PUBLIC HEALTH ASSESSMENT
PADUCAH GASEOUS DIFFUSION PLANT (U.S. DOE)
PADUCAH, MCCRACKEN COUNTY, KENTUCKY
In this appendix air dispersion modeling and measured emissions are used to evaluate the off-siteconcentrations and potential health effects of airborne metal particulates emitted from secondarymetal smelting operations in the C-746A facility at the Paducah Gaseous Diffusion Plant (PGDP).Between 1952 and 1986, PGDP operated several smelters to recycle scrap metals. These metalsincluded steel, nickel, aluminum, copper, monel (a copper-nickel alloy), cobalt, gold, and silver .Of these metals, only nickel and aluminum were smelted in large quantities (more than 11 millionpounds of aluminum and about 37 million pounds of nickel) [1,2]. Because nickel is more toxicthan aluminum, this evaluation initially focuses on nickel emissions and potential exposures. Giventhat the dispersion and transport of the other recycled metals is basically the same as for nickel, theconcentrations of the recycled metals will be evaluated relative to the toxicity and estimatedconcentrations of nickel (airborne uranium emissions have been previously evaluated in this PublicHealth Assessment).
Nickel has a relatively high melting temperature (1455oC) such that it is very unlikely to occur ingaseous (vapor) form at normal atmospheric temperatures . Nickel (and other smelted metals) ismost likely to have been released from the smelter stack in a solid or particulate form. The PGDPpermit application states that nickel particulate emissions occurred as nickel oxides .
Approximately 17 million pounds of non-radiologically contaminated nickel were smelted from1977 to 1982. From late 1983 to 1986, an additional 20 million pounds of radiologicallycontaminated nickel were smelted. No off-site nickel air concentration data were collected by PGDPor by the Kentucky Department of Environmental Protection . Potential off-site exposures tonickel particulates released from the smelting operation are estimated using the Breeze Version ofthe US Environmental Protection Agency (EPA) Industrial Source Complex (ISC) air dispersionmodel . This model uses meteorological data from the Paducah-Barkley Airport (1989-91), andparticulate emission and source data from the PGDP air discharge permit application .
The smelter emission rate (nickel particulates) used in the air dispersion model is based on measuredemission rates described in the air discharge permit application . Three trial runs provide anaverage emission rate of 160 g/hr (0.044 g/sec) based on an average smelter charging load of 1520kg/hr (3350 lbs/hr). Modeled emission rates were rounded up to 0.05 g/sec. The 20 million poundsof nickel smelted from late 1983 to 1986 is equal to an average of ~6.7 million pounds/year. This 3-year time frame represents the period of highest annual nickel output and will be used to evaluatepotential air concentrations.
Although the specific operating schedule of the smelter is not known, an average annual productionof 6.7 million lbs/yr divided by the loading rate of 3350 lbs/hr equates to an operating schedule of 8hrs/day for ~250 days/yr. Variation in the operating schedule, such as 16 hrs/day for 125 days/yr,will not change the instantaneous emission rate nor significantly change the annual dispersedconcentrations. Some variation in short term concentrations may occur as a result of specific weatherconditions during smelter operation. However, multiple model runs were conducted usingmeteorological data from three years (1989, 1990, and 1991) to ensure that the range of weatherconditions were evaluated for both short term (one and eight hour maximum averages) and longterm (annual average) concentrations. Meteorological data from the 1984 to 1986 years are notavailable on the EPA website .
In addition to emissions from the PGDP smelters, nickel and other metal particulates were (and arestill) released from combustion of fossil fuels at the PGDP steam plant and the Tennessee ValleyAuthority (TVA) Shawnee facility. Instantaneous emission rates from the TVA facility are estimatedfrom annual releases submitted to the Environmental Protection Agency Toxic Release Inventory(TRI) . The 1999 TRI indicates that 159 pounds of nickel compounds were released to air, the1998 release amount was 137 pounds. In order to account for yearly variations, this evaluationestimates an annual release of 170 pounds which, distributed over the course of an entire year,equals an emission rate of 0.0025 g/sec (released from a 244 m stack).
Airborne emissions released from the PGDP steam plant occur from two 34 m stacks that are inclose proximity to the each other and are modeled as a single source. Nickel emissions from thePGDP steam plant are estimated from maximum monthly coal and fuel oil usage (3300 tons/monthcoal and 400,000 gallons/year for fuel oil)  and standard emission factors . The estimatedinstantaneous maximum nickel emission rate from the steam plant (0.00009 g/sec) is more than 500times lower than smelter emissions. However, the steam plant was assumed to operate 24 hours/day,7 days/week for an annual emission rate about 100 times lower than the smelter emission rate.
The nickel releases from all sources are predominantly in a nickel oxide form [3;10]. Particulatereleases from the smelter are predominately about 30 microns in diameter with small fractions in the10 and 20 micron diameter size ranges . Nickel particulates from the PGDP steam plant andTVA facilities are predominately less than 5 microns in diameter [3,10].
