ML18177A022

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Comment (182) of Linda Sager Squire on Holtec International HI-STORE Consolidated Interim Storage Facility Project
ML18177A022
Person / Time
Site: HI-STORE
Issue date: 05/03/2018
From: Squire L
- No Known Affiliation
To:
Rules, Announcements, and Directives Branch
References
83FR13802 00182, NRC-2018-0052
Download: ML18177A022 (14)


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Common Neurological Disease Cluster Threads: An Outline Describing Potential Combined and Cumulative Effects ofRadionuclides, Lead or other Heavy Metals, Fluoride and Aluminum Updated February 22, 2018 The mode of infectivity of prion-related diseases and the exact mechanism by which these mysterious entities cause disease in humans and animals is largely unknown. It has been proposed that CJD, Alzheimer's disease, Parkinson's disease, CFS/ME or chronic fatigue syndrome, and MS are all associated with abnormal prion proteins. Autism may eventually also be found to fall into this category. In animals, BSE, CWD, Elk Wasting Disease, TME in mink and scrapie in sheep have all been shown to be transmissible to other animals of the same species with the transfer of infective prion materials. It seems possible that the clinical manifestations of each of these human and animal diseases could have common origins but that the various symptoms and final outcomes might be determined by age at first exposure of the patient, route of exposure and tissue or organ involved, duration of exposure, and intensity or concentration of inciting substances, elements or compounds.

Looking for common factors or threads in each geographical area that has been known to harbor a neurological disease cluster of people or animals has revealed some striking similarities. Geology, fault lines, earthquake and volcano activity, drilling, mining, industrial activities, pollution incidents of all types, water quality, soil quality, farming practices, waste disposal, sewage sludge and biosolids applications, radionuclide contamination, radiation exposures, nuclear accidents, wars and soldier heaJth issues were just a few of the factors that have been examined.

The following outline presents some of the similarities that were noted. Four main cluster factors were found to be present in almost every cluster location studied. It is interesting to note that cancer clusters in general followed patterns similar to prion related disease cluster sites. It is also noted that there is an aversion on the part of many individuals to acknowledge the presence of a disease cluster of any type and this has certainly hampered efforts to study these diseases and to develop strategies for prevention and possible cures.

Findings:

I. Issues of environmental contamination with chlorinated hydrocarbons, such as TCE, PCE degreasers, and PCBs may be a factor in defining some cluster areas. Exposures to pesticides such as paraquat have been known to precede the onset of Parkinson's disease and the exposure of laboratory animals to certain toxic chemicals has been recognized as a method of creating animal models for studying this disease. Heavy metals may also be a part of the picture as naturally occurring mineral deposits, air or soil pollutants, or as water contaminants in certain cluster areas.

Manganese, lead and uranium seem to be frequently encountered as part of the geology of cluster areas. Most often the above-listed contaminant combination will be related to military bases, weapons manufacturing, or to uranium mining, processing, or enrichment.

Degreasers were used to remove radioactive fallout from planes and ships returning from test sites during the cold war. Certain uranium compounds are known to readily dissolve in these potent organic chemicals and while the half-life of uranium is measured in the billions of years, further down the decay chain, a great number of the daughter elements will have half lives of 22.3 years or less. As uranium (or thorium) decays, the level of daughter elements increases and this increases the total radiation emitted when compared to the amount that was being emitted at the starting point. (NRC, Frequently Asked Questions about Depleted Uranium Deconversion Facilities) and (Ancient Roman Metal Used for Physics Experiments Ignites Science Feud, SUNSI Review Complete Template= ADM 013 E RIDS-ADM 03 ADD-Antoinette Walker Smith, Jill Caverly (JSCI)

COMMENT (182)

PU Bl ICA TION DATE: 3/30/2018 en A no

  1. 83 FR 13302

Scientific American). Once the decay of uranium or thorium reaches the stage of 222Rn or 228Ra, all of the many subsequent decays down to non-radioactive lead will be found to be easily within a normal human life span.

Each stage of decay will release alpha particles or beta particles and energy. Over time, a buildup of daughter products from the decay of radionuclides such as uranium, thorium, radium, radon, strontium, or polonium, to name a few, within an animal or human body could result in cumulative and severe damage. Symptoms and severity could vary according to age of the animal or person at the times of exposures, the radioactivity or radionuclide dose, and the exact locations of deposition. The basis for neurological problems arising from exposure to organic solvents or pesticides may actually be the fact that radionuclides may be bound to these substances and the solvents may provide a route by which the radionuclides can enter fatty tissues such as liver, brain or adipose deposits where the potential for devastating chronic problems could exist for many years. Areas of intersection of alpha or beta particle tracks emanating from multiple sites would be prone to even more damage ( death of many cells and subsequent vacuolation) than would tissue along a few linear paths that would likely be found with only sparsely distributed intra-cranial radionuclides.

