(This copy is for reference use only. It is not an official copy)


WRITTEN PAPER PRESENTED AT THE U.S. SENATE VETERANS AFFAIRS HEARING

By William J. Brady, Scientific Advisor for the National Association of Atomic Veterans.

21 April 1998

It is my pleasure to provide this written paper in addition to speaking before the U.S. Senate Veterans' Affairs Committee in support of atomic veterans and Senator Wellstone's Senate Bill 1385. This bill increases the number of diseases that will be considered "presumptive" in P.L. 100-321, thereby increasing the number of atomic veterans who can receive benefits.

Even more important, veterans' claims regarding these diseases will not be subject to dose reconstructions during claim adjudications because P.L. 100-321 does not require them. It is supposed to presume that radiation exposure caused these diseases and require only that the veteran was present at an atmospheric nuclear test. I certainly hope that the meaning of "presumptive" is clear to the Department of Veterans Affairs (VA) and the Defense Special Weapons Agency (DSWA) so they cannot somehow continue use of these deceptive dose reconstruction practices.

Since long before the inception of the Nuclear Test Personnel Review (NTPR) program by DSWA (then called Defense Nuclear Agency or DNA), my early involvement in the Nevada Test Site (NTS) radiological safety organization had a profound influence on the development of NTPR some 20 years later. In 1957, after five years experience in nuclear testing, I began collecting radiation exposure records for all nuclear testing on the continent and in the Pacific from 1945 forward.

My belief that interest in nuclear testing personnel exposure records would be of interest in the future led to preservation of these exposure records and a computerized master file I created by 1969 from some 350 cubic-foot archive boxes containing source documents of mostly external exposure rosters, reports, microfilms, letters, memoranda, procedures, and other documents. In 1977, after disclosure by the Center for Disease Control (later Centers) that leukemia cases seemed to be caused by military participation in 1957 Shot SMOKY at NTS, I participated in meetings with military and Department of Energy (DOE) officials on status of military participants' records in nuclear testing.

Being responsible for radiation dosimetry at NTS for many years, having designed the film badge dosimeter worn for 26 years at NTS, and with my health physics specialty being personnel radiation dosimetry, it seemed natural that both DOE and DNA would turn to me for advice on the NTPR program and a dosimetry research project (DRP) which I helped institute for DOE. The General Counsel for DNA who had worked for me many years previously, advised the DNA Director to seek my help after military-service NTPR teams had trouble beginning their research on identifying military participants in nuclear tests.

Forty-four microfilm cassettes of my 350 boxes of source documents presented to each of the five NTPR teams soon changed their lack of progress. After attending almost all NTPR meetings, usually monthly for twelve years, DNA soon considered me their personnel dosimetry expert, as DOE had for many years. DOE provided funding that allowed me to select from 18 applicants and hire Dr. Barton C. Hacker, a premiere historian who had written a history of the Gemini project: On the Shoulders of Titans...Sixteen years of his labor produced The Dragon's Tail: A History of Radiation Safety in the Manhattan Project and the award-winning Elements of Controversy; The Atomic Energy Commission and Radiation Safety in Nuclear Weapons Testing 1947-1974.

My intense interest and enjoyment during monthly sojourns to Washington, D.C. NTPR meetings, plus attending meetings of two National Academy of Sciences committees on personnel dosimetry, and traveling to archives and records' centers all over the country to find and research records of military participants in nuclear testing were tempered with my developing dislike for internal dose reconstructions performed by DNA contractors.

The first contractor did little for two years except give the same promises of action in its monthly briefings and then produce an impossibly non-scientific draft dose reconstruction report and an unnecessary dose reconstruction on excavation of Shot TRINITY tower footings, an excavation which had been fully documented with film badges and air samples. The contractor had not found the documentation, but I had easily found the documents at Los Alamos. They were part of my 350 boxes of files available to DNA NTPR teams and contractors, and I produced the documents at the contractor's home-city meeting during the sham dose reconstruction presentation.

