PUBLIC HEALTH ASSESSMENT

80

Page 35, Line 24. Regarding the "contaminated sediment from the high flux isotope reactor (HFIR) ponds." Which specific radionuclides are related to this process? Which are known to be in this 'contaminated sediment?' Are these contaminated sediments still in place or have they been removed? If they have been removed, where did they go? Are they still at DOE ORR? Have they been taken to an offsite location? If they are still in the bottom of the HIFR ponds are they continuing to leach into WOC?

ATSDR needs to be more forthcoming about the nature, extent, and actual location of these contaminated sediments and whether or not they still pose an ongoing public health hazard. What is the actual state of affairs here? Are these contaminants still there leaking into the groundwater? Are the citizens of Oak Ridge and downstream communities still at risk from leachate from the HFIR ponds into WOC? Which is ostensibly ATSDR's main purpose in producing this PHA?

(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. In addition, it is important to understand that the high flux isotope reactor ponds (HFIR) are located on site at the reservation; this public health assessment evaluates radionuclides released to White Oak Creek that traveled off site into the Clinch River and the Lower Watts Bar Reservoir. Nonetheless, we would like to provide responses to your questions below.

The HFIR at the Oak Ridge National Laboratory (ORNL) has operated since 1966 to produce radioisotopes for medical, academic, and industrial purposes, as well as perform other scientific functions (e.g., irradiation tests and experiments). The HFIR uses highly enriched uranium 235 as fuel for this light water-cooled reactor. Radioisotopes produced at the HFIR include einsteinium 253, iridium 192, platinum 195, berkelium 249, lutetium 177, cobalt 60, nickel 63, californium 252, holmium 166, tin 177, fermium 257, tungsten 188, rhenium 186, and others.

From the 1960s until 1986 radioactive contaminants related to processes at the HFIR were placed into four ponds, also referred to as surface water impoundments or subbasins. These ponds, located south of the HFIR building, are inactive and lie along Melton Branch. According to the Melton Valley remedial investigation, no data are available on radionuclides in HFIR pond sediment. Sediment data show, however, the presence of cobalt 60 and cesium 137 in contaminated sediment along Melton Branch downstream of the HFIR facility. Soil data for the ponds show the presence of cesium 137, cobalt 60, strontium 90, and thorium 288. Primarily, cesium 137 and cobalt 60 are contaminants of concern for the area. But according to the ORNL's risk assessment information system (available at http://risk.lsd.ornl.gov/maps/x-10/x10_relsites.shtml ), these disposal ponds have not released radionuclides.

Because of the short half-life of cobalt 60 (5.3 years), releases of this contaminant from the HFIR ponds has decreased to the point of no longer being detectable in surface water near the ponds. A surface water monitoring location on Melton Branch is just downstream of the HFIR drainage areas. In 1993 and 1994, these areas only contributed <1% of tritium and <0.2% of strontium 90 releases into White Oak Dam, but reportedly contributed 17.2% of cesium 137 to White Oak Dam based on remedial investigation data for waste area grouping (WAG) 5 (though data at this monitoring station usually show nondetects for cesium 137).

Excavation activities began in summer 2004 to remove contaminated sediment at the four HFIR ponds—7905, 7906, 7907, and 7908. The HFIR ponds, built for storing wastewater from the HFIR and for providing further settling before treatment or discharge to surface waters, are clay-lined, earth-bermed, and open. The ponds are located in Melton Valley, a restricted area of the reservation remaining under DOE control. Remediation goals were established based on anticipated future use of the land. No residents have access to this land and future use is expected to remain industrial. The waste is being disposed of on site at the Oak Ridge Environmental Management Waste Management Facility (EMWMF) located in Bear Creek Valley near the Y-12 Plant. In addition, contaminated soils, liquids, and sludges associated with the ponds will be removed.

According to the Melton Valley remedial investigation, no groundwater contaminants of concern associated with the HFIR ponds have been identified. For information on ATSDR's evaluation of off-site exposure to groundwater related to the ORR, please refer to the PHA titled Evaluation of Potential Exposures to Contaminated Off-site Groundwater From the Oak Ridge Reservation (USDOE) (available at http://www.atsdr.cdc.gov/HAC/PHA/region_4.html#groundwater). Copies of this and other ATSDR documents are available from the ATSDR Information Center. The center can be reached toll-free at 1-888-422-8737.

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 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. Based on our evaluation, 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, or who currently do so or will in the future. Thus, even if radionuclide releases did occur from the HFIR ponds to White Oak Creek, exposures to radionuclide releases from the creek via the Clinch River and the Lower Watts Bar Reservoir would not be expected to cause adverse health effects.

81

Page 36, Line 9. Offsite Locations. Name the top twenty radioactive contaminants that have actually been released to the Clinch River and Watts Bar Reservoir from WOC. Give an estimate of the respective curie loads of each of these radionuclides. Cite the actual levels of these radionuclides in fish sampling data in the OREIS database.

The DOE ASERs (Annual Site Environmental Reports) contain data volumes that are available to stakeholders. For example, these data volumes cite that Cs-137 concentrations in fish filets is 0.44 pCi/gm, which should be a significant risk driver for further investigations far downstream of DOE ORR. If the sediments contain Cs-137 and Sr-90 then the bottom feeding fish surely contain these radionuclides as well. This is amply demonstrated in both DOE's ASERs and its OREIS database. (Comment received on the initial release PHA dated December 2003.)

As presented in Section III.B.2. Past Exposure in the final PHA and discussed in the Oak Ridge Health Agreement Steering Panel (ORHASP) report titled Releases of Contaminants from Oak Ridge Facilities and Risks to Public Health (available at http://www2.state.tn.us/health/CEDS/OakRidge/ORHASP.pdf ), an initial evaluation conducted by Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) identified 24 radionuclides that were released to the Clinch River via White Oak Creek from 1944 to 1991: americium 241, barium 140, cerium 144, cobalt 60, cesium 137, europium 154, hydrogen 3, iodine 131, lanthanum 140, niobium 95, neodymium 147, phosphorus 32, promethium 147, praseodynium 143, plutonium 239/240, ruthenium 106, samarium 151, strontium 89, strontium 90, thorium 232, uranium 235, uranium 238, yttrium 91, and zirconium 95. The Task 4 team identified eight key radionuclides of potential concern based on its screening analysis: cobalt 60, strontium 90, niobium 95, ruthenium 106, zirconium 95, iodine 131, cesium 137, and cerium 144. Table 3 in the final PHA presents the peak annual releases in curies for these key radionuclides.

In Section III.B.3. Current and Future Exposure of the final PHA, the maximum radionuclide concentrations are presented for Lower Watts Bar Reservoir sediment (Table 13), surface water (Table 14), and fish (Table 15). In addition, as mentioned in the final PHA, ATSDR obtained data in electronic format from the Oak Ridge Environmental Information System (OREIS) (detailed throughout the document and 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 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).

DOE's annual site environmental reports (ASERs) are included in OREIS. Please refer to Section II.F.4 of the final PHA and the response to comment 54 for a detailed discussion on OREIS.

82

Page 36, Line 9. Offsite Locations. The ATSDR BRA (Baseline Risk Assessment), which unfortunately established PCBs, instead of strontium-90 and cesium-90, is fatality and irrevocably flawed and must be redrafted.

ATSDR's finding of 'No Public Health Risk' is irresponsible at best and possibly fraudulent. This BRA is not supported by the high levels of Sr-90 and Cs-137 documented in DOE's own fish sampling data in DOE's own OREIS database.

As long as these radioactive sediments remain in place they are and will continue to be mobilized in the environment and bioaccumulation in fish and other aquatic organisms — and on to those people consuming them. The risk of consuming PCBs in these fish, compared to the risks of ingesting radioactively contaminated fish is literally a 'red herring' foisted onto stakeholders in these downstream communities in order to quell their legitimate public health concerns.

The citizens of Oak Ridge, Kingston, Spring City, and all other communities downstream absolutely reject out-of-hand ATSDR's patronizing, condescending finding of 'No Risk' from these contaminated sediments. Stakeholders demand that ATSDR immediately reorient itself to the reality of the existing DOE and TVA fish tissue data. ATSDR must attempt to redeem itself by reworking this fatally flawed BRA and try to earn the trust of these stakeholders now, which it certainly neither has nor deserves. (Comment received on the initial release PHA dated December 2003.)

