Uniontown IEL 2016 FIVE YEAR REVIEW BY REGION 5 US EPA

Posted by on Feb 11, 2016 in Letters | 0 comments

US EPA Region 5

Uniontown IEL Project Manager –

Ms. Karen Cibulski

Chicago, Illinois .

Re:  Region 5’s Uniontown IEL Superfund Site’s “2016 5 Year Review :  Citizens’ Plea for Scientific Accountability by EPA Adhering to What is Considered “Best Available Science”   – (by Following its own Guidelines  )

 As part of US EPA Region 5’s 2016 Uniontown Industrial Excess Landfill Superfund Site “Five Year Review” required, citizens formally request  that US EPA Region 5 use this opportunity to correct past serious mistakes made at IEL, so grave that these mistakes, many believe, led to  fatally flawed clean up decisions being made –  the killing off of the various basic institutional controls /clean up components one by one –  measures that Region 5 had vehemently once promised this town would be carried out to insure that toxins would remain “isolated” in perpetuity…  Due to what appeared to citizens/ many elected officials to be immense political pressure/arm twisting (and worse – see Dr. Toby Clark’s follow up Clean Sites report done for US EPA on IEL for US EPA) – , today, all that remains of the so called “clean up” is the continued flushing of the site into our area’s aquifer, a toxic dump that, according to Ohio EPA, contains  “greater than 780,000 tons of hazardous substances“,  perched just above our area’s water supply.

 However, we still try to remain hopeful after all these years and therefore making this appeal to Region 5.  Frankly, we are compelled to do so  – the lives of children and future generations is at stake….and we now know without a doubt that US EPA failed to adhere to “best available science” at IEL.    Reinforcing this hope is the fact that we have learned that over time, various new and significant scientific guidelines and other relevant reports have since been developed by EPA and others, all evolving in the years after the IEL EPA Remedial Investigation and Feasibility Studies & Post ROD studies were initially conducted back in the 1980s and into the early 1990’s…We personally know of many wonderful, caring EPA scientists who have had to fight hard at times to keep those efforts alive, because they truly cared about protecting the health of Americans and took seriously upholding their oath as US public servants regarding the US Constitution…to protect not simply from threats posed from without, but, threats also posed from within our country….

 So, Region 5, it’s time for the agency (and Ohio EPA)  to stop caving to the political pressures related to our IEL case, and use instead as your bench mark, what is known by EPA today be best scientific practices identified within various newer US EPA Guidelines/reports and at other government resources, such as DOE, or, such as the studies recently reported nationally done by academia like the radiation testing report published by an Iowa U radiation team,  that put forth critical findings pertaining to US EPA’s continued usage of certain EPA 900 Methods on raw unfinished water when testing for water soluble  Radium 226 – how some 900 procedures may miss up to 99% of the radium that might be present...To assure the public you are following the highest standards, we request a written responsiveness summary be provided concerning the IEL Review to concerns, questions we present below, a review that compares and contrasts such US EPA documents as EPA’s  “Vapor Intrusion Guidelines”  & “MNA, Metals & Radiation, ” ( the latter we were told by EPA in D.C. could be a game changer for the Uniontown IEL clean up, but appears that Region 5 has yet to read this document?)

Before we get into this list we  first must preface this request with the following:

 It is time Region 5 stops hiding behind the 22 year old EPA Science Advisory Board Report done on IEL in 1994,  particularly given that an investigative journalist had exposed the extremely troubling admission he obtained from various  IEL SAB panelists several years later:  that panel members had acknowledged that they were not even qualified to properly examine those US EPA  radiation testing methods ( even though the SAB ended up rubber stamping EPA’s continued usage of the 900 Methods nevertheless).

