April 19, 2001
The Committee on Environment and Public Works
456 Dirkson Senate Office Building
Washington D.C. 205010-6175
Subject: Fallon Leukemia Cluster

Dear Committee Members:

I am writing in response to a request for public testimony concerning factors to consider connection with the Fallon Leukemia cluster. I would like to see this committee carefully consider the role of fire in the disbursal of hazardous materials through the environment, including fire's role in remobilized radioactive isotopes and other contaminates deposited in Nevada as a result of weapons testing. I would request the committee to consider the dangers associated with fire as a remobilizing agent of radionuclides from the Nevada Test Site and other testing ranges in the state.

During the period of above ground testing from 1951 to 1963, radioactive releases from the Nevada Test Site emitted over 12 billion curies of radioactive material into the atmosphere, 148 times as much as the nuclear disaster at Chernobyl. Other pre-1971 nuclear tests released 25,300,000 curies, and from 1971-1988, 54,000 curies were released, including the 36,000 curies from the Mighty Oak accident, which was itself 2000 times greater than the release at Three Mile Island. Over half of all underground tests have leaked radiation into the atmosphere (DOE Report on Radioactive Effluents, 1988). DOE has been out of compliance with federal and state permit requirements in the areas of air emissions, water releases, and solid waste disposal (DOE Nevada Operations Office Five Year Plan, 1989).

There is contamination in soil, air, ground and surface water. Strong winds, common to this area of Nevada, can carry plutonium-contaminated dust across a large area. Fallout from above ground nuclear tests in the United States and other countries has radioactively contaminated the atmosphere around the Earth. Project Faultless in Hot Creek Valley was found to have caused radioactive contamination in groundwater. According to EPA Publication 520/4-77-016, cumulative deposits of plutonium (Pu-239 and Pu-240) have been found in soil over 100 miles north of the NTS at levels of 790 mg per acre. Plutonium has a half-life of 26,000 years, and plutonium contaminants ingested in microscopic amounts are capable of causing cancer for 200,000 years. There is no cost-effective technology for decontaminating such sites. No surveys have been conducted to determine health effects on Native American or other residents from Nevada Test Site (NTS) releases. Currently the Nuclear Risk Management for Native Communities project is working to answer some of these questions.

It is known that plutonium translocates to specific radiosensitive organs, especially reproductive organs.

During the years of 1999 and 2000, almost 3,000,000 acres of Public Lands in the State of Nevada were subjected to fires, both wild fire and prescribed burns. Fire remobilizes contaminants. Particles are lifted from the ground into the air, then mobilized through environment on wind currents. The particles are resuspended for an indefinite time period, finally redeposit onto the earth. This process creates fallout. As a result of this process, fire can carry containments across the globe.

We understand that the Nevada BLM oversees management of 1,722,330 acres of public lands considered contaminated with UXO, (unexploded military ordinances). BLM lands border NTS (Nevada Test Site), Nellis Bombing and Gunnery Range, Tonopha Air Force Base, together with the Fallon Range. No one knows the amount or extent of nuclear contamination in the area surrounding the NTS and Nellis Air Force Base which tests depleted uranium (DU) bombs. In 1997 it was estimated that 30 tons of DU had already been deposited in the target area (Draft Environmental Assessment Resumption of Use of Depleted Uranium Rounds at Nellis Air Force Range Target 63-10), a total of 9,500 combat mix rounds (7,900 DU rounds) being expended annually, there.

Depleted uranium or U-238 has an atomic mass of 238. Its half-life is 4.468 billion years (Rokke, 2001). It's natural occurrence is 2.1 parts per million. Uranium is silver white, lustrous, malleable, ductile, and pyrophoric. This makes DU an ideal metal for use as kinetic energy penetrators, counterweights, and shielding or armor. High density and pyrophoric (catches fire) nature are the two most significant physical properties that guided its selection for use as a kinetic energy penetrator.

A study performed at Yucca Proving Grounds found DU residues in all components of the environment, that environmental concentrations varied widely, that corroded DU residues are soluble and mobile in water, that wind dispersal during testing is the prevalent means of dispersal of DU particles, and that an unknown degree of risk was posed to human health by DU in the environment. Moreover, there appears to be no insight into the issue of long-term (100 to 1,000 years and longer).DU forms of both soluble and insoluble oxides. The inhalation of the insoluble oxides presents an internal hazard from radiation if retained in the lungs.

The long-term effects of internalized depleted uranium are not fully known, but the Army has admitted that "if DU enters the body, it has the potential to generate significant medical consequences." Inhaled DU particles or respirable size may become permanently trapped in the lungs. Inhaled DU particles larger than respirable size may be expelled from the lungs and ingested. DU may also be ingested via hand-to-mouth transfer or contamination of water or food supplies. DU, which is ingested, or enters the body through wind contamination, will enter the bloodstream and migrate throughout the body, with most of it eventually concentrating in the kidney, bone, or liver. The kidney is the organ most sensitive to DU toxicity.

More testing of soil and plants needs to be done to determine what radionuclides might be released into the air in a fire, since a fire and its relationship to the resuspension of contaminants has not been the subject of study. Plutonium and radionuclides concentrate in dust, thus higher concentrations are found in the dust sampling than in regular soil sampling. The standard air monitors and surface water samplers usually used are not sufficient to measure submicroscopic particles of plutonium. Further, plutonium contamination is not homogeneous, so simplistic sampling methods are inadequate (John Till, President, Risk Assessment Corp; 2000). Wind-blown particulates must be considered. Debris and gas will go somewhere, but where? Into the water or the soil?

Radiation detection devices that detect and measure alpha particles, beta particles, x-rays, and gamma rays emissions at appropriate levels from 20 dpm up to 100,000 dpm and from .1 mrem/hour to 75 mrem/hour must be acquired to assess the distribution of particles. Standard rad-meters or Geiger counters do not measure these levels.

In order to assess the health risks and damage due to exposure to tritium (radioactive hydrogen), three blood tests must be done. White blood cells must be tested for the presence of micronuclei, indicating the loss of DNA repair processes and leading to increased cancer risk. Red blood cells must be examined for genetic modification of surface glycophorin-A molecules, also indicating DNA damage. A study of Japanese nuclear bombing victims forty years from the time of the blasts showed DNA codes were still unrepaired. In addition, chromosome painting allows chromosomes to be stained for identification of structural and sequential or numerical abnormalities linked to radiation and chemical exposure, cancer, and inherited diseases.

In addition to the redistribution of containments, we need to consider the effects of fire upon other substances. For example, we must consider chemical reactions which may take place when multiple herbicides are burned together. For instance, one chemical being most often utilized on public lands is Tordon. But Tordon is also called Grazon, and the active ingredient is picloram, better known as Agent White, similar to Agent Orange, and one of several defoliants used in Vietnam. In fact, Agent White (picloram) appeared in 5 of the 15 defoliants used there. Agent White is currently being sprayed by the U. S. on the coca fields in Columbia as part of the drug war. In 1998, Dow Chemical, manufacturer of Agent White (picloram) tried to halt its use, warning that it does not bind well with soil, easily washes into the groundwater and could cause irreparable damage to the Amazon Rainforest. Yet, U.S.G.S. Pesticide 1992 Annual Use Map showed estimated annual agricultural use of Agent White to be less than 0.370 pounds per square mile per year. The map shows the entire state of Nevada has been exposed. This is a lot, and has probably increased since that time. If it's dangerous to the water and forest areas of Colombia, it is dangerous here in the U. S. The use of Tordon is banned in some countries.

Also commonly used are 2, 4-D which forms poisonous gas in fire. It is on the Hazardous Substance List because it is regulated by OSHA. The chemical is a mutagen (changes the genetic structure), a teratogen causing birth defects, and a carcinogen particularly related to breast cancer. Short term effects of its use include the death of animals, birds, fish, and plants within 2-4 days after exposure. About 91.7% of 2, 4-D will eventually end up in water. In 1990, the Clean Air Act announced 2, 4-D as a hazardous air pollutant. Run off vapors can kill non-target plants. Agent Orange was a mix of 2, 4-D and 2, 4, 5-T. Another name for 2, 4, 5-T is Weedar. And both of these chemicals appear on the recommended list of chemicals used on public lands.

Garlon is also known as triclopyr (both names appear separately on the recommended treatment list as if they are different herbicides). Triclopyr's chemical structure is very similar to 2, 4, 5-T. The MSDS sheet includes the following data: Nitrogen oxides, hydrogen chloride, and phosgene may result under fire conditions and NIOSH/MSHA requires approved SCBA and full protective equipment for firefighters. Garlon-treated wood that is burned during forest fires, or in wood stoves at home produces a dioxin, one of the most damaging compounds to living organisms. Garlon is an endocrine disrupter.

It mimics a plant hormone, acting systematically to kill the plant or tree. The hormone that Garlon mimics is perceived by the human body to be estrogen. In women, this may result in breast cancer, miscarriages, infertility, birth defects, and possibly ovarian cancer. In men, it can cause prostate or testicular cancer and reduction of sperm count. It also may aggravate liver and kidney disease. We do not know what the effects of burning multiple pesticides and the full extent of the risk to public health from such events.

I suggest that a more appropriate methodology for determining causation of the Fallon leukemia clusters would use a multidimensional model for analysis. In other words, rather considering singular etiologies, as suggested by Prescott from CDC at the hearings, a more complex multi-factor dynamic process may be in operation. We might hypothesize very generally that exposure to radionuclides such as tritium, plutonium, or DU, might cause mitochondrial damage to cells. In addition to other functions, mitochondria contribute to a sort of "programmed cell-suicide". For example, in certain stages of fetal development, humans have webbed fingers. The mitochondria detect this, and at the appropriate time, seek to destroy the web cells, leaving humans with fully formed fingers. This cell-suicide is necessary.

However, when exposed to an error or to toxins or radionuclides, the mitochondria engage in a process of "unprogrammed cell suicide." Thus, healthy cells are destroyed. Such suicides may lead to destruction of critical elements of immune system function, resulting in cancers, leukemia, and the inability to fight the effects of various viruses and bacteria. The cells may be more vulnerable to effects of exposure to chemicals or pesticides. In addition, adequate production of certain neurotransmitters and hormones might be disrupted leading to diabetes or neurological damage. These medical conditions have been reported as increasing in the general population, and though differing in appearance, may be reflecting a basic underlying cellular assault caused by radiation exposure. I refer you to the work of Guy Brown. Thank you for your thoughtful consideration.


Dr. Bonnie Eberhardt Bobb Shundahai Network PO Box 6360 Pahrump NV 89041