As a clarification, the commenter refers to a U.S. Department of Energy (DOE) baseline risk assessment in the remedial investigation/feasibility study for Clinch River/Poplar Creek available at http://www.osti.gov/bridge/servlets/purl/226399-5omhIT/webviewable/226399.pdf . This was not an assessment conducted by ATSDR. It is important to note that the findings of the baseline risk assessment were approved and agreed to by the U.S. Environmental Protection Agency (EPA), the Tennessee Department of Environment and Conservation (TDEC), and DOE. ATSDR's findings in this final public health assessment concur with the findings of the baseline risk assessment that radionuclides in fish, sediment, and surface water in the Clinch River do not present a health hazard.

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 .

Although radionuclides and other contaminants might be 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, the 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 ATSDR's public health assessment on PCBs can be obtained by contacting ATSDR's Information Center toll-free at 1-888-422-8737.

83

Page 39, Line 4-5. Any objective environmental scientist, with access to the OREIS database, can demonstrate many instances as to why this uninformed statement is wholly fallacious. (Comment received on the initial release PHA dated December 2003.)

As reported in the record of decision (ROD) for the Lower Watts Bar Reservoir, human health standards would not be met if deep channel sediments containing cesium 137 were dredged and placed in a residential area. The ROD concluded, however, that these sediments, if left in place and undisturbed, pose no human health threat: no exposure pathway exists to the contaminants in the deep sediment. ATSDR has reviewed and evaluated the Oak Ridge Environmental Information System (OREIS) data and reports indicating the presence of radionuclides in the deep channel sediments (beneath several meters of water and 40 to 80 centimeters of sediment) of the Lower Watts Bar Reservoir. In addition, in 1996 ATSDR prepared a health consultation to review various potential exposures associated with the reservoir. We concluded that the current levels of radiological contaminants in sediment posed no public health hazard and recommended that reservoir sediment not be removed, disturbed, or disposed of without prior careful review of sediment sampling data for the specific area.

Furthermore, as discussed in the final PHA in Section III.B.3. Current and Future Exposure, since February 1991 the Watts Bar Interagency Agreement has set guidelines related to any dredging in the Watts Bar Reservoir and for reviewing potential sediment-disturbing activities in the Clinch River below Melton Hill Dam. Under this agreement, the Watts Bar Reservoir Interagency Working Group (WBRIWG) reviews permitting and other activities, either public or private, that could possibly disturb sediment, such as erecting a pier or building a dock. The WBRIWG consists of the U.S. Department of Energy (DOE), the U.S. Environmental Protection Agency (EPA), the U.S. Army Corps of Engineers (USACE), the Tennessee Department of Environment and Conservation (TDEC), and the Tennessee Valley Authority (TVA) because of their permit authority or their knowledge of the sediment contamination and how that contamination if disturbed could affect the public.

Therefore, based on the enormous amount of data available, ATSDR's own independent evaluation of the deep channel sediment at the reservoir, and controls in place to prevent the disturbance of deep channel sediment, ATSDR believes that this finding approved by DOE, EPA, and TDEC is supported by the available data indicating that because of the absence of an exposure pathway, people would not come in contact with cesium 137 buried in deep channel sediment.

84

Page 43, Figure 13. Map of the White Oak Creek Study Area. The study area does not extend far enough downstream. It should include at least all downstream communities that appear in the Spatial Query Tool of the DOE OREIS database. More appropriate would be to include other sampling sites that TVA has included in its analyses of radioactively contaminated fish. Yes, these data are available too, if stakeholders ask for them. Certainly, ATSDR should be interested too. More appropriately, the study area should extend to at least to the TVA embayment at Mocassin Bend in Chattanooga — if not the entire TVA dendritic system, which extends to Paducah, KY. (Comment received on the initial release PHA dated December 2003.)

The White Oak Creek study area (see Figure 11 in the final PHA) consists of the area along the Clinch River from the Melton Hill Dam to the Watts Bar Dam. Past studies have shown that most sediment-associated contaminant releases from the reservation have collected in the Lower Watts Bar Reservoir. Concentrations of ORR-related sediment-associated contaminants have been detected at much lower levels in reservoirs located downstream of the Watts Bar Dam, and accordingly, also at concentrations well below levels found to be of human health concern. ATSDR extended its evaluation in this public health assessment to the Watts Bar Dam because this is the downstream boundary of the reservation.

No public health hazards associated with ORR releases have been identified downstream of Watts Bar Dam. This information is based on many past studies and a baseline risk assessment prepared for the Lower Watts Bar Reservoir. Please see the record of decision for the Lower Watts Bar Reservoir for more information at http://www.epa.gov/superfund/sites/rods/fulltext/r0495249.pdf . The record of decision was issued by the U.S. Department of Energy (DOE), as well as approved by the U.S. Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC). The baseline risk assessment indicated that standards for environmental and human health would not be reached if deep channel sediments with cesium 137 were dredged and placed in a residential area and if people consumed moderate to high quantities of specific fish that contained increased levels of PCBs. But there is no exposure pathway to this deep channel sediment. Thus, areas of the Lower Watts Bar Reservoir do not pose a health hazard for radionuclides. Areas further downstream—where contaminants associated with the ORR have been detected at much lower concentrations than at the Lower Watts Bar Reservoir and at levels not of public health concern would therefore not need to be included in this evaluation of White Oak Creek radionuclide releases to the Clinch River and the Lower Watts Bar Reservoir; they are not an ORR contaminant-related public health hazard.

85

Page 66, Line 3. Why is the DOE OREIS database no longer readily accessible to the public? ATSDR should take immediate steps to insist that DOE be more flexible in granting groups like institutions of higher learning, civic community organizations, churches, civil rights organizations, non-governmental environmental advocacy groups, and indeed any 'legitimate' stakeholder group access to this robust database. These user groups should be given group accounts to the OREIS database, along with the easy to read OREIS Users Guide. ATSDR should take immediate steps to facilitate stakeholders access to this crucial environmental data. Think of the millions of dollars of taxpayers money that went into archiving this data into OREIS. Downstream stakeholders have a fundamental Right-to-Know about the sampling data in OREIS which amply demonstrates that here should, in fact, be considerable concern about the risk manage of environmental releases from DOE ORR. There needs to be a 'sea change' at ATSDR in the project management of this PHA — it is superficial and simply attempts to lull downstream stakeholders into a woefully false sense of security. (Comment received on the initial release PHA dated December 2003.)

The U.S. Department of Energy (DOE) created the Oak Ridge Environmental Information System (ORIES)—an electronic data management system that integrates an abundance of environmental data into a single database. OREIS was developed to facilitate access to environmental data related to ORR operations while also maintaining data quality. DOE's objective was to ensure that the database had long-term retention of the environmental data and useful methods to access the information. OREIS contains data related to compliance, environmental restoration, and surveillance activities. Information from all key surveillance activities and environmental monitoring efforts is entered into OREIS. These include but are not limited to studies of the Clinch River embayment and the Lower Watts Bar, as well as annual site summary reports.

Before September 11, 2001, OREIS was accessible to the public. Following these events, however, access of OREIS was restricted due to sensitive information contained within the database, such as geographic information system (GIS) data identifying locations of buildings on the Oak Ridge Reservation. Today, DOE and its contractors and subcontractors, the U.S. Environmental Protection Agency (EPA), the Tennessee Department of Environment and Conservation (TDEC), ATSDR, and other agencies have access to OREIS through officially obtained user ids and passwords. Members of the public can request a user id and password, but the applicant would have to be sponsored by a DOE or other government representative. The public can contact bjc-oreis@bechteljacobs.org to request a user account and password, but only those with proper sponsorship will be provided access. Further, OREIS could be accessible to the public again soon; DOE's subcontractors are in the process of working on the database so that it can be made publicly available in the near future.

ATSDR is not involved in the management of OREIS or in providing people with access to the database. We understand DOE's need to remove the database from public access due to the sensitivity of information within OREIS, but again, this was not our decision and we have no involvement in OREIS other than using the data contained within it.

86

Page 116, Actual Comment #11, third paragraph, Line 2. The list of potential contaminants of significant concern is inadequate and incomplete. The ORHASP Final Report, in fact, lists eighteen cardinal contaminants of concern as having been released off site by DOE ORR.

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

As a clarification, the statement referenced by the commenter is not a list of potential contaminants of concern. Instead, it is a list of the contaminants for which ATSDR is preparing public health assessments. The rationale for the selection of these contaminants is detailed below.

