Discharging Toxic Chemicals (Specifically, Radium) from a Superfund
Site into the Delaware River Ecosystem: Considerations for Making a
Good Decision
Testimony before the Camden County Municipal Utilities Authority
September 10, 2003
Camden, N.J.
Peter Montague, Ph.D.
Environmental Research Foundation
P.O. Box 160
New Brunswick, N.J. 08903
Telephone 732-828-9995
erf@rachel.org
http://www.rachel.org
This document is on-line at http://www.rachel.org/library/getfile.cfm?ID=302
My name is Peter Montague. I live at 153 Nichol Avenue in New Brunswick, N.J. I am the director
of the Environmental Research Foundation in New Brunswick.
Thank you for the opportunity to offer testimony on this important matter. You might ask, "Why
would someone from New Brunswick care about the discharge of wastewater from a Superfund site
into the Camden County sewer system?" The answer is simple: The decision to allow a Superfund
site to discharge wastewater to a sewer system in Camden County will set a precedent for the rest
of New Jersey and even for the nation.
I want to focus on only one aspect of the decision -- the discharge of radium into the sewer lines
and eventually into the Delaware River. (When I use the term "radium" I mean radium-226 and
radium-228 together.)
This is a very specific decision, but it also represents the general case of an environmental decision
being made under conditions of scientific uncertainty.
The discharge of radium into the Delaware River has been justified on the basis that radium is only
present at levels permitted in drinking water (5 pCi/L).
The assumption is that, if radium is present at levels deemed acceptable under the "Safe Drinking
Water Act" it must be "safe" for humans to drink.
And it is assumed that, if radium is "safe" to drink, it must be "safe" to release into the Delaware
River.
Therefore it must be a good decision to transport radionuclides 17 miles through sewer lines and
discharge them into the river.
I believe this logic if deeply flawed, and I want to explain why.
I believe that the decision to transport radionuclides 17 miles and discharge them into the river is a
not a good decision and should be reversed.
I am basing my testimony on three documents:
1) The U.S. Environmental Protection Agency's "National Primary Drinking Water Regulations;
Radionuclides; Final Rule," which appeared in the Federal Register Dec. 7, 2000, pgs. 7670776753. This document is available on the web at http://www.epa.gov/safewater/radionuc.html
and at http://www.rachel.org/library/getfile.cfm?ID=300 . I will refer to this document as "Final
Rule." Because it is long, I have not attached a copy to this testimony.
2) Poul Harremoes and others, Late Lessons from Early Warnings: The Precautionary Principle,
1896-2000 (Copenhagen, Denmark: European Environment Agency, 2000). Available on the web
at http://www.rachel.org/library/getfile.cfm?ID=301 . See especially Chapter 3, which is titled,
"Radiation: early warnings, late effects," pgs. 31-37. I refer to this document as "Late Lessons." I
have attached a copy to this testimony.
3) Donald Ludwig, Ray Hilborn, and Carl Walters, "Uncertainty, Resource Exploitation and
Conservation: Lessons from History," Science Vol. 260 (April 2, 1993), pgs. 17-18. This document
is available on the web at http://www.rachel.org/library/getfile.cfm?ID=201 . I will refer to this
document as "Ludwig." I have attached a copy to this testimony.
In a nutshell, here is my argument:
1) There is considerable scientific uncertainty about the "safety" of radium in drinking
water. This is very clear from the Final Rule.
a) The drinking water standard for radium was set on the basis of cancer risk to humans. No other
health "end points" were considered. This is very clear from the Final Rule.
** The effects of radium on the immune system were not considered.
** The effects of radium on the endocrine (hormone) system were not considered.
** The effects of radium on the nervous system were not considered.
** The effects of radium on the metabolic system were not considered.
** The effects of radium on the biological processes of growth and development were not
considered.
** The effects of radium on the fetus were not considered.
** The effects of radium on ecosystems were not considered.
b) The drinking water standard was set on the basis of exposure to radium alone, in the absence of
other contaminants. In setting the 5 pCi/L standard for radium, EPA assumed that humans would be
exposed to radium without other contaminants. Obviously, this is a false assumption.
If radium is mixed with other contaminants, could its effect be magnified by the presence of those
other contaminants? Today, we just don't know.
Therefore, any prudent person would take the "safety" of the 5 pCi/L radium standard with a grain
of salt. Because our knowledge of the effects of radium is so limited, and because the assumption
that radium does not occur in a mixture of contaminants is unrealistic, we should regard the
"safety" of the radium standard with suspicion.
2) Both EPA and the Nuclear Regulatory Commission Recommend Zero Exposure Whenever
Possible
It is clear that EPA wants us to take the radium standard with a grain of salt. EPA does not want
anyone to rely too heavily on the "safety" of the radium standard. In Final Rule, the agency set as a
target goal ZERO radium in drinking water. In other words, in setting the radium standard for
drinking water, EPA said, in effect, "We're willing to live with 5 pCi/L when necessary, but ideally
no one should be exposed to any radium, if it can be avoided."
