Letter to David Lucas

This is a letter that was sent to David Lucas, manager of Rocky Flats National Wildlife Refuge. Randy Stafford sent the letter several months ago, but there has been no response.

Mr. David Lucas
Manager, Rocky Flats National Wildlife Refuge
United States Fish and Wildlife Service
134 Union Boulevard
Lakewood, CO 80228

Dear David,
It was a pleasure to meet you and speak with you at Rocky Flats National Wildlife
Refuge “Sharing Sessions” numbers 3 and 4 over these last couple of months.
As I stated, I respect the good men and women of the United States Fish and Wildlife
Service, having had two uncles who spent their careers in the service as refuge
managers most of the time. My earliest memories of my uncle Ned Peabody were on
the refuge in Valentine, Nebraska. He finished his career at the Federal Center in
Lakewood, after long stints in Pierre, South Dakota and Brigham City, Utah.
And my uncle John Martin was the first manager of the Alaska Maritime National
Wildlife Refuge (AMNWR) and held that position for 20 years, from 1980 through
2000 (see https://www.fws.gov/news/ShowNews.cfm?ref=new-manager-foralaska-
maritime-national-wildlife-refuge&_ID=5568). Prior to taking that position,
my Uncle John lived on Adak Island beginning in 1976, and I actually visited him and
my Aunt Donna there in 1977.

David, I understand that you are in a tough position. You are trying to dutifully
implement a decision that was made by act of Congress in 2001 and passed down to
you through your agency and the sequence of decisions made in the 15 years since.
I’m writing to share with you that there is a precedent for operating a wildlife refuge
on a former nuclear site, and it didn’t turn out well in the long run, health-wise, for
the USFWS employees involved. That precedent is Amchitka Island in the Aleutians.
As you probably know, Amchitka Island was the site of underground nuclear bomb
testing by the Atomic Energy Commission in the late 1960s and early 1970s (see
https://en.wikipedia.org/wiki/Amchitka). Amchitka was part of the Aleutian
Islands National Wildlife Refuge since 1940, which was included in the AMNWR in
1980. Consequently my Uncle John had oversight responsibility for USFWS
operations on Amchitka as AMNWR Manager, and he and my Aunt Donna knew the
USFWS employees who worked on Amchitka because, frankly, there just aren’t that
many USFWS employees in the Aleutians. Furthermore those employees probably
reported up through my Uncle John once he became AMNWR Manager.

I asked my Aunt Donna whether she knew of any USFWS employees who had
worked on Amchitka and had developed cancer. This was her response:
Sometime you asked me if I knew any of the folks who got cancer on
Amchitka. The answer is yes. [name elided] ran the power plant there for the
USFWS for probably 20 years when we had the goose raising project out
there. He and his family lived at the old airport terminal and kept things
maintained and the power on. He got cancer and, sadly, so did his wife and
daughter. We lost touch with them when they moved away, but John heard
about some kind of investigation on the high cancer rates.

[name elided], who was the biologist-goose keeper out there, and lives here
now also got cancer, and his wife got breast cancer. We don't know if it is
related. I think he was contacted during that investigation. Maybe John can
add more knowledge when he gets this CC. So far, the previous goose keeper
has stayed healthy.
The investigation to which my Aunt Donna refers is most likely the Amchitka
Medical Surveillance Program (see

I wrote to that program’s Principal Investigator, Dr. Knut Ringen, to ask whether he is
aware of any USFWS employees affected by radiation on Amchitka, and this was his

I am aware of several US Fish and Wildlife Service workers who have spent
time on Amchitka. Unfortunately there are too few in number in our medical
program to make any kind of determination about cancer risk, and because
of the small number I cannot discuss any medical findings we have on them
without risking a violation of their privacy.
Amchitka is still under the stewardship of DOE, but is monitored by a
consortium led by the the Alaska Department of Environmental
Conservation, in which USFWS participates. DOE has provided funding for
this consortium.
I am sorry I cannot provide additional information.
Best wishes,
Knut Ringen, DrPH, MHA, MPH

