ARTICLE - "A Citizens' Guide To Risk at the Mixed Waste Landfill
Or:
"Learn How To Read a Rosetta Stone In 8 Easy Steps…"

By Sue Dayton, M.S. and Miles Nelson, M.D.

How much risk does the Mixed Waste Landfill, a hazardous waste dump at Sandia National Laboratories (SNL), pose to humans and animals? To find out we read the 1999 Sandia National Laboratories "Report of the Mixed Waste Landfill Phase 2 RCRA Facility Investigation," Attachment 9, Risk Assessment. Reading the SNL Risk Assessment document for the Mixed Waste Landfill is like reading the "Rosetta Stone." This document is one of many that taxpayers paid $10 million to SNL to generate information on the landfill, a number they've waved both proudly and repeatedly in the public's face; a number which somehow attests to SNL's library of knowledge on the Mixed Waste Landfill and their conclusions as to why it poses no risk to the public - or does it?

Industry traditionally uses risk assessment to defend unnecessary activities that harm human health and the environment. In the case of the Mixed Waste Landfill at Sandia Labs, these "unnecessary activities" consist of thirty-years of dumping hazardous waste into unlined pits and trenches in the ground. Although dumping in the ground is still the favored form of waste disposal by the Department of Energy (DOE), the act of dumping in unlined pits and trenches is an unacceptable practice today. However, getting the nuclear weapons industry to clean up their unacceptable practices of the past is like pulling the teeth out of a Kangaroo rat. How do they get away with not cleaning it up and proving that the risk posed to humans from hazardous waste buried in this dump is negligible? By doing a risk assessment.

1. Why do a risk assessment? To show people there's no problem. Is there any money riding on this risk assessment? You bet. In the case of the MWL about $30 million in clean up costs, minimum. Besides, a precedent is being set here with the MWL called "stewardship," the Department of Energy's (DOE) newest plan, used in place of cleaning up contaminated sites at DOE facilities across the country. The Mixed Waste Landfill is the "flagship stewardship site" for the State of New Mexico. First, Sandia Labs. Next, Los Alamos National Labs.

2. Who's doing the risk assessment? This is another clear-cut case of
"the fox guarding the henhouse." Sandia Labs and its contractors generate this data.

3. Do you know exactly what and how much you're assessing? Workers dumped radioactive and chemical waste in holes in the ground for thirty years. Who would've thought it would make its way to groundwater someday? Obviously, not much thought was given to dumping liquids in the landfill as employees dumped 270,000 gallons of nuclear reactor coolant water into the landfill in1967. Nevertheless, Sandia went back and did their best in gathering up all the records they could find on what was dumped in this dump. They even went as far as to interview any former workers still alive who might remember what they dumped into these pits and trenches starting in 1959, over forty years ago.
As a result we have an inventory, but no one really knows just how complete it is. Numbers documenting the amounts of waste buried don't exist, at least not publicly. Bottom line: You can't do an accurate risk assessment on things you don't have accurate information on.

4. What are the toxic effects of EACH of the known contaminants on humans? Human beings are a diverse species. Are the known effects of each contaminant based on a token 28-year-old white male? Race, age, metabolism, level of health may all play a factor in assessing risk from certain contaminants. The MWL contains at least 28 types of radioactive waste as well as a multitude of toxic chemicals. This does not include the decay products of the radioactive waste. But the potential health effects of each known contaminant buried in the landfill are not considered in this risk assessment nor are the effects of each of these contaminants in combination with each other. Since hazardous waste and other garbage were dumped willy-nilly into the Mixed Waste Landfill it is a perfect candidate for something called radiolysis to occur. Radiolysis happens when radioactivity comes into contact with rubber and plastics and forms new chemical compounds. These are also not considered.

5. Was a risk assessment done on each of the known buried radioactive contaminants? No, risk assessment was performed on only one short-lived radionuclide of concern, called tritium. Tritium is a radioactive element that usually lives in a water molecule and therefore is a freely migrating liquid. Only tritium was evaluated because it has leached 120 ft. from the landfill into the surrounding soil. Tritium is classified as a class A carcinogen (cancer-causing agent). After punching in the numbers on their risk assessment calculators they found that tritium poses an excess cancer risk of 2.6 times NMED guidelines. But they seem to dismiss this and instead apply a lesser federal standard (EPA).

