Environmental Defense Institute
News on Environmental Health and Safety Issues

November/December 2004

Volume 15 Number 4

Idaho Downwinders Tell their Story at NAS Hearing

Congress mandated that the National Academy of Sciences (NAS) track the implementation of the Radiation Exposure Compensation Act (RECA). After enormous public and media pressure, the NAS agreed to conduct an official hearing in Boise, Idaho on November 6. About 400 downwinders from across Idaho gathered in Boise to share their stories and seek government compensation and acknowledgment in regard to the health impacts of atomic bomb testing and the radioactive fallout that fell on Idaho from the Nevada Test Site. This unprecedented public outrage is spurred on by President Bush's restart of nuclear weapons testing in Nevada.

Currently, Idaho is not eligible for RECA, which pays downwinders in eligible counties $50,000. In a 1997 National Cancer Institute study, however, four Idaho counties - Gem, Blaine, Custer, and Lemhi - were identified as being among the five hardest hit nationwide in terms of radioactive fallout levels.

Tragically, the NAS deliberately limited the time for downwinders to give testimony on the public record. However, the NAS told EDI November 11 that the comment period is extended for submitting written testimony prior to March 2005 when the NAS report is scheduled to be submitted to Congress.

The Environmental Defense Institute (EDI) has over several decades collected interviews and news stories about individuals who have been affected by radiation exposure at or near the Department of Energy Idaho National Engineering and Environmental Laboratory (INEEL) located northwest of Idaho Falls, Idaho, the Hanford nuclear reservation in eastern Washington State, and the fallout from over a thousand nuclear weapon detonations at the Nevada Test Site.

EDI believes this "snap-shot" puts a face on the thousands of INEEL workers and Nevada Test Site "downwinders" harmed by radiation exposure. At this time it is not possible for the public to differentiate between INEEL, Hanford, and nuclear weapons fallout from the Nevada Test Site. The National Cancer Institute conducted a 1997 study that found that four of the five counties in the US that received the most radioactive Iodine-131 from the Nevada Test Site (NTS) nuclear bomb fallout were in Idaho. EDI considers all these victims of America's nuclear legacy regardless of its INEEL, Hanford, or NTS source, and offers on its website a small sampling of about 100 of their documented stories.

 In addition to the "official" National Academy of Sciences Board on Radiation Effects Research meeting November 6th in Boise, nearly a dozen spontaneous grassroots downwinder meetings brought folks together throughout southern Idaho to express their collective anger against the federal government's intentional radiation exposure of them and their families. This anger is spurred on by the Bush Administration's $27.6 million to restart nuclear bomb testing in Nevada that largely contributed to the current health crisis in Nevada, Utah, Idaho, and Washington whose residents were also exposed to DOE operational releases of radioactivity from Hanford and INEEL.

To their collective credit, regional newspapers continue to publish dozens of major articles that include extensive exposes on individual downwinders' health problems. If you are a subscriber/reader of one of these papers we recommend sending a "letter to the editor" praising the papers exemplary journalism.

 Researchers Find Radiation Causes More Diseases

Scientists at the Stanford University School of Medicine found that "Ionizing radiation can functionally alter the immune system and break self-tolerance"(a technical term for when radiation breaks down the normal ability to fight off disease). The study is published in the Journal of Immunology. The researchers irradiated the thymus and the peripheral lymphoid organs/tissues in mice to induce the autoimmune response. Total lymphoid irradiation on mice caused various organ-specific autoimmune diseases, such as gastritis, thyroiditis, and orchitis, depending on the radiation dosages, the extent of lymphoid irradiation, and the genetic background of the mouse strains. They concluded, "these results indicate that high dose, fractionated ionizing radiation on the lymphoid organs/tissues can cause autoimmune disease by affecting the T cell immune system." (1)

Downwinders have claimed for decades that radiation causes more diseases than the limited list of cancers that the federal government recognizes. High on the Downwinders list is the autoimmune disease multiple-sclerosis (MS), which appears to occur in epidemic proportions in regions exposed to Nevada Test Site, INEEL, and Hanford fallout.