That response suggests to me that Dr. Ringen is aware of the cases my Aunt Donna
reported to me.
I wanted to share this precedent with you because it is not likely a coincidence that
five out of six USFWS employees and / or their family members stationed on a
former nuclear site developed cancers later in their lives. It’s more likely causal.
Though I have not discussed this with him directly, I imagine my Uncle John may
carry that fact on his conscience, as a former manager of those employees. Would
you want to be in that position someday? Of knowing you had exposed USFWS
employees in your charge to cancer risks on a former nuclear site, which eventually
materialized into cancers?

I also asked my Uncle John for his thoughts on the federal government turning
former nuclear sites into national wildlife refuges, and this was his response:

You have hit a pet peeve of mine. The USFWS always was in the market for
getting more land to put in refuges. However, I felt we were dealing with the
devil when looking at DoD or DoE lands. Their idea was to do the minimum
cleanup and then transfer to the USFWS. Liability went with the land, of
course. I always thought the land should be “cleaned up” and kept by the
agency that screwed it up. They should be required to fence it and patrol it.
Of course, cleanup is the wrong term. We are really talking about risk
assessment and how much can you reduce the risk. One can never get it
down to the same risk level that existed before contamination.
Many people think that wildlife can get along with a higher risk than people.
That is not true since wildlife is mobile and they could carry some of the risk
across boundaries. I believe that land such as the flats should be cleaned up
to the lowest risk, fenced, and patrolled to keep people out. It should not be
transferred to another agency. These fenced plots of land would then become
reminders to the public that they need to know what the government is
doing on their lands with radiation, chemical and biological weapons testing,
etc. We don’t need to put refuge signs around it since to most people that
would indicate beautiful pristine lands and would be an attractive place to
live next to. It is counter- productive. Like a playground built on an old dump.
That is from a man who spent his career in the USFWS (he's long retired) in Alaska
and had oversight responsibility for AMNWR operations on Amchitka. He also
testified before Congress when the Exxon Valdez oil spill happened.

David, I know you are just trying to do your job. I respect that, and I respect your
career choice and professional field. I really do admire the USFWS and its mission
and its people.

But in the case of Rocky Flats, I believe as a concerned citizen that the potential
consequences of exposing humans to the soil on the refuge grounds are too grave to
justify any amount of risk-taking. We’re talking about human lives here. Maybe
your employees’ lives, or even your own life or your family members’ lives. We’re
talking about suffering. My relative was diagnosed with breast cancer this year
(incidentally she grew up in Arvada, downwind of Rocky Flats), and I personally
took her to two surgeries to excise malignant tissue from her body, and I personally
took her to her radiation therapy appointments. Why take any action that might
cause anyone to go through that kind of suffering, that they otherwise might not
have to go through? It’s just not right; it’s not humane; it’s not reasonable.

If you have not already done so, I would urge you to read the books about Rocky
Flats. I’m referring to The Ambushed Grand Jury by Wes McKinley and Caron
Balkany, and Full Body Burden by Kristen Iversen. I think you will see that there is
much to be concerned about. In Full Body Burden, for example, there is an account
of controlled burns of grasses on the Rocky Flats site which drastically increased
offsite radiation counts for several weeks. That would seem to suggest that the
plant materials contain radioactive particles, either on their surface in dust, or
perhaps brought up through their roots from the subsurface soil, which becomes
airborne if they burn. It just does not make any sense for humans to disturb the soil
at that site – at all.

Thank you, David, for taking the time to read what I wanted to share. I don’t want to
see anybody suffer ill health or death as a result of the decision to turn Rocky Flats
into a wildlife refuge. The only precedent we know of didn’t turn out well for the
USFWS employees involved. It’s not too late to change the decisions. The soil does
not have to be disturbed. Humans do not have to visit the site.

With Best Regards, and Most Sincerely,
Randy Stafford
Littleton, CO