June 30, 1999

Chief
Program Evaluation, Records and Information Services Branch
ATSDR
1600 Clifton Rd (E-56)
Atlanta, GA 30333

Via fax and mail

Dear Sir/Madam:

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 decade.

Section I.
Pp. 38-44, Los Alamos National Laboratory

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 ATSDR¹, 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 at TA-21.² TA-21 stills houses major operative tritium facilities.³

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 problems.⁴

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 further consideration.

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 analysis⁵ 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 LANL.

Four additional issues merit special attention.

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 spatial analysis.

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.

Section II.

Questions and Recommendations

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 to plutonium.

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 Activities.

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 exposure.

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 New Mexico?

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 LANL?

1. Community Involvement.

CCNS would appreciate the opportunity to participate in ATSDR's community involvement program to address current progress and future plans.

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 these comments.

CCNS supports the continuation of the Centers for Disease Control's Dose Reconstruction Study at LANL, including the off-site exposure assessment.

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 experiments.

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 addressed.

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 investigated.

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 assessment.

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 investigators.

The DOE Beryllium Workers Medical Surveillance Program should provide independent physicians and health specialists to workers concerned about the health effects of beryllium exposure.

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 LANL-released microorganisms.

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 LANL.

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 surrounding LANL.

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- sampling costs.

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 operations.

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.

Respectfully submitted,

Ken Silver,

Joni Arends,
CCNS Waste Program Director

Jay Coghlan,
CCNS Executive Director

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