Elevated lead levels have been reported in the serum of Alzheimer's patients and children with autism. These elevated levels may reflect lead that resulted from nuclear disintegrations taking place within the body. Ores containing heavy metals are often radioactive and smelted lead is also radioactive. The total amount of radionuclides and radioactivity present in lead would decrease with the age of the lead.

2. Exposure to radionuclides in the form of fallout or in foods, or from the presence of uranium, thorium, radium or radon in the air or water or both seems to be a feature of many of the neurological disease cluster areas, both human and animal. Exposures to various forms of ionizing radiation would also fall into this category. Cold War nuclear testing, especially the many above ground detonations all over the planet contaminated almost every comer of the earth, leaving behind a background radiation level almost twice what it was before the first bomb was set off. Proximity to uranium deposits, abandoned mines, tailings piles, abandoned military facilities or fields of battle that processed, used or tested weapons containing depleted uranium seems to be a common feature in many cluster patterns.

Oil, gas, and coal reserves may contain elevated levels of naturally occurring radionuclides, fluorides and heavy metals. Black shale, as found in the Marcellus formation in northeastern Ohio and western Pennsylvania, may harbor uranium or radium compounds. Fracking has been implicated in creating issues related to water quality in that contaminants and pollutants may follow fault lines and fracture lines into water tables and may make their way into drinking water.

Where uranium is found naturally in water, elevated levels of nitrates will often be found as well.

Uranyl nitrate is water soluble. When nitrate level in water is high, the uranium will become more soluble and more available. This has been observed in states in the west where the Ogallala aquifer is tapped into for drinking water and for irrigation water. The Ogallala underlies Nebraska a state with one of the highest incidence rates of Parkinson's disease and with CWD cases reported. When the pH of water is low or the dissolved oxygen level is low, more uranium can be mobilized in it. (Environmental Science and Technology Letter and map showing nitrate and uranium levels in aquifers)

Illustrative maps of water wells in the US with radon, radium and uranium issues (Cothern and Rebers) may also be aligned with known cluster sites of various prion-related neurological

diseases. (CWD in Southeastern Wisconsin and Radium in Bedrock Aquifers in Southeastern Wisconsin) and (Colorado Game Management Units, CWD Map of North America and Abandoned Hardrock Mines and Waters Polluted by Metals for Colorado-Mineral Policy Center Map by Ali Steimke) and (Interactive map of Radium contamination in public water systems nationwide, Environmental Working Group)

Meat from wild boar harvested from certain forests in the Czech Republic, Germany, and Austria was found to contain elevated levels of 137 Cesium from fallout that drifted into these areas from the Chernobyl disaster over thirty years ago. The wild boar have apparently been feeding upon radioactive mushrooms, with the net effect of transfer of radioactivity to their soft tissues and bones to the point that eating the meat may not be safe for consumers. Mushrooms have been utilized in phytoremediation and chelation strategies due to their ability to absorb and incorporate radioactive metals. Deer antlers and antler velvet from numerous regions throughout the world have also been shown to have detectable levels of radioactivity.

3. Close proximity to a site of a noticeable magnetic anomaly pattern, where a strong positive area borders a strong negative area (as measured by aircraft flying at a fixed altitude and displayed on a gridded gravity map) is easily observable for many of the cluster locations. USGS state maps of magnetic anomalies will verify this point. These types of areas will often have fluoride containing mineral deposits located in the electronegative areas and metals associated with the electropositive areas. Such an area would probably attract both electro-negatively charged airborne fallout particles as well as the electropositive ones, possibly increasing total radiation dosages in this manner. This phenomenon is very marked in Iceland, which is the epicenter of many neurological diseases, both human and animal. It is also quite noticeable in portions of Colorado where clusters of CWD and elk wasting disease have been identified and mapped. The gridded electromagnetic anomaly maps were created in the 50s and 60s to help geologists locate areas with the greatest potential for yielding minerals of all types, but with specific goals of determining where uranium and thorium deposits might exist.
4. The extreme resistance of prion proteins to the high temperatures and pressures commonly used to sterilize surgical instruments points to the fact that the misfolded proteins are probably only a part of the prion structure. Elements, such as uranium, thorium, radium, strontium, polonium, cesium or radioactive lead could be the disease-causing entity incorporated into the prion, most likely in the form of a complex metalloprotein, not unlike those found in petroleum deposits. Another possibility is that the metal atom may be surrounded by a porphyrin ring structure and that it may be part of a biologically active and mobile molecule. Phosphate containing enzymes could easily become compounded with heavy metal ions and could easily cross membranes and barriers that would normally block heavy metal transport.

