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By Cliff Honicker, M. A., Director, American Environmental Health Studies Project, Inc.,

with assistance from Jackie Kittrell, Esq., AEHSP; Sandra Reid, R.N., Romance Carrier, Oak Ridge Health Liaison; Cheryll Dyer, Coalition for a Healthy Environment; [CHE] George Kennedy-White, Esq., AEHSP; Janet Michel, CHE, Mike Knapp, SOCM and Kathryn Swain, M.A., CHE

This paper is dedicated to Ann and Mack Orick, the members of the Coalition for a Healthy Environment and the countless workers at K-25 who came into contact with nickel powder.
 

Summary

After a careful investigation, through worker interviews and from records made available to us from the DOE declassification office, we conclude that, on December 6, 1976, the Department of Energy (DOE) created a Health study with a predetermined conclusion. Doing so violated their duties not only to protect workers, but they violated fundamental cannons of ethics in science and medicine.

    DOE created a health mortality study for political, rather than medical ends.

    They sought specific epidemiologists, records, and facts that would support their predetermined conclusion.

    They manipulated the cohort base and excluded two-thirds of the people that they acknowledged were potentially exposed to nickel. Declassified papers revealed Manhattan Project and AEC doctors found women to be more sensitive to nickel powder exposure than men. African-Americans during the 1940's and 50's would have had the jobs most likely to expose them to nickel powder. Who were the people excluded from the study? Women and blacks.

    According to internal reports there were gross discrepancies between the air monitoring data and the visual inspections of loose nickel powder in the workplace environment. "Official" records showed the level to be at the current permissible standards. Visual inspections by the manufacturer of that powder in the workplace showed it to be well in excess of the official record. DOE, working with the contracted ORAU scientists doing the study with the pre-determined conclusion, disregarded the visual evidence, as it ran contrary to the intended findings of the study.

    While they accepted highly questionable air monitoring data, the same scientists openly rejected biologic data extracted from the worker's urine as indicators of their exposure to nickel powder. Their reasoning? The levels found in the workers were too high. They did not conform with the data found in the air monitoring. The nickel levels found in the urine of the K-25 workers were ten to hundreds of times higher than any other nickel workers in this country and around the world.

    DOE took every conceivable opportunity to reach the conclusion of no adverse health effects in order to defeat a proposed new NIOSH standard to lower the allowable exposure limits. This was done ostensibly to protect the country's ability to make uranium. The approach would save millions of dollars by avoiding the retooling of the nickel powder facilities at INCO in Canada and at K-25 in Oak Ridge.

    DOE met their political objective. In so doing, they may have also created a false myth of safety in exposure to nickel at K-25, putting untold workers at greater risk at both K-25 and in other nickel processing plants around the country. Where the "permissible" standard to nickel would have a workplace where nickel in the air is virtually invisible to the naked eye, several eyewitness accounts of nickel processing and waste handling operations at K-25 in the 1980's and 1990's tell of "smoky" "hazy" and "fog" like conditions in nickel powder operations.

    In 1999, after Secretary Richardson apologized to workers for unsafe working conditions at the DOE facilities, DOE held a number of meetings in Oak Ridge, Rocky Flats, Hanford, Portsmouth and Paducah. At every site, scores of workers told the same story of slipshod industrial hygiene, questionable if not falsified radiation badge dose readings, falsified air monitoring reports, and callous and cruel treatment to workers who attempted to reveal the truth to the public of these conditions. .

    This investigation gives those anecdotal testimonies scientific weight. By investigating DOE's past wrongdoings, it is hoped this effort will: 1) lead to ethical, exhaustive and independent health studies of, by and for the affected workers at these facilities; 2) establish a concrete record of the real working conditions within these facilities; and 3) lead to the formation of a new method of conducting science, medicine and health investigations within the walls of the DOE facilities such that the health of the people, rather than the "institutional protection" of the DOE and it's Contractors, is of paramount importance.

On December 6, 1976, a group of ERDA officials gathered in a closed-door meeting in a windowless office⁽¹⁾

Government officials, including Oak Ridge Gaseous Diffusion Plant/Oak Ridge Operations managers, and nickel suppliers for the uranium enrichment gaseous diffusion production program sat around a table. The meeting was an outgrowth of at least two, and possibly as many as twenty, earlier meetings -- all classified "Secret".⁽²⁾ The reason for the closed-door meeting was that Joseph Califano, Secretary of Health, Education, and Welfare (HEW), along with the National Institute for Occupational Safety and Health (NIOSH), had proposed a strict new standard for worker exposure to airborne nickel powder. From a worker perspective, the new standards promised a healthier workplace. But no worker advocates were present at the meeting to offer their viewpoint. For the officials at the table, the proposed standard represented a threat. The new standard, if put into place, could seriously jeopardize the U.S. nuclear weapons operations and the world supply of nickel powder for commercial sales.

The new standard would reduce permissible airborne workplace exposure to the powder by 200 time-from one-thousandth of a gram per cubic meter to five millionths of a gram per cubic meter.⁽³⁾ This proposal mobilized the management of both the Oak Ridge Gaseous Diffusion Plant, known as K-25, and the International Nickel Company [INCO], a Canadian company and the world's largest manufacturer of nickel, into action. Nickel powder, mixed with other classified material,⁽⁴⁾was one of the key secret ingredients in the machinery used to enrich uranium for America's nuclear power and nuclear weapons program.

The amount of nickel powder used at K-25 is a secret, but recently declassified documents give a hint as to both the amount and the particle size. While the quantity used can only be roughly estimated, its amount is gargantuan, perhaps in excess of a quarter-billion pounds. As huge as that number is, the individual particle size is so infinitesimally small that it is difficult to imagine. It is, however, so small that it has to be measured with an electron microscope.⁽⁵⁾ Ironically, the smaller the size of the particle, the greater the biological impact of the nickel on the people who breathed the dust or absorbed it through their skin.

The men in that closed-door meeting were faced with a dilemma. In one of the earlier secret meetings on the subject, the government officials and INCO corporate representatives speculated that the proposed regulation would result in only a ten-fold tightening in the current standards. Yet a ten-fold reduction would have required "considerable modifications to our powder handling equipment since average air samples taken in the area of the blend towers in the barrier plant are about 0.3 mg/m³.^(6)"  If a ten-fold reduction would cause "considerable modifications," one can only speculate as to the degree of plant overhaul that would be needed to meet a two-hundred-fold reduction in airborne nickel powder levels at both the commercial and secret industrial sites. The proposed standards would make it extremely difficult and very expensive for all the industries to process, refine, and use nickel powder. That much is clear.

It should be noted now that the telling of this story is heavily circumscribed because practically all aspects of this half-century-old uranium enrichment technology are still very, very secret. The processes in which the nickel was handled at every step and stage in the uranium enrichment process is classified to this very day. The buildings in which hundreds of millions of pounds of nickel were transformed into tens of millions of parts are so classified that the even the linking of a basic industrial process to a specific building at K-25 is still a secret⁽⁷⁾. Every worker, from the janitor sweeping nickel powder dust off the shop floor, to the top management must be security-cleared to work in the area. They are admonished under National Security laws to reveal no aspect of their work under the penalty of "up to life" in prison under the Treason Act. Conducting any kind of independent investigation under these circumstances is practically impossible. Therefore, estimates of use, description of processes, and worker accounts are told as accurately as possible without intentionally divulging any national security secrets.

Nickel was a lynchpin in uranium enrichment. Americans have never been told of its critical role in America's nuclear weapons program, or its impact on the setting of US worker nickel exposure standards. Requests for the declassification of more than a 150 "Secret" documents on the subject, combined with an earlier 1993 Congressional request for information, make up the bulk of what is known regarding a largely untold story.

This much can be said. Over 500 "Converters," joined together in stages, enriched uranium at K-25. The converters varied in size -- some being larger than a standard-size room. The guts of each massive uranium enrichment converter at K-25 were filled with tens of thousands of porous nickel tubes. The converters were powered by multi-thousand-horsepower electric motors. It is often stated in Oak Ridge that when the single uranium enrichment plant ran at full capacity, the K-25 site consumed more electricity than all of New York City combined.

The barrier tubes inside the converters were made from pressed nickel powder in a process called "sintering." How the tubes were made and what substances went into the nickel tube production process is one of the most closely-held secrets of the uranium enrichment and atomic bomb-making efforts in America. Despite repeated requests to the Freedom Of Information Act [FOIA] office and the Public Affairs Office in Oak Ridge for the total amount of nickel powder used in the enrichment process, the exact amount is still classified. Recently declassified documents reveal that in the 1960's, approximately six million pounds of new nickel powder was used at K-25 each year to make replacement barrier tubes for the converters, while six million pounds of nickel tubes were then removed from the converters and the cascade as scrap barrier.⁽⁸⁾

Although these are rough estimates, it is possible that INCO could have sold perhaps as much as a quarter billion pounds of nickel powder to the U.S. government for the Oak Ridge Operations.⁽⁹⁾ This means that, at least during the 1960's and 70's for which there is declassified documentation, every single month, the K-25 facility processed as much as a million pounds combined of "fresh nickel powder" and "contaminated nickel scrap."

The new standard proposed by Califano would cause serious problems in the nickel industry generally and also in operations at ORGDP (referred to by its site name, K-25). If the management of the K-25 uranium enrichment nickel barrier tube operations had to adhere to the new limits, the whole enrichment process could be thrown into jeopardy!⁽¹⁰⁾ No enriched uranium translated into no new bomb material for America's nuclear weapons stockpile. Something had to be done and fast.

