June 30, 1999
Program Evaluation, Records and Information Services Branch
1600 Clifton Rd (E-56)
Atlanta, GA 30333
Via fax and mail
Concerned Citizens for Nuclear Safety (CCNS) and Mr. Ken Silver
are pleased to submit these comments on the Draft Agenda for
Public Health Activities for Fiscal Years 1999 and 2000 at U.S.
Department of Energy Sites (April 1999), specifically pp. 38-44
(Los Alamos National Laboratory) and pp. 102-104 (NIOSH).
CCNS is a 501(c)(3) nonprofit, Santa Fe-based nuclear safety
organization who has earned a national reputation for community
organizing, research, litigation, public education and outreach on
a wide range of nuclear safety topics. Our nuclear safety programs
address ongoing activities at Los Alamos National Laboratory and
the Waste Isolation Pilot Plant. Ken Silver, the principal author
of Section I of these comments and These Figures Should Not Be
Recorded (attached), is an environmental health consultant who
has researched LANL public health issues for nearly a
Pp. 38-44, Los Alamos National
p. 38, "Background." The description of major points of
release is quite incomplete. Mortandad Canyon also received direct
discharges of large amounts of both hazardous and radioactive
liquid waste. And, because Omega West Reactor (OWR) is included
among the sources of air releases, the reader must assume --
despite the text's use of the present tense -- that this section of
the "Background" seeks to encompass historical air emissions: OWR
has been shut down since 1991. The Chemical and Metallurgical
Research (CMR) Building (TA-3) and HP Site (TA-33) should be
included among major sources of historical air emissions. This is
based upon intensive dissertation research, partly supported by
which was conducted in the Lab's Occurrence Reports Collection; it
is also consistent with information presented in the Lab's own
"Environmental Surveillance..." report series. Additionally,
another area that richly deserves investigation is the old DP site
TA-21 stills houses major operative
In terms of current and future emissions, the CMR building has
had several fires in recent years involving classified nuclear
materials and is projected to be a major source of air emissions
under the Stockpile Stewardship Program, most notably of beryllium.
Pp. 38-9, "Off-Site Contamination."
"[R]esidential wells": Wells serving the town's water supply
system have tested positive for tritium and strontium-90. ATSDR
needs to check whether, in fact, "residential" wells were
previously evaluated or whether the town's supply wells were the
subject of the health consultation. Lab spokespeople continue to
cite the ATSDR health consultation in public presentations that
downplay any radiological threat to the town's supply wells. In
the years since the ATSDR health consultation, the temporal trend
in concentrations and number of radioactive contaminants appears to
be upward. Ongoing independent assessment of the public health
implications of the latest data is warranted, in light of the Lab's
murky handling of past analyses of environmental samples. Water is
a scarce resource in New Mexico. It's never too early to plan for
community's long-term water quality and supply
Acid Canyon: Unfortunately, ATSDR's health consultation
which concluded that Acid Canyon is "not a public health hazard"
may need another look. In December 1996, a long-time Los Alamos
environmental scientist -- no enemy of the Lab -- expressed alarm
to one of us (K.S.) over her neighbor's use of soil hauled up from
Acid Canyon for use in a home strawberry patch. Community memory
over Acid Canyon's history appears to be on the wane. Exposure
pathways besides direct recreational use of the canyon may need
P. 39, "Community Health Studies"
Review of Cancer Rates: The period of excess thyroid cancer
in Los Alamos County was 1988-1993. The New Mexico Department of
Health study observed that nearly 80% of the cases had resided in
Los Alamos for more than 10 years, but their average age was no
greater than the cases that had resided in Los Alamos for fewer
than 10 years. This suggests one or more causal factors occurring
before 1980. Possible sources of environmental emissions were
never aggressively pursued by NM DOH. (See the following pages of
the enclosed document, "These Figures Should Not Be Recorded...",
for possible historical sources of radioiodine around LANL: pp. 24,
55, 56, 60, 65, and 71).
NMDOH also failed to make full use of the relatively greater
number of cases of benign nodular thyroid disease, which is also
known to be caused by ionizing radiation. Similarly, little use
was made of the five confirmed cases of childhood thyroid cancer
occurring in Los Alamos county since the 1960's. An independent
of these cases as sentinel health events, taking latency into
account, points to the mid- to late 1960's as a period in which the
cases' time windows overlap, and a putative release of radioiodine
or gamma radiation might have occurred. These leads deserve
collaborative follow-up by ATSDR and/or NCEH.
ATSDR personnel will be interested to learn that it was in the
late 1960's that Omega West Reactor won a national security
exemption from the AEC's siting criteria for nuclear reactors, over
the objections of the AEC's safety personnel in Washington, D.C.
