PUBLIC HEALTH ASSESSMENT

Data and Modeling

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Page 2, Line 13: "radionuclides from White Oak Creek." High levels of these specific radionuclides have been earmarked in the OREIS (Oak Ridge Environmental Information System) database for decades. OREIS is not now readily available to the general public, but it is readily available to State of Tennessee scientists and public health officials. Many citizens also hold archives of these environmental releases from the time before DOE limited access to it.

DOE's own sampling data, especially from its key fish sampling locations has been carefully archived for decades and these data confirm high levels of Cs-137 and Sr-90 and other radionuclides and fish tissue in many locations downstream of WOC. ATSDR should immediately get access to the OREIS database, confirm these findings, and release this information to the public.

(Comment received on the initial release PHA dated December 2003.)

ATSDR has access to and has obtained data in electronic format from the Oak Ridge Environmental Information System (OREIS) (as mentioned throughout the final PHA; OREIS is detailed in Section II.F.4.). ATSDR used the OREIS data covering the time period from 1989 to 2003 to evaluate the current and future exposures and doses related to radionuclide releases from White Oak Creek. Samples included surface waters collected from the Lower Watts Bar Reservoir and sediments from the associated shorelines. ATSDR also evaluated biota data, including fish, geese, and turtle samples. ATSDR analyzed samples for rivers in the watershed that included the Clinch River below Melton Hill Dam and the Tennessee River below the mouth of the Clinch River. For comparison purposes, ATSDR reviewed data collected from background locations (Emory River, streams that feed into the Clinch River, the Clinch River above the Melton Hill Dam, and the Tennessee River upstream of the Clinch River). In addition, ATSDR evaluated data from the Tennessee Department of Environment and Conservation (TDEC) and the Tennessee Valley Authority (TVA), and used doses calculated in Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) to evaluate past exposures.

When initially sorting the data, ATSDR included the radionuclides associated with the Task 4 report, as well as the radionuclides reported in the OREIS data. The purpose of the data sorting was to collate data by the following parameters: river location, species (for biota), radionuclide, or a combination of one or more of these parameters. As a result of this sorting, ATSDR performed its evaluation on the radionuclides presented in Table 17 of the final PHA. As shown in this table, OREIS data for cesium 137 and strontium 90, as well as cobalt 60, yttrium 90, americium 241, and hydrogen 3 were evaluated. ATSDR's estimated doses for current and future exposures to radionuclides from White Oak Creek based on these OREIS data were below levels shown to cause adverse health effects. Accordingly, ATSDR concluded that these current and future exposures are not a health hazard.

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Page 4, Line 4: "ATSDR determined that the levels of radioactive contaminants that entered the Clinch River, and as well as those that reached the downstream Lower Watts Bar Reservoir, are too low to cause observable adverse health effects for most people who used or continue to use the river for food or recreation."

This statement cannot be supported by publicly available information from both DOE itself (documented in the OREIS database, the technical information that supports the DOE ORR's own ASER (Annual Site Environmental Report), and scientific reports of fish tissue content available from the TVA (Tennessee Valley Authority). ATSDR's failure to adequately explore the publicly available data for decades of fish tissue analyses both on the Reservation and downstream is blatantly irresponsible.

(Comment received on the initial release PHA dated December 2003.)

In the PHA, "ATSDR concluded that past, current, and future exposures to radionuclides released from White Oak Creek to the Clinch River/Lower Watts Bar Reservoir are not a public health hazard. People who used or lived along the Clinch River or Lower Watts Bar Reservoir in the past, or who currently do so or will in the future, might have or might yet come in contact with X-10 radionuclides that entered the Clinch River or Lower Watts Bar Reservoir via White Oak Creek. However, ATSDR's evaluation of data and exposure situations for users of these waterways indicates that the levels of radionuclides in the sediment, surface water, and biota are—and have been in the past—too low to cause observable health effects."

As part of ATSDR's public health assessment process, we conducted a thorough search for available data to evaluate exposures to White Oak Creek radionuclide releases via biota, sediment, and surface water. For past exposure, ATSDR reviewed and evaluated Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) and documents associated with this report. The Task 4 team performed extensive searches to obtain data for X-10 radionuclide releases to the Clinch River via White Oak Creek during the time period 1944 to 1991. The Task 4 team based its quantity estimates on log books, interviews with personnel associated with collecting samples and monitoring radioactive releases from White Oak Dam, and laboratory documents.

For current and future exposures for the Lower Watts Bar Reservoir, ATSDR evaluated data collected from 1988 to 1994 as presented in ATSDR's 1996 Lower Watts Bar Reservoir Health Consultation. For the Lower Watts Bar Reservoir, this incorporated environmental monitoring data for surface and deep channel sediment, surface water, and local biota (including fish) collected from the Lower Watts Bar Reservoir by DOE and TVA during the 1980s and 1990s. For current and future exposures for the Clinch River, data were obtained from the Oak Ridge Environmental Information System (OREIS). OREIS contains data from all key surveillance activities and environmental monitoring efforts, including annual site summary reports and studies of the Clinch River and the Lower Watts Bar Reservoir. The data received and analyzed by ATSDR covered the time period from 1989 to 2003. Samples included surface waters collected from the Lower Watts Bar Reservoir and sediments from the associated shorelines. ATSDR also evaluated biota data that included fish, geese, and turtle samples. ATSDR analyzed samples for rivers in the watershed that included the Clinch River below Melton Hill Dam and the Tennessee River below the mouth of the Clinch River. For comparison, ATSDR also reviewed data collected from OREIS for background locations (Emory River, streams that feed into the Clinch River, the Clinch River above the Melton Hill Dam, and the Tennessee River upstream of the Clinch River).

In addition, ATSDR presented the data sources to be used to the former Public Health Assessment Work Group (PHAWG), later referred to as the Exposure Evaluation Work Group (EEWG), to determine whether any additional data sources were available. This information was also shared with the Oak Ridge Reservation Health Effects Subcommittee, as well as with state and federal agencies (i.e., the U.S. Department of Energy [DOE], the Tennessee Department of Environment and Conservation [TDEC], and the Tennessee Department of Health [TDOH]).

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Page 39, Lines 1–2. Again, ATSDR's Watts Bar is fundamentally flawed because ATSDR did not account for DOE's own fish sampling data in OREIS. ATSDR cannot reconcile this BRA with these fish sampling data that exist for downstream communities from at least 1985. (Comment received on the initial release PHA dated December 2003.)

Page 38, Line 10. Please see the TWRA website for (Tennessee Wildlife Resources Agency) fish advisories for Watts Bar and other locations downstream: http://www.state.tn.us/twra/fish/contaminants.html . If ATSDR had even visited this website it would quickly learn that the fish consuming citizens of Tennessee are not even informed about their fish being contaminated with Sr-90, Cs-137, and other radionuclides released from DOE ORR. This amounts to a deliberate and unconscionable attempt to cover-up the fact that the fish in the TVA system have been and continue to be radioactively contaminated. This denial of these stakeholders fundamental right-to-know borders on conspiracy to obstruct justice. (Comment received on the initial release PHA dated December 2003.)

Many citizens downstream of the DOE ORR are particularly concerned that the State of Tennessee has yet to inform its citizens of the real risks that they are sustaining from consuming fish collected in tributaries leaving the DOE ORR. Although the State of Tennessee has posted a fish advisory for PCBs on its website, there is not one mention of these fish also being contaminated with radionuclides, especially high levels of Cesium 137 (Cs-137) and Strontium-90 (Sr-90). This inability for the State of Tennessee to inform its citizens that these fish are also radioactively contaminated is unconscionable. ATSDR should, and must, take immediate action to issue a public health advisory warning people of the danger.

The State of Tennessee should, and must, immediately post this information (that it has known about for decades) on its fish advisory website, and immediately change all affected stream signage to reflect this warning. At each and every location where it has already posted its PCB warnings, it must also specify the risks from radionuclides, especially Cs-137 and Sr-90. These two radionuclides are particularly dangerous to growing children and pregnant women. (Comment received on the initial release PHA dated December 2003.)

This referenced statement of the document—"The largest threat to public health from the Lower Watts Bar Reservoir is related to the consumption of PCB-contaminated fish."— does not refer to the U.S. Department of Energy's (DOE) baseline risk assessment as indicated by the commenter, but to the record of decision (ROD) for the Lower Watts Bar Reservoir (accessible online at http://www.epa.gov/superfund/sites/rods/fulltext/r0495249.pdf ). This finding in the ROD is based on the conclusions of the baseline risk assessment, which determined that standards for environmental and human health would not be reached if people consumed moderate to high quantities of specific fish that contained increased levels of PCBs. The ROD is agreed to by the three members of the Federal Facility Agreement (FFA): DOE is the lead agency that issued the ROD, and the U.S. Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC) are supportive agencies.

In a 1996 health consultation, ATSDR conducted an independent analysis of the Lower Watts Bar Reservoir data to evaluate whether radiological and chemical contaminants in reservoir fish, surface water, and sediment posed a public health hazard. ATSDR concluded that PCB levels in fish were the only contaminants that posed a public health hazard. ATSDR determined that no public health hazards were associated with the three primary radioactive contaminants (cesium 137, cobalt 60, and strontium 90) in reservoir fish and that current levels of chemical and radiological contaminants in reservoir surface water and sediment did not pose a public health hazard.