The distance of the C-746A smelter building to the closest residence is more than 1000 meters (0.6 miles). Estimated air concentrations 1000 m from the source are used to evaluate potential residential exposures. Results of the air dispersion modeling are compared with the ATSDR health-based, non-cancer, comparison value (0.2µg/m3 chronic inhalation EMEG/MRL) [3,11] to determine if estimated long term air concentrations are at levels of health concern for residents. Potential cancer effects are evaluated by multiplication of the EPA unit risk for nickel subsulfide(1) of 4.8E-4 per µg/m3  and the maximum off-site nickel concentration (and an exposure factor based on duration of exposure of nine years).
WKWMA workers may have been present in buffer areas from 500 to 1000 m from building C-746A. Concentrations at points 500 m from C-746A will be used to evaluate potential worker exposures. WKWMA worker exposures are evaluated using the National Institute of Occupational Safety and Health (NIOSH) Recommended Exposure Limit of 15µg/m3 for soluble or insoluble nickel (8 hour time weighted average(2) ) . Nickel soil concentrations are compared with estimated air concentrations to determine if estimated nickel dispersion and deposition are reflected in nearby soils.
Activities of radiological contaminants from nickel samples (Th 230, Th 232, U 235 and Tc 99) and stack emission monitoring (U234, U235, and U238)  are used to determine the quantity ofradionuclides released during nickel smelting. Calculated quantities and rates of radionuclideemissions from nickel smelting are about 10,000 times lower than airborne radionuclide emissionsfrom other PGDP process operations used in Appendix E. Consequently, radiological emissionsfrom the smelting operations did not constitute a significant radionuclide source and will not changepreviously estimated releases or exposures.
The estimated average annual concentrations of nickel particulates (based on 1984-1986 emission data and hourly weather data for 1990) are shown in Figure I-1. The highest estimated annual average nickel concentration of 0.18µg/m3 occurred approximately 200 m north of the C-746A building which reflects prevailing southerly winds. The maximum one hour average concentration is estimated to be 15µg/m3 and the maximum eight hour average is estimated to be 3.0µg/m3 with both maxima about 200 m north of the stack. Distribution of short term nickel concentrations, although higher to the north, are more uniformly distributed around the C-746A building and reflect short term weather conditions which may have winds from any direction. Model runs using hourly weather data(3) for the years 1989, 1990 and 1991 produced essentially identical results for both short term (hourly and daily) and long term (annual) nickel dispersion. All of the above maximum air concentrations occurred at areas within the DOE property.
The estimated nickel air concentrations at areas of potential off-site exposure (Table I-1) includeseveral notable trends. First, short term concentrations are much higher than long termconcentrations. This trend reflects how short term meteorological conditions control transport andhow averaging time affects concentration. One hour maxima are significantly greater than eight hourmaxima and much greater than annual average concentrations. Second, overall concentrations dropvery rapidly with distance away from the stack. At 1000 m, which is the distance to the closestresidence, all concentrations are about an order of magnitude lower than concentrations at 500 m.Third, the similarity between concentrations and distributions for different weather years indicatesthese data adequately capture the range of potential meteorological conditions.
The dispersion modeling indicates that most nickel deposition will occur within 500 m of the smelterbuilding. Measured soil nickel concentrations support the model results. Average soil concentrationsat locations within the security fence average 25 ppm. Areas within the buffer zone and off-site areashave statistically similar averages of ~12 ppm. These results indicate that onsite soils have elevatednickel concentrations relative to off-site areas but that there is no significant difference betweenbuffer area and off-site concentrations. Local nickel air concentrations and deposition to soil fromthe TVA plant may have been higher prior to the increase in stack height in the early 1970's .
The highest average annual nickel concentration at 1000 m from the smelter building is 0.004 µg/m3 which is about 50 times lower than the ATSDR comparison value of 0.2 µg/m3. Estimated long term exposures at 1000 m also represent no potential cancer risk(4). Similarly, the maximum short term nickel concentration of 1.1 µg/m3 (at 500 m from source; maximum one hour average) is more than 10 times lower than the worker exposure limit of 15 µg/m3 (which includes consideration of potential occupational cancer risk). The estimated maximum hourly, daily, and annual nickel air concentrations from PGDP smelter operations, with potential contributions from the PGDP steam plant and TVA facility, are below levels of health concern.
These estimated off-site nickel concentrations in air include potential contributions from the PGDPnickel smelter emissions, the PGDP steam plant nickel emissions, and the TVA Shawnee coal plantnickel emissions. Modeled emission rates from the PGDP steam plant were based on healthprotective assumptions concerning fuel usage, operating schedules, and emission factors. Actualemission rates are probably lower than modeled rates. All estimated nickel air concentrations,calculated using health protective model assumptions, in areas of potential off-site exposure aremore than 10 times lower than relevant health comparison values.
|500 m||1000 m||1500 m|
|1989 Annual Average||0.018||0.003||0.001|
|1990 Annual Average||0.022||0.004||0.002|
|1991 Annual Average||0.018||0.003||0.001|
|1989 1 hour maximum||1.0||0.12||0.05|
|1990 1 hour maximum||1.0||0.15||0.07|
|1991 1 hour maximum||1.1||0.17||0.06|
|1989 8 hour maximum||0.25||0.05||0.02|
|1990 8 hour maximum||0.23||0.05||0.02|
|1991 8 hour maximum||0.25||0.05||0.02|
Table I-2 lists the metals smelted at PGDP along with the estimated total amount of each metal andthe relevant inhalation health comparison values for each metal. The health comparison values forresidential and occupational exposure are a measure of the toxicity of each metal. The most toxicmetals have the lowest health comparison values because it takes a lower amount of the substance tocause sickness or adverse health effects. This evaluation focuses on nickel because it is relativelytoxic and very large quantities of the metal were smelted resulting in the highest potential off-site airconcentrations.
