Risk-Based
End States at Savannah River?
Radioactive
Pollution Gets A Facelift
In 2002 the US Department of Energy
established a new program for the management and
clean up of the nation’s 29
radionuclide-contaminated atomic weapons
facilities. The program is called Risk-Based End
States, or RBES, and it is being implemented at
the Savannah River Site in South Carolina. The
RBES program is already affecting how clean up is
done, how much it costs, and how long it will
take. The establishment of risk into
environmental remediation is a warning to people
living near contaminated sites that their
communities may remain polluted forever.
Risk-based determinations of pollution’s
effect on human beings puts people’s lives
on the bargaining table because it allows
guesswork to determine the method and goal of
environmental restoration. Risk-based
decision-making poses questions such as: Who will
be harmed by the pollution? When will it reach
them? How much contamination is OK? What will it
cost to return the site to its original state?
Answers to such questions shift regulatory
agencies away from established, quantifiable
standards and into a murky realm of conditional
“end states.”
Citizens have a nominal voice in the RBES
process but are largely relegated to
“external participation” via state
regulators and SRS’s Citizens Advisory
Board. In April 2004 the Citizens Advisory Board
endorsed the concept of a risk-based end state at
SRS:
| The new vision for the
end state at the Savannah River Site
(SRS) when environmental cleanup is
completed by 2025 is that all of SRS land
will be federally owned, controlled and
maintained in perpetuity. SRS is a site
with an enduring mission and is not a
closure site. Additional missions will
continue under the National Nuclear
Security Administration (NNSA)
management. * |
The overall concept and
detailed documents which determine how the
Risk-Based End States program is developed is led
by a consortium of universities called CRESP, the
Consortium for Risk Evaluation with Stakeholder
Participation. CRESP is comprised of six academic
institutions: the University of Medicine and
Dentistry of New Jersey, Rutgers Universities,
the New Jersey Environmental Occupational Health
Sciences Institute, the School of Public Health
and Community Medicine at the University of
Washington in Seattle, Vanderbilt University in
Tennessee, and the University of Alaska at
Fairbanks.
CRESP is dedicated to “working to advance
cost-effective cleanup and greater stakeholder
understanding of the nation's nuclear weapons
production facility waste sites” by making
“risk a key part of [DOE] decision
making.” (webpage at
http://www.cresp.org/mission.html)
CRESP is funded by the Department of Energy
and has placed particular emphasis on the two
largest and most contaminated sites of the Cold
War legacy: Hanford in Washington State and the
Savannah River Site.
DOE’s previous environmental management
program at SRS was embodied in its Performance
Management Plan. For example, in 1999 the
Environmental Restoration Division had in place
80 enforceable agreements which were embodied in
the SRS Federal Facility Agreement for the F and
H areas. Under RBES, there are already five
“variances,” or exceptions to the
agreement, which are defined as “a
significant different cleanup approach or
different end state relative to the original
August 2002 SRS EM Program Performance Management
Plan.” *
| These variances
include * (1)
future land use and exposure scenario
modification,
(2) area risk
methodology and protocols,
(3) alternate disposal
for Pu-238 contaminated waste,
(4) in situ
decommissioning in lieu of demolition,
and
(5) "glass
durability" waste acceptance
criteria for high level waste (HLW)
federal repository.
|
Underground tanks at the
Savannah River Site store about 35 million
gallons of liquid high-level radioactive waste,
there are 262 radioactive and hazardous waste
sites, and 16 million cubic feet of solid
low-level radioactive waste is buried in trenches
in the sand. According to the SC Department of
Health and Environmental Control, wastes are
leaking from SRS and public drinking water is
already showing signs of such contamination.
Contamination at SRS includes radioactive
tritium, plutonium, and cesium and toxic arsenic,
cadmium, chromium, mercury, and lead. Radioactive
tritium has already been found in drinking water
70 miles downstream from SRS at Beaufort, SC. In
situ decommissioning as outlined in RBES
variance (4) would allow wastes to remain below
ground and would only add to the problem.
The risk-based method balances risk with cost,
according to the SRS Citizens Advisory Board:
| Furthermore, while a
RBES approach may ultimately reduce
cleanup costs, the RBES Vision is not
driven by cost considerations. [emphasis
added] * |
The US Department of Energy
should not be permitted to cut costs and leave
hundreds of millions of curies of dangerous
radioactive waste in the sands of South Carolina.
The Savannah River is vital to people who depend
on it for recreation, food and drinking water.
The DOE should clean up the mess and should not
endanger the lives of people living downstream
for generations to come.
* from “Risk
Based End State Workshop, Strategic and Legacy
Management Committee,” April 13, 2004
CLEAN UP,
DON’T BUILD UP!
BLUE RIDGE ENVIRONMENTAL
DEFENSE LEAGUE
www.BREDL.org ~
PO Box 88 Glendale Springs, North Carolina 28629
~ Phone (336) 982-2691 ~ Fax (336) 982-2954 ~
Email: BREDL@skybest.com
September 2004
|