To evaluate current and future exposures for the Clinch River and the Lower Watts Bar Reservoir, ATSDR did obtain and evaluate biota, surface water, and sediment sampling data from OREIS from 1989 to 2003 in this final PHA. ATSDR determined that radionuclides in fish, sediment, and surface water do not pose a health hazard for people who used and continue to use the Clinch River and the Lower Watts Bar Reservoir. Therefore, even though radionuclides might be present in the Clinch River and the Lower Watts Bar Reservoir, only PCBs in certain fish species have been found at levels that might cause adverse health effects.

TDEC's Division of Water Control is responsible for issuing and posting fish advisories. Evaluating fish tissue problems in the state of Tennessee involves a multi-agency effort, comprised of DOE, EPA, TDEC, the Tennessee Wildlife Resources Agency (TWRA), and the Tennessee Valley Authority (TVA). An abundance of data are available on contaminants in fish in these systems, including data collected by TVA, DOE, TWRA, and TDEC. These agencies use Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) criteria to analyze fish tissue in these waterways, which applies EPA risk assessment to evaluating potential exposures to contaminants in fish. DOE, TDEC, and EPA have responsibilities under CERCLA, but the state has ultimate responsibility for the advisories. The state fish advisories are available at: http://www.state.tn.us/twra/fish/contaminants.html .

It is important to understand that although there might be radionuclides and other contaminants present in fish in the Clinch River and the Lower Watts Bar Reservoir, only PCBs have been found at levels in particular species of fish that could potentially cause adverse health effects. This is why radionuclides are not part of the advisories for these waterways—they have not been detected at harmful levels in these water systems. These agencies are basing their advisories on numerous data collected over several years by different entities, all of which show that radionuclides are not present in fish in the Lower Watts Bar Reservoir and the Clinch River at levels that could cause adverse health effects. ATSDR's evaluation in this public health assessment concurs with the findings of the state, EPA, and these other entities. In addition, ATSDR is preparing a public health assessment that will evaluate PCB releases from the three main ORR facilities: X-10, Y-12, and K-25. When available, copies of ATSDRs public health assessment on PCBs can be obtained by contacting ATSDRs Information Center toll-free at 1-888-422-8737.

As a public health agency, ATSDR could make recommendations for public health actions if our evaluation showed that radionuclides in the Lower Watts Bar Reservoir and the Clinch River posed a potential health hazard for people living along and using these waterways. For past exposures to X-10 radionuclide releases via the Clinch River, estimated annual and lifetime whole-body radiation doses for all pathways combined were 25 and 18 times less, respectively, than health-based comparison values. For current exposures to the Lower Watts Bar Reservoir, estimated annual and lifetime whole-body radiation doses for all pathways combined were 3 and 2.5 times less, respectively, than health-based comparison values. For current exposures to the Clinch River, estimated annual and lifetime whole-body radiation doses for all pathways combined were 30 and 20 times less than, respectively, ATSDRs health-based comparison values. Therefore, based on an analysis and evaluation of data in our 1996 health consultation and in this public health assessment, we have concluded that exposure to X-10 radionuclides released from White Oak Creek to the Clinch River and the Lower Watts Bar Reservoir via biota, surface water, and sediment is not a public health hazard. Please see the final PHA for more details on ATSDRs evaluation.

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Page 76, line 28: Mathematical modeling was used to estimate the annual average concentrations of the radionuclides in water and sediment downstream from White Oak Creek. We used actual measurements in water, when available, to calculate doses.

Thank you for your comment. The following text was added to the final PHA: "To calculate doses for Cs 137, Sr 90, Ru 106, and Co 60, the Task 4 team used—when available—actual measurements from the Clinch River water it collected 1960–1990 at CRM 14.5 (K-25 Grassy Creek) and at 4.5 (Kingston Steam Plant). For the remaining radionuclides and for time periods when data were unavailable, the Task 4 team used modeling to estimate the historical radionuclide concentrations in Clinch River water."

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Page 90, Table 13. Maximum Radionuclide Concentrations in Lower Watts Bar Reservoir Area Fish. Page 99; Table 19. Estimated Radiation Doses From Current Consumption of Geese and Turtle. Page 100; and Table 20. Estimated Radiation Doses From Current Consumption of Fish.

This information is not factual. DOE's own fish sampling data in its ACER data volumes are in excess of these levels. ATSDR and all interested stakeholders can easily access these data at: http://www.ornl.gov/sci/env_rpt/ . To get the desired data volume the stakeholder needs to scroll down the index and the data bookmark is typically near the bottom for each year. These data volumes provide a wealth of additional data that most will be very interested in as well! ATSDR needs to do a better job on its homework in obtaining the same additional, publicly available data sets that interested downstream, downwind, and down-aquifer stakeholders are already using to do their own competing risk analyses.

Page 102, Table 21. Summary of Public Health Implications From ATSDR's Evaluation of Past and Currently Exposure to Radionuclides Released to the Clinch River/Lower Watts Bar Reservoir. There are over 150 species of fish and other aquatic animals that dwell in the Clinch River, and many are used for food. Some of the available organisms from the Clinch River and TVA's reservoirs are not included in this PHA are crayfish and frogs. Nevertheless, DOE ORR has radiological sampling data in the OREIS database on all of these.

There is no paucity of extensively archived and publicly available data regarding the radionuclide content of an immense array of other aquatic organisms (or their consumers) that people in the TVA region consume as well. For example, there are extensive archives of radionuclide contents of the following: turtles, mussels, crayfish, raccoons, beaver, and many others.

ATSDR must come to grips with the publicly available sampling data. Thereafter is must apply standard EPA risk assessment methodologies to these voluminous data. Instead of trying to find ways not to find and evaluate the immense volumes of publicly available data confirming the existence of threats to the public health, downwind and downstream of the DOE ORR, ATSDR must start now and evaluate the levels of these radionuclides in fish and other biota used as food by the many residents downstream.

Since many of these radioactively contaminated fish definitely don't remain 'in residence' near WOC, but could range far and wide throughout the TVA system, this PHA is definitely over simplistic and is lulling stakeholders into a false sense of security when it deals with fish consumption.

(Comments received on the initial release PHA dated December 2003.)

The former Table 13 being referenced by the commenter is now Table 15 in the final PHA. The information presented in this table is based on data collected from 1988 to 1994 as presented in ATSDR's 1996 Lower Watts Bar Reservoir Health Consultation, including environmental sampling data from the 1980s and 1990s that had been collected and assembled by the U.S. Department of Energy (DOE), the Tennessee Valley Authority (TVA), and various consultants. Also, ATSDR analyzed data from TVA's 1993 and 1994 annual radiological environmental reports for the Watts Bar Nuclear Plant. Thus, the data contained in this table are inclusive of data collected by DOE during the time periods of study.

For the health consultation, ATSDR analyzed chemical and radiological data in surface water, sediment, and fish. ATSDR evaluated potential exposures by using worst-case scenarios assuming the most sensitive population was exposed to the maximum concentrations of each contaminant in each media. ATSDR concluded that exposure to radionuclides detected in Lower Watts Bar Reservoir fish, surface water, and sediment was not a public health hazard. Again, as noted previously, these conclusions were based on available data not only collected from DOE, but also from TVA and from various consultants.

In the final PHA, the referenced former Tables 19 and 20 are now Table 19. Estimated Radiation Doses From Current Ingestion of Fish and Table 20. Estimated Radiation Doses From Current Ingestion of Geese and Turtles. The radiation doses presented in Table 19 and Table 20 are based on an evaluation of data collected from the Oak Ridge Environmental Information System (OREIS). When calculating the doses, ATSDR used the concentration of the radionuclides in the environment, and site-specific factors if they were available, such as the amount of fish consumed based on ATSDR's 1998 Watts Bar Reservoir exposure investigation. Default values were used when site-specific factors were not available, such as for drinking water ingestion. These two tables present estimated whole-body doses, as well as doses for the critical organs—those organs receiving the highest radiation doses. OREIS consists of data from all key surveillance activities and environmental monitoring efforts associated with the Oak Ridge Reservation operations, including DOE's annual site environmental reports (ASERs).

When initially sorting the data, ATSDR included the radionuclides associated with Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report), as well as the radionuclides reported in the OREIS data. The purpose of the data sorting was to collate data by the following parameters: river location, species (for biota), radionuclide, or a combination of one or more of these parameters. As a result of this sorting, ATSDR performed its evaluation on the radionuclides presented in Table 17 of the final PHA. As shown in this table, OREIS data were evaluated for cesium 137, strontium 90, cobalt 60, yttrium 90, americium 241, and hydrogen 3.

ATSDR conducted a thorough search for available data to determine whether exposure to White Oak Creek radionuclide releases were and are a public health hazard for people who used and continue to use the Clinch River and the Lower Watts Bar Reservoir. For past exposure, ATSDR reviewed and evaluated the Task 4 report and documents associated with this report. The Task 4 team performed extensive searches to obtain data for X-10 radionuclide releases to the Clinch River via White Oak Creek during the time period 1944 to 1991. The Task 4 team focused its information collection activities on records at the X-10 Laboratory Records (containing "active" types of records, such as technical reports and memorandums regarding X-10 activities) and the X-10 Records Center (containing more "archived" types of records). The Task 4 team based its quantity estimates on various sources utilized during data collection activities, including log books, interviews with personnel associated with collecting samples and monitoring radioactive releases from White Oak Dam, and laboratory documents.