 Because US EPA had purposefully chosen to steer the charge of the IEL SAB panel away from what investigator Thomas Grumbly had sought (on the behalf of former EPA Administrator William Reilly) –  specifically, Grumbly said he had expected the SAB would look into what ” had  gone on between Region 5 and the two commercial labs that had found high levels of radiation at IEL back to back that Region 5/NAREL had tossed out as “invalid”  – ”  EPA inexplicably altered the mandate dramatically to instead direct the SAB panel to generically examine the radiation testing methods used on IEL samples = I.e, the EPA Finished Drinking Water Method 900.  Of course, this nicely took the heat off Region 5, but it did in turn increase the importance of the SAB’s findings done on IEL nationally –  EPA declared that it was using the Uniontown IEL SAB report  as the EPA’s “case in point” for ALL  other sites around the nation suspected of containing radiation.  

Ten years later, in 2003, CCLT learned from scientists within US EPA, whistle blowers in truth –  that internally several EPA scientists had attempted for some 15 years to stop this practice –  saying it was NOT scientifically appropriate.  The EPA Finished Drinking Water 900 Method was never meant for raw, untreated dump water like at superfund sites, known to be high in solids, they said, but rather, intended for  “treated” water systems… Due to the SAB’s rubber stamping of this Methodology and its continued use on raw water, it now unfortunately comes as no surprise to learn that this same EPA Finished Drinking Water method is still being used to test for radiation – this time on radioactive fracking wastes.  We must wonder just how much radiation is still being missed like at IEL and when, if ever, EPA will lever isten to what those experts inside EPA had warned about, when they were urged to abandon this practice long ago.

Secondly, Region 5 needs to stop hiding behind the other frequently referenced report  – the one done by the US EPA Inspector General/ EPA Ombudsman McKechnie 14 years ago.   Interestingly, McKechnie  replaced the former National EPA Ombudsman, Robert Martin, after Mr. Martin had quit US EPA in utter disgust, following the agency’s move to strip him of his independent powers to be able to properly investigate US EPA cases and potential corruption at EPA.   In our opinion and others, scientifically speaking, the  second IG/Ombudsman blew it big time, when they inexplicably failed to consult with DOE’s RESL Lab at Idaho National Lab  ( seemingly a “no brainer” )concerning IEL’s Plutonium scandal and what are known to be best practices concerning proper Pu testing.  Surely the EPA IG should have known at that time that DOE’s RESL serves as the radiation “reference lab” for  US EPA and other US government agencies?    Instead, the IG/Ombudsman chose to go out of the country to a Canadian for its radiation advice on IEL…

Had the EPA IG bothered to consult with our government’s reference lab concerning the IEL Plutonium testing issue, the IG and thus your Region 5 in charge of IEL, would have readily learned  from DOE’s reference lab that Region 5/NAREL screwed up when it permitted the polluting corporations to stop the counting of IEL’s Pu samples at just merely two hours; that to do Plutonium testing right, i.e,  to obtain good certainties, DOE counts the samples a minimum of 16 hours…..vs. just 2 hours….The IG would have also been told that the EPA’s permitting the polluters to collect IEL’s samples in the field UNpreserved as was done in 2000/01  by PRPs was scientifically not complying with best available science, as failing to preserve immediately can allow the plutonium to migrate to the walls of the jars and therefore not be detected.  Our government has known that acidification is important for many decades.  These are just a few reasons why Region 5 should stop hiding behind the IG report now and view our case with fresh eyes for the sake of our citizens and future generations.  

Now, please respond in writing to each of the following, citing specific language from EPA Guidelines, etc. you have complied with:  

*  One area that is most compelling is with regard to the latest US EPA Guidelines fairly recently released pertaining to toxic vapor migration/intrusion.   We were dismayed when you wrote last year as IEL’s most recent project manager, that you believed Methane gas was the only gas of concern at IEL!   Obviously, if Region 5 refuses to recognize the presence of these other toxic gases including Radon,  the new EPA Guidelines on Vapor Intrusion won’t help us.  To assist your review that we believe will clearly prove to you there are many other dangerous gases involved, please pull up the following from IEL’s file:

>  EPA contractor PRC gas testing done in early 1990’s .  Independent experts’ review of PRC’s data base said that at least 150 tons of toxic gases ( excluding methane) are generated yearly at IEL.  Case in point.  See the borehole data sets which included PCE in a landfill borehole at approx. 500 ppb, Then, compare that with the NW Uniontown vapor testing done by EPA at approx. 20 feet down around residents’ homes, we believe also was approx. in this 500 + ppb range in soil vapors… Do these similar findings suggest possible steady state going on for toxic vapors ?….

