LDRRP saga

The first installment of this series, Inconvenient Low Dose Radiation Science Axed Under Obama Administration, described actions taken by Department of Energy (DOE) managers to ensure that the Low Dose Radiation Research Program that they had eliminated from their budget remained dead.

They planned to prevent information about the program’s successes and future opportunities from reaching the House and Senate staffers who were working on legislation designed to require funding the program. When the scientist who was managing the program departed from the planned script, they retaliated by separating her from her position and then separating her from federal service.

Not mentioned in the first installment, but addressed in the House Science, Space and Technology committee report on the way that Dr. Noelle Metting, the LDRRP Program Manager, was treated, DOE managers have also kept Dr. Metting away from the office that she occupied and have prevented her from retrieving both personal items and hard copy notes and papers related to her program’s accumulating results.

Also not mentioned in the first installment is the unstable document management system Dr. Todd Anderson, as the designated LDRRP Program Manager following the forced departure of Dr. Metting, chose to use to archive the program records.

Instead of maintaining the existing document organization on a federally controlled server, the program’s official website is an incomplete mirror hosted on Archive.org, a non-profit private organization whose site is also known as the Wayback Machine.

DOE Office Of Science Budget Priorities

According to publicly available documents and statements, the managers in the DOE Office of Science state that the LDRRP was a productive research effort that received “over a quarter of a billion dollars” during a period starting in 1998 and ending in 2016. They do not explicitly state why other programs were found to be of such high priority that they needed to be funded with the money originally allocated to the LDRRP.

As part of the HSST hearing conducted on Sep 21, 2016, Dr. Sharlene Weatherwax provided written testimony that describes the kinds of research conducted by the DOE Biological and Environmental Research (BER) program and the processes by which potential research areas are identified and prioritized.

Her testimony describes the importance of the BER program to the nation’s biofuel program and mentions some of the advances that have been made in genetic engineering and genome sequencing as a result of science derived from the human genome project completed in 2003.

Dr. Weatherwax’s prepared testimony then describes some of the accomplishments of the LDRRP.

Over the past 18 years the program has provided new technological advances and fundamental scientific understanding of the mechanisms cells use to sense, repair and adapt to the impacts of low dose radiation. Research investigations have included a number of critical biological phenomena induced by low dose exposure including adaptive responses, bystander effects, genomic instability, and genetic susceptibility. The program has supported the development of systems genetic strategies, including the role of epigenetics in integrated gene function and response of biological systems to environmental conditions, with a goal of translating molecular scale effects of low dose radiation to whole model organisms. The program outcomes and data are available to the community and other interested agencies through peer-reviewed scientific publications

Those words beg the question, “How did the Office of Science conclude that this productive, well-managed program needed to be eliminated?”

Retirement Of Primary Congressional Sponsor

One contributing factor was that Senator Pete Domenici, the strong Congressional champion for the program, retired in January 2009. Apprently, Sen. Domenici left office without finding someone to take over his role as champion of this small, but important research project.

Unlike Congressional earmarks that direct funds to a specific project of interest to constituents, Sen. Domenici had a keen interest in nuclear energy as an issue of national importance. His replacement as a Senator from New Mexico would not necessarily be the right person to receive the turnover on the importance of sustaining the LDRRP. It’s probably that Domenici wanted the program to continue as long as it was finding evidence that reduced uncertainties in an area area of inquiry that has been the subject of intense discussion for more than 60 years.

Almost immediately after it became apparent to budget decision makers in the Office of Science that there was no longer a Congressional protector for the LDRRP, they determined they had better uses for the $20-$25 million/year being invested in the program.

Of course, the timing could be purely coincidental.

Support Inside Of DOE

Documents discovered and published by the HSST investigation prove that there were people in leadership roles within the DOE outside of the Office of Science who believed the LDRRP was important and wanted it to continue. Dr. Pete Lyons, the Assistant Secretary of Energy for Nuclear Energy, was one of those internal DOE supporters.

HSST investigators discovered an email from Dr. Weatherwax to Dr. Marcos Huerta in which she acknowledged Dr. Lyons efforts to support the program.