At the secret 12/76 meeting, the men argued that the new proposed standard was based on old health data that might present an unfair picture of nickel exposure. What they were working with at K-25 was pure metallic nickel. The earlier health studies were based on health studies of nickel workers that were exposed to nickel and a number of impurities. The earlier studies had found excess cancer deaths in nickel workers in America, Russia, England, and Norway. But, the men sitting around that conference table in 1976 speculated that it was the impurities, not the nickel that led to the excess cancer deaths of nickel workers around the world.⁽¹¹⁾

They insisted that the solution was not to improve the industrial hygiene of the plants, thereby exposing workers to lower levels of nickel, but to create their own health study to "prove" the new standard proposed by Califano and NIOSH to be unnecessarily strict. A study at K-25 could provide such data which might be used in preventing the establishment of unreasonably low exposure limits by OSHA.⁽¹²⁾INCO and ERDA Oak Ridge Operations agreed to jointly fund a study to show that workers exposed to much higher levels than those now proposed were, in fact, healthier than the general population. In the earlier "Secret" meeting, INCO stated their motivation for funding the study quite clearly. He stated that INCO would be willing to aid in the cost of making a study since the information would be used in defending against unreasonably low TLV's.⁽¹³⁾

At the moment this agreement was reached, any hope for an independent, unbiased study conducted to protect worker health vanished. The stated assumption was that the new regulation would be unnecessarily strict. Before even knowing the outcome of the scientific study, the men around the table knew that the results would be used in "defending" their company against "unreasonably low" Threshold Limit Values [TLV], or the new standards proposed by NIOSH. The greatest unstated assumption is that the health study had a pre-determined conclusion. The unstated assumption was that the new standard threatened the national security because it threatened the production of nuclear weapons. Also unstated, but on a very real personal level, it threatened the profits of the world's largest manufacturer of nickel and ultimately the global nickel economy. The new standard threatened to raise the cost of every nickel-related product made in America, right down to the stainless steel kitchen sink -- even the cost of minting the U.S. nickel coin.

They had one year to get the study completed so their case could be argued in Washington, DC,against the proposed nickel health standards. How they ultimately defeated the proposed standard is not an exercise in medical or health science, but an exercise in political science.

Several key issues and critical assumptions permeated every detail of the study from this point forward. This paper will highlight and address these key turning points where the researchers could have revealed information that shed light on the flaws in their study and the possible connections between nickel exposure and adverse health effects. In each instance, the collaborators adhered to the foregone conclusion of their health study that no adverse health effects resulted from exposure to nickel powder at K-25.

An epidemiologist "inside" the government operations was quickly assigned the task of conducting the health study.⁽¹⁴⁾ There was, however, a drawback to this choice: . . . she is closely related to Oak Ridge Operations which could detract from the credibility of the study.⁽¹⁵⁾ The men anticipated a "credibility problem" in their choice of a researcher so close to the Oak Ridge Operations, but their future operations were at stake. Theywere the sole funders of the study. Only people inside the Oak Ridge Operations loop would be chosen to do the work, and the management of K-25 wouldclosely oversee the progress of their work. They could short-circuit any questions about credibility by having the study "peer reviewed" by outsiders.⁽¹⁶⁾  In the meantime, a K-25 manager would be project director of the study. Both the project manager and Ms. Tompkins, an epidemiologist with Oak Ridge Associated Universities (ORAU, an institution that derived over 90% of it's financial existence from AEC/ERDA/DOE) would keep INCO, ERDA, and K-25 management updated on the progress of the study through monthly reports. The management involved in the meeting would review all drafts of the health study before release to the public. To say it was a tightly controlled and managed study would be an understatement. Given the aims and objectives of the study, it is not surprising that affected workers, union health and safety stewards, and independent medical professionals were not even considered to participate in the creation, conducting, or oversight of the study.

According to the notes from the confidential business meeting, over 2,500 people who worked in or around the nickel operations at the K-25 plant for at least six months were to be included in the study.⁽¹⁷⁾

Absence of Animal and Human Medical Data From Oak Ridge

In addition to studies of these 2,500 people, according to the Confidential meeting notes, animal assay and toxicity nickel studies, that the Atomic Energy Commission research labs had conducted in the past would be reviewed, and possibly more nickel exposure animal studies would be conducted at Oak Ridge National Lab's Biology Division.⁽¹⁸⁾. No results of an investigation on the toxic effects of nickel powder on animals was found in the completed health studies, nor in the documents placed in the public reading room by DOE in response to the request that released these nickel papers. An independent archival search in the earliest Atomic Energy Commission (AEC) reports reveals Oak Ridge Operations' interests in nickel exposure effects as early as 1953, when radioactive tracer studies were conducted on animals to find the primary areas of nickel deposition: the lungs, kidney, and liver⁽¹⁹⁾. Ms. Tompkins, the epidemiologist chosen for the nickel study, reported none of the nickel toxicity or assay studies generated by either Oak Ridge National Lab or the joint Atomic Energy Commission/ University of Tennessee Agricultural research program findings on the toxic effects of nickel exposures in animal research.

If the only objective of the Tompkins study was to find that the proposed health standards were too strict, then any data that would even hint at harmful effects from exposures at any level would not rise to the surface of the published report. That sort of information would not be supportive of their stated objective. A memo written during the health study indicates clearly that the researchers did review classified health-related material involving both humans and animals on nickel.⁽²⁰⁾

If one did want to make a link between causes of death and other health related problems associated with nickel powder exposure, then locating and reporting the classified and unclassified animal studies on nickel toxicity would be a first step in any scientific investigation on health effects. To those people who might still be living and suffering symptoms related to nickel poisoning, finding those documents and providing them to their doctors could be vitally important. Current and former workers at K-25 may be suffering symptoms related to nickel exposure. These classified studies may provide a link to establish that they have, in fact, been damaged by exposure to nickel. But, despite FOIA requests and independent archival searches, formerly classified nickel animal and human toxicity studies conducted in Oak Ridge, Tennessee have not been found or provided to the public.

People allegedly harmed by Nickel exposure not reported in the Study

In any mortality study involving a few hundred to a few thousand people, the absence or presence of a few key deaths can make a 180 degree difference in the study's outcome. The entire outcome can be changed by excluding from the study population, people who are known to have been affected by such exposures. Deciding who should be included in a study population when workers move in and out of different work areas, departments, buildings, and job classifications is difficult. However, it is reasonable to expect that anyone reporting harm related to exposure to the substance being studied would at least be mentioned. This is especially true when the health outcome of a single individual can sway the study from negative to positive adverse health findings. In a draft of a February monthly progress report. the author (presumably Ms. Tompkins, no author is listed on the draft) states, "Another melanoma, lymphosarcoma, or a single nasal sinus cancer among them could make things look quite different with regard to occupational risk."

Nine months into the year-long study, the project manager, C. W. Weber, a manager at K-25, updates the list of nickel workers being studied⁽²¹⁾. Weber makes note of four workers who are identified as "Special Cases." It was reported in the New York Times over a decade ago that the term, "Special Cases," referred to workers who claimed illnesses and injuries in the nuclear weapons production industry from workplace exposures during the Manhattan Project and the AEC days⁽²²⁾. The four "special cases" were separated for a "special presentation"⁽²³⁾. What was the presentation? Were their health problems compared to the data found in the animal toxicity studies? Were they included or excluded from the health study as a result of their reported claims of illness or injury? Were their health problems similar to the "problems" reported in nickel workers in other countries? We do not know. Their health conditions were not reported in the final study. Neither the detailed medical, radiological, and nickel exposure files of the four special cases, nor the notes from the presentation, were among the investigation papers of the nickel health study⁽²⁴⁾. Nor were the detailed files of the "Special Cases" provided to Congressional investigators in the 1992-93 inquiry on heavy metals and possible human health effects in Oak Ridge⁽²⁵⁾.

This is even more striking given that in the confidential business meeting, during which the nickel health study was designed, it was determined that both mortality and morbidity data would be collected. Morbidity data have to do with people who have health problems but have not died from those health problems. The "Special Cases" could have been integrated into the formal study a number of ways:

The health problems of the "Special Cases" could have been compared to sick nickel workers in other countries,

Their symptoms and health problems could have been compared to those found in the animal studies; and

Their health problems could have been compared to the health problems found in the morbidity data that was collected on their fellow workers.

All of this could have been reported in the final report. That is, if the report had been created to look for, identify, and rigorously investigate the real health effects of exposure to the nickel workers. They could even have investigated the levels of nickel that were excreted by the special cases, both at the time of their exposure and now. Such information could be especially useful in determining appropriate exposure standards to protect worker health. Such investigations were short-circuited. Perhaps they raised more questions than they answered--questions that undermined the foregone conclusion of the study that the newly proposed standards were unnecessarily strict.

Who's in, Who's Out? "Massaging" the Cohort Base

The health of the workers was to be officially studied from the perspective of the workers' cause of death. The death certificates were collected from the pool of 2,589 workers to be studied. According to the design of the study, monthly progress reports were to be made by both the project manager at K-25 and by Tompkins and her group at ORAU. Yet, only fragments of a few progress reports are found in the documents from Tompkins group, and only one progress report from the project manager at K-25 is found. It is clear, however, from a fragment of a progress report, that the selection of the study cohort population group was made after the search for causes of death were made on the entire study group of 2,589 workers to be studied. The reasons given:

1:    Two lung cancers were found in white males in the nickel workers, none in the African-Americans or females.

2:    The majority of people hired in the nickel area of the plant were hired before 1954.

3:    The study group would be white male workers hired from 1948-1954 in the nickel barrier production facility.

The latency period for the cancers of concern ranged from 20-35 years. As it was, their study period (1954-1972) would just barely make it into the beginning latency period for lung cancer, while missing the peak latency period for nasal-sinus cancer altogether. The study group was narrowed from 2,589 black and white men and women to 814 white males.⁽²⁶⁾

While on the surface, it does appear logical to limit the study to the earliest workers hired so that the latency period for cancers would have a chance of manifesting the cancers expected from workplace exposures, it is clear there were some significant drawbacks in the manipulation of the study population. It simply appears incongruous to gather the death certificates, review the causes of death, and then unilaterally decide to limit the study population size by two-thirds.

