ach data source is as accurate as possible. While it is probably truethat nickel particulates reaching the final stack of the C-746A induction furnacewould have been dominantly nickel oxide, releases from other portions of the smelterwere composed of other nickel compounds. For example all nickel was run through alarge calciner to convert the chemical composition of the scrap before it was fed tothe smelter. Particulates and gas from this process were released to a chemical trapsystem that exhibited a less than stellar ability to capture materials.
- Item three: Page one paragraph 4---"No specific nickel air concentration data were collected.."
Comment: This statement is very important for two reasons. First, it should madeclearer through the rest of the document (other instances cited below) that allconclusions are based on modeling which may or may not have been based on validassumptions. Second, it is widely understood (perhaps as a point of urban legend) atthe PGDP that orders for shutting down activities at the C-746A smelter come downfrom high ranking DOE folks in DC that were concerned with air emissions…simplyput, it is unlikely that this facility would operated at the PGDP without air emissiondata being internally collected,…period. Although records in the building had beenlargely and obviously purged by the time I conducted research in the building in1994(there were file cabinets filled with hanging folders with no contents), I didmanage to fill two boxes with information which might contain references to airsampling. These two boxes were placed in the document vault in Kevil, Kentucky(now under the control of Bechtel Jacobs) and should contain information that wouldat least point a researcher in the right direction. In addition, several of the folks thatmanaged the operation are still available to discuss if and what data was collected.
- Item four: Page one paragraph 4--- " This model uses...and source data from the PGDP air discharge permit application ."
Comment: It is unlikely that the permit application was totally forthcoming, though I will try to get a copy and check it out.
- Item five: Page three paragraph 3---"Activities of radiological contaminants…fromnickel samples  are used to determine the quantity of radionuclides released duringnickel smelting".
Comment: Using the level of radioactive materials in the nickel ingots is completelyinvalid. If this was information provided by DOE then I am deeply saddened andinsulted as member of the public. It was demonstrated in lab tests conducted beforethe major melting campaigns began that radioactive materials were highlyconcentrated at the top of the melt (subjecting it to greater release than from thebody of the melt) and subsequently removed as slag. The highly radioactive nature ofthe slag was the subject of internal documents and safety guidance. At a minimum theworst-case concentration should be used to see if there might have been a problem(perhaps modeling the elevated concentrations in the slag might show there were noproblems at all).
- Item six: Page three paragraph 4---"The average annual concentrations of nickel particulates (based on 1984-1986 emission data…."
Comment: According to Page one, no air concentration data were collected??? Ifquoted statement is based on data please cite the source(s) and add it to the referencelist at the end. If this is based on their permit application and production rates forthe time frame please clarify. The referenced map also lists the same informationsources. I certainly hope that the most significant output from this effort (the mapand conclusion that there is not any problem present) is not simply based on a modelconstructed from a KDEP application when better data is available. The better datashould be demanded from DOE before the ATSDR puts their final stamp on thisthing.
- Item seven: Page 3, footnote one---"Some nickel compounds, such as refinery dust…are known or probable human carcinogens . Nickel oxides, which is the chemicalform released…".
Comment: I suggest changing the wording to "Nickel oxides, 