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PUBLIC HEALTH ASSESSMENT

IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY (U.S. DEPARTMENT OF ENERGY)
[a/k/a IDAHO NATIONAL ENGINEERING LABORATORY (USDOE)]
IDAHO FALLS, BUTTE, CLARK, JEFFERSON AND BIN COUNTIES, IDAHO


APPENDIX G. RADIATION AND RADIOACTIVE MATERIAL

Information in this section comes from The Health Physics and Radiological Health Handbook. Schlein, B [ed]. 1992. Silver Spring, MD: Scinta, Inc.

What is radioactivity?

Radioactivity is the spontaneous emission of radiation from the nucleus of an unstable atom. Atoms are the smallest units of an element that have the same properties as the element. All matter is made up of atoms, and atoms are made up of protons and neutrons (found in the nucleus of the atom) and electrons. The number of protons in an atom of a particular element is always the same, but the number of neutrons may vary. Whether an atom is unstable, or radioactive, is determined by the ratio of neutrons to protons. Isotopes are forms of the same element with different numbers of neutrons. The number of protons and neutrons in the atom is added to name the isotope. For example, an atom of cobalt that has 27 protons and 33 neutrons is called cobalt-60. Cobalt-60 is radioactive and is therefore called a radioisotope, or a radionuclide.

Where does radioactivity come from?

All elements heavier than bismuth (which contains 83 protons) are naturally radioactive. Lighter elements, such as carbon-14, tritium, and potassium-40, are radioactive because of natural processes in the environment. Everyone is exposed to naturally occurring radiation from space and from radioactive materials in the ground. People can also create radionuclides of most elements. For example, people create radionuclides to use as tracers to help measure the flow of materials in sick people or in the environment. Radioactive or not, the way a substance moves in people or through the environment depends on its chemical properties. Some radioactive materials can travel through the air as particles or gases; some can enter soil, water, plants, and animals. Most of the radiation that people are exposed to in the air is radon, an alpha emitter that results from decaying uranium-238, which is found to varying degrees in all soil and rocks.

What is radiation?

Radiation, a form of energy, may be ionizing or non-ionizing. Ionizing radiation occurs as alpha particles, beta particles, gamma rays, x-rays, neutrons, high-speed electrons, high-speed protons, and other particles able to produce ions, or charges. Non-ionizing radiation includes radio waves, microwaves, visible light, infrared light, and ultraviolet light.

What radioactive materials were processed at INEEL?

INEEL was established to build, test, and operate various types of nuclear reactors and support plants. In support of DOE reactor research programs, INEEL received spent fuel from many reactors nationwide. Among the radionuclides processed and discharged on site were tritium and strontium-90.

What are alpha particles, beta particles, and gamma radiation?

Alpha particles are positively charged particles made up of two protons and two neutrons. They can travel only a few inches (centimeters) in air. The particles lose their energy quickly and do not penetrate the skin surface if exposure is external. Alpha particles can enter the body through a cut in the skin, by ingestion, or by inhalation. Once inside the body, alpha-emitting radioactive substances may be harmful. Uranium-238 and plutonium-239 are sources of alpha radiation.

Beta particles, or beta radiation, are fast-moving particles that may be either positively or negatively charged. A negatively charged beta particle is an electron, and a positively charged one is a positron. Beta particles are easily stopped by a thin sheet of metal or plastic. Beta radiation can penetrate a few millimeters in human tissue before losing all its energy. Large amounts of beta radiation may cause skin burns, and beta emitters may be harmful if they enter the body from ingestion or inhalation. Iodine-131, phosphorus-32, and strontium-90 are sources of beta radiation.

Gamma rays, or gamma radiation, occurs as high-energy, short-wavelength electromagnetic radiation, or packets of energy emitted from the nucleus, or core, of an atom. Gamma radiation often accompanies alpha and beta emissions, and it always accompanies fission, or splitting of atoms. Unlike alpha and beta particles, gamma rays are very penetrating and are best stopped, or shielded against, by dense materials, such as lead. Gamma rays are like x-rays, but more energetic. Gamma rays emitted from a nearby source may enter the body without ingestion or inhalation. However, the energy (and the dose that can be deposited) drops rapidly with distance from the source of radiation. The dose received by a person 1 meter (just over a yard) from a source is 0.01% of the dose that would be received 1 centimeter (just under a half inch) from the source. If enough gamma rays pass through the body, they may damage cells. Cesium-137 is a source of gamma radiation.

What is worldwide fallout?

Fallout is the term given to radioactive particles that fall from the atmosphere and settle on the Earth's surface. Radionuclides enter the atmosphere worldwide from atmospheric testing of nuclear weapons and accidents at weapons production facilities. Accidents involving weapons transport, satellite reentry, and nuclear reactors have also released some radionuclides, though in much smaller amounts. Scientists track radionuclide levels in our environment that have resulted from fallout. The information collected to date suggests that the levels are very low and that exposure to these low levels is not likely to increase an individual's chances of developing health effects such as cancer.

What is plutonium and where did it come from?

Plutonium is a silvery white metal that exists as a solid under normal conditions. It is produced when uranium absorbs an atomic particle (a neutron). Trace amounts of plutonium occur naturally, but large amounts have been produced in nuclear reactors. Trace levels of plutonium can be found in the environment, from past nuclear bomb tests, in several forms called isotopes. The most common plutonium isotopes are plutonium-238 and 239.

How can plutonium affect my health?

Plutonium has not been shown to cause adverse health effects in people. Animal studies have shown lung diseases from short-term exposure to high concentrations of plutonium. Animal studies have also shown effects on the blood, liver, bone, and immune system from plutonium exposure. Studies in people have found no cancer from plutonium. Animal studies have reported an increase in lung, liver, and bone cancers from exposure to plutonium.


APPENDIX H: PUBLIC COMMENTS

ATSDR released the public comment version of this public health assessment on June 17, 2003. This appendix included comments received during the public comment period from June 17 to August 5, 2003. For some comments, ATSDR was unable to find the text that corresponded to the comment. It is possible the comments referred to an earlier version of the public health assessment.

