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June 21, 1999
Chief
Program Evaluation, Records, and
Information Services Branch
Agency for Toxic Substances and Disease Registry
1600 Clifton Road (E-56)
Atlanta, Georgia 30333
Dear Sir/Madam:
In response to the April, 1999 request for public comments on the "Draft Agenda for
Public Health Activities for Fiscal Years 1999 and 2000 at U.S. Department of Energy Sites," the
following comments are provided on behalf of the State of Nevada. It should be noted that the
State of Nevada was unaware of the existence of the Draft Agenda document until mid-June,
even though it was issued for comment over two months earlier. This, despite the fact that the
State of Nevada has been working with the Agency for Toxic Substances and Disease Registry
(ATSDR) over the past eighteen months on potential health activities with respect to the
Department of Energy's (DOE) nuclear activities in Nevada. As it was, we learned of the Draft
Agenda fortuitously through a contractor who just happened upon it accidentally. A document of
this importance to a state such as Nevada that hosts a major DOE facility with a long history of
exposing workers and the public to radiation and other toxic materials should have been formally
transmitted to the State - at the very least to the Governor and, in Nevada's case, to the state
agency (the Agency for Nuclear Projects) designated by the Governor as the liaison with ATSDR
for developing health initiatives with respect to Nevada Test Site activities. Failure to do so has
substantially impaired our ability to review the document and provide comments within the time
period prescribed.
Background
In February, 1998, then-Governor Bob Miller wrote to ATSDR Assistant Director Dr.
Barry Johnson requesting ATSDR assistance with studies of health risks posed to Nevada's
citizens as a result of the federal government's radiological activities at the Nevada Test Site
(NTS) and other locations within our State. Specifically, Governor Miller asked for help in
developing a statewide and, perhaps, regional approach for identifying past, present, and future
health risks associated with federal nuclear activities in Nevada, including but not limited to,
epidemiological studies and health surveillance activities. The Governor designated the State
Agency for Nuclear Projects to coordinate Nevada's involvement with ATSDR.
As a result of Governor Miller's initiative, a series of meetings was held over the next
eighteen months. These meetings involved affected State of Nevada agencies, ATSDR staff
from Atlanta and San Francisco, DOE, and the U.S. Environmental Protection Agency. The
meetings identified a number of NTS-related health programs and activities that could be
undertaken but were not pursued due to lack of resources.
We are concerned that the results of this ATSDR - Nevada planning process are not
adequately reflected in the Draft Agenda document. In fact, the Nevada section of the document
reflects DOE's continuing failure to address and adequately plan for Nevada-specific health
assessment and health monitoring needs related to past and ongoing federal nuclear activities in
southern Nevada.
Failure to Address Nevada-Specific Health Needs
During the 1950s through the first part of the 1990s, State of Nevada communities and
citizens were subjected to radiation exposures resulting from activities at the Nevada Test Site.
These exposures were primarily from fallout generated by above and below ground nuclear tests
conducted at the site over a period spanning more than 40 years. In addition, the disposal of low-level radioactive wastes and other radiation-related activities at NTS likely contributed to some
level of public radiological exposure.
In all, there were over 900 nuclear weapons tests conducted in Nevada before testing was
suspended in 1992. Just over half of those tests resulted in some form of radiation release -
either from fallout from above-ground tests or from leaks and venting from underground shots.
People and the environment throughout Nevada were exposed to varying levels of radiation over
an extended period of time. Today, large areas of NTS remain highly contaminated, including
soil contamination and radionuclides migrating through the subsurface to the water table below.
Over the years, there has been considerable controversy about the actual public health
consequences of radiation exposures from NTS activities. After decades of debate, Congress in
1990 passed the Radiation Exposure Compensation Act which, for the first time, acknowledged
the causal relationship between fallout from atomic tests conducted in Nevada and certain types
of cancers in persons downwind from NTS, primarily in Utah, and Arizona. However, since no
pre-testing baseline information was collected before the onset of the weapons testing program, it
was extremely difficult to determine just how widespread and serious fallout and related effects
were within the populations exposed. All of the work identifying exposures and related health
impacts to "downwinders' had to be accomplished through retrospective studies that sought to
recreate types and degrees of exposures and the general health status of the at-risk population at
the time of exposure. This approach made it extremely difficult to identify relationships between
exposures to specific radiological sources and actual health problems that were identifiable in
communities subsequent to exposure episodes.