(See pages 31-36 in "These Figures..."). To justify the exemption,
Lab management relied on the findings of a UCLA doctoral
candidate's research. His name was Harry Otway and his
dissertation was a risk analysis for Omega West Reactor. This is
the same Harry Otway who in 1991-2, as chairman of the Community
Working Group, tried to thwart ATSDR's public health assessment of
Four additional issues merit special
Pueblo Thyroid Disease: A nurse employed at the IHS Santa
Clara Clinic independently discovered an apparent cluster of
nodular thyroid disease (benign and malignant cases) during the
1980's. These cases did not reside in Los Alamos County and were
not included in the aforementioned NMDOH study. She brought her
concerns to the attention of state health officials, but feels she
did not receive an adequate response. NCEH's plans for an analysis
of the spatial distribution of cancer in surrounding communities
are most welcome. In light of the Los Alamos thyroid cancer rate
spike of 1988-1993, NCEH should include an intensive look at this
putative pueblo thyroid disease cluster. That is, NCEH's analysis
should include a strong temporal component, in addition to
Leiomyosarcoma: At least four confirmed cases of this rare
type of soft tissue sarcoma have occurred in Los Alamos in recent
years. Citizens' concerns were first brought to the attention of
state health officials in October 1996, then again in May 1997.
Except for confirming the diagnoses, no serious attempts have been
made to elicit occupational or residential histories which might
elucidate common risk factors. The citizens themselves have a
"hunch" that the cases had residential histories in common on the
rim of Acid Canyon. This neighborhood also happens to be downwind
from one of the Lab's old incinerators, whose ash disposal pile
still contains substantial quantities of dioxin ("These
Figures...", p. 69). Data are not available on historical
concentrations of dioxin in the incinerator plume, but an emissions
modeling exercise might prove fruitful. But first things first:
there is more than enough evidence to justify a rigorous cluster
investigation. Leiomyosarcoma is almost always fatal.
Brain Cancer: The NIOSH case control study of brain cancer
at several DOE sites may finally elucidate risk factors for the Los
Alamos cases of the late 1980's and early 1990's. These cases
failed to achieve statistical significance in NMDOH's work. NIOSH
is to be commended for undertaking this important work.
Sentinel Health Events for Radiation Communities: Because of
the small populations around LANL, the agencies should consider
supporting further work on alternatives to statistical significance
testing in environmental and occupational epidemiology. Sentinel
health events is one such approach. While the NIOSH list of SHE's
for occupational settings is well-advanced, a list of environmental
SHE's might need further development.6 Data on the radiation
sensitivity of various cancer sites could be incorporated to
develop a list of SHE/O's and SHE/E's specifically for radiation
communities. Incident and recent cases would be investigated with
an eye toward occupational and residential histories. Analysis of
overlapping time windows of exposure might shed light on putative
causal factors. Perhaps the most fruitful application of such a
list of SHE's for radiation communities would be in training
programs for primary care providers in occupational and
environmental medicine around facilities like Los Alamos.
Recognition, reporting and follow-up on incident SHE cases would go
a long way toward allaying public suspicion that under-
ascertainment of Los Alamos-related health outcomes is still the
norm, not the exception, in rural Northern New Mexico.
A. What have we learned from
our studies and assessments of LANL?
1. Off-site Contamination.
What were the levels of tritium found in the residential
wells? CCNS strongly recommends that ATSDR prepare and make
available to the public a radiological profile on the potential
health effects (including potential generational health effects) of
tritium exposure from drinking water.
What levels of plutonium contamination were detected in Acid
Canyon? By what standards did ATSDR determine that these levels of
plutonium are not a public health hazard? CCNS strongly recommends
that ATSDR prepare and make available to the public a
toxicological/radiological profile on the potential health effects
(including any potential generational health effects) of exposure
CCNS recommends that the exposure limit for nitrates in
groundwater for the most sensitive populations be expanded to
include all children under 12 years old. CCNS also recommends that
ATSDR suggest a workplan to DOE to accomplish the elimination of
nitrate exposure. CCNS strongly recommends that ATSDR prepare and
make available to the public a toxicological profile of the
potential health effects (including any potential generational
health effects) of nitrate exposure from drinking water.
2. Community Health Studies and
CCNS recommends updating the 1993 New Mexico Department of
Health (NMDH) study, which determined that the incidence of brain
cancer in Los Alamos was not elevated. CCNS also recommends a re-
evaluation of the factors that might have led to the high incidence
of thyroid cancer in the Los Alamos community to begin with. In
addition, CCNS recommends updating the data supporting the NMDH
claim that the incidence rate of thyroid cancer rate has been
declining since 1990.