# Public Comment Agency Response
1 The title for the report incorrectly identifies the counties which the INEEL impacts. It should be Butte, Bingham, Bonneville, Clark, and Jefferson counties, not Idaho Falls, Butte, Clark, Jefferson and Bin counties as stated on the report cover and first sheet. The cover sheet and title list EPA's information for the site, not the potentially impacted counties.
2 The data that ATSDR used in the construction of the public health assessment (PHA) is typically only through 1999. However, there is more current data available of which ATSDR should avail itself. Specifically, the Idaho Department of Environmental Quality (IDEQ) referenced current data sources in their review comments of the document. The more current data referenced, have been evaluated by ATSDR staff and as it would not change the conclusions of this report. Therefore, it has not been included.
3 It does not appear that ATSDR utilized the work of Risk Assessment Corporation, contractor to CDC's Radiation Studies Branch. This company performed screening evaluations of the site for chemical and radiological constituents as they pertain to dose reconstruction activities at the site. ATSDR did review RAC's reports, but did not include them. ATSDR did not want to duplicate the reporting of CDC's dose reconstruction work.
4 In general, the document narrative requires the reader to determine information on their own based upon the appendices. For example, only two paragraphs are devoted to health outcome data review. They are very vague and simply refer the reader to the appendices. There should be more of a narrative description of what is contained in the appendices. The health outcome data appendix has been removed and more narrative has been put in the body of the health assessment.
5 There is not really any explanation of who the population is that ATSDR is evaluating in this document. Both workers and the general public are discussed, but this needs to be stated more obviously in the beginning of the document and in the Summary. Is ATSDR evaluating off-site health impacts only, or on-site too? What about tribal considerations? ATSDR is only looking at off-site exposures. The document addressed a particular scenario for non-employee exposure to a contaminated well in the central facility, by request of a HES member.
6 There should be mention made at some point in the document that there are currently arguments about how long it will take for contamination from INEEL to reach the aquifer and reach off-site populations. The document says that contaminants have already been detected off-site, but not at levels that would cause adverse health outcomes.
7 The summary is very vague and would be more appropriate in a question and answer format. For example, What is the INEEL and what are the issues? What chemicals and radioactive materials did ATSDR find? How can the site affect my health? Can my cancer be caused by the site? Etc Also, we suggest that if ATSDR is going to list two of the public concerns raised about the site (cancer/birth defect rates, and the SL-1 accident), then brief mention should be made about the other concerns delineated in the report, status of cleanup measures at Pit 9, potential health threats posed by contaminated water supply wells, and exposure to plutonium from its reburial. No change. The summary lists ATSDR's conclusions regarding potential health effects. ATSDR included these concerns at the request of the HES.
8 Page 1, 4th paragraph The assigned public health hazard category of no apparent public health hazard is stated for the off-site community; however, your completed exposure pathway is for on-site workers drinking water containing tritium. We understand your selection of no apparent public health hazard, but as we have found in one of our PHAs you need to be very clear in the beginning that even though contamination was found and completed exposure pathways exist, it doesn't necessarily mean that it is a public health hazard. Again, you must also be very clear about what population you are addressing. Additionally, in the next two paragraphs, you discuss the potential public health hazards in the present, future and in the past. This can be very confusing. We suggest different wording accompanied by justification as to why you are discussing potential health concerns when you just told the reader that there was no apparent health hazard. Clarified. This exposure scenario was requested by members of the HES, to evaluate the worst possible exposure of a non-employee visiting the site.
9 Page 1, last paragraph with bullets Since there is much controversy about how soon until contamination on site migrates to the Snake River Plain Aquifer and then reaches down gradient communities, we suggest you include in bullet #2 that no site-related contaminants are currently, or will in the future, be accessible to the public on or off site at levels that would cause health concerns. This backs ATSDR's justification that by the time contamination in the water would reach off site populations, it would be too dilute to cause adverse health conditions. Changes made as suggested.
10 Page 2, first paragraph We suggest changing the second sentence to address that no adverse health effects are expected because the concentrations of the contaminants found are below comparison values. Changes made as suggested.
11 Page 2, second paragraph ATSDR obtained the assistance of the INEEL Health Effects Subcommittee, the Idaho Division of Health (Bureau of Environmental Health and Safety and the Center for Vital Statistics and Health Policy), and the Cancer Data Registry of Idaho. ATSDR needs to include both offices under the Idaho Division of Health that contributed information to the report. Changes made as suggested.
12 Page 2, third paragraph In the second sentence, "remainder of the" needs to be inserted after ".. .based on comparisons with the.. ...[insert wording] State of Idaho." The "s" in State should be capitalized throughout the document. There is no sentence in the paragraph that provides the evaluation results of birth defects data. Were the rates high, low, or what was expected? Additionally, the paragraph contains more description than is necessary for the summary. Delete from the third sentence on. Sentence removed as suggested.
13 Page 2, fourth paragraph We suggest the following change to the first sentence: "Public concern was also voiced about a nuclear accident on January 3, 1961, which resulted in an air release at the site's Reactor Testing Station." We also suggest taking out the second and third sentence (including the parenthetical) and deleting the italics in the fifth sentence. Rephrased first sentence as suggested.
14 Page 3, table There is no discussion to go along with the table and no way for the reader to fit the information in context with the summary narrative. This table would be better replaced with narrative and move the table to the Pathways Analysis section. Table was moved as suggested.
15 Page 4, 5th paragraph Provide more detail about what the "growing environmental program" at INEEL is. Sentence removed.
16 Page 5, second paragraph after Environmental Restoration and Management When were monitoring activities initiated at INEEL? In 1986 as stated in the following paragraph of the PHA.
17 Page 8, Table 1 If you add the number of operable units (DUs) listed within the 10 waste area groups on the table, the total is 97 not the 83 mentioned in the following narrative. If some of the OUs are overlapping, a comment about this needs to be made. Also, the narrative doesn't summarize that there are a total of 360 solid waste management units throughout the 10 waste area groups. They overlap. Text added to state that some overlap.
18 Page 9, 3rd paragraph Toward the end of the paragraph, ATSDR mentions the State of Idaho Oversight Program but does not identify it as part of the Idaho Department of Environmental Quality. Also, the last sentence needs to be divided into two. After "INEEL," a period should be added. The new last sentence should begin, "The results of.. ..." An "s" needs to be added to the word "lend" in the last sentence. Changes made as suggested.
19 Page 9, 4th paragraph The last sentence should refer to INEEL handling DOE spent nuclear fuel from the national nuclear weapons complex. Changes made as suggested.
20 Page 10, 5th paragraph In the second sentence after "Atomic City" the parenthesis are incorrect. Corrected.
21 Page 11, first full paragraph The paragraph refers to Figures B-1 and B-2, but does not tell the reader where to locate them (Attachment B). Added: (Appendix B)
22 Page 11, Table 2 Under Racial Characteristics, there should be a comma after "American Indian" and before "Eskimo." Table replaced with 2000 Census data.
23 Page 12, 2nd paragraph Insert "the" in the first sentence before "substance." No change.
24 Page 12, 3rd paragraph This is the first paragraph where you can define the acronym for comparison values (CV). Corrected.
25 Page 13, 2nd full paragraph Insert "ambient" before "ionizing radiation exposures" in the second sentence. Additionally, in the third sentence it states that ATSDR reviewed material from the 1950s through 1999. However, there are references in the document to 2000 reports, and as suggested in the general comments section of this document A ATSDR should be utilizing the most current data available. Changes made as suggested.
26 Page 13, 3rd paragraph and table There is an inconsistency between the spelling of "Systeme International" in the paragraph versus the table. Also in the table, the parenthetical in the description of the milliroentgens can be eliminated. Corrections made as suggested.
27 Page 14, second half of table The final row on the table refers to "Negative Numbers as Results." Is this necessary? It does not come up in the body of the report. No change.