Because the DNA official responsible for NTPR and the DNA general counsel were present, the poor dose reconstruction report and TRINITY reconstruction sham caused that DNA dose reconstruction contractor to lose its contract. To my knowledge, the contractor's draft dose reconstruction report remains on a shelf at DNA and was never printed for release to the public, a sad monument to two years of payments and to DNA's contracting policies.

Next came dose reconstruction contractor Science Applications Incorporated (now Science Applications International Corporation--SAIC). They appeared to know a little more about what they were doing but not much about health physics and even less about personnel radiation dosimetry. None of the four employees who normally represented SAIC at NTPR meetings were or had ever been members of the Health Physics Society, an unusual situation given that dose reconstruction is in the field of health physics. While a requirement in the "Request for Proposal" for their predecessor's contract required the contractor "to assemble a panel of recognized experts in the field of ionizing radiation health effects," that requirement did not find its way into the SAIC contract.

I cooperated with them fully at first but then began to sense something more difficult to deal with than the incompetence of the first dose reconstruction contractor. SAIC seemed to have some political power over DNA that prevented DNA from exerting normal control of a government agency over its contractor. While DNA still accepted me as one of its 2 dosimetry experts, I was unable to influence DNA to correct the growing tendency of SAIC to establish its own agenda of reducing both external and internal dose reconstructions for atomic veterans, despite DNA and VA stated policies of giving veterans the benefit of the doubt.

Veterans who already had dose reconstructions of more than 5 rem, which seemed to be the dose level at which VA would judge that radiation exposure contributed to cancer and thus award benefits, had their doses reduced below 5 rem, effectively making them ineligible for benefits under P.L. 98-542. During Operation CASTLE in the Pacific, 28 men were evacuated from Rongerik Atoll after Shot BRAVO. Original estimated exposures were 85 R for eight men and 95 R for the rest. Later reconstructions were 40 to 98 R. SAIC reduced these to 32 to 52 rem (the difference between "R" exposure and rem dose is not great--perhaps 10-20 percent depending on gamma energy) (See Elements of Controversy mentioned earlier, page 142-143).

SAIC was supposed to provide external dose reconstructions for cases when film badges had not been issued or results were missing. Soon, however, as in the above example, SAIC was reducing external dose reconstructions done by others and then trying to replace film badge readings with their lower dose recontructions, maintaining for 1952 Nevada Operation TUMBLER-SNAPPER, after I located missing military rosters with actual film badge doses, that the reason their dose reconstructions for the large number of troops involved were only about half the actual film badge results was that the troops must have been "doing something they were not supposed to do."

When SAIC attacked recommendations of a National Academy of Sciences National Research Council (NAS/NRC) Committee on Film Badge Dosimetry in Atmospheric Nuclear Tests report, which established upper-bound doses for DSWA to provide to VA for adjudication of veterans' claims, I was astonished, being a member of that Committee and knowing that the SAIC employees were not health physicists. The memorandum to "DNA-RARP/NTPR" was dated 15 December 1989, and the subject was "Application of NRC Film Badge Study." The SAIC author, one of the four employees mentioned, was worried that atomic veterans would want to use the upper bounds, as they were intended, when he stated:

As the upper-limit values in the majority of operations exceed the film badge reading, those parties who seek higher values whenever available will urge the generation and adoption of all such values.

This audacious four-page attack on a scholarly committee, which included the current president and president-elect of the Health Physics Society, ended with the following statements, obviously designed to protect SAIC's dose reconstruction activities, and profit generation:

Without more in-depth, costly research, the typical biases and uncertainties of film badge dosimetry will have to be accepted as small, but unquantified. However, the NTPR dose reconstruction effort will continue to unearth and compensate for any major departures of film badge readings from credible personnel doses.