In addition, little Nevada-specific research has been done to identify health effects of past
NTS nuclear activities for Nevada citizens and communities. No baseline studies were done, and
no systematic process for collecting relevant health indicator data was ever established. In effect,
the health effects of weapons testing activities for the citizens of Nevada were almost entirely
neglected. When they were addressed at all, this was done as part of wider "downwinder" and
"fallout" studies that focused primarily on citizens of Utah and other states.
While nuclear testing at NTS has been indefinitely suspended with the end of the Cold
War, DOE is continuing to use the NTS and some adjacent lands for activities involving
significant quantities of nuclear materials. DOE has been using the NTS as a disposal location
for low-level radioactive wastes (LLW) for several decades. In the final Waste Management
Programmatic Environmental Impact Statement, a nationwide study released in May, 1997 that
examined the environmental impacts of managing more than 2 million cubic meters of
radioactive wastes from past, present, and future DOE activities, the Nevada Test Site is
identified as a potential central storage and disposal location for as many as 290,000 shipments
of low-level radioactive waste from throughout the country. In addition, DOE is currently
studying Yucca Mountain on the northwestern edge of NTS as a possible location for a
repository to dispose of spent fuel and other high-level radioactive wastes (HLW) from
commercial nuclear power plants and DOE defense facilities. Should all of the expected
inventories of spent fuel and HLW be disposed of at Yucca Mountain, the site could see over
100,000 MTU (with the radiological equivalent of over 2 million nuclear detonations the size of
the Hiroshima bomb) emplaced underground over a 25 year period. Congress is also considering
legislation that would accelerate the movement of spent fuel to Nevada by authorizing
construction of an interim, above ground storage facility at NTS sometime around 2003.
All of these activities have significant implications for putting Nevadans (and others) at
risk for as yet undetermined levels of exposures to ionizing radiation. Because the current and
planned waste disposal activities are substantially different from past nuclear activities at NTS
(i.e., primarily weapons testing), they pose new and different challenges for monitoring exposure
occurrences and levels and for identifying and monitoring the health effects of such exposures.
For example, LLW and HLW destined for disposal at NTS or Yucca Mountain would have to be
transported into Nevada through populated areas via rail and truck. These shipments would pose
risks of exposure from both routine operations (cumulative exposures to low levels of radiation
over several decades) and accident conditions (potentially higher exposures concentrated in the
vicinity of the accident). There will also be risks of exposure from operations at the waste
handling facilities and from possible surface and groundwater contamination over longer periods
of time.
As was the case prior to the onset of weapons testing in 1950, neither the federal
government nor the State of Nevada has the capability for identifying exposures or monitoring
the health impacts of current and potential future exposures resulting from nuclear activities (in
this case, primarily waste disposal) at NTS or Yucca Mountain. Unfortunately, the "Draft
Agenda for Public Health Activities for Fiscal Years 1999 and 2000 at U.S. Department of
Energy Sites" completely ignores the need for such proactive baseline information and health
monitoring systems.
Specific Comments With Respect to the Public Health
Activities Site Plan for the Nevada Test Site
Inequitable treatment compared to other DOE facilities
Perhaps the most apparent deficiency in the draft Public Activities Site Plan for the NTS
is the stark difference in the types of activities and levels of effort at NTS as compared
with other DOE facilities, especially the other major DOE sites. This is true within all
categories of activities addressed in the Draft Agenda - prior health studies and
assessments, current public health studies and activities, and proposed activities. The
attached table (Table 1), while dealing only with current activities(1) at various facilities,
graphically portrays the severe inequities that exist between NTS and other facilities in
terms of health activities. This despite the fact that NTS is the only DOE facility to
experience hundreds of weapons tests over the years and intensive and ongoing nuclear
waste disposal operations.
