL-STI-2010-00029.pdf
 Kaiser-Hill Co., Actinide Migration Evaluation Pathway Analysis Summary Report, ER-108 (April 2004), p. 28; see p. 24.
 Kaiser-Hill, AME Pathway Analysis Summary Report, ER-108 (April 2004), p. 28.
 For a critique of the cleanup including the risk calculation on which it is based, see my “Rocky Flats: The bait and switch cleanup,” Bulletin of the Atomic Scientists (January/February 2005), pp. 50-57. http://www.rockyflatsnuclearguardianship.org/leroy-moores-blog/papers-by-leroy-moore-phd-2/
 Establishing the cleanup level for plutonium in soil at 10 picocuries per gram or less was recommended in a report prepared for the Rocky Mountain Peace and Justice Center by Arjun Makhijani and Sriram Gopal, “Setting Cleanup Standards to Protect Future Generations: The Scientific Basis of the Subsistence Farmer Scenario and Its Application to the Estimation of Radionuclide Soil Actions Levels for Rocky Flats” (Takoma Park, MD: Institute for Energy and Environmental Research, December, 2001). http://www.ieer.org/reports/rocky/toc.html
 Kaiser-Hill Co., Report on Soil Erosion and Surface Water Sediment Transport Modeling for the Actinide Migration Evaluation at the Rocky Flats Environmental Technology Site, 00-RF-01823/DOE-00-93258 (August 2000), p. 51.
 Kaiser-Hill, AME Pathway Analysis Summary Report, ER-108 (April 2004).
 J. E. Law, Rocky Mountain Remediation Services, L.L.C., Memo to D. C. Shelton, K-H. Environmental Compliance, dated August 18, 1997, Re: Recent elevated plutonium and americium in water at RFCA point of compliance, Walnut Creek at Indiana Street.
 Yucca Mountain Site Description, TDR-CRW-G5-000001, Rev 01 ICN 01 – 10. Factors Affecting Radionuclide Transport (http://www.ymp.gov/documents/m2nu_a/sect10/sect10-01.htm).
 A. B. Kersting et al., “Migration of plutonium in ground water at the Nevada Test Site,” Nature, vol. 397, no. 7 (7 January 1999).
 Alexander P. Novikov et al., “Colloid Transport of Plutonium in the Far-Field of the Mayak Production Association, Russia,” SCIENCE, vol. 314 (27 October 2006); notes 6 and 8 of this article reference reports of similar long-distance plutonium migration at DOE’s Los Alamos and Savannah River sites; note 10 suggests greatly increased public health risk from such migration at Yucca Mountain. Kersting is quoted in David Biello, “Colloids in Russia: Have Plutonium, Will Travel,” Scientific American.Com, November 10, 2006.
 Bruce D. Honeyman, “Colloidal culprits in contamination,” Nature, vol. 397, no. 7 (7 January 1999), quoted in Christine S. Dayton, Kaiser-Hill, to LeRoy Moore, March 13, 2003 (03-RF-00441), with attachment from AME Advisory Group (CSD-004-03).
 For the graph and discussion, see Michelle Boyd and Arjun Makhijani, “Poison in the Vadose Zone: Threats to the Snake River Plain Aquifer from Migrating Nuclear Waste” http://www.ieer.org/sdafiles/vol_10/10-1/poison.html.
 Christine S. Dayton, Kaiser-Hill, to LeRoy Moore (03-RF-00441), March 13, 2003, with attachment (CSD-004-03).
 Arnie Heller, “Plutonium Hitches a Ride on Subsurface Particles,” Science & Technology Review, Lawrence Livermore National Laboratory, October/November 2011, pp. 16-18.
