From: dyurman@igc.apc.org (Dan Yurman)
Newsgroups: sci.environment
Subject: CDC Chem/Rad Dose Study at INEL
Date: 22 Nov 92 19:54:00 GMT
Nf-ID: #N:cdp:1466601929:000:16015
Nf-From: cdp.UUCP!dyurman    Nov 22 11:54:00 1992


From: Dan Yurman <dyurman>
Subject: CDC Chem/Rad Dose Study at INEL

/* Written 11:53 am  Nov 22, 1992 by dyurman@igc.apc.org in igc:en.toxics.righ */
/* ---------- "CDC Chem/Rad Dose Study at INEL" ---------- */
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Dan Yurman            | dyurman@igc.apc.org | Chance favors only
PO Box 1569           | MCI Mail: 364-1277  | the prepared mind.
Idaho Falls, ID 83403 | 43N28 112W02 -7 GMT | -- Louis Pasteur
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November 21, 1992

Mr. Charles W. Miller, Ph.D
Environmental Health Physicist
Radiation Studies Branch
Centers for Disease Control, MS-F35
4770 Buford Highway NE
Atlanta, GA 30341-3724

SUBJECT:  Idaho Environmental Dose Reconstruction Project
          Idaho Falls, ID, Public Meeting 11/19/92
Sir:

The purpose of this letter is to submit in writing my comments
given at the public meeting on November 19, 1992, held in Idaho
Falls, ID, at the Shilo Inn.  Also, I will add new comments.

SUMMARY

*    Documents and data which may be needed for future health
     effects studies could be at risk.

*    The legitimacy of a planned Federal Advisory Committee is
     doubtful at best.

*    CDC has not yet contacted populations in areas most likely
     to be affected by off-site releases of radionuclides.

*    CDC is not yet considering historical cancer rates in
     Eastern Idaho its methods for dose reconstruction.

*    CDC does not appear to understand that the Idaho National
     Engineering Laboratory (INEL) is a research facility and not
     a production plant like Fernald or Savannah River.

*    CDC has not yet considered the future effects of past doses
     on current populations or future generations.

*    CDC has not yet communicated a framework for epidemiological
     responses to potential environmental contamination.

Detailed comments follow.

1. Status of Documents: The objectives of the study in Phase I
were identified as focusing on the creation of a bibliographic
database.  This was stated to mean that documents will be
identified as to their location and content.  It is not clear
what measures will be taken to preserve documents or data in
electronic storage until such time as they may be needed for
analyses.  

It is not my intention to suggest nor imply that any malicious
tampering of documents or data could or might occur over time. 
In large organizations such as the INEL, which has more than
11,000 employees including contractors and Federal civil
servants, it is inevitable that some data will be misplaced or
inadvertently destroyed regardless of the expressed interest in
these documents and data by other agencies of the Federal
government such as yours.  

At this time I question whether the CDC team has recognized this
as a fact of life, and has considered what measures it will take
to preserve critical documents and databases until such time as
they may be needed for health effects studies.  Additionally,
some databases are operational and thus dynamic.  CDC will have
to find ways to obtain snapshots of the data it wants without
interfering with INEL computer operations.

2. Federal Advisory Committee: CDC Team staff do not appear to
understand in practical ways the objectives I stated as being
necessary for the legitimacy of a Federal Advisory Committee for
the INEL study.  These objectives are (1) the panel must be
representative of the potentially affected populations in Idaho;
and, (2) responsive to the public through timely and
comprehensible means of communication regarding all policy and
technical matters.  While the staff were responsive in the
abstract, I think they need to take a closer look at what it
means to create this kind of organization in Idaho.

Some Federal Advisory Committees in the West are poor examples of
public participation.  For instance, advisory committees created
by Federal land management agencies often are filled with
interests who benefit directly from the policies they help shape. 
As a result, few in the environmental community or the public at
large consider these committees to be serious forums for reviews
of policies or operations of these agencies.  CDC will have to
find a way to overcome well deserved cynicism in this area.

3. Effective Outreach:  A comment was made by a citizen at the
meeting that the CDC needed to be holding public meetings in the
small towns located along the immediate edges of the INEL such as
Arco and Atomic City.  I think this is an excellent comment.  

4. Cancer Rates:  CDC has not yet expressed interest in comparing
historical and current cancer rates to measurements of
radiological doses in affected populations.  This seems odd, and
an unnecessary limitation within the scope of Phase I of the
Project.  