A particular concern is the exclusion of African-Americans from the study. According to R.L. Ayers, a long-time resident in Scarboro and a student of African-American history at the plant, in a recent interview,"In the early days, it didn't matter if you had education or not. Black men with bachelors and masters degrees came to work at the plants at Oak Ridge, they came in as janitors." An interview by this researcher with a retired worker from the nickel barrier facility told the story of how, at the end of the shift, the janitors would line up in a long line and sweep the powder off the floor, from one end of the building to the other. By sweeping the waste nickel powder on the floors, re-suspending the particles in the air, and having no protective respiratory gear. They would have had, potentially, some of the highest exposures to the nickel powder. This alone casts doubts on the conclusiveness of this study--especially since very small numbers of cancers could dramatically change the results of the study.

Only two months into the study, the lead epidemiologist reported some disturbing news to the project manager.⁽²⁷⁾ They found two respiratory cancers in the exposed nickel workers. That alone, compared to the control group, was not significantly high. But, if one extrapolated out to the point where all the people in the study group were to eventually die, "The size of the population is such that the observed number of cases is consistent with as much as a 50 per- cent increased incidence in lung cancer and a 4,000 per-cent increase in cancer of the nasal sinuses".⁽²⁸⁾ Tompkins and her colleague, Dr. James H. Godbold, Jr., said that the exposed population of now only 814 white males was very small for drawing statistical inferences to the larger population. The epidemiologist also made the puzzling statement that even though there were no sinus cancers, (with the expected number in this small a group being .07 case, or less than one-tenth) the current rate of respiratory cancers would lead one to expect a 40-fold increase in sinus cancers in the 8l4 nickel workers by the time they had all died. In other words, they would be reporting a false positive, due to the small size of the study population. Finally, if those two statements were not amazing enough, they left no doubt as to the sole purpose for conducting the study, and of the questionable value of the study they would eventually author:

"However, it must be recognized that the population size is so limited that even if this population displays exactly the same mortality rate due to lung cancer and nasal sinuses as a similar population not exposed to nickel, these findings would still be consistent with an increased risk of lung cancer and a large increased risk of nasal sinus malignancy. This statistical limitation of the population at risk, coupled with the fact that this population is just now coming into the assumed peak latency period, casts doubt on the efficacy of using findings in this population to convince OSHA that the NIOSH-proposed standard for exposure of nickel workers is set too low".⁽²⁹⁾

It would seem that a reputable scientist at this point would shut the study down. The inherent short-comings of the population size and the latency period issue biased the study toward not finding excess cancer mortalities in the nickel workers. But, that is exactly what they wanted to find. And that is why the study went on, despite the fatal scientific flaws of the study. The study was conducted to protect the current and future production of nickel, because that ultimately ensured there would be no interruptions in the production of enriched uranium for America's nuclear weapons program. The project director of the nickel mortality study was not a disinterested, independent health professional, but a management official for one of the largest consumers of nickel in America, the US government's uranium enrichment program.

Only the draft and the final version of the January monthly report by the K-25 project manager, Dr. C. W. Weber was found in the nickel documents that DOE released as a result of a request by Rep. John Dingell in 1993.⁽³⁰⁾ While Dr. Weber stated in the objectives of the study,

"To evaluate whether the tolerable airborne nickel levels and other conditions for working with nickel powder at K-25 need improvement to reduce personnel health hazards," (pg 1), the top priority appeared to be "Throughout the course of the project, give specific attention to the NIOSH proposal to reduce the TLV for airborne nickel to 5 ug/m³. This is a factor of 200 less than the present TLV and may be too restrictive."⁽³¹⁾ By his directive for keeping the ERDA-ORO, INCO and K-25 management informed every month by every member of the project team, more than 50 status and progress reports should have been generated on the nickel project. Only portions of a half dozen of those reports focusing on the months of January and February, 1977, were made available to Rep. John Dingell as per his request for all documents relating to heavy metal exposure and health effects from DOE/ERDA/AEC's Oak Ridge operations in his 1993 request.⁽³²⁾ Having a complete set of those progress reports would be invaluable in understanding the true strengths, weaknesses, and objectives in the creation of this historic health study.

It would seem if the people involved in this study were really concerned about "reducing personnel health hazards," they would have conducted extensive interviews with workers retired from, and currently at the K-25 nickel barrier operations. A series of such interviews would be vital to determine what the real health hazards were, both historically and contemporaneously. That would have been in line with the original directive in the Confidential business meeting that set up the outline of the study that morbidity data would be collected on the workers. Weber notes in the official January progress report: "The project study group has visited the Barrier Plant and plans additional briefing and tours. More complete information will be received relevant to work history of specific employees and nickel exposure conditions."⁽³³⁾ However, from the documents publicly released, there is a complete absence of any interview notes of potentially affected nickel workers that personally describe their working conditions in the nickel barrier operations taken by either Tompkins or Godbold. Again, if the focus of the study was to evaluate whether the NIOSH proposed standards were unnecessarily strict, conducting such interviews might bring more to the study than they needed or bargained for. Throughout the rest of this article, worker interviews made in 1998-99 by this researcher will be reported in boxes. These notes are intended to give the reader a feel of the "real" working conditions in the nickel manufacturing and storage areas at K-25, within the limitations imposed by National Security:
 

Security Guard, Harry Williams, K-25 "We would have responsibility all over the facility. When we were in that area, we had different kind of exposures than most people. We had tactical concealment, lay down in prone and low profile positions, made it easier for us to ingest the contaminants that were present. The facilities were not very well maintained, janitorial services, keeping dust and things in control, even containing extremely hazardous substances like UF6, yellow cake, nickel dust, anything you would run across, all sorts of nasty chemicals."  "In the nickel dust, when you would come out of the process area, blow it out your nose, and at times, had that taste on your tongue."

Sampling in and around the K-25 plant vicinity revealed that workers outside of the barrier plant operations were exposed during "excursions" of nickel powder from the barrier plant to airborne concentrations levels that were slightly higher than the maximum permissible level proposed by NIOSH.⁽³⁴⁾ If the control group, or unexposed workers chosen to represent healthy workers were selected from K-25, how would the researchers deal with the fact these "excursions" resulted in readings in the plant's vicinity being greater than the proposed standard for nickel exposure to workers? The solution to the confounding effectwas to avoid mentioning the problem existed in the first place. Also, another key exposure fact seemed to be minimized in the Tompkins study. While the control group was not exposed to daily doses of nickel powder, the unexposed group worked in a plant where workers were potentially exposed to enriched and unenriched uranium isotopes U-233, U-235, U-238, uranium hexafluoride, beryllium, chromium, asbestos, calcium fluoride, chlorine trifluoride, fiberglass, technetium, PCB's, solvents, and other cancer causing substances⁽³⁵⁾. This might be akin to the "unhealthy" worker effect, in that one is comparing two groups of workers, one that is "exposed" and one that is "unexposed," when in reality, both are exposed to industrial toxins--they just happened to be different toxins. Tompkins and Godbold did not discuss how this factor might have confounded the results of the study by increasing the risk estimates of the control group.
 

Retired worker, K-25 "People doing dose reconstructions and the like, they figure things on an 8 hour day and five day work week. What they don't realize is that we worked these facilities around the clock, seven days a week. The managers knew about the midnight ventings, but at the same time, they didn't want to know. We did not, and they did not leave a paper trail on the midnight ventings, because it meant more paperwork for everyone. But, the managers knew, and those higher up knew too. We had these huge fans and vents on top of the ceilings of those big old buildings. No monitors up there, no filters. Sometimes, that's how we took care of it. A manager or supervisor would walk in and we would say "venting to atmosphere!" and they would walk right out the door again. That's how we took care of it when the UF6 or the nickel got so thick in the air."

Another tool for building cause and effect is rejected

Conducting epidemiology studies and "controlling" or singling out the factors that lead to a "cause" and "effect" relationship is admittedly very difficult. In addition to "work site" as a category for determining nickel exposure, the scientists in this study had an even more powerful tool they could have used in creating a cause and effect relationship--the level of nickel powder excreted in the worker's urine samples. The most effective way of creating a cause and effect relationship in these workers would have been to create categories of workers with known levels of nickel powder exposure, absorption, and excretion, compare those with the highest exposures, to those with the lowest exposures, then adjust for age, race, sex, socio-economic status. If, "all things being equal," there is no difference in the cancer rate between the exposed and non-exposed groups, then one can say that the nickel powder exposure at the current levels was indeed not harmful to those exposed.⁽³⁶⁾

Worker's urine were routinely collected and tested for the presence of not only nickel, but for fluorides, mercury, uranium, and other substances. By looking at animal data and estimating the amount of the nickel that is retained in the various organs in the body, the scientists could have estimated the body burden of nickel in the nickel workers. As pointed out earlier, the nickel-animal studies generated by Oak Ridge National Laboratory (ORNL) and the Comparative Animal Research Lab (CARL) were supposed to be collected for this study. Nickel retention and toxicity studies conducted by the AEC's ORNL or the CARL data on the subject is not found in the Godbold/Tompkins study. The only mention of any animal studies is the fact that NIOSH's own research found "metaplastic changes" in some animals exposed to metallic nickel powder. That finding, along with the historical excess cancers in nickel workers led NIOSH to categorize nickel powder as a suspect carcinogen.⁽³⁷⁾

A second and less accurate method for determining nickel exposure to the workers was to look at the nickel powder airborne monitoring data collected at the plant. This would give the researcher only a general rough average of a yearly exposure, not case-by-case profiles of individual exposures. And finally, the least accurate method was to simply look at where people worked and make assumptions of exposure and non-exposure to nickel powder by building and department site. Ultimately, they used the last two methods, simply classing workers by their department code and the "average" exposure level in the nickel manufacturing area averaged over a period between 1948-1963, that determined whether or not a worker at K-25 was classified as an exposed versus non-exposed nickel worker.⁽³⁸⁾ That could have eliminated people who may have had potential significant exposures to nickel, such as guards who patrolled the nickel buildings but were situated in another building, health physics sampling technicians, firemen, janitors, maintenance men, and others whose paychecks came out of differently coded areas.