28 Page 14, 1st paragraph The second sentence is not clear where it pertains to the depth of the aquifer. The sentence says, " the aquifer -or water-saturated zone -lies about 200 to 1000 feet below ground surface and is made up of rocks... ." Does this mean that the thickness of the aquifer spans 800 feet or does it mean that in some locations you find the aquifer at 200 feet and other locations you find the aquifer at 1000 feet? It does not seem likely that the latter is true, as the site does not have the elevation gain to account for such a dramatic fluctuation in the depth of the aquifer. Changed "about" to "between".
29 Page 15, 2nd paragraph How could the perched water zone be formed from the Big Lost River being dry as stated in the third sentence? Also, there are no references to substantiate the final sentence of the paragraph that perched water zones can sometimes protect the SRPA from contamination hot spots. The Big Lost River flows seasonally. Perched zones prevent direct flow of water through waste areas into the SRPA.
30 Page 15, 4th paragraph The document should include within the paragraph that the Idaho Nuclear Technology Engineering Center (INTEC) was formerly the Idaho Chemical Processing Plant (ICPP). Added suggested text.
31 Page 16, 2nd full paragraph Preface the "Oversight Program" with State of Idaho. Change the last sentence to read: "These samples are tested for gross alpha and beta radioactivity and tritium. With the use of gamma spectroscopy, they are also tested for Sr-90, Tc-99 and other selected ions." Changed text as suggested.
32 Page 16, 4th paragraph In the first sentence change "its" to "the INEEL" and add that pesticides and metals are also routinely monitored for. State that Table A-I can be found in Attachment A. Add "if known" to the end of the last sentence. No change.
33 Page 1 7, 1 st paragraph State that of the contaminants detected, all of the maximum concentrations exceeded the comparison values. In the text box adjacent to the first paragraph, ATSDR should include that much of the VOCs in the waste areas were from off-site waste that had been brought in from other facilities such as Rocky Flats for disposal. Added: "Much of the VOCs in the waste areas were from off-site waste that had been brought in from other facilities such as Rocky Flats for disposal."
34 Page 17, 4th paragraph Add "For example," before 1,1,1-TCA in the second paragraph. Add "The maximum concentration of' before carbon tetrachloride in the last full sentence of the paragraph. Additionally, there is no reference for the final sentence of the paragraph that extends to page 18. Changes made as suggested.
35 Page 18, 1 st paragraph In the second to last sentence VOCs "have been" removed, not "were." The last word of the paragraph should be "area" not "layer. Changes made as suggested.
36 Page 18, 4th paragraph State that it is the TAN injection well for clarity. In the fifth sentence, insert that the plume was kept from rising in part by bioremediation. Bioremediation is not solely responsible. The same is true for the parenthetical toward the end. The bacteria assist in bringing the concentration closer to the MCL. Unable to find referenced paragraph.
37 Page 19, 2nd full paragraph We are not geohydrogologists, but it does not seem plausible that a layer of clay can ultimately prevent water from passing through. It seems more likely that the clay will dramatically impede water from migrating, but not completely prevent it. Changed "prevent" to "impede".
38 Page 19, 3rd paragraph and Table 3 Add to your list of groundwater contaminants SVOCs, PCBs, and pesticides. You list them in your attachments, but not in the narrative. Does Table 3 refer only to the TAN and RWMC drinking water wells for non-radiological contaminants? What about all of the other facilities and other contaminants? Why pick those two chemicals when the data is available in the appendix? Additionally, are there more current source data than ESRF 1996 for the chemical concentrations? The narrative only discusses locations of maximum concentrations.
39 Page 19, 4th paragraph Insert a discussion about the INEEL drinking water facilities. As IDEQ pointed out in their review comments, each facility had their own drinking water systems. If this is true, there are many references to a single, site-wide drinking water system that need to be changed to make the document accurate. If necessary, ATSDR will have to change their exposure assumptions because there won't be a network of piping under the INEEL that mixes and dilutes the contamination to below the comparison values. Each facility has its own drinking water facility. Discussion of mixing water is removed.
40 Page 20, 2nd paragraph The last sentence refers to TSF#2 still being used. Is it routinely monitored? If so, state. No change.
41 Page 20, 4th paragraph The word "regions" at the end should be changed to "region's" to make it possessive. Not found.
42 Page 21, 1 st paragraph and text box The first paragraph makes mention of the groundwater flowing off-site toward Minidoka, not the Magic Valley. This is the first time we have heard of this philosophy. Does ATSDR have references for this statement? If so, please provide them. This same reference is made in several locations in the PHA. The text box only refers to two radionuclides out of seven identified. Mention should be made that there were seven. The second paragraph in the text box should reference that tritium is used/produced at the INEEL, it is also produced in the upper levels of the atmosphere. No change, see reference (Johnson 2000). Figure 1 shows flow toward Minidoka County.
43 Page 21, 3rd paragraph Divide the second to last sentence into two sentences at the semicolon. The second sentence should begin with "since that time," instead of "subsequently." In the last sentence ATSDR states that "today, INEEL disposes of much"less tritium in the infiltration ponds." How much less? Fifty percent less? Ten percent less? Changed to suggested wording. Much less means just that, a small fraction of its previous output.
44 Page 23, 1st paragraph In the second to last sentence, the word "samples" is the wrong tense. It is in the proper tense. No change made.
45 Page 23, Table 4 The table has no reference and is placed far below the discussion to which it belongs. The table should follow the second paragraph and should be labeled so the reader knows that it is addressing drinking water supply wells for the CFA only. Changed header to clarify it is only from the CFA.
46 Page 24, 3rd full paragraph Same comment as number 20 above. Corrected.
47 Page 25, 4th paragraph ATSDR states that flooding is a concern at INEEL due to frozen soil. It should be frozen soil thawing. Added thawing.
48 Page 26, 4th paragraph Define DEHP. Not found.
49 Page 26, 5th paragraph Why is the paragraph italicized? Not found.
50 Page 27, 1st paragraph The first paragraph should include a discussion on what typical background radiation exposures are for the average person (300 mrem/yr) and how they receive it. Added to text box: "More detailed explanations can be found in Appendix G Radiation and Radioactive Material."
51 Page 27, text box The title/question should be in relation to contaminants traveling off-site through air as the body of the text explains. Added: "airborne" to the title.
52 Page 28, 3rd full paragraph This paragraph is the first of several that mentions INEEL's greatest release. However, there is never a description of that event and there are no references to support it. For example, why are there no mention of the Risk Assessment Corporation documents addressing dose reconstruction? The PHA deals with current releases and after those considered in RAC's dose reconstruction.
53 Page 29, 1 5t paragraph ATSDR mentions why monitoring was done for VOCs and NOx, but does not mention why the facility monitored for S02 and PM. SO2 and PM were not considered as potential completed pathways at levels that could cause adverse health impact.
54 Page 29, 2nd paragraph Where are Van Burean Avenue and the Experimental Field Station? Are they on or off site? Was NO not monitored for? It is on-site. The Experimental Field Station (EFS) is about 5 km north-northeast (downwind) of the INTEC main stack. NO was not monitored.
55 Page 29, 3rd paragraph Insert "sampling" after EFS in the beginning of the first sentence. Added.
56 Page 29/30, 6th paragraph Define RBC. Divide the last sentence into two at the semicolon. Why is the last sentence italicized? Not found.
57 Page 31, 1st/2nd paragraphs There are no tables in the appendices with the non-radionuclides for off-site air and both on and off-site radionuclides and their concentrations. The appendix only has Table A-6 listing non-radiological contaminants in on-site air. They were not monitored off-site or there was no off-site monitoring data available.
58 Page 32, 1 st full paragraph Again, no mention of what INEEL's greatest release was or reference. Greatest stack releases from INTEC.
59 Page 32, 2nd paragraph ATSDR says that atmospheric samples were taken at 4 off site locations and only five of these samples indicated any positive detects for tritium. At what cities were the detects? Not found.
60 Page 32, 3rd paragraph In the second sentence after the comma, change "but" to "therefore." Not found.
61 Page 32, 4th paragraph In the second sentence, ATSDR should refer to pronghorn antelope in the list of game species since they are referenced later in the report. Additionally, the full name pronghorn antelope, not just pronghorns should be used. In the latter part of the paragraph the "INEEL buffer zone" needs definition. Are there more current grazing information than 1995? The fact that dairy cattle are not permitted on-site should be emphasized by making it its own sentence. Changed "pronghorn" to "pronghorn antelope".
62 Page 33, 1st paragraph There is not a consistent use of the word biota in the first paragraph. For example the second sentence states "vegetation, wildlife, and other biota." This is redundant as biota is plants and animals -whether they are wild or domestic. We suggest changing the first sentence to read: "Surveillance of biota is conducted at INEEL at select facilities and at off-site locations." The last sentence, change "and" to "including" between biota and locally grown foods. Not found.