Dr. Peter Rickards, DPM, reviewed the Multiple Sclerosis Society data on the incidence rates in Idaho. While searching for data Rickards found the government's Hanford website had noted, but dismissed the clear MS rate difference between Washingtonians upwind and downwind from Hanford. Rickards notes that the CDC says we should expect 88 cases of MS per 100,000 people, and states the American high is a rate of 160/ 100,000 people. The government noted, "The Society's estimated rate in Yakima, Kittitas, Benton, Franklin, and Klickitat counties is 200 cases per 100,000. These counties are in eastern Washington; Benton and Franklin counties are usually considered to be in the immediate downwind area from Hanford. The Multiple Sclerosis Society puts western (Pacific coastal region west of the Cascades) Washington's rate at 65 cases per 100,000 people based on voluntary reports to the Multiple Sclerosis Society," (2)

When Rickards checked the voluntary Idaho MS Society rates, the whole state averaged 174/100,000 , which is higher than the stated American highest rate. "High MS rates in Idaho include Ada County at 238.17 per 100,000, Lemhi at 200.5, Lincoln at 260.48, Gem at 191.49, Bonneville at 197.45 ." (3)

Rickards was contacted by former College of Southern Idaho faculty member, Fred Trenkle. While Lincoln County had the Idaho State high rate, that was with only ten voluntary reports. Fred's wife has MS and he has collected many classmates health information. Fred listed 21 people with MS just in Shoshone. That is just those with official diagnosis, with many more unable to afford a doctor, but showing signs of the disease. The highest rate of MS in the world that is confirmed by scientific study is 309 cases per 100,000 per people in the Orkney Islands, Scotland. Just using those 21 people in Shoshone (40 miles north of Twin Falls in Lincoln County) rates 520 per 100,000, and the town of Shoshone at 1487/100,000. Looking at a 30-mile circle Fred totals over 100 people with MS.

While MS clusters are often dismissed, when you look at downwind Hanford and all of Idaho, "it does appear a large footprint from the Nevada Test Site fallout matches the high MS rates." In asking the National Academy of Sciences for fallout compensation for autoimmune disorders, Rickards questioned, "We are a little big to be dismissed as a cluster, aren't we?"

According to an October 2004 article in the New Scientist, "The risk of getting cancer from tiny amounts of radioactivity inside the body could be 10 times higher than previously thought. That is the conclusion of an exhaustive investigation into the health effects of low-level radiation in the body by UK government advisers. It could prompt a rethink of the international safety limits for exposure to such radiation, which occurs during medical radiation therapy and when pollution from nuclear plants and weapons' tests is taken into the body via air, water or food.

"In a published report, the Committee Examining Radiation Risks of Internal Emitters (CERRIE) says that there are major uncertainties in estimating the dangers from plutonium and similar radionuclides inside the body. But the uncertainties could cut both ways, either greatly increasing cancer risks or reducing them to almost zero. In the circumstances, CERRIE urges the adoption of a precautionary approach to protect public health.

" 'We have to be particularly careful in judging the risks of radiation sources inside the body,' says CERRIE's chairman, Dudley Goodhead. 'The uncertainties in these internal radiation risks can be large, and these need to be taken properly into account in policy and regulatory decisions.' CERRIE was set up in 2001 and includes a dozen experts from the government's National Radiological Protection Board, the nuclear industry, universities and environmental groups. Surprisingly, the committee has come to broad agreement about the level of uncertainty involved in calculating the radiation doses received by different parts of the body, and in working out how much damage the radiation will inflict upon cells.