The connection between cause and effect based on the airborne monitoring data became even more remote when it was reported that the nickel airborne monitoring data program was lost after 1963.⁽³⁹⁾

Tompkins and Godbold reported that while the working conditions at the plant improved as the years went by, the levels of airborne nickel reported had increased. They attributed this to better collection and detection techniques. They acknowledged that the median exposure level of 0.13 mg/m³ was on the low side⁽⁴⁰⁾. But they made no effort to find out how "low" was low. This issue became a great concern to Dr. J. S. Warner of INCO. From his knowledge of the industry and the plant conditions at K-25, it was his opinion that the airborne exposure levels to which the workers were routinely exposed to nickel were, in fact,considerably higher than was reported in the Godbold and Tompkins study. At least, according to the unclassified papers provided to the Dingell Congressional investigation, it appears that Dr. Warner made repeated attempts, including site visits by his employees, and correspondence with scientists associated with the sampling process, to gain the truth about the real exposure levels at K-25. But, he was unable to fully resolve the issue of both the true levels of nickel in the air and in the bodies of the workers at K-25.⁽⁴¹⁾ This was perhaps the most critical element of the "cause" end of the cause and effect nickel mortality study. If one could not determine precisely how much nickel the workers were exposed to, then how could the study say, "8l4 men were exposed to X amount of nickel, and found to have suffered no excess cancers deaths as a result of that exposure." Knowing the value of "X" was extremely important.
 

Sally Tinker (worked around nickel powder for three years)  "Sometimes the dust in the building where the nickel was worked was an inch to two inches thick. It was all over everything. They did not tell me what it was. They told me to go clean. I also mopped the locker room in the change houses. The mop stayed black all the time. You could not see the dust [in the change house], but if you walked around in your socks, if you mopped it, even if you took the broom and swept, you see the greyish, sometimes black, metallic color."

The "shotgun" approach to estimating nickel exposure in the workers was used despite the fact there was biological monitoring data available on over 500 individual nickel workers. What they found, unfortunately, put a wrench in their study. The premises of their study, of course, were that the nickel workers in Oak Ridge were exposed to approximately the current maximum permissible levels of nickel in the air (one-thousandth of a gram per cubic meter), and that these workers experienced no harmful health effects as a result of those exposures. If they experienced no health effects at the current levels, so the logic goes, if the current levels were sufficient to protect the workers--then the new proposed standards that were 200 times lower were, therefore, unnecessarily strict.
 

Harry Williams, Age 53, Security Police "Nickel powder was extremely fine and hard to confine, in bulk storage, it had leaked out into the surrounding environment and into the atmosphere. In the process, sometimes it was so heavy in the air, it looked like a fogged room, like where steam had got loose. You would inhale that. The janitorial services in the direct proximity of the process area was not good. The dust would settle around those areas and stay there for an indeterminate time. In the supporting facilities, for the process, you had snack rooms and break rooms and places to eat. Understand this powder was very fine, it would make its way all over the area. Even when you would buy a coke, it would be on the bottle or the can. The vending machines had to be thrown away. They would bury new vending machines in classified areas. There was a hazard the technicians would have been exposed in servicing them. It would cost more to decontaminate them than to buy them and throw them away."  "If you didn't keep your hands washed every ten seconds, if you wiped your nose, if you ate a sandwich, you were going to ingest a little [nickel powder] at a time."

But the levels of nickel exposure reported in the urine nickel sample data indicated that the workers had not been exposed to the current accepted standards of airborne nickel. The urine testing results were dismissed as faulty because they showed high levels of nickel. If the data held true, they had been in fact exposed to nickel powder tens to hundreds of times higher than the acceptable level of exposure. In fact, perhaps higher than any other nickel workers in industrial nickel operations anywhere else in the country.⁽⁴²⁾ This revelation could have diverted attention away from the intended focus of the study. How could nickel workers with such high exposures suffer no adverse health effects, when nickel workers in other parts of the world suffered excess cancers as a result of lower exposures? The high exposures would have focused attention on the questionable industrial hygiene of a highly secret government facility. It could have caused quite a concern with the labor pool at the plant as well. This one fact could have also been devastating to the attorneys and plant management of K-25 from a liability perspective should any of the "special cases," (i.e., people claiming injury to the nickel) get wind of the high nickel levels in the worker's urine. The management was caught between a rock and a hard place. How could they explain that these workers were, according to their research, perfectly healthy, given the inordinately high exposures? Was it a fact that nickel was completely harmless in the human body? Had the study population been manipulated to the point where people with possible nickel-related cancers had, for one reason or another been eliminated from the study? One will never know. Suffice it to say, the extremely high nickel urine values had the real potential to derail the nickel mortality study in Oak Ridge altogether.
 

Ann and Mack Orick (Health Physics Technician, Mechanic) "My husband worked around it a lot, in the ventilation ducts, in the change houses where they would do swipes off the top of lockers and people put their clean clothes on. My husband [who is sitting next to her by the phone and voicing his agreement] said you could write your name in the powder on top of the lockers, it was so thick. It would be cleaned up, but then two weeks later it would be just as thick. Now that was in the Change houses. That's supposed to be the clean area, not part of the industrial processes.  According to Mack, where he worked at one time in one of the classified areas, the nickel powder was so thick in the air you could not see the person standing next to you. The person next to you would not be across the room, but only three or four feet away. This was during routine operations, not just during accidental releases. At that time he was having severe rashes on his body. He went to the dispensary [the onsite medical clinic], but, of course, they did not identify to him what it was that was causing the rashes. Now, I think they knew what was causing his rashes, but they never told him. He had severe reactions to the nickel powder."

When in Doubt, Throw it Out

How did they deal with the information that most closely linked nickel exposure to it's potential effect in the individual workers? They discredited the AEC's Oak Ridge Operations own sampling and analytical chemistry program and simply threw the data out. They discarded it. The biological data on the workers was "discredited" by the ORAU scientists on a number of grounds. They could have taken urine samples from the current nickel workers exposed to comparable levels of nickel powder in the air and arrived at a correction factor, as Dr. Warner recommended. Instead, they chose to simply throw the data out⁽⁴³⁾. Why? Because, according to the ORAU investigators, 1) it was not in line with the levels found in other nickel workers around the world, 2) the airborne nickel powder readings reported at the K-25 plant were so low that workers could not have possibly been exposed to levels high enough, and 3) the urine samples were probably contaminated, or the sampler confused the presence of iron with nickel in making their analyses⁽⁴⁴⁾. What was not answered was, if the samples were contaminated, where in the world was scientific quality assurance for their analytic labs for over two decades?

When one makes assumptions without thoroughly investigating the facts, one is prone to criticism. It is no exception in this case. The assumption that the levels were wrong because the values were not in line with nickel workers in other industries was not a sound assumption. What the men and women at the nickel barrier plant made at K-25, and the massive amounts that were used on a daily basis, may never be fully known to the general public. What is known is that the standard for exposure of even 1mg/m³ of air was such that the nickel particles would be barely visible, if at all, to the naked eye if the plant operated "to code."

Eyewitness reports from former workers who worked in and around the nickel barrier operations have described that the nickel in the air was, at times, so thick that it was like "being in a smoky pool hall on a Friday night."⁽⁴⁵⁾ These eyewitness accounts make it clear that the nickel workers were clearly potentially exposed to levels of nickel that could have been much higher than the levels reported in the final study Godbold and Tompkins study.
 

Ann Orick, Health Physics Technician "What I know I encountered was nickel, was a powder, in old bags or containers that had rotted out, spilled out, all over everything, I was required to monitor it. I would go in with a beta/gamma meter, read it, [take radiation readings] then take clear plastic bags and clean it up. They would give us masselin cloth to clean it up, like a cheese cloth. It [the nickel powder] would get on us, it would come out of the packages. Try hard as you could, [to avoid it] it would get on you. One area was in ventilation ducts, and off the [vent] fans, where it [the nickel powder] was loose. Hot radiation readings were found on those items. We had to sample. I had to fool with it personally. As much as you tried not to get it on you, it was like sprinkling talcum powder on your hands, it was that fine."  Author's note -- Ann Orick revealed in a Senate Hearing on March 22, 2000, that doctors have given her only 3-6 months to live. Ms. Orick believes her nickel exposures are, at least partly, to blame for her impending demise.

