Ms. H. O'Leary
Feb. 9, 1994

Radiation-Induced Cancer:

The combined influence of secrecy, budgetary control, and the inherent conflict of interest within the AEC/ERDA/DOE between the goals of nuclear weapons and nuclear power development on the one hand, and the assessment of radiation-induced health risks on the other, has compromised the objective assessment of the most serious aspects of radiation-induced cancer and other radiation health problems. Gross negligence on the part of the DOE and its contractors in the conduct of epidemiological studies of the nuclear weapons work force has been pointedly noted in a recent report of the Physicians for Social Responsibility (Dead Reckoning: A Critical Review of the Department of Energy's Epidemiologie Research, Physicians for Social Responsibility, Wash. D. C., 1992). Similarly, for more than 40 years, the staff of the AEC/ERDA/DOE have contrived to minimize radiation health effects in almost every conceivable way, including blocking the conduct of research on the role of radionuclides in the etiology of some of the more common lethal human cancers, including lung cancer and other soft tissue cancers. The AEC/ERDA/DOE staff controlled the review and funding of radiation research, and thus limited the scope and direction of the research they sponsored. They also exercised a high degree of control of radiation research sponsored by other agencies. Thus, for example, the Radiation Study Group of the National Cancer Institute was invariably chaired by a pronuclear staff member of the nuclear energy establishment. Research proposals on important aspects of radiation-induced cancer were given short shrift. Monthly reports of the Public Health Service on radioactive fallout and radiological health were screened and sanitized by the AEC's Gordon Dunning, a leading defender of the "no harm" theory of radioactive fallout. In the suppression of disturbing information on radiation health effects, the AEC/ERDA/DOE had the help of the national and international agencies involved, including the NCRP, ICRP, IAELA, and even the BEIR-IV committee of the U.S. National Academy of Science. With rare exceptions, members of these organizations and committees were high salaried staff of the nuclear establishment and their contractors. Reports of these organizations should be judged by their sins of omission and their understatement of the more serious radiation health effects. Reports of the United Nations Scientific Committee on the Effects of Atomic Radiation provide a far more objective and credible source of the effects and risks of ionizing radiation (see UNSCEAR, 1988, "Sources, Effects and Risks of Ionization Radiation").

My main purpose here is to direct your attention to a few of the most serious areas of neglect as well as misstatements regarding cancer risks and other adverse health effects attributable to inhaled and ingested alpha- and beta-emitting radionuclides of both natural and man-made origin, as follows:

1. Plutonium Risks and Standards: Occupational and public exposure standards are highly unconservative. K. Z. Morgan has pointed out (Amer. Indusl Hyg. Assn. J., Aug. 1975, 567-575) that the present maximum permissible body burden of 239Pu "should be reduced at least by a factor of 200," thus from 40 nCi to 0.2 nCi or less. Plutonium cancer risks appear to be far more serious than Morgan suggests because of the substantially enhanced tumor incidence for protracted exposure and thus for chronic exposure to internal alpha emitters and other high-LET radiation (Upton, Hlth. Phys. 55, 605-614, 1988; Muller et al., Hlth. Plays. 35, 33-55, 1978). These considerations suggest serious cancer risks for chronic exposure to as little as tens of picocuries of insoluble 239PuO2 particles and other insoluble alpha particle-emitting radionuclides. The ICRP and DOE have failed to consider this evidence and to adopt conservative standards for occupational and public exposure to plutonium. It is evident that conservative standards would limit body burdens and organ burdens of plutonium to levels well below the sensitivity of external scintillation detectors. On this basis plutonium processing would require automation, at prohibitive costs. A complete, objective, independent follow-up of the medical histories and body burdens of plutonium machinists and other plutonium process workers is long overdue and would shed considerable light on the full magnitude of plutonium cancer risks. There are a number of experimental radiobiologists who have conducted animal experiments with inhaled 239PuO2 (Dr. Charles Sanders of Washington State University and others) who are well qualified to carry out a critical assessment of plutonium cancer risks and standards. It is exceedingly important to have the best possible assessment of plutonium cancer risks before cleanup of plutonium contamination sites at Rocky Flats and elsewhere.

2. Average Organ Dose vs. "Hotspots": In a discussion of cancer risks from internal alpha emitters, polonium and plutonium (BEIR-IV, 1988, p. 163) we are incorrectly assured that the average organ dose is the more pertinent measure of cancer risk and that a diffuse distribution of alpha activity "can be as effective or even more effective in carcinogenesis" than is a highly nonuniform distribution of aggregates which deliver much higher alpha radiation doses in small tissue volumes. These BEIR-IV statements are completely at odds with the cancer distribution for inhaled 239PuO2 in rats (see, for example, Sanders et al., Int. J. Radiat. Biol. 54, 115-121, 1988). These authors point out that "High-dose overlapping, alpha-track radiation zones in bronchiolar epithelium may be required for maximum development of lung tumors." The BEIR-IV suggestion that the cell-killing component of aggregates diminishes their effectiveness in cancer induction also is seriously misleading. A high rate of cell killing at hot spots stimulates the mitotic activity of cells, including the proliferation of premalignant cells, and speeds up the multistage process of malignant transforrnations. This is only one example of the seriously misleading discussions and important sins of omission of the BEIR-IV report.

A highly nonuniform soft tissue distribution of alpha-particle-emitting radionuclides Internally is well established. Autoradiographic studies of the plutonium in mice (Ullberg et al., Acta Radiologica 58, 459-471, 1962) showed considerable uptake, highly nonuniform distribution, and long term retention in some soft tissues including the mammary glands, ovaries and fetal membranes. Autoradiographs following intravenous injection of 210po in pregnant mice showed colloidal aggregates of 210po in the lung, liver, mammary glands, Iymph glands, cortex of the kidney, bone marrow, and placenta (Soremark and Hunt, Ant. J. Radiat. Biol. 11, 43-50, 1966). Autoradiographs of the soft tissue distribution of 224Ra and other radionuclides (Graul, Atompraxis 5, 173- l 82, l 959) suggest that the occurrence of radionuclide hotspots in tissue may be a general phenomenon. A strong case has been made for radionuclide hotspots at bronchial tumor sites of cigarette smokers in the etiology of bronchial cancer--the most common, lethal human cancer (discussed below). Why were the serious implications of these studies ignored in radiation research sponsored by the AEC/ERDA/DOE? Why was the BEIR-IV report written largely by Jacob Fabrikant, BEIR-IV Committee Chairman, with no apparent critical review and input by other committee members or by the most able experimental radiobiologists? Why was AEC/ERDA/DOE sponsored research on radiation-induced cancer restricted largely to relatively low incidence leukemia and bone cancer, with almost complete neglect of research on cancer risks attributable to internal alpha and beta emitting radionuclides, particularly that for radionuclide hot spots in soft tissue?

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