During Phase I and Phase II of the Oak Ridge Health Studies, the Tennessee Department of Health (TDOH) conducted extensive reviews and screening analyses of the available information and identified four hazardous substances related to past ORR operations that could have been responsible for adverse health effects: radioactive iodine, mercury, polychlorinated biphenyls (PCBs), and radionuclides from White Oak Creek. In addition to the dose reconstruction studies on these four substances, the TDOH conducted additional screening analyses for releases of uranium, radionuclides, and several other toxic substances.

To expand on TDOH efforts—but not duplicate them—ATSDR scientists conducted a review and a screening analysis of the department's Phase I and Phase II screening-level evaluation of past exposure (1944–1990) to identify contaminants of concern for further evaluation. Using this review, in addition to this public health assessment on X-10 radionuclide releases to White Oak Creek, ATSDR scientists are conducting public health assessments on: Y-12 uranium releases, X-10 iodine 131 releases, Y-12 mercury releases, K-25 uranium and fluoride releases, PCB releases from X-10, Y-12, and K-25, and other topics such as the Toxic Substances Control Act (TSCA) incinerator and off-site groundwater. In conducting these public health assessments, ATSDR scientists are evaluating and analyzing the data and findings from previous studies and investigations to assess the public health implications of past, current, and future exposures.

Contrary to the commenter's statement, the Oak Ridge Health Agreement Steering Panel (ORHASP) (see page 72 of its final report at http://www2.state.tn.us/health/CEDS/OakRidge/ORHASP.pdf ) lists the primary Oak Ridge Reservation contaminants as iodine 131, mercury, PCBs, and White Oak Creek radionuclide releases—the same as those identified during the Oak Ridge Dose Reconstruction. The statement questioned by the commenter in ATSDR's public health assessment for which public health assessments are being conducted lists the same contaminants identified as priority contaminants by ORHASP. Further, ATSDR is conducting assessments on additional topics because of community concern, including the TSCA Incinerator, uranium and fluoride releases from K-25, and off-site groundwater.

87

Page 125, Line 6. This statement is not true. This PHA is fatally flawed and should be redone in its entirety. Next time try to have it prepared by competent, credentialed health professionals. This PHA in definitely lacking the caliber of talent that is elemental in such a serious task. Peoples' health and lives are at stake and ATSDR should not be so cavalier in assigning the preparation of this PHA to non-medical staff. We stakeholders, many of us already sick, demand that the next time ATSDR tries to float this PHA that it have at least one medical doctor in charge of its preparation and at least three other physicians sign off on it. ATSDR might think that our health and welfare can be easily discounted by such an inane, superficial, and incompetently prepared PHA. We stakeholders and the State of Tennessee know better and we are not going to stand for this level of tyrannical federal arrogance that ATSDR has demonstrated in its attempt to foist unto us this fatally flawed PHA.

What health professional – meaning a physician or nurse, and not simply a non-medical staff member without any medical or nursing credential – would ever risk putting his or her signature on this – it would be indefensible in federal and state court. Note, by the way, that there is not, in fact any credentialed health professional that ever did sign off on this PHA. See comment regarding the PREPARERS OF REPORT. Of all the fleet of well credentialed physicians that ATSDR has on its payroll, not one, repeat, not one of them has committed his or her signature to this PHA. Stakeholders believe that this is because they well know that if a fatally flawed PHA looks like a duck, walks like a duck, and quacks like a duck – it might be a duck, or some other fowl. (Comment received on the initial release PHA dated December 2003.)

The referenced conclusion was altered slightly in the final public health assessment to the following: "ATSDR concludes that exposures to X-10 radionuclides released from White Oak Creek to the Clinch River and to the Lower Watts Bar Reservoir are not a health hazard. Past and current exposures are below levels associated with adverse health effects and regulatory limits. Adults or children who have used, or might continue to use, the waterways for recreation, food, or drinking water are not expected to have adverse health impacts due to exposure. ATSDR has categorized those situations as posing no apparent public health hazard from exposure to radionuclides related to X-10. This classification means that people could be or were exposed, but that their level of exposure would not likely result in any adverse health effects." Contrary to this commenter's opinion, this conclusion is factual based on ATSDR's thorough evaluation of data, exposure situations, and public health activities associated with radionuclides released from White Oak Creek to the Clinch River and the Lower Watts Bar Reservoir.

Please note that the White Oak Creek Radionuclide Releases PHA underwent several phases of review before its final release, including an internal ATSDR review, a data validation review by other agencies (i.e., the U.S. Department of Energy [DOE], the U.S. Environmental Protection Agency [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 from other agencies received 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. 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 (see Appendix H for the peer reviewer comments and ATSDR's responses). 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 public comment period, any member of the public, including physicians, nurses, and other members of the community, can provide comments to ATSDR, which are included within this appendix. ATSDR uses a multi-disciplinary approach for reviewing public health assessments, including having experts in toxicology, medicine, health physics, and other disciplines review our work.

All peer reviewers approved of the assessment and found no major flaws that would invalidate ATSDR's conclusions and recommendations. In the words of one peer reviewer: "You [ATSDR] have done a good job under very difficult circumstances with a lot of unwanted publicity and carping. The science under the report is very good and the report is well written in a very good manner that is suitable for both an informed and interested public and the scientific community."

88

Appendix C. A Conservative Approach in Radiation Dose Assessment, Issues Associated with Being Protective or Overestimating Radiation Doses, ATSDR can become more sensitive to the legitimate concerns of fish consuming stakeholders downstream of DOE ORR by commissioning a subsistence fisher study. (Comment received on the initial release PHA dated December 2003.)

This appendix was removed during subsequent revisions and is not included in the final PHA.

89

Appendix D. Implications of Exposure to the Eight Radionuclides Identified for Further Evaluation in the Dose Reconstruction Report, Page D-1, Line 1. See comment for Page 125, Line 25. Also, this list of only potential contaminants of significant concern is inadequate and incomplete. The ORHASP Final Report, in fact, lists eighteen cardinal contaminants of concern as having been released off site by DOE ORR. (Comment received on the initial release PHA dated December 2003.)

This appendix was removed during subsequent revisions and is not included in the final PHA. Please see Table 2 and Table 3 in the final PHA, as well as information on the screening process from Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) described in Section III.B.2. Past Exposure.

90

Appendix D. Implications of Exposure to the Eight Radionuclides Identified for Further Evaluation in the Dose Reconstruction Report, Page D-16, Line 22. This is not true. If pregnant mothers are consuming Clinch River fish, or indeed any fish taken from many other downstream waters, this most probably has already occurred. (Comment received on the initial release PHA dated December 2003.)

This appendix was removed during subsequent revisions and is not included in the final PHA. Please see Section VII of the final PHA for a discussion of potential exposures to pregnant women, including ingestion of Clinch River fish.

91

Appendix D. The brief of the Watts Bar Reservoir (WBR) exposure investigation assumes that an average fish consumption rate of 66.5 g/day corresponds to a median of 33.1 meals per year. However, the calculated portion size for this assumed combination of numbers is 26 ounces per meal, which is unreasonably high. Therefore, the original data from the WBR exposure investigation needs to be re-examined to determine the proper relationship between the two given numbers.

To clarify the statements made by this commenter, the average daily consumption rate presented in the Watts Bar Exposure Investigation brief is for fish and turtles—not only fish. Only persons who consumed moderate to large amounts of fish and turtles from the Watts Bar Reservoir (generally more than 15 grams/day) were included in this investigation. The average fish and turtle consumption rate (66.5 grams per day) presented in this brief is based on self-reported estimations of actual (not assumed) consumption frequency and meal size from 116 individuals who participated in the exposure investigation.

Following a review of these comments, ATSDR evaluated the data further. A rate of 66.5 grams per day is slightly more than two 8-ounce fish meals per week, which would be expected among moderate to large fish and turtle consumers. The median value presented of 33.1 meals per year is, however, much lower than would be expected from this population. Therefore, the value of 33.1 meals per year was removed from the exposure investigation brief in the final PHA.

92

The nature of the Clinch River/WOC plume should be described as lying adjacent to the DOE property where it dissipates before reaching the K-25 water intake, a point of frequent sampling and overview by the State.

We agree and recognize that the concentration of contaminants released from White Oak Creek is diluted by the tremendous amount of water in the Clinch River.

93

It should be stressed that the dilution ratio at the Clinch River/White Oak Creek confluence is in excess of 1000 and that the Kingston water intake is located in the Tennessee River just above its confluence with the Clinch. The Tennessee River supplies an additional dilution factor for downstream water usage.

Thank you for your comment. Changes have been made in Section I. Summary and under the Clinch River in Section III.B.3. of the final PHA.