> Please locate the radon gas testing done ( only once in all these years that we know of, it was refused thereafter, inexplicably).   You will find levels of radon gas found in the IEL gas vents went up to 3,600 pico curies.  Both Ruth Vandegrift,  formerly of Ohio Dept. of Health’s rad division, and experts down at CDC/ATSDR expressed to citizens their serious concern.   We believe you will also find test results for radon in a western monitoring well in water at 150 depth over 300 pico curies..  Again, all further testing was halted after just that one round…How was stopping radon testing scientifically supportable given those  initial EPA results? 

>  Please locate the gas work up by outside contractor from Lorton VA., ( We think his name was Jim Walsh)…He came to a public TIC meeting in the 1990’s with EPA and citizens and acknowledged his surprise ( and did a mea culpa of sorts) regarding his newer data showing levels of VOCs found in the IEL landfill gases.  If you check, we believe he said while a normal landfill may show VOCs at around  0.1 %, – while  IEL’s VOCs ranged at like 8 – 9 % . 

 

>  Please locate the gas work done by US EPA’s Emergency Response Team from Gross Isle , Michigan at IEL from 1984/85…KEY:  Those experts told us that a “typical” landfill has approx. 70 % methane, IEL even back in 1984/85 was registering only 28%, prompting EPA to bring in “auxiliary fuel” to keep the MVS gas control system running!  US EPA’s Emergency Response experts at a meeting told us:  It wasn’t the explosiveness that they were concerned about, that it was the “long term”, but that their hands were tied they said, because they could only deal with the acute explosive aspects….Please be sure to also locate

*  KEY: Please locate and review the sample results from when Emergency Response manager, Bob Bolus “hand delivered” to PEI in Cincinnati…We raised this result to the EPA IG, given the number of entities who were latter reportedly gagged by the judge, and we believe those results were part of that gag/ confidentiality agreement….What did EPA find down at PEI in those gases? !!

NOTE:  * Former landfill owner, Charles Kittinger, told citizens that PRP attorneys told him nerve gas was buried at IEL.  See PRP lawyer Haynum’s questioning of Kittinger found in the Federal Court transcripts regarding the Army disposal of Plutonium at IEL, where the attorney asks Kittinger about a chemical agent called “Arsine ( Arzine?)

> Please directly contact and consult with US EPA top gas expert, Dr. Henry Schuver in D.C. who was involved in writing the Vapor Intrusion Guidelines on the follow issue: 

 We know now that EPA erroneously all these years claimed that the only gas they need to look for is Methane, insisting it is the “tracer”, is representative of all the other toxic gases/vapors, so they asserted that if they weren’t seeing significant levels of Methane, then they assumed the toxic VOCs were not migrating either….So time and again, while conducting very very limited VOC/ toxic vapor testing around homes, when they did test for gas migration, they only looked for Methane, and reportedly according to Ohio EPA the equipment used  were meters that ONLY looked for Methane that might register around the  LEL’s-  lower explosive limit ranges, stopping at 1 %…If you ask OEPA, we believe they will tell you that 1 % = 50,000 ppb…  Benzene, last time we checked, had an EPA cut off of just 5 ppb…..

Also, with regard to the questions below concerning the sealing of the 33 monitoring, many of which were shallow, ask Dr. Schuver about the importance of such upper most shallow wells with regard to gas migration scientifically speaking, and how EPA can still justify the sealing of those shallow wells in light of US EPA’s Vapor Intrusion Guidelines, if for no other reason…?