For current and future exposures for the Lower Watts Bar Reservoir, ATSDR evaluated data collected from 1988 to 1994 as presented in ATSDR's 1996 Lower Watts Bar Reservoir Health Consultation. For the Lower Watts Bar Reservoir, this incorporated environmental monitoring data for surface and deep channel sediment, surface water, and local biota (including fish) collected from the Lower Watts Bar Reservoir by DOE and TVA during the 1980s and 1990s. For current and future exposures for the Clinch River, data were obtained from OREIS. The data received and analyzed by ATSDR covered the time period from 1989 to 2003. Samples included surface waters collected from the Lower Watts Bar Reservoir and sediments from the associated shorelines. ATSDR also evaluated biota data that included fish, geese, and turtle samples. ATSDR analyzed samples for rivers in the watershed that included the Clinch River below Melton Hill Dam and the Tennessee River below the mouth of the Clinch River. For comparison, ATSDR also reviewed data collected from OREIS for background locations (Emory River, streams that feed into the Clinch River, the Clinch River above the Melton Hill Dam, and the Tennessee River upstream of the Clinch River).

Contrary to this commenter's statements, the OREIS database does not contain radiological sampling data for the "over 150 species of fish and other aquatic animals that dwell in the Clinch River." Reportedly, the Clinch River Valley actually maintains over 350 different species of wildlife. Data contained in OREIS from 1989 to 2003, however, only include radiological sampling data for the areas of study and radionuclides of interest (see Table 17 in the final PHA) for the following species in the Clinch River known as food sources: fish (bass, catfish, and sunfish), geese, and turtles. ATSDR evaluated available sampling data for these particular species for the study areas and radionuclides of interest (see Table 17), as well as on the known exposure pathways to these wildlife. Data for the radionuclides and areas of interest were available for fish in the Clinch River and the Lower Watts Bar Reservoir for past and current exposures, as well as for geese and turtles in the Clinch River for current exposures. No radiological data are contained in OREIS for 1989 to 2003 for other wildlife species in these areas of study known as food sources, including crayfish or frogs (as specifically requested by the commenter). Particular to this commenter's list, data for turtles were available and evaluated in Section III.B.3. of the final PHA for current exposures to the Clinch River. Mussels are detailed in the PHA (see Section III.B.3) regarding the Clinch River, and how the likelihood is low that people consumed mussels from the Clinch River. Data for the remaining species on the commenter's list, as well as additional species, were not evaluated because the data are not available for the radionuclides of interest and the study area of interest, or people are not known to consume the particular species.

ATSDR not only looked at fish remaining near White Oak Creek, ATSDR evaluated fish data for the entire White Oak Creek study area, consisting of the area along the Clinch River from the Melton Hill Dam to the Watts Bar Dam. Section III. Evaluation of Environmental Contamination and Potential Exposure Pathways in the final PHA details ATSDR's analysis of past, current, and future exposures to White Oak Creek radionuclide releases via consumption of fish and other biota. Section IV. Public Health Implications details the weight-of-evidence approach ATSDR used to compare estimated radiation doses to situations associated with disease and injury to determine whether harmful health effects could be possible and observable. Using our evaluation, ATSDR determined that the levels of radionuclides in biota, sediment, and surface water were too low to cause observable health effects. Accordingly, ATSDR concluded that past, current, and future exposures to radionuclides released from White Oak Creek to the Clinch River and the Lower Watts Bar Reservoir are not a public health hazard for people who lived along or used these waterways in the past, present, and future.

Regarding ATSDR applying EPA risk assessment methodologies, please refer to Appendix F in the final PHA and the response to comment 44 within this appendix.

Accuracy/Clarification of Statements

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Page 20, Table 2. Estimated Discharges (in curies) of Radionuclides from White Oak Creek. This table is busy and seems to hide information instead of revealing the nature and extent of radioactive discharges from White Oak Creek. Is this obfuscation by design on ATSDR's part?

Page 13, Line 22. Thorium and plutonium releases are detailed in the OREIS database. These two extremely long-lived radionuclides should be cited in Table 2 and Table 3, but are conspicuously absent. Was ATSDR's omission of thorium and plutonium from these two tables purposeful?

(Comments received on the initial release PHA dated December 2003.)

Table 2 in the final PHA was taken directly from the Remedial Investigation/ Feasibility Study of the Clinch River/Poplar Creek Operable Unit prepared by Jacobs Engineering Group Inc. in 1996. It is available at http://www.osti.gov/bridge/servlets/purl/226399-5omhIT/webviewable/226399.pdf . The table presents the estimated discharges (in curies) for only those radionuclides released from White Oak Creek to the Clinch River that required investigation. It contains the radionuclides, the year of release, and the estimated discharges in curies. We believe that this table provides useful information for the reader.

Table 3 in the final PHA was taken directly from the Tennessee Department of Health's Oak Ridge Dose Reconstruction Summary Report available at http://www2.state.tn.us/health/CEDS/OakRidge/ProjSumm.pdf . This was based on the Task 4 report titled Radionuclide Releases to the Clinch River from White Oak Creek on the Oak Ridge Reservation—an Assessment of Historical Quantities Released, Off-site Radiation Doses, and Health Risks. The Task 4 team identified 24 radionuclides during its screening assessment that had been released to the Clinch River via White Oak Creek from 1944 to 1991. Among this group of 24 radionuclides were thorium and plutonium. Using a risk-based screening process, however, 16 of the radionuclides were eliminated because the estimated screening indices were below the Task 4 team's minimal level of concern (1 x 10^-5). Both plutonium and thorium were removed from further evaluation because the releases of the contaminants to the Clinch River via White Oak Creek were below the team's minimal level of concern.

Therefore, to be clear, these tables were created by entities other than ATSDR, but we did review their work prior to including it in this public health assessment. Also, please note that there are many radionuclides in OREIS other than thorium, plutonium, and those presented in these tables. Thorium and plutonium, as well as other radionuclides, are not presented in these tables because their releases to the Clinch River via White Oak Creek have not been found at levels of concern and at levels requiring further investigation.

See Appendix D for a brief on the 1999 Task 4 report. Copies of the Task 4 report are available at the DOE Information Center located at 475 Oak Ridge Turnpike, Oak Ridge, Tennessee (telephone number: 1-865-241-4780) or at http://www2.state.tn.us/health/CEDS/OakRidge/WOak1.pdf .

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He questioned the PHA's statement (on page 16, line 7) that the X-10 facility still produces isotopes.

According to the Tennessee Department of Environment and Conservation's (TDEC) 2004 Status Report to the Public (available at http://www.local-oversight.org/TDEC2004.pdf , see pages 14–15) and the U.S. Department of Energy (DOE), the High Flux Isotope Reactor (HFIR) and the Radiochemical Engineering and Development Center (REDC) are active facilities at the Oak Ridge National Laboratory (ORNL), formerly known as X-10, used for the production of medical and industrial isotopes.

For more information, see the Web sites for the HFIR facility (http://web.ornl.gov/sci/rrd/pages/hfir.html ), and the REDC (http://www.ornl.gov/sci/nuclear_science_technology/redc/ ).

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P. 27. The statement about designs lacking, "adequate containment structures", taken from the Oak Ridge End Use Working Group (EUWG) report, reveals an inadequate understanding of hydrogeologic design on the part of the EUWG. How would they design a septic tank drain field? Any sort of impervious barrier would simply lead to flooding and stop the process. Furthermore, the comment about, "improper design", appears not to be a quote from, but rather an inaccurate and unjustified addition to, the wording of the EUWG report. This phrase should be deleted. The trenches functioned as natural electrostatic filters. They were not improperly designed.

In the final PHA the text has been changed to the following: "Radioactive waste material, such as Cs 137 and Sr 90, is present in old waste sites at the ORR. These waste sites constitute 5% to 10% of the reservation. Releases from these waste sites, as well as leaching caused by abundant rainfall and high water tables, have contributed to the radionuclide contamination of surface water, groundwater, soil, and sediments at the ORR."

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Page 34 Line 18: The largest concentrations of radionuclides that have been detected are buried between 8 and 32 inches into the deep sediments; radionuclide contamination has not been detected in the shoreline sediment (Jacobs EM Team 1997b).

Radionuclides have been reported in shoreline sediments of the Clinch. Consequently, the above statement appears to be incorrect.

Thank you for the clarification. This information was obtained from the Clinch River/Poplar Creek record of decision that states, "Those few DOE-related contaminants above background levels in the near-shore sediments are arsenic in McCoy Branch, and chromium and manganese in Poplar Creek." The correction will be made to reflect this updated information.

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Page 34, Line 27. Has any treatment of these wastes actually occurred yet, or are they still residing in place at the MVSTs? In other words, specifically state here which, if any, fraction of these wastes have actually been removed and treated, and which fraction remains in situ. If in fact, the wastes still remain in place this passage is misleading to the reader and gives the public a false sense of 'security' that these stored wastes, in leaking concrete containers, are being 'remediated.' The citizens of Oak Ridge and all downstream and down-aquifer deserve a straight answer from ATSDR. (Comment received on the initial release PHA dated December 2003.)

The Melton Valley Storage Tanks (MVSTs) consist of eight underground storage tanks (USTs) each with an approximate 50,000-gallon capacity, located in Melton Valley. The MVSTs are used to store transuranic (TRU) waste from past processes and remedial activities, including the old hydrofracture facility (OHF) tanks referenced by the commenter (see Appendix B in the final PHA for more information on the OHF tanks).

