The Alliance For A Clean Environment

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To: PA DEP Public Hearing Testimony – December 16, 2002
Pottstown Landfill / Radiation Protection Action Plan

We oppose approval for Waste Management’s application for a Major Permit Modification (Permit 100549) under the proposed Action Plan, which would allow Pottstown Landfill to Dispose of Radioactive Contaminated Wastes.

1. The Greater Pottstown Area is already overexposed to radiation. To change Waste Management’s permit to legally allow radioactive contaminated wastes to be disposed in the Pottstown Landfill could, in reality, result in even more radioactive wastes transported through our community in the 300 trucks coming to the Pottstown Landfill every day, and an even larger concentration of radiation in the 4,000 to 6,000 tons of waste dumped in the Pottstown Landfill every day.

2. DEP claims they do not consider the kinds of radioactive contaminated wastes which they would “permit” to be dumped under their plan, a threat to public health. DEP has ignored continuous, additive, cumulative, and synergistic health impacts from this waste. DEP has no idea how much of this radioactive contaminated waste is being disposed of every day in the massive amounts of waste dumped in the Pottstown Landfill. Their claim of no threat to health has no meaning when it is not based on the health threat to our children and those who already have cancer or other serious illnesses. All things considered, DEP could not produce site-specific peer-reviewed science, to prove their claim that these “approved” radioactive wastes will not be a threat to public health.

3. Radiation exposure causes cancer and leukemia. All doses of radiation are additive and synergistic.

    a. Childhood cancer rates (children under 20 in the area around the Pottstown Landfill) almost 100% higher than the state and tri county averages and 92.5 % over the national average (PA Cancer Registry 1995-99)

    b. Leukemia rate almost twice the state average around the Pottstown Landfill according to the PA Cancer Registry (Montgomery County Health Department Cancer Investigation reported Jan. 1998).
4. DEP’s Monitoring Plan will not protect our community.
    a. CONCENTRATIONS of “permitted” radioactive contaminated wastes will present unnecessary increased cancer risks in an already toxic damaged community.

    b. CONTINUOUS EXPOSURE to CONCENTRATIONS of “accepted” short lived radioactive isotopes from massive amounts of medical wastes will increase cancer risks where cancer is already far too high. While these isotopes break down in days, we are exposed day after day, week after week, year after year.

    c. Monitoring equipment will be calibrated to background levels. Ours are too high from exposure over time to Limerick Nuclear Power Plant emissions, radon, and radiation emissions from Pottstown Landfill gas.

    d. Monitoring will only be done for gamma. High levels of beta are currently documented to be in the Pottstown Landfill. If DEP will not monitor for all radiation, how could this plan possibly stop it from entering the landfill? How can DEP determine health risks from their permit?

    e. While radioactive contaminated wastes would be permitted in the landfill, there is NO plan to do comprehensive continuous perimeter monitoring for radiation escaping the landfill in the gas and leachate.

    f. DEP and NRC have allowed radiation to be dumped in the Pottstown Landfill for many years in spite of the fact that the permit did not allow it. We have learned that radiation can contaminate the rest of the waste and travel off site with the gas and leachate. Once the radiation is in the gas and leachate it can not be filtered out or burned off.
How could DEP even consider granting Pottstown Landfill’s request for a MAJOR PERMIT MODIFICATION to dispose of radioactive contaminated wastes when DEP can not possibly protect this community from increased risks to our health?

Most risks could be minimized by denying this permit application for the Pottstown Landfill and by requiring radiation monitors to be placed on waste trucks coming to the Pottstown Landfill as well as at the landfill.

DEP is Failing to Protect Public Health

Greater Pottstown Area residents are demanding that DEP follow its mission statement and use the Precautionary Principle to protect public health. Permitting landfills across PA to accept radioactive contaminated wastes is inexcusable,
    a. knowing that waste could expose unsuspecting residents and drivers along the garbage routes and on the way to the landfills;

    b. not knowing what will happen from unknown amounts and kinds of continuous, additive, and synergistic CONCENTRATIONS in landfill communities as the waste stream becomes more and more radioactive; and

    c. knowing that radiation in landfills can travel with the gas and leachate and can not be filtered out or burned off once it contaminates a landfill.

DEP’s Radiation Action Plan Is Unacceptable

1. DEP’s ineffective and impractical plan to deal with an ever-increasing radioactive waste stream will not protect landfill communities in PA and actually threatens to increase the risks and further jeopardize the people living around landfills.

2. DEP’s plan will help generators of radioactive wastes to dispose of their waste cheaply and avoid liability. It is unlikely waste haulers will be able to identify the source of radioactive waste unless it is clearly marked, which is highly unlikely in most instances.

3. DEP’s plan forces landfill employees to choose between a time consuming, impractical, confusing procedure to protect public health, or saving time to protect profits of the landfill.

Prevention Is The Only True Protection!

1. We want DEP to require monitoring on every waste truck coming to the Pottstown Landfill to avoid transporting radioactive contaminated wastes through our communities. That is in addition to monitors required at the landfill.

2. We want DEP to require the wealthy waste industry, which has made PA the #1 dumping ground in the nation, to provide a way to dispose of all radioactive contaminated wastes in isolated containment areas away from people, not in our 49 landfills surrounded by people already at risk.

3. Greater Pottstown Area residents are demanding that DEP say NO to Waste Management’s request to dispose of radioactive contaminated wastes at the Pottstown Landfill. We can’t afford DEP’s Radiation “UNprotection” Action Plan. In fact, we suspect there are other landfill communities who can not afford it either.

4. If DEP can not meet these requests to protect public health in our high risk community, we demand that the Pottstown Landfill be shut down. Otherwise, DEP is failing in its mission to protect our air, water, soil, and health.

For More Information:

landfill radiation

P.O. Box 3063
Stowe, PA 19464

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