 After completion of the Rocky Flats cleanup, about seven square miles (roughly three quarters of the site) were transferred from the DOE to the U.S. Fish & Wildlife Service to manage as a wildlife refuge. FWS intends eventually to open the refuge for public recreation. For details on why this should not happen, see the four brief parts of chapter 8 of my “Plutonium and People Don’t Mix,” online at http://media.wix.com/ugd/cff93e_ba3aba3546e545278e4de4d8b3990c57.pdf http://media.wix.com/ugd/cff93e_a1b30d0398e943b0b92bb758a938f391.pdf http://media.wix.com/ugd/cff93e_2ad82029215b4aa6a63ab37cc0466a5f.pdf http://media.wix.com/ugd/cff93e_109f46d1cf6d46a490cb8bd2e56e4519.pdf
Today, Tuesday , May 17, 2016, the Rocky Flats Downwinders launched their health survey for people who reside downwind of Rocky Flats and may have health problems due to exposure to plutonium and other toxins released from Rocky Flats. See the following Denver Post article: http://www.thedenverchannel.com/lifestyle/health/residents-who-lived-near-rocky-flats-from-1952-and-1992-to-be-surveyed-about-health
5280, the Denver magazine, just published an article on Jon Lipsky, who led the FBI raid on Rocky Flats in 1989. After being away for several years, he now lives in the area and follows the Rocky Flats issue closely. To read the article, go to: http://www.5280.com/news/magazine/2016/04/rogue-agent?page=full
The condition of the Rocky Flats site after completion of the Superfund “cleanup” is crucial, because contamination remaining in the environment after the “cleanup” will affect the public health for eons. Especially is this true regarding plutonium particles, since the half-life of plutonium-239 (the primary contaminant present at Rocky Flats) is 24,110 years. It will remain radioactive for more than a quarter-million years.
Evidence of environmental crime at the site: In June 1989 the FBI and EPA raided the Rocky Flats plant to collect evidence of violation of federal environmental laws at the plant. To review this evidence of criminal behavior for a lawsuit brought against plant operator Rockwell International, a special grand jury was convened. However, in 1992, while the grand jury was in the midst of its review of the evidence, the Department of Justice reached an out-of-court settlement with Rockwell, in which major charges against the company were dropped. As part of the settlement, federal judge Sherman Finesilver sealed 65 cartons of evidence collected by the FBI and reviewed by the grand jury, documents containing data that should have been reviewed as part of the Rocky Flats “cleanup.” The federal government thus denied access by the public, the media or researchers to crucial information about alleged environmental crime at Rocky Flats. The judge ordered members of the grand jury not to reveal what they had learned in their review of evidence.
During the Superfund cleanup of the site the public repeatedly called for release of the sealed records. Finally, Senator Mark Udall asked U.S. Attorney for the District of Colorado John Suthers to make the documents available to the two government agencies that were regulating the cleanup, the EPA and the Colorado Department of Public Health and Environment. Though these documents were made available to them, they were never reviewed by either agency. According to “Rocky Flats Brouhaha,” an article by Ann Imse in the Rocky Mountain News, August 20, 2004, no one from these two agencies even requested to see the documents. Thus the environment at the Rocky Flats site was cleaned up without any review of documents about environmental crime at the site. Wes McKinley, foreman of the grand jury, and attorney Caron Balkany, co-authors of The Ambushed Grand Jury; How the Jujstice Department Covered Up Environmental Crimes and How We Caught Them Red Handed (NY: Apex Press, 2004), concluded that the real purpose of the FBI raid at Rocky Flats was not to reveal environmental law-breaking but to cover it up by collecting and sealing the evidence.
Map showing where waste had been deeply buried on the site: Former Rocky Flats worker Jerry San Pietro was told by his uncle, an older worker at the plant, that he had seen Caterpillar D9 bulldozers digging trenches so deep at various locations on the Rocky Flats site that the enormous bulldozers dropped completely out of site. The purpose of the trenches was to bury radioactive waste and then to cover and forget it. San Pietro’s uncle said that a map showing the locations of these deep burials existed. San Pietro, who was a radiation monitor at the site, and a colleague repeatedly asked plant authorities to let them see this map. Their request was repeatedly denied. But they persisted. Finally, one day they were told to come to a particular location at a specific time. When they arrived, they were met by several plant officials who told them they would be allowed into a locked room to see the map for ten minutes, provided they did not go with pencil and paper and made no record of what they saw. Thus they saw a map showing various locations on the site where plutonium waste had been buried 20 to 30 feet below the surface.