That conclusion was also reached by the top representative of INCO, the Canadian company who sold the nickel powder to K-25 inthe first place. In a series of memos, Dr. J. S. Warner (who was a vice-president of Industrial Hygiene and Occupational Safety and Health with INCO) tried to get to the bottom of why the values on the airborne nickel levels at the plant were reportedly so low⁽⁴⁶⁾. He knew how difficult it was to contain the highly fine ground nickel powder, as the Canadian company had some of the same dust control problems as K-25. He said other industries had a tough time keeping the airborne levels down to the levels at the 1 mg/ m³ level, which was ten times higher than what was reported as the average airborne nickel powder level at the K-25 plant. He knew that K-25 was not regulated by NIOSH, OSHA, or EPA in their industrial operations. They operated in secret and were "self-policing" when it came to maintaining health and safety standards.A recently declassified memo reveals that the manufacturer of the nickel powder treated potential human exposure to the toxic substance with a great deal more respect and caution. The secret document confirms that, at least around the nickel handling machines, the level of nickel in the air was several times higher than reported in the Tompkins study:
 

Notes from a secret meeting with INCO representatives (August 19, 1976, K/C-1075, Part 20) "Currently, NIOSH is collecting data on the effects of a number of materials, including nickel compounds and nickel powder. A proposal has been made to decrease the present Threshold Limit Value (TLV) from 1.0 mg/m3 to 0.3 mg/m3 of nickel powder. Such a change would have a serious effect on the nickel industry and would necessitate substantial revisions to the nickel powder handling system at K-25. Airborne nickel powder data at K-25 and INCO facilities average three to seven times the proposed TLV; excursions which are, at least an order of magnitude above the proposed TLV, probably occur in both facilities." (page 2 see above cite)  "INCO offered to provide at least part of the funds needed to make a study. It was agreed that future contacts would be made between Mr. Johnson and Mr. Manilla. This provides for some security protection since they are already working together on the disposal of old nickel powder facility owned by ERDA at Huntington." (page 2, ibid.)  "INCO uses full protective clothing, using Scott air packs for maintenance on nickel powder systems. This is done on the basis of applying uniform policies to all maintenance work. This type of protection is absolutely necessary for nickel carbonyl and nickel sulfite systems and INCO does not differentiate between these systems and nickel powder systems." (page 3 ibid.).

Dr. Warner later found at least a partial answer as to why the nickel airborne monitoring data at the plant were so low. For every year reported, the highest single nickel airborne level value for each department reported was, like the earlier urine nickel data, simply thrown out -- discarded. The reasoning by the scientists conducting the health study was that the levels were too high to be accurate, and so they were considered "outliers" that skewed the "average" airborne values too high. This scientific "sleight-of-hand," was not reported in the final study⁽⁴⁷⁾.
 

Harry Williams, Age 53, Security Police "No respirators were required when I was around the nickel.  I was not apprized of any hazards, and I asked. I'm not one of these kind of folks that would just accept that it was safe, I asked them every year if my duties, as I performed them at K-25, were safe. Every year they assured me, yes, the workplace was safe."

NIOSH Proposed Standard Successfully Defeated

The tightly controlled health study was completed in a little over a year's time; that is, just in time as it was originally proposed to fight NIOSH in Congressional hearings. The study achieved its intended effect. The proposed Califano standard was successfully defeated. It turns out that the Tompkins study had international significance, since it was the only study of its kind at the time to study pure nickel metallic powder exposure to workers. What originally had been a study whose effects would be felt on thousands ofworkers' lives in America would now potentially impact the lives of hundreds of thousands of nickel workers in this country and around the world. It would be interesting to see the impact the Tompkins/Godbold study had in affecting the nickel standards in France, Germany, and Canada, as they were re-examining their exposure standards at the same time as the Americans.
 

Fannie Ball, worked in the nickel barrier manufacturing processes on and off for 16 years, disabled, retired. "One time, a group of people who worked for me, came into the room where I was working on a computer and dumped a hamper of nickel all over me. I looked like a ghost. They thought it was funny. Nobody thought the nickel powder would hurt you. The nickel was supposed to be vented through stacks with filters on them, but it was also vented into the air through huge ceiling fan vents with no filters on them. I worked in one room that was separated by a thin wall and a door. On the other side it got to be over a 110 degrees in that room. Were the ceiling fans used routinely? Of course they were!"

While in private management circles, the real purpose of the study is to fight against the proposed NIOSH standards, the "official" motivation for the study sounds benevolently paternalistic. Robert Hart, head of DOE Oak Ridge Operations wrote to OSHA representatives saying "In our continuing effort to obtain additional information which will help us protect DOE and contractor employees from harmful exposures to these materials..."⁽⁴⁸⁾

Meanwhile, a quarter of a century has passed. Thousands of workers at that plant have been exposed to not only the nickel powder, but to the other classified alloys, and chemicals that were blended into nickel powder. Ironically, the reason this worker population was supposed to be so important and the study so unique, was that the workers were only supposed to be exposed to "pure metallic" nickel. But mixed in with the nickel were other heavy metals, and toxic chemicals, the type and amount of which are still classified to this very day. This one fact alone casts doubt as to exactly what these nickel workers were exposed to while working in the barrier manufacturing process buildings at K-25. One also wonders if DOE's own generated health study finding no harmful health effects from exposure to nickel has in fact re-enforced a myth of nickel being safe and, has thus, led to even more lax safety practices when handling the nickel powder at K-25?

"I think we have a problem here"

Flash forward to the early 1990's. A medical doctor new to the area of Oak Ridge, Dr. William K. Reid, M.D. has been sent a number of patients about whom other doctors have failed to make a solid diagnosis of their health problems. Dr. Reid possessed a strong background in medical research. He was trained in hematology, oncology, infectious disease, and biochemistry. He conducted extensive interviews and created profiles on the patients to eliminate the most probable causes of their health problems. He then gathered the occupational histories of his patients, It appeared to Dr. Reid that several of his patients, particularly workers, who exhibited clinical symptoms of chronic heavy metal poisoning. What stood out in Dr. Reid's mind was that he was seeing too many renal cell cancers in such a small population. He found in both, his cancerous and non-cancerous patients, advanced and aggressive immune system dysfunctions. The patients had AIDS-like symptoms, only they didn't have AIDS.

One of the metals he suspected was causing his patients to be sick was nickel. Initial testing confirmed elevated levels of nickel in some of his sick patients. He had no idea of the size and the massive scope of the industrial operations of the 30,000-acre DOE nuclear reservation. He did not know that the K-25 facility at one time housed the single largest industrial operation under one roof in the world. He knew nothing about the earlier Godbold and Tompkins study or of the futile effort to tighten the health and safety standards of exposure to airborne nickel particles.
 

Janet Michel, 47, DOE Public Information Specialist I started out going to the buildings K-1037 and K-1001 part time during 1994 and 1995, a couple times a week for meetings. They gave me an office to work out there. It must have been right about the first of January, 1995, where I would be there entire days, they gave me a computer and phone. I had a "real" office there then. After about five months, May of 1995, I was there full-time, until I left in May of 1996, when I returned to my "offsite" office. That was when I found out I had the high urine thiocyanate level. When I left, there was a computer person that came with a tiny vacuum cleaner that cleaned out my computer. They vacuumed my computer before I moved out. I thought they were with security. I got so sick after working in K-1037. I was exhausted all the time. In the morning, when I woke up, it felt like I had just worked a ten hour day. My sinuses went bad. I had breathing problems. I could barely stand up in the shower, my balance was so bad. Going into work, I was already worn out. And that was just the start of the day.  I was at an offsite location for about six months, then my health did not improve. I had the first test for nickel in November, 1996. It was a three-day mobilization (oral medicine only) which showed a little mercury and nickel. After a five-day IV chelation in March, 1999, the 24--hour urine found the nickel levels 26 times above the reference range. At four times over the reference range, one is considered as having a "toxic-level" exposure. As I was driving to my friend's after Dr. Reid chelated me each day, I had headaches, nausea, was light-headed, and very tired. Then it hit me, this is how I felt every day working at K-25. [Most, if not all of the millions of pounds of nickel flowed through the blending tower that was located in building K-1037, according to de-classified documents].

Dr. Reid had no idea that, at one time, up to a million pounds or more of nickel powder may have been processed at the K-25 plant every month. He only knew that there was a problem and that the head of the plant medical department medical operations for the contractor of the Department of Energy might have some answers and be of help to him in treating his patients. He contacted the Contractor's head Medical doctorat the Oak Ridge facility and suggested they do a joint medical investigation of the problem of possible metal poisoning in his patients. He even suggested the possibility they might work together to write a medical journal article for JAMA on the chronic heavy metal poisonings; i.e., write up case studies on the affected workers.

Rather than being praised for his astute investigation, the local doctor was berated by the contractor's medical director. The company doctor told Dr. Reid, in no uncertain terms, that their studies had shown no one had been injured by exposure to heavy metals at the DOE Oak Ridge nuclear operations.

Shortly after the fateful phone call, Dr. Reid's medical career was suddenly thrown into jeopardy. Hospital administrators pushed for a medical peer review of Dr. Reid's patient care. Unlike ORAU's self-selected review, Dr. Reid's "peers" were clearly hostile to him. Dr. Reid was found to be a competent doctor who practiced above the current levels of "standard" medical practitioners in Oak Ridge. But, because of the hostile work environment, he chose to practice in Nashville, over 200 miles away. The costs of defending his professional reputation left him financially challenged for many years.

Near that same time in the early 1990s, a group of Q-cleared, blue-collar shift workers were working the graveyard shift in the waste vaults at K-25. They were doing something that was not allowed under civilian law. They were moving thousands of drums of contaminated nickel powder, (nickel that was ground up from old used nickel barrier tubes) and shipping it off in the dead of night in unmarked 18-wheel tractor trailers. The nickel dust was thick in the air every time a forklift dropped one of the 300-lb drums that were the size of a half-keg. One worker described the nickel powder as being silky-smooth, the texture like talcum powder. Had they been told that, by even the old standards, any nickel powder visible to the naked eye in the air was a violation of NIOSH standards and a threat to their health, they could have taken steps to protect themselves. But according to a health physics waste sampling technician on the job, they were not told. The radioactively and chemically contaminated nickel powder, which had been stored as special nuclear material waste for years, was being shipped to an unknown destination--no labels, no manifests, no idea of the final use of the material. Everything was kept mum because of "national security."

A worker complained of the working conditions-- no respirators, nickel powder hanging in the air as thick as smoke in a beer joint on a Saturday night. She asked repeatedly for verification of "no danger" by issuance of an MSDS and an industrial hygiene sampling and was told there was no MSDS for the material. When she obtained an MSDS from another source outside of the facility, the worker learned that the nickel powder was a carcinogen and protective precautions were to be taken. Supervision at the facility would not allow her to pursue the proper protective procedures and equipment. Her exposed skin ws flecked with red dots, which she believed was from contact with the powder. Black mucous was expectorated for days following work in the nickel powder waste vaults.