"The committee has also accepted that indirect damage caused to cells by low-level radiation are 'real biological events'. Laboratories in Europe and North America have shown that the descendants of cells that seem to survive radiation can suffer delayed damage, a phenomenon known as 'gnomic instability.' Cells adjacent to those that are irradiated can also be damaged, known as the 'bystander effect'. And increased mutations have been found in small pieces of DNA called mini-satellites which are passed from one generation to the next." (4)

Researchers at the Department of Epidemiology, School of Public Health at the University of North Carolina report that, "The US government recently implemented rules for awarding compensation to individuals with cancer who were exposed to ionizing radiation while working in nuclear weapons complex. Under these rules, chronic lymphocytic leukemia (CLL) is considered to be a non-radiogenic form of cancer. In other words, workers who develop CLL automatically have their compensation claim rejected because the compensation rules hold that the risk of radio-induced CLL is zero. In this paper we review molecular, clinical, and epidemiological evidence regarding the radiogenicity of CLL. We note that current understanding of radiation-induced tumorigenesis and the etiology of lymphatic neoplasia provides a strong "mehcanistic" basis for expanding that ionizing radiation exposure increases CLL risk. The clinical characteristics of CLL, including prolonged latency and morbidity periods and low case fatality rate, make it relatively difficult to evaluate association between ionizing radiation and CLL risk via epidemiological methods. However, epidemiological findings are consistent with an hypothesis of elevated CLL mortality risk following a latency and morbidity period that spans several decades. The findings of this review suggest that there is not a persuasive basis for the conclusion that CLL is a non-radiogenic form of cancer." (5)

According to a 1996-2000 report only recently released by the Cancer Registry of Idaho, "From United States cancer statistics 1999 incidence, Idaho had the highest rate of brain cancer among males in the nation. The reason for this [is] unknown, as the causes for brain cancer are not well understood. Suspected risk factors include exposure to vinyl chloride, radiation, and agriculture chemicals. Age-adjusted incidence rates (2000 U.S. standard) differed by [Idaho] health district, ranging from 6.9 cases per 100,000 females in Health District No. 5 to 9.8 cases per 100,000 females in Health District No 7 [in southeast Idaho]. Compared to [National Cancer Institute Surveillance, Epidemiology, and End Results] (SEER) data, brain cancer incidence was significantly higher in Idaho from 1999-2000." (6)

The incidence rate per 100,000 of brain and other nervous system cancer (1996-2000) by Health Districts that start numerically at #1 in the north and end with # 7 in the southeast of Idaho; Health District One (7.4); Health District Two (8.3); Health District Three (7.7); Health District Four (8.5); Health District Five (6.9); Health District Six (8.1); Health District Seven (9.8). National SEER brain and other nervous system cancer rates for all races is 6.5/100,000. "From 1970-2000, brain cancer incidence increased about 48% in Idaho, an average increase of 1.4% per year. From 1970-2000, brain cancer mortality doubled in Idaho, increasing at an average rate of about 2.2% per year. Compared with SEER regions, Idaho's brain cancer mortality rates were lower in earlier years, and higher in later years. Both Idaho an SEER regions had large numbers of brain and ONS tumors with unknown grade, although the percentage of unknown [and unreported] grade was almost twice as high as the SEER regions" (7)

Also according to the Cancer Data Registry of Idaho there is a steady increase in overall Idaho cancer rates from the beginning of data collection through 2002 (the latest report issued by the Registry). The 2000 report notes an increase of 359 cancer cases in recent years. "This was one of the largest single-year increases in cancer incidence in the history of the Cancer Data Registry of Idaho. Cancer sites with notable increases from 1999 to 2000 were lung, melanoma (in-situ), oral cavity and pharynx cancer counts increased over 1999 levels. The number of in-situ melanoma cases is 65% higher than for any previous year. The prostate cancer incidence rate is the highest it has been since the spike in prostate cancer rates in 1990-1993 due to prostate-specific antigen screening. However, the increase in rates was limited to Health Districts, 2 [north-central],4, 5 [south-western], and 7 [south-eastern]." (8)