First of all, it is important to note that contrary to the commenter's statement, the OHF tanks were not leaking. In fact, the waste was moved to the MVSTs for safer storage of wastes remaining in the tanks before treatment took place and before any of the tanks could potentially leak. Because there were concerns about the proximity of the tanks to White Oak Creek, the potential threat to environmental receptors, and the possibility of tank leakage, an action memorandum was prepared in September 1996 to move and treat the tank waste. The memorandum outlined an aboveground, double-walled hose system to transfer the tank contents and waste to the MVSTs. Prior to the transfer, some treatment of the waste occurred so that the waste would meet the waste acceptance criteria for the MVSTs. From June to July 1998, more than 98% of the waste was moved through a pipeline to the MVSTs, where additional treatment will occur.

Another action memorandum for the OHF, prepared in May 1999, focused on tank stabilization and on the surface impoundment sediments associated with the OHF. The tank stabilization activities included removing the piping system, placing submersible pumps into the tanks, using mixer spool pieces, and grouting the tanks. For the surface impoundment, the remedial activities consisted of applying grout for sediment stabilization, placing grout into standpipes, removing excess water, treating any excess water at the Process Water Treatment Plant (PWTP), and using filler material to replenish the impoundment. These remedial activities were completed, and in May 2001 a removal action report was released.

Waste to be treated at the ORR's Transuranic Waste Processing Facility is still being stored or consolidated in the MVSTs. After the TRU waste is treated, it will be shipped off site for disposal at the Waste Isolation Pilot Plant in Carlsbad, New Mexico. Processing of the waste is underway and completion of off site disposal is expected to occur in 2008.

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P. 57. Line 19. Do you really mean Cr (VI) at all three ORR sites when you state "ORR?"

Yes, this statement is correct as presented in the PHA. Hexavalent chromium was used in cooling towers at K-25, Y-12, and X-10. Please refer to Sections 5.4 (Hexavalent Chromium Releases from the Oak Ridge Reservation) and 7.0 (Conclusions) in Task 7 of the Reports of the Oak Ridge Dose Reconstruction titled Screening-Level Evaluation of Additional Potential Materials of Concern. The report is available online at http://www2.state.tn.us/health/CEDS/OakRidge/Screen.pdf .

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P. 72 (and Appendix E). Shouldn't the term "screening index" be identified as being a calculated probability, or risk?

An explanation that a "screening index" is a calculated probability of developing cancer has been added to the summary, page 77, and to Appendix E. In addition, the term "screening index" was added to and defined in the glossary in Appendix A.

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Page 92 line 6, Table 13. Maximum Radionuclide Concentrations in Lower Watts Bar Reservoir Sediment: Table 13 indicates that Strontium-89 was detected at 2.30 pCi/g in Lower Watts Bar Reservoir surface sediment. Strontium-89 is a short-lived fission product with a half-life of only 2.1 days; consequently, it seems unlikely the radionuclide would have originated from historical wastes. Since a recent nuclear reaction would be required to produce the isotope, is it reasonable to assume the contaminant originated at the High Flux Isotope Reactor or is the result due to laboratory error?

Your comment is noted. We agree that because Strontium 89 has a short half-life, this reported concentration of 2.30 picocuries per gram (pCi/g) in Table 13 could either be a misidentification or the radionuclide was released from the High Flux Isotope Reactor (HFIR) at the Oak Ridge National Laboratory.

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The report should acknowledge that White Oak Creek and its discharges affect Roane County, not Anderson County. The title of the report is misleading in this case.

Thank you for the clarification. The X-10 site and White Oak Creek are located in Roane County, not Anderson County, and this change has been made to the title of the final PHA. It is important to note, however, that the study area for this public health assessment (see Figure 11 of the final PHA) consists of the area along the Clinch River from the Melton Hill Dam to the Watts Bar Dam. This not only includes Roane County, but also Meigs and Rhea Counties. ATSDR evaluated these areas in the final PHA because they are potentially impacted by X-10 radionuclide releases to White Oak Creek via the Clinch River and the Lower Watts Bar Reservoir. Please see Section II.E. Demographics in the final PHA for a description of the communities included within this study area.

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It should be more clearly stated that this Public Health Assessment (PHA) is for off-site downstream residents exposed to radioactive elements and not for anyone working in the waste disposal areas. Other PHAs for this geographic scope should be cited, summarized, and referenced.

Your comment is noted. Under ATSDR's Evaluation of Exposure to Radionuclide Releases From X-10 in Section I. Summary of the final PHA, the following was added to the end of the first paragraph: "Please note that this document only evaluates off-site exposures to White Oak Creek radionuclide releases for downstream residents and others who use or who live along these waterways. It does not evaluate any exposures potentially occurring on site at the reservation, including exposures to workers and other individuals who may contact contaminants while at the ORR."

Please note further that ATSDR does not prepare any public health assessments to evaluate on-site worker exposures. Other agencies are responsible for evaluating worker exposures that occur on site. ATSDR scientists have also conducted or are currently conducting public health assessments on: Y-12 uranium releases, off-site groundwater, Toxic Substances Control Act (TSCA) Incinerator releases, Y-12 mercury releases, X-10 iodine 131 releases, K-25 uranium and fluoride releases, PCB releases from X-10, Y-12, and K-25, and a current screening (1990 to 2003) of environmental data. For copies of these public health assessments, please contact ATSDR's Information Center toll-free at 1-888-422-8737.

Groundwater

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Page 11, Figure 3. Location of X-10 in Relation to Bethel Valley and Melton Valley. Display Bethel Valley and Melton Valley watersheds with depiction of existing groundwater plumes of contamination. Include the names of the underlying aquifers and their directional flow. Display the potential number of consumers that may be using these contaminated aquifers as a drinking water source.

Page 17, Line 23. Add a statement that this means of disposal was entirely unprotective of the groundwater below these pits because of the very porous nature of the geology of this region. This region is nearly entirely very porous karst limestone. Contaminants released onto it leak through it like a sieve. The true extent of groundwater contamination from these unlined earthen pits is well know to ATSDR, EPA, TDH, TDEC, and DOE, but it has yet to be revealed by any of these 'public health' and/or 'regulatory' agencies. This passage will be useful in identifying the Primary Responsible Parties (PEPS) under CERCLA that will be responsible for paying for the cleanup of sediments if the Clinch River is ever dredged and cleaned up, just like has already been done with the Hudson River in New York.

Page 18, Figure 7. Location of Solid Waste Storage Areas (SWSAs) at the X-10 Site. Show the contaminate plumes under these sites that are known to ATSDR, EPA, TDEC, TDH, and DOE. Show the directional flow of these contaminant plumes wit their directional flow and the aquifers that they have already reached as well as those others at risk. Show the potential numbers of people consuming water from these affected aquifers that these contaminant plumes drain into, both now and in the future.

Page 19, Line 8. 'Hydrofacture technology' has most probably irrevocably contaminated deep groundwater beneath the facility where it occurred. Which aquifers have been contaminated by this technology at Oak Ridge National Laboratory (ORNL)?

What is the latitude and longitude of all injection sites on the DOE ORR where these injections were made? This information will be necessary so that environmental advocacy groups, institutions of higher learning, and other stakeholders can utilize desktop Geographical Information Systems (GIS) to further analyze where these contaminants have migrated.

These analyses will allow stakeholders to determine, on their own, the true extent of groundwater contamination from these unlined earthen pits. Is the true nature and extent of groundwater contamination from these unlined earthen pits known to ATSDR, EPA, TDH, TDEC, and DOE? Have federal and state public health and regulatory agencies withheld this information from stakeholders?

Page 19, Line 11. The public also has a fundamental Right-to-Know right to this information concerning the nature and extent of this actual deep groundwater contamination and the potential numbers of consumers of these waters.

Page 22, Line 22. Include a diagram of the extent of this watershed within DOE ORR. Include a depiction of the affected aquifers from the contaminant plumes beneath these tracts of land. Include the prospective numbers of populations that have in the past or will most probably in the future use these potentially contaminated aquifers for drinking water.

Page 22, Line 29. Provide a detailed map of these five watersheds. Annotate this detailed map with their respective receiving aquifer(s) and the numbers of people who are either current or future consumers of these waters.

Page 25. Figure 9. Map of the Major Remedial Activities in Bethel Valley.

Several three dimensional depictions of affected groundwater aquifers and contaminant plumes have been developed by DOE and should be added to this PHA as companion figures to Figure 9.

If ATSDR has trouble locating these, either check with several stakeholders that know of their whereabouts. Alternatively, and probably faster, check with the EPA Southeastern Regional Office in Atlanta, TDH, or TDEC. All of the above agencies already have these maps of contaminant plumes beneath this portion of DOE ORR. To date, these 'public health' and 'regulatory' agencies have simply withheld this critical information from the other stakeholders.

Are there still contaminated groundwater plumes left in place below these 'grouted' tanks? If so, what is the nature and extent of the contamination of groundwater at these location, especially the radionuclides involved?

Which specific radionuclides have been identified in these plumes?

Which aquifers do they drain to? How many current and future users of these aquifers have been identified?

Page 26, Line 25. Are there still contaminated plumes left in place below these 'grouted' tanks? If so, what are the specific radionuclides in these respective plumes? Which aquifers do these plumes drain into? What are the numbers of people either current or future consumers of water from these aquifers? These are critical answers for ATSDR to formulate responses to because on Page 27, line 25 ATSDR cites a DOE document (US DOE 2002b) as follows: "As a result, the waste sites in the Melton Valley Watershed..." are the primary contributors to off-site spread of contaminants" from the ORR. The citizens of Oak Ridge and all of its downstream (and down-aquifer) consumers of these waters are not reassured by ATSDR's seemingly superficial treatment of these critical exposure issues.

