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

In the early 1990s, the DOE embarked on a cooperative process with the EPA to develop national cleanup standards, but it reneged on this process and has, since the mid-1990s attempted to proceed on a site-by-site basis. This has led to a welter of proposals for cleanup using various scenarios, with the wildlife refuge having emerged as one of the favorites of the DOE and its contractors. Proponents of this method argue that because nuclear weapons sites have been off limits to the public for so long, they have become havens to endemic species that would otherwise have been at risk due to sprawl and human intervention (see for example, From Waste To Wilderness).⁹⁰ They also argue that up until now, the DOE cleanup program has been very expensive, ineffective, inefficient, and the costs will only increase. On the other hand, declaring them wildlife refuges would exempt the DOE from major cleanup and would also serve to protect the natural ecosystems that have flourished. The Chernobyl Exclusion Zone has been described by a scientist, Ron Chesser, from the Savannah River Ecology Laboratory run by the University of Georgia for the DOE, as "a beautiful place with thriving wildlife communities. Without a Geiger counter you wouldn't know you were in a highly contaminated place."⁹¹

Five sites out of the more than 130 sites in the nuclear weapons complex are expected to account for the majority of cleanup costs. These sites are Oak Ridge in Tennessee, Hanford in Washington State, Savannah River Site in South Carolina bordering on Georgia, Rocky Flats in Colorado, and the Idaho National Engineering Laboratory. These same sites are now being proposed as wildlife refuges by proponents of this model.⁹² Of these Rocky Flats is the only one located in the middle of a rapidly growing urban corridor. Congressional legislation is pending to designate Rocky Flats as a wildlife refuge.

Robert Nelson has argued for the wildlife refuge scenario for DOE sites based on the following four principles:⁹³

1. Old DOE sites have a high ecological value in their current condition.
2. A wildlife refuge would minimize actual risk to off-site human populations by restricting access to the site, which would be done in case of its designation as a wildlife refuge. Indeed, he has cited "radiation danger" and site access restrictions as the basic reasons that wildlife is flourishing at several sites in the nuclear weapons complex as well as areas in other parts of the world.⁹⁴
3. The technology for long-term cleanup to high levels is not available at present and it will require technological advances to accomplish such clean up.
4. Ecological values at DOE sites will be conserved by stewardship that would be implicit in a wildlife refuge and contribute in that way to protecting public health.

The second and fourth points are substantively the same. There is also a partial overlap of these points with the first one. The high bio-diversity at some DOE sites such as Savannah River and Hanford does not actually apply to Rocky Flats, which is a far smaller site and relatively homogenous ecologically. It is also already a part of the rapidly growing Denver-Boulder urban corridor, and therefore not a promising prospect as a long-term wildlife refuge. Further, the proposals for making contaminated sites into wildlife refuges have not taken into account the long-term evolutionary impacts on wildlife. For instance, synergisms of radioactive with non-radioactive contaminants have not been well studied even as they relate to human beings, much less wildlife.

There is a more fundamental evolutionary argument against using highly contaminated sites as wildlife refuges. Proponents have argued that flora and fauna are thriving in radioactively contaminated environments. By leaving them contaminated, human beings will leave these contaminated areas to wildlife. Rather than the genetic abnormalities often attributed to radiation, Nelson cites radio-ecologist Ward Whicker's findings that wildlife is healthy and "absolutely thriving."⁹⁵

Yet, it is well established that ionizing radiation is one of the causes of genetic mutation. It is also known that some of these mutations are deleterious. Even if we grant that all of the arguments about the health of individual wildlife specimens that have been observed are correct, one cannot therefore conclude that there is no danger to the genetic integrity of wildlife and hence to the ecosystem.

Diethard Tautz has argued, in the context of genetic engineering, that subtle genetic changes that do not result in readily observable effects upon individuals in a species may nonetheless have substantial and possibly devastating impacts upon the species in the long term. He has noted that "...genes or genetic functions that have only a very small effect on the fitness of an individual, but are nonetheless important for long-term fitness within a population," an adequate understanding may require "experiments that involve the whole population of the respective species." ⁹⁶ This genetic "uncertainty principle" means that nearly the entire population would have to be changed to discover whether deleterious changes have occurred.

Understanding of gene-ecosystem interactions at the molecular level and their implications for evolution is an emerging science in which there are huge uncertainties.⁹⁷ Long-term considerations of the integrity of wildlife are simply not understood well enough to support the claims of wildlife refuge proponents that assigning contaminated areas to wildlife will be a boon to natural ecosystems and to life forms that are now endangered that society has decided to protect.

Further, the radiological pathways from animals to humans are being revealed as far more complex than is recognized in standard risk assessments. In recent years surprising problems regarding the spread of contamination have emerged. For instance, a garden in a private home near the Sellafield nuclear materials processing site in England was found to be contaminated with radioactive pigeon droppings to the point that the soil and the pigeons had to be declared a radioactive waste.⁹⁸

The problem of non-availability of technology is at least in part a spurious one in regard to RSALs. There is no reason why highly contaminated soil cannot be removed and stored retrievably as radioactive waste. It is desirable to develop technologies to cleanup this soil in the long term to avoid the problem of shallow land burial, but soil removal and storage allows the contamination to remain concentrated which makes for easier long-term cleanup and also prevents the spread of radioactivity in the environment. Most importantly, soil removal and storage protects vulnerable populations from exposure by the various pathways that have been described in the RAC reports. While it is true that present technology will not return some portions of the site to near pristine conditions, there is no incentive for developing new technologies if standards are so loose that large amounts of residual contamination are left behind as a matter of routine, as would be the case with a wildlife refuge scenario.

The protection of public health by restricting site access can only be a temporary expedient, at best. It would be unreasonable to assume long-term site control or that site use will not be changed in the future due to loss of institutional control and institutional memory. A current example from Washington, D.C. is discussed in the next section. It shows that institutional memory may not endure even a few decades where military contamination is concerned even in the heart of the capital of the United States. Restricting site control can only be a temporary expedient for other purposes but cannot be justified on the grounds of public health protection over a period of decades, much less hundreds or even thousands of years. Therefore even if the Rocky Flats site is designated as a wildlife refuge at present, this is not an adequate basis on which to set RSALs. Stringent RSALs at the outset will not only ensure that public health is protected in the long-term, but also that resources will be set aside in order to ensure the protection of public health.

Finally, the DOE has done quite a bit to characterize the nature of the environmental problem in the weapons complex since the end of the Cold War. However, the actual process of cleanup has been limited by the fact that DOE has been unable to develop a coherent set of priorities. Much of the waste of money is not due to the difficulty of cleanup but the poor management that has plagued DOE projects. Poor institutional culture is at the core of the problem, as IEER has shown in a previous detailed study of the subject.⁹⁹ While even a well managed and coherent cleanup program would be expensive, one must look at these costs in context. The DOE estimate for partial environmental restoration, waste management and disposal is $227 billion over 75 years. Between 1940 and 1996, the United States spent 5.5 trillion dollars to construct and deploy nuclear weapons. ¹⁰⁰ Cost internalization of environmental problems is an important principle that the government tries to impose when it creates regulations for private industry. Setting and meeting strict cleanup standards is a part of cost internalization for nuclear weapons. It is essential that the government set for itself the high standards it expects of the private sector. The costs of the cleanup program overall are estimated at about five percent of the total cost of nuclear weapons during the Cold War . This is hardly an excessive expense. Moreover, most of this expenditure is actually for materials management and safeguards, site security, and the like, which would have to be spent anyway. Actual cleanup costs are possibly on the order of a couple of percent of the total Cold War nuclear weapons expenditure even if it is done to exacting standards, if the money is well spent.

Next: 9. Enforcement for the eons

---

Order this report