Perhaps during the preparation process for amino acid sequencing in early prion research, radionuclides may have been removed, washed or stripped away from the abnormally folded protein sheets of the prion materials being tested, right along with other debris and impurities. It is unlikely that tiny bursts of radiation at the molecular level could be detected in the laboratory, even with today's modern instrumentation.

It seems logical that if temperatures in excess of l 000 degrees C, or 1832 degrees Fahrenheit, are needed to drastically reduce infectivity of prion materials, (Challenge of Prion Decontamination, Clinical Infectious Disease) the melting and vaporization points of uranium metal and its compounds must be considered. Uranium has a melting point of 1132 degrees C and the tetrafluoride of uranium melts at 1032 degrees C. Triuranium oxide melts at 1,150 degrees C and uranium dioxide boils at I, 150 degrees C. (Depleted Uranium Production and Handling Slide 21:

Melting Points of Uranium and its Compounds, web.ead.an I.gov/uranium/ gu ide/prodhand/sld/021 /cfm)

5. Another noticeable geologic similarity of the cluster areas is that detailed geology maps show the presence of clay deposits, specifically bentonite and/or Montmorillonite. These specific types of clays will normally have large percentages of aluminum in them and they may harbor or sequester radioactive metals. These maps will also show the presence of numerous fault lines, indicating instabilities and potential conduits for radon gas to work its way up through the ground and enter a subterranean structure such as a basement or a cave. By this same mode, uranium, radon or radium, if in extensive contact with an aquifer under certain pH conditions, may also enter into water supplies to the extent that human or animal health could become adversely affected.

Dusts and fine particulates (such as aluminum clays) may provide a vehicle for entrance of uranium or various fluoride compounds via the nasal passages across the mucous membranes into the blood stream or across the nerve connections directly into the regions of the brain that control the sense of smell. Prion testing procedures have been described for direct swabbing of the dorsal nasal turbinate region near the posterior reaches. Radon may directly enter the nasal turbinates and possibly proceed on to the brain by this route. (Fluorine is one of the few elements with which this noble gas will combine, even under laboratory conditions.)

6. Exposure to fluorides is another common factor, through PFOA contamination from firefighting foams used at training centers or airports, Teflon manufacturing, or from excessive fluoride in the drinking water. Well over 80% of US cities have added fluoride to city water supplies for over fifty years at a target level of 1 ppm. That recommended level has recently been lowered to a level of. 7 ppm, but many researchers are concerned that this level may also be too high for optimum health. The recommended fluoride levels often exceed safe levels especially for the very young and the very old, those whose kidneys cannot handle the excretion of this element. (These same groups cannot handle excessive exposure to uranium either, as this element is also removed mainly via urinary excretion.) Many US children currently have overt signs of fluorosis, chalky white spots or deposits in and on their teeth. This is an indication that too much fluoride exposure has been taking place for too long.

Fluorides may build up in the pineal gland and in bones and joints as well. Fluoride side chains may be incorporated into the complex molecular structures of certain drugs and pharmaceuticals that are intended to produce central nervous system effects. Fluoride compounds may cross the placenta and may produce adverse effects on the unborn.

The Ogallala aquifer is one of many water sources notably high in fluoride, seeming to increase in amounts the further south the wells are located. Some areas pulling water from this aquifer have recorded water fluoride amounts in excess of 4.6 ppm. Dental fluoride treatments and fluoridated tooth care products, especially if swallowed can contribute to excess fluoride intake. Certain pesticides, such as cryolite, may make US wines unsalable in Europe due to high fluoride carrying through on the sprayed grapes. Certain medications and fruits and vegetables irrigated with fluoride-containing water or prepared in a way that concentrates fluorides may also contribute to fluoride exposure. Inhalation anesthetics or certain types of refrigerant or cooling chemicals can leave behind a fluoride exposure load. Fluoride (and radionuclide) exposure may result from volcanic eruptions via direct air pollution and later by precipitation of water and runoff into drinking water sources. (Iceland, Philippine Islands, Azores, Japan)

Fluoride exposure may result from being in close proximity to phosphate mines and this is a triple hazard, as phosphate deposits are often loaded with radionuclides and aluminum compounds as well. CFS clusters in Tallahassee, Florida may serve to illustrate.the fact that there may be an association of this disease with phosphate mining and refining. In addition to the above elements, phosphate deposits will often have abundant calcium, potassium and silica associated with the phosphate formation.

