Dr. Johnsrud

P 58 Increasing amounts of radioactivity that are both generated and released. I believe with respect to ionizing radiation and its impact on human health that we have in fact for these 50 years of the atomic age, grossly underestimated the effects.

Our standards do not reflect what we have learned in the past 10 to 15 years with regard to the effects of low level exposures. Sophisticated research at the cellular and subcellular level finds increasing concern about the impacts of all doses.

P 61 With a landfill gas, if radioactive materials have been disposed of in a landfill, as has been reported for the Pottstown Landfill, then through the gas, through groundwater movement, we will see ultimately the release of these materials, some of which are very long-lived.

P 62 When we set the standards, we look at standard man, the young, healthy, adult male, rather than the most sensitive people. We don’t look at the embryo or the fetus in development stage. We don’t look at those with impaired health.

P 62 All exposures, including naturally occurring background, do offer the possibility of mutagenic alteration, damage, which is then carried through genetically or somatically in terms of health.

P 63 Standards do not cover the very sensitive, nor all of the impacts associated with radiation. Rather we’ve limited to lifetime, risk of fatal cancer and some of the severe genetic defects. More recent research is showing us that indeed there are impacts at low dose.

P 64 With regard to landfills in particular, we are now at a point in terms of economics of management of radioactive materials and wastes, of allowing more and more materials to be deregulated. Release to the biosystem will be either directly to landfills at certain low levels determined by NRC or, if the regulation is approved by NRC low level radiation will be released and recycled into a wide range of consumer products. These radioactive materials will come from the equipment of nuclear facilities, reactors and others as well, including scrap metal that has been partially decontaminated and the concrete of nuclear facilities.

P 65 Those consumer products will probably each have a dose level that is well within the range of variability of ionizing radiation so that the individual would have no way of detecting the differences. Each exposure would compromise a small additive dose to that individual.

P 67 Ultimately what happens to such consumer materials is that they go into landfills. These products will be unlabeled and unmonitored in their use and their disposal. There is no way of knowing. There will be even more accumulation within a given landfill in the future of more and more such materials. They include the components of the uranium decay chain and reports of radium and of thorium.

We also have the naturally-occurring and technologically-enhanced naturally-occurring radiological materials not under NRC regulation. Those may appear in landfills being an additive component.

P 68 So if we have URANIUM, URANIUM DECAY PRODUCTS, THORIUM, and RADIUM decaying into radon gas, then indeed we have a POTENTIAL for the COMPONENT in the LANDFILL GAS.

There is NO QUESTION in the minds of responsible researchers that radon gas and the radon daughters, being alpha emitters, comprise a particular HAZARD with respect to INHALATION DOSES.

P 69 Recent research indicates down to the single hit or three or four or eight or ten to a cell to the cytoplasm or the nucleus of the cell that alpha emitters are biologically, relatively far more hazardous than gamma and betas. And yet THIS is NOT TAKEN INTO ACCOUNT BY THE REGULATORY AGENCIES.

We have hundreds of thousands of tons of depleted uranium to be dealt with. Clearly there is strong effort on the part of DOE to finalize regulations that would allow the release and recycling of all forms of the radioactive materials and wastes, that are generated in vast amounts by the DOE, apart from commercial materials. Once released into the market economy they are no longer under any control.

P 72 The International Commission on Radiological Protection concurred that research done on a variety of other organisms, apart from human beings, indicates clearly that ADDITIVE IMPACTS ARE SIGNIFICANT. THIS IS ESTABLISHED. There is much research to be done.

P 73 ADDITIVE MULTIPLE SOURCES OF EXPOSURES, CUMULATIVE IMPACTS and the most difficult to ascertain but necessary, the SYNERGIES among RADIATION EXPOSURES and the ENTIRE RANGE of ALL OTHER CONTAMINANTS. It is recognized that this is a REGULATORY OBLIGATION and that almost unquestionably it WILL RESULT in FAR MORE STRINGENT CONTROL.

ISOLATION needs to be our GOAL. ISOLATION for the FULL HAZARDOUS LIFE of the materials.

P 75 I hope DEP will begin to not look at the options but to bring the alternatives into existence, to reduce the amount of waste, rather than permit uses, which result in further contamination by the recipient of the landfill waste, who burn it for the energy, in order to produce a substance which is, in itself, also seriously toxic. We need a total system analysis. It is not easy and we want to help.

Dr. Kirk

P 80 I was peripherally involved with some testing of the landfill leachate and soil and what not a couple of years ago and it was found that there was a fair amount of radioactivity in the landfill.

Why was there no in depth investigation about this fair amount of radiation at that time and the possibility of its effects on the health of our community, especially since there was a pending permit of expansion of the Pottstown Landfill which was passed less than a year after that report? Why was there no extensive monitoring for radiation, coming in and going out of this landfill, set up by DEP to protect this community, before another landfill expansion permit was issued?

