tial source contributions from the PGDP steam plant and TVA Shawnee Facilityhave been added to the dispersion model. Clarifying information and references have been added asindicated in each response. The comments are included verbatim and refer to the consultation,although names and personal identifiers have been redacted. ATSDR responses are in bold type todistinguish the community comments from ATSDR's responses.
I read the recently released Health Consultation titled Exposure Assessment of Airborne Nickel andother Metal Particulates from Historic Smelter Operations at the Paducah Gaseous Diffusion Plantand have the following observations and recommendations for your review.
- Item one: Page one paragraph 2--"Between 1952 and 1986 the PGDP operatedseveral smelters to recycle scrap materials"
Comment: During the referenced time frame the PGDP did operate smelters in theC-746A building for recycling materials but most of the scrap was processed todestroy or disguise the classified nature of the scrap. Another smelter operated in theC-340 complex to produce uranium alloys for use by the DOD and AEC. Though it ispresented as a total review of smelting operations at the PGDP I found no mention ofthe uranium smelter in the document. The processing of other materials is veryimportant since some materials handled in these units was far more dangerous (e.g.organics, beryllium components and uranium) and the cumulative problem presentedby all operations must be studied and quantified. Were conditions "beyond the fence"terribly bad? I don't know but I had hoped that those with the expertise to evaluatethe situation would be given all available information by the DOE.
- Item two: Page one paragraph 3--"The PGDP permit application…emissions occuras nickel oxides."
Comment: As this entire review appears to be based on the PGDP permit applicationand ingot samples (addressed under item 5) and since this report is apparently goingto be used by the DOE as the "there are no problems from smelting" banner, we mustmake sure that each 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 appli