Marcos, this is the program that Pete Lyons has always been keeping track of and asking about, because he started the program many years ago and believes its continuation is essential for the future of [the Office of Nuclear Energy]. So whenever there’s a public meeting, etc the NE community is reminded of it, and asks about it. Right now there is proposed legislation referring to this that is asking for engagement of the national academy, and development of a plan, etc.
…
So we don’t exactly know who in Congress is specifically advocating for this program, but the community is certainly ramping up the pressure by constantly asking about its fate. In terms of budget, it’s less than 10% [actually < 4%] of the [Biological and Environmental Research] budget, and it is not directly related to administration priorities of climate or clean energy. Only two DOE national labs are engaged in any research related to Low Dose.

(Source: HSST Dec 20, 2016, p. 13)

Dr. Lyons retired from his position as the Director of the Office of Nuclear Energy in June 2015, so Dr. Weatherwax could have coordinated with him about the program’s future before the program was eliminated. Apparently, that kind of coordination did not occur. In fact, the phrasing of the email can give the impression that Dr. Weatherwas was specifically not interested in what Dr. Lyons might say. She appears to believe that he was biased by his early involvement in recognizing the need for the research and creating the program.

It’s also intriguing to note that a scientist inside the DOE would dismiss research into the health effects of radiation, a significant issue associated with nuclear power plants, as having no direct relationship to administration priorities of climate or clean energy. President Obama started making public statements about the importance of nuclear energy as a clean energy source almost as soon as he became a candidate for President.

Dr. Lyons said that he stopped keeping close tabs on the program about the time that he was confirmed in the position of Assistant Secretary in April 2011. His professional attention, not surprisingly, became focused on events and policies influenced by the March 11, 2011 events at the Fukushima Dai-ichi nuclear power station.

However, Dr. Lyons stated that whenever the LDRRP was discussed in staff meetings, he “pleaded” for the program to be continued and described the importance of the program’s research results.

He said that he was joined in this effort to protect the program by leaders in both Environmental Management and the National Nuclear Security Administration (NNSA). When asked why, if the program was so important to his mission, he did not put it into his own budget, Dr. Lyons explained that he didn’t want to give nuclear energy opponents the opportunity to dismiss the program results. He feared they would claim that it was fatally flawed by being funded by the Office of Nuclear Energy. He indicated that would be seen in a light similar to having the nuclear industry fund the research.

He acknowledged that the same charge might be levied by nuclear energy opponents simply because the funding was from DOE, but he thought that the basic science arm of the DOE was the right place for the program to be managed. It is the organization with the management expertise, the equipment, and the specialized scientists. He was unaware of any other agency that was doing the kind of biological experiments conducted under the program in a real effort to understand how living systems react to radiation and how that reaction varies in different dose regimes.

Impact On Regulatory Actions

Dr. Weatherwax and Dr. Todd Anderson, the two DOE managers above the LDRRP Program Manager, told each other and the HSST investigators that the “program was not intended to address regulatory policy” because the EPA and the NRC were the regulatory agencies that establish regulations associated with radiation. That assertion exposes a fundamental misconception; the DOE is the regulator for occupational exposure to radiation in most of the facilities at the national labs.

Dr. Weatherwax’s prepared testimony also indicates a misunderstanding of modern science associated with low dose radiation.

At that time there was ample evidence from atomic bomb survivor studies to clearly indicate a statistically significant linear response between observed human health effects (cancer) and radiation at relatively high doses but no statistically significant data available at the low doses (less than 100mSv) more commonly experienced by most people.

Aside: The phrase “statistically significant” doesn’t mean the same as significant. In the lowest exposed cohort of the atomic bomb survivors (21,343 people) 39 people had died of leukemia by 1998. 4% of that total (2 people) was attributed to radiation. 1781 people had died of other forms of cancer; just 0.5% of that number (9 people) is the “statistically significant” excess due to radiation exposure. Readers can determine if those numbers rise to the level of significance or concern. End Aside.

The atomic bomb survivor studies have numerous limitations. Here are just two of them. Not only do they only provide indications of effects at high total doses, but they also provide information on a population where the dose rate was very high and where nearly all of the total dose happened in seconds to minutes, potentially overwhelming the repair mechanisms that were being identified by carefully crafted experiments under the LDRRP. Doses were not measured, only estimated based on distance from the blast and assumed shielding.

Weatherwax’s testimony also included the following statement.