Page 35, Line 19. Since ATSDR cites the interception of "downgradient contaminated groundwater:" Which specific radionuclides are contaminating the groundwater? What is the approximate curie load of each respective radionuclide? Which aquifer(s) are receiving this "downgradient contaminated groundwater? What are the numbers of current and future users of this contaminated groundwater?

(Comment received on the initial release PHA dated December 2003.)

In this public health assessment, ATSDR evaluated radioactive contaminant data for White Oak Creek releases that enter the Clinch River and travel downstream to the Lower Watts Bar Reservoir. To be clear, this public health assessment only evaluated X-10 radionuclides in White Oak Creek after the surface water was released off site. We recognize that oftentimes contaminants released into surface water may originate from contaminated groundwater, including on-site seeps and other sources of groundwater contamination. These potential exposures to off-site groundwater associated with the Oak Ridge Reservation, however, are addressed in another public health assessment titled Evaluation of Potential Exposures to Contaminated Off-site Groundwater From the Oak Ridge Reservation (USDOE). This assessment addresses all of the issues presented by the commenter including plumes, contaminants flowing from groundwater, the underlying aquifers, and the other questions posed as well. Copies of this and other ATSDR documents are available from the ATSDR Information Center. You may call the center toll-free at 1-888-422-8737 or view the groundwater document online at http://www.atsdr.cdc.gov/HAC/PHA/region_4.html#groundwater.

In addition, remedial actions are underway at the Oak Ridge Reservation and are proceeding according to the requirements of the Comprehensive Environmental, Response, Compensation, and Liability Act of 1980 (CERCLA). Completed and ongoing actions, including those associated with on-site groundwater contamination, are published annually in a remediation effectiveness report (RER). The RER is available at the DOE Information Center located at 475 Oak Ridge Turnpike, Oak Ridge, Tennessee (telephone number: 1-865-241-4780).

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Appendix A. ATSDR Glossary of Environmental Health Terms, Page A-1, Line 38. Down-aquifer stakeholders note that 'aquifer' is absent from this glossary. This is unfortunate because this PHA discusses groundwater injection of radioactive wastes at WOC, which of course has contaminated WOC's underlying groundwater. Groundwater leads to an AQUIFER. Stakeholders, many quite distant from WOC, may be drawing water from a contaminated aquifer. It would be helpful if aquifer were to be included in this glossary.

(Comment received on the initial release PHA dated December 2003.)

This term is defined in ATSDR's PHA titled Evaluation of Potential Exposures to Contaminated Off-site Groundwater From the Oak Ridge Reservation (USDOE) available online at http://www.atsdr.cdc.gov/HAC/PHA/region_4.html#groundwater. Copies of this and other ATSDR documents are also available from the ATSDR Information Center. You may call the center toll-free at 1-888-422-8737.

Concerns of Conflicts of Interest

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Page 125, Line 25. ATSDR is not fulfilling its public health mandate because of an obvious conflict of interest with its funding from DOE. This PHA should be immediately redrafted using the many years of fish sampling data in the OREIS database. This robust data set dates from 1985. Importantly, next time use EPA standard CERCLA guidance and its risk-based PRGs for radioactive contaminants.

Page 127, Line 6. Simply put, stakeholders believe that ATSDR is betraying the public health trust of the citizens of East Tennessee. DOE accepts DOE funding to perform DOE's "health studies." ATSDR and DOE both know the true extent of which radioactive contaminants that downwind, downstream, and down-aquifer stakeholders are being exposed to. The risk estimates of these known exposure are being handled in a schizophrenic fashion: low-balling the estimates for the public and other "unsanitized" and probably higher estimates for DOE's epidemiological archives.

(Comments received on the initial release PHA dated December 2003.)

In 1980 Congress created ATSDR to implement the health-related sections of laws protecting the public from hazardous wastes. ATSDR is a public health agency within the U.S. Department of Health and Human Services (HHS), and the lead agency for implementing the health-related provisions of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), referred to as Superfund. Since the 1986 Superfund Amendments and Reauthorization Act (SARA), ATSDR has been required by law to conduct public health assessments at each site on the U.S. Environmental Protection Agency's (EPA) National Priorities List. The investigation and the clean up of these sites is the responsibility of EPA and the individual states.

As a potentially responsible party (PRP), the U.S. Department of Energy (DOE) provides funding to HHS for its Worker and Public Health Activities Program. The goal of this program is to improve understanding of the effects on workers and people living in communities surrounding DOE facilities from exposures to ionizing radiation and other hazardous materials used in DOE activities. Under a memorandum of understanding (MOU) between DOE and HHS, three agencies within HHS will independently perform public health activities—ATSDR, the National Institute for Occupational Safety and Health (NIOSH), and the National Center for Environmental Health (NCEH). NIOSH performs epidemiological studies of DOE workers and NCEH conducts community-based epidemiologic studies and historical dose reconstruction projects. ATSDR conducts studies to determine if environmental contaminants could have caused past, present, and future health effects for off-site communities near DOE Superfund sites.

As the lead public health agency responsible for implementing the health-related provisions of Superfund, ATSDR is charged with assessing health hazards at specific hazardous waste sites, helping to prevent or reduce exposure and the illnesses that result, and increasing knowledge and understanding of the health effects that may result from exposure to hazardous substances. As the PRP, DOE is required to fund cleanup and public health investigations, such as the ATSDR PHAs, for the Oak Ridge Reservation.

The DOE funding is outlined in the MOU between HHS and DOE (see http://www.eh.doe.gov/health/documents/mou.pdf ). This MOU also addresses ATSDR's public health responsibilities around DOE sites including public health assessments, health studies, health surveillance, and exposure registries. Implementing this MOU requires significant interaction with communities living in proximity to DOE sites. This charter is in response to requests from community representatives surrounding DOE sites to provide consensus advice and recommendations on community concerns to CDC's and ATSDR's activities related to the sites.

As a federal advisory agency, ATSDR conducts independent and objective public health evaluations. We make our decisions based on available data and current science—the source of our funding does not bias our evaluations, our assessment of data, or our scientific conclusions. In public health assessments for the ORR, ATSDR uses available data not only from DOE, but from other government agencies such as the Tennessee Valley Authority (TVA). ATSDR conducts its own evaluations of data and makes its own conclusions; it does not depend on previous conclusions and findings from DOE, other governmental agencies (federal, state, or local) or private entities.

In addition, to ensure accuracy of this PHA's data and conclusions the White Oak Creek Radionuclide Releases document underwent several phases of review before its final release, including an internal ATSDR review, a data validation review by other agencies (i.e., DOE, EPA, and the Tennessee Department of Environment and Conservation [TDEC]), an Oak Ridge Reservation Health Effects Subcommittee (ORRHES) review, an independent external peer review, and a public comment review. During the agency's internal review process, individuals within the agency who have the proper background (e.g., toxicology and health physics) carefully reviewed the document for technical content and other aspects. After reviewing comments received from other agencies during the data validation review, ATSDR made changes to the document as appropriate. ORRHES members consisted of individuals representing different expertise, backgrounds, geographic areas, and interests from the communities surrounding the Oak Ridge Reservation. ORRHES had technical experts in toxicology, health physics, medicine, geology, and other disciplines as well. ORRHES members carefully discussed all suggested editorial and technical changes and then submitted recommendations to ATSDR for changing the document. Through its external peer review process, ATSDR's Office of Science had three scientific experts review this public health assessment (see Appendix H for the peer reviewer comments and ATSDR's responses). The agency's peer review process allows an external, thorough evaluation of this PHA by experts in the field that this assessment covers—health physics. During the external review process, individuals (not employed by ATSDR or the CDC) independently reviewed this document and provided their unbiased, scientific opinions of it. ATSDR also presented the data and information used in this public health assessment several times at public meetings, including work group and ORRHES meetings. In addition, during the PHA public comment period, any member of the public can provide comments to ATSDR. The public comments are presented and responded to within this appendix.

Regarding EPA CERCLA guidance, please see the response to comment 44 in this appendix describing the differences between risk assessments and public health assessments.

HHS and DOE's Office of Health Studies collaboratively develop an Agenda for HHS Public Health Activities at DOE Sites, including the Oak Ridge Reservation. The most recent version of the agenda is available online at http://www.eh.doe.gov/health/documents/Agenda2003-08.pdf . The agenda includes HHS committees' proposals for health studies and public health activities for DOE sites. In addition, for some sites such as the Oak Ridge Reservation, the agenda includes feedback provided during open public meetings. The agenda identifies issues needing attention at each DOE site and outlines proposed future public health activities. A draft agenda is released for public comment and the input received is reflected in the final agenda.

In 2001, ATSDR scientists conducted a review and analysis of the Phase I and Phase II screening evaluation of the Tennessee Department of Health's (TDOH) Oak Ridge Health Studies, available at http://www2.state.tn.us/health/CEDS/OakRidge/ORidge.html to identify contaminants that require further public health evaluation. In the Phase I and Phase II screening evaluation, TDOH conducted extensive reviews of available information and conducted qualitative and quantitative analyses of past (1944–1990) releases and off-site exposures to hazardous substances from the entire Oak Ridge Reservation. Having reviewed and analyzed Phase I and Phase II screening evaluations, ATSDR scientists are conducting nine public health assessments on: Y-12 uranium releases, White Oak Creek radionuclide releases, off-site groundwater, Toxic Substances Control Act (TSCA) Incinerator releases, Y-12 mercury releases, X-10 iodine 131 releases, K-25 uranium and fluoride releases, PCB releases from X-10, Y-12, and K-25, and a current screening (1990 to 2003) of environmental data. For copies of these public health assessments, please contact ATSDR's Information Center toll-free at 1-888-422-8737.