These sentences state upper-bound ranges will result in only small changes affecting upper-bound ranges, directly in conflict with the earlier quoted statement complaining that veterans will "seek" the higher values. More onerous is the last sentence quoted, which 3 actually admits that SAIC will continue to watch for any high film badge readings and continue to "compensate" for them with dose reconstructions. A contractor memorandum to DNA/NTPR trying to set policy seemed a strange way for a government agency to do business.

A second SAIC memorandum attacked all film badge dosimetry in 1956 Operation REDWING in the Pacific. Operation REDWING was the first in which an attempt was made to issue film badges to all participants. An abortive attempt was made to have film badges worn for six months, far longer than the usual weekly or monthly periods previously used.

In one month it was apparent that environmental damage was taking its toll and replacement film badges were issued for either three or four-week wearing periods, depending on whether wearers were in two task forces likely to be exposed frequently or not. A few film badges exposed during Operation REDWING could not be read because environmental damage was too severe. The remainder were reported as damaged or not and all could be read in undamaged portions of the film.

This memorandum was to "DNA/RARP-NTPR" and the name of an NTPR official and was from another of the four SAIC employees previously mentioned. The date was 17 July 1992 and the subject was "Evaluation of REDWING Dosimeter Films." Key statements in this seven-page memo, including enclosures, were as follows:

Therefore, as discussed below, it is possible that some or all of the measured "dose" from seemingly undamaged portions of such films was actually caused by non-radiation effects...The readings from all films that are obviously damaged and/or do not exhibit clear filter images should be annotated as questionable and superseded by a reconstructed dose on a case-by-case basis.

Omitted from the memorandum were certain relevant facts. First, the NAS/NRC film badge study had found no great problem with REDWING film badges. Second, SAIC had already requested my company, which maintained all the nuclear test operation dosimetry films I had found, to retrieve and reread a large number of REDWING films from several ships at considerable cost to DNA, until SAIC found one ship to complain about in the memo. Third, the dosimetry technician who reread the films had worked in NTS radiation safety many years and had read hundreds of thousands of dosimetry films during his long career (NTS used 75,000 to 125,000 films per year). Fourth, none of the four SAIC employees were health physicists and none were dosimetry technicians, explaining why the above two memos were filled with scientific nonsense.

Again, SAIC employees were attempting to generate dose reconstruction business and DNA was doing business with SAIC in a strange way. This memo was actually the third on REDWING films. The first was dated 16 March 1989, as SAIC tried repeatedly to increase the number of dose reconstructions it performed and reduce doses of veterans in the process. At least, DNA, to its credit, eventually turned down SAIC's request to reexamine REDWING films again and again.

These "beltway bandit" tactics to ratchet contract costs, while reducing veterans' radiation doses to below 5 rem, seemed to have support at higher political levels than DNA. Another tactic used to reduce internal dose reconstructions for atomic veterans was establishing requirements for individual internal dose reconstructions which were almost impossible to meet. As usual, I had confronted SAIC this time with the question "With all the crisscrossing fallout patterns at most Yucca Flat test locations, how in the world are you going to perform the extensive calculations necessary to estimate total internal dose for each atomic veteran at each nuclear test who inhaled these resuspended old and new fission products, activation products, and unfissioned materials?" The answer from the current survivor of the four SAIC employees was, "We have found a way around that problem." The "way around that problem" was a "Low Level Internal Dose Screen" concocted to eliminate military units and, therefor, essentially all atomic veterans from consideration for individual dose reconstructions. It was published in 1986.

Page 1 stated that a method was needed to: eliminate those who most likely did not receive a significant internal dose.

Page 2 stated: Most DoD participants in continental nuclear testing received a bone dose commitment less than the screen threshold of 150 mrem.

In several veterans' claims, internal dose reconstructions were not done because 150 mrem to the bone was not exceeded in general dose reconstructions for their units. The screen, of course, set up improbable parameters for receiving that bone dose, and use of the bone at all, minimized internal dose from inhalation of radionuclides.

