Fax to Supervisor Bellone: 853-4818 From Dr. Carmine F. Vasile 1/30/14 631-758-6271 Attached, please find my Petition For Pine Barrens/BNL Health Assessment & To Amend All Past Health Assessments/Consultations That Failed To Address Cancers Caused By Radon & Its Deadly Progeny [1] [2] It provides evidence that the author of your evasive response to my post is extremely ill-informed, at best. I also attached letters from the EPA to support my comments. Date: Wed, 29 Jan 2014 11:44:46 -0800 To: [email protected]From: [email protected]Accordingly, please correct your post and support said Petition & Objection annexed thereto. Yours truly, Dr. Carmine F, Vasile Subject: Suffolk County Executive Steven Bellone commented on your post. Suffolk County Executive Steven Bellone commented on your post . Suffolk County Executive Steven Bellone wrote: "As with all emerging contaminants, SCDHS is concerned with potential radionuclide contamination, and remains proactive in investigating potential sources. In fact, the SCDHS has the only certified radiological laboratory on Long Island. To date, the SCDHS has not confirmed any significant concentrations of radionuclides in public water supply wells in Suffolk County. With respect to your specific questions, radon levels are naturally low on Long Island compared with background levels in other areas of the country, tritium levels have been well under drinking water standards, and there have been no confirmed significant detections of lead-210 (which is a naturally occurring radionuclide for which there is currently no drinking water standard). The Suffolk County Department of Health Services, Office of Water Resources currently tests all community water supply wells for radionuclides every 3 years, except that Suffolk County Water Authority wells closest to Brookhaven National Laboratory are sampled every year as a precaution. In addition, there is also a monitoring well network upgradient of the Suffolk County Water Authority Wells that are frequently sampled by Suffolk County Department of Health Services staff, Suffolk County Water Authority and Brookhaven National Laboratory. This sampling exceeds the requirements of the Safe Drinking Water Act. The NYSDOH, the USEPA, and the SCDHS have previously reviewed the Suffolk County Water Authority’s Annual Water Quality Report supplements that included detections of Lead-210. However, these detections were determined to be likely false positives, and subsequent resampling by SCWA in 2013 did not identify any detections. The standard error, also known as uncertainty, for nearly all of the historical detections were close to or more than the actual measurements reported by Suffolk County Water Authority’s contract laboratory. The Suffolk County Water Authority has investigated the high uncertainties and they were informed by their contract laboratory that the results were an anomaly of the analysis. Radon is a naturally occurring radioactive gas produced from the breakdown of radium which may be present in certain soil and rock geological formations. Studies conducted by the USEPA reveal that radon is a natural constituent of most groundwaters. Based on historical monitoring and research, it has been determined that the radon levels detected in Suffolk County water resources were below the natural background level found in other areas of the country. At present, there is no enforceable drinking water standard for radon; however, please note that our staff in the Suffolk County Department of Health Services, Office of Water Resources routinely collect samples for gross alpha, gross beta and tritium analyses. The gross alpha analysis would identify the presence of radon’s parent compound, Radium-226, which is an alpha emitter and regulated under the USEPA Radionuclide Rule; gross alpha results in public water supplies in Suffolk have never approached drinking water standards. Finally, in response to your inquiry on the BNL sewage treatment plant, the NYSDEC has determined that the relocation of the outfall to groundwater will have beneficial effects on the Peconic River. Our evaluation of the proposed discharge, using best available modeling and assessment tools, shows that the outfall will not be near the contributing areas to any public supply wells, and the discharge is not expected to impact public water supplies." Carmine Vasile Suffolk County Executive Steven Bellone January 27 at 9:55am · Comment Re: "Bellone eyes added sewers to fight pollution" by Emily Dooley, Newsday online (January 23, 2014) Dear Mr. Bellone: Did you see the following comment? If so, please address this issue because nitrogen doesn't cause cancer. NEWSDAY COMMENT "If Supervisor Bellone read water quality & supplemental well reports @ scwa.com, which show huge amounts of Radon in wells near BNL, he would know the "number one threat to public health and safety in Suffolk County is not" nitrogen pollution of ground and surface waters -- it's pollution from some of the 39 isotopes of Radon; the 2nd leading cause of lung cancer. One of its isotopes, Radon-220; produces the most carcinogenic of all water contaminants, Lead-210, which is found in SCWA wells, as is Tritium (H-3). Lead-210's cancer risk is about 20,000 times higher than Tritium's, yet the SC Health Department tests our groundwater only for Gross Alpha, Gross Beta & Tritium. To make matters worse, the DEC recently gave tentative approval to DOE's application to divert radioactive discharge from BNL's sewage treatment plant from the fast-moving Peconic river to slow-moving ground water in the Pine Barrens. Because NYS allows water companies to blend contaminated water sources if it's cheaper than treating, once radionuclides from this new source reaches SCWA wells it will be pumped (untreated) back to the surface to re-pollute ground water, lakes & streams. Why is Bellone allowing this?"
Transcript
Fax to Supervisor Bellone: 853-4818 From Dr. Carmine F. Vasile 1/30/14 631-758-6271
Attached, please find my Petition For Pine Barrens/BNL Health Assessment & To Amend All Past Health Assessments/Consultations That Failed To Address Cancers Caused By Radon & Its Deadly Progeny [1] [2] It provides evidence that the author of your evasive response to my post is extremely ill-informed, at best. I also attached letters from the EPA to support my comments.