I realize that CDC strenuously and repeatedly emphasized there is
no commitment to future health effects studies at the INEL.  I
will take this issue up in a later comment.  However, I do not
understand why CDC would close its eyes to cancer rates as a
surrogate measure for the effects of doses of radiological
contamination.

5. INEL v. Other US DOE Sites:  CDC does not understand that INEL
is not a weapons plant.  The INEL has always been a research
facility.  If you compare INEL with other facilities such as
Fernald, Savannah River, or Hanford, the immediate distinction is
that INEL is not a plutonium production plant.  Except for the
Chemical Processing Plant, the  majority of workers at INEL did
not and do not come in contact with processes that shape or
transform radioactive materials in an industrial production
setting.  The Radioactive Waste Management Complex (RWMC) buries
waste underground.  The Test Area North supports a research
reactor.  It is not a factory setting like Pantex. 

The volume and mass of radioactive materials processed at INEL
over the past 30 years are significantly smaller than for the
same materials processed at the other US DOE facilities noted
above.  For this reason, exposures in measurable doses to
uncontrolled releases of radioactive materials at INEL are likely
to be significantly smaller than elsewhere.  This, of course,
assumes that in the past there were not unknown or unreported
releases of these materials.  This leads to another issue.  CDC
has not yet explained what protocol it will use to inform the
government and the public if it finds a previously unreported and
thus uncontrolled release of radionuclides which affected humans.

6. Rhetoric v. Reality: CDC staff made the rhetorical remark that
they are interested in "real doses to real people, off-site and
workplace exposure."  If that is the case, then CDC must look
forward into the future as well as into the past.  I refer here
to future doses which on-site workers might encounter cleaning up
currently uncontrolled hazardous and mixed waste sites at the
INEL.  

Another way to look into the future is to consider that for
certain persistent hazardous chemicals, and long-lived
radiological waste residuals, which remain toxic to humans for
hundreds or thousands of years, potential threats to future
generations must be assessed.  Further, the biological effects of
releases may yet be felt in the future because there is a long
lag time between exposure to harmful substances and the
manifestation of disease.  

For instance, some cancers are synergistic.  They do not appear
unless there is a combination of an insult to the body by
contamination and then later a breakdown of the body's natural
ability to repair itself, e.g. resulting from age.  CDC did not
indicate that at this time it considers this to be a legitimate
area of inquiry.  

Future health effects can take other forms.  

*    Persons exposed might not manifest cancer, but could become
     more likely to have other common illnesses, and these might
     not be distinguished from normal causes.

*    Genetic effects might not manifest except in future
     generations which are difficult to link to specific episodes
     of exposure.

I encourage CDC to examine the work being done by the Colorado
Health Department regarding Rocky Flats and the Rocky Mountain
Arsenal.  A team of epidemiologists is trying to plot transport
and fate, doses, and responses, over the past 40 years.  They are
running into methodological and data problems because of multiple
sources of contaminants, migration patterns, the idiosyncratic
way peoples' health responds to environmental pollution.

7. Framework for the Study: CDC did not communicate a framework
of ideas and concepts which form the basis for its work. 
Instead, CDC's public comments left me with doubts about its
objectives in this project.  For this reason, I will describe a
framework of ideas about public health impacts of radiological
and hazardous chemical contamination.  I encourage CDC to examine
this framework and respond to it in future public statements.  

     Public Participation

     In terms of public participation for a Dose Reconstruction
Study, people will want to know four things.

     [1] are we exposed?
     [2] are we affected?
     [3] did exposures contribute to or cause disease?
     [4] if we are not affected now, will we suffer later?

     CDC is to be complimented for hiring outside expertise to
advise it on effective public participation techniques.  The CDC
contractor is apparently just starting to write a workplan, as
was stated at the public meeting.  So, while it is premature to
make a judgement about the effectiveness of CDC's efforts in this
area, the four questions noted above may be helpful in writing
the workplan.

     CDC's Scope of Work

     CDC has committed itself to a very limited scope of work,
which is to identify relevant documents and develop a
bibliographic database.  Given the attention the thyroid study
got at Hanford, I was surprised that CDC took such a limited view
at INEL.  I suggest that CDC would benefit from examining other
ways it could contribute to knowledge about the health effects of
exposure to radionuclides.

