State Seal
1802 N. Carson Street, Suite 252
Carson City, Nevada 89701
Telephone: (775) 687-3744 • Fax: (775) 687-5277
Executive Director

June 21, 1999

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.


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

  1. 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.

  2. 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.

  3. 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.

  4. 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:

    1. 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:

      1. 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;

      2. 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

      3. 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.

    2. Prepare a design for a data collection and analysis system based on the results of work in Task 'A' above:

      1. Prepare a plan that integrates existing data collection capabilities with specific plans for implementing data collection for new/needed data elements identified in 'A';

      2. Prepare a detailed scope of work and budget for implementing the integrated data collection and monitoring system; and

      3. 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.

    3. 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:

      1. Design and implement a program for systematically conducting health baseline data in targeted vulnerable communities at the local level;

      2. Implement pilot community health information programs in at least Amargosa Valley, Caliente, Moapa, Indian Springs;

      3. Refine the community health information survey instrument and procedures for collecting data;

      4. Develop systems for analyzing the data collected;

      5. 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

      6. 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.


Robert R. Loux
Executive Director

Attachment: Table 1

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

  1. 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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