During the Superfund “cleanup” San Pietro tried to bring attention to what he had seen on this map, because the “cleanup” focused only on what was in the top 6 feet of soil and didn’t deal with the deep burials. He was ignored by those doing the “cleanup” or regulating it, as well as by state officials and members of Congress. Convinced that a great deal of waste remains deeply buried at the site, he calls Rocky Flats “the largest unlicensed nuclear burial site in the United States.” (For San Pietro’s story, see Transcript OH1384v in the Rocky Flats Oral History Collection, Maria Rogers Oral History Program at the Carnegie Branch of the Boulder Public Library.) When San Pietro contacted me about this, I made a Freedom of Information Act (FOIA) request for the map he had seen. In response, the Department of Energy sent not the map he described but one with which I was familiar showing well-known disposal sites, none of which were deep burials. San Pietro thinks the map showing the deep burials was probably destroyed.
Migration of plutonium in soil: Those who designed the “cleanup” for Rocky Flats relied on the conclusion of the multi-year Actinide Migration Evaluation (AME) that plutonium in the soil at Rocky Flats remains “relatively immobile.” (Kaiser-Hill Co., Actinide Migration Evaluation Pathway Analysis Summary Report, ER-108, April 2004, p. 28.) The AME results were based primarily on computer modeling rather than on empirical observation. By contrast, environmental engineer M. Iggy Litaor, with instruments he had set up on the Rocky Flats site to make measurements, in the unusually wet spring of 1995 detected significant horizontal migration of plutonium in shallow subsurface soil at Rocky Flats. His stunning real-time discovery attracted a great deal of attention because it countered the Rocky Flats orthodoxy that plutonium in soil remains in place. He produced a widely published preliminary summary of his findings – ‘The Hydrogeochemistry of Pu in Soils of Rocky Flats, Colorado: Summary,” Public Presentation, Denver, May 15, 1996. Despite his stunning, unexpected finding – or because of it – he was involuntarily terminated and replaced by the AME team. Back in his native Israel, he tried for about two years with my assistance to get the Department of Energy to provide him with computerized data he needed to complete a publishable report of his findings. They ignored his request. He thus never produced a report documenting what he had found. Absent such a report in a technical journal, it’s as if the movement of plutonium Litaor directly observed in the saturated conditions at Rocky Flats in the spring of 1995 never happened.
In the Superfund cleanup (1995-2005), the Rocky Flats orthodoxy triumphed truth. The government agencies responsible for the cleanup – the Department of Energy, the EPA, and the Colorado Department of Public Health and the Environment – made no reference to Litaor’s finding. Instead, they incorporated into the cleanup the AME assumption that plutonium in the soil at Rocky Flats remains “relatively immobile.”
Despite the Rocky Flats orthodoxy, studies showing migration of plutonium are abundant. For references on recent findings of plutonium migration in soil at various sites, see Alexander P. Novikov et al., “Colloid Transport of Plutonium in the Far-Field of the Mayak Production Association, Russia,” SCIENCE, vol. 314 (27 October 2006), notes 6 and 8. Research done by Annie Kersting of DOE’s Lawrence Livermore National Laboratory confirms colloidal transport of plutonium; see her “Plutonium Hitches a Ride on Subsurface Particles,” Science & Technology Review, LLNL, Oct./Nov. 2001, pp. 16-18. The conflict between Litaor and the AME is dealt with at greater length in my “Science compromised in the Cleanup of Rocky Flats,” on line at http://media.wix.com/ugd/cff93e_1ae76276c5814bf8aa21dc530da95857.pdf .
In my October 20, 2015, entry I at first stated that the Jefferson Parkway had been canceled. This not true. A key highway transport group, the WestConnect Coalition, has withdrawn its support from the parkway. What follows is the latest article from the Golden Newsletter, explaining in detail the current situation with the proposed parkway.
