Press Release

Table of Contents

Acknowledgements

Summary and Recommendations

1. Introduction

2. The concept of the critical group and the maximally exposed individual

3. Description of the subsistence farmer scenario

4. International use of the subsistence farmer approach

5. Reasonableness of the subsistence farmer scenario on occupational grounds

6. Relation of the subsistence farmer scenario to Radionuclide Soil Action Levels (RSALs) at Rocky Flats

7. Erosion of the subsistence farmer scenario

8. The Radioactive Wildlife Refuge

9. Enforcement for the eons

10. Conclusions and Recommendations

11. References

Today the term subsistence farmer often connotes a poor person scratching out a meager living from the soil. But this is not the assumption in radiation protection regulations. They assume that a subsistence farmer will eat a good diet, which will be locally grown with local water supply. It is not at all fanciful to consider a future where people might choose to grow most of their own food and, thanks to advanced technology, be able to do so very efficiently and in a sustainable way. Such individuals may even be able to devote most of their time to other pursuits and might be economically well off even by today's U.S. standards. Yet they would fit the radiological description of a subsistence farmer scenario. The term "subsistence farmer" is a rather unfortunate one in that it usually connotes a poor person. A "self-sufficient" farmer might be more appropriate to describe the hypothetical person created by radiation protection regulations.

It is not at all implausible that there may be significant numbers of people in the future who would choose to be self-sufficient farmers or something close to it, even in the context of rapid urbanization of populations. In fact, the adoption of lifestyles closer to the land is a trend that has emerged in reaction to the increasing distance from the production and reproduction of our own existence that characterizes modern lifestyles. It is not necessary for a majority or even a substantial minority to adopt a self-sufficient farmer lifestyle for it to be germane to future health protection. It should only be a plausible lifestyle for some people based on what we know of society today. Indeed, it is quite possible to imagine economic, social, and technological arrangements under which a large proportion of the population of the future would grow most of their own food or obtain it very locally.

Some recent trends point in the direction of preference for local food and reinforce the arguments for adopting the subsistence farmer scenario. There has been a boom in the demand for organic food and the large numbers of people who are willing to work long hours, days, and years as organic farmers to meet that demand. The markets for such very local products now amount to billions of dollars per year in the United States alone. This means that the numbers of people who may consume the kind of diet assumed in the subsistence farmer scenario could be far larger than a small local community living on contaminated land. While this larger population would not have direct gamma radiation doses from contaminated land, and may not have the same drinking water doses as the subsistence farmer, they may have a similar dietary dose. There are many circumstances in which the dietary component dominates the dose. Such considerations mean that the dose calculated for some of the people who are not part of the critical group may not be significantly lower than that of the subsistence farmer. This is another important reason for using the subsistence farmer scenario as the basis for a clean up standard. It is important therefore to not only use the subsistence farmer scenario as the basis for protecting future populations, but to set a stringent standard limiting risk to protect against the possibility of large population doses due to lifestyle changes that are foreseeable based on many people's preferences today.

In addition to being a reasonable scenario in general, it is also important to underscore the point that this is reasonable for the Rocky Flats site. Because the Denver-Boulder corridor is one of the fastest growing areas in the country, there is a great deal of pressure to develop open spaces. There are farms, businesses, and homes located just up to the boundary of the site. The reasons given for declaring Rocky Flats a wildlife refuge include preserving open space and limiting the costs of cleanup.⁴⁹

However, declaring the site a refuge and limiting short-term expenditures should not be confused with long-term public health protection and clean up standards for the site. If a law can create a wildlife refuge out of a plutonium contaminated site in a few months time, a reversal of such a decision can also be made. The pressures of development makes such a reversal plausible, if not likely. Further, preserving open space is not at variance with the adoption of a subsistence farmer scenario. Indeed, such a scenario would not only be more protective of human health, it would also be more conducive for the same reasons in protecting the integrity of any wildlife on the site, should the area be designated as a refuge. The idea that leaving a place highly contaminated by human occupation standards would preserve the space for wildlife, such as the endangered Prebles Jumping Mouse, begs the question of what such contamination could do to the long term health of the wildlife that is sought to be preserved. Finally, protection of the health of future generations should not be based on the budgetary convenience of the moment but on sound scientific arguments that take the context of clean up decisions into account. In other words, a soil standard should be set according to stringent public health standards that are independent of current and short-term designations of site use since the basic concept of a standard should be long-term public health protection.

Next: 6. Relation of the subsistence farmer scenario to Radionuclide Soil Action Levels (RSALs) at Rocky Flats

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