Idaho registry data indicate the high cancer rates continue. "There were approximately the same numbers of cases diagnosed in 2001 as in 2000. However, there were some large differences by cancer site. Cancer sites with notable increases from 2000 to 2001 were Hodgkin's lymphoma, larynx, liver, plasma cell tumors, pancreas, and thyroid. Thyroid cancer incident cases increased 40% over 2000 levels, with increases of 50% or more in Health Districts 1, 3, and 4." (9)

Again, in the 2002 Idaho Cancer Data Registry, "There was a large increase in the number of reported cases from 2001 to 2002 (an increase of 452 cases from 2001 into 2002 as of one year after close of calendar year). Cancer sites with notable increases from 2001 to 2002 were brain, cervix, melanoma of the skin, pancreas, and stomach. Health District No. 1, [6, & 7] had statistically significantly more cases of cancer than expected based on the rates for the remainder of Idaho." (10)

The high cancer rates in Health District 1 could be attributed to emissions from DOE's eastern Washington Hanford nuclear reservation. Dr. Allen Bensen's analysis, as well as the research conducted by Dr. Thomas Pigford which was commissioned by the US District Court hearing the Hanford Downwinders suit, both showed that causation for the high rate of cancer in the Northern Idaho Panhandle and Health District 3 (Lewiston area) can be attributed to Hanford emissions following wind patterns up the Columbia and Snake River drainage canyons. For more information on this issue see Environmental Defense Institute website.

Rosie Mestel reports in the Los Angles Times on "Soviet Nuclear Tests Altered DNA" (2/8/02) that above ground nuclear tests conducted by the former Soviet Union from the 1940s until the early 1960s appear to have altered the DNA of people who were living near the test site and exposed to fallout, new research indicates.

"The study, conducted by scientists in Britain, Kazakhstan and Finland, looked only at selected pieces of DNA chosen as markers. The findings underscore the risks borne by civilian populations living near testing sites during the early years of the Cold War." (11)

Reports on the Chinese nuclear weapons test site in eastern Turkestan document that 200,000 people in Eastern Turkestan have died because of nuclear fallout" (12) This is clear evidence that nuclear bomb testing, regardless of where it occurs, kills people. The only sane solution is to reopen the Comprehensive Test Ban Treaty that the Bush Administration has spurned.

Idaho Politicians Sellout to DOE Legislative Efforts to Circumvent Established Nuclear Waste Laws

The October 2004 passage of the Republican controlled Congressional Defense Authorization Bill contains a buried provision that will allow Department of Energy (DOE) operations at the Idaho National Engineering and Environmental Laboratory (INEEL) to leave significant quantities of formerly classified high-level radioactive waste in place for ever. This will result in additional contamination of the Snake River Aquifer over time. INEEL radioactive and chemical waste is already extensively contaminating the aquifer that most of Idaho and the downstream Columbia River states of Oregon and Washington depend on as a primary water source. DOE is now given the green light by radical neo-conservative Republicans in Idaho and South Carolina to just dump grout on top of the tank waste and call it "cleanup."

In a New York Times article the Institute for Energy and Environmental Research, Brice Smith, a physicist, said government agencies have raised questions since 1991 about the stability of the grout. Among the problems, he said, is that the waste generates heat, and that the temperature in the environment around the tanks varies greatly by season. The resulting temperature differences could create cracks in the grout, he said. The group had previously calculated that if as little as one part in 1,000 of the radioactive cesium in the tanks were allowed to escape in the first 100 years, local drinking water supplies would be polluted above allowable standards.

This new legislation specifically exempts INEEL and the Savannah River Site in South Carolina from provisions of the Nuclear Waste Policy Act (NWPA) that mandates that all high-level radioactive waste be interned in a permanent and permitted geologic repository.