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With respect to ATSDR work at Oak Ridge, the local situation has become quite serious. There appears to be willful administrative intent to ignore both internal and outside comments and criticism.

Members of the local ORR Health Effects Subcommittee have been allowed to influence discussions and voting procedures who have known organizational and economic conflicts of interest. Yet, few members of the ORRHES have the required expertise in dose reconstruction, risk evaluation, and quantitative uncertainty analysis in order to effectively oversee the technical work of ATSDR and properly interpret past work in dose reconstruction conducted at Oak Ridge. Those who have raised critical concerns and comments have been summarily dismissed.

In 1999, ATSDR established the Oak Ridge Reservation Health Effects Subcommittee (ORRHES) under the laws, rules, and guidelines of the Federal Advisory Committee Act (FACA) to provide ATSDR with advice and recommendations related to public health activities and research at the ORR. FACA requires all committee members to be "fairly balanced in terms of the points of view represented and the functions to be performed." As a result, the selected subcommittee members consisted of individuals representing different expertise, backgrounds, geographic areas, and interests. ORRHES had technical experts in toxicology, health physics, medicine, geology, and other disciplines as well.

Regarding the statement concerning ORRHES members having known conflicts of interest, every ORRHES member was considered a special government employee. Under this role, each subcommittee member had to comply with the Standards of Ethical Conduct for Employees of the Executive Branch, Conflict of Interest Statues, the U.S. Department of Health and Human Services (HHS) Standards of Conduct, and regulations governing confidentiality and procurement integrity. Under these guidelines, ORRHES members had to be impartial in their roles and responsibilities while serving on the subcommittee.

All ORRHES meetings followed the operation of FACA. ORRHES and work group meetings were open to the public, and ATSDR considered feedback and opinions from public members as well as from ORRHES members. The subcommittee voted to use Robert's Rules of Order, and operated its meetings in accordance with these guidelines. No individual ORRHES member was able to influence or change these established rules governing the subcommittee and its operations. Every change and recommendation in ORRHES was not accepted unless it was approved by a two-thirds majority vote within the subcommittee. Though ATSDR gave significant weight to the ORRHES's consensus recommendations when making its decisions, ATSDR retained independent decision-making authority for public health activities. Over the past 5 years, more than 25 ORRHES and 135 work group meetings were held. During this time, ATSDR staff members gave numerous technical presentations on public health assessments and related issues to ORRHES and work groups and technical experts in various disciplines presented to ORRHES as well. For information on meeting agendas and meeting minutes, please visit the ORRHES Web site at http://www.atsdr.cdc.gov/HAC/oakridge/.

In addition, all nine public health assessments undergo several phases of review, including internal ATSDR review, a data validation review by other agencies (i.e., DOE, EPA, and TDEC), an ORRHES review, an independent peer review, and a public comment review (see the response to comment 70 for more details). Thus, even though participants at ORRHES and work group meetings provided expertise in these areas mentioned by the commenter (i.e., dose reconstruction, risk evaluation, and quantitative uncertainty analysis), these are not the only individuals reviewing this document. It undergoes several rounds of review by experts in these fields of study and other areas of interest for this document (e.g., health physics). All comments received during the public comment period and review are responded to and included within this appendix in the final PHA. In addition, comments received by the peer reviewers and ATSDR's responses are included in Appendix H of the final PHA.

Additional Comments

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Page 5, line 4: ATSDR needs to amplify its very limited bibliography to, at a minimum, include the website for DOE's OREIS database and users guide. (Comment received on the initial release PHA dated December 2003.)

The Oak Ridge Environmental Information System (OREIS) has been added to the reference list. The references presented in Section XII of this PHA include the resources used to prepare this final PHA. Though the documents such as reports, the OREIS users guide, and other available information about the ORR are numerous, only resources used to prepare the report are presented in the reference list.

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Page 7, Line 24. There was another facility near this location as well, the S-50 plant. We believe that it was a nuclear reactor used to make an atomic aircraft. The project was subsequently abandoned. This should be included here because it is on the map in Figure 1, and its contaminants possibly are still in place, especially Co-60, Sr-90, and Cs-137. (Comment received on the initial release PHA dated December 2003.)

ATSDR scientists conducted a review and analysis of the Phase I and Phase II screening evaluation of the Tennessee Department of Health's (TDOH) Oak Ridge Health Studies to identify contaminants that require further public health evaluation. In the Phase I and Phase II screening evaluation, TDOH conducted extensive reviews of available information and conducted qualitative and quantitative analyses of past (1944–1990) releases and off-site exposures to hazardous substances from the entire Oak Ridge Reservation. Using this review, ATSDR scientists are conducting nine public health assessments on

• Y-12 uranium releases,
• White Oak Creek radionuclide releases,
• off-site groundwater,
• Toxic Substances Control Act (TSCA) Incinerator releases,
• Y-12 mercury releases,
• X-10 iodine 131 releases,
• K-25 uranium and fluoride releases,
• PCB releases from X-10, Y-12, and K-25, and
• a current screening (1990 to 2003) of environmental data.

For copies of these public health assessments, please contact ATSDR's Information Center toll-free at 1-888-422-8737. As noted, this includes a public health assessment on uranium and fluoride releases from the K-25 site, which comprises the former S-50 plant. For more information on the screening evaluation, please see the Phase I Dose Reconstruction Feasibility Study and Task 7 Screening Level Evaluation of Additional Potential Materials of Concern briefs in Appendix D of the final PHA. For additional information on how specific contaminants were identified as requiring further evaluation based on screening evaluations that evaluated past exposures, please see the TDOH's Oak Ridge Health Studies at http://www2.state.tn.us/health/CEDS/OakRidge/ORidge.html .

The S-50 site contained approximately 37 acres and was located next to the K-25 Power House along the Clinch River. This site operated for less than 1 year; however, and is now part of the K-25 site. As all of the facility's buildings were destroyed and buried in 1946, no physical evidence of S-50 at the K-25 site remains. Construction of the former S-50 liquid thermal diffusion plant began on June 6, 1944, and it was fully operational by October 1944. The purpose of the plant was to assess the financial and scientific feasibility of separating uranium 235 (U 235) from uranium 238 (U 238) through liquid thermal diffusion. Because of constant equipment malfunctions and releases to the Clinch River and to the air, the plant was closed in September 1945. The only documented process at the S-50 site was liquid thermal diffusion enrichment between 1944 and 1945.

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Page 12, Figure 4. Location of White Oak Creek (WOC) and the Relationship Between X-10, White Oak Lake, White Oak Dam, the Clinch River, and the Watts Bar Reservoir. In the legend, the direction of primary river flow is indicated. No information indicates the existence of the well-known 'back flow' of the river caused by hydraulic changes in the directional flow due to 'draw downs' in the TVA system, power generation events at Watts Bar, and other events. This is important because the water supply for towns like Kingston is, in fact, water intakes that do draw water from the Clinch River from water that occasionally FLOWS BACKWARDS. This means that even though Kingston's water intake appears to be upstream from the contaminated confluence of tributaries from K-25 Kingston's water intake is actually downstream during frequent river backflow events. This unfortunate set of circumstances means that the entire population of towns like Kingston are drawing water from the contaminated confluence of K-25's tributary to the Clinch. Local citizens are particularly aware of this [backwards flow] during periodic fish kills near Kingston.

Anyone can watch the dead fish float from the K-25 confluence right up to Kingston's water intake for the city. Some citizens have documented these events with photographs, in case ATSDR did not realize that the people of Kingston are, in fact exposed via drinking water because of the backflow events described above. The citizens of communities like Kingston, Spring City, and many others do not believe that ATSDR had done its homework in contemplating the consequences of the backflow events of the Clinch in determining possible routes of exposure by drinking water.

The citizens of communities along the Clinch again do not believe that ATSDR has done an adequate job of determining where the radioactive fish actually are because of Agency's simplistic assumption that fish contaminated by radioactive sediments at the confluence of tributaries draining from waste sites like WOC and K-25 simply stay put. Fish don't stay put. Fish swim around and do leave the area. Some species travel far downstream and upstream. Bottom feeders, which are most probably contaminated via consumption of sediment can be flushed out during reservoir drawdowns and/or power generation events. This means that radioactively contaminated fish are not 'contained' by Watts Bar, but most probably have already either migrated upstream or have been 'flushed downstream.'

(Comment received on the initial release PHA dated December 2003.)

Page 38, line 25: Kingston public water supply is located about one mile up the Tennessee River from the mouth of the Clinch, which is not in the study area; however, at times Clinch River Water can enter the intake on the Tennessee River.

Kingston maintains public water supplies in the vicinity of the Oak Ridge Reservation (see Figure 13). The Kingston water supply has two water intakes, but ORR contaminants would potentially affect only one of the intakes located upstream on the Tennessee River in Watts Bar Lake at Tennessee River Mile (TRM) 568.4. Spring City obtains its water from an intake on the Piney River branch of Watts Bar Lake. The city of Rockwood receives its water from an intake on the King Creek branch of Watts Bar Lake, located at TRM 553. These three intakes could potentially be affected, however, only during reverse flow conditions.