Current radiation protection standards are based on the presumption that any exposure to radiation presents some risk of cancer to the exposed individual. That is, the relationship between cancer risk and radiation exposure is linear and there is no threshold level of radiation below which there is not some risk of cancer. Any changes to the current protection standards would require strong and compelling evidence that a higher amount of radiation is safe.

The problem with adhering to that precautionary philosophy is that it is only appropriate in an area of ignorance, or where there is conflicting evidence. In the case of low dose radiation, even the most authoritative bodies that have advocated use of the linear, no threshold assumption have admitted that the atomic bomb survivor studies provide no information about doses below 200 mGy. Evidence discovered by experimentation using measured doses at that level and below has to provide a higher quality basis for decision making that having no information at all.

In the internal email from Dr. Weatherwax to Dr. Huerta that was quoted above, one more assertion was made.

But in terms of our program priorities, we feel we have accumulated sufficient research results to inform EPA’s regulatory process. EPA has indicated that they do not require additional research information that would cause them to overturn their current regulatory limits, which are based on the extremely conservative Linear No Threshold (LNT) theory.

With that that statement, “EPA has indicated that they do not require additional research information that would cause them to overturn their current regulatory limits…” Dr. Weatherwax seemed to be telling her colleague that she had checked with a counterpart at the EPA and found out that agency had not any interest in continuing the LDRRP, especially if it would threaten their current regulatory model.

When the EPA was contacted to find out if that correctly represents their position, Enesta Jones, a spokesperson from the U.S. EPA Office of Media Relations, provided the following comment dated Jan 12, 2017.

EPA supports low dose radiation research as a way to better inform our regulatory activities.

Though Dr. Weatherwas did not respond to email or return calls, Rick Borchelt, Director, Office for Communications and Public Affairs, DOE Office of Science, provided the following comment in response to a request to address the apparent disagreement between what Dr. Weatherwax wrote in her email in Oct 2014 and what the EPA spokesperson wrote in Jan 2017.

The email of October 3, 2014, reflected the understanding in DOE based on interagency discussions at the time.

The good news from this whole episode is that the EPA has expressed interest in low dose radiation research and acknowledges that the experimental results from modern science would be used to better inform its regulatory activities.

Not only would LDRRP restoration be a positive step, but any legislation that directs that the research be revived should include guidance about gathering the evidence that has been revealed already. It should be used to support near term rulemaking.

Many radiation effects experts believe there is sufficient reliable evidence available to reverse the regulatory ratcheting that has been imposed since the advocates of the “no safe dose” assertion won the public communications battle. It’s important to know that they won that battle without having evidence to support their claim. They must not be allowed to win the war.

Senior Department of Energy executives, several of whom were “Acting” Obama Administration appointees in roles that normally require Senate advice and consent, made decisions that eliminated unique research into the biological effects of low dose radiation in the United States.

Early research results from the program are arguably sufficient to support decisions with globally important economic, medical and environmental implications, but there is enormous opportunity for returns from continuing the effort to understand exactly how living organisms respond over time to various doses and dose rates of ionizing radiation.

Here is a representative statement heard during discussions with leading radiation biology experts about the elimination of the LDRRP.

I was very disappointed to learn of the cancelling of the DOE LD program. The US had once led the world in this type of research, and is now abandoning this important effort. Thankfully Europe is active in this area still, otherwise lack of knowledge will continue to feed fear and misinformation. We absolutely need to really understand the biological effects of low doses of ionizing radiation. There is too much at stake not to.

Cynthia H. McCollough, PhD, FAAPM, FACR, FAIMBE
Professor of Medical Physics and Biomedical Engineering
Director, CT Clinical Innovation Center and X-ray Imaging Core
Department of Radiology
Mayo Clinic

Is This Old News, Or An Important Historical Tale?

This is not a scoop or a breaking story. It is a piece designed to provide a new perspective on a story that has already been the subject of a congressional investigation that included a televised Congressional hearing.

There were several news stories issued soon after the release of the congressional investigation (Ex: Energy Dept. Defends Obama’s Climate Action Plan By Firing Honest Scientist Daily Caller, Dec 20, 2016) but there has been little follow up or attention.

Perhaps that is related to the fact that the committee staff released its report on December 20, 2016, probably as one of their last items to complete before the Christmas holidays.