First, radionuclides produced during a nuclear detonation are mostly oxides, and the inhaled oxides usually stay in the lungs for long periods with little dose to the bone. Second, use of the bone as an organ of concern was obsolete for many years before the "screen" was published, and the bone could take large radiation doses without discernible effect or production of cancer. Third, the permissible dose to bone was understated by a large amount to make selection of bone for the screen more plausible. Another interesting aspect that came up during correspondence on the subject was that the bone was selected and even mandated "by higher authority." That authority has not yet been identified, but appears to fit the "higher political power than DNA" category mentioned earlier.

Parameters, or how internal doses are calculated in the screen, were set at artificially low levels. One example of several, is the resuspension factor used for maneuver troops. It involves the greatest number of participants and is ridiculously low at one part in 100,000 of radioactivity on the ground being resuspended to be breathed. A more reasonable factor is more than one part in one hundred of radioactivity on the ground being resuspended to be breathed.

Considering the hurricane-force winds of 180 mph or more caused by blast waves, using the larger amount of resuspended material could increase internal doses of atomic veterans by 1,000 times. Other factors could further increase doses. Another reason why screen parameters were set so veterans could not pass them was internal doses received by atomic veterans actually were much greater than external doses, so SAIC and the so-called higher powers wanted to avoid internal dose assignments.

Use of the "Screen" is evident in several individual dose reconstructions. The "less than 150 mrem to the bone" tips off the reader. DSWA representatives, however, have denied that the screen has been used for individual internal dose reconstructions. To make matters worse, DSWA representatives recently have provided incorrect statements about internal dose reconstruction procedures.

In recent briefings, DSWA representatives again have attempted to foist the artificial parameters on the public and on atomic veterans by claiming their contractors "high-sided" internal doses. Some of these claims are listed below. Each claim is followed by the truth regarding that claim. A general claim that is quite incorrect is that dose reconstructions not only high-side but overestimate doses to veterans and also benefit veterans.

1. "Generally assume most (60%) activity occurred outside vs indoor." All activities at NTS were outside

2. "Individual dose reconstructions performed upon receipt of NTPR inquiry." Not internal dose reconstructions--we have letters to veterans stating they received less than 150 mrem to the bone, with one even mentioning the "screen," which supposedly determines dose to the bone for military units, not individuals.

3. "Decrease in residual fallout from weathering is ignored." Weathering is not a factor at NTS. Fallout stays where it was deposited and on or very close to the ground surface. A very large part of fallout patterns in the Pacific were over water and obliterated by ocean currents. The very small amount of fallout on islands may have been decreased by weathering, but this decrease continues to be controversial.

4. "Working breathing rates used vice a resting rate." SAIC used a breathing rate of 1.3 cubic meters per hour in the "Internal Dose Screen," 1986. This is a light exertion rate as used for a laboratory worker example in NCRP Report 125, Deposition, Retention and Dosimetry of Inhaled Radioactive Substance, 1997. A heavy exertion rate is 3.6 cubic meters per hour (same source), so a more reasonable breathing rate for marching or maneuvering troops is 2.4 cubic meters per hour. This alone would result in almost doubling calculated internal doses.

5. "Highest reasonable resuspension factors used for fallout." SAIC used one part in 100,000 of radioactivity on the ground resuspended to be breathed by observers and maneuver troops touring display area after shot, on foot or inside vehicle, ground assaults, trucking, etc. This applied to the great majority of military participants. For one test, 1953 Shot GRABLE, SAIC used one part in 100 of radioactivity resuspended for troops because a dust storm occurred on Frenchman Flat at the time. The blast wave and hurricane-force winds accompanying it after an atmospheric detonation at NTS resuspended much more dust and dirt than a simple dust storm. The total resuspension factor should be 1.25 parts resuspended per 100 parts radioactivity on the ground, only 25 percent more than SAIC used for GRABLE. Using this resuspension factor for all tests would increase calculated internal doses by more than 1,000 times in addition to the doubling above.