P 81 It almost exactly matched the amount of radioactivity in the soil surrounding he area in terms of the long-term uranium and thorium levels and potassium. K-40 was a large amount of it.

If the landfill gas carried radiation, wouldn’t you expect it to be found at the same level in surrounding soil from air contamination of the soil? Shouldn’t elevated background levels be a reason not to expose a community to more? It is imperative to consideration additive doses.

There were SEVERAL HUNDRED PICOCURIES PER LITER of GROSS BETA in the leachate and it matched. There was MORE K-40 there than the gross beta showed. The one thing that was unusual that was found was TRITIUM, which was found in a COUPLE of the CELLS. WE BELIEVE THE TRITIUM MOST LIKELY CAME FROM PEOPLE DUMPING SIGNS, the radioactive exit signs that are widely used. The NRC is not working on getting a better handle on the rules on those things. It only takes like one or two signs to produce the amount of tritium that we found in that landfill.

Where is the science to back up this assumption? With so much radioactive waste permitted by DEP and NRC to be dumped in the Pottstown Landfill how or why would any scientist make that assumpotion?

P 83 When we looked at what was coming through the landfill and out, by the time it got to the place where anybody would be exposed to it, it was down below detection limits or marginally at detection limits. I don’t remember the exact numbers offhand.

Exactlly when was this done? For how long a time? How and where can we get the exact numbers?

That is going through the landfill’s treatment system, but it’s mainly due to dilution from the rest of the water that was in the landfill. IT WOULD BE LOGICAL TO THINK THAT SOME OF THAT TRITIUM WOULD COME OUT IN GAS FROM THE LANDFILL, ALTHOUGH WHAT WE FOUND IS IN THE FORM OF TRITIATED WATER.

If the water in the landfill diluted the radiation, wouldn’t the water then be more concentrated with radiation?

IT COULD EASILY GET CONVERTED TO TRITIATED METHANE or like one of these other gases in the landfill.

P 84 We are STARTING to do some MONITORING DOWNWIND of the FLARE just to see what we can find. I WOULD NOT EXPECT to see ANYTHING ELSE COME OUT IN THE GAS OTHER THAN THE TRITIUM. The uranium compounds and the thorium compounds and whatnot. RADON may come out. We did not find very much radium in the landfill at all.

If the tritium in the landfill can get converted to tritiated landfill gas, this will travel through the pipeline and go through the boiler at Occidental and be emitted into our air next to our hospital.

P84 There is a guidance being considered at this time, which would require all landfills, all the solid waste facilities to monitor their incoming waste for radiation. Most landfills in PA do this already. And perhaps 95% of what comes in is from medical isotopes. Almost all the hits that we’ve gotten have been things like adult diapers or somebody that’s had a radio iodine treatment. In your area a hit at a landfill on a bag of radioactive kitty litter. Somebody had a cat treated for a thyroid problem down in Virginia.

If the landfill does its own monitoring, do we really know the truth about radiation dumping? Instruments can be callabrated or set to unprotective levels and who is watching? There is probably a great deal of money in radioactive dumping. People running the landfill probably have no idea how dangerous low-level radioactive waste can be.

Since 1983 DEP and NRC were allowing 35,000 tons a year of radioactive contaminated waste from Cabot to be dumped in the Pottstown Landfill. Who was monitoring this? Because of this permitted radioactive dumping why wasn’t a monitoring station set up at the Pottstown Landfill, and monitored by the NRC?

Mr. Kirk says that 95% radioactive waste in landfills comes from medical isotopes. He wants us to believe it is as simple as an adult diaper and kitty litter from a cat treated for thyroid problems. Obviously the Pottstown Landfill gets a lot more medical waste than that. In one year alone, 1994, the Pottstown Landfill received over 894,000 tons of medical waste. If one diaper and kitty litter set off monitors at other landfills, it is no wonder Pottstown Landfill is not monitored properly. The monitor woud be set off all the time.

Dr. Johnsrud

P86 Sources are considered separately. The concern that we’re voicing for the public is that it is the additives, the totality of these multiple sources that are not taken into consideration.

Linda King

On a long-term chronic exposure basis.

Dr. Kirk

P87 If I went around this area and took 100 soil samples randomly in a ten-mile radius and compared it to the uranium and thorium levels that are in the landfill, it would be little, if any, difference. Main reason is they are bringing soil in from all over the area, including up in the Reading prong area and using it as the soil between the lifts in the landfill.

If there is enough landfill gas to have caused the landfill to use over 217 gaswells, and if that gas contains radiation, and since that gas has been emitted into the community in an unknown radius day-in and day-out for many years, wouldn’t that be also another explanation as to why surrounding soil would show little difference in radiation levels?