63 Page 33, 2nd paragraph In the discussion about children's vulnerability, change "..children just tend to be more sensitive.." to "children, in general are, more sensitive." Not found.
64 Page 33, 3rd paragraph Delete the parenthetical from the second sentence about potato sampling. Removed.
65 Page 33, general comment There are not sampling data or appendices for biota/food chain as there were with other exposure pathways. There is also mention again about INEEL' s greatest release but no reference or description. No change.
66 Page 34, general comment There are no data tables for ambient radiation. No change.
67 Page 34, 2nd paragraph We suggest ATSDR change the 5th -7th sentences to read: "Alpha particles cannot travel far and are unable to penetrate skin. Alpha particles typically do not contribute to a person's external dose. However, if an alpha particle source entered the body, through inhalation or ingestion, it would contribute to a person's internal dose. Beta particles also may be responsible for both internal and external doses, but they do not penetrate body tissue as easily as gamma rays." Examples of alpha, beta, and gamma radioisotopes from INEEL should be included. No change.
68 Page 34, 3rd paragraph It needs to be made clear that fallout is from former nuclear weapons tests and detonations and from large nuclear facility accidents. No change.
69 Page 35, 2nd paragraph At the end of the paragraph the parenthetical note should be deleted as a note, changed to a sentence beginning with "The" and the parenthesis dropped. Not found.
70 Page 35, 3rd paragraph The last sentence appears to have contradictory information in it because ATSDR states that the external dose is about 131 mrems/year and does not exceed the estimated background. However immediately following in the sentence it says that the external dose, if any, does not exceed the estimated background. The sentence states the dose is 131 mrem but also states that there may not be any dose. Additionally, ICRP recommendations are to not exceed 100 mrem above background in a year. The dose contribution from the site is 131mrem, 31 mrem above the 100 ICRP recommends. Not found.
71 Page 36, 1st paragraph This paragraph should also be stated in the summary. The third sentence should be divided into two sentences at the semicolon. Added paragraph to beginning of Summary.
72 Page 36, 2nd paragraph The second sentence should be divided into two sentences at the semicolon. Edit made as suggested.
73 Page 36, 4th paragraph Throughout the 4 paragraph, ATSDR uses examples of the elements of exposure. However, there are no examples of the air pathway which is an important pathway of concern at INEEL. We suggest including something to the effect of: "emissions" in #1, "facility air emissions" in #2, and "outdoor/indoor air" in #3. No change.
74 Page 36, 6th paragraph We suggest the following change to the 6th paragraph: "Following the strategy outlined above, ATSDR identified completed and potential exposure pathways by which the public could be exposed to contamination specifically associated with INEEL. All of these involve workers and visitors drinking INEEL drinking water. The following table (Table 5) shows all of the exposure pathways. A discussion about which pathways are completed, potential or eliminated begins on Page 43." Changed to suggested text.
75 Page 41, Comments Column in Table There is no reference to the dose reconstruction work that has been done for INEEL. Added reference to the Draft Historical Dose Reconstruction for the ICPP.
76 Page 42, Biota Pathway, Comments Column in Table The comments section refers to "crops grown at the site," however, there is no reference to crops grown on site anywhere in the document and all data indicate crops grown offsite. Changed to Off-Site.
77 Page 44, General Comment Again, ATSDR needs to be very clear about who this public health evaluation is for, especially when it comes to eliminating exposure pathways on basis of worker/nonworker populations, etc. It this report evaluating on or off-site exposures? Workers or general public? No change made. The worker exposure scenario was addressed at the request of the INEEL Health Effects Subcommittee.
78 Page 44, first bullet Are future exposures being considered in the elimination of the surface waters and surface soils exposure pathway? Yes, but not in the EPA's unrestricted scenario.
79 Page 44, 3rd bullet The words "food chain" in the title should be one word to maintain consistency with the rest of the document. Again there is mention in the bullet about on-site crops, but not anywhere in the text of the report. Changed as suggested.
80 Page 44, 4th bullet The paragraph is not clear if exposures on-site exceeded the comparison values/background radiation as was the case with off-site exposures. If there were exposures at the site near source facilities, wouldn't this then become a potential or completed pathway for workers? Also, there is no mention of future exposures with this pathway, especially considering remediation work that is continually underway at the site. No change.
81 Page 46, last paragraph We have the same comment as previously about the drinking water distribution system. According to IDEQ, each facility had its own drinking water distribution system, nota site-wide distribution system. Changed to reflect that distribution systems were for each facility and not site-wide.
82 Page 47, 1 st paragraph Since workers at the site are typically transported there and remain until their shift is complete, wouldn't the typical worker on the site have access to the drinking water for 9 hours per day, 5 days per week? Workers, from our understanding, stay on site for their lunch hour. Additionally, assuming workers ingest less than 12% of 2 liters per day of water seems low. This is only 8 ounces of water per day. It would seem more practical and conservative to assume that all 2 liters (67.6 ounces) of water were ingested to calculate exposure. Additionally, how many weeks per year was the person drinking water? There are 52 weeks in a calendar year and a typical employee works 50 weeks out of that year. Unable to find.
83 Page 48, 5th paragraph In this paragraph, your assumptions for daily water consumption are different than those on page 47. This paragraph states that a full-time worker drinks a full 2 liters of water per day, 5 days per week for 50 weeks a year. Why the discrepancy? No discrepancy. Unable to find text in comment #82.
84 Page 49, General Comments After careful review of the health outcome data section of this report by the Bureau of Environmental Health and Safety, the Bureau of Health Policy and Vital Statistics (formerly the Center for Vital Statistics and Health Policy) and the Cancer Data Registry of Idaho, many comments were generated regarding the section. All comments regarding the health outcome data evaluation and reporting can be found in the following section dedicated to the review of Appendix K. The review comments are also based on questions presented to the Bureau of Health Policy and Vital Statistics and the Cancer Data Registry of Idaho by ATSDR regarding the information/data they provided. Appendix K was removed, since it was difficult to understand. More narrative was added to the Health Outcome section of the PHA.
85 Page 49, 1 st paragraph The narrative for the health outcome data section is very short and the reader is left to read the results in Appendix K. More description and explanation should be incorporated into this paragraph and the following. Furthermore, there is no description long or short about the results of the birth defects analysis. More narrative was added to the Health Outcome section and Appendix K was removed.
86 Page 49, 2nd paragraph The paragraph should not begin with "in brief' because it is not a follow-on discussion to the birth defects information. It is a paragraph dedicated to the description of the cancer evaluation. There is also no mention of the Cancer Data Registry of Idaho providing ATSDR and its contractors with the data used to conduct the analysis. Finally, the parenthetical makes no sense. It states: "e.g., although breast cancer incidence was significantly increased in Clark County, it was significantly decreased in the more populous Bingham County, compared to the incidence in the rest of the state." Unable to find referenced text.
87 Page 50, 3rd paragraph The second paragraph on Page 49 says that the cancer in the area is within the normal/expected range, but this paragraph confuses that statement. Unable to find referenced text.
88 Page 53, 1 st paragraph Again, there is mention of a site-wide drinking water system. Does not mention any site-wide system. Refers to multiple distribution systems on site.
89 Page 53, 2nd paragraph Again there is mention of groundwater flow toward Minidoka. We commented previously that it is not our understanding that the groundwater flows in that direction and there is no reference to support ATSDR' s assumption. No change, see reference (Johnson 2000). Figure 1 shows flow toward Minidoka County.
90 Page 54, 1 st paragraph Same comment as #8 above. Additionally, the paragraph refers to a lifetime of drinking water 24 hours per day, 7 days per week, and "50" weeks per year. There are 52 weeks in a year to account for an annual exposure. This is a standard assumption that residents are away from home on holiday for 2 weeks a year.
91 Page A-2 There is no reference for the 1,1,2-trichloroethane comparison value. Added reference to (CREG).
92 Page A-6 In the title for concentration of becquerels per kilogram, the acronym should be Bq, not "Bg." Additionally, as ATSDR has done with all of the other tables, there should be a column at the last devoted to comparison values (ICRP recommendations). Corrected typo to "Bq". There are no comparison values for radiological concentrations in media.
93 Page A-8 There are no data tables for off-site air for non-radiological contaminants and there are no tables for on and off-site radiological contaminants. There were no data for off-site air available.