The Natural Resources Defense Council (NRDC) won a lawsuit in US District Court against DOE for attempting to violate the NWPA law. DOE appealed that decision in the US Court of Appeals, which has yet to issue a ruling. In March 2004 the states of Idaho, Oregon, New Mexico, New York, South Carolina, Washington, and the New York State Energy Research and Development Authority filed an aggressive joint Amicus Curiae (friend of the court) brief in support of NRDC. It is instructive to note that only Idaho and South Carolina later went along with DOE in the legislative exemption that gave these two states exclusive control over determining cleanup standards for this high-level radioactive tank waste. What this means for Pacific northwest residents is that we are at the mercy of what critics call a "politically compromised" Idaho Department of Environmental Quality (IDEQ) that has already issued a closure permit for five of INEEL's high-level radioactive waste tanks using grout for permanent in-place internment. The Environmental Defense Institute filed a formal challenge to this IDEQ permit, but were summarily dismissed. See EDI's website publications for the text of tank closure petition.

Idahoans and future generations within the Snake River and Columbia River basins are now at an even greater risk because of these misguided political decisions. The INEEL waste percolating into the aquifer will be biologically toxic for tens of thousands of years. Is this the legacy Idahoans want to pass on to future generations? It is time for all of us to demand political accountability of these politicians who claim to represent our interests!

Tragically, the US Ninth Circuit Court of Appeals failed to issue a ruling other than to remand the high-level waste disposition case, initially brought by the Natural Resources Defense Council, back to US District Court in Idaho with the recommendation to dismiss the case. "The appellate court said November 5th it was too soon to say if those Department of Energy plans to reclassify formerly high-level waste violated the Nuclear Waste Policy Act. All parties must adopt a wait-and-see attitude rather than make assumption about the Energy Department's intentions and ability to dispose of waste a three-judge panel of the 9th U.S. Circuit Court of Appeals said." (13)

Thanks to Idaho's Congressional delegation's successful passage of legislation, INEEL is already exempt from the Nuclear Waste Policy Act, so presumably any additional court rulings will only affect Hanford and the other states who refused to sign on to the compromised legislation exempting DOE from environmental laws.

Now Idahoans only have a politically compromised Idaho Department of Environmental Quality between them and the prospect of thousands of years of leaking radioactive contamination into the region's sole source aquifer.

EPA's Own Inspector General Says the Agency's

Rulings Aid Polluters

Michael Janofsky reports in the New York Times (10/1/04) "In a rebuke of the Bush administration, the inspector general of the Environmental Protection Agency (EPA) said that legal actions against major polluters [by nearly a dozen state attorney generals class action suit] had stalled because of the agency's decision to revise rules governing emissions at older coal-fired power plants [and DOE operations that were also granted an exemption]. The inspector general Nikki L Tinsley, took direct aim at the administration's revision of the New Source Review rule, on of the administration's most prominent - and vilified - environmental initiatives, saying that it makes it easier for power-plant operators to postpone or avoid adding technologies that reduce polluting emissions. The revised rule, made final last year, has not been put in effect yet because of legal challenges [by state attorney generals]. But the report concludes that just by issuing the rule, which scuttled the enforcement approach of the Clinton administration, the agency has 'seriously hampered' its ability to settle cases and pursue new ones.

"Ms. Tinsley's report serves as a sharp challenge to Jefrey R. Holmsted, an assistant EPA administrator who has been the agency's leading proponent of the new rule. Ms. Tinsley said in the report that her investigators found little basis for the rule and suggested that "while the language of the report is critical, the inspector general cannot force the agency to do anything." The report also showcased a split in the agency between political officials in the air quality office, which Mr. Holmstad leads, and lawyers charged with enforcement including some who have left the agency in frustration. "Ms. Tinsley, who was appointed by President Bill Clinton, said in the report that under the prior case-by-case standard, legal action over a 10-year period resulted in 650,000 tons of reduced emission of nitrogen oxide and sulfur dioxide. She said current enforcement actions could lead to another 2.3 million tons of reductions but that the likelihood of looser restrictions had caused plant operators to put off making upgrades."