She witnessed in the mid-1990s, not the mid-1940s, an air sampling protocol which may answer the question raised by Dr. Warner a decade earlier "how could the nickel airborne monitoring data be so low?" The worker witnessed that first, nickel operations in the waste handling area were shut down for 24-48 hours. Then, and only then, were airborne sampling machines turned on to detect nickel powder levels in the air. They literally waited "for the dust to settle." She demanded answers to the midnight shipment of the nickel kegs. Instead, she was told to "Shut up. This operation is classified. You are costing the company money with your griping about protective equipment and procedures."⁽⁴⁹⁾

That worker's health began to deteriorate. Short-term memory loss became so acute she would have to leave notes for herself wherever she went. She developed profound chronic fatigue, sinus problems, problems with her kidneys and liver, and severe rashes,all problems known by the ORAU health professionals studying the nickel workers, as early as 1983, to be signs of toxic nickel exposure.⁽⁵⁰⁾  (See Cragle Foreign travel report, March 23, 1983).

For her efforts to make the workplace a healthier place, she was taken off that assignment and put on increasingly dangerous and meaningless jobs. Finally, too sick to work, she left work and applied for short-term disability.

Four years ago, this worker and others who suffered similar unexplained health problems, banded together. Some of the workers, like her, worked in the industrial buildings where the nickel handling operations took place. But a surprisingly large number of the workers were white-collar workers who worked in buildings that, at one time, were either adjacent to the nickel process operations, or in fact had housed the operations and been converted to office use. Ironically, Janet Michel was in the Contractor's pollution prevention program. She would come into her office in building K-1037 in the morning to find a fine grey powder had settled out on her computer and desk over the weekend.

As her health declined, she and several other affected workers eventually became the patients of Dr. Reid, the local doctor whose practice is now 200 miles away. No other doctor could, or would, track down the origins of their maladies. To get the medical treatment they needed, they have to travel the 400-mile round trip for simply a visit to their personal physician.

These sick people could not get adequate medical treatment from either the corporate medical department of DOE's contractor, or from other private physicians in Oak Ridge. They began asking DOE, CDC, ATSDR, EPA, and the local state health agencies in Tennessee to investigate their health problems and give them real answers and solutions to their grave, unexplained health problems. The nickel powder was just one of many, many contaminants to which they had been potentially exposed. What they got back instead was not answers, not help, but in the words of one affected victim, more roadblocks rather than genuinely helpful medical investigations, diagnoses and treatment. Three workers, despondent and devastated by their unexplained illnesses committed suicide. Others were impoverished by the loss of their jobs and escalating medical costs.

In December, 1996, the affected workers, led by Ann Orick's letter-writing and fax campaign, turned to reporters at the Tennessean to investigate their puzzling and undiagnosed health problems. What began as a three-day series of articles after a month-long investigation by Susan Thomas, Laura Frank and Ann Payne of the Tennessean has blossomed into more than 100 articles. The stories cover both the conditions around the Oak Ridge facilities and a dozen more nuclear-weapons-related DOE facilities nationwide. At each facility, common health problems involving therespiratory system, chronic fatigue syndrome, depressed immune systems, and other seemingly unconnected maladies were reported.

Ironically, researchers at an International meeting on Nickel Toxicity in France in 1983 reported kidney cancer, immunosuppression, and "compound and systemic effects" as health problems to be on the lookout for when dealing with exposure to nickel in the industrial workplace. (Foreign Travel Report, March 23, 1983 by Donna Cragle ). These are the some of the most unusual problems that Dr. Bill Reid first identified, and the Tennessean reporters later found as well, during their extensive interviews.

Even though there was no increase in respiratory or sinus cancer deaths reported in the Tompkins/Godbold study, they did find a higher than expected number of deaths from "symptoms and ill defined" causes of death. They attributed thisto the reporting vagaries of the State of Tennessee, rather than to any medical connection of exposure to nickel. But, exposure to nickel produces "compound systemic effects" according to doctors and scientists studying the toxicity of nickel in other countries. A depressed immune system will weaken the body and allow for a whole host of opportunistic infections to attack the individual. To this day, that fact has not been accepted, or to our knowledge, studied by the medical investigators or corporate medical doctors involved in the DOE health studies of the Oak Ridge workers.

Critical Facts Kept Secret

1.     In one of the secret meetings held between INCO, ERDA, and the K-25 management, it was pointed out that INCO supplied each worker in the nickel areas with personal battery- powered air samplers. That would have given each worker a clear record of their daily exposure. That was in 1975. How far back that practice went is unknown. K-25 management could have adopted the same individualized monitoring system, but since they were not required by OSHA or NIOSH to follow such standards, they opted for less expensive, less accurate, stationary air monitors, which they could conveniently turn on and off when it suited their needs to create an "official" air monitoring record.

2.     At the same secret meeting, it was pointed out that INCO treated the pure metallic nickel powder with the same respect in terms of potential toxicity to its workers as they did with nickel carbonyl and the nickel sulfites. When workers changed out nickel handling equipment, they wore contamination suits and self-contained breathing units (presumably oxygen tanks). The workers at K-25 were required only to wear respirators. After the barrier tube production was shut down in 1985, respirators were required only in restricted work areas. And, according to contemporary interviews with workers, even the respirators were not always required.

3.     Recently declassified documents reveal that nickel carbonyl was used in the nickel barrier tube manufacturing process. It was possibly used in the separation and purification process before arriving in Oak Ridge, and possibly in the scrap re-cycling efforts, according to declassified documents. The use, time, and amount of nickel carbonyl present in the K-25 facilities is, and probably will remain, classified. A document that remains classified, though its title is declassified, lends one to believe that nickel carbonyl was used in the barrier tube production process (See "Production of Membranes from Carbonyl Nickel Powder" RHTG 27073 and RHTG 27074). Government sponsored nickel toxicity studies on nickel carbonyl date back to 1945 and the Manhattan Project. See also NNES, a listing of declassified studies conducted during the Manhattan Project.⁽⁵¹⁾

4.    According to Haven, nickel carbonyl has been shown to be highly toxic. Symptoms produced by inhalation of nickel carbonyl are headache, dizziness, marked dyspnea, cough, fever, leucocytosis and toxic pneumonia. Capillary hemorrhages in the brain are also found... Nickel or nickel carbonyl may be active agents in the high incidence of cancer of the nasal sinuses and lung in copper-nickel refinery (Mound process) workers; the latent period of these cancers is 22 years... Inhaled nickel carbonyl is believed to be absorbed unchanged in the blood stream with damage to the pulmonary epithelium, where it may act as an allergen on the lung as it does on the skin. The action of nickel carbonyl has been likened to that of a catalytic poison which influences the central nervous system and the metabolic processes... In one review, Haven pointed out that nickel carbonyl was five times more toxic than carbon monoxide.⁽⁵²⁾

5.    Coincidentally, in an expose' by the Tennessean reporter, Susan Thomas, over 30 workers from K-25 were interviewed as to their health problems. Some of the symptoms sound similar to that of exposure to nickel carbonyl. Thomas summarized the symptoms: fatigue, tumors, memory loss, blood disorders headaches, reproductive abnormalities, dizziness, liver problems, sleeplessness, rashes, panic attacks, hair loss, tremors, numbness, vision loss, immune system deficiencies, depression, hearing loss, asthma, acute muscle and joint pain, chemical sensitivity, rapid heartbeat, thyroid malfunctions, nervous disorders and digestive troubles.⁽⁵³⁾

6.    We know from a review of declassified titles of currently classified documents, that the causing of rashes by nickel powder exposure was known as early as 1944 at the K-25 site (See title of classified document "Control of Nickel Dermatitis", RHTG 7648 11/20/44 and RHTG 7649 11/6/44). We also know that medical information on exposure to nickel powder was strictly controlled from the very onset (See title of classified document "Nickel Powder; Dr. Lancaster; Access and Need to Know for Medical Reasons: Information" RHTG 14239 4/17/50) . As mentioned earlier, even though Mack Orick and others developed rashes from direct contact with nickel powder, their rashes were not connected to exposure by the plant medical doctors. If the injured person does not have a "need-to-know," then who does? Unfortunately, "need-to-know" does not refer to personal health but to national security.

It appears to those poisoned by these substances that their personal health and well-being have been taken away from them, all in the name of "national security."

7.    It is illuminating to compare the symptoms as observed "unscientifically" by the Tennessean reporter in both the blue and white collar workers at K-25, with the symptoms observed by clinicians with respect to nickel exposure symptoms:
 

In a separate section on the effects of Nickel Carbonyl, Wilson notes:   Nickel Carbonyl is the most toxic of the nickel compounds and is (sic) has been historically established as a neurotoxin.⁽⁵⁵⁾

There are several extremely important points to note. One is the obvious number of times the symptoms found by the Tennessean reporters matched the symptoms reported by Wilson as indicative of nickel exposure. What is also striking is the "end point" diseases of nickel exposure; i.e., lung and sinus cancer, are out-numbered over 15 to one in the clinical manifestations the exposure causes to the individual. Thus, it is very important to be looking for the clinical and sub-clinical symptoms of exposure in the effected people, rather than simply looking for the causes of death. It is also important to note that the Tennessean reporters, while not trained scientists, conducted in a sense, "door step epidemiology." Nowhere in the February 1997 articles were the reporters focused on nickel exposure. They merely collected the "raw data." The striking number of positive matches of symptoms certainly merits a symptoms-survey of the people currently suffering from "unexplained" illnesses and maladies that may be the result of working at or living near the the K-25 site.

Current Studies and Critical Issues: Is Our Government Doomed to Repeat Its Past Mistakes?

