April 9, 2001
Mr. David Allard, Director
DEP Bureau of Radiation Protection
Rachael Carson State Office Building
P.O. Box 8469
Harrisburg, PA 17105-8469
Dear Mr. Allard,
We understand that you addressed the National Research Council concerning recommendations on the release/recycling/reuse of radioactive materials and wastes in consumer products. ACE is requesting copies of all peer-reviewed research, identifying the authors and who authorized and funded the studies which you used to support your position to lower already unprotective standards concerning this extreme threat to the future health of all people in PA and in fact our nation.
ACE is astounded at your apparent callous disregard for public health. On June 7, 1999 you attended a landfill gas forum in Pottstown, where radiation exposure from Pottstown Landfill gas was discussed in detail and evidence was presented which you had a responsibility to address with sound science. This was never done. In a letter to you August 11, 1999, ACE also addressed radioactive waste in the Pottstown Landfill. On January 10, 2000 ACE sent you a letter clearly identifying many of our concerns and questions concerning radiation testing of the Pottstown Landfill gas and leachate. You were requested to clearly and specifically answer all our concerns and questions in that letter before our public hearing on the Pottstown Landfill gas pipeline March 15, 2000. We are still waiting for detailed, clear, and specific answers to that letter. WHY?
ACE identified research that linked leukemia to low-level radiation, like that which was identified by DEP in Pottstown Landfill gas and leachate. The Montgomery County Health Department Cancer Investigation found that the Greater Pottstown Area has a leukemia rate doubled that of the entire state of PA. Our low-level radioactive exposures from the Pottstown Landfill are believed to be a factor.
DEP and the NRC have allowed enormous amounts of radioactive wastes to go into the Pottstown Landfill and have yet to require continuous and comprehensive radioactive monitoring. DEP only tested three cells of the landfill for radiation and found one to be four times higher in levels of radiation than the other two. Inexplicably, DEP walked away and never tested the other cells or suggested any remediation of this threat. DEP said it does not regulate radiation in landfills. NRC says it doesnít either. Neither agency would take the responsibility to do what was protective for our community.
Mr. Allard, we were told that you were touting your new landfill regulations, which allow DOUBLE the release/dose levels that the NRC and IAEA are planning to permit. Can you cite any peer reviewed sound science to prove this will be safe for human health? Why have you ignored evidence sent to you by ACE as well as other evidence which exists that suggest, this is clearly unprotective? Why are you heading in the wrong direction with radiation regulations? Why are you ignoring the PRECAUTIONARY PRINCIPLE with such a dangerous threat to public health and safety?
Our research evidence suggests it is indefensible to allow any increased levels of radiation in landfills. This radiation can be emitted with the gases and leachate from landfills, as evidenced by your testing of the Pottstown Landfill gases and leachate. Your position to allow the health threat from landfills to become even worse by increasing the risks from radiation exposure not only defies logic, it lacks common sense, good judgment, and caring. As director of PADEPís Bureau of Radiation, you have a responsibility to protect the publicís air, water, and health from radiation. We wonder just who you are trying to protect. It certainly is not the public that you are paid to protect.
As an employee of a government agency, we believe that you have an obligation to respond to our questions and concerns as soon as possible. We expect sound scientific research and evidence when you specifically answer our letter of January 10, 2000. Before you answer this letter, we suggest you review the ACE Radiation Notebook of Testimony for the Pottstown Landfill gas pipeline, which ACE submitted to DEP on April 10, 2000 as part of our testimony. Since that date we have collected additional evidence to support our concerns from the threat of low-level radiation.
If you try to prove that your recommendation to double NRCís release/dose level of permitted radiation into landfills is safe, we also expect to receive a copy of all supporting research along with who ordered it, produced it, and paid for it. We also would like you to explain how each landfill would even be accurately monitored to determine the exact levels of radiation entering the landfill and who will do the monitoring of what radiation is entering these landfills? If DEP is going to allow such levels of radiation to go into the landfills, then DEP has the obligation and responsibility to monitor what radiation is coming out of those landfills in the gases and leachate. How will this be done by a DEP staff which we are told is already understaffed? It would also be DEPís obligation to take immediate action on all violations. Our experience in the past has found that DEP is either not able or willing to take immediate action. We do not believe DEP can or will protect the public from your new landfill regulations on radiation.
Please answer all our questions and concerns as soon as possible.
Dr. Lewis Cuthbert
Montgomery County Commissioners
Montgomery County Health Department
State Health Department, Mr. Joel Hirsh
Pottstown Council and Mayor Jones
Upper Pottsgrove Commissioners
West Pottsgrove Commissioners
P.O. Box 3063
Stowe, PA 19464