94 Figures One of the figures presents the "demographic variables in 1, 5, and 10 mile increments from facility buildings." The figure is very confusing because the accompanying data table says that at 1 mile from "the site buildings" there is a total population of5l5. However, is that 1 mile from the TAN facility? Is it 1 mile from the RWMC facility? Are they counted the same? It is feasible that one person could live within 5 miles of the RWMC or the ANL-W because the site boundary ends within that isopleth. However, it does not seem possible that anyone lives within one mile of any of the facility buildings when looking at the map. Updated with 2000 Census data and consistent distances.
95 Page G-2, 4th paragraph In response to the question about what radioactive materials were processed at INEEL, there is nothing discussing plutonium. Even if it is not processed at INEEL and is at the site due to other circumstances, there should be a discussion about it. Added discussion on plutonium.
96 Q1: Statistical analysis of birth defects: There appear to be some errors in the analysis of birth defects in Table K-1. All rates appear to be in error by about 3% (e.g. Table K19, Heart Malformations). The state rate should be >285/1.59955 = 178.2 (not 186.2). Ai: The footnote for Tables K1a-K1g states "rates are based on records with known data for congenital anomalies (rate = specific anomaly/number of live births -"unknowns"). See Table K-2. The number of records with unknowns are shown in Table K-2. The state rate for heart malformations = 285/(159,9955-6,914) = 182.2 per 100,000 births. The National Center for Health Statistics calculated US rates based on records with known data and Idaho rates are based on records with known data. Idaho and US data are comparable in these tables. Appendix K was removed.
97 Q2: The method of analysis described on page K-4 to evaluate the birth defects for the six counties near INEEL is not appropriate. A2: Len Young asked for numbers and rates for the six counties. Method of analysis was composed by Mr. Young or ATSDR? Appendix K was removed.
98 Q3: It also appears that "Iowa" rates for most conditions is often much higher than the US 1997 rate given in column 2 of Table K. (The question continues with rate calculations and a note that a better approach would be to use Poisson regression on individual county data.) A3: Mr. Young was provided the data and analysis he requested. Tables were compiled by Mr. Young or ATSDR. Appendix K was removed.
99 Q4: Statistical analysis of cancer incidence and mortality: Results in Table K-5 through K-8 should also be based on Poisson regression methods. If analysis is limited to the State of Idaho then calling the entire state (with the six counties subtracted) the "reference population" is not appropriate. In cancer incidence and mortality analyses the models also include age specific data usually in 5 or 10 year intervals. The results of this analysis would be cancer cause specific relative risks for "exposed" counties relative to non-exposed counties. The definition of "at risk" counties could also be changed to reflect information available on the hazardous material of interest. These statistical methods are described in detail in Breslow and Day (1987) and can be done using a number of widely available computer programs (GLIM, Splus, R, AMFIT, SAS, etc). A4: The response to A4 was provided by the Cancer Data Registry of Idaho (CDRI) and is covered in a multi-part reply that completes this evaluation of ATSDR's PHA. CDRI provided data to Mr. Young, ERG, but conducted no analyses. The choice of the statistical methods was made by, and all analyses were conducted by, Mr. Young or ATSDR. CDRI concurs with the recommendations made in Q4. Appendix K was removed.
100 Page K-IO, Section II. Cancer Evaluation, Data Sources: Data on cancer incidence for the state of Idaho were obtained from the Cancer Data Registry of Idaho (CDRI), Idaho Hospital Association. CDRI operates a statewide cancer registry under contract with the Idaho Department of Health and Welfare. As part of a data sharing agreement, CDRI may analyze and report unofficial cancer mortality statistics. This is the source for mortality data cited in the INEEL PHA Initial Release. Appendix K was removed.
101 February 1, 2000 1. Idaho cancer incidence data for the years 1970, 1971-1975, 1976-1980, 1981 1985, 1986-1990, 1991-1995, 1996-1997 which included case counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
102 SEER cancer incidence data for the years 1973-1975, 1976-1980, 1981-1985, 1986-1990, 1991-1995 which included case counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex. Appendix K was removed.
103 Idaho cancer incidence data for the years 1971-1997 which included case counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
104 Idaho cancer incidence data for the years 1971-1998 which included case counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
105 Idaho Behavioral Risk Factor Surveillance System data for the years 1989-1998 for prevalence of clinical breast exam, mammogram, Pap test, current smoking, ever smoked, ever used smokeless tobacco. Appendix K was removed.
106 Idaho cancer incidence data for the years 1971-1997 which included case counts, person-years, crude rates by cancer site, sex, and 5-year age group for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
107 Idaho cancer incidence data for the years 1971-1997 which included case counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for the aggregated 6-county area (Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties). Appendix K was removed.
108 Idaho cancer mortality data for the years 1971-1997 which included death counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
109 Idaho cancer incidence data for the years 1993-1997 which included case counts, person-years, crude rates by cancer site, sex, 5-year age group for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, and the State of Idaho. Appendix K was removed.
110 Idaho cancer mortality data for the years 1971-1997 which included death counts, person-years, age-adjusted rates (1970 standard) by cancer site and sex for the aggregated 6-county area (Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties). Appendix K was removed.
111 Idaho cancer mortality data for the years 1971-1997 which included death counts, person-years, age-adjusted rates (1970 standard) for cancers of the bones and joints (a site not previously specified) by sex for Bannock, Bingham, Bonneville, Butte, Clark, Jefferson Counties, Idaho Public Health District 6, Idaho Public Health District 7, the State of Idaho, and the aggregated 6-county area. Appendix K was removed.
112 Page K-I0, Section II. Cancer Evaluation, Data Sources, Incidence Data: As mentioned above, the cancer registry is operated by CDRI, not CVSHP. Appendix K was removed.
113 Page K -11, Section II. Cancer Evaluation, Data Sources, Incidence Data: It is inappropriate to measure a trend by comparing a data set to a subset of those data, as was described. It does not appear that such a comparison was actually attempted in the analysis. Appendix K was removed.
114 Page K-ll, Section II. Cancer Evaluation, Methods: It is inappropriate to compare the 6-county area to the State of Idaho because the expected counts are comprised partly from data from the study area. A general rule used by many statisticians is that if the study area's population is 5% or more of the total, then it is necessary to subtract out the remainder to obtain an unbiased comparison area. It would be appropriate to compare the 6-county area to the remainder of the State of Idaho. Appendix K was removed.
115 A better statistical method would have been to use Poisson regression to model counts (incident cases or deaths) based on person-years and include indicator variables for age group, sex, and geographic area. This would allow for a more appropriate test of the hypothesis of no difference in rates between the study and comparison areas. The data provided to ERG were of sufficient detail to be easily used in this manner. Furthermore, this methodology would have allowed the inclusion of known confounding data on cancer screening and risk factors from the Idaho Behavioral Risk Factor Surveillance System (these data were provided for this purpose). Appendix K was removed.
116 Page K-13, Section II. Cancer Evaluation, Limitations: The cancer incidence data were complete statewide at the time they were reported to ERG; reporting differences do not account for apparent differences in rates among counties. The "over-reporting" and "under-reporting" biases do not have merit. Using address of residence at the time of diagnosis or death may be problematic as a proxy for exposure (due to in and out-migration), but this is not a problem of duplicative or missed reporting. Appendix K was removed.
117 Page K-21, Section II. Cancer Incidence Discussion: A more detailed discussion should be included on multiple statistical tests and the chances of finding statistically significant results based on the number of tests conducted. Specifically, how many tests were conducted, and how many significant high and low rates would be expected based on the numbers of tests. Appendix K was removed.
118 Summary Page One: Statement: "According to the information received by ATSDR, under normal operating conditions, INEEL poses no past, current, or future apparent public health hazard for the surrounding community for groundwater, surface water runoff, soil biota or air" Comment: In my opinion, the use of the word future is not warranted. I believe it shows a bias which is not scientific. Presently, the Snake River Aquifer, is still being evaluated. Past and present studies are still being evaluated. Dose Reconstruction studies are ongoing, so that even present conditions are not well characterized. In the words and of Niels Bohr "prediction is difficult especially when it concerns the future." No change.
119