This version of the story is partly based on that staff report and its associated appendices. It has been supplemented with additional research and conversations with key players in the drama. It will be told in several parts.

Scientist With More Than 30 Years Government Service Fired

Some stories, like this one, are best told from the end with supporting historical details provided as necessary.

The individuals involved in eliminating the DOE’s Low Dose Radiation Research Program, most of whom were in the senior executive service, went to a lot of trouble to execute and solidify their decision. Efforts to halt the program seem to have begun within months after the January 2009 retirement of Senator Pete Dominici, the program’s creator and protector in Congress. The defunding effort finished in October 2014 with the beginning of FY2015, which included only enough funding to close out the last of the grants.

The decision defense efforts were fully completed in December 2014 after the deciding managers had successfully beaten back a Congressional effort to pass legislation to restore funding to the program.

Their protective actions included risking their own careers by suppressing information requested by responsible Congressional committee staff and violating rules that protect government employees from retaliation for performing their professional duties with integrity.

Anyone who has any knowledge of rules associated with managing federal government workers will recognize the uniqueness of the series of actions that killed the LDRRP when they learn that the responsible people went to the trouble of firing – not reassigning – a well-respected Radiation Biologist with a Harvard PhD in Cancer Biology who had been working for the government for more than thirty years.

No, Dr. Noelle Metting didn’t assault anyone and she was not found guilty of any acts of turpitude.

Her offense in the eyes of her bosses was answering questions from Congressional staffers about the program she had been managing for more than a decade. Within a week after briefing staffers, she was removed from her position as Program Manager. Less than two months later on the same day as her office’s Christmas party, she was officially notified that she was being separated from Federal Service.

Note: After months of haggling that involved both union representatives and legal counsel, Dr. Metting was restored as a civil servant in a different office with a different assignment.

What Happened To Justify The Personnel Action?

No direct transcripts of the fateful October 16, 2014 meeting with both House and Senate staffers have been made available. The senior DOE people who attended the meeting (Dr. Todd Anderson, Dr. Julie Carruthers, and Dr. Marcos Huerta) have refused to answer or return calls on numerous occasions during the past three weeks.

Here is an excerpt from the official Notice of Proposed Removal that DOE Office of Science managers issued to Dr. Metting on December 4, 2014 – with the approval of the DOE Office of General Counsel – that details her “Defiance of Authority” one of the two charges that supposedly supported the decision to fire her.

“On October 16, 2014, several members of SC’s senior staff met with Hill staffers to discuss H.R. 5544, a House bill which currently conflicts with SC’s management prioritization plan… You were cautioned to avoid interjecting contradictory opinions regarding this project. When you gave the presentation, you did not follow instructions or the prepared briefing… Your failure to adhere to SC’s talking points while speaking in your professional capacity on behalf of SC as a DOE official was confusing and undermined the purpose of your presentation… By defying my instructions, you directly undermined SC management priorities.”
(Note: For obscure reasons, SC is the internal DOE abbreviation for the Office of Science.)
(Source: HSST Dec 20, 2016 p. 20)

Dr. Metting, after suffering in silence for a couple of years, has decided to share her experiences. She recognizes that she was treated unfairly and that remaining silent is harmful not only to herself, but to the science to which she has devoted her career.

During the meeting with Congressional staffers, Dr. Metting provided a brief that had been vetted and approved by her managers. In response to questions from the knowledgable staffers who attended the meeting, she described opportunities for future research related to the science projects her program had funded. As she stated, she answered truthfully and passionately.

Her bosses had already repurposed all of the funding for the low dose program. They had no desire for Congress to obtain information that might encourage legislation that would to force them to revise their budget priorities.

Following the meeting with Congressional staff, Dr. Anderson called Dr. Metting aside and criticized her for being too forthcoming with information that called into question the policy direction to eliminate the LDRRP that had been established by the Office of Science. Perhaps they believed that a scientist who has been working on questions that have been open areas of inquiry since the 1950s was supposed to be reticent about expressing enthusiasm for research that was starting to provide solid experimental evidence for phenomena that many scientists have observed indirectly for several decades.

Perhaps surprisingly, because Dr. Metting is a self-admitted introvert and described by her peers as a dedicated, but shy scientist, she reacted to her supervisor’s criticism with the apparently horrendous offense of saying it was “idiotic” to accuse her of stepping out of the bounds of her scientific position.