94

No medical professionals, meaning no medical doctor or nurse, have been included in the preparation of this PHA. Considering the significant number of omissions in delineating actual exposures for downstream stakeholders, we recommend that at least one qualified physician from ATSDR's large complement of medical staff on their payroll be in charge of the preparation of a complete redraft of this PHA. Further, stakeholders insist that this redrafted PHA be internally peer reviewed by at least three other of its qualified physicians. These physicians should attach their signatures and state license numbers to the PHA's front page. This should prevent further flagrant omissions by ATSDR evidenced in this one. Additionally, attaching medical doctor signatures to this PHA will facilitate appropriate rectification of any future 'omissions' through federal tort action. (Comment received on the initial release PHA dated December 2003.)

The White Oak Creek Radionuclide Releases PHA underwent an internal ATSDR review, a data validation review by other government agencies (i.e., the U.S. Department of Energy [DOE] and the Tennessee Department of Environment and Conservation [TDEC]), and an external review. Through its external peer review process, ATSDR's Office of Science had three scientific experts review this public health assessment. 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. Individuals within the agency who have the proper background (e.g., toxicology and health physics) reviewed the document during the agency's internal review process. ATSDR and CDC do have physicians on their staff; that said, however, individuals within the agency who have the proper background reviewed the document during the agency's internal review process. 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 (see Appendix H for the peer reviewer comments and ATSDR's responses). During this external review period, any member of the public, including physicians, nurses, and other members of the community, can provide comments to ATSDR. ATSDR uses a multi-disciplinary approach for reviewing public health assessments, including having experts in toxicology, medicine, health physics, and other disciplines review our work.

All peer reviewers approved of the assessment and none found any major flaws that would invalidate ATSDR's conclusions and recommendations. In the words of one peer reviewer: "You [ATSDR] have done a good job under very difficult circumstances with a lot of unwanted publicity and carping. The science under the report is very good and the report is well written in a very good manner that is suitable for both an informed and interested public and the scientific community."

Editorial Comments

95

Page 2, Line 13: "radionuclides from White Oak Creek,"

The specific radionuclides should be identified here. Uranium is specified, as is Iodine-131; why not the others such as Cs-137, Sr-90, and Cobalt-60 (Co-60). For starters, identify the specific radionuclides being evaluated here. (Comment received on the initial release PHA dated December 2003.)

Uranium and iodine131 are discussed here, but not in the context of listing radionuclides that were released from White Oak Creek. Instead, this referenced part of the document is listing the PHAs ATSDR is preparing because these particular contaminants required further evaluation based on ATSDR's review, the screening analysis of the Tennessee Department of Health's (TDOH's) Phase I and II screening-level evaluation of past exposure (1944–1991), and community concerns. Thus, the text reads: "...ATSDR scientists are conducting public health assessments on X-10 iodine 131 releases, Y-12 mercury releases, K-25 uranium and fluoride releases, PCB releases from X-10, Y-12, and K-25, and other topics such as the Toxic Substances Control Act (TSCA) incinerator and off-site groundwater." This statement is not, however, listing the contaminants released from White Oak Creek. In fact, in this context, uranium refers to releases from the Y-12 plant and the K-25 site and iodine131 refers to releases from the X-10 site, but not into White Oak Creek.

TDOH's Oak Ridge Health Studies, conducted over 9 years, investigated historical releases from the ORR facilities to see if these releases could have caused health problems for nearby residents. The project included dose reconstruction studies focusing on four areas:

• Iodine131 releases from X-10
• Mercury releases from the Y-12 Plant
• PCB releases from ORR facilities
• X-10 radionuclide releases to the Clinch River via White Oak Creek

All of the final reports from the Oak Ridge Health Studies are available online at http://www2.state.tn.us/health/CEDS/OakRidge/ORidge.html . In addition, you may contact ATSDR's Information Center toll-free at 1-888-422-8737 for copies of ATSDR public health assessments that evaluate contaminants released from these facilities.

96

P. 4. Line 23. Define "Screening Index."

The comment is noted. The text was changed in the final PHA by adding "or calculated probabilities of developing cancer" after the term screening indices.

97

Pp. 5-6. On pp. 5-6, the statement is made that radiation lifetime doses to critical organs (e.g. bone, lower large intestine, red bone marrow, breast, and skin) are less than ATSDR's comparison values. Then, on pp. 65-66, 82, and in the footnotes to Table 11 on p. 84, it is explained that the individual annual organ doses are each multiplied by "weighting factors," the products summed, and the sums multiplied by 70 to get lifetime effective whole-body doses. However, mention is not made on pp. 82 or 84 that the "weighting factors" are listed in Table 6 on p. 66, nor is the reader directed to Table 22, on p. 111 where the calculated doses are finally compared to the "comparison values." This information is out of order and too strung out. It should be collected and presented in one place.

This information is presented in various parts of the document to correspond to different portions of the evaluation conducted as part of the public health assessment process. The information referred to is detailed in the summary, in the introductory information describing the exposure evaluation process, in the description of Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) and ATSDR estimated radiation doses, in the summary table for past radiation doses, and in the public health implications section. The information is intentionally presented in these various sections to help readers as they go through the different portions of the evaluation.

Although these sections will not all be put into one place, changes were made as suggested to refer the reader to Table 6 in the notes for Table 11. In addition, the following sentence was added after Table 11 (page 88) regarding Table 22: "These calculated doses have been screened against the comparison values found in Table 22 of Section IV. Public Health Implications."

98

P. 6. Line 9. "...that are not considered to be a public health hazard."

The comment is noted. The text was changed in the final PHA.

99

P. 7. Line 12. "of chemical contaminants...."

The comment is noted. The text was changed in the final PHA.

100

P. 7. Line 17. "ATSDR estimated committed effective...."

The comment is noted. The text was changed in the final PHA.

101

P. 7. Line 18. "for adults and children...."

The comment is noted. The text was changed in the final PHA.

102

Page 7, Line 24. There is an incomplete sentence at the end of this page. Content of this passage doesn't flow with the discussion resuming at the top of page 10. (Comment received on the initial release PHA dated December 2003.)

This incomplete sentence was fixed in subsequent versions of the document and the two passages now flow together. The referenced passages are two separate paragraphs—not one continuous paragraph as it might have appeared since the last sentence was incomplete in this former version of the document. To clarify further, the paragraph on former page 7 provided a general overview and background of the main ORR facilities: X-10, Y-12, K-25, and S-50. The next paragraph on former page 10 narrows the focus to discussing only X-10 because this PHA evaluates those radionculides released from this facility that entered White Oak Creek.

103

P. 8. Line 11. Define "screening comparison value."

The following information was added into a text box in the final PHA to define this term: "Comparison values (CVs) are doses (health guidelines) or substance concentrations (environmental guidelines) set well below levels known or anticipated to result in adverse health effects. Health guidelines are derived based on data drawn from the epidemiologic and toxicologic literature with many uncertainty or safety factors applied to ensure that they are amply protective of human health. Environmental guidelines are derived from the health guidelines and represent concentrations of a substance (e.g., in water, soil, and air) to which humans may be exposed via a particular exposure route during a specified period of time without experiencing adverse health effects. During the public health assessment process, ATSDR uses CVs as screening levels. Substances detected at concentrations or doses above CVs might be selected for further evaluation."

104

He suggested changing the word "reasonably" on line 25 of page 8 to better suit the public.

The comment is noted. The word "reasonably" was changed to "be expected to."

105

Page 8, Figure 1. Location of the DOE ORR. Make sure the fish sampling sites are identified as such. Add a legend note to explain that the 'CRMs' are sampling sites with extensive and continuous fish sampling data archived into the OREIS. Also mention that this data, now withheld from the public, is still available to group users, such as non-governmental organizations, institutions of higher learning, environmental advocacy groups, civil rights groups, church groups, et al. Mention that robust fish sampling data in OREIS dates from 1985.

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

Please refer to the Oak Ridge Reservation Annual Site Environmental Reports (ASERs) for information on areas sampled during investigations. These reports are available online at http://www.ornl.gov/sci/env_rpt/ and the findings are also included in the Oak Ridge Environmental Information System (OREIS). Also, the Tennessee Department of Environment and Conservation (TDEC), DOE Oversight Division, has published its environmental monitoring plan online at http://www.state.tn.us/environment/doeo/pdf/EMP2005.pdf . This indicates the areas where fish sampling will be conducted.