As the smelting of other metals will release particulates in proportion to the total amount of materialsmelted and the dispersion of those metals will follow the same dispersion patterns as nickel, itfollows that the off-site concentrations of other metal particulates will be proportional to the amountof metal smelted. Based on the relative toxicities of the various metals and the amounts of eachmetal smelted, off-site concentrations of all metals smelted at PGDP are below levels of healthconcern.
ATSDR considered interactive effects (cumulative, additive, synergistic, and antagonistic) ofsubstances following exposure to multiple substances to the extent of scientific knowledge in thisarea.
- Cumulative effects (the effects associated with concurrent exposure by all relevant pathwaysand routes of exposure to a group of substances that share a common mechanism of toxicity) were addressed on pages 91 and 92 and in Table 24 of the PHA.
- Additive effects (the combined effects of two substances is equal to the sum of the effects ofeach agent given alone) were considered for exposure to radioactive materials on pages 117through 119 in the PHA. Of the metals evaluated in this appendix only nickel and monel areconsidered to have additive effects (because monel is a nickel alloy). However, the amountof monel smelted and emitted is insignificant with regard to the amount of nickel smelted.
- Existing information is inconclusive with regard to potential synergistic effects (when thecombined effect of two substances is much greater than the sum of the effect of each agent given alone) for the metals evaluated in this appendix.
- Antagonistic effects (when a substance reduces the toxicity or uptake of another substance)were not considered in this appendix in order to maintain a health-protective screeningscenario even though concurrent exposures to magnesium or zinc reduce the toxicity ofnickel.
ATSDR has reviewed the scientific literature surrounding chemical interactions and noted that if theestimated exposure doses for individual contaminants detected at the site are below doses shown tocause adverse effects (No Observed Adverse Effect Level; NOAEL), then ATSDR considers that thecombined effect of multiple chemicals is not expected to result in adverse health effects. It should benoted that typical environmental exposure doses to both carcinogenic and non-carcinogenicchemicals are more than 1,000 times lower than laboratory-induced effect threshold doses. Thisapproach to chemical interactions is based on the results of numerous studies:
- Several animal and human studies [15,16,17,18] have reported thresholds for interactions. Studies have shown that exposure to a mixture of chemicals is unlikely to produce adversehealth effects as long as components of that mixture are detected at levels below the NOAEL for individual compounds [19,20].
- The absence of interactions at doses 10-fold or more below effect thresholds have beendemonstrated [21,22]. Specifically, in two separate subacute toxicity studies in rats [23,24], adverse effects disappeared altogether as the dose was decreased to below the threshold level.
- For carcinogens, the interactions are more difficult to quantify due to the large study size(humans or animals) needed for statistical significance at the low doses observed inenvironmental exposures . In an animal study, Takayama et al. (1989) reported that 40substances tested in combination at 1/50 of their cancer effect level (CEL) resulted in anincrease in cancer . However, Hasegawa et al. (1994) reported no increase in cancerwhen dosing animals at 1/100 of the CEL for 10 compounds .
Estimated maximum hourly and annual nickel concentrations in areas of potential off-site exposuredo not exceed health-based cancer and non-cancer comparison values for either acute or chronicexposures (WKWMA workers and residents; respectively). As the toxicity of other smelted metals islower than nickel and/or the quantity of metals smelted is much lower, estimated airborneconcentrations of the particulates of the other metals are also below levels of public health concern.Past emissions of metal particulates from PGDP smelter operations in building C-746A posed "noapparent health hazard", which means that people may have been exposed to metal particulates butthat such exposure is not expected to cause any adverse health effects.
|Metal||Estimated Amount of Metal Smelted at PGDP (pounds) 1||Health Comparison Value |
|Aluminum||> 11,500,000 pounds over more than 21 years 2||8 hr TWA3- 5000 µg/m3|
|Cobalt||71,500 pounds over 4 years||14-365 day MRL4- 0.03 µg/m3 |
8 hr TWA- 50 µg/m3
|Gold||~5284 pounds over 21 years||Not Available|
|Lead||>1,258,990 pounds (no dates)||8 hr TWA- 50 µg/m3|
|Monel (copper-nickel alloy)||882,440 pounds over 4 years||see Nickel|
|Nickel||~37,000,000 pounds over |
6 ˝ years
|>365 day MRL- 0.2 µg/m3 |
8 hr TWA- 15 µg/m3
|Silver||~9,630 pounds over 8 years||8 hr TWA- 10 µg/m3|
|Steel||22,000 pounds (process terminated after test runs)||8 hr TWA- 5000 µg/m3 (as iron oxide dust/fumes)|
|1 Estimates of total amount of metals smelted are derived from DOE [1,2]. |
2 Internal DOE (or AEC) memos and letters indicate, but do not prove, that aluminum smelting at PGDP began in the 1950's, but that in early years was limited to laboratory and bench testing of methods and processes that were instituted in production scale operations in the 1960's.