It seems that eruption of emotion was translated into justification for the second of the two charges against her, “Inappropriate Workplace Communication.”

Was Program Killed Because Supervisor Didn’t Understand It?

While the actions taken prove the importance of the decision to eliminate the program, it is more difficult to discern the motives behind the assault on this particular branch of science.

Dr. Metting suggested an explanation. She thinks her supervisors were uncomfortable with the highly specialized area of radiation biology. She suspected that Dr. Weatherwax, the person who had to defend budget priorities for the Biological and Environmental Research office simply did not understand the science and disliked having to defend it during annual budget preparations. Apparently, she is the kind of manager that does not like to delegate explanations to subordinates, feeling that she should be seen as the expert in all areas that she is asked to fund.

From experience during the years when the LDRRP had its own budget line, Dr. Metting knew that budget reviewers in the Office of Management and Budget were always interested in understanding why the Department of Energy was investing in what some would call medical science that might be more appropriately funded by the National Institute of Health.

Dr. Metting was always able to answer that question by pointing to the fact that DOE is responsible for the standards used to protect its many occupational radiation workers, the expertise in the subject area that resides in the National Laboratories that work for DOE, and the fact that the labs and the universities that worked with them had the appropriate facilities for conducting the research. She was also able to explain the uniqueness of her program and the other agencies that were keenly interested in the results it was finding.

She was also able to explain how the science was progressing and the benefits that the government was receiving for its modest investment of approximately $20-$25 million per year. It had been her area of expertise for thirty years; it is her favorite professional topic of conversation.

Was Program Killed To Provide More Money For Climate Change Research?

The House Science, Space and Technology Committee report, along with several of the media pieces based on that report, suggested a different explanation that seems to be biased by partisan bickering. They concluded that the DOE executives moved the money from the LDRRP to fund Obama Administration priorities in climate change research. That explanation makes little sense based on the fact that the LDRRP was less than 3% of the $600 million – and growing – budget for Biological and Environmental Research. It was too small to make any substantive difference in accomplishment.

In addition, one of the prime potential payoffs for the research is information that would reduce uncertainties about the effects of low doses of radiation. With the research that had already been completed under the program, there was growing experimental evidence showing that there are radiation doses and dose rates that are not only safe, but beneficial to living organisms including human beings.

For too long, certain authoritative bodies have asserted that it was safe to assume that all doses of radiation. no matter how small, could harm people. They said that without more certain information, the best standard was to keep doses As Low As Reasonably Achievable, with the implied goal of zero if at all possible. That assertion, ostensibly meant to protect the public, causes angst, stress and ever more expensive effort since zero radiation dose is not an achievable destination anywhere on earth.

The assertion that all radiation is dangerous is an especially pernicious mantra; it tells people that every exposure causes harm that will never heal. The harm cannot be detected and the timing of the long term effects cannot be predicted. For people who tend to worry, this unknown, unseen boogeyman is ready to strike at any time and there is nothing they can do to have any control of the situation.

That assertion of invisible harm rests on a foundation of thin or non-existent evidence. Permissible doses and whether or not humans have any tolerance for radiation has been a subject of intense debate since the 1950s. The LDRRP was carefully designed to help provide evidence that would reduce the unknowns and allow decisions based on information, not ignorance.

The LDRRP Can Enable Effective Solutions

Firming up recognition of the already existing evidence and supporting additional research that integrated that evidence with large scale epidemiology efforts like the NCRP’s Million Worker Study could go a long way in making ultra low emission nuclear energy easier to develop, more affordable to maintain and easier to clean up to acceptable levels.

Continuing the LDRRP would have supported the Administration’s focus on effectively addressing climate change.

It also offers a new vector for health related research. Prior to the 1956 assertion that all doses of radiation are harmful, medical practitioners had developed a number of effective treatments using radiation. With new biological understanding and measuring tools, the LDRRP offered the possibility of developing even better treatments that might avoid some of the horrific side effects of chemical medicines that one often hears or reads in the lengthy disclaimer sections of pharmaceutical advertising.

The next installment of this series will go further back into history to find other possible reasons that the LDRRP became an important bureaucratic target for elimination.

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A version of the above was first published on Forbes.com under the headline Inconvenient Low Dose Radiation Science Axed Under Obama Administration