CCNS recommends that ATSDR sponsor annual workshops for pueblo
and rural communities, as it did in September 1995, to discuss
environmental health information on chemical and radiation
3. Studies of the Health of LANL Workers.
CCNS asks that ATSDR update the cause-specific mortality study
on more than 15,000 white male workers that worked at LANL between
1943 and 1977. The update should address all forms of radiological
exposure. CCNS recommends expanding the study to include all races
and both genders, as well as expanding the time frame to include
workers who worked at LANL from 1977 to the present.
The 13% higher rate of digestive system cancer in exposed LANL
and Zia Company plutonium workers was arrived at by a comparison of
plutonium workers to "non-exposed" workers. How much higher is the
digestive system cancer rate in the exposed plutonium workers when
compared to the general New Mexico public?
To what causes does the ATSDR attribute the "excess" suicide rate
for women workers at LANL? How high is this rate compared to the
nationwide female suicide rate? To the female suicide rate of New
Mexico? To the female suicide rates in the counties of northern
To what causes does the ATSDR attribute the "excess" rates of
ovarian and pancreatic cancer in women workers at LANL? How high
is this rate compared to the nationwide female ovarian and
pancreatic cancer rate? To the female ovarian and pancreatic
cancer rate of New Mexico? To female ovarian and pancreatic cancer
rates in the counties of northern New Mexico?
The University of North Carolina study found an association
between external radiation and death from multiple myeloma among
workers exposed to external radiation at older ages. CCNS
recommends that the study be expanded to include investigation into
multiple myeloma incidence as well as mortality and that the
study be expanded to include workers of all ages. CCNS also
recommends that the study investigate the relationship between
internal radiation and the incidence of multiple myeloma.
B. What are the current studies and public health activities at
1. Community Involvement.
CCNS would appreciate the opportunity to participate in ATSDR's
community involvement program to address current progress and
2. Off-site Contamination.
CCNS is very concerned about the possibility of the DOE closing
down the classified records for the historical documents retrieval
and assessment project. CCNS has attached a copy of a June 1999
letter to Secretary of Energy Bill Richardson to be included in
CCNS supports the continuation of the Centers for Disease
Control's Dose Reconstruction Study at LANL, including the off-site
CCNS is pleased to learn that ATSDR is developing a toxicological
profile for the potential health effects of uranium exposure. CCNS
strongly encourages ATSDR to conduct generational studies of any
potential health effects from uranium exposure. One possibly
fruitful area of inquiry is into the large amounts of uranium used
in explosive dynamic experiments. In these experiments, DOE has
assumed that 10% is aerosolized. The 1979 LANL Site-Wide
Environmental Impact Statement stated that by that time 100,000
kilograms of uranium had been blown up in dynamic
CCNS strongly recommends that ATSDR develop a toxicological
profile that will discuss potential occupational and public health
effects associated with exposure to beryllium. We recognize
beryllium exposure as a rising health concern across the nuclear
weapons complex, with particular relevancy for LANL's planned
expanded beryllium operations. This concern is heightened by the
fact that LANL ceased ambient air monitoring for beryllium in 1995,
the same year that the State of New Mexico repealed its beryllium
air emissions standard. We note as well that DOE's newly proposed
occupational standard may still be insufficient to adequately
protect occupational health, given the admittedly still deficient
knowledge of the health effects of beryllium exposure.
3. Community Health Studies and Activities.
Please clarify and explain the analyses of incidence,
mortality, and tumor characteristics for nine specific cancer sites
or types for Los Alamos County and immediate outlying districts.
Please expand this study to include the counties of Northern New
Mexico. Please note that residents of Los Alamos County frequently
travel to hospitals in other counties for cancer operations and
treatment, specifically St. Vincent's Hospital in Santa Fe.
4. Occupational Health Studies.
The ongoing NIOSH leukemia case control study results should
be compared to the general public in northern New Mexico by county,
the entire general New Mexican public and the U.S. at large.
In addition to the Boston University study of the effects of job
stressors at DOE sites, please conduct a study of the effects of
the proximity stressors involved in being a neighbor (resident of
Los Alamos and surrounding counties) to LANL. Stressors including
worries about LANL's honesty in monitoring and reporting emissions,
concerns about the increasing production of plutonium pits for
nuclear weapons, and uneasiness about the transportation of nuclear
materials through the neighboring communities should all be
Please expand the State University of New York study of female
nuclear workers at 12 facilities, including LANL, to address the
health effects as well as mortality resulting from ionizing
radiation and chemical hazards. CCNS also recommends that the
synergistic effects of ionizing radiation and chemical hazards be
The University of Southern California study should include the
integration of the synergistic effects of radiation,
chemical/biochemical agents, and microorganisms (as used by LANL in
biowarfare detection testing) in their statistical exposure
The first phase of the DOE Former Worker Medical Surveillance
Project at LANL should be expanded to include current machinists
and workers exposed to beryllium and their families,
specifically their children. Please use the Hanford Health
Information Network model for generational studies.
