BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE www.bredl.org
Blue Ridge Environmental Defense League
BREDL NUCLEAR


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