Q&A REGARDING WESTCONNECT COALITION
From: Dan Hartman, 10/20/15
As I mentioned at [Golden City] council on the 8th we had some concerns with the information in Dick [Sugg]’s article posted in your news letter about the WestConnect process and the Jefferson Parkway. I met with Dick and discussed it and he is updating information. I will continue to work with Dick regarding his concerns about the Jefferson Parkway, and specifically using public money to build it.
This Q and A sheet will give your readers the best information on the WestConnect process and Golden’s participation.
DRAFT 10/07/15 City of Golden
Questions and Answers Regarding the WestConnect Coalition Process
Members of the community have recently asked about the WestConnect Coalition, a regional transportation forum working to improve transportation through Golden and the entire northwest region of the Denver metropolitan area. Specifically, a resident asked whether the Coalition has eliminated the possibility of constructing the proposed Jefferson Parkway between SH 128 in Broomfield to SH93 in Arvada. The answer is no. A decision whether to build or not build the Jefferson Parkway will be made outside of the WestConnect process. Nothing the WestConnect Coalition is doing is designed to make the Jefferson Parkway more or less likely.
What is the West Connect Coalition?
The WestConnect Coalition is a cooperative effort of cities, counties, and agencies like the Colorado Department of Transportation to analyze mobility, environmental, and economic issues and solutions from C-470 and Kipling north to Boulder. Members of the Coalition include the City of Golden, Jefferson County, the City of Arvada, CDOT, the City of Boulder, the City of Lakewood, Douglas County, the City of Boulder, the Town of Morrison and the Town of Superior. Under the Coalition’s Charter, decisions will be made by consensus.
Is the Golden Plan part of the WestConnect study?
Yes, the Golden Plan will be considered as improvements to SH93 and U.S. 6. The City of Golden has also indicated that it is willing to consider implementing the Golden Plan in phases to secure its benefits as soon as possible. For example, the U.S. 6 and 19th Streetinterchange is proceeding now.
Has the WestConnect Steering Committee eliminated the Jefferson Parkway as a segment of the proposed “Western Beltway”?
No. The WestConnect Steering Committee concluded that the decision of whether to build the Jefferson Parkway should be made outside of the WestConnect process. Thus, WestConnect is neither eliminating nor promoting the Jefferson Parkway.
Will any analysis of the Jefferson Parkway be done in the WestConnect Planning and Environmental Linkages Study?
Yes, it is important to understand the effects of the proposed Jefferson Parkway on other highways in the region, such as U.S. 6 and SH 93, and the environment. Similarly, it is important to understand how different options for roads in the WestConnect study area (like U.S. 6 or SH 93) would have on the Jefferson Parkway concept. As a result, the WestConnect Study will consider two scenarios for the Jefferson Parkway: (1) that it will be built as proposed by the Jefferson Parkway Public Highway Authority; and (2) that it will not be built.
Will the WestConnect Planning and Environmental Linkages Study consider alternatives or modifications to the Jefferson Parkway?
No. The Study will only look at scenarios with and without the proposed Jefferson Parkway. Any consideration of alternatives to the Jefferson Parkway (such as different numbers of lanes, alignments, or interchange locations) will be done outside of the WestConnectCoalition process.
Who will make the decision about whether to proceed with the Jefferson Parkway and how will it be made?
The Jefferson Parkway Public Highway Authority will make the primary decision whether to proceed with that highway. However, to connect to SH 93, SH 72 and SH 128, the Authority will need permission from CDOT, which it will make only after analysis of the environmental impacts of the connections. The Authority has applied for this permission through the CDOT “1601” process. CDOT has assured that the public will have an opportunity to comment on the Authority application and the CDOT environmental analysis. In addition, the Authority will need approvals from sources of funds, such as private investors or public entities.
Has the WestConnect Coalition made any determinations regarding funding for the Jefferson Parkway?
No. Financing the Jefferson Parkway is outside of the scope of the WestConnect process. The Jefferson Parkway Public Highway Authority is still seeking private and public funds to construct the Jefferson Parkway. The WestConnect Coalition will not make any decisions regarding whether and how the Jefferson Parkway could be financed.
How can I find out more about the WestConnect Coalition?