3 TWA- is the 8 hour time weighted average occupational exposure limit established by the National Institute of Occupational Safety and Health .
4 MRL- is the minimal risk level for residential exposures established by ATSDR.
Comments and Responses to the Public Release Version of the Health Consultation(November 6, 2001)
The following comments were received by ATSDR in response to the public release version of thehealth consultation dated November 6, 2001, which has been included in the public healthassessment as this Appendix I. These comments elicited several modifications of the originalevaluation. Potential 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 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, 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 (see Table E-1 inAppendix E for uranium values evaluated for specific release years). For example, thepreviously evaluated 1956 annual releases included 1.6 Ci/yr for U234, 0.08 Ci/yr forU235, and 3.5 Ci/yr for U238.
As the much higher 1956 releases did not result in off-site exposures of public healthconcern, the measured 1985 emissions from uranium metal production in C-340 are belowlevels of public health concern. We will make appropriate revisions in the Public HealthAssessment document to ensure that potential releases from C-340 uranium operations areexplicitly referenced even though such emissions do not constitute a significant source.
ATSDR Response: The Commentor is correct in indicating that the entire smelting processincluded several operations in addition to the smelting furnace. Scrap nickel was subjected tophysical grinding in order to produce a small, uniform feed material. According to airpermit documents and personal communications  this process occurred in enclosedcontainers and emissions were subject to filtration before release to the atmosphere. Aftergrinding, the nickel chips were processed through the calciner to remove hydrogen fluoride(HF). This process was designed to remove gaseous HF and did not release particulatematerials. Although both of these processes may contribute to contamination of the on-siteprocessing facilities, only the smelting furnace emissions served as a significant source ofnickel particulates for off-site dispersion.
ATSDR Response: We will review the document to ensure that all conclusion statementsexplicitly indicate that the results are referenced as modeled (or estimated) airconcentrations. In the absence of directly measured air concentrations, modeled datarepresent the best available information. It is also important to point out that thisconsultation does use measured stack concentrations as the basis for determining the sourceor emission concentrations which is the source term for the dispersion modeling. We haveevaluated extensive amounts of air monitoring data. However, the available data do notinclude ambient nickel analyses. Even if such data did exist, it is very unlikely that themonitor locations would have been appropriately located so as to assess the spatiallyrestricted areas affected by emissions from the nickel smelter. As our modeled ambient airconcentrations are based on measured stack concentrations and are consistent with measuredsoil concentrations, we are confident that the results of the evaluation are protective of publichealth.
ATSDR Response: According to the information available , stack concentrations weremeasured for three separate trial runs of the batch smelter using an average of 96% of themaximum charging capacity. The average annual smelter output was ~72% of the annualmaximum charging capacity. Therefore, the trial runs were conducted using conservativeestimates of operating capacity. ATSDR used an estimated instantaneous nickel emissionvalue that was 13% greater than the measured average trial run value. Overall, theseemission and production values indicate that ATSDR employed health protective estimatesof annual production and instantaneous emission rates in estimating airborne nickelconcentrations to off-site areas.
The odd thing about some of the slag was it's tendency to roll onto the surface of themelt in the form of golf ball sized spheres which were sometimes kept as souvenirs onworker's desk. A more accurate estimation of releases could be made by having thesespheres tested (they are still around, no pun intended) or better still performing amass balance (drums of flakes were weighed and sampled before and ingots weretested after they were cast so total material lost could be estimated). [redacted name]in the C-710 building closely studied distribution of materials within the meltingprocess and his documents detail his findings (a search of the database using his nameas the author should kick out some good information, e.g. K/TL 338-339-443 andK/PS230). If nothing is easily available I could provide some of the analytical resultfrom the testing done.
ATSDR Response: The Commentor is correct that radionuclide concentrations in the nickelbuttons underestimate the total radionuclide concentration of the feed material due tosegregation in the slag and nickel ingots. However, as stated in the above response to item 1,radionuclide stack emissions were also directly measured. Annual emissions from the C-746A stack are reported for the calender year 1985 . As these values are all at least fiveorders of magnitude lower than the emissions from other previously evaluated sources forearlier years (1956-59), they do not comprise a significant additional source of radionuclideemissions (see Table E-1 in Apendix E for uranium values evaluated for specific releaseyears).