Again, CCNS is concerned that DOE documents revealing LANL
releases and site exposure information will not be released to
The DOE Beryllium Workers Medical Surveillance Program should
provide independent physicians and health specialists to
workers concerned about the health effects of beryllium
CCNS strongly recommends that monitoring of beryllium air
emissions at LANL be resumed. Due to increased plutonium pit
production, beryllium air emissions are expected to increase.
Public health in the Los Alamos area should be monitored with
respect to beryllium exposures at the same time.
C. What are the gaps in our knowledge, and what important
issues need to be addressed?
CCNS concurs with the statement that the increase and decrease of
cases of thyroid cancer "remains unexplained." We encourage the
federal Department of Health and Human Services to further
investigate the unexplained trends.
CCNS supports the education of community members and health
professionals concerning potential health effects of significant
exposures from radiation, chemical agents, biochemical agents and
CCNS supports the CDC's Dose Reconstruction Study at LANL. We
hope that the CDC and its contractor, ChemRisk, have learned from
their previous mistakes in dose reconstruction studies at other DOE
sites. CCNS will continue to watchdog this process.
In 1990, almost a decade ago, the International Commission on
Radiation Protection (ICRP) recommended that the occupational
radiation exposure limit be reduced from 5 rem per year to 1 to 2
rem per year. The federal Department of Health and Human Services
must work strenuously towards convincing DOE to reduce occupational
radiation exposure limits to the ICRP recommended dose.
CCNS strongly urges the federal Department of Health and Human
Services to conduct further studies in order to understand the
relationship between internal radiation dose and health effects.
Generally, any additional health studies should focus on
incidence as well as mortality, which is particularly
relevant for Los Alamos County. The population there is highly
affluent by New Mexican standards, and thus has available to it a
superior medical detection and treatment infrastructure. A recent
review of cancers in New Mexico found that "[t]he incidence of
county mortality rates roughly coincided with that seen with
incidence. A notable exception was Los Alamos County, which had
the highest incidence rate among all New Mexico counties but
one of the lowest cancer mortality rates." 7 (Emphasis added.) CCNS
also recommends that all additional health studies address the
potential generational health effects of exposure to radioactivity,
chemical hazards, and biological hazards associated with past,
present, and future LANL operations.
CCNS supports the need to ensure that complete records, including
industrial hygiene and work history data for the various levels of
subcontractors at each site, are available to investigators and
workers. We are aghast at the recent wholesale destruction of
unreviewed records at INEEL. Those events must not be allowed to
be repeated at LANL or any other DOE site.
D. Proposed Activities
1. Ongoing Activities
CCNS requests being added to the mailing list for notification
of the progress of existing and new projects proposed for
2. New Activities for FY 1999 and FY 2000
Please expand the review of the New Mexico cancer registry
data to investigate spatial distribution of observed cancer risk to
include populations throughout northern New Mexico counties
CCNS suggests that ATSDR conduct a public health assessment for
all of northern New Mexico as well as the LANL area. CCNS
highly recommends that ATSDR duplicate NCEH's dose reconstruction
data and information. The duplication of NCEH's work would
serve as an audit.
CCNS strongly recommends the practice of split sampling for
current exposure assessments. The DOE should pay for all split-
CCNS would appreciate notification of and the opportunity to
participate in any health consultations provided by ATSDR to the
DOE and the regional communities evaluating and addressing specific
questions regarding site remediation or community concerns. CCNS
strongly recommends that independent health specialists be included
in these community health consultations. The DOE should pay for
these independent health specialists.
CCNS supports the NIOSH study of the Zia Company workers. CCNS
suggests that the federal Health and Human Services Department
change "Mexican-American" to Hispanic population to reflect the
culture of northern New Mexico. This study must include
incidence as well as mortality analyses.
CCNS supports the preparation by ATSDR of toxicological profiles
for cesium, cobalt and strontium, but strongly urges ATSDR to
include plutonium, tritium and beryllium as well. ATSDR should
prepare toxicological profiles of the potential health effects
(including possible generational health effects) of all elements,
radioactive isotopes, chemical agents, biochemical agents, and
microorganisms associated with past, present, and future LANL
CCNS requests the opportunity to participate in the health needs
assessment for FY 1999 and FY 2000.
Thank you for considering our comments. Should you have any
questions, please do not hesitate to contact us.
CCNS Waste Program Director
CCNS Executive Director
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