In October of 1997, a report was released by Robert Wages, et al., of the Oil Chemical Atomic Workers Union⁽⁵⁶⁾ (that union is now known as Paper Allied-Industrial Chemical, and Energy Workers International Union or PACE for short). The assessment is part of a five-year long medical study, in conjunction with medical researchers from the University of Massachusetts at Lowell, offormer workers at the three Gaseous Diffusion plants in Tennessee, Kentucky and Ohio. It is probably the most rigorous and "real-life" plant-wide assessments of the working conditions at the gaseous diffusion plants to date. Rather than focus on quantifying specific toxins in individual workers, the researchers took into account the sketchy and sometimes flawed sampling and monitoring programs of the AEC and DOE and instead focused on the industrial processes, and the detailed eyewitness accounts of processes, operations and releases from interviews with dozens of former workers. From that, qualitative "risk maps" were generated to give medical researchers a good idea of the types and levels of exposures in various parts of the buildings where workers were potentially exposed.

Credibility is the Key

Focus group meetings with former workers were held by trained Union researchers. It is interesting that they found attitudes expressed by retired workers from two decades to two generations earlier that were similar to those expressed by sick workers today. They found :

a strong feeling of personal vulnerability to disease as a result of DOE employment; a sense of shared risk with co-workers, an overwhelming feeling of uncertainty and ignorance about significance of exposures; a deep sense of distrust about communications from and actions of DOE and contractors; and a lack of faith in the ability of current health providers to evaluate presence of occupational diseases. ⁽⁵⁷⁾

In other words, the findings after interviews with several dozen former workers are that they had and have an inherent distrust of the Department of Energy and it's inherent conflict in protecting worker health versus protecting it and its own contractor operations and liability concerns.

Near the same time that the union released their medical needs assessment report, a meeting was held in Oak Ridge on Halloween, 1997 between the affected community groups and nine local, state and federal agencies that were charged with investigating the health concerns raised as a result of DOE Oak Ridge Operation toxic releases. The meeting was held, in part, to answer the criticism brought by local health activists Sandra Reid and Jackie Kittrell on the inability to compare scientific data from one agency study to another, and the need to coordinate research so that efforts in Oak Ridge are not duplicated with the attendant loss of time, money and energy.

First Broken Promise

According to Janet Michel, former information specialist for DOE in their Pollution Prevention program, and immediate past President of Coalition for a Healthy Environment [CHE] at the time of the meeting, and chief presenter for CHE in that meeting, several promises were made by the multi-agency officials to the people attending the meeting. 1) There was a promise to distribute proceedings from that meeting within 90 days after the meeting. The agencies had contracted for the meeting to be taped and transcribed. As a former information specialist for the Department of Energy, Ms Michel understood from the officials that the Proceedings were to be comprehensive. "What we got from them was absolutely pathetic. None of the agencies presentations were in there. Absent was Jim Hall's (head of DOE Oak Ridge Operations at the time) presentation", said Ms Michel in a phone interview.

"I gave them a twenty-page hard-copy of my presentation on behalf of the more than 100 affected workers and community members of CHE, and it was nowhere to be found in the final proceedings. Rather than complete transcriptions of the talks given to the multi-agency panel, there were only badly edited "snippets" of those talks. It was the shoddiest job of a Proceeding that I have ever seen. I should know because this is what I used to do for a living at DOE before I became too sick to work," said Ms Michel.

Second Broken Promise

At the conclusion of that meeting, the leaders from the multi-agency meeting promised to hold a second meeting in Oak Ridge in March, 1998, five months later. They would respond to the recommendations and concerns they had heard from the community. They also promised to work with the affected people in the community of Oak Ridge to develop the agenda for the March, 1998 meeting. The multi-agency group had several phone conferences, and met between themselves over the next several months. But, they failed to include the affected people in the agenda setting, failed to include the affected people in any meetings or phone conferences and they failed to hold the meeting five months later as promised. Janet Michel sadly summed it up "These bureaucrats waste so much time and money. In the end, they do nothing. And meanwhile, we are dying and waiting for the truth. For us, it is a race against time, and time for many of us is something we don't have a lot of."

Eighteen Months Pass: The Voices of the Sick are Still not Heard

In February, 1999, the multi-agency group [CDC, ATSDR, EPA, DOE, NIOSH, NIEHS and Tenn. Dept. of Health] re-convened, not in Oak Ridge, but in Atlanta, for a strictly a closed-door meeting. Representatives of thehealth oriented groups were not officially informed of the meeting, but heard about it through "back-door" channels. When they did, they (AEHSP, CHE, and ORHL) requested, practically demanded, admission to the meeting, and were denied. An attempt to placate the Oak Ridge organizations representing the affected people was made by holding a telephone conference with them before and after the meeting. Again, Janet Michel sums up the mood:

"Those phone calls were simply a waste of time. The things that were said by the agency people were disheartening. Hearing phrases like "Well, it's just going to take a long time to put it together..." It is like they were not even listening to what we were saying. We, at first, interpreted the fact that they were busy again because we assumed that they had been given "Marching Orders" from Dr. Michael's office (Assistant Secretary of DOE) to really work on the problems in Oak Ridge. We were mistaken. What came out of these people mouths was bullshit. This is not what we were promised by Dr. Michaels. He led us to believe we would not have to put up with another three year study." [As with the Lockey, Freeman and Bird "evaluation" on the affected workers that was contracted by LMES/DOE)

One of the products of that meeting, was supposed to be a compendium of all the health studies done by all these agencies on worker and residents in the Oak Ridge community. Researchers from the multi-agencies were supposed to put them all on the table together. Members of CHE and ORHL told the agency representatives that they wanted a copy of this compendium immediately. They were told there was an embargo on it, because it was not finalized.

A week later, the Oak Ridge Site Specific Advisory Board had copies of the "embargoed" report. And, then, another group in Oak Ridge set up by Department of Energy funding, the Local Oversight Committee, also had copies of the supposedly embargoed report. Still, the affected people and their organizations were not given copies of the report.

Janet Michel said: "We were the ones who are the affected people. The meeting was held to deal with our concerns. But, we were given nothing."

Taking a peek behind the Closed Doors: What the Agency Officials Really Felt

At hand was the task on how to deal with the issue of the sick workers and community residents around the DOE Oak Ridge Operations and the government's response to the demands for community-driven, clinical investigations of the affected people in the worker and resident communities. The February 1999 closed-door meeting in Atlanta went back to the lack of credibility the agencies had in the Oak Ridge community. Sandra Reid and Jackie Kittrell of AEHSP and ORHL made a Freedom of Information Act (FOIA) Request to each agency attending that February meeting for the notes taken by their agency representatives. Only the Environmental Protection Agency complied with the FOIA request at the time of this article. The notes that were taken are highly revealing:

"Dr. Heather Stockwell [official with the Department of Energy, Environmental Health-62] then observed: "we have no trust because we haven't been willing to involve them (meaning the citizens of Oak Ridge) in the planning process."

John Williamson then added: "To give lip service (meaning DOE, and specifically Dr. Seligman, (Deputy Assistant Secretary for Health Studies of the Department of Energy)and not follow through destroys all (potential to gain trust of the community)"

Jack Hanley [official with the Center for Disease Control's Agency for Toxic Disease Registry, and listed as the Lead Health Assessor for Oak Ridge, in the October 30-31, 1997 Proceedings of the Oak Ridge Workshop on Energy Related Public Health Activities) then (amazingly) added: Community meetings (in the Oak Ridge area) are like the Jerry Springer Show and (ATSDR) won't come back. (Emphasis authors')

Earlier in the meeting, Dr. Bill Moore with the Tennessee Department of Health said: "DOE is the hand that feeds Oak Ridge and they (meaning the medical community of Oak Ridge) are not going to find or identify problems that make DOE look bad."

DOE officials in the meeting, specifically Dr. Paul Seligman, one of the top officials in DOE that oversee over a $100 million worth of health related research a year, repeatedly and steadfastly resisted throughout the meeting the idea of there being any community-driven and led clinical investigations of the potentially affected people in Oak Ridge. The solution to deal with the lack of trust by the people in Oak Ridge of the multi-agencies approach to their health problems was attacked head-on by Dr. Seligman. In one exchange, the meeting notes were again extremely revealing:

Dr. Warren then suggested that the group set the number of government partners and that an equal number of non-government partners be identified.

Dr. Seligman was visibly concerned about the suggestion and commented that DOE wants to decide "who is in charge" and "which agency should lead"and that "DOE wants out."

"Dr. Warren simply replied: "Ask the community who the lead agency (meaning for leadership issues) should be."

"Jim Smith (from DOE EH) immediately interjected "DOE/EH should lead."

"Then, Dr. Litchfield quickly announced "We (meaning ATSDR) will lead. Phase One will be to get the Stakeholders together."

One would question the wisdom of the ATSDR taking the "lead' on holding the "stakeholder" meetings in Oak Ridge, when their officials see the Stakeholders as being something akin to the people on the Jerry Springer Show. The Springer show has degenerated to the point where the people on that show represent the lowest forms of human decency, integrity and mental stability. For an agency representative to characterize people struggling with environmental-toxin-induced illnesses to such people is certainly a travesty from an environmental justice point of view. But, it is highly illustrative to show the depth of the chasm between the agency officials and the people whom they are paid hundred's of thousands of dollars every year to supposedly help, protect, and serve. It is reminiscent of the Queen of France responding to the pleas of the starving peasants to "let them eat cake."

On April 27, 1999, the Multi-agency group came back to Oak Ridge. They had decided the "stakeholders" in Oak Ridge consisted of many business and economic-related organizations. In a four hour meeting, the affected organizations representing the sick workers and community residents were restricted to making formal presentations that lasted only three minutes. ATSDR's solution to the health problems in Oak Ridge appears not to be a medical response in terms of medically studying and helping the potentially poisoned people, but instead to create another community advisory committee, which could take years to create, fill positions, and formulate a study agenda. Meanwhile, people are dying. There was no agency response that indicated the agencies intended to immediately identify potentially poisoned workers and residents, no voice was expressed by the government agents that immediate medical interdiction was in the cards.