Page 2: Statement: "... that the types of cancers commonly associated with radiological and chemical exposures are within the range of what would be expected based on the comparisons with the state of Idaho."

Comment: Referring to paragraph 3 on page 23, which begins with the statement "A Strontium-90 plume has formed in the SRPA beneath the INTEC facility, extending Southwest with the general direction of the ground flow. Concentrations have reached 516,000 pCi/L"

Refer then to appendix I-28, which states "Cancer in the bone and joints is also elevated in males in three of the six counties that were included in the analysis (19711997 incident rates).

I saw no evidence in the report that would exclude strontium as a possible cause of some of the bone tumors noted in the male population.

In the same paragraph (I-28), the paragraph continues to read "it is difficult to interpret the meaning of the increased number of cases, since they only occur in men. If environmental exposures were contributing to the development of cancer of the bone and joints, both men and women would likely be affected, either by increases, or by decreases."

Comment: It appears to me, that men and women generally have had quite different job descriptions and duties until fairly recently. I would be willing to venture, even without the data, that most of the men involved had more contact with the environment, working with materials, and building facilities, while many more women were in more isolated environments more frequently being involved in secretarial type occupations.

The paragraph also contains a statement concerning the rarity of this type of cancer and a very small populations of these counties. Does not the occurrence of a rare type of cancer in a small population cause the agency some concern?

Appendix I was removed.
120

Page 55 Public Health Action Plan: In the original document, it was stated to that "Upon request from the public, ATSDR will develop and implement an environmental health education program to help community members understand the findings and implication of this public health assessment"

Comment: This part of the plan appears to be left out of the revised edition. As far as the community is concerned, I thought this was the most important part of the plan and heartily endorsed it, as I think there's too little community involvement in these issues. Along this line, when there is public involvement at our meetings there has been little if any discussion of the issues brought forth by the public. Why should the public testify if their concerns fall on deaf ears? Personally, I have brought up the issue of the possibility of a higher incidence of non-Hodgkins lymphoma as well as the high incidence of congenital defects in Twin Falls County over a year ago, and have had no reply to my concerns.

It was changed to a broad statement to include any health actions necessary and not just health education.
121 Page 56 Preparers of the Report: From the report that I have, I see no involvement by medical experts, especially those involved in oncology. I would strongly recommend that the report be reviewed by oncologist, hematologists, and other cancer specialists. Their comments should be attached as an addendum to the final report. The public health assessment has been reviewed by medical experts in and outside the agency. All external comments on the public comment release are included in this appendix.
122

Page I-2 Last paragraph: Statement: Note that this is a first step in the process of evaluating health outcome data. If a specific birth defect or several birth defects appear to be occurring more often than expected, ATSDR considers making a closer examination of the known causes or likely causes, depending on the magnitude of the rate ratio (observed: expected) and the statistical significance of the defect.

Comment: What would the values need to be in order to "trigger" a response from ATSDR? In my opinion, these threshold values should be pre-determined in order to initiate action, otherwise further studies can be put off indefinitely. Based on ATSDR's statement I-13 "For the cancer evaluation, ATSDR calculated 9500 CIs to determine statistical significance. A statistically significant result is one whose likelihood of having occur by chance is less than 5 percent."

In the attached tables in the report there are many results that are indicated as being statistically significant, yet the conclusion of the report is that there are no problems. That is not to say that ATSDR is derelict in their duties, it only suggests a high degree of denial about possible public health concerns.

Appendix I was removed.
123

Page I-9 Last paragraph
Statement: The line which states that the relatively small magnitude of most of the elevated OERs argue against a single causative physical or chemical agent.

Comment: The logic of this last paragraph escapes me. Who has restricted causes to a single agent? Why can there not be multiple agents and also synergistic reactions between multiple agents? Also the logic appears to suggest that those conditions with relatively small magnitude's of change, either negative or positive, cancel out those in which there is a consistent pattern of significantly higher OERs. Is that a statistically valid procedure to follow? Please have your statistician address this issue. Along this line refer to 1-17, where there is shown to be an increased incidence of acute lymphocytic leukemia in Barulock county. The paragraph then goes on to say "The incidence is significantly changed in the opposite direction in two counties for acute lymphocytic leukemia in males, and for breast cancer in females.

Appendix I was removed.
124

The report then goes on to say "the negative change overbalances the positive one, so the overall effect in the six counties is that the incidence of breast cancer is significantly lower in the six counties in the state of Idaho.

Comment: This seems to indicate that one county with an increased incidence of malignancy is compared to all of the other counties combined. In my opinion, two of the counties should not be included in the statistical analysis due to their low population densities. Clark County has a population of less than 1000, and Butte as a population of less than 3000. Jefferson County may be borderline with a population of about 19,000 people.