How does Region 5 still justify this behavior described above as being sound scientifically concerning IEL?    Dr. Schuver will tell you that many of the sites EPA tests for VOCs like PCE around the country don’t even have methane gas….He will tell you relying upon methane for the VOCs is “old school”…At one point IEL vents had 24 VOCs found, (when EPA bothered to look) EPA found even Phosgene Nerve Gas, Benzene, Carbon Tet, Carbon Disulfide, Vinyl Chloride, Toluene, Xylenes, and of course radon…among others.  Our residents living on the border had their blood tested for chemicals ( see Akron Beacon Journal in around 1987 front page). One of those residents who lived right near the IEL blower house stack, had PCE in her blood up to 500 ppb. ( When she was retested, it was still over 200 )  She died of cancer this past year.  Even the SAB said Tritium vapors should be tested for, but that was asking for the moon, despite the high levels reported, up to a million pico curies of Tritium found in a drinking water well East of IEL shallow….Our Ohio EPA project manager likened that to “residents drinking water from a (nuclear) power plant.”btw… .

> The gas testing that the PRPs did in around 2005  that led to EPA allowing the PRPs to shut off the system. – Isn’t it true that this testing was geared toward ambient air  ( for the Twp.s’ supposed “walking trails” ) vs. laterally migrating gases that ER said were most significant in levels “just above the water table“?   ( Also see OEPA Stark County Court testimony, William Skoronski –  regarding gases more explosive the deeper they went) .  Isn’t it true that some of the PRP sampling was done in the winter that year? Again, there was never  scientific monitoring of other VOCs routinely done at IEL at varying depths down to the water table –  just methane.

See the Uniontown IEL ATSDR 1989 Health Assessment.  Top Risk Assessment experts at CDC, like Dr. Mark Bashor challenged Region 5 on IEL toxic vapors, fighting to get language put into the ROD that ensured ( ATSDR thought) the old gas system would be expanded, saying to the effect in this report the agency wasre deeply worried about IEL’s gases and the , potential for outward gas migration and long term health affects.  See statement where the agency sought the expansion of the IEL gas collection system on around page 22 , indicating that significant quantities of toxic vapors could be missed by that old system….So perhaps the PRPs sampling from those outdated, limited locations likewise “missed” what ATSDR was talking about could be missed?  Perhaps you can consult with Dr. Bashor and ask how he feels about the IEL gas system being shut down instead of expanded upon?

*  If the above information doesn’t convince you that more than just methane should be routinely tested for at IEL, please contact Dr. Henry Cole in D.C. who formerly worked at US EPA and his degree is in atmospheric science… Dr. Cole was one of the TAG experts hired with Superfund grant dollars, and his team of experts identified a “Benzene hot spot” on the landfill We believe  that hotspot showed Benzene 5 feet above the ground at around 8 PPM……Experts said this indicated IEL was a “co disposal site…”     One of the upper most shallow monitoring wells ( now conveniently sealed up that showed not only radiation, but Benzene in the shallow ground water in approx. 2001 at 25,000 ppb.  How does Region 5 justify scientifically sealing that well up, when contrasting that with US EPA Vapor Intrusion Guidelines?  Was it sealed because radiation was also found in that well along with the Benzene?

* Related to the above concerns, in tandem with the US EPA Vapor Intrusion Guidelinesplease refer to the National & Regional Monitored Natural Attenuation Guidelines ( Region 5/Muno/2000)…See where the Guidelines say that potential preferential pathways, conduits like outside storm sewers SHOULD BE INVESTIGATED prior to deciding up MNA at a site.  Please explain how /why these specific  MNA Guidelines were ignored concerning conducting such investigations to rule conduits for migration out,  especially given those NW Uniontown PCE readings EPA obtained and the storm sewers that run in front of the dump north and south and the permeability of area soils ( sand and gravel) with a semi confining top layer, according to Stark Soil Scientist, James Bauder, of “wind blown loess” .  Also, please consider frozen ground months of the year..

*   In reviewing the EPA Guidelines about things to consider before selecting MNA, doesn’t it also say EPA should be sure that a site’s waste is first fully characterized?  Has Region 5 fulfilled this requirement at IEL?  We don’t believe so…It routinely refused to conduct core samples.  Case in point:  See correspondence in your file given to your predecessor, Timothy Fischer….Mr. Fischer was informed via a notarize sworn statement from an eyewitness regarding their having seen Army trucks bearing many stainless steel canisters coming into IEL…If Region 5 cannot conclusive tell us the nature of what was in those Army canisters buried, how can Region 5 scientifically justify solely relying upon MNA and allow PRPS to scale back when the do test what remaining monitoring wells are at the site, for limited parameters, and no radiation?  Even a major PRP consultant, Rick Laubacher, who we believe worked for Goodyear,  told citizens that we may never know all what the Army dumped at IEL….