ATSDR Response: The section containing the cited paragraph is entitled "Evaluation ofModeled Concentrations of Airborne Metals Particulates." While this clearly indicates thatthe data in question are model results, we will add the term "modeled" or "estimated" to thecited sentences. The comment is not correct in stating that "better data" are available whichshould be demanded from DOE. As historic off-site airborne nickel concentrations were notcollected for the express purpose of quantifying potential off-site exposures, any additionaldata will be subject to inherent uncertainty which limits its utility for exposure assessment.The best response to such uncertainty is to seek consistency from different types of data.Because our modeled off-site concentrations are based on measured stack concentrations andare consistent with measured soil concentrations, we are confident that the results of theevaluation are protective of public health.
ATSDR Response: The suggested revision has been incorporated into the healthconsultation. It is important to note the distinction between emissions from primary andsecondary (such as PGDP) nickel smelting operations. More than 90% of emissions fromsecondary smelters are in an oxide form . Refinery dust (primarily nickel subsulfide) ismore typically produced during primary nickel smelting operations (i.e., during theproduction of nickel metal from nickel ore). Nickel operations at PGDP may have producedlimited quantities of the non-oxide forms. However, from a quantitative perspective, mostPGDP emissions were in an oxide form.
ATSDR Response: Information supporting and clarifying this statement has been added tothe consultation. The toxicity of all of the metals smelted was assessed using healthcomparison values and quantities of smelted metals. These comparison values are stated interms of a dose or contaminant mass per unit body weight per unit time (mg/kg/day). Themore toxic metals have lower comparison values, i.e., it takes less of the metal to causeillness. As nickel was by far the most toxic metal that was smelted in quantity, it was used asa benchmark for assessing levels of significant exposure. Cobalt was the only smelted metalwith a higher toxicity than nickel. Based on ATSDR and EPA health comparison values,cobalt is approximately 10 times more toxic than nickel. However, only about 38,000pounds of cobalt were smelted which is about 1700 times lower than the 6.7 million poundsof annual nickel production. Because smelting operations of relatively toxic nickel did notproduce off-site concentrations at levels of health concern, smelting of much smallerquantities of other toxic metals will also be below levels of health concern.
ATSDR Response: ATSDR considered cumulative, additive, synergistic, and antagonisticeffects of exposure to the extent of scientific knowledge in this area. Information andreferences related to ATSDR's process of evaluation have been added to the consultation.
ATSDR Response: See above for response to assessing interactive effects to differentcontaminants. The PGDP Public Health Assessment does assess potential cumulative dosesand health effects to community members that may be exposed to contaminants throughmultiple pathways. Potential exposure doses to nickel (and other metals) were estimatedfrom ground water, surface water, soil, and food items. None of these other pathwaysresulted in nickel exposure doses of public health concern. It is also important to note thathow the nickel is taken into your body affects the toxicity. Inhaled nickel, via airborneparticulates, is much more toxic than the same amount of nickel ingested with food or water.Also, nickel particles larger than 5 microns are not considered respirable  and are routedthrough the gastro-intestinal system rather than the lungs. As the estimated inhaled nickeldose is below a level of public health concern, adding a minor amount of less toxic ingestednickel will not significantly increase the total estimated nickel dose.
I thank you for the opportunity to comment on the Health Consultation, "Exposure Assessment of Airborne Nickel and other Metal Particulates from Historic Smelter Operations at the Paducah Gaseous Diffusion Plant" (Public Comment Release- November 6, 2001). I am pleased that the investigation found no cause for public concern. I have the following comments on the report.
It would be helpful to have a statement of no public concern near the beginning of the report. I suggest adding to the first paragraph- "Concentrations of concern were not found and no recommendations are warranted."
The rationale for not including metal particulates from the TVA Shawnee Steam Plant is not clear. While the emissions of the steam plant and smelter stacks will not be additive during any short period, the annual average concentrations would be additive. The lack of any significant contribution from the steam plant may be deduced from the results of the soil sampling. The 12 ppm nickel found in off-site soils probably represents deposition from steam plant effluents during its nearly 50 years of operation, during many of which the stack heights were only about 60 meters. The significantly higher soil concentrations on the PGDP site is evidence that the contribution, however small, of the nickel smelter to airborne concentrations was significantly higher than that from the steam plant and that from the steam plant may be ignored.
ATSDR Response: A summary has been added to the revised document (to the healthconsultation; not in this appendix). We have also reconfigured the ISC air dispersion modelto include potential contributions from both PGDP steam plant and the TVA facility. Basedon 1998 and 1999 Toxic Release Inventory data for the TVA facility , the instantaneousnickel air emissions average ~0.0025 g/sec. Assuming that those later years are similar tothe years of PGDP nickel smelter emissions, the instantaneous TVA release is about 20times lower than the PGDP smelter release (0.05 g/sec) and is dispersed from an 800+ footstack. Similarly, using standard emission factors for coal and oil combustion and annual fuelusage rates, instantaneous nickel emissions from the PGDP steam plant averaged 0.00009g/sec, which is 500 times lower than the smelter emissions (dispersed from two adjacent 110foot stacks). The results of the revised air dispersion models indicate no differences in theshort term or annual distributions of nickel. All estimated concentrations are still well below levels of health concern.