Cattle and people downwind of aluminum smelters have been shown to suffer signs of fluorosis due to airborne releases of fluorides, both directly by inhalation and indirectly by contamination of foods and forages. (Lennart P. Krook, Cornwall Island Study) Secondary trace mineral imbalances due to exposure to airborne aluminum particles have been documented in cattle, with anemia and immunodeficiency noted as symptoms.

Mineral supplements for cattle may contain dangerous levels of fluoride depending upon the sourcing of the components. Over I 00 cows with arthritis in one study had fluorine levels in the bone of between 2,000 and 8,000 ppm, clearly illustrating a possible good reason why the banning of meat and bone meal feeds to ruminants greatly aided in prevention of further spread of BSE in the UK. Over half of the mineral supplements tested in the same study showed dangerous levels of fluorine in the range of 3,000 to 13,000 ppm. (Fluorosis in Dairy Cattle, Griffith-Jones Vet. Rec.) and Virgil Hulse, Milk Gate)

Phyllis Mullenix wrote a paper demonstrating that deleterious effects of exposure to ionizing radiation were amplified when concurrent exposure to the fluoride contained in an immunosuppressant steroid medication being given was also a factor. Another study states that older people who "have surgery" are more likely to develop Parkinson's disease later in life. Perhaps this study did not take into account a lifetime of drinking fluoridated water and of being administered a fluoride-containing inhalation anesthetic along with the radiation exposure associated with the multiple cat scans, contrast studies and radiographs that probably preceded the surgery. Perhaps the study did not take into account the placing of a Teflon implant or joint replacement or a mesh sling or patch. Developed countries have much higher rates of neurological diseases such as Autism, PD and Alzheimer's. Developed countries also have historically subjected their citizens to fluoridated water ever since the post WW2 era. Only recently have some communities rejected fluoridation. All US military bases are fluoridated.

It is interesting to note that instead of adding fluoride to the drinking water of their people, the Chinese government is actively engaged in installing water purification systems to remove excess fluoride in regions where this has been a problem. They have determined that fluoride exposure is the cause of many cases of crippling arthritis and that it may lower the IQ of those consuming fluoride in high amounts. They have also acknowledged that burning low quality coal in a home releases fluoride in high enough amounts to cause dental fluorosis, even where the drinking water is not a problem.

Sewage sludge, or "biosolids" as it has been aesthetically renamed, contains all four of the factors outlined above. When applied onto farmland, all four of these factors will enter the food chain and could potentially contaminate water sources. Spreading sewage sludge on agricultural lands places all four of these risk factors in close proximity to each other and increases the likelihood of concurrent exposures of plants, animals and humans to all four, either directly or indirectly.

Immunosuppression and trace mineral imbalances in cattle have been linked to their exposure to the components of biosolids through the feeding of contaminated hay and forages. (David L.

Lewis, Science for Sale)

Certain vaccines, especially the ones containing the rendered product gelatin, (Virgil Hulse, "Milkgate") will most likely be found to contain fluorides and radionuclides because the bones and tissues of rendered animals may be high in fluoride and strontium or uranium. Heavy metals, chemical contaminants and amorphous debris have already been found to be present in a number of vaccines tested. Aluminum adjuvants in the form of phosphates or hydroxides, compounds commonly added to boost the immune response or to fool the body's immune system, serve to complete the list of the four factors. (Gatti) It seems possible that by virtue of combining the four factors, a neurological disease cluster site in a vial could inadvertently be created.