The SNL risk assessment states that even if all "institutional controls break down" (meaning signs, fences, and land use restrictions fail) and people end up living in houses on top of the landfill the risk posed by tritium will still be "acceptable." The SNL definition of acceptable risk may not be the same as yours or mine. Apparently this "acceptable risk" does not consider people digging gardens, growing trees and plants (that would act as conduits for radioactivity), homebuilder projects, or babies eating soil - just a few of a hundred different scenarios that would contribute to increased risk. Obviously, if people dug into the ground on top of the landfill they'd not only be exposed to tritium, but the over 27 additional radioisotopes buried in the landfill.

6. Ecological Risk Assessment.
This part of the report looks at the potential effects of contaminants on animals, in this case, the burrowing owl and the deer mouse. However, it fails to look at the hundreds of holes currently dotting the surface of the MWL, holes that are most likely a result of the Kangaroo rat. The pocket gopher is another rodent ubiquitous to the area that was not included in the report. Holes dug by these burrowing animals can go below surface soil to depths of 10 or more feet. The soil cap currently proposed for the MWL does not contain any barriers to keep these animals from burrowing into the buried waste and turning them into radioactive rats - much like the radioactive tumbleweeds at Hanford resulting in a spread of contamination. Not only that, holes made by the rats may act as tiny conduits for surface water in aiding to the migration of contaminants into the groundwater. Additionally, hungry carnivores such as coyotes and birds of prey are consuming these radioactive rodents. Where will the dispersal of radioactive and contaminated flesh end up?

7. Gerrymandering the numbers.
Sandia was faced with a dilemma when they calculated the risk posed by the MWL; they proved that the dump was dangerous. In their first draft they determined that the excess cancer risk posed by non-radiological contaminants in the Mixed Waste Landfill was 90 times that allowed under New Mexico Environment Department (NMED) guidelines. This sent them scrambling back to their computers. Reading the risk assessment document on the MWL is like discovering the "Rosetta Stone;" it is a primer on the manipulation of figures and statistics to accomplish a goal: make the dump saleable to the regulatory agencies.

This is how they did it.
· First, knowing that the standards for industrial land use are less stringent than for residential land use they recalculated and based the numbers on this new lower standard, and still came in too high.
· Next, they took the average values for all those contaminants that had leaked out of the dump rather than the original "highest" value and they still came in too high.
· Next, they used something called incremental risk. This is using just that amount of a contaminant that exceeds background levels. Doing their calculations based solely on this lesser amount they still came in too high.
· Next, they threw out certain values because the measurements were "estimated." Interestingly, they only threw out high values, and not low values as this furthered their goal of polishing up this dump so that it looked presentable. After doing this they still came in too high.
· Next, they threw out an entire pathway of exposure, called the inhalation pathway. Some of these contaminates are "volatile" which means they can escape as gases. For example, if you put gasoline in your tap water you would be able to smell it because it is "volatile." If this gasoline were a carcinogen (a cancer-causing agent) you would be inhaling it into your body and suffering the ill effects. Sandia initially incorporated an inhalational pathway for these volatile cancer-causing agents that had leaked into the groundwater, but in order to come in with an acceptable cancer risk they deleted this pathway. Would you believe it? They almost met the NMED guidelines this time. For the non-radioactive contaminants the final risk assessment has them just over the NMED guidelines at 1.3 times the allowable limit. Apparently this is close enough for them.

8. After all this Sandia and the NMED will designate the MWL for an industrial land use scenario. What this means is you shouldn't worry about getting cancer from the landfill if you go to work at the Dunkin Donuts that was built on top of it, but living around it increases your chances of getting sick. It's a numbers game. Just don't work any long hours.

"We should remember that risk assessment data can be like the captured spy: If you torture it long enough it will tell you anything you want to know."
- William Ruckelshaus, Administrator, USEPA, 1989

We believe that communities have a right to participate in decision-making that affects the health of their families and future generations. Communities deserve better than this. To get this landfill cleaned up call, e-mail or write:

Pete Maggiore, Secretary, NMED
PO BOX 25110
Santa Fe, NM 87502
(505) 827-2855
peter_maggiore@nmenv.state.nm.us

Do it today as Pete will be making a decision soon!
For more information contact Citizen Action: 280-1844
www.radfreenm.com