     There are three things a public health agency can do when
asked to investigate the potential for disease resulting from
environmental contamination.  However, CDC has only committed
itself to the first

     [1] determine exposure and dose
     [2] determine health effects of exposures
     [3] determine dose / response relationships

     CDC will likely find itself spending some of its energies in
the area of public communication explaining why it has only
chosen the first task.  I will discuss the politics of this in a
later comment.  Further, there are seven possible areas where CDC
could respond to these questions, but has chosen only to pursue
one.  These are;

     [1] exposure assessment {the current dose study}

     [2] response assessment
          -- disease cluster investigation
          -- cross-sectional studies by disease and population
          demographics

     [3] analytical epidemiological studies which would separate
     the health effects of pesticides from other sources of
     environmental contamination.  This part of Idaho has
     intensive irrigated agriculture.

     [4] disease registries, see #3 above

     [5] medical surveillance for incidence of all diseases as
     compared to national baselines; links to #2, #3, & #4

     [6] reference surveys, e.g, baselines for all exposure
     pathways from all industrial sources such as coal fired
     power plants, auto pollution, and background sources such as
     radon in wells used as drinking water supplies.

     [7] risk assessments

     *    Many of the contaminants released to the environment by
          US DOE operations and waste management practices
          represent a clear danger to human health if people are
          exposed to sufficient does of these materials.

     *    All radionuclides are human carcinogens.

     *    Three conditions must be met for adverse human health
          effects to result from contamination.

          [1] the contamination must be hazardous to biological
          systems,

          [2] the contamination must be able to make contact with
          people; and,

          [3] exposure to contaminants must occur at
          concentrations and for periods of time to produce
          biological effects.

     *    Factors to be considered in weighing health risks once
          doses have been measured include;

          [1] the concentration and frequency of exposure; and,

          [2] differences in individual's susceptibility to toxic
          effects.

     It is recognized that CDC is conducting the study at the
request of the State of Idaho.  Expansion of the scope of the
study is a two-edged sword in that it could unnecessarily raise
additional public fears about radioactive contamination which
might turn out not to exist.  This is a case of letting the genie
out of the bottle.  Once you've raised the question, it is
virtually impossible to put it to rest.  This is what Governor
Andrus has done in his aggressive campaign to address the issue
of US DOE waste shipments to the INEL.  

     Here are some examples.

     *    The State Attorney General's Office released inaccurate
          risk assessment numbers and has thus far has not been
          as aggressive in correcting itself as it was in
          announcing its incorrect findings in the first place.  

     *    Because of the Governor's high profile campaign, the
          State of Idaho is experiencing a "bash the INEL"
          phenomenon which increases in intensity as you travel
          further away from the site.  People in Twin Falls, 150
          miles away, are convinced that radioactivity from the
          INEL is likely to french fry their potatoes right on
          the vine.  

     *    In the fall elections J. D. Williams, a close aide to
          Governor Andrus, and a candidate for Congress, tried to
          "tar" Mike Crapo, his opponent and an Idaho Falls
          native, with the INEL "brush" by saying that this
          person was "too close to the INEL" to be an effective
          advocate for it.  Williams postured that he could do a
          better job promoting the future of the facility.  This
          allowed Williams to have his cake and eat it too.  He
          could support the INEL, which has 11,000 jobs at stake,
          and also appeal to Governor Andrus and the "bash the
          INEL" ethic which is popular as a political reflex in
          Boise and elsewhere.

     In effect, the Governor changed the public perception of
environmental risks from the INEL from one of being benign, or
voluntary acceptance, to one of dread and involuntary acceptance. 
In effect, politics shaped public perceptions of government
environmental science and those perceptions will go to work on
the CDC project.  

     Your agency will be walking a tightrope between being
responsive to the Governor's request and preserving scientific
independence to do a credible job.  This balancing act needs to
be reflected in your public communications activities and in your
scope of work.

Closing Statement

I welcome CDC's desire to gain public input.  I encourage CDC to
do more homework on the INEL and on public participation
techniques for public health studies.  I urge CDC to broaden its
perspective on its scope of work.  Also, I request that CDC make
copies of this letter available to its contractors working on the
project.

Disclaimers: Nothing in my letter is intended to imply or confirm
that any data sources exist, or do not exist, regarding exposures
to uncontrolled releases of radiological substances.  The views
expressed in this letter are my own as a private citizen.  If you
have any questions regarding any topics discussed in this letter,
you can write to me at the letterhead address, which is my
residence.

Sincerely,


Daniel J. Yurman

cc:  Honorable Cecil Andrus
     Governor of Idaho
Newsgroups: sci.environment,sci.energy