cation 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, 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