The Draft Agenda document is blunt testimony to the neglect Nevada and Nevadans have
been subject to with respect to health matters associated with DOE activities in the State.
Considering that the NTS is one of the three or four largest DOE facilities, that past
radiological and toxic contamination and exposures have been extensive, and that current
and planned NTS activities have potential for significant future exposures, such
continuing neglect is inexcusable. Nevada should be afforded at least the same level of
public health assessment, monitoring, and surveillance as Hanford, Oak Ridge, Rocky
Flats, and Savannah River.
Lessons learned from past studies and activities
Not surprisingly, this section of the Site Plan for NTS deals exclusively with findings
from fallout studies. The section contains nothing with respect to health findings specific
to Nevada. In fact, findings from the dosimetric evaluation and thyroid disease and
leukemia studies referenced in the "Community Health Studies and Activities" section
are reported for Utah residents, with no information about these health impacts as they
may be reflected in Nevada populations.
Perhaps even more disturbing is that the Draft Agenda contains no information on past
studies of worker exposures and worker health at NTS. Given the fact that DOE and its
predecessor agencies had been exploding nuclear weapons at NTS for over 40 years and
exposing workers and others to various types of radiation, the lack of any data on
workers' health speaks volumes for the neglect that has characterized health activities at
NTS.
Gaps in knowledge and important issues to be addressed
In addition to the bulleted items contained in this section of the NTS Site Plan, the
following issues urgently need to be addressed:
There is a need for community-based health baselines and ongoing health
monitoring in rural communities surrounding the NTS and in communities located
along highway and rail corridors that are used or could be used in the future to
ship radioactive materials (primarily low-level radioactive waste, spent fuel, and
high-level waste) to the NTS for storage or disposal. There is a need for a comprehensive State health information system that is
adequate to monitor health indicators of possible radiological and other toxic
substances health effects associated with NTS activities. Such a State system
should include, in addition to systems for the collection and analysis of
mortality/morbidity data and vital statistics, an adequately funded Cancer Registry
that collects data from all health care providers serving citizens of Nevada; and an
adequately funded birth defects registry. Such a comprehensive health system
needs to be institutionalized within the State government and should be operated
by appropriate State health agencies. There is a need for creative new approaches to monitoring radiological exposures
from NTS activities associated with the transportation of radioactive materials.
Such monitoring might include networking appropriate radiation monitoring
equipment at strategic locations within communities along transportation routes,
at targeted intersections, and at locations where the public and shipping vehicles
are likely to interact. Monitors could also be required onboard truck and rail cars
carrying radioactive materials. There is a need to assure that the existing DOE radiation/environmental
monitoring network around the NTS is maintained and improved to assure that
any off-site releases are readily identified. This is especially important in light of
DOE's attempt last year to terminate EPA's long-term work in managing the
existing monitoring network and analyzing data from it. There is a need for information on health effects from past NTS activities (i.e.,
weapons testing) for Nevada communities and citizens. As noted above, such
information is available for communities in Utah, Arizona, and elsewhere, but
very little has been done that is Nevada-specific. There is a need to develop adequate information on the special health
circumstances of Native Americans who may have been exposed to radiation from
past NTS activities and who may be vulnerable to exposures from continuing and
future DOE activities. Research has shown that Native peoples may be especially
impacted by off-site radiation releases due to certain lifestyle characteristics.
These characteristics of Native communities in Nevada need to be assessed, and
past and future exposure levels and pathways identified.
Proposed activities
With the exception of the ATSDR proposal to prepare toxicological profiles for various
elements and radioisotopes, the proposed activities contained in the NTS Site Plan section
of the Draft Agenda deal almost exclusively with development of educational materials
and a "community health communication strategy." Given the paucity of information
available on Nevada-specific health effects and the lack of adequate health information
systems for collecting and analyzing such information in Nevada, it is difficult to see
what utility there is for "education" and "communication" activities. It would seem that
information on Nevada health effects needs to be developed first before people can be
educated or communicated with about such effects.