106

Page 9, Figure 2. Original and Current ORR Boundaries. The 'Current' boundaries are not visualized on this map. It is impossible to visualize the information in the legend in black and white because it is probably in color: Land Transferred from DOE Ownership, Pending Transfer, and Leased Land. Add to this map all land that has been 'transferred' without substantive environmental cleanup.

Also add a note to this map in the legend that DOE is still responsible for any 'misadventures' in its Land Use Controls (LUCs) in the event any future lease holders of transferred become sick, injured, or die consequent to properties on this site being transferred without actually fulfilling the legal requirements of CERCLA. For example, if any workplaces on these transferred sites remain contaminated and a leaseholder business decides to place a daycare center on site at that workplace, then DOE would still be liable for such misadventure, despite its 'property transfer.' In other words, there should be explicit mention on this map, which depicts property transfers and leased land that, in fact, DOE is still liable for subsequent injuries, illnesses, and/or deaths which might devolve from a 'land rush' to transfer property with marginal and/or environmental cleanup beforehand.

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

The April 2005 public comment PHA and the final PHA present this map in color. The current lands comprising the DOE Oak Ridge Reservation, land transferred from DOE ownership, lands pending transfer, and leased lands are all identified by different colors on the map and outlined in the legend.

Section 120 (h) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires documentation of the condition of federal lands upon sale or transfer, and it establishes the federal government as the responsible party for any remedial action found to be necessary after land transfer. Under a Covenant Deferral Request, DOE can transfer properties if it can show that the land is protective for the intended use. This enables DOE to transfer properties before CERCLA remedial activities are completed.

Properties could only be transferred if they were considered safe for their intended future use. Moreover, ATSDR is evaluating wastes that traveled off site only—not wastes remaining on the reservation. Through various measures, including monitoring, remediation, institutional controls, engineering controls, and sampling, DOE continues to evaluate contaminant releases on the reservation and to mitigate contaminants from leaving the ORR. ATSDR considered these measures, including institutional and engineering controls, and evaluates and discusses them in the final PHA.

107

Page 10, Line 1. There appears to be missing text at the top of this page because the content is out of place because it does not flow with the end of page 7, the immediate preceding passage. (Comment received on the initial release PHA dated December 2003.)

No incomplete sentence was found at the end of the page on this previous version of the document. The passages being referenced are actually two separate paragraphs—not one continuous paragraph as it might have appeared since the last sentence ended at the bottom of page 7 in this previous version. It is clear that these are two separate paragraphs in the final PHA. To clarify further, the paragraph on former page 7 provided a general overview and background of the main ORR facilities: X-10, Y-12, K-25, and S-50. The next paragraph on former page 10 narrows the focus to discussing only X-10, given that this PHA evaluates radionculides released from this facility that entered White Oak Creek. Thus, ATSDR believes that these passages do indeed flow in the order they are presented within the document, as the initial paragraph provides a general overview of the facilities and the following statements focus on the facility of interest for this PHA.

108

P. 12. Line 15. Clinch River Mile (CRM) is defined, but Fig. 3 presents the acronym "CRK," that is not defined in the text, the figure, nor in the list of acronyms. The conversion 1 km = 0.6214 mi. should also be given in the nomenclature, or in Fig.3. It should also be noted that CRK 33 is also CRM 20.5, which is the reference location on Jones Island.

Thank you for your comment. To be consistent throughout the document, the Clinch River Kilometers (CRKs) have been replaced with the equivalent distances in Clinch River Miles (CRMs).

109

Page 14: Figure 5. X-10 Facility Time Line: Missing depiction. (Comment received on the initial release PHA dated December 2003.)

This figure was inadvertently missing from the December 2003 version, but it is included in subsequent revisions of the document, including the final PHA.

110

Page 15, Line 27. Which contaminants ended up on the Clinch River? Name them and the approximate curie load of each of those contaminants which are radioactive. (Comment received on the initial release PHA dated December 2003.)

This PHA evaluates the releases of radionuclides—not all contaminants—to the Clinch River and the Lower Watts Bar Reservoir from the X-10 site via White Oak Creek. The estimated discharges (in curies) of radionuclides released to the Clinch River via White Oak Creek are presented in Table 2 of the final PHA.

111

P. 15. Line 20. "nuclear fission products"

The comment is noted. The text was changed in the final PHA.

112

Page 16, Figure 6. Location of the Gunite Tanks at the X-10 Site.

Define 'WAG', 'gunite', and 'grout sheets' in the legend. Also mention, both here and in the text, that 'gunite' is actually just concrete and state the average life expectancy of concrete (approximately 84 years). This means that the integrity these aging 'gunite tanks' are most probably already compromised. Identify on this figure those gunite tanks that are known to be leaking by DOE, ATSDR, EPA, and TDEC collectively.

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

The legend is a guide for terms used in the figure; WAG, gunite, and grout sheets are not presented in the figure.

The following was added as a footnote to define "gunite": "Tanks were constructed of a water, concrete, and sand mixture called 'gunite,' which was sprayed over a wire mesh and steel reinforcing rod frame."

Most of the mixed waste was removed from the gunite and associated tanks in the 1980s. In September 1997, an interim record of decision identified these tanks as a priority for clean up, partly because of the risk to the public, to workers, or, if a tank leaked or collapsed, to the environment. A total of 87,000 gallons of sludge and 250,000 gallons of liquid waste were treated and transferred off site. The action was completed in September 2000. The tanks were empty, left in place, and grouted in 2001. Information on the gunite tanks suggests that these remedial actions were conducted to prevent leaks, not because leaks had already taken place. Thus, ATSDR is unable to identify leaking tanks on the figure because evidence supports that the waste was removed before any leakages occurred. In addition, the life expectancy of concrete is irrelevant for this discussion because the tanks are empty. Please refer to Appendix B in the final PHA for more details on these remedial activities.

113

P. 17. Fig. 5 is impossible to read.

An 11 x 17 size of this time line was incorporated into the final PHA.

114

Page 17, Line 14. Name the 'top twenty' of these contaminants by 'curie load' and identify the 'top twenty' radionuclides contributed by these facilities. Provide two pie charts for this information. (Comment received on the initial release PHA dated December 2003.)

To be clear, this PHA only evaluates the releases of radionuclides to the Clinch River and the Lower Watts Bar Reservoir from the X-10 site via White Oak Creek. The estimated discharges (in curies) of radionuclides released to the Clinch River via White Oak Creek are presented in Table 2 of the final PHA. Also, a detailed discussion of the 24 radionuclides initially evaluated and the process of determining particular contaminants for additional screening are presented under Task 4 Screening Assessment in Section III.B.2. Past Exposure (1944-1991). You can also refer to the Oak Ridge Dose Reconstruction Task 4 report online at http://www2.state.tn.us/health/CEDS/OakRidge/WOak1.pdf for more information on estimated radionuclide releases.

115

Page 17, Line 23. After the word 'seven' add the words 'unlined and unprotective.' (Comment received on the initial release PHA dated December 2003.)

Thank you for your comment. The term "unlined" was added to the referenced sentence in the final PHA.

116

P. 18. Fig. 6 lacks a color legend, especially for the unlabeled blue areas.

Thank you for your comment. The blue shading was removed in the final PHA.

117

P. 19. Line 19. Specify how the waste managed to "travel over the dam."

The wording was changed to the following: "This dam was used as a basin for further settling of the solids that remained...But some waste products did not settle into the 3513 Pond or White Oak Lake; instead, some of the flow spilled over White Oak Dam into the White Oak Creek Embayment and then reached the Clinch River."

118

P. 20. Insert "tags" that identify areas of interest in Fig. 7.

Thank you for your comment. Labels were added to this figure in the final PHA to identify the locations of the Clinch River, X-10/ORNL, the X-10/ORNL disposal area, White Oak Lake, White Oak Creek, White Oak Dam, White Oak Creek Embayment, and the Sediment Retention Dam.

119

Page 20, Table 2. Estimated Discharges (in curies) of Radionuclides from White Oak Creek. Line 9: "The four radionuclides expected to be of most concern are highlighted in gray." Okay, we can't guess what these four most important ones are; there is no gray shading on this document. Please identify them specifically. Please prioritize them, along with the route of exposure of most concern.

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

The gray highlighting is apparent in the April 2005 public comment version of the PHA as well as in the final PHA.