Under the Safe Drinking Water Act, the U.S. Environmental Protection Agency (EPA) has set health-based standards for substances in drinking water and specified treatments for providing safe drinking water since 1974 (USEPA 1999). In 1977, EPA gave the state of Tennessee authority to operate its own Public Water System Supervision Program under the Tennessee Safe Drinking Water Act. Through this program, the Tennessee Department of Environment and Conservation's (TDEC) Division of Water Supply regulates drinking water at all public water systems. As a requirement of this program, all public water systems in Tennessee individually monitor their water supply for EPA-regulated contaminants and report their monitoring results to TDEC. The public water supplies for Kingston, Spring City, Rockwood, and other supplies in Tennessee are monitored for substances that include 15 inorganic contaminants, 51 synthetic and volatile organic contaminants, and 4 radionuclides. See http://www.epa.gov/safewater/pws/pdfs/qrg_smonitoringframework.pdf for EPA's monitoring schedules for each contaminant.

On a quarterly basis, TDEC submits the individual water supply data to EPA's Safe Drinking Water Information System (SDWIS). According to EPA's SDWIS, the Kingston, Spring City, and Rockwood public water supply systems have not had any significant violations. To access information related to these and other public water supplies, go to EPA's Local Drinking Water Information Web Site at http://www.epa.gov/safewater/dwinfo.htm .

In addition, in 1996 TDEC's DOE Oversight Division began to participate in EPA's Environmental Radiation Ambient Monitoring System (ERAMS). As part of the Oak Ridge ERAMS program, TDEC collects samples from five facilities on the ORR and in its vicinity. Under the Oak Ridge ERAMS, TDEC collects finished drinking water samples from the Kingston Water Treatment Plant on a quarterly basis and then submits the samples to EPA for radiological analyses. The contaminants sampled at the Kingston Water Treatment Plant are presented in Section II.F.3. of the final PHA. TDEC has also conducted filter backwash sludge sampling at Spring City because radioactive contaminants from the ORR could potentially move downstream into community drinking water supplies. TDEC analyzed Spring City samples for gross alpha, gross beta, and gross gamma emissions. To inquire about your drinking water, please call TDEC's Environmental Assistance Center in Knoxville, Tennessee at 1-865-594-6035 or call EPA's Safe Drinking Water Hotline at 1-800-426-4791. More details are also available at EPA's Safe Drinking Water Web site at http://www.epa.gov/safewater/ .

For past exposure, Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) (presented in Section III.B.2. Past Exposure of the final PHA) estimated the amount of radiological contamination resulting from Clinch River backflow that could have entered the Kingston water intake, as well as the effect of water treatment on the drinking water. Nonetheless, under drinking water ingestion in Section III.B.2. of the final PHA, the following was added to the discussion of how the Task 4 team evaluated drinking water for the city of Kingston: "Water from the Clinch River can travel up the Tennessee River when the Clinch River's flow is greater than the Tennessee River's flow. As a result of this backflow, the city of Kingston could receive Clinch River water. The Task 4 team estimated 1) the amount of radiological contamination resulting from Clinch River backflow possibly entering the Kingston water intake and 2) the effect of water treatment on the drinking water."

Although during backflow Clinch River water can enter these intakes, this water is treated before it is distributed to Kingston city drinking water consumers. Further, the past estimated whole-body lifetime (over 70 years) dose from ingestion of city of Kingston drinking water was 1.4 mrem, which is more than 3,500 times less than ATSDR's radiogenic cancer comparison value of 5,000 mrem over 70 years. Because of strict regulatory guidelines and water treatment prior to distribution, potential current and future exposures to harmful levels of radionuclides in the home from municipal water use are expected to be limited—monitoring data indicate that drinking water has met safe drinking water standards for radionuclides.

Regarding the "fish kills" mentioned by the commenter, it is important to note that there has never been enough (at least 2,000 rad) acute radioactive pollution in the Clinch River or White Oak Creek to kill fish.

The highest radiation doses for past exposures to the Clinch River were associated with consuming fish collected from the Clinch River near Jones Island. For fish ingestion near Jones Island, ATSDR's derived annual whole-body dose was less than 3.4 mrem/year—nearly 30 times less than the 100 mrem/year dose limit recommended for the public by the International Commission on Radiological Protection (ICRP), the U.S. Nuclear Regulatory Commission (NRC), and the National Council on Radiation Protection and Measurements (NCRP). The lifetime whole-body dose from ingesting fish near Jones Island was 238.6 mrem over 70 years, which is more than 20 times less than ATSDR's radiogenic cancer comparison value of 5,000 mrem over 70 years. Because even the worst-case scenario was not found to be a public health hazard, areas downstream of White Oak Creek—where X-10 radionuclide concentrations would be lower—would also not be expected to pose a hazard.

Please note that the White Oak Creek study area, as shown in Figure 11 and discussed throughout the final PHA, consists of the area along the Clinch River and the Lower Watts Bar Reservoir from the Melton Hill Dam to the Watts Bar Dam. In the final PHA, please also see Figure 13 and Figure 14 for the location of the Kingston water intake included in this study area. Further, page 90 of the final PHA discusses how Clinch River water can enter the Kingston water intake.

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Page 15, Line 12. What were the major components of these liquid wastes which were discharged into White Oak Creek (WOC)? According to the ORHASP Final Report, p. 40, releases of Cs-137, which contributed most to the risk, were highest in 1955 to 1959. WOC was drained in 1955 and the lake stayed low until 1960. This allowed the high creek flows accompanying heavy rains, especially in the winter and early spring of 1956, to scour the sediments in which radionuclides had accumulated. Releases during these years are believed to be responsible for the relative high concentrations of Cs-137 found in subsequent cores and samples from WOC below: the lake, the Clinch River, and lower Watts Bar. Additionally, because Cs-137 is in the same chemical periodic table family as Potassium (K), it, like K, Cs-137 in the environment is incorporated into the flesh of fish and other aquatic species. Were there also large releases of Sr-90 as well? ATSDR's Public Health Assessment (PHA) is apparently silent on this.

Page 38 of the ORHASP Final Report indicates that the main radionuclides releases to WOC were: Cs-137, Ruthenium-106 (Ru-106), Co-60, and Sr-90. The releases of Sr-90 are particularly important to human health because, analogous to Cs-137 substituting for K, Sr-90 is likewise in the same chemical periodic table family as Calcium (Ca). Consequently, Sr-90 in the environmental will bioaccumulate into the bones of fish. Thereby, if fish are either stewed or made into patties the Sr-90 in the fish bone will end up in the bones of the people who consume them. (Comment received on the initial release PHA dated December 2003.)

See Table 2 in the final PHA for the estimated discharges of radionuclides from White Oak Creek to the Clinch River as reported in the Clinch River/Poplar Creek remedial investigation/feasibility study (RI/FS) (http://www.osti.gov/bridge/servlets/purl/226399-5omhIT/webviewable/226399.pdf ). The radionuclides expected to be of most concern are depicted in gray—cesium 137, ruthenium 106, strontium 90, and cobalt 60. Table 3 in the final PHA presents a summary of the peak annual releases from White Oak Dam for the eight key radionuclides as reported in the Oak Ridge Dose Reconstruction Project Summary Report (available at http://www2.state.tn.us/health/CEDS/OakRidge/ProjSumm.pdf ). In addition, see Section III.B.2. Past Exposure in the final PHA for a description of the screening evaluations conducted in the Task 4 of the TDOH's Reports of the Oak Ridge Dose Reconstruction: Radionuclide Releases to the Clinch River from White Oak Creek on the Oak Ridge Reservation—an Assessment of Historical Quantities Released, Off-Site Radiation Doses, and Health Risks (referred to as the "Task 4 report"). A brief on the Task 4 report is also available in Appendix D of the final PHA and the report can be viewed at http://www2.state.tn.us/health/CEDS/OakRidge/WOak1.pdf .

There were also large releases of strontium 90 in addition to cesium 137 releases. This is mentioned throughout the PHA (see Sections II.C., III.B.2., and III.B.3) and past, current, and future potential exposures to this radionuclide are evaluated in this document. According to the RI/FS for the Clinch River/Poplar Creek, since 1944 the X-10 radionuclides disposed of in the largest quantities—either via on-site burial or liquid waste discharge to pits and trenches—are cesium 137, strontium 90, and unidentified beta emitters. Please note, however, that these are releases that occurred on site. ATSDR only evaluated radionuclides released into White Oak Creek that traveled off site into the Clinch River and the Lower Watts Bar Reservoir.

Strontium 90 is chemically similar to calcium and tends to deposit in bone and blood-forming tissue (bone marrow). Accordingly, strontium 90 is referred to as a "bone seeker." For evaluating past exposures, ATSDR summarized the Task 4 organ doses for the bone, lower large intestine, red bone marrow, breast, and skin. The contaminants of concern, particularly strontium 90 and cesium 137, tend to concentrate in these organs. For current exposures at the Lower Watts Bar Reservoir, ATSDR evaluated fish sampled for cesium 137, cobalt 60, and strontium 90 and estimated whole-body doses resulting from potential exposure to these contaminants via fish consumption. For strontium 90, ATSDR assumed that the meal could include some bone. For current exposures for the Clinch River, ATSDR evaluated cesium 137, cobalt 60, strontium 90, yttrium 90, americium 241, and hydrogen 3 based on the Oak Ridge Environmental Information System (OREIS) fish data. ATSDR evaluated the critical organ for each radionuclide and estimated the radiation dose delivered to the whole body. These evaluations show that the level of potential radiological exposure from radioactive contaminants in Clinch River and Lower Watts Bar Reservoir fish do not represent a past, current, or future public health hazard. This evaluation is discussed in detail in Section III.B. Exposure Evaluation of the Clinch River and Lower Watts Bar Reservoir in the final PHA.

