CCLT/ UNIONTOWN IEL SUPERFUND SI

Re: Response to Region 5 US EPA's Karl letter dated March 22"^d concerning IEL Plutonium & related issues

We continue to be dismayed that you are deferring letters seeking your office's intervention back to Region 5: Clearly, the Region is not an impartial entity, to say the least. Please find the following responses to Mr. Karl's responses written on your behalf.

Mr. Grumbly personally conveyed to CCLT that, "the SAB clearly was not adequate in getting to the bottom of what went on between Region 5 and the labs," upon his learning from released documents by administrative order that plutonium was reported in the second round along with high levels of tritium_ At that point, Mr. Grumbly informed CCLT that he was seeking a "fullscale congressional investigation with subpoena power." It can readily be confirmed that Grumbly then went to Oversight & Investigations. In addition, a letter from former Administrator Browner to CCLT indicating additional steps taken by Grumbly should be on file as well as news clips on this matter. Therefore, it is simply not accurate to portray that Tom Grumbly either intended for Uniontown to be generically used to reinforce the Finished Drinking Water 900 Method, nor was he satisfied that the SAB was even adequate to address key issues!

Furthermore, given that the majority of the IEL SAB ad hoc panel have recently informed a reporter investigating the IEL radiation that they were NOT qualified to comment on radiation testing methodologies, it is inappropriate for this report to be used any further to justify past botched radiation testing conducted at Uniontown IEL, nor should it be used at any other site. Because it is believed that the SAB report was politically used to undermine US EPA's own research scientists concerns regarding risk/site assessment and the man-made radioactive particle phase, it is important that your office immediately correct the record, and abandon the use of the Finished Drinking Water Gross Alpha/Beta for raw untreated water at toxic dump sites.

While we will no longer discuss the SAB debacle at IEL specifically, we would direct Mr. Karl and the Administration once again to your own US EPA scientific data base found at Kerr Lab regarding concerns about field filtering - they are extensive. Moreover, it is essential that you examine the "decision tree" in documents from Kerr Lab pertaining to Low Flow, metals and filtering. While field filtering took place at IEL in 1992/93 that could cause serious underestimation of the radioactive particle phase, unfortunately, the practice continued in a" modified" version in 2000/O1. Since Low Flow was meant to negate the need to filter samples,

Page 2^, letter to Administrator Johnson - Uniontown IEL radiation

it is our understanding that your scientists indicated in these documents that, once Low Flow was performed,, the next step should be to record the turbidity in the field. IF the turbidity exceeded the 5 NTU cut off, only then should filtering be contemplated - provided that unfiltered samples are likewise collected. (The weight of evidence into ultimately go to the unfiltered results, if there is debate beyond that point, when the results are obtained.).

We request that the US EPA tell us precisely why the above described decision tree was circumvented at IEL - replaced with a blanket filtering order made to the Oakridge lab for all the IEL samples collected in 2000/01 prior to gross alpha/beta analysis - regardless of whether it was warranted or not. Please also refer to the MARLAP MANUAL, which states that it is preferred that filtering NOT take place following Low Flow.

* THE FAILURE TO PRESERVE IEL SAMPLES IMMEDIATELY IN 2000/01

Mr. Karl's response on the Administrator's behalf indicates that the concern we raised about this failure to immediately preserve is not valid. In part he wrote, ."any potential precipitation or absorption of radionuclides would be negligible in terms of some potential loss of an analyte. "...We request full disclosure of names of resource people, Mr. Karl relied upon to make this claim. We ask that their qualifications also be provided. Because we previously anticipated that Region 5/ NAREL would hide behind the IG report's consultant, we had also requested that Dr. Gascoyne be asked to address the question: Would there be any opportunity for loss of count if samples were not immediately preserved? It is essential that there is a full airing of this matter so that a proper scientific peer review can be made by experts from both academic institutions and other governmental agencies.

Contrary to what Mr. Karl and his advisors have stated, we have been informed by a top US government radiation scientist that almost all plutonium (and other insoluble isotopes; transurances; as well as thorium) can be lost before analysis may take place due to precipitation

out if not immediately preserved. This specific example was offered to support this: A sample was spiked with plutonium and sent, unacidified to the lab as a test. The lab caught that it was received unpreserved, 'so it added acid, stirred it and held it a length of time before analysis. The lab flunked. It only recovered THIRTY PERCENT of the plutonium that had been added

Therefore, as with the concerns. about field filtering, filtering ontop of Low Flow, this failure to properly preserve the IEL samples immediately in the field is not a small matter. We request this letter be given top priority by the Administration arid a written response be provided to all issues raised in this letter as soon as possible. Thank you.

Yours Truly,

Christine Borello - President
Concerned Citizens of Lake Twp./ IEL

cc: Congressionals, US EPA R & D, NRC, Ohio EPA, ES & T, National Academy of Sciences, Media, public