which is the dominantchemical form reported to have been released (citation)". What it appears by thestatement in the document is that it is a fact that only nickel oxides were released. It isquite likely that material more similar to refinery dust was released in the processing(shredding and calcining) stages and I wouldn't be amazed if the smelting processitself produced some interesting nickel compounds given the composition of the metaland observations made by former operators.
- Item eight: Page 5, paragraph one---"As the toxicity of other smelted metals is lower than nickel…"
Comment: Since the emissions of uranium from the uranium furnace were apparentlynot reviewed in this project and there were other nastier materials (metals andorganics which would flash off before complete combustion) fed to the C-746Afurnace than is mentioned in the text, this is a rather bold statement to be made, eventhough it is fairly well documented that nickel was the largest in volume by far theabsolute nature of this statement should be reduced.
- Item nine: Page 5, paragraph one---" Because the estimated concentration of allmetal particulates from PGDP are below health concern, no adverse health effectsare likely from potential residential or WKWMA worker exposures. As metalparticulates from smelter operations are not identified as contaminants of concernand did not occur at concentrations of public concern…."
Comment: I did not see a section in the text wherein the concentration of "all metal particulates from PGDP" was reviewed. It is the cumulative affect of PGDP sourceson the surrounding environment that would have affected it negatively. I am verymuch interested in the review of the cumulative affect of materials released from thePGDP. Back reference again to such broad references being made based on a permitapplication and samples taken from a final "cleaner" product. It should be noted thatit has not been determined definitively that metal particulates "did not occur atconcentrations of public health concern" since the conclusion is based on review of amodel and that model is based on data that is not entirely correct.
A valiant effort was made given the amount of information available/provided to theresearchers preparing the report. Additional effort needs to be made to add thesampling information available at DOE to the review and models. A huge amount ofprocess information was removed from C-746A at some time between 1987 and 1994.Managers of the smelter could indicate what types of records were kept anddocument archivists for the site could indicate where this information was taken.Some information was removed from the building in 1995 and uniquely "stored" indrums destined for disposal. Studies such as these need to be put together to ascertainthe cumulative affect of all of the sources of contamination and see if off-site residentswould have been within the radius of influence. Doing this in a location-by-locationmanner is akin to informing the family of a torture victim that everything should befine because each of the thousand cuts was studied and found to be insignificant.
ATSDR Response: This consultation specifically addresses releases from the C-746Asmelters. Appropriate revisions have been made to clarify the purpose of the healthconsultation. Releases from uranium metal operations at the C-340 complex were evaluatedas part of total uranium releases from the entire PGDP facility and are included in the PGDP Public Health Assessment.
As you have indicated there was a uranium metal production operation in building C-340.1985 annual uranium emissions from the C-340 operations are provided in Table 1 of the1985 Environmental Monitoring Report . Annual emission values for U234, U235, andU238 are 7.1E-6, 3.3E-7, 2.6E-5 Ci/yr, respectively. As these values are all at least 10,000times lower than the emissions from other previously evaluated sources (C-310 stack, C-400group, seal/wet air exhaust, C-710 laboratory) for earlier years (1956-59), they do notcomprise a significant additional source of radionuclide emissions (s