2/25/06 to Steve Johnson, US EPA

Posted by on Feb 18, 2014 in Letters | Comments Off on 2/25/06 to Steve Johnson, US EPA

Sent Via Fax  2/5/06


Steve Johnson – US EPA Administraton

US EPA Headquarters
Washington D.C.


Dear Administrator Johnson:

In the letter we wrote to you dated 10/13/05, we asked that you investigate the misuse of an SAB panel and its report issued at our Superfund Site in 1993/94 , that is believed to have been used to subvert and undermine the scientific concerns of US EPA’s research department.

Indeed, instead of conducting the investigation envisioned by Thomas Grumbly (who had made this recommendation to former Admininstrator Reilly) to learn what went on between Region 5 and two commerical labs who had found man-made radiation at our site and the use of a non-standard method forced upon the second lab, the focus was switched to that of using IEL generically as the example for the rest of the nation – whether the US EPA Finished Drinking Water 900 Method for Gross Alpha/Beta was appropriate for not only Uniontown but any other Superfund Site suspected of containing radiation.

When we questioned once again the assertion that the all-important SAB “bottom line,” which concluded this testing method was adequate for sites expected to contain “common radionuclides“ was meant to also include man-made Plutonium, Region 5’s Superfund Chief, Richard Karl has stated on your behalf, …“it is incorrect to infer that this determination does not consider the potential presence of man-made radionuclides”…and, according to a statement recently given to a reporter by Region 5’s PR man, Mick Hans, NAREL’s John Griggs has reportedly responded to this question on whether the SAB intended “common radionuclides” to include plutonium, by allegedly stating, ”For both cases (naturally occurring & Plutonium),..the SAB found the analytical approach employed by EPA as “appropriate and sufficient.”

Mr. Johnson, we ask that the Adminstrator’s office contact each and every SAB panel member, including Robert Huggett (the panel chair), and ask them, first of all,  were they qualified professionally to address technical aspects concerning proper field collection for Plutonium as well as actual laboratory analysis; second, given that the panel documented in this same report its concerns that the the particle phase of IEL water samples was not fully accounted for (where Pu would likely be bound), did the SAB, as EPA has repeatedly claimed, really intend “common radionuclides” to include the highly particle reactive Plutonium?

Because you apparently had Mr. Karl respond to CCLT on your behalf in the letter dated 11/9/05 on this matter, we further ask for clarification regarding his claims pertaining to the filtering conducted on IEL samples, when he stated that, …”IEL samples were filtered in the laboratory after sample collection, and the filtrate portion of all groundwater samples collected at IEL has been analyzed for gross radiation along with the filtered groundwater portion of the samples. Therefore, there is no opportunity for loss of radiation count in the sample.”…

To the best of our knowledge, Mr. Karl is in serious error when he says IEL samples were filtered in the laboratory. On the contrary, all the US EPA samples collected in 1992 – 93 (the all- important rounds reviewed by the SAB panel) were infact 100% “field filtered. There is a wide consensus of radiation experts in and out of the government that “field filtering” can alter the chemistry and underestimate the true concentrations. Please see US EPA Kerr lab papers on this subject. There is also dispute at US EPA regarding Mr. Karl’s claim regarding whether there is no chance for radiation count loss when filters are “added back”. CCLT has been told that loss can occur due to margin of error for each separate additional analyses, vs. maintaining the integrity of the whole portion.

However, if Mr. Karl is only referring to the radiation testing performed in 2000/01 by the IEL PRP’s, we must bring urgently to the Administrator’s attention a serious deviation from the normal collection method that was approved by Region 5 & NAREL in 2000/01. We ask that you have Mr. Karl/ NAREL address whether it is still his/their opinion that there “was no opportunity for loss of count” when the PRPs and NAREL (in its 9/01 samples) failed to preserve with acid the radiation samples at the time of collection in the field.

CCLT has consulted with many experts, including a top NRC/DOE expert on Plutonium on this issue, and they have stressed that it is critical that the samples be preserved immediately upon collection in the field, or loss of count could indeed take place within hours. (It was expressed that any rad expert worth their salt knows this, and is as commonly known as “we know we need oxygen to breathe.”).Yet, a Region 5 letter to CCLT dated 10/3/00 by Ross DelRosario documented that the filtering (ontop of Low Flow) and then the subsequent preservation took place not in the field, but at the lab, sometime ”between 16 to 32 hours “ later.

Again, according to this expert and others, an unknown percentage of the plutonium could have precipitated out of the IEL samples and onto the container walls before the tests were actually run. Because we will presume that NAREL and Region 5 will now back away and refer you to the IG report and its expert, Dr. Gascoyne, rather than standing on their own, we also ask that you have the IG pose this same question to Gascoyne: Was there an “opportunity for loss” of plutonium by this failure to preserve in the field? Since the IEL case was closed based on Gascoyne’s opinion, it is fair to ask this be revisited. We just learned via FOIA that the IG paid Mr. Gascoyne a significant amount of money (instead of listening to the advice of your own US EPA research scientists – like Ron Wilhelm & Dr. Puls – who are already on your payrole at no additional cost to the taxpayers.)

We understand from talking to your office that you have assigned as special assistant to look these issues. We request a written response to this letter from US EPA within 14 days. Thank you for your attention to this most serious matter that has national ramifications



Christine Borello – President


Cc: Congressionals, US EPA R & D, Ohio EPA, public