Before too much credit is given to the Inspector General, it most be noted that nearly a dozen state attorneys general filed a joint law suit against EPA over the agency's ruling that resulted in a temporary suspension of the EPA ruling.

Hanford's ongoing process to shut down its huge nuclear processing plants is generating enormous quantities of liquid highly radioactive waste that the DOE is blocked from disposing at the Hanford site by the State of Washington. This waste is now shipped to INEEL for treatment/disposal because the Idaho Department of Environmental Quality is not opposed for political reasons. Most recently, 300,000 gallons of Hanford's Fast Flux Test Facility reactor (FFTF) waste was shipped to INEEL for processing and disposal. Huge volumes of other Hanford nuclear fuel storage pool liquid/sediment wastes now in "cleanup" mode are slated for shipment to INEEL.

This Hanford waste shipped to INEEL is processed in unpermitted treatment plants that currently cannot pass Clean Air Act or Resource Conservation Recovery Act emission standards. See EDI website for detailed challenges to the INEEL INTEC Liquid Waste Management System.

INEEL Changes its Name and
Mission Again

For the fourth time in its history, INEEL has changed its name once again. Department of Energy (DOE) now calls the site the Idaho National Laboratory (INL) that will now include the Argonne National Laboratory-West (formerly managed by the University of Chicago) under the direct management of DOE's Idaho Operations Office. Additionally, the operating contractor for INL is changed from Bechtel to a consortium called Battelle Energy Alliance under a new $4.8 billion contract with DOE. This new contractor consortium includes Battelle, BWTX (that includes Bechtel), Electric Power Research Institute, Washington Group International, and Massachusetts Institute of Technology. In the past, changes in site operating contracts has resulted in massive document destruction and loss of accountably on operations during that period. Moreover, this churning of site contractors limits the liability exposure for the contractors. See EDI website for more information on document destruction.

One of the new missions for INL is plutonium production for NASA's space program. DOE issued a Record of Decision designating the Advanced Test Reactor and other reactor fuel reprocessing operations at INL for the production of 5 kilograms of plutonium-238 per year. (14) This production will likely expand when NASA's $11 billion nuclear rocket program moves into testing mode. INL is a likely candidate site for testing of the nuclear rocket due to the site's long testing history of Aircraft Nuclear Propulsion engines and existing infrastructure to support the new program.

CDC Releases Draft INEEL Worker Health Study

CDC's National Institute for Occupational Safety and Health (NIOSH) released a draft of the INEEL worker health study. This study contains fundamental methodological flaws that the Environmental Defense Institute brought to the agency's attention at the very beginning of the study, but were ignored. NIOSH used "The mortality experience of workers who were badged for ionizing radiation exposure [that] was compared to that of un-badged workers," and "regional cancer rates" otherwise called "downwinders." This is like comparing smokers and non-smokers inside a smoke-filled bar and is not good science! A more credible "control group" to the "badged" INEEL workers would be a healthy military unit at Ft. Bragg that has no history of radiation exposure. This is noted because of the "healthy worker effect" that CDC has consistently ignored in this and other studies because the agency wants to compare INEEL results to the general public cancer incidents that by definition include vulnerable individuals not in the "healthy worker" workplace. This compromised science skews the results toward a politically predetermined result.

INEEL workers have for decades challenged the accuracy of their radiation "badge exposure" data by DOE contractors and the arbitrary median age of 54.4 years because it does not include post-occupational health outcomes. Despite NIOSH's methodology warping the agency still found elevated levels of bone cancer, non-Hodgkins lymphoma, brain tumor, asbestosis, mesotheliomas, leukemia, and lymphatic cancers. (15)

Nuclear Weapons Research Today = Testing Tomorrow

Jim Matheson, U.S. House of Representatives Democrat from Utah's 2nd District reports in the 10/24/04 Salt Lake Tribune, "There's an ongoing debate on resumed nuclear weapons testing. Some have suggested that research and development of new nukes can somehow be accomplished without actual testing before the weapons enter our nuclear arsenal. I disagree with this claim because scientific experts have laid out a clear argument for why new nuclear weapons research will lead to testing.