Dr. Johnsrud

P87 And so that’s another additive.

Dr. Allard

It’s naturally occurring.

It is long past time for the naturally occurring rhetoric to be stopped. The issue is not whether or not a substance is naturally occurring, but instead whether or not it will harm human health. Lead is naturally occurring but it is very harmful to our health.

Dr. Johnsrud


P88 Yes it is naturally occurring, but it is nonetheless an additive component in a concentrated area, for people who live in this area.

Dr. Kirk

Exactly. But do people in this area give any consideration to the natural regulation radioactive levels in their homes as compared to the landfill? I’ll guarantee you there are thousands of homes within a 50-mile radius who have very high radon levels that have not been tested.

That is even more reason to be concerned about radiation being dumped in our landfill. Radiation dumping in the Pottstown Landfill has added to already serious exposures in this area ? Radon in people’s homes should be a reason to keep all other radiation exposures away, not an excuse for allowing more.

Dr. Allard

P90 Since February of 1999, Director of the DEP Bureau of Radiation Protection, medical health physicist, 25 yrs. in field, much of career in industry, last 8 yrs. oversight for DOE.

We live in a sea of radiation. A coast to coast plane trip gives us 5 millirem of radiation exposure. We get about 300 millirem per year from cosmic rays and from the uranium/thorium materials in rocks and soil.

Potassium 40, another naturally occurring radioactive material contributes to an internal radiation dose from our food.

Uranium eventually decays down to the stable lead, we get radon produced. The radium that’s produced in that decay series decays to a radioactive element, radon gas. The radon decay products contribute dose to our lungs and our bodies.

(DEP) Nuclear safety division works closely with low-level waste disposal concerns in the state.

P94 Right now the country for low-level waste sites, I believe personally, is in a bit of a national crisis.

Dr. Kirk under DEP, BRP - Licensing and use of radioactive materials in industry and medicine and x-rays. This is another piece of the exposure that we get in a technological society as we’re exposed to medical x-rays, dental x-rays, chest x-rays, barium enemas, whatever.

P95 I’m very concerned about all sorts of exposure to the public in PA.

P97 We assume that even these low-level effects will possibly cause some level of cancer incidence.

We assume prudently that it’s a linear relationship and that there are biological effects. And WE REGULATE. We regulate exposure to workers allowed 5,000 milligram a year.

PUBLIC DOSE LIMITS are 100 milligram per year of radiation exposure for NRC regulators.

EPA is the main regulatory agency for setting radiation standards. EPA’s guidelines for radiation exposure are implemented by NRC, DOE, DEP. P 100 EPA has strict regulations for drinking water pathway and good modeling pathway to human beings. 4 milligrams per year on the drinking water pathway. EPA drinking water guidelines for tritium – 20,000 picocuries per liter.- the amount of radioactivity per unit volume and drinking water. We can monitor and compare results to EPA and NRC standards.

P 101 4 to 6 page REPORT DONE FOR THIS LANDFILL by a certified health physicist with a certain code of ethics who did monitor the gas. This individual monitored, actually analyzed samples under pressurized , sampled that landfill gas and scrutinized it as far as gamma emitters, radon, particulates, uranium, thorium, and radon and the tritium.

P 102 EVERYTHING was WELL BELOW ORDERS of MAGNITUDE, 100 times below any sort of ----- the only thing they found was the tritium from the exit signs and that was 100 times less than the allowable standards for concentration in the air.

P103 I believe this was a one-time measurement back last year. This was gas sampling. This was not in ’98, I believe. The results came out, I think, in February.

Dr. Kirk “I don’t remember the date on the report. I thought it was ’99.

ACE is requesting a complete copy of both the raw data and the report of this one time gas measurement of radiation. Please include the name of the certified health physicist who did the testing, the cost of the testing, who secured this health physicist and who paid for the testing.

P 103 The other aspect is the testing the Bureau did on the leachate at any sort of receptor point where you might drink any tritium that came out of the landfill was well below any sort of drinking waters there.

P 104 TRITIUM is NATURALLY OCCURRING – Radioactive material that’s produced in the upper atmosphere by cosmic rays. Also tritium entered the atmosphere in the above ground testing in the 50’s and 60’s. We still have a lot of tritium in the environment from those series of weapons tests by various governments around the world.

P 105 We have established two state air sampling systems at the landfill that have just been installed. We are sampling for tritium, radon, particulate, a whole spectrum of gamma emitters and uranium thorium.

P 106 These stations are as close as I can get to the flare and to the power generation facility without having the plume go over the station. I have tried to optimize the predominant downwind direction as close to those burn points as I can without missing the plume sampling and we will run these for the next ---- we’re doing weekly samples and composite notes for the testing.

We also have a background station at another location because there is natural radon, tritium and uranium series in the dust and air that we breathe.