For information on fish advisories, please refer to the response to comment 9 in this appendix.

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Page 22, line 18: "The building of a coffer cell dam to prevent the backflow of water from the Clinch River into White Oak Creek Embayment:" Prior to 1963 there was little backflow into White Oak Creek embayment except during floods on the Clinch River. However, in 1963 Melton Hill Dam was impounded and became a peaking unit which means that water from the dam was released during the morning and evening hours for a short period of time to meet the increased electrical demands. However, the amount released was about equivalent to the daily flow of the Clinch River at White Oak Creek. This large volume released from Melton Hill Dam would cause a backflow up White Oak Creek Embayment and would result in the scouring of sediment from the embayment. The large amount of Cesium-137 released in 1956 after the draining of White Oak Dam that had been covered by sedimentation was gradually uncovered by the backflow of water from Melton Hill Dam that was being transported into the Clinch River.

This change in flow of water below Melton Hill Dam also changed the distribution of radionuclides released into the Clinch River. Whereas previously a more or less constant flow of water passed the mouth of White Oak Creek, afterwards (except during peaking operations) there was virtually no flow past the mouth of White Oak Creek. The outflow from White Oak Creek would often flow upstream in the Clinch River.

Thank you for your suggestions. We have similar text on pages 14, 17, and 25 of the final PHA, and incorporated some of these suggested changes into that text.

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Page 28, Line 5. Regarding these eight 'experimental' plots – was this an actual DOE experiment, or actually a cheap-and-dirty disposal practice, similar to the common practice of drying municipal sewage on land? (Comment received on the initial release PHA dated December 2003.)

The referenced section is no longer within the main text, but in Appendix B of the final PHA. As discussed in the record of decision for the waste area grouping (WAG) 13 cesium plots (available at http://www.epa.gov/superfund/sites/rods/fulltext/r0493137.pdf ), these plots are the result of an actual U.S. Department of Energy (DOE) experiment at the Oak Ridge National Laboratory (ORNL) to simulate conditions of a nuclear fallout. These plots are located on site and access is restricted. In this public health assessment, ATSDR evaluates exposures occurring off site only.

In 1968, each of four 33-by-33-foot treatment plots were contaminated with 2.2 curies of cesium 137 via fusing the cesium with silica sand particles at high temperatures; four "control" plots were not contaminated. Cesium 137 was selected because it is a long-lived component of weapons fallout. The main purpose of the experiment was to evaluate the long-term, low-dose effect of radiation to the environment, specifically to vegetation. The plots occupy an approximate 6-acre area and are enclosed by a perimeter fence. Sheet metal, extending 18 inches below and 24 inches above ground surface, enclosed each plot.

Before the experiment, ORNL researchers suspected that the fused cesium particles would not migrate horizontally in any direction or more than 6 to 12 inches vertically. Soil samples collected at the site in 1987 indicated, however, that cesium had migrated horizontally in a northwest plume of several feet and vertically to depths of 3 to 4 feet. To prevent potential threats to public health and the environment, remedial actions were conducted and finished in July 1994.

The main aspects of the interim action were:

• excavating soil until contamination was reduced to permissible levels;
• placing extracted soil into boxes made to store low-level radioactive waste;
• moving the soil to the low-level waste silos at WAG 6; and
• placing a porous liner, clean fill material, and a clean top layer of soil into each excavated plot.

Since completion of the interim action, a fence containing many locked gates has enclosed WAG 13. Several signs are posted to notify people of on-site soil contamination and of restricted access to the site. In addition, the site is inspected on a quarterly basis.

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Page 28, Line 27. What is meant by "uncontrolled?" It should intend that the contaminated sediments from WOC moved offsite to the Clinch River, onto Watts Bar, and to other downstream locations. Most probably, these contaminated sediments, and the bottom fish and other aquatic organisms that feed on them, have undoubtedly been flushed far and wide through the TVA system. The extent of this spread either through electrical power generation events or drawdowns in the series of TVA reservoirs has likely spread these sediments and the aquatic organisms that feed on them to at least Mocassin Bend in Chattanooga, TN if not to the TVA confluence at Paducah, KY. For ATSDR to simply postulate that the dam at Watts Bar contains the problem and the dredging these radioactive sediments is not an option is baseless.

The citizens of Oak Ridge, Kingston, Spring City, and all other downstream communities along the hundreds of miles of the TVA system from Clinch River Mile 1 to the confluence of the Tennessee and Ohio Rivers are not buying it. All of these stakeholders insist that ATSDR start sampling sediments from at least Oak Ridge to at least the embayment at Mocassin Bend in Chattanooga. Otherwise, ATSDR doesn't really know which sediments are affected downstream, who is actually exposed now, and who is likely to be exposed in the future from radioactive contamination of fish and other aquatic organisms all along the TVA system. (Comment received on the initial release PHA dated December 2003.)

Please note that the referenced section is no longer within the main text, but in Appendix B of the final PHA. "Uncontrolled" refers to how surface sediments containing cesium 137 and other sediment-bound contaminants in the White Oak Creek Embayment can erode and be transported downstream to the Clinch River system. Daily releases of water from Melton Hill Dam and flood flows in White Oak Creek caused water to surge into and out of the White Oak Creek Embayment, resulting in the erosion of cesium 137 and other contaminant-containing sediments. In the early 1990s, however, a sediment retention structure was built at the mouth of White Oak Creek to retain the sediments in the lower White Oak Creek Embayment and lessen the off-site movement of the sediments to the Clinch River and the Watts Bar Reservoir.

According to various studies, most of the sediment-associated contaminants released from the Oak Ridge Reservation collected in the Lower Watts Bar Reservoir. Therefore, concentrations of sediment-associated contaminants released from the reservation are significantly lower in reservoirs located downstream of Watts Bar Dam. Past studies have found that detected levels of contaminants released from the ORR into the Tennessee River system—below the Watts Bar Dam—are far below levels found to be hazards for human health in the Watts Bar Reservoir baseline risk assessment. If ATSDR believed that the sediments and fish were a public health issue, then we would recommend that additional sampling be conducted. The findings in this PHA, past studies on the Tennessee River system, and ongoing monitoring programs, however, show that additional sampling is unnecessary.

The record of decision (ROD) for the Lower Watts Bar Reservoir (available at http://www.epa.gov/superfund/sites/rods/fulltext/r0495249.pdf ), issued by the U.S. Department of Energy (DOE) and supported by the U.S. Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC), determined that buried sediments remaining in place pose no health risk because of the absence of any exposure pathway for humans. In 1996, ATSDR conducted a health consultation on the Lower Watts Bar Reservoir that concurred with the ROD. ATSDR reviewed these findings in this public health assessment and we continue to support this conclusion. Based on our findings in this PHA, we concur with DOE, EPA, and TDEC that leaving deep sediments in place poses no public health hazard. According to the record of decision and ATSDR's evaluations, the only threat to human health was associated with the consumption of certain fish species due to PCB contamination—no health hazards were found to be associated with ORR-related radionuclide releases in Watts Bar Reservoir sediment (if left undisturbed), surface water, or biota.

Please note: as shown in Figure 11 and discussed throughout the final PHA, the White Oak Creek study area consists of the area along the Clinch River and the Lower Watts Bar Reservoir from the Melton Hill Dam to the Watts Bar Dam.

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Page 28, Line 28. What are the radiological measurements of this area, both before and after 'remediation?' If these areas have actually been 'remediated' to acceptable levels of public exposure, why is the hazard warning signage still in place?

(Comment received on the initial release PHA dated December 2003.)

Please note that the referenced section is no longer within the main text, but in Appendix B of the final PHA. This section of the document refers to the White Oak Creek Embayment located on site at the reservation where access is restricted; our public health assessment evaluates radionuclides that traveled off site.

Sediment samples collected in summer 1990 from the lower portion of the White Oak Creek Embayment showed the presence of cesium 137 and cobalt 60 in near-surface sediment (upper 2 to 4 inches). Levels of cesium 137 were higher than expected—a finding based on sediment samples collected at the embayment in 1979 and 1984 that showed contamination only in deeper sediment (about 1 to 2 feet below surface). These results in 1990 caused concern: White Oak Creek Embayment sediments were uncontrolled at that time, meaning surface sediments could erode and travel downstream to the Clinch River.

As explained in Appendix B of the final PHA, in the early 1990s a removal action was conducted at the embayment. This action consisted of building a sediment retention structure at the mouth of White Oak Creek in the early 1990s to prevent contaminants in surface sediments from traveling from the White Oak Creek Embayment to the Clinch River system. Thus, this time-critical removal action resulted in retaining the sediments in the lower embayment and reducing off-site movement of the sediments to the Watts Bar Reservoir and the Clinch River. In 2001, after about 10 years of data collection and monitoring, a remediation effectiveness report suggested discontinuing regular water level monitoring at the embayment because data showed that the sediment retention structure prevented scouring of the embayment and sustained sediment water coverage.

Completed and ongoing actions at the reservation, including those associated with the White Oak Creek Embayment, are published annually in a remediation effectiveness report (RER). The RER is available at the DOE Information Center located at 475 Oak Ridge Turnpike, Oak Ridge, Tennessee (telephone number: 1-865-241-4780).