- Kentucky Environmental Oversight: List of Hazardous Waste and RadionuclideParameters Currently Analyzed and Monitored by the Commonwealth of Kentuckyat the Paducah Gaseous Diffusion Plant (Name Redacted) includes nickel, nickelcompounds, nickel carbonyl, and nickel cyanide. What PGDP operation(s) producesthis waste stream? Did this Health Consultation and/or the Public Health Assessmentfor PGDP include this source of nickel? Is this nickel monitored in air, soil, or water?
- Phase II Independent Investigation of the Paducah Gaseous DiffusionPlant...February 2000, section 3.2.5 smelting, refers to scrap metal recovery recordsbeing "...removed by another DOE team investigating scrap metal recovery at theplant." Has ATSDR reviewed those records? Additionally, the same section of PhaseII refers to "a 1972 study of radionuclides in scrap..."; did ATSDR review that study?Further, a chart on page 74 of Phase II indicates smelting activities at C-746 (A),PGDP, from the 1950's to 1990. This Health Consultation only considers nickelsmelting from 1977 to 1986; was nickel smelted at PGDP at any other time? Thus,was the 37 million pounds smelted during that period the total amount of nickel eversmelted at PGDP?
- ATSDR, 2001 Public Health Assessment for the Paducah Gaseous Diffusion Plant(USDOE), May 14, 2001. (see page 38) When determining the contaminants ofconcern for the May 14, 2001 health assessment did the ATSDR review the historicalreleases from the nickel smelting and lead "recycling" operations at PGDP? (see page57-Table 11) What chemical form of nickel is considered here? (see page 68-Table15A) When the ATSDR determined off-site soil concentrations of nickel did notexceed health guidelines were they able to determine the source of that nickelcontamination? What was the source? (see page 17-Table 2) Nickel was detected in 42of 110 off-site groundwater samples. What was the source of this nickel? (see page 19)"...nickel (was) only detected downwind of the PGDP smelter and mainly up-wind ofthe TVA plant. What was the source of that nickel? (see page 65-Table 14A) Whenthe ATSDR estimated nickel posed no health problem to workers and visitors of theWKWMA did they consider the concentration of nickel in ash spread on the roadsthroughout the refuge and how nickel laden dust rises from roads when vehiclestravel them? (see page 74-Table 17A) What was the source of the nickelcontaminating the deer liver and muscle? (see page 146 #3) "...you can always ask forit to be explained in the form that is easiest for you to understand." (Thus) From1977 to 1982 how many pounds of non-radiologically contaminated nickel wasreleased from the PGDP nickel smelter stack? From 1983 to 1986 how many poundsof radiologically contaminated nickel was released from the PGDP nickel smelterstack? At the time ATSDR prepared the May 2001 Health Assessment were theyaware nickel smelting and lead "recycling" operations were conducted at PGDP? Ifso, why was the Health Consultation for nickel an addendum to that report?
- Did the ATSDR assess the emissions data from and disposal path of nickelcompounds formed during the nickel stripping evaporation (tank) process in C-400-C at PGDP?
- As part of this Health Consultation did the ATSDR review any health data formembers of the community surrounding PGDP. Non-smoking individuals in the residential community have records showing an elevated body burden for nickel.
- The Toxic Release Inventory (USEPA) data reports for nickel compounds released bythe TVA Shawnee Fossil Plant show releases to air, water, and land. For decadesnickel compounds were released via this facilities 244 m stack into the surroundingenvironment. While the height of the TVA stack facilitates the dispersion of thesepollutants away from PGDP during times of prevailing winds, the opposite occursduring a significant number of days each year. Figure 1 of this Health Consultation(Figure I-1 of this appendix) demonstrates changes in wind direction and resultingdispersion patterns. Further TRI data for TVA shows a significant level of nickelcompounds in ash generated at the Shawnee plant. Historically, this ash (cinders) wasspread on roadways in the WKWMA, dramatically increasing the levels of nickel inthe Health Consultation study area. Consequently, the nickel compounds releasedfrom the TVA facility should be included in this assessment. Additionally, while thePGDP steam plant emissions of nickel compounds are far less than those from theTVA plant, PGDP releases should not be excluded when calculating TOTALNICKEL at this locale. To date ash piles from PGDP continue to pollute the environsof the North-South Diversion Ditch and the Little Bayou Creek watershed. TOTALNICKEL from this toxic triad affects the health of the residents in the surroundingcommunity.
- Nickel particulates from TVA, PGDP, and nickel smelting could remain suspended in air for approximately one week.
- Nickel can be transported in air adsorbed to other particles.
- Nickel particulates adsorbed to another variety of particulate can be inhaled as oneparticle.
- Nickel oxide is insoluble in water hence, there exists the likely-hood of particlesbecoming airborne again and again.
- When inhaled, nickel oxide is retained longer in the lung than any other form ofnickel.
- Nickel can cross the placental barrier.