In this public health assessment, ATSDR evaluated radioactive contaminant data for the Clinch River and the Lower Watts Bar Reservoir surface water, sediment, and fish, as well as vegetables, turtles, and local game animals for the Clinch River, to determine whether the levels of radionuclides might pose a past, current, or future public health hazard. Depending on the waterway and time period, the evaluation included the following exposure scenarios:

• Incidental ingestion of water during recreational activities,
• Ingestion of river or reservoir water for drinking water,
• Contact with water during recreational activities, irrigation, or showering,
• Contact with surface sediment,
• Contact with dredged sediment used as topsoil in home gardens,
• Consumption of locally grown milk, meat, or produce, and
• Consumption of fish, turtles, or local game animals.

Section III. Evaluation of Environmental Contamination and Potential Exposure Pathways presents a detailed evaluation of past, current, and future exposure to these radionuclides based on the various exposure scenarios presented above. Please refer to this section of the final PHA for more information.

120

Page 21, Line 18: Table 3. Summary of Peak Annual Releases for the Eight Key Radionuclides. There are more than twenty four radionuclides that have been released to WOC over the years. This fact is documented in the ORHASP (Oak Ridge Health Agreement Steering Panel) Final Report, although they are not cited individually. Citizens can access this complete report themselves at the following website, and ATSDR should include that website at this point in its text: http://www2.state.tn.us/health/CEDS/OakRidge/Oridge.html . All of these radionuclides should be identified here and the 'Eight Key Radionuclides' simply highlighted on the more inclusive list. What are the target organs of concern if citizens have been exposed to these twenty-four contaminants?

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

Page 12 of the Oak Ridge Health Agreement Steering Panel (ORHASP) final report states: "Of the more than two dozen radionuclides that have been released to White Oak Creek over the years, eight were identified as historically most important: cesium 137, iodine 131, strontium 90, cobalt 60, ruthenium 106, niobium 95, zirconium 95, and cerium 144." These are the same eight radionuclides presented in Table 3 of the final PHA that presents a summary of peak annual releases from White Oak Dam for the eight key radionuclides. Thus, the table presents a summary of those releases found to be of most concern; it does not present all of the radionuclides released because many of them were not released at levels determined to be of potential concern to the public and therefore do not require in-depth discussion or evaluation.

In addition, in Section III.B.2. Past Exposure of the final PHA, ATSDR details the Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report) screening assessment that involved a phased approach, including a discussion on the target organs, radionuclides of concern, and pathways requiring further evaluation. First, the Task 4 team identified 24 radionuclides released from the X-10 site into the Clinch River from 1944 to 1991 as potential contaminants of concern. These were not the only radionuclides released, but these were the only ones identified as potential contaminants of concern based on the Task 4 team's initial assessment. Through a risk-based screening process, the Task 4 team then calculated conservative human health risk estimates for reference individuals and target organs to further determine the radionuclides and exposure pathways of concern. Eight radionuclides required further evaluation; following a supplemental analysis, four radionuclides were found to be important contributors to dose and health hazards. Please see this section of the final PHA for more information and the Task 4 report at http://www2.state.tn.us/health/CEDS/OakRidge/WOak1.pdf .

The ORHASP final report is discussed in detail in Section II.F.2. of the final PHA. The Web site link to the report was added to the paragraph on ORHASP: "For additional information on the ORHASP findings, please see the final report of the ORHASP titled Releases of Contaminants from Oak Ridge Facilities and Risks to Public Health at http://www2.state.tn.us/health/CEDS/OakRidge/ORHASP.pdf ."

121

P. 22. Terminology describing "earthen pits" (aka LLW seepage pits) and "earth-covered trenches" (aka LLW seepage trenches) should be consistent between text and Fig. 8.

The principle of operation of the liquid waste disposal trenches should be described. These trenches operated hydraulically in a manner similar to a septic tank drain field, but with the waste being retained closely downstream rather than upstream, in this case, by virtue of the electrostatically polar nature of the clay and shale particles surrounding the trenches. These particles attracted and held a large fraction of the radioisotopes seeping out of the trenches. The trenches were also originally known as "Intermediate Level" liquid waste disposal trenches.

If possible, the percentage of the radioisotopes pumped into the trenches that were retained by the shale and clay should be estimated and stated.

Thank you for your comment. The text was changed as suggested. In the final PHA, it now reads: "In 1960, the 'earthen pit' (also known as a low-level waste [LLW] seepage pit) was changed to an 'earth-covered trench' (also called a LLW seepage trench) to reduce inadvertent radiation exposure and rainwater buildup."

Thank you for this suggestion. This text was added verbatim as a footnote to describe the operation of the waste disposal trenches.

Please note that the percentage of radioisotopes pumped into and retained in the trenches relates to contamination remaining on site at the reservation. In this public health assessment, ATSDR is only evaluating releases that traveled off site from the ORR.

122

P. 23. It would be instructive to identify the Intermediate Holding Pond and the Wastewater Treatment Process Plant in Fig. 8.

The Intermediate Holding Pond and the Process Waste Treatment Plant have been added to Figure 8 in the final PHA.

123

Page 23, Figure 8. Map of the Bethel Valley Watershed and the Melton Valley Watershed. This diagram does not delineate the boundaries of each respective watershed. Where are the other three watersheds cited in Page 22, Line 29? (Comment received on the initial release PHA dated December 2003.)

To facilitate the investigation and remediation of contamination related to the reservation, the contaminated areas on the ORR were separated into five large tracts of land that are typically associated with the major hydrologic watersheds. The contaminated areas associated with X-10 (the only releases evaluated in this PHA were from X-10) are, however, located in the Bethel Valley Watershed and the Melton Valley Watershed. Therefore, only these two watersheds are highlighted on Figure 9 in the final PHA and described in detail in the document. For information on additional watersheds, please refer to the PHA titled Evaluation of Potential Exposures to Contaminated Off-site Groundwater From the Oak Ridge Reservation (USDOE) (available at http://www.atsdr.cdc.gov/HAC/PHA/region_4.html#groundwater) for ATSDR's evaluation of off-site groundwater. 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.

124

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

Where are Core Hole 8 Plume (cited in Page 24, Line 15) and First Creek (cited in Page 26, Line 2) on this map? Where are the MVSTs (Melton Valley Storage Tanks) on this map? Add a legend for all the acronyms for these remedial activities: HFIR, HPFR, TSF, CFRF, and others. Define "grouted." (Comment received on the initial release PHA dated December 2003.)

The Corehole 8 plume and First Creek are both identified in the final PHA on Figure 10. Map of the Major Remedial Activities in Bethel Valley.

This map, as the title indicates, only presents where major remedial activities are taking place in Bethel Valley. These actions are described in further detail in Appendix B of the final PHA. The Melton Valley Storage Tanks are not depicted on this map because they are not considered part of the major remedial activities occurring in Bethel Valley for a few reasons. These eight approximate 50,000-gallon underground storage tanks (USTs), located in Melton Valley, are used to contain transuranic (TRU) waste from past processes and remedial activities. Thus, these tanks are not currently being remediated, but are being used to contain wastes resulting from on-site remediation activities at the X-10 site.

As a clarification, the acronyms mentioned in this comment (HFIR, HPRR [not HPFR], TSF, and CFRF) are not on the map of major remedial activities in Bethel Valley because they are not remedial activities—they are various facilities on the ORR: consolidated fuel recycling facility (CFRF), high flux isotope reactor (HFIR), health physics research reactor (HPRR), and tower shielding facility (TSF). These acronyms, which are presented in the final PHA in Figure 9. Map of the Bethel Valley Watershed and the Melton Valley Watershed, have been defined in the map's legend.

The section describing these remedial activities is now presented in Appendix B. The referenced sentence was changed to the following to define the term "grouted:" "The empty tanks were left in place and grouted (i.e., sealing off the flow of contaminants by pumping cement grout or chemicals into drill holes) in 2001; the remedial action report was approved in October 2001."

125

Page 28, Line 28. Which other contaminants? Specifically name them. (Comment received on the initial release PHA dated December 2003.)

The following reference was used for this information:

• Science Applications International Corporation. 2002. 2002 remediation effectiveness report for the US Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee. Science Applications International Corporation. US Department of Energy: Office of Environmental Management; March.

This document states that "The WOCE TC RmA [White Oak Creek Embayment Time-Critical Removal Action] was initiated in 1991 after site characterization data indicated the embayment was an uncontrolled source of cesium 137 and other sediment-bound contaminants to the Clinch River system." No other contaminants are specifically mentioned regarding the "other sediment-bound contaminants." Thus, ATSDR is unable to provide the additional requested information.