*  Moreover, please  review the National EPA MNA Guidelines, and find the EPA  reference pertaining to TICs – “tentatively identified compounds“… Then, review the IEL files back to the EPA Remedial investigation and post ROD, and you will find page after page of TICs in the ground water at and around IEL and in neighborhoods with private wells..  EPA found one particularly nasty group of TICs at IEL,  called “Glycol Ethers”… We believe you will see many Phthalates frequently found in residential drinking water wells as well as test wells, but blown off..dismissed by EPA. 

 Another example of a TIC found in wells offsite SW was Phosphine …According to what we gathered from ATSDR, this chemical is linked to military “White Phosphorus” and is considered a “Class A Poison”….This was found in area where there had been 14 miscarriages and two crib deaths in a short span…How can Region 5 continue to allow MNA, flushing, given ALL the above?

*  How can US EPA justify the 2004 sealing up  of 33 test wells, when such “monitoring” is all that we have left?

> If you search, the truth is,  some of highest readings for both chemicals and radiation were found in shallow wells, many of which Region 5 permitted the polluters to seal up.  Example, see 4s and 7s….One of the arguments made about allowing the sealing of all those test wells was that they were no longer needed because the ground water flow only went “east to west”…

Therefore, it is essential that you objectively review the US Geological Report ( triggered back in 1987 when ATSDR /CDC became greatly frustrated with Region 5 claiming only this east to west  linear flow.) ..US GS came in and did a 1988/89 report stating the flow was “radial” going in all directions, particularly NW and SE.

> See findings from the polluters’ own contractors’ work done at IEL in 1997 !!!!  ( the year they got to take the site over and take control of all the testing)…Find the info. where that contractor for the companies  appear to have indicated flow also appeared to have possible Easterly and Southerly components……Why should citizens trust the polluters who put the waste in IEL and NOT believe  US GS?  Even Ohio EPA will tell you the flow also goes Southwest.  See OEPA’s testimony before the Governors Blue Ribbon Panel .. Indeed, citizens were warned at a meeting held with 13 ATSDR US public health officials who met with our citizens group  and the County Prosecutor at the Uniontown fire station in preparing our  1989 Health Consultation, to NEVER let EPA tell us any differently:  ..They were adamant that the water goes in all directions, with the exception perhaps past a mile east, they qualified! …SEE Bennett & Williams colored elevation map produced while under contract with the Lake Twp. Trustees, 1999, entitled “Exhibit 46 A” found on our web site….You will under stand the concern about migration to the SE and SW better after seeing this document, we are sure.

> IMPORTANT:    Relating to the above, please look in your file for a document we had given to our OEPA rep. Larry Antonelli a few years ago concerning the “CARLISLE MUCK”  . Experts believe the PRPs got it wrong, and this information could be vital to our clean up!    Please let me know if you cannot locate this information after consulting with Antonelli.

 

*  NOTE :   Further supporting documentation regarding the shallow wells that got sealed up.  See Ohio EPA’s radiation test results from “split samples” the State collected …We believe you will discover that the State intentionally chose ALL shallow wells, and ALL Gross Alpha readings were over 100 pico curies.  How can Region 5 justify the sealing of those wells?  A senior geologist said that given those results he suspected “spent fuel” was buried at the site…

 

ADDITIONAL CONCERNS NEEDING RESPONSES BASED UPON BEST AVAILABLE SCIENCE:

 

 **  Please  explain in your written response why EPA allowed the polluters to deviate from what EPA considered and “recommended” as best practices that rad samples be preserved  immediately upon collection.