- Nickel is a mutagen (human)
ATSDR Response: ATSDR has reviewed all of the data collected by or through theKentucky Federal Facility Oversight Unit that they have provided to ATSDR. Although thedata sets do contain some measurements of nickel (or nickel compounds) in various media,we have not reviewed any specific nickel cyanide or nickel carbonyl measurements in theavailable data. Several different PGDP process operations may result in nickel emissions. Asindicated in the Health Consultation, past smelting operations and fossil fuel combustionrelease(d) nickel and nickel oxides. Limited quantities of nickel carbonyl or nickel cyanideas liquid effluents may be released from metal cleaning/degreasing operations in C-400building. However, these compounds are not stable in the environment (nickel carbonyl is aliquid at ambient temperatures) and will quickly be transformed to more stable compounds(nickel hydrates in water or nickel ferrite in soil) .
In determining the contaminants of concern for the Public Health Assessment, ATSDR didnot attempt to correlate specific sources of nickel for each environmental media. The PHAevaluation was based on the measured concentrations of the contaminants in various media,such as soil, water, and sediment. The rationale for conducting this health consultation is thatwe did not include metal particulates released from smelting operations in assessing airbornecontaminant distributions. Nickel, as dissolved or total nickel, is monitored in surface water,ground water, and soil. This Health Consultation used modeled airborne nickelconcentrations to estimate off-site distributions, because nickel was not monitored at off-site locations.
ATSDR Response: ATSDR has reviewed a number of documents relating to various aspectsof the aluminum and nickel smelting processes including the referenced DOE report on the"Metals Recovery Program" . While that document does discuss the types of documentsthat were reviewed, neither that document or the Phase II Report  contain specificreferences or bibliographies. Consequently, ATSDR cannot determine if we have reviewedthose same documents. However, ATSDR did review, and the Health Consultation doesreference, the report produced by that investigative team (as well as the report of anotherteam investigating related issues) [1,2]. ATSDR has not reviewed the "1972 study ofradionuclides in scrap." Although, it is mentioned, as stated by the commentor, in the PhaseII Report, it is not specifically referenced so ATSDR has no way of finding or tracking thatdocument.
As stated in the Health Consultation, smelting activities in C-746A did apparentlycommence in the 1950's. However, the summary statement describing the years of smeltingoperation are the only reference to smelting in the 1950's (other documents suggest thatearlier smelting activities mainly involved aluminum). Based on available reports, the yearsof significant nickel smelting were restricted to 1977 to 1986 (inclusive). While limitedquantities of nickel may have been smelted during other years, the exposure assessment inthis consultation focuses on those years of maximum nickel smelting (1977-86) and airborneemissions. As the airborne nickel concentrations estimated using conservative (healthprotective) assumptions during years of peak smelter operation are below levels of healthconcern, emissions during any earlier years of lower emission concentrations are also below levels of public health concern.
ATSDR Response: In determining the contaminants of concern for the Public CommentRelease of the Public Health Assessment, ATSDR did not evaluate specific sources of nickelor lead. That evaluation was based on the measured concentration of the contaminants invarious media, such as soil, water, and sediment. The rationale for conducting this healthconsultation (this appendix) is that we did not include metal particulates released fromsmelting operations in assessing airborne contaminant distributions. The form of nickelevaluated in the Public Comment Release of the Public Health Assessment for the groundwater, surface water, soil and sediment, and biota pathways is total nickel. For the airpathway in this consultation (this appendix), the chemical form is, as referenced, nickeloxide(s); however, the nickel health comparison values used are applicable to elemental ormetallic nickel, and both soluble and insoluble forms.
With regard to the chemical form of nickel compounds, only the nickel carbonyl form has asignificantly higher toxicity than other forms (and only via inhalation). As nickel carbonyl isnot thermodynamically stable in soil, air, or water, it will be converted to other morethermodynamically stable forms, such as nickel hydrates in water and nickel ferrite in soil. Nickel also tends to strongly adsorb onto larger particles in both soil sediment whichlimits its subsequent mobility . Although in some cases, it may be important to assess thepotential distribution and concentrations of the most toxic chemical forms, the limitedchemical stability of nickel carbonyl precludes significant off-site transport and exposure.For the determination of the off-site contaminants of concern at PGDP, if the totalenvironmental nickel concentrations are below levels of health concern, it is not necessary todelineate the specific sources of the nickel.
With regard to the total nickel distribution in the environment surrounding PGDP, there area number of potential sources including naturally occurring background levels in all media(nickel is the 24th most common element in the earth's crust) . In addition to the PGDPsmelter and steam plant and the TVA facility, minor sources include forest fires, volcanoes,fuel oil combustion, and other manufacturing processes. Any measurement of nickel in anyenvironmental media will include contributions from all sources. Neither the public healthassessment nor the health consultation attempted to discern the specific source of nickel inany media. The objective in these contaminant evaluations is to determine if the totalexposures result in doses of public health concern. If the doses are at concentrations of publichealth concern, it may become necessary to determine the specific sources in order toimplement a dose reduction strategy.
The annual smelter nickel emissions for the years 1983 to 1986 is estimated to be about 794pounds per year (based on an instantaneous emission rate of 0.05 g/sec for 8 hours per dayand 250 days per year). This operating schedule is in agreement with estimates of annualsmelter production of 6.7 million pounds per year (for the radiologically contaminatednickel). Using an average smelter loading rate of 3350 pounds per hour for 8 hours day, 250days per year equals a smelter output of 6.7 million pounds per year which is very close tothe average annual nickel production. It is assumed that releases of non-contaminated andcontaminated nickel are similar even though the maximum amount of non-contaminatednickel produced was stated to be just over 5 million pounds per year.
