He said it would be "virtually certain" that such inhalation would result in an increased frequencies of a variety of cancers. "Moreover, the increased risk of developing cancers would be borne disproportionately by the women and children living downwind."

Among others filling comments transmitted by Hager are those by:

• Richard L. Miller of Woodlands, Texas, a certified industrial hygienist and certified safety professional who has worked for the Occupational and Safety Health Administration. He is author of the five-volume "U.S. Atlas of Nuclear Fallout." Miller says the government's revised draft environmental assessment is deficient.

Area 16, where the blast would take place, "has received contamination from above-ground nuclear tests," he wrote.

Federal fallout maps show Area 16 to be "within the contamination zones" of six nuclear blasts between 1955 and 1957. The bombs produced numerous radioactive isotopes that are likely still active, he wrote.

Miller listed 11 different isotopes with half-lives into many thousands of years, including deadly radioactive plutonium.

He added that the assessment does not include an estimate of the amount of small particles, 2.5 microns in size, that would be stirred up. These particles are able to penetrate into the deepest parts of the lungs, he wrote, citing the Environmental Protection Agency.

The government has two different estimates for the possible height of the resulting dust cloud, he said. They are about 8,158 and 9,750 feet above ground level, which is itself at 1,592 feet above sea level.

"If the debris cloud reaches nearly 10,000 feet altitude above the ground ... then it will have exceeded the maximum altitudes achieved by many above-ground nuclear tests," Miller wrote. The debris cloud from one of the tests was tracked to Canada, he added.

There is a significant potential for radioactive particles to be part of the PM2.5 dust lofted by the blast, according to Miller. "If so, these particles can travel for hundreds or thousands of miles with the wind currents and can potentially be inhaled by persons living downwind."

• Michael E. Ketterer, Northern Arizona University. Ketterer wrote that the government did not do sufficient sampling for plutonium contamination at the blast site. "It is likely that the data presented ... underestimate the average activity and/or total quantity of plutonium and definitely understate the activities present in the top 1-2 cm. of the soil."

• Diane M. Stearns, Flagstaff, Ariz., professor of chemistry at Northern Arizona University. She notes that the environmental assessment "now admits ... (that) 'since suspended natural radionuclides and resuspended fallout radionuclides from detonation have potential to be transported off of the NTS by wind, they may contribute radiological dose to the public.'"

The issue, she wrote, is the ability of the planners of the test to properly estimate the amount of radioactive particles and radiation to which nearby residents would be exposed.

She called the environmental assessment's description of those factors as "guestimation."

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E-mail: bau@desnews.com