A Decent Effort to Medically Study the Problem: But, is it too little money, too few people studied, wrong tests used, in other words:  "Too Little Too Late?"

The Paper Allied-Industrial, Chemical and Energy Workers Intl Union (PACE, formerly OCAW) secured a $7.5 million grant from the DOE to conduct an independent "Worker Health Protection Program" for former gaseous diffusion workers as cited earlier as the Wages, et al. study. Mr. Tom Moser, a member from that union recently met on March 4, 1999 with members of the Coalition for a Healthy Environment, Oak Ridge Health Liaison and American Environmental Health Studies Project. According to Sandra Reid, R.N. and head of the Oak Ridge Health Liaison, there are problems in the design of their medical follow-up of the potentially affected K-25 gaseous diffusion workers. Ms. Reid questioned whether tests for heavy metals using X-ray fluorescence, or tests for cellular DNA damage using the PSA tests, or porphyrin tests for enzyme metabolic changes would be conducted on these people? Mr. Moser said that those tests would not be part of the examination. They are expensive tests and the study had only a limited amount of money to conduct the physical exams. Ms. Reid was critical of the design of the study, because it appeared that they would be looking for end point stages of damage from exposure, such as cancer, rather than looking at ongoing chronic manifestations of harm by exposure, such as compromised immune system problems from toxic exposures. Ms. Reid, without having knowledge of Dr. Moore's comment regarding the Oak Ridge's medical community "not wanting to bite the hand that feeds them," was openly distressed that local doctors in Oak Ridge using hand-picked labs would be an integral part of the Union health medical surveillance program. She stated to Mr. Moser that for the sake of the credibility of the Union study, completely independent medical professionals and labs be used in their study. Ms. Reid also questioned whether the DOE, by not putting enough money into the study to pay for the tests that would link environmental illnesses back to the toxins that had caused them, had not, in effect, made the study "inconclusive by design," (a concept by Linda King, director of the Environmental Health Network).

Mr. Moser conceded that because of a lack of money for the medical study, at the very most, less than a third of the former gaseous diffusion workers from K-25 would be medically examined under their medical surveillance program (Meeting with Mr. Moser and the Coalition for a Healthy Environment March 4, 1999)

Because of classification issues, all of the work product and interviews with the former workers is being held in a locked vault at DOE Oak Ridge Operations and is available only to the contracted researchers. That information is not available to the public or to individual workers who would want to corroborate the working conditions that would have led to their potential exposures.

Wage, et al. in the 1997 needs assessment study did cite the nickel process buildings as being a primary target for medical investigations, as the workers in those buildings (K-1100, K-1037, K-1004L and K-1420) were exposed to average potential exposures of nickel at 1.5 to 2 mg/ in the barrier manufacturing building (K-1037). (Wages, et al. 1997, pg 10). They, unlike Godbold and Tompkins, did not unilaterally discard the urinary data. They found the urine nickel data "showing high average urinary concentration in selected buildings (e.g.- K-1037, K-1004L, and K-1401) extending into the 1970's." (Ibid, page 10) Finally, they noted "that the current NIOSH REL (REL 'Recommended Exposure Limit) is 0.015 mg/ m³, which is one hundred times lower than the levels found at parts of Oak Ridge over the past several decades." (Ibid, page 10).

Actions needed immediately to correct past and present wrongs.

1.    Secure the records, revise the study group.

It is clear that much more focused studies need to be conducted on not only the workers who made up the Godbold and Tompkins nickel mortality study, but the other 1600 nickel workers who were excluded from the 1977 study as well. African-Americans and women should be included in the new study. A thorough description of both the workplace and the job duties of the people who worked in the areas of potential nickel exposure should also be made.

It would also be in the best interests of the affected workers if a copy of all the records relating to the 1977 study by Godbold and Tompkins were secured by a special master appointed by DOE or Congress. In addition, the workers, up to the present day, who have been exposed to the nickel powder need to be studied as well. The materials, other heavy metals, and toxic chemicals, that were "blended" into the nickel powder need to be declassified and made known to all the potentially exposed individuals both onsite and offsite as well so that those who are suffering may notify their doctors of the toxic substances to which they have been exposed.

Both the workers and the public are caught in a bizarre "Catch-22" on this issue because the Classification Officer for DOE Oak Ridge operations now insists that anything that the workers at the K-25 facility have been exposed to is not classified as long as they are conveying the information to their doctors. However, theinformation is still classified as it relates to a specific process. Even though a worker may be Q-cleared, and may work with classified material on a day-to-day basis for years on end, he or she may still not know what they have been exposed to because one has to have a "need-to-know" in order to be told of the existence or nature of classified material. "Need-to-know" literally meant that you needed to know in order to do your job. That was left mainly to the scientists, chemists, physicists and engineers that controlled the actual processes of manufacturing. So, a janitor, or chemical operator, or security guard, or secretary next to a ventilation duct where toxic material flowed through may be Q-cleared in order to simply work in a top secret building, but if they did not have a specific reason or "need-to-know"of the material they were working around and exposed to, they would never be in the position to tell their doctor what they were exposed to in the first place, because they were never told. It is very important to know what people have been exposed to from a synergistic standpoint.

For instance, research at the Pharmacology and Toxicology division of the University of Rochester Atomic Energy Project in 1949, a half century ago, found that "Because relatively large amounts of fluoride have been shown to be present in manufacturing areas where clinical beryllium disease has existed, it seemed reasonable to test the hypothesis that fluoride might contribute to the observed beryllium toxicity. Such a study has been performed in rats exposed either to beryllium sulfate mist or to hydrogen fluoride vapor alone, or to both agents in daily, alternating exposures for one month.

The results based on mortality, weight response and a study of histologic sections of the lungs of these rats were consistent in the various exposed groups and confirm the hypothesis under test, namely that hydrogen fluoride enhances the toxicity of beryllium sulfate when both agents are admitted through the respiratory route. By H.E. Stokinger, et al., 5/12/49, University of Rochester, Atomic Energy Project UR-68, page 4)

For instance, we know that massive amounts of fluoride were used in the enrichment process (the process gas, Uf⁶) at K-25. From declassified titles of classified documents we know that the nickel was contaminated with fluorine (see "Fluorine Plugging of Nickel Barriers" RHTG 7032, and RHTG 18439 and see "Formation of Protective Films on Fluoride and Oxide on Nickel RHTG 34683). We know from personal worker accounts, and from the Wages, et al. study, beryllium was also machined at K-25 as work for the Y-12 operations and in the uranium thermal separation processes (S-50) back in the 1940's at the K-25 site. Knowing that these substances have profound synergistic effects, as well as, all the possible exposure pathways is very important in determining human health effects. Especially so if the two ingredients could have at any point in their industrial processes be co-mingled and released in particle sizes that approached aerosol form. Stokinger, et al, found that the two ingredients combined doubled the toxicity of beryllium sulfate alone on the experimental rats. Does exposure to fluoride have the same "toxicity enhancing effect" in the human body when mixed with nickel? Do doctors treating these people today, or medical investigators know basic toxicological facts such as this one that the AEC contracted scientists learned a half century ago?

Secondly, as the December, 1976 Business Confidential memo first cited in this paper pointed out, monitored air releases to the general environs of the massive K-25 plant site (over ten thousand acres in size with several hundred acres in buildings) approached values that were in line with Joseph Califano's proposed maximum permissible standards for exposure to nickel powder for the nickel worker. In other words, anyone at the facility might have had the potential to be exposed to significant levels of the nickel powder that was laced with other classified substances.

Unless there is a full and complete disclosure of those contents, some workers who are "in the know" and who diligently persist with DOE might get access to the necessary information to tell their doctors of their exposures, but there will be countless thousands who will, because of "national security," be left in the dark, most because they never knew they were put into harm's way in the first place.

2.    Create science that is honest and independent.

An independent team of medical doctors, epidemiologists, toxicologists and investigative researchers need to be identified and pulled together to study the problem. An independent oversight leadership team that is composed of people who have been affected by the nickel powder need to be intimately involved in the direction of the study. An independent review team within DOE is insufficient. The participation of independent journalists, scientists and community leaders would add strong oversight quality to the leadership team. Given that the adjacent community was subjected to "excursions" of nickel powder from the K-25 site, people from that community need to be included in the creation, design and oversight of the study as well. The study's leadership team should be a group of people that have respect for the people who may be suffering from compound systemic effects of exposure to multiple toxins such as heavy metals, chemicals and radionuclides. It should not be headed by a person who views these people as being akin to "people on the Jerry Springer show", as the ATSDR official, Jack Hanley, is attributed as saying at the February, 1999 multi-agency meeting in Atlanta.

3.    Who pays?

INCO and the DOE, have a moral and a legal obligation to fund a new morbidity study and to make whole every single person exposed to nickel who may have been damaged as a result of their fatally flawed mortality study and their subsequent lax nickel handling operations. The new study should first focus on those exposed to the nickel powder where immediate medical help will have a profound difference in their lives. An independent medical team, paid for by DOE and INCO, but driven and directed those injured by past operations, i.e., the affected workers and their representatives should be immediately initiated by DOE, INCO and the public interest organizations working with the affected workers. . Rather than a "study", the investigation should be a Comprehensive Health and Environmental Response. The medical response should include symptom surveys, medical exams, body burden determinations of nickel and other heavy metals these people were exposed, as well as short-term and long-term medical treatment.

Then, and only then, can a truly clear picture of the cause and effect of nickel on these workers be ascertained. The medical protocol, with the best known medical science and technology world-wide, should be employed and should not be constrained by a budget pre-determined by the agencies that created the health problems in the first place.

4.