Although ATSDR was aware that metal smelting operations had taken place at PGDP, wehad not included such emissions in the Public Comment Release of the Public HealthAssessment. This consultation (this appendix) is a response to comments received.
ATSDR Response: Nickel stripping operations in C-400-C consisted primarily in use oforganic solvents (either trichloroethylene or trichloroethane) to remove surfacecontamination from nickel components. This process will not result in the release ofsignificant quantities of nickel. Emissions of and potential exposures to the organic solventswere evaluated in the PHA.
ATSDR Response: Any such health data is confidential information. ATSDR has no accessto such data unless provided by the individual in question and cannot review or evaluatewithout such access.
ATSDR Response: We have reconfigured the ISC air dispersion model to include potentialcontributions from both PGDP steam plant and the TVA facility. Based on 1998 and 1999Toxic Release Inventory data for the TVA facility , the instantaneous nickel air emissionsaverage ~0.0025 g/sec. Assuming that those later years are similar to the years of PGDPnickel smelter emissions, the instantaneous TVA release is about 20 times lower than thePGDP smelter release (0.05 g/sec) and is dispersed from an 800+ foot stack. Similarly,using standard emission factors for coal and oil combustion and annual fuel usage rates,instantaneous nickel emissions from the PGDP steam plant averaged 0.00009 g/sec(dispersed from two adjacent 110 foot stacks), which is 500 times lower than the smelteremissions. The results of the revised air dispersion models indicate no differences in the shortterm or annual distributions of nickel. All estimated concentrations are still well below levels of health concern.
While the revised air model does not include potential re-suspension from roadways,particulates from road dust are relatively large particles with limited capacity for widespreaddispersion. Additionally, exposure to road dust within the non-residential WKWMAroadways would be a relatively infrequent type of exposure. As a result of the limitedcapacity for significant dispersion and the infrequent exposure, nickel in road dust alongWKWMA roadways is not an important contributor to the total airborne nickel load.
ATSDR Response: While this comment is theoretically true, based on availabledocumentation, particulates from the smelter are much larger than those from the PGDPsteam plant and TVA facilities and much more likely to settle out in a short distance fromthe release point. Conversely, the smaller particle sizes from the fossil fuel facilities andmuch higher release points (stack heights), which leads to longer suspension times, meansthat nickel from those sources is dispersed over a much larger area and does not significantlycontribute to localized air concentrations. The models include appropriate parameters forparticle size that largely determine settling rates and travel times. The modeled dispersionalso conservatively neglects wet deposition. Wet deposition occurs during precipitation (rain,snow events) and serves to limit dispersion. Neglecting this term increases the range andconcentration of potential dispersion.
ATSDR Response: The above factors have all been considered in the development of the healthcomparison values, the Public Health Assessment, and by reference, in this health consultation.
- Once again it is apparent that the ATSDR, while recognizing the variety andconcentration of contaminants at PGDP, has failed to address their combined effectwhen concluding "...estimated concentrations of all metal particulates from PGDPsmelter operations are below levels of health concern, (and that) no adverse healtheffects are likely...." In fact, inhaling a mixture of pollutants , individually or incombined form, can magnify the effect several times over the effect of inhaling anyone pollutant individually.
- The Health Consultation did not include specific mailing instructions for individualssending comments. Since a telephone inquiry seeking those instructions was notreturned I have sent our comments to the same address as comments for the PGDPHealth Assessment.
ATSDR Response: See above for response to assessing cumulative effects to differentcontaminants. ATSDR considered cumulative, additive, synergistic, and antagonistic effectsof exposure to the extent of scientific knowledge in this area. Information and referencesrelated to ATSDR's process of evaluation have been added to the consultation (and to thisappendix).
ATSDR Response: Instructions for mailing of written comments will be added to futureATSDR consultation cover pages (Health Consultation: A Note of Explanation) for healthconsultations. Thank you for bringing this to our attention.
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1. The cancer risks for other forms of nickel, such as nickel carbonyl, nickel oxides, and elemental nickel have not been estimated by the various oversight agencies (EPA, ATSDR, etc.).
2. Because air concentrations at any location vary over time due to changing emission and weather conditions both health comparison values and estimated air concentrations are based on time weighted averages. The average times used in this appendix are annual averages for evaluating long term exposures and 1 or 8 hour averages for short term exposures.
3. Hourly weather data for the Paducah-Barkley Airport were obtained from the US Environmental Protection Agency (EPA) Support Center for Regulatory Air Models (SCRAM) website (http://www.epa.gov/ttn/scram ) and converted to the ISC3 format using EPA PCRAMMET software .
4. No potential cancer risk is based on nine years of exposure to a concentration of 0.022 µg/m3 and a unit risk of 4.8E-4 per µg/m3 (which assumes 70 years of exposure) .