ACE is requesting a copy of the raw data and report of the Bureau’s leachate sampling on tritium from the landfill. We would like included who did the sampling and the report. Who paid for this? Was it peer reviewed?

ACE is also requesting complete raw data and the report on the surrent air sampling when it is done. ACE is requesting as soon as possible a diagram on the location of the stations and information used for establishing predominant downwind direction and information used to establish points that will absolutely capture the plume. We would like to know what instruments are being used to measure for the radiation and the background setting for those instruments.

P 98 In certain situations, the air pathway, ten milligram under the Neshape (phonic) regulations.

P 98 EPA does not regulate indoor air pollution – Radon

P99 NRC very strictly regulates waste disposal in this country and so does DEP.

By-product materials that have potentially gotten into this landfill are perhaps these generally licensed exit signs that we see on the airplanes, the self-illuminecent signs. They contain tritium and it’s a radioactive isotope of hydrogen.

Dr. Johsrud

P 108 With regard to background radiation, we need to be very careful to recognize there is now a distinction between what is called background radiation and naturally occurring background because we’ve had ADDITIONS of radiation from many, many sources over 50 years plus. A very small %, now remaining, from fallout back in the 1950s and ‘60’s.

The background levels of radiation that I still monitor are nowhere near the 300 millirem per year figure given as background radiation. In actuality this 300 millirem includes the naturally occurring, is includes the fallout. It is going to include the permissible releases from nuclear facilities. Anecdotal information indicates the pre-splitting of the atom radioactive levels, that naturally occurred, we consider in our part of the world approximately 80 to 100 millirem per year. In general what we would really be seeing currently is more on the order of perhaps 120 millirem per year.

P 112 What concerns me is adding another millirem or 2 or 10 from a variety of additional sources – some from sewage sludge that’s released, some from the recycled materials, plus the medical, plus, plus, and plus all the other exposures each of which is small. THEY ARE THEN COMPARED by some authorities TO THE 300 or 360 AVERAGE THAT ISN’T THERE.

P 113 With reference to existing standards and low-dose impacts is the non-cancer, non-fatal impacts, the DAMAGE to the IMMUNE SYSTEM, the impairment of the immune system.

Dr. Kirk

P 113 An equally large amount of literature that would indicate that the immune system is stimulated by low levels of radiation.

ACE would like to receive copies of this literature, along with the author, and who funded the report or who employs the author.

Dr. Johnsrud

P 114 In part, the controversy that exists among scientists means that we need to exercise extreme caution and prudence – that means the application of the precautionary principle.

Tritium occurs in small amounts in this landfill. Then we have to think about that tritium as it may enter the body and its impact within the body.

Tritium – 12 year half-life and I would have said 12 days in the body. Very short, but nonetheless pervasive within the body. P 115 Authorities said the people getting sick around Chernobyl was only public hysteria. Dogs given low dose levels in the laboratories got sick just like the children from these low dose levels, and dogs don’t get hysterical from exposures.

P 116 I think the concern is legitimate concerning the increasing amounts of radioactivity in the biosystem.

Linda King

P 117 The NRC does not very strictly regulate all radiation wastes going into landfills.

DEP does not know the contents of what Cabot has dumped or continues to dump in this landfill.

If you don’t know what is going into a landfill you can’t possibly determine what to test for, whether it is toxic chemicals or radiation. You need to know what is going in before you can do thorough, comprehensive testing on what is coming out.

What is going into that landfill radiation-wise and even toxic chemical – wise they don’t know and we need to know.

Dr. Connett

P 118 I was actually quite shocked to hear you, ( Mr. Allard) as a government official tell the public or give some modicum of reassurance based upon one measure. To take one measurement of a landfill gas when you’ve got billions upon billions of cubic meters of gas coming out of that thing, it may be a preliminary data point, but to use it for the public to give some kind of reassurance to the public------

ACE also objects to use of this gas sample to tell us we do not have a radiation problem with the gas from that landfill since we know massive amounts of radioactive wastes were permitted to be dumped in that landfill. You know and we know that our radioactive problems are not just exit signs, adult diapers, and kitty litter. We are also once again shocked that representatives of DEP would attempt to minimize such a seriously devastating issue. This attitude continues to obstruct the truth and therefore interferes with our efforts to get urgent help for a severely impacted community. With the ever changing composition of landfill gas and the ultimate serious consequences of radiation exposure, we would expect to have very long range and comprehensive radiation testing with peer reviewed reporting. We also expect to receive all raw data and reports as soon as they are completed.

Mr. Allard

P 119 That’s why we’re validating that right now.

Dr. Connett

I don’t think you should have even used that one gas sample with the public because it was given in the sense of some kind of reassurance. We have this limited, very limited leachate data and we have this one measurement of gas. That is not enough reassurance. I’m surprised you would use one data point like that.