* Please explain why, after  Region 5 did not require the PRPs to follow the language stated for Gross Alpha and Beta /EPA 900 Method regarding by preserving immediately then the samples were to be preserved upon receipt at the lab…Why didn’t EPA insist those EPA requirements adhered to at the PRPs lab? I.e,  We believe your EPA instructions are that upon receipt at the lab, they are to be preserved and HELD for a min. of 16 hours before transfer and analysis..

 Instead, a second deviation took place.  We learned that EPA allowed them to take “an aliquot” still un preserved, filter it, and run IEL’s gross alpha and beta – for reportedly the purpose of then deciding which samples received further speciation for Plutonium etc…It also was reportedly used to eliminate many of the monitoring wells from further testing that year ( though we had been promised four quarters of rad testing)….Was Plutonium lost to the walls of the jars meanwhile and missed? 

*  KEY:  Please explain why EPA allowed the 2000/01 rad samples done by PRPs  for Plutonium  to stop the Pu counting at just two hours.  Please consult with DOE’s RESL lab , Idaho Nat’l lab for the DOE’s expertise on this answer…We believe you will learn that stopping the counting raises the uncertainty, that DOE routinely counts at least 16 hours for Pu, to get good results…

* Regarding the PRPs doing “low flow” in the field on IEL samples for radiation…Please explain why EPA went against US EPA’s own R & D documents, see Puls, Kerr Lab, and reportedy required the PRPs in 200/01 to filter all the IEL radiation samples at the lab, even though R & D recommended only filtering when a sample individually was above 5 NTUs, then , the sample should be analyzed BOTH ways, filtered and UNfiltered,with the weight of evidence if there is a discrepancy for the UNfiltered results…How did this comport with best available science…?

*  Please justify EPA relying upon Gross alpha drinking water 15 as the “cut off” for Plutonium ingestion at IEL, when we learned that US EPA litigated the Rocky Flats case in Colorado when their samples exceeded 0.15 pico curies….  Note:  We read in the newspaper a local consultant paid by Lake Twp. Trustees that he had claimed

 that if IEL Pu results were valid reported,  ( for example,  results from a test well  0.28  pico curies that  rad expert, Dr. Baskaran,  said was at least 1000 times higher than world wide in surface waters, (and this was deep ground water at IEL) – so how can US EPA justify relying upon Ohio’s omissions because the State failed to set the same standard as Colorado –

>Why is it scientifically acceptable for US EPA to treat our citizens so differently than Colorado, where you will find US EPA fined them hundreds of thousands of dollars for exceeding the  0.15, an amount that is lower than what was found in IEL’s sampling?

 

 Thank you for addressing these technical questions based upon best available science.  We look forward to your response to each.

 

Sincerely,

CONCERNED CITIZENS OF LAKE TWP./UNIONTOWN IEL SUPERFUND SITE, OHIO

Chris Borello, President 

 


Addendum:

 

Dear Ms. Muhtsun & Ms. Cibulski,

Re:  CCLT’s request for confirmation that Region 5 received our letter dated 1/30 on concerns pertaining to Uniontown IEL and your ensuing Five Year Review….

It may also assist you by also checking out our website which we forgot to include with our letter…  For example, we have many TV Broadcast clips, where your predecessors at Region 5, i.e, John Pereconne in your PR Dept., , stood before TV cameras, elected officials  and the town and assured us that at least, the ROD’s components of the synthetic  cap, pump & treat system of the ground water beneath the site, and expanded gas control system would be implemented…(See clips # 8  & forward to see the various town meetings at which those promises were made time and again…Citizens had wanted the dump dug up, but Region 5 said that would be too problematic, but they would do the above, to isolate those wastes..trust us……)  Our superfund TAG experts had raised serious questions about even those components , questioning whether they would be protective enough….See Dr. Cole’s speaking on this at one of those TV broadcasts…

And, perhaps one of the best examples caught on camera was more recent, in around 2002 for your review, please see CLIP # 24