Soon, the Coalition will have a stand-alone website. For now, some information on the Coalition can be found on the Jefferson County website, at http://jeffco.us/transportation-and-engineering/westconnect
Sunday, October 18, 2015, was a ceremony commemorating artist Jeff Gipe’s “Cold War Horse.” He prepared the horse for the 25th anniversary of the FBI raid on Rocky Flats event at the Arvada Center in June 2014. The large horse sculpture wears a red hazmat suit, goggles and a gas mask — to protect it from plutonium blowing on the breeze at Rocky Flats. He wanted to place the horse on a permanent location near the Rocky Flats site. Earlier this year he finally found a very good location on a high point along Highway 72, a short distance west of Indiana St., not far south of the Rocky Flats site, just across the road from the Candelas development. In the summer someone vandalized the horse, pulled it down and hammered on it, badly damaging it. Jeff Gipe rebuilt it, remounted it, put a fence around it with motion-sensitive cameras and lights. And Sunday, October 18, he held a commemoration ceremony. Speakers were author Kristen Iversen, Jon Lipsky who led the FBI raid in 1989, Wes McKinley who was foreman of the Rocky Flats Grand Jury, Randy Sullivan a former fireman at Rocky Flats and myself. Presiding was Eric Fretz of Regis University. Here is a copy of the poem I read.
Horse Sense about Jeff Gipe’s Horse
Jeff Gipe’s Cold War Horse
signifies a problem,
the problem of Rocky Flats,
more specifically the problem
of plutonium at Rocky Flats.
This problem is denied
by government personnel who favor
opening the Rocky Flats Wildlife Refuge
to the public, with some on horseback.
These government personnel do not honor
the truth about plutonium,
though they know that some quantity
remains in the environment
after the purported cleanup of the site.
They know too that the incomplete cleanup was done
against the will and wisdom of concerned people.
Of course it was impossible to remove
all the plutonium buried in soil on the site,
but the responsible parties made no effort to remove
as much as possible with existing technology.
Instead, they chose a quicker, cheaper cleanup.
One more point about the so-called cleanup.
When the EPA and the Colorado Department
of Public Health and the Environment
regulated the cleanup, the U.S. attorney
gave them the opportunity to examine
63 cartons of evidence of environmental crime
committed at Rocky Flats, documents collected
by the FBI, reviewed by a special grand jury
and sealed by the federal court.
Instead of reviewing this data the agencies declined,
preferring a cover-up to a real cleanup.
And now they expect us to forget
and to let the site be opened to the public.
No one can say
what beings will be harmed
by plutonium particles left behind –
particles too small to see
but available to be inhaled.
It is well known that once taken into the body
plutonium lodges in a specific location,
such as lung, liver, bone, brain, the gonads.
Thus lodged it will steadily bombard
with radiation the cells of nearby tissue,
typically for the rest of one’s life.
Tom K. Hei and colleagues at Columbia University
reported 18 years ago (in 1997) in the Proceedings
of the National Academy of Sciences
that inhaling a single particle of plutonium
can damage a cluster of cells
and that replication of these cells
constitutes genetic damage
that may not only wreck the individual’s health
but also harm future generations.
Instead of serving a harmful industry
and fostering an economy of urban sprawl,
why don’t government officials
act on the basis of such studies?
They are not ignorant,
but they do ignore the reality of such studies
and gamble with the health and well-being
of all creatures near Rocky Flats.
This is not a temporary problem,
since the plutonium-239 in the environment
remains radioactive for more than
a quarter-million years.
It will still be radioactive long after
the Rocky Flats Wildlife Refuge
ceases to exist.
According to some random schedule
animals, plants and water will bring
buried plutonium to the surface
where the wind common at Rocky Flats
can distribute it near and far,
ready to be inhaled
by some unsuspecting person
who decades later may have cancer
or some other ailment.
The government’s gambles
with the permanent problem of plutonium
at Rocky Flats are careless.
Jeff Gipe’s horse reminds us
of the necessity of being careful.
This is the essence of Nuclear Guardianship.
Thanks be to Jeff Gipe.
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.
(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:
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.”
 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.
 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.
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.
 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).
 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
 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.
 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
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:
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.