the Peace Farm
Getting to "cleanup" at PantexCommunity groups at many Department of Energy (DOE) sites struggled over the last two years with efforts to weaken environmental cleanup standards by way of a program called Risked Based End States (RBES). Those of us working on environmental issues around Pantex worked to keep up with the push by the plant to meet a May 2005 deadline for completion of environmental investigations and the deadlines of a state-imposed compliance plan.
This summer marked a major turning point for environmental restoration activities at Pantex. In 1999, the state environmental agency, adopted new regulations for environmental remediation. Facilities that could complete their investigations, defining the contaminants and areas of contamination, by May 2005, could be "grandfathered" under the old rules; those that could not would be required to use the new rules.
For Pantex, failure to meet the deadline would have meant redoing a large number of environmental studies, adding both substantial financial costs and time to the remediation activities.
For community activists and technical experts, the last year involved evaluation of numerous investigation reports, numb>ering thousands of pages, under tight deadlines Because the "old" rules require cleanup to background levels in many areas, the definition of background became an important and contentious area.
Nationally, the RBES was the latest in a series of DOE efforts over more than a decade to dodge responsibilities and weaken standards for cleanup of both chemical and radioactive contamination. With cleanup projects behind schedule and over budget at its largest and dirtiest sites, DOE looked for a shortcut. Especially at facilities slated for closure, it would leave "dirtier" sites. In several locations, implementation of the RBES would have invalidated existing agreements with stakeholders and regulators.
Alliance for Nuclear Accountability groups at many of these locations worked hard to bring the program into the open and reestablish public accountability. They were especially critical of poorly defined terms and the lack of public participation. Among those poorly defined terms were such key ones as "risk," "end state," "end state vision," and "risk-based end states."
In many cases, activists around DOE facilities learned only indirectly about the existence of the RBES program. At Pantex, for example, the program was never voluntarily raised at a public meeting, and only came into discussion l)ecause of questions raised by meeting participants.
In several locations, community activists were joined in their criticism by state and federal regulators. In California, for example, regulators said the RBES program for the Lawrence Livermore National Laboratory "sacrifices long-term effectiveness and may pose a long term liability for NNSA," and that the "DOE'S definition of risk is short- sighted and short-term." For the Fernald site in Ohio, regulators indicated they were not "supportive of any of the proposed items on the master list" and recommended "no further pursuit of the actions proposed in the RBES document."
At Pantex, the RBES Vision Document indicated that the program was essentially no different from the existing "Accelerated Cleanup Plan that is based risk reduction rules promulgated by the Texas Administrative Code " and that "variances between the RBES and Accelerated Cleanup Plan end state are not anticipated."
George Rice, on behalf of STAND of Amarillo, reviewed the risk-reduction guidance document for Pantex, found that there were serious problems in the way background for groundwater had been established. For example, "some of the wells used to establish background concentrations are on Pantex property or down gradient of Pantex. Thus,they may have been affected by contaminants emanating from the plant."
Rice was also critical of the use of unfiltered samples for determining concentrations of metals, the failure to use adequately sensitive analytical methods, and the overestimation of background concentrations for thallium and chromium.
The Texas Commission on Environmental Quality (TCEQ) issued a "Pantex Project Milestone Summary Report," essentially accepting the investigative documents submitted by the plant, but carrying many projects into the next phase, the Baseline Risk Assessments. In the document it is acknowledged that "uncertainties are inherent and will always need to be managed."
Community activists are concerned that the baseline risk assessment process will be used to whitewash both human and ecological risks and that major data gaps still exist, particularly in regard to radium.
by Sharan L Daniel
"There appears to be no threshold below which exposure can be viewed as harmless," said Abrams, professor emeritus of radiology at Stanford and Harvard universities and a member in residence at the center for International Security and Cooperation (CISAC) in the Freeman Spogli Institute for International Studies.
Abrams was one of two physicians and the only member from Stanford on the committee of 16 international experts in fields including epidemiology, radiation biology, genetics, cancer biology, radiology and physics. As a radiologist, Abrams said he "was able to serve as a bridge between the epidemiologists and the biologists on the committee, whose approaches to risk were based on completely different data sets."