7. Often, but not consistently, an animal reservoir of retrovirus infection near the area of a cluster may be identified. Perhaps humans create their own reservoirs in the use of certain vaccines and biologicals. In southwestern Kentucky there is a strange cluster of CJD. Illness has been linked to consuming fried squirrel and squirrel brains, items considered a delicacy in that area. The neurologists who observed this suffered some repercussions as a result of speaking of it publicly. Wild small rodents of course can serve as retrovirus reservoirs. Squirrels typically eat acorns. Nuts are known to be high in manganese and they may also concentrate radionuclides and fluorides. Western Kentucky is the site of extensive contamination from both radionuclides and fluorides due to activities at DOE sites where both the handling and enriching of nuclear materials have taken place. Much information is out there about attempts to mitigate problem substances from water tables and from lakes and streams in surrounding areas. Phyto-remediation is a tool for cleaning up badly contaminated areas by selecting plants that preferentially uptake and sequester problem radionuclides from the soil. Any animal that eats plant materials, or predators that eat herbivores or omnivores, in a contaminated area will bioaccumulate and bioconcentrate contaminant radionuclides. Animals highest on the food chain will naturally encounter more problem substances available for ingestion and absorption.

Kentucky has extensive reserves of coal, which may contain variable levels of radionuclides and fluoride. Phosphate reserves are also prominent in the geology of Kentucky and mining activities and agricultural use of phosphorus fertilizers may expose humans and animals to additional radionuclides and fluoride in foods and forages.

Deer and elk may have retrovirus infections in certain locales, but wide area studies have not been done. Bats and kangaroos are known to harbor retrovirus as well. The retrovirus part of this big picture may simply be a result of immune systems being weakened by the above four factors, and the presence of some nearby reservoir of virus, rather than a primary cause.

In cluster areas for CFS in Incline Village, Nevada, Lyndonville, New York, Tapanui, New Zealand, and Durban, South Africa, the four basic conditions are found in one form or another.

The same conditions have been observed in various areas of New Jersey, New York, Texas, and the UK where CJD clusters have been identified. Geographic locations of BSE cases throughout the UK can be shown to line up with areas where the four factors can be identified. CWD clusters in certain areas of Colorado, Arkansas, Nebraska and several locations in Canada correlate fairly well with maps of active and abandoned uranium mines, areas known to have water wells with unusually high levels of fluoride and various clay formations. (Colorado brown stain or fluorosis in the teeth of people drinking well water is adequately documented.) The four geological and environmental parameters were also found to be present at certain points along the Snake River in Idaho and these locations correlated fairly well with a coarse map of CJD cases in that state.

I have loosely outlined the basis for the hypothesis that I am trying to develop and clarify, hoping to be able to put it into a credible written format. I am very optimistic at this point when I

consider the idea that if various combinations of the cluster factors are found to be involved in the pathological processes that give rise to prion related neuropathies, we could be well on the way to being able to protect our animals and ourselves from these frightening and devastating diseases.

Solving this mystery is way beyond the abilities of any one scientist or researcher. I get the feeling that looking at the big picture first and then filling in all the details might be the only way to make progress. At this point, I think that putting together a group of qualified concerned people willing to participate in efforts to check out the above points would yield the most compelling and reliable results in the least amount of time. I have contacted other veterinarians who are specialists in pathology, animal nutrition, and in diseases of deer and elk. Another contact is an expert in hydrology and water pollution issues. I have also contacted a radon mitigation specialist who is very knowledgeable in the field of evaluation of uranium and radon health effects and disease prevention. This is just the beginning.

In 1975, an old professor in the small animal outpatient rotation at The Ohio State University College of Veterinary Medicine told our class of senior students that for every mistake we would make in the years after graduation for not knowing, we would make hundreds for not looking.

How true these words seem as we attempt to explain and define the etiologies of the various spongifonn encephalopathies and other prion-related illnesses.

Linda Sager Squire, DVM 575-752-0172 lindajsquire@yahoo.com

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existing medical conditions. Nitrate affects the ability of red blood cells to carry oxygen, but in most pevple the levels rapidly go back to normal. Infants on the other hand need longer to stabilize the oxygen leYels and mi develop a condition called methemoglobinemia or "blue baby syndrome." Nevertheless n r 1 1 1

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It can also adversely affect people who do not have enough stomach acids and people who have a Ja k (If enzyme that is needed to convert red blood cells back to normal (an inherited condition). Moreowr. h can increase the risk of miscarriages and certain birth defects.

The study found that 78% of the uranium-contaminated sites are linked to the presence of nitrate, a eot:X::ZlltlD groundwater contaminant, that stems from chemical and animal waste fertilizers. Nitrate, through a bacterial and chemical reactions, oxidizes uranium which then makes it soluble and capable ofleachlng

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The researchers report their results in the August edition of the journal J: m ironn1t 11l.i t nn: Jn I t