In this broadcast ( done by Cleveland Channel 3 investigative team, who not only interviewed the head of Region 5 superfund, Muno, but flew to D.C. to interview Grumbly & Dr.Ttoby Clark who did the reports via Clean Sites, Inc. for Admin. Reilly…( Oh, btw, your PR Dept. might like to see the Clean Sites /Dr. Clark’s findings found in bullets in the report done for US EPA following the Grumbly report done for Bill Reilly…. Dr. Clark flew into town and  after interviewing many people in this community, including several elected officials in the County..you will see that he wrote to the effect he learned that there existed a widespread belief of a “pernicious conspiracy” against the health and welfare of our community regarding IEL and EPA’s conduct- held not just by our citizens, but by those many elected officials Dr. Clark interviewed.  ( This countered the spin that Region 5 liked to do , asserting it was just our CCLT citizens group saying these things…Dr. Clark proved otherwise in this report…

…So, certainly many folks thought Mr. Muno, then Superfund Chief at Region 5, was suggesting in Clip # 24 nothing would cause them to alter EPA’s course from what had been outlined in the 1989 ROD

NOTE:  While not on that tape, you can find the rest of the transcript from that four part series on our web site…called, “Lethal Landfill“..also on our web site in the articles section…

SEE:  Investigator Grumbly, brought in on Bill Reilly’s behalf in 1991,  stated not only on the Clip # 24 what you will see, but he also said not shown on camera, but found in the TV transcripts the following:

….” They simply made up their mind to quash absolutely what the right assessment was here and then engage in what people do when they discover evidence that goes against their theory and incorporate evidence that went with their theory“…Grumbly said…

We also urge you to check out Dr. Julie W. Rice’s report done for CCLT in approx. 2006, discussing current site conditions… I.e, The PRPs claimed many of those test wells were “clean 10 + years”  .  We believe you will see that this was not consistent with Dr. Rice’s findings.   Also, see the report done in this same time frame early 2006, by radiation Plutonium experts, Dr. Mark Bashor , Wayne State U.,and former US EPA official, Dr. Mike Ketterer, U of N. Arizona did a report on their review of the anthropogenic/man mades at IEL via testing declared valid by US EPA’s NAREL…  We would strongly urge you to view these findings, but the Ohio EPA also has the memos written by these experts where they discuss the Pu 238 found by the PRPs in approx. May 2001 being quite significant in MW 23 s., and the reading found early of Pu in a westerly test well about that result being of Pu being comparable to the ground water at Nevada Test Site from the detonation of some 800 nuclear devices ( actually, the range of Pu cited in the IG report by Gascoyne was higher than the NTS readings if we recall correctly, For  NTS we believe they said the range was like 0 .2 – 0.5 pico curies… INdeed, these rad experts from the EPA validated data from 2000/01 estimated IEL contains up to 1/2 ton of Plutonium buried…See the front page Canton Repository story in 12/01 by Brad Davis  “Radiation Mystery”…..which includes an interview with the DOE Hanford , showing IEL’s Pu readings almost 2000 times higher than near Hanford, Columbia River…..  

Dr. Baskaran & Dr. Ketterer also collected independent water samples offsite north, NW and west/sw and found man made fission material, a beta emitter, Technetium 99, in all the wells sampled in two different seasons in 2005.  Note:  Even the IG report admitted our Tc 99 detection limits were  ( jacked up  – our words, not theirs) but in essence, they said that  the 2000/01 Tc 99 results had higher Tc 99 starting detection limits – vs. what EPA normally desired.. I.e, .Instead of 5 pico curies, for some reason, IEL’s started at around 15 pico curies… Thus, ..3 xs  higher to begin with.. (please do verify this for accuracy.though)   ..In other words, had they required the PRPs to have that more conservation/typical EPA detection limit of  5 pico curies, perhaps they might have found what independent experts found ubiquitously at lower levels around the site in various directions, NOT merely straight west…supporting that radial flow were raised once again in the 1/30 letter to you…

SEE ;  http://starksummit.org   Find links in upper right corner of home page, and find “articles” link to find those TV broadcasts…Oh, you may also want to check out all the letters to US EPA Admin. in D.C. in around 2006, 2007… ( .US EPA’s own experts in R & D provided much of the information we based our technical concerns  on, as well as Dr. Baskaran, Ketterer, NRC and DOE……)…

 

Chris Borello for CCLT

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