The landmark 700-page advisory report to the U.S. government, titled "Biological Effects of Ionizing Radiation (BEIR) VII, " was completed in July, near the eve of the 60th anniversary of the Hiroshima and Nagasaki bombings. It is the seventh report in a series since the 1945 bombings to investigate the effects of low-level radiation exposure. The reports provide U.S. policymakers and health agencies with authoritative risk estimates. Beginning with the first BEIR study, published in 1956, the reports have used data from the Life Span Study by the Radiation Effects Research Foundation in Japan, which continues to track developments among a cohort of 120,000 people who were in Hiroshima or Nagasaki at the time of the bombings, as well as other radiation exposure studies.
The NRC convenes BEIR committees periodically, at the request of U.S. Government agencies, to decide whether sufficient new information is available to merit an updated study, and if so, to conduct it. This process has yielded BEIR reports I, III- V and VII, which assess low-level radiation risks in general, and BEIR II and VI, which focus on radon gas effects.
BEIR Vll, sponsored by the U.S. Departments of Defense, Energy, and Homeland Security and the U.S. Nuclear Regulatory Commission, "provides the most up-to-date, comprehensive estimates of risk for cancer and other harmful health effects from low- dose radiation," according to the NRC. The committee reviewed not only new data on A-bomb survivors and their offspring, but also 1,300 other studies on radiation exposure at the cell, animal and human levels, Abrams said. Since the 1990 publication of BEIR V, "substantial epidemiologic and experimental research has yielded a wealth of new information on radiation-induced cancer, as well as other adverse health impacts," he added.
The new report confirms that even very low doses of radiation can produce cellular injury. The committee defined "low-dose" as a range from near zero up to about 100 milliSieverts, about 10 times that from a CAT scan, 1,000 greater than a mammogram and 30 to 40 times the annual background exposure a person encounters. Background radiation from the natural environment, including outer space, and basic activities such as eating, drinking and breathing, accounts for about 82 percent of human exposure, while man-made radiation from sources including medical X-rays and consumer products accounts for the remaining 18 percent.
Progressive exposure to radiation causes DNA damage, Abrams said, which correlates with an increased risk of developing a variety of cancers. While the report examined a range of potential health risks, it focused on causal relationships to solid cancers in humans.
The report is among the first of its kind to include detailed estimates for radiation- induced cancer incidence and mortality, Abrams said. The report enhances prior risk estimates for solid cancer and leukemia, using risk models based on a gender and age distribution similar to that of the entire U.S. Population. The committee estimated the excess lifetime risks for 12 categories of cancer.
Examining data on the children of A-bomb survivors, the committee did not find genetic effects in children whose parents had been exposed to radiation from the bombs, but exposure of the fetus during pregnancy was associated with significant damage to the brain, including mental retardation. Studies of mice and other organisms have produced extensive data showing that radiation- induced cell mutation in sperm and eggs can be passed to offspring, the committee reported. Such mutations might also be passed on the human offspring, but their detection might require a survivor population higher than that of the children of A-bomb survivors.
The report identified key areas for further research:
Determining various molecular markers of radiation-induced DNA damage. Examining adverse genetic impacts, with particular emphasis on hereditary effects. Elucidating the specific role of radiation in the development and growth of tumors. Clarif^ng the genetic factors that influence radiation response and cancer risk, as well as the correlation between radiation and other diseases such as heart disease and stroke. Exploring the health effects of radiation exposure to patients in the practice of diagnostic radiology, such as repeated screening CT scans and in high-risk occupations such as nuclear industry workers and uranium miners. Conducting epidemiologic studies of workers in these high-risk jobs as well as persons exposed in key regions of the former Soviet Union and remaining atomic bomb survivors.
Studies in these areas could inform the next BEIR report, when enough new data accumulate to warrant an update.
For Abrams, completion of BEIR VII adds to an already distinguished career. The director of Diagnostic Radiology at Stanford in the 1960s, Abrams was the Philip H. Cook Professor and Chairman of [radiology at Harvard Medical School for 18 years before returning to Stanford in 1985 to join the (radiology Department and CISAC. He was a founder of the International Physicians for the Prevention of Nuclear War, which received the 1985 Nobel Peace Prize.
(from the Stanford Report, October 25, 2005)
Arundhati Roy, Sept. 2002 (War Talk, page 47.)