Appendix I was removed.
125 Choice of diseases to monitor: It is stated in the literature, that the lymphatic system (i.e. lymphocytes) is one of the most sensitive systems to ionizing radiation. For this reason, leukemias are especially important to monitor. In addition, non-Hodgkin's lymphoma should be included in this study. I have already submitted to the ASTDR a chart that shows that from the time of approximately 1979-1998, 6 of the 9 counties with significantly increased observed rates over the expected rates were in the INEEL area. Reference: Cancer Trend in Idaho, 19711998, September, 2000, page 76. Of the germ cell tumors, in this 19 year period, Bannock was the only county in Idaho with an increased incidence of testicular tumors and also of interest, it is also the county with the increased incidence of acute lymphocytic leukemia in males. Bingham was one of only four with an increased incidence of ovarian neoplasms. Leukemia was monitored, but Appendix I was removed.
126 Choice of counties to monitor: Because of the concern of the flow pattern of the Snake River Aquifer, I believe that Twin Falls, Jerome, and possibly Gooding County should also be included in the monitoring of malignancies and congenital defects. Twin Falls County has a very high rate of congenital defects. For the years 1990-1992, Twin Falls had an expected rate of 53, and an observed rate of98 cases. From 1993 to 1995, the expected rate was 45 cases and the observed was 86. For the years 1996 to 1998 the expected rate was 70 with the observed rate of 107. Again the question of a threshold level for an intensive investigation arises. The rate in Twin Falls is almost double, does it need to triple or quadruple before it rises to the level of concern for ATSDR or is it just a problem of bad statistics. Many of the abnormalities are statistically significant at the 95% level, how high must they go to become truly statistically significant? Counties were chosen based on proximity to the site.
127 The Assessment should clarify the assumptions for its major conclusion that there are no complete exposure pathways by which members of the public are, or have been, exposed to levels of contaminants sufficient to cause adverse health effects. We suggest: "As long as the federal government completes needed remediation and maintains appropriate institutional controls, the INEEL poses no apparent current or future public health hazard for the surrounding community from ground water, surface water runoff, soil, biota, or air." As stated throughout the document, there are no completed pathways above a level of concern. If the clean-up progresses and there is adequate stewardship, there should not be any adverse impact on public health.
128 On-Site Drinking Water, page 2: Only VOCs and tritium are listed as potential contaminants of concern that could have affected drinking water wells. Additional contaminants should be added such as I-129 and Sr-90. Both contaminants could have affected the drinking water wells given existing data. I-131 and Sr-90 were monitored, but were not found above comparison values at site boundaries.
129 Site Description and History, third paragraph, page 4 This paragraph describes ordnance testing that occurred during World War II but fails to mention testing that occurred during the Vietnam era from inside the southern boundary of the INEEL. This project involved proof testing gun barrels, (up to 16-inch diameter) from a site near the RWMC. Shells were fired into Big Southern Butte outside the INEEL boundary. No change.
130 Waste Area Groups at INEEL, Table 1, page 8: This table lists multiple Solid Waste Management Units (SWMUs) for INEEL Waste Area Groups (WAGs), such as 63 SWMUs for TAN, 49 SWMUs for TRA, etc. The use of the SWMU designation is no longer relevant under the 1991 Federal Facilities Agreement and Consent Order (FFA/CO). An Operable Unit (OU) within a WAG is the designation for a site that is investigated, evaluated for. No change. This is how the Annual Environmental Reports have organized their data.
131 Demographics, Table 2, page 11: This table uses data from the 1990 census but page 1 states the ATSDR "focused its review on data generated from 1987 to 2000". The review should update this table with data from the 2000 U.S. Census. Updated to 2000 Census.
132 Media-Specific Contamination, continuation of Table, page 15: The text should be expanded to more accurately portray "Uncertainty Measurements." Usually data from the INEEL are presented in the form of one standard deviation which gives one (1) confidence in 68 of 100 cases that the true level of radioactivity falls between the measured concentration plus the uncertainty value and the measured concentration minus the uncertainty value. In the past, the INEEL used two standard deviations (95 out of 100) as a criterion for determining whether the measured value was valid. The INEEL now uses three standard deviations as the criterion, which is 997 cases out of 1000. Added suggested text.
133 Ground water, first paragraph, page 15: Ground water velocities on site have a greater range than noted, ranging from about 0.5 ft/day around Test Area North (TAN) to greater than the 10 ft/day in the vicinity of the Idaho Nuclear Technology and Engineering Center (INTEC). These velocities are high compared to many other aquifers, and overall ground water velocities should not be characterized as being "slow." The text also states that "Some local ground water flow beneath INEEL is more complex and variable, because it is influenced by recharge from the Big Lost River, by percolation and sewage ponds, by areas of low aquifer transmissivity, and possibly pumping from the production wells." The production wells will have a greater effect on ground water flow than the "percolation and sewage ponds" because the source of the water is ground water and only a fraction of the water pumped returns to the aquifer. The statement should be rephrased to more accurately reflect hydraulic reality. Added suggested text.
134 ibid., second paragraph, second, fourth, and last sentences, page 16: ".. .that sit on relatively impermeable layers of sediment or clay (ESRF 2000)." It is commonly accepted that perched aquifers also can form on top of dense basalt flows, usually a flow interior (Ackerman, D.J., 1991). "The systems formed over time from water trickling down through the percolation ponds and the sewage treatment plant lagoons, precipitation, flooding events and particularly when the Big Lost River is dry (DOE 1999)." This statement makes no sense. A dry riverbed is not going to supply water to form a perched aquifer. "Perched water zones sometimes protect the SRPA from contamination hot spots." Perched zones may temporarily inhibit the downward migration of fluids in the vadose zone, but should not be considered protective of the SRPA. A perched water zone will eventually diminish if recharge stops, and the disappearance is also a result of the eventual vertical (downward) migration of the remaining fluids (and associated contamination) in the perched zone. The Big Lost River flows underground when the riverbed appears dry.
135 ibid., fifth paragraph, page 16: The paragraph states the wells are screened at different depths across the INEEL ranging from 200 to 900 feet below ground surface. This information tells the reader little without including the important point that the depths to the water table range from about 200 ft to over 900 ft below ground surface. This additional information should be included to provide the reader with relevant data pertaining to the thickness of the vadose zone. Clarified that depths to the water table range from about 200 ft to over 900 ft below ground surface.
136 ibid., third paragraph, page 18: The estimated amount of solvents disposed at the RWMC has increased seven fold from the original estimate provided in the Assessment. The updated VOC estimates are: 140,000 gallons Carbon Tetrachloride, 16,000 gallons TCE, 16,000 gallons TCA, and 16,000 gallons PCE. (Miller and Varvel, 2001). ATSDR can not identify this reference.
137 ibid., boxed paragraph, What are VOCs?, last sentence, page 18: The majority of the VOCs under investigation and/or remediation originated from injection well disposal at TAN (TCE used as a cleaning and degreasing solvent) and burial at the subsurface disposal area (SDA) at the RWMC (predominantly carbon tetrachloride (CCI4) from the DOE Rocky Flats Plant in Colorado, contained in lathe cutting oil). Added carbon-tetrachloride.
138 ibid., fifth paragraph, page 18: There are no wells completed through Pit 9. Text regarding VOC concentrations below the pit needs to be reworded so it does not imply wells were drilled through disposed waste. ATSDR can not identify a reference to support this statement.
139 ibid., first paragraph, page 19: Per the meeting minutes of the November 6-7, 2002, INEEL Health Effects Subcommittee meeting, ATSDR indicated it would incorporate data through 2001 in the revised INEEL PHA, but did not do so. The final version should use the latest data, at least through 2001. No change. The 2001 Environmental reports only include data through the year 2000.
140 ibid., first paragraph, last sentence, page 19: The sentence should read "Ongoing efforts continue to remove and treat VOCs extracted from the vadose zone." Changed to suggested text.
141 ibid., second paragraph, page 19: A major facility and historical component of TAN that is omitted is the Loss of Fluid Testing (LOFT) facility. Added "Loss of Fluid Testing (LOFT) facility"
142 ibid., third paragraph, page 19: The PHA is misleading when it says "TCE and PCE were measured at levels up to 32,000 and 110 ppb, respectively, above their ATSDR CVs of 5 ppb for each. During more recent monitoring in 1998, levels of these VOCs have decreased to below 5 ppb (ESRF 1998)." Concentrations in wells in the hotspot (>20,000 ppb) and in the medial zone (1,000 to 20,000 ppb) are declining but still exceed the MCL (US DOE, November 2000). TCE concentrations in TAN-25 were less than 10 ppb in June, July, and August of 2000 but cis-1 ,2,2-DCE ranged from 22.7 to 69.5 ppb and trans-1,2-DCE range from 398.8 to 490.5 ppb for the same time period (US DOE, September 2001). TAN-25 is within the active in-situ bioremediation zone directly influenced by the injection of sodium lactate. TCE concentrations in TAN-28, located in the medial zone, range from 579.4 to 768.3 ppb for the same time period. Concentrations in the distal zone (5 to 1,000 ppb) exceed the MCL and have changed little since inception of the remedial action. TCE concentrations in TAN-52, located in the distal part of the plume, range from 46.22 to 55.3 ppb in June and August of 2000 (DOE September 2001). Deleted sentence: "During more recent monitoring in 1998, levels of these VOCs have decreased to below 5 ppb (ESRF 1998)."
143 The acronym CV is used several times in the document, but is not included on the abbreviation list. CV means Comparison Value.
144 ibid., fourth paragraph, second sentence, page 19: The PHA states "Sludge had been removed in 1990, but not before TCE had settled to form pools of dense non-aqueous phase liquid (DNAPL) below the SRPA." We are not aware of any evidence that TCE is present in a liquid phase and certainly not in "pools" as stated. Nor have DOE, EPA, or DEQ agreed that pools of TCE exist in or beneath the SRPA. It is estimated that up to 35,000 gallons of TCE were disposed in the injection well along with other wastes (DOE, November 2000). No change.