Accordingly, please correct your post and support said Petition & Objection annexed thereto. Yours truly,
Dr. Carmine F, Vasile Subject: Suffolk County Executive Steven Bellone commented on your post. Suffolk County Executive Steven Bellone commented on your post.
Suffolk County Executive Steven Bellone wrote: "As with all emerging contaminants, SCDHS is concerned with potential radionuclide contamination, and remains proactive in investigating potential sources. In fact, the SCDHS has the only certified radiological laboratory on Long Island. To date, the SCDHS has not confirmed any significant concentrations of radionuclides in public water supply wells in Suffolk County. With respect to your specific questions, radon levels are naturally low on Long Island compared with background levels in other areas of the country, tritium levels have been well under drinking water standards, and there have been no confirmed significant detections of lead-210 (which is a naturally occurring radionuclide for which there is currently no drinking water standard). The Suffolk County Department of Health Services, Office of Water Resources currently tests all community water supply wells for radionuclides every 3 years, except that Suffolk County Water Authority wells closest to Brookhaven National Laboratory are sampled every year as a precaution. In addition, there is also a monitoring well network upgradient of the Suffolk County Water Authority Wells that are frequently sampled by Suffolk County Department of Health Services staff, Suffolk County Water Authority and Brookhaven National Laboratory. This sampling exceeds the requirements of the Safe Drinking Water Act. The NYSDOH, the USEPA, and the SCDHS have previously reviewed the Suffolk County Water Authority’s Annual Water Quality Report supplements that included detections of Lead-210. However, these detections were determined to be likely false positives, and subsequent resampling by SCWA in 2013 did not identify any detections. The standard error, also known as uncertainty, for nearly all of the historical detections were close to or more than the actual measurements reported by Suffolk County Water Authority’s contract laboratory. The Suffolk County Water Authority has investigated the high uncertainties and they were informed by their contract laboratory that the results were an anomaly of the analysis. Radon is a naturally occurring radioactive gas produced from the breakdown of radium which may be present in certain soil and rock geological formations. Studies conducted by the USEPA reveal that radon is a natural constituent of most groundwaters. Based on historical monitoring and research, it has been determined that the radon levels detected in Suffolk County water resources were below the natural background level found in other areas of the country. At present, there is no enforceable drinking water standard for radon; however, please note that our staff in the Suffolk County Department of Health Services, Office of Water Resources routinely collect samples for gross alpha, gross beta and tritium analyses. The gross alpha analysis would identify the presence of radon’s parent compound, Radium-226, which is an alpha emitter and regulated under the USEPA Radionuclide Rule; gross alpha results in public water supplies in Suffolk have never approached drinking water standards. Finally, in response to your inquiry on the BNL sewage treatment plant, the NYSDEC has determined that the relocation of the outfall to groundwater will have beneficial effects on the Peconic River. Our evaluation of the proposed discharge, using best available modeling and assessment tools, shows that the outfall will not be near the contributing areas to any public supply wells, and the discharge is not expected to impact public water supplies." Carmine VasileSuffolk County Executive Steven Bellone January 27 at 9:55am ·
Comment Re: "Bellone eyes added sewers to fight pollution" by Emily Dooley, Newsday online (January 23, 2014) Dear Mr. Bellone: Did you see the following comment? If so, please address this issue because nitrogen doesn't cause cancer.
NEWSDAY COMMENT "If Supervisor Bellone read water quality & supplemental well reports @ scwa.com, which show huge amounts of Radon in wells near BNL, he would know the "number one threat to public health and safety in Suffolk County is not" nitrogen pollution of ground and surface waters -- it's pollution from some of the 39 isotopes of Radon; the 2nd leading cause of lung cancer. One of its isotopes, Radon-220; produces the most carcinogenic of all water contaminants, Lead-210, which is found in SCWA wells, as is Tritium (H-3). Lead-210's cancer risk is about 20,000 times higher than Tritium's, yet the SC Health Department tests our groundwater only for Gross Alpha, Gross Beta & Tritium. To make matters worse, the DEC recently gave tentative approval to DOE's application to divert radioactive discharge from BNL's sewage treatment plant from the fast-moving Peconic river to slow-moving ground water in the Pine Barrens. Because NYS allows water companies to blend contaminated water sources if it's cheaper than treating, once radionuclides from this new source reaches SCWA wells it will be pumped (untreated) back to the surface to re-pollute ground water, lakes & streams. Why is Bellone allowing this?"
FAX to: Thomas R. Frieden, MD, MPH Director, Centers for Disease Control and Prevention CDC) Administrator, Agency for Toxic Substances and Disease Registry (ATSDR) 4770 Beauford Hwy MSF61 Atlanta, GA 30341 770-488-0604 (F: 488-3385)
December 30, 2013 Dr. Carmine F. Vasile Ph.D. Electrophysics 60 Herbert Circle Patchogue, NY 11772 631-758-6271 (F: 730-3918)
Petition For Pine Barrens/BNL Health Assessment & To Amend All Past Health Assessments/Consultations That Failed To Address Cancers Caused By Radon & Its Deadly Progeny [1] [2]
Dear Dr. Frieden: Please support my enclosed Objections against DOE’s application on behalf of the Brookhaven National Laboratory (BNL) to divert radioactