IEER

Setting Cleanup Standards to Protect Future Generations:
The Scientific Basis of the Subsistence Farmer Scenario and Its Application
to the Estimation of Radionuclide Soil Action Levels (RSALs) for Rocky Flats

By: Arjun Makhijani, Ph.D. and Sriram Gopal
A report prepared for the Rocky Mountain Peace and Justice Center, Boulder, Colorado
by the Institute for Energy and Environmental Research
December 2001



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

Acknowledgements

We would like to like to thank the reviewers of this report: Professor Thomas H. Pigford, professor emeritus at the University of California at Berkeley, Dr. John Till of the Risk Assessment Corporation, and Leroy Moore of the Rocky Mountain Peace and Justice Center. All of their comments and insights were extremely valuable, especially those of Professor Pigford who provided us with some of the references used in this report. We would also like to thank Dr. Bruce Napier of the Pacific Northwest National Laboratory and William E. Kennedy, Jr. of Dade Moeller & Associates for their help in finding some of the historical documentation that is referred to in this paper. We would also like to thank IEER Librarian, Lois Chalmers, for her extensive bibliographic research and fact checking. Of course, the authors of this report remain solely responsible for its contents, conclusions, recommendations, and any omissions or errors that might remain.

This report was prepared under contract with the Rocky Mountain Peace and Justice Center. The Rocky Mountain Peace and Justice Center was very helpful in pointing us to documents and keeping us current with ongoing developments regarding the standard setting process for cleanup at Rocky Flats.

This study required considerably more resources than were available to the Rocky Mountain Peace and Justice Center for it. Given the crucial national importance of the process of setting cleanup standards for sites contaminated by nuclear weapons production, we decided to use some of the funds we raise from foundations to complement locally available resources. As a result, funds for this study were also partly drawn from grants to IEER from the John Merck Fund, Stewart R. Mott Charitable Trust, Poughshares Fund, Public Welfare Foundation, Rockefeller Financial Services, Town Creek Foundation, and Turner Foundation. General support to IEER's nuclear work is provided by the Colombe Foundation, HKH Foundation, New-Land Foundation, and Rockefeller Financial Services for general support funding, part of which was used for this report. We deeply appreciate their generous support.

Arjun Makhijani, Ph.D.
Sriram Gopal
December, 2001.

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December 2001