145 ibid., fourth paragraph, seventh and last sentences, page 19: ATSDR should not consider the treatment plant to have "been used to provide hydraulic containment of the contaminants"; rather it is part of the remedial action system. The stimulated bacteria are not located in the remaining injection well sludge but rather in the fractured basalt matrix, which is being augmented by the addition of sodium lactate. The true remedial action is occurring in the aquifer around the injection well. No change.
146 ibid., second paragraph, second and third sentences, page 20: Fine-grained sediments (clay) can cause perched aquifers, but the conclusion that this layer "ultimately prevents water from passing through" is not correct. Even clay has a finite permeability that allows the passage of contaminants. The presence of contamination in the SRPA refutes the conclusion drawn in this paragraph. Changed from "prevents" to "impedes".
147 ibid., fourth sentence, page 20: This sentence should be rewritten to say "Note that perched water aquifers may not be large enough or permeable enough to be used as a major source of drinking water, but may still be tapped locally (a few households) for a drinking water source, and can still contain contaminants that may represent a future threat to the SRPA." Changed to suggested text.
148 ibid., fourth paragraph, third sentence, page 20: The following statement is incorrect: "At INEEL, water is drawn from multiple drinking water wells, mixed, and fed into a system of pipes that leads to water taps. Water from each of the drinking water wells is diluted by water from the other wells." Many miles of desert separate the facilities at the INEEL and each facility is self-contained with respect to water supply and wastewater disposal. The only dilution that can occur is where the facility has multiple drinking water wells such as the Central Facilities Area (2 wells) and Test Area North (2 wells). Facilities such as the Radioactive Waste Management Complex and the Main Gate have a single production well and dilution is not feasible. Changed to reflect facility systems only.
149 ibid., third paragraph, page 21: See preceding comment. Changed to reflect facility systems only.
150 Continuing paragraph, third and last sentences, page 22: Third sentence: "If any contaminants traveled with groundwater off site, they would travel south-southwest from INEEL, toward Minidoka. ..." This theory on the direction of groundwater flow in the Eastern Snake River Plain Aquifer is counter to the many published reports on the aquifer and current understanding of flow directions. For example, S.P. Garabedian (1992) clearly presents data and interpretations of the data that do not support this theory. Last sentence: "at which point [referring to Minidoka] its contaminants would be present at less than 0.02% of their original concentration, and not at levels sufficient to make people sick." Even if the flow direction stated by this assessment were correct, it ignores potential risk to rural residents that lie along the flow path from the INEEL to Minidoka. The report should consider not only public water supplies but also present and future domestic supplies in determining public health impacts. Disagree, no change.
151 ibid., fourth paragraph, page 25: This paragraph incorrectly states that ground water flows toward "south-southwest from INEEL toward Minidoka, located 73 miles away." Please note previous comments submitted in August 2002, directing the authors of this report to the correct flow direction. Disagree, no change.
152 Surface Waters, first paragraph, fifth sentence, page 26: The Big Lost River should be added to the sentence along with the Little Lost River and Birch Creek as it is also used for irrigation. They are already mentioned in the first sentence of the second paragraph.
153 ibid., sixth sentence: The sentence should be edited to say: "However, when there is a very high snow pack, rapid snowmelt, or heavy rainfall, water from these rivers may enter the INEEL and recharge the ESPRA." The phrase "ground water aquifer" is redundant; the ESRPA (Eastern Snake River Plain Aquifer) should be used throughout the document to note the aquifer. Unable to find referenced text.
154 ibid., fourth paragraph, first sentence, page 26: As noted previously, the general direction of ground water flow is toward the Snake River between Twin Falls and King Hill and not toward Minidoka as portrayed in this report. See response to comment #42.
155 Soils, second paragraph, second sentence, page 27: Besides 2,4,6:-trinitrotoluene (TNT), RDX and HMX are also present. These compounds are commonly found at the explosives testing areas such as the Naval Ordnance Disposal Area, the Railcar Explosion Area, etc. (U.S. DOE, August 2002). Other compounds were not above comparison values.
156 fifth paragraph, second sentence, page 27: "Because INEEL is in the middle of the Arco Desert, ATSDR derived screening estimates of doses for the sparsely vegetated pasture use scenario. This scenario is the most appropriate for INEEL's potential future unrestricted use. Moreover, this scenario provides more conservative values than do industrial or residential-use scenarios." ATSDR should explain how this scenario can be more conservative than the CERCLA risk assessment future residential scenario routinely used for the INEEL. Remove statement about more conservative values.
158 What is background radiation?, box in lower right corner, page 27: ..."from the natural decay of' is incomplete. Corrected printer error. Should read:.."from the natural decay of radon."
159 third paragraph, page 29: This paragraph requires more specificity and/or references. General terms such as "contamination" (what contaminant?), "INEEL boundary" (which part of the boundary?), and "INEEL's greatest release" (no information presented) do not inform the reader. The comprehensiveness of off-site soil sampling is debatable, and indeed CERCLA concerns in regards to soil contamination revolve around contamination originating at INEEL facilities, and future exposure to workers or potential future residents in or near these sites. Unable to find referenced text.
160 Air, fifth paragraph, page 30: The information cites several concentrations for volatile organic compounds such as "4,520 milligrams per cubic meter (mg/m3) of toluene to 20,800,000 mg/m3 of carbon tetrachloride." These values appear to be consistent with subsurface vapor concentrations and not surface air concentrations. Please check sources through 2001. Added: "but these were actually measurements of subsurface vapor concentration and not ambient air."
161 ibid., sixth paragraph, first sentence: "decreased" should be "decrease". Changed as suggested.
162 Biota/Food chain, first and third paragraphs, page 33: The term "biota" is inconsistently used in this section. Biota should refer to both flora and fauna, as in the discussion in the third paragraph. The discussion in the first paragraph appears to use the term to differentiate between sagebrush (vegetation), and rabbits, mice, and insects (biota). Changed "biota" to "animals".
163 Table 5, Exposure Pathways Evaluation Table, pages 38-41: The "future worker" and "future residential" scenarios should be included in these tables to clearly address what CERCLA investigates and remediates as necessary. The tables should clarify where ATSDR's conclusions depend on completion of remediation and/or maintenance of institutional controls. See comment #2. Those scenarios do not enter into ATSDR's pathway analysis.
164 Consumption of Volatile Organic Compounds in Drinking Water at INEEL in the Past, first paragraph, page 45: "In the past, TCE and carbon tetrachloride (both volatile organic compounds, or VOCs) in some INEEL production wells (RWMC #1, TSF #1, and TSF #2) exceeded ATSDR CVs and EPA MCLs for drinking water in the past. The production wells fed into a distribution system in which the water from each production well was diluted by the water from other production wells." This conclusion is incorrect. Please see comment # 22. Corrected to make clear that each area on site had its own water distribution system.
165 ibid., fifth paragraph, page 46: Agree with the use of the previous slope factor for TCE, even though EPA has withdrawn it for review. Disagrees, however, that information linking TCE in drinking water to human cancers IS controversial, inconclusive or inadequate. The EPA draft health risk assessment for TCE proposes slope factors greater than the previous slope factor. The available evidence, taken from both animal and epidemiological studies, indicates that TCE is somewhat more carcinogenic than previously recognized. The TCE risk assessment has undergone external peer review, but has not yet completed IRIS consensus review. The assessment received an overall favorable review by EPA's Science Advisory Board. The proposed toxicity values have a strong scientific basis reflective of the current science on TCE; another strength is that they address cumulative risk particularly in the discussion of TCE metabolites. Unable to locate referenced text.
166 Status of Cleanup Measures at Pit 9, third paragraph, page 50: If ATSDR is quoting information as current as mid 2002, it should in its next revision, update this report with the latest information available which DOE can supply. EPA, DOE and DEQ went forward with a new design, completed construction, and anticipate waste excavation starting in November of this year. At this date, the Pit 9 has not been excavated, and ATSDR stands by the conclusions of its previous consultation.
167 ibid., top partial paragraph, last sentence, page 51: Given many changes concerning Pit 9 and remediation of the SDA as a whole, we recommend this sentence be deleted. Disagree, no change.
168 Potential Health Threats Posed by Contaminated Water Supply Wells, second paragraph, page 52: It would be helpful to present which contaminants would have their concentrations diluted, and what their initial and diluted concentrations would be. A concentration reduced to 0.02% of its initial value does not have much meaning when the initial value is not presented. No change.
169 Exposure to Plutonium that is Being Reburied Over the Snake River Plain Aquifer at INEEL, page 52: This paragraph needs clarification. Colloidal transport is thought to be a possible method of plutonium migration from Pit 9 and the rest of the SDA, but has not yet been quantified. ATSDR should provide support for its statement that plutonium is still not a health threat because "it is not in a bio-available form." The paragraph implies ongoing excavation and reburial of plutonium contaminated material, which is not the case. ATSDR should use current information for planned retrieval of plutonium-contaminated material (and other transuranics). The INEEL CERCLA Disposal Facility (ICDF) may accept soil or debris contaminated with transuranics below 10 nanocuries per gram only from designated CERCLA WAGs. It is configured to monitor for leakage of contaminants into the underlying strata via perched water wells and ESRPA wells. The ICDF is near INTEC and should open later this calendar year. The Subsurface Disposal Area, from which plutonium-contaminated waste will be retrieved in the future, does not have a leakage detection system but is monitored via Iysimeters, perched water and ESRPA wells. No change.
170 Conclusions. First paragraph, and conclusion 1, page 54: As noted in comment #2, ATSDR should state that its conclusions depend on the completion of remediation and maintenance of appropriate institutional controls. No change.
171 ibid., Conclusion 2., second sentence, page 54: As discussed on Pages 24 and 25, at least three site-related contaminants, tritium, iodine-129 and chlorine-36 have been detected in groundwater outside the southern INEEL boundary. ATSDR should clarify that these contaminants have migrated off-site, but not at levels posing a current risk. No change.

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