126

Page 29, Figure 20. Map of the Major Remedial Activities in Melton Valley. A recurrent omission on most of ATSDR's figures. Please spell out all acronyms used in the figure in a legend: WAG, SEEP, OHF, and others. (Comment received on the initial release PHA dated December 2003.)

The acronyms are presented on the figure in the final PHA. Please note, however, that "seep" is not an acronym.

127

Page 30, Figure 11. Completed, Current, and Future Remedial Activities in Melton Valley. Please spell out all acronyms used in the figure in a legend: SWSA, MSRE, OHF, and others. (Comment received on the initial release PHA dated December 2003.)

Acronyms are included in this figure (Figure B-1) in the final PHA.

128

Page 35, Line 1. What is "grouting?" (Comment received on the initial release PHA dated December 2003.)

"Grouted" was defined previously in the final PHA as "sealing off the flow of contaminants by pumping cement grout or chemicals into drill holes."

129

P. 36. Line 33. "When the government..." (Delete the comma.)

The comment is noted. The text was changed in the final PHA.

130

Page 38, Lines 22-25. Unclear what is trying to be said here — rework this passage. (Comment received on the initial release PHA dated December 2003.)

The text was rewritten as the following: "The baseline risk assessment indicated that standards for environmental and human health would not be reached if deep channel sediments with cesium 137 were dredged and placed in a residential area, and if people consumed moderate to high quantities of specific fish that contained increased levels of PCBs."

131

P. 39. Lines 22-26. These are parenthetical statements.

ATSDR contacted an editor regarding this comment. Though these are not truly "parenthetical statements" per say, the sentences are an aside from the preceding text. To address this comment, ATSDR separated these statements from the other text by placing the information in a text box.

132

P. 40. Line 9. In this and in subsequent text, please state clearly to which year these data apply and consistently provide a reference.

Historical census data for Meigs, Rhea, and Roane Counties were obtained from Bureau of the Census 1993: 1990 Census of Population and Housing, Population and Housing Unit Counts, United States. This might seem out of place as this reference is dated 1993, but it provides county data for 1940, 1950, 1960, 1970, 1980, and 1990. See Table 30 (page 107) of the reference at http://www.census.gov/prod/cen1990/cph2/cph-2-1-1.pdf for more information.

Census data for Harriman, Kingston, Rockwood, and Spring City were obtained from census reports for the individual years (i.e., 1940, 1950, 1960, 1970, 1980, 1990, and 2000).

The reference was consistently changed to Bureau of the Census.

133

P. 61. Lines 14–17. The statement about providing images in slideshow format in FY 2004 needs updating.

ATSDR contacted DOE to inquire about the status of the Comprehensive Epidemiologic Data Resource (CEDR). According to DOE, CEDR now provides images in slideshow format that give estimated concentrations, doses, and risk values for three contaminants (iodine, mercury, and uranium) in air at locations studied in the Tennessee Department of Health's (TDOH) Oak Ridge Dose Reconstruction. The text was changed to reflect this updated information in the final PHA.

134

P. 66. Line 10. Put Footnote 3 on this page. The footnote should also state whether or not the "new system" still involves "weighting factors."

The comment is noted. The footnote (now footnote 6) was moved to this page in the final PHA and changed to the following: "For 2005, the ICRP is proposing a new system, which still involves weighting factors, that uses cancer incidence and considers lethality rate, years of life lost, and weighted contribution from the nonfatal cancers and hereditary disorders."

135

P. 66. Line 11. Note that the term should be "W_T."

The comment is noted. The text was changed in the final PHA.

136

P. 68. Line 16. Replace the word decay with the words be eliminated. The sentence would read: "Radionuclides that are taken into the body will also be eliminated by biological processes such as excretion."

The comment is noted. The text was changed in the final PHA.

137

P. 68. Line 25. Delete the sentence containing the words always less to avoid confusion when the reader sees rounded values that are the same in Table 7 on page 69.

The comment is noted. The text was changed to: "The effective half-life is always less than or equal to either its physical or biological half-life."

138

P. 72. Line. 27. "provides a table of Task 4...."

The comment is noted. The text was changed in the final PHA.

139

P. 77. Lines 14–16. The sentence beginning on line 14 is hard to understand because of its grammar ("Though, because...") and because the phrase, "actively exchanged," is not explained.

The sentence was changed to the following in the final PHA: "Because Clinch River sediments are not as actively exchanged as the river water itself (i.e., the sediments do not mix as much as the surface water), the Cs 137 in sediment at CRM 14 has decreased as a function of its half-life."

140

Page 77, Table 6. Conservative Screening Indices for Radionuclides in the Clinch River. This table is useless for the reader. This information should be parceled out into nine separate tables, according to the nine Exposure Pathways displayed. Each of these separate tables should then be rank ordered according to the decreasing levels of risk for respective radionuclides. Add a tenth table to summarize the preceding nine tables by teasing out only those bold values in the present Table 6 (i.e., only the first eight lines).

Please avoid the use of the words 'Conservative Screening Indices.'

Stakeholders may misconstrue this as inferring a relationship to the right wing of the Republican party. Instead substitute the words: 'Screening Levels Which are Protective of Public Health' — which should be done through out all your PSAs.

Briefly explain to the reader the CERCLA risk range of discretion — 1 x 10^-4 to 1 x 10^-6. Otherwise, how will stakeholders glean from this monstrosity of a table which of these scientific notation numbers are critically important to their public health? For instance, The reader has a fundamental right-to-know that the first line of this table is displaying information to the effect that the Cs-137 contamination of fish in the Clinch River is at a higher level than the CERCLA 'acceptable' risk range above. The EPA risk limits are also exceeded for separate exposure to all of the following:

• Sediments along the shoreline
• Dredged sediments
• Eating beef
• Drinking milk
• Eating vegetables

How are stakeholders supposed to ferret this critical exposure information from this table? To the interested stakeholder, this regurgitation of undecipherable critical exposure information, with exposure levels hidden in the cryptographic hieroglyphics of scientific notation, is not helpful. Stop 'talking down' to stakeholders by providing overly complex tables of important exposure data, which cannot possibly be deciphered by most stakeholders downstream of DOE ORR. Is this purposeful on ATSDR's part — or is this just plain stupid? Interested readers and all downstream stakeholders deserve better.

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

This table was taken directly from Table 3.1 on page 3-10 of Task 4 of the Tennessee Department of Health's Reports of the Oak Ridge Dose Reconstruction (Task 4 report); it was not modified by ATSDR. ATSDR believes that this table, which is in Appendix E of the final PHA, provides a useful summary of the conservative screening indices (or calculated probabilities of developing cancer) for radionuclides in the Clinch River as reported in the Task 4 report. 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 .

ATSDR finds that creating 10 tables to display the information that is already presented in this one table would complicate the information for the reader. The purpose of this table is to summarize the conservative screening indices from the Task 4 report and indicate those (in bold) that were carried into the next iteration of analysis by the Task 4 team. The Task 4 team's analysis and the radionuclides and pathways that were evaluated in detail are presented in Section III. Evaluation of Environmental Contamination and Potential Exposure Pathways in the final PHA. Anyone who would like additional information is prompted throughout the final PHA to the original source material, but again, the purpose here is to present the information in a concise and user-friendly format.

The term "conservative screening indices" was used by the Task 4 team, and thus ATSDR uses the team's terminology when presenting this information and would not feel comfortable changing it. The term is, however, defined in the summary section of the final PHA as "calculated probabilities of developing cancer."

Contrary to trying to hide or make information undecipherable, ATSDR is summarizing and providing this complex data in an easy-to-read, user-friendly format. In fact, a commenter at a work group meeting noted, "the document as a whole was easy to read." Please refer to Section III.B.2. Past Exposure (1944–1991), Task 4 Screening Assessment, in the final PHA. This section discusses that the Task 4 team used an upper bound of 1 in 100,000 (1 × 10^-5) as the decision point, or minimal level of concern, during its assessment. This value was one-tenth of the Oak Ridge Health Agreement Steering Panel (ORHASP)-recommended value of 1 in 10,000 (1 × 10^-4); thus, the value used by the Task 4 team was more conservative than the ORHASP-recommended value. The remaining text of this section of the PHA explains in user-friendly detail how certain pathways and radionuclides were evaluated and retained for further analysis. Please see this section of the document and refer to the Task 4 report for any additional information.

141

P. 81. Line 29. The definition of the 95% confidence interval needs improvement. The 95% confidence interval is the range of values, centered on the estimated mean, within which there is a 95% probability that the true mean will actually fall. Note that "95^th confidence level" is improper terminology.