"For the past two years, the National Nuclear Security Administration (NNSA) has been insisting that Congress fund new nuclear weapons research. Congress knuckled under to the pressure last year by lifting a decade-old research ban and funded enhanced test site readiness and research on two new nuclear weapons programs, the Robust Nuclear Earth Penetrator (RNEP) and the Advanced Concepts Initiative (ACI). I opposed all of these measures.

"Supporters of these new weapons claim that they won't need to be tested, referencing the RNEP. Let's keep in mind that funding is also going toward completely new designs, via the Advanced Concepts project, which experts say can't just be computer simulated. The highly respected National Academy of Sciences has already said that nuclear weapons testing 'would be essential to certifying the performance of new designs at the level of confidence associated with currently stockpiled weapons.'

"The prospect of renewed testing strikes fear in the hearts of thousands of Utahns. Yes, the days of above-ground testing are gone, but it's not enough that a device be buried. More than 900 underground tests took place at the Nevada Test Site. The 1989 Office of Technology Assessment Report says, 'Since 1970, 126 tests have resulted in radioactive material reaching the atmosphere. Here's the bottom line: Experts say if new nuclear weapons are developed, they would likely need to be tested. Underground testing is not foolproof. It is wrong to use Utahns or Americans, least of all our soldiers, as guinea pigs. Let's not go down this road again." Congress approved $27 million for nuclear weapons testing at the Nevada Test Site."


1. N. Sakaguchi, K. Miyai, and S. Sakaguchi, The Journal of Immunology, Vol 152, Issue 5 2586-2595, American Association of Immunologists, April 2-6, 1994.

2. Environmental Health Programs, Hanford Health Information Network website page 5 to 8, http://www.doh.wa.gov/hanford/publications/overview/immune.html

3. Dr. Peter Rickards letter to Isaf Al-Nabulsi, chair of National Academy of Sciences, RECA Panel, September 20, 2004..

4. NewScientist.com News Service, October 20, 2004

5. Richardson, David, et al., "Ionizing Radiation and Chronic Lymphocytic Leukemia," Environmental Health Perspectives, National Institute of Environmental Health Sciences, www.ephonline.org

6. Cancer Data Registry of Idaho website www.idcancer.org/special/ brain 9600.pdf

7. Ibid

8. Cancer in Idaho - 2000, Annual Report of the Cancer Registry of Idaho, December 2001, page 5. http://www.idcancer.org

9. Cancer in Idaho - 2001, Annual Report of the Cancer Registry of Idaho, April 2003, page 5.

10. Cancer Data Registry of Idaho, Annual Report, Cancer in Idaho 2002, April 2004, pages 5 & 72, that shows Health District Nos. 1 (p=0.05 or less), and Health Districts 6, & 7 (p=0.01 or less) had statistically significantly more cases of cancer than expected based on the rates for the remainder of Idaho. http://www.idcancer.org/annualreports.html

11. Rosie Mestle, Los Angles Times, "Soviet Nuclear Tests Altered DNA Study Says," February 8, 2002

12. Eastern Turkestan Union in Europe, "Consequences of Nuclear Tests in Eastern Turkestan China's nuclear tests in Eastern Turkestan." Mavlan Yasin, Myasin@UniversalCare.com, November 15, 2000

13. Seattle Post-Intelligencer, 11/7/04

14. Federal Register Vol.66, No. 18, 1/26/2001. Also see Final EIS for Accomplishing Expanded Civilian Nuclear Energy Research and Development and Isotope Production Missions in the US, DOE/EIS-0310

15. CDC National Institute for Occupational Safety and Health, An Epidemiologic Study of Mortality and Radiation-Related Risk of Cancer among Workers at the Idaho National Engineering and Environmental Laboratory, a US Department of Energy Facility, October 2004. http://www.cdc.gov/niosh/2001-133.html