The Nuclear Regulatory Commission (NRC) takes a similar approach to radium and other
radionuclides. The NRC's policy is known as ALARA -- As Low as Reasonably Achievable. The
NRC wants all exposures to radionuclides to be "as low as reasonably achievable" because we
know that ALL exposures to radioactivity cause SOME damage. The ALARA policy means that no
one should ever be exposed to radium, if it can be avoided. (See
http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1003.html .)
Obviously, the decision to discharge radium into the CCMUA sewer system and then into the
Delaware River will create exposures that could be avoided. Therefore they should be avoided.
This is only prudent public health policy: avoid harm whenever possible.
3) The history of standards for radium shows us that standards tend to get stricter as time
passes because new scientific information allows us to understand new ways in which harm
can occur.
It is worth remembering that radium used to be considered beneficial for human health. Physicians
used to prescribe exposure to radium in health spas. At that time, they did not understand that they
were exposing people to a deadly danger. Their knowledge was limited and their ignorance was
great. (Full discussion can be found in Late Lessons, Chapter 3, which is attached.)
By the 1970s, scientists knew that radium was dangerous. In 1976 U.S. EPA set 5 pCi/L as the
allowable drinking water standard for radium. Then in 1991, U.S. EPA proposed to relax the 5
pCi/L standard. The in 2000, EPA reversed itself and decided to retain the 5 pCi/L radium standard.
Our knowledge changes and our understanding of harm changes. We should make decisions that
take into consideration the likelihood that knowledge will change and understanding of harm will
change.
In 2000 EPA reversed itself because the 1991 proposal was based on an "outdated risk analysis."
(Final Rule, pg. 76708) Just as 1991's risk analysis became outdated, today's risk analysis will
become outdated tomorrow.
In 2000, EPA said the risk coefficients in its risk analysis was "based on state of the art methods
and models and are a significant improvement over the risk coefficients that supported the 1991"
proposal.(Final Rule, pg. 76711)
In 9 years, the data changed, the understanding of risk changed, the methods of assessing risk
changed, and the scientific conclusion changed. It seems likely that similar changes in data,
methods, understanding, and conclusions will occur in the next 9 years.
What will we know 9 years from now that we don't know today? And will the knowledge we have
9 years from now make us regret today's decision to put radium into the Delaware River
unnecessarily?
We should make decisions today that anticipate future changes in knowledge and understanding.
Think of how our knowledge of radium itself has changed in just the last 5 years. In 1998 U.S. EPA
discovered that Radium-224 is present in drinking water along with Radium-228 and Ra-226. This
was a complete surprise to EPA. In its Final Rule, EPA says, "Previously it was assumed that the
alpha-emitting radium-224 isotope rarely occurred in drinking water." (Final Rule, pg. 76711) In
the Final Rule, EPA described this as "important new information." (Final Rule, pg. 76711)
Marie Curie received a Nobel Prize in 1903 for discovering radium. In 1998 -- 95 years later -EPA discovers that Radium-224 is present in our drinking water. Think about that. Our knowledge
is incomplete. Our ignorance is great. In all our knowledge, uncertainties are large. This recognition
of our own fallibility, our own ignorance, and the uncertainties in our science, should always guide
our decisions.
Today's "safe" level is tomorrow's public health problem. Let's anticipate tomorrow and make
decisions today that we will not regret when new information becomes available.
4) Our understanding of radionuclides in ecosystems, such as the Delaware River, Delaware
Bay and the continental shelf of the Atlantic ocean, is even more sketchy and crude than our
knowledge of the human health effects of radium. The risk assessment of ecosystems is in its
infancy. Does radium accumulate in any living organisms? Does it move through food chains and
food webs? Will it get into fish or shellfish? Will humans be affected by some indirect pathway of
exposure that no one has considered?
As we learn more about radium in ecosystems, will new knowledge make us regret that we decided
to put radium into the Delaware River?
To summarize:
a) Our knowledge of the effects of radium on human health is very limited.
b) Our knowledge of radium on ecosystem health is even more limited.
c) As time passes, increasing knowledge tends to show that we had underestimated risks in the past,
and that more stringent standards are warranted and needed.
d) In recognition of this, both U.S. EPA and the Nuclear Regulatory Commission urge us all to
keep radiation exposures "as low as reasonably achievable," and preferably ZERO.
e) Radium is long-lived; ra-226 has a half-life of 1600 years. Radium-226 put into the environment
today will not disappear for 10 half-lives or 16000 years. With a half-life of 5.8 years, Ra-228
released today will circulate in the environment for about 60 years before it decays away.
f) The release of radium into the Delaware River ecosystem will be irreversible. Once we allow
radium to escape, we will not be able to retrieve it -- even if new knowledge tells us we made a
serious mistake.
g) THEREFORE, a prudent public health and environmental protection policy would urge us NOT
to release radium into the Delaware River, but to maintain close control over it so that we can
monitor it and contain it. (Ludwig.)
That way, as new knowledge develops, we will not find ourselves regretting a bad decision and
spending our hard-earned money once again on remediation. We should spend our money on
prevention. An ounce of prevention is worth a pound of cure. Better safe than sorry.
Thank you.