The comment is noted. The text was changed in the final PHA based on this suggested wording.

142

P. 82. Line 13. "ATSDR narrowed its evaluation..."

The comment is noted. The text was changed in the final PHA.

143

P. 82. Line 18. Explain "weighting factors," and give examples.

Weighting factors are explained and examples are provided on page 68 of the final PHA. A reference to this table and explanation is now provided in the suggested paragraph of the final PHA.

144

P. 86. Place footnote 8 on this page, not on the following page.

The footnote, now footnote 11, has been placed on the correct page in the final PHA.

145

P. 95. Line 23. Note that "becquerel" is not defined here nor in Appendix A.

Becquerel is defined in Table 8 of the final PHA. The term becquerel was added to Appendix A.

146

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. Separate this table into three tables, one for past exposure and one for current exposures. Keep the current exposure all on the same page. Create an additional table which drops all the text in the third column and simply displays columns one, two, and four.

Row one of this table states that people sustain greater exposure if they take fish closer to the confluence of WOC and the Clinch. No mention of the range of travel of these 'hot fish' is provided and fish swim around. Fish don't simply stay put. Fish are occasionally 'flushed' out of Watts Bar Reservoir by reservoir drawdowns and power generation events. Certain species in the Clinch, like the Gizzard Shad, migrate from the Ohio River near Paducah, Kentucky, even to locations upstream of DOE ORR, and back downstream. The migratory patterns of the many species are not discussed at all. (Comment received on the initial release PHA dated December 2003.)

This table was completely modified during subsequent revisions of the document. In the final PHA, this is broken into two tables: Table 22. Past (1944 to 1991) Radiation Doses for the Area Along the Clinch River and Table 23. Current Radiation Doses for the Lower Watts Bar Reservoir and Clinch River. The third column no longer exists as it was; instead, there are six columns in Table 22 and seven columns in Table 23. The information is now presented in a much more simplified manner so the reader can easily see the estimated doses, comparison values, and whether these doses were above or below the comparison values.

147

Page 109. Except for the first two lines, the lines of text are unnumbered. For what would be Line 11, stakeholders are providing this additional collection of citizen's concerns, which ATSDR may not yet be aware. (Comment received on the initial release PHA dated December 2003.)

All of the line numbers were removed in the final PHA. ATSDR appreciates your comments, which are addressed here, as well as all of the concerns provided by residents and other interested parties. All of the concerns received by ATSDR regarding radionuclide releases to the Clinch River and the Lower Watts Bar Reservoir via White Oak Creek are addressed in this final PHA. Community concerns related to other topics are covered in corresponding PHAs.

148

P. 111. Footnote 11. Shouldn't the word "data" be replaced with the word "survivors?" Also, the reference (Schull 1995) does not appear to be in the reference list.

Thank you for your comments. The table note was changed to the following in the final PHA: "Based on studies of atomic bomb survivors." In addition, the following was added to the reference list in the final PHA: Schull WJ. 1995. Effects of atomic radiation: a half century of studies from Hiroshima and Nagasaki. New York: John Wiley and Sons, Inc.

149

P. 144. Line 10. "Ringworm" is like the word "deer;" it has no plural form ("ringworms"). The word is used correctly in footnotes of page 111, line 12 and on page 112, line 11.

The comment is noted. The text was changed in the final PHA.

150

Appendix A. Undefined terms include "screening index" and "gray."

Thank you for your comment. Both of these terms are defined in Appendix A in the final PHA.

151

Appendix A. ATSDR Glossary of Environmental Health terms, Page A-2, Line 18. Fishers and other stakeholders note that 'bioaccumulation' and 'food chain' are conspicuous by their absence from this glossary. This is important because certain non-radioactive contaminants like mercury, and certain radioactive contaminants like Sr-90 and Cs-137, all three are amplified up the 'food chain' and their effects can be magnified far above what might be expected from their initial release concentrations. Again, it would be helpful if bioaccumulation were to be included in this glossary.

ATSDR provides this glossary to define certain terms that are used throughout the final PHA. "Food chain" was added to and defined in the glossary because the term is used in Section IV. Public Health Implications of the final PHA. Because, however, the term "bioaccumulation" is not used anywhere in the document, it was not added to the glossary.

152

Appendix A. ATSDR Glossary of Environmental Health Terms, Page A-5, Line 41. A definition for "environmental fate" needs to be included as well.

Again, it would be helpful if environmental fate were to be included in this glossary. (Comment received on the initial release PHA dated December 2003.)

ATSDR provides a glossary in Appendix A of the final PHA to define terms used in the document. The term "environmental fate" was not added to the glossary because it is not used anywhere in the final PHA.

153

Appendix A. ATSDR Glossary of Environmental Health Terms, Page A-12, Line 37. Add a definition of what is meant by "reference man." "Reference man" is cited multiple times throughout this PHA, but not explained. For instance, see Appendix C, Page C-1, Line 26 and Page C-2, Line 24. (Comment received on the initial release PHA dated December 2003.)

This appendix, which previously used the term "reference man," was removed during subsequent revisions of the PHA. The term is not included in the final PHA, and therefore it was not added to the glossary in Appendix A.

154

Page B-6. The note that Trenches 5 and 7 are to be remediated by in-situ vitrification (ISV) is out of date. In May 2004, the method of remediation was changed from in-situ vitrification to in-situ grouting. (See the article in the Knoxville News Sentinel dated March 15, 2004, and a letter from Mr. David Mosby of the Oak Ridge Site Specific Advisory Board to Mr. Steve McCracken, DOE-ORO, dated July 15, 2004).

Thank you for your comment. In May 2004, the U.S. Department of Energy (DOE) issued a proposed plan to substitute in situ vitrification with in situ grouting. This proposed requirement for the record of decision and the remedial action work plan for in situ grouting were approved in September 2004.

The acronym has been changed in the figure noted by the commenter (Figure B-2) and the term was changed on Figure B-1. In addition, the following text was added to footnote 17 (which describes in situ vitrification) in the final PHA: "In situ vitrification (ISV) is a process that applies electrical power to contaminated soil to produce the heat needed to melt and blend the soil and waste into an immobile form (USDOE 1995b). DOE determined, however, that ISV could be problematic because of standing water in the trenches and higher than anticipated expenses related to the process. Thus, in May 2004, DOE issued a proposed plan to amend the Record of Decision by replacing ISV with in situ grouting (ISG). ISG involves a low-pressure grouting method to inject Portland cement-based grout throughout the trenches. In addition, a solution grout would be used to treat soil adjacent to the trench walls to close potential seepage pathways (ORSSAB 2004). In September 2004, the proposed requirement for the Record of Decision and the remedial action work plan for ISG of the trenches were approved."

155

Pp. C-1, Line 16, and C-6, Line 21. Replace "blot clots" with "blood clots."

The comment is noted. The text was changed in the final PHA.

156

Please number the pages of Appendix D.

Page numbers have been added to all of the pages in Appendix D in the final PHA.

157

Appendix D. Implications of Exposure to the Eight Radionuclides Identified for Further Evaluation in the Dose Reconstruction Report, Page D-14, Line 19. State which types of cancer would probably be produced (e.g., soft tissue sarcomas). (Comment received on the initial release PHA dated December 2003.)

This appendix was removed during subsequent revisions and is not included in the final PHA.

158

Table E-1. What are the units of "Screening Index?"

The screening indices in this table are presented directly as reported in 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. 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 .

To estimate the screening index, or screening-level risk, the Task 4 team used different equations to represent the various possible exposure pathways. According to the Task 4 report: "These screening values represent conservative estimates of excess lifetime risk of cancer incidence from an exposure duration equal to the number of years of historical releases. The contaminants and pathways with a screening index above 10^-5 have been analyzed in more detail ..." Each equation considered different parameters with varying units. These equations are presented for all of the pathways (drinking water, fish ingestion, external exposure to the shoreline, swimming, external exposure to dredged sediment, ingestion of beef, ingestion of milk, ingestion of vegetables, and irrigation) in Appendix 3A of the Task 4 report at http://www2.state.tn.us/health/CEDS/OakRidge/WOak2.pdf .

Though most of the various parameters considered in these screening index equations had units, the screening index is a risk level calculated and compared to the decision point or the minimal level of concern—determined as 1 x 10^-5 (also written as one in 100,000) by the Task 4 team. Any screening indices that exceeded the minimal level of concern were carried through the screening evaluation and further analyzed.