Likewise, the activities discussed under the subsection dealing with "activities for which
that funding source is external to the [MOU] between [DOE and the Department of
Health and Human Services (DHHS)]" are, in reality, national studies of fallout
exposures and related health impacts. While they are useful and important studies, they
do little to increase the understanding of Nevada-specific health effects or how the
cumulative impacts of past, present, and future radiation exposures are - and might in the
future - affect the health and well-being of Nevadans.
The State of Nevada strongly recommends that the Draft Agenda be modified to provide
immediately for the conduct of the following activities as the first remedial step in
providing adequate radiological and toxic health effects information collection,
monitoring, and assessment.
Requirements for a Nevada Health Effects Program
A comprehensive program for identifying and monitoring the possible effects of radiation
exposures resulting from future NTS and Yucca Mountain activities requires four
interrelated components: health assessment, health monitoring, environmental
assessment, and environmental monitoring. These four components can be briefly
summarized as follows:
Health Assessment
This element of the program involves the establishment and maintenance of requisite
health-related data and statistics that are meaningful in ascertaining the health status of
target populations with regard to health effects associated with radiological causes. This
aspect of the program generally involves assuring that State health information collection
and analysis resources are adequately monitoring needed health indicator data for the
population identified as being at risk for NTS or Yucca Mountain related exposures and
that the information collected is appropriately and routinely analyzed. Information
sources such as a statewide cancer registry, birth defects registry, morbidity and mortality
data, vital statistics, reproductive health data, and other such information are part of the
health assessment component. In addition, capacities for evaluating the data so as to
identify indications of health effects from specific sources and types of exposures must be
put into place.
Health assessment also involves the collection and routine monitoring of community-level information for communities considered to be vulnerable to exposures from NTS or
Yucca Mountain activities. This involves the identification of potentially vulnerable
communities (i.e., those along transportation routes or in proximity to fixed facilities), the
systematic collection of health baseline information for each community, and subsequent
monitoring of community health status over time.
Health Monitoring
Health monitoring involves the extensive evaluation and monitoring of targeted groups of
people considered at risk of radiological expose. This would involve the identification of
specific individuals in selected communities, along with people in control communities,
whose health status would be monitored through a regular program of medical
monitoring (baseline physical exams and health status work-ups plus regular, systematic
follow-ups). Health monitoring is used in conjunction with the health assessment
component, focusing resources in areas where risks of exposure are predicted to be high
or where assessment data indicates that radiological health impacts may be occurring.
This is an extremely expensive and time intensive element of the program and would
need to be designed and implemented in a careful and targeted manner.
Environmental Assessment
This element of a comprehensive health effects program involves the systematic
collection and maintenance of baseline data regarding environmental conditions that
relate to the level of radiation exposures for targeted populations. Types of data required
include background radiation levels; sources of existing radiation exposures such as
radon, etc.; local environmental conditions that may affect how and when people are
exposed; and other relevant environmental information.
Environmental Monitoring
This component addresses the sources of radiological exposure from waste transportation,
handling, and storage/disposal activities. It involves establishing the capabilities needed
to measure the different types and occurrences of exposures over time, including
monitoring stations along transportation routes; monitoring exposures to workers, drivers,
etc.; monitoring contamination at handling and disposal/storage locations; monitoring
levels and extent of soil, air, and water contamination; etc. This aspect of the program
will require the establishment of fairly extensive monitoring systems, both for fixed
facilities (at NTS, Yucca Mountain, and any intermodal/transfer facilities that may be
required) and along transportation routes, especially in areas where repeated exposures to
waste shipments are expected to occur over long periods of time (i.e., congested
intersections, places where lengthy stops may be required in areas where people live or
work in close proximity to the road or rail line, etc.).
Specific Types of Activities that Need to be Undertaken Immediately
The difficulties of adequately conceptualizing and framing a comprehensive program that
collects health information at both the state and local levels, evaluates that information in
light of possible effects resulting from radiation exposures, and provides useful data on
NTS and related impacts are considerable. Such a program must combine large scale
epidemiological approaches to data collection and analysis with approaches that will
yield useful information for small rural populations.
In order to begin to put together a health assessment component of a comprehensive
health effects monitoring system, it is proposed that the initial steps in an overall project
be divided into sub-tasks as follows:
Evaluate the information currently being collected and maintained by State
agencies; identify gaps in these data elements; and develop a detailed work plan
and budget for filling identified gaps:
Using available reports on potential exposure scenarios, literature reviews
done by Dr. Boutté as part of this initial reconnaissance effort (including
work on thyroid and leukemia studies), and information from analogous
studies/efforts such as the Hanford health studies, etc., identify those
specific types of health information that are needed to monitor radiation-related health effects;
Formally survey State of Nevada agencies involved with the collection,
maintenance, and evaluation of health-related data and identify
specifically what information is currently available (and how adequate that
information is for our purposes); and
Assess available information/monitoring data in light of what is minimally
required for a radiation monitoring program focused on areas/communities
of Nevada impacted by the federal HLW program and other radiation-related activities.
Prepare a design for a data collection and analysis system based on the results of
work in Task 'A' above:
Prepare a plan that integrates existing data collection capabilities with
specific plans for implementing data collection for new/needed data
elements identified in 'A';
Prepare a detailed scope of work and budget for implementing the
integrated data collection and monitoring system; and
Prepare a detailed design for a data analysis system that is capable of
evaluating the information being collected in the integrated data collection
system, including adequately specified and formatted research questions,
analytical models, and other aspects of an adequate assessment system.
Implement a Community-based Health Assessment Program in Targeted
Communities potentially impacted by NTS/Yucca Mountain radiological
activities, either from impacts associated with fixed facilities or from impacts
related to the transportation of radiological materials:
Design and implement a program for systematically conducting health
baseline data in targeted vulnerable communities at the local level;
Implement pilot community health information programs in at least
Amargosa Valley, Caliente, Moapa, Indian Springs;
Refine the community health information survey instrument and
procedures for collecting data;
Develop systems for analyzing the data collected;
Put in place community-operated health monitoring programs in each
targeted community that will permit the ongoing tracking of community-specific health indicators related to possible radiation-related health
effects; and
Expand pilot programs to other communities as these are identified and
resources become available.
Specific Issues/Needs to be Addressed
Within the context of the initial pan of work, the following specific information needs,
issues, and uncertainties need to be addressed:
What specific types of data and data elements will be informative with respect to
assessing and monitoring short-term/immediate health effects and longer-term
trends? What information is needed to permit identification of health effects associated
with varying levels of radiation exposures? What data elements are currently available at the State and local levels within
Nevada:
How useful is the currently available mortality data being collected at the
State level?
What kind of morbidity data are currently being collected, and how does
this data relate to assessing radiological health effects?
How adequate are specific data collected by the State Cancer Registry and
the breast and cervical cancer information systems in terms of assessing
radiogenic concerns/effects?
What data are currently being collected that can be useful in assessing
reproductive health and its relationship to radiation exposures?
What information is available that could be used in the context of a birth
defects registry, and how might such a registry be integrated with a
radiological health effects assessment system? What data are needed for a
birth defects registry that would allow the State to identify radiation-caused birth defects?
How can State health information systems be improved to permit State
health data/conditions to be evaluated in relation to national
data/conditions? Are such comparisons useful/essential for assessing
radiological health impacts?
How can State health information systems be designed and configured to
permit the disaggregation of information to regional and local levels in
Nevada and to provide useful information about local/community-level
health effects?
I trust these comments will be helpful to ATSDR, DOE, and DHHS in formulating an
adequate approach to the implementation of public health activities for the Nevada Test Site.
Should you have questions or need anything further, please do not hesitate to contact me.
Sincerely,
Robert R. Loux
Executive Director
RRL/cs
Attachment: Table 1
cc:
Governor Guinn
Nevada Congressional Delegation
Nevada Commission on Nuclear Projects
Dr. Mary Guinan, State Health Officer
Paul Liebendorfer, Environmental Protection
Stan Marshall, Radiological Health
Local Governments
Comparing past and proposed activities at the various DOE facilities results in the same type of
discrepancy between NTS and other DOE sites. Table 1 is presented for illustrative purposes.
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