6. "NAS Findings: "Internal dose calculations... 'deliberately high sided' "

(1985); If any bias exists in the estimates, it is probably a tendency to overestimate the most likely dose, especially for internal emitters"

(1995).DSWA selected the above favorable 1985 quote and omitted preceding negative quotes, such as "Thus, the NTPR dose calculations for internally deposited radioactivity are not considered by the Committee to be scientifically defensible." About SAIC internal dose calculations based on external exposure, including film badge readings, the NAS committee stated "These methods involve assumptions about relationships between airborne and deposited fallout that are not scientifically valid, and their reliability, even for establishing upper limits of internal radiation doses, is unknown."

Having been invited to speak before the 1985 committee and being extensively quoted in their report regarding a report I co-authored on film badges and radiac instruments used in atmospheric tests, I can assure you that the committee was not enamored with NTPR internal dose calculation attempts. Furthermore, the committee did not understand all the sources of internal dose at NTS. The committee was partially right in assuming that larger than respirable-size particles in the Pacific could contribute to external exposure, thereby tending to cause estimated internal doses to be overestimated.

Poor understanding of urine sample results added to the problem. The committee did not understand that because fission products and plutonium did not appear in the urine of Japanese fishermen and Marshall Islanders, the reason was not that particles were too large to be inhaled and therefore caused more external than internal dose. The real explanation is that particles were inhaled, did cause internal dose, but did not show up in the urine because they mostly were oxides and stayed in the lung.

The issue of urine sampling validity has become more important recently. The July 1997 issue of the Health Physics Journal is dedicated to the plight of the Marshall Islanders, who suffered considerably by being moved from home islands, relocated, and worst, being exposed to radiation fallout, all as a result of our testing in the Pacific. In the July issue, Brookhaven National Laboratory published an article which indicated that essentially all urine samples taken from the islanders for plutonium 239 analysis before 1989 were cross-contaminated during the 24-hour sample collection procedure and that resampling done on board ships under controlled conditions indicated essentially no plutonium in the urine.

This revelation confirms what some health physicists, including me, have contended for years--that none of the thousands of urine samples taken and analyzed at AEC/DOE facilities for decades have shown confirmed positive plutonium 239 results. The reason is plutonium 239 from weapons tests is in the oxide form and it stays in the lungs and lymph nodes when inhaled. This information is confirmed in Report No. 125 of the National Council on Radiation Protection and Measurements, Deposition, Retention and Dosimetry of Inhaled Radioactive Substances, issued February 14, 1997.

Because fission products also are produced as oxides in a nuclear detonation, a probable explanation for strontium 90 not appearing in the urine of Japanese fishermen highly exposed by Shot BRAVO fallout during 1954 Operation CASTLE is that fission product oxides also remain in the lung and lymph nodes for long periods and do not appear in the urine in detectable amounts. The 1985 NAS review committee chose to believe that particles too large to be inhaled was the reason strontium 90 was not seen in the fishermen, who were exposed to near-lethal radiation doses.

Studies of particle sizes in the Pacific have shown that as much as 20 percent of radioactivity, even in close-in fallout, was in respirable size ranges. Thus, the more logical solution is strontium 90 primarily remained in the lungs. Cross-contamination of Pacific urine samples for plutonium 239 casts doubt on results of all positive urine samples analyzed.

From all of this, it is apparent that the NAS review committees were incorrect when they stated use of film badge exposures for internal dose reconstructions by SAIC, though scientifically invalid, tended to overestimate internal doses.

Strontium 90 and its daughter yttrium 90 produce most of the internal dose from resuspended old fission products and they are not even detected by film badges, being beta emitters, not gamma emitters. Thus, using film badges as SAIC did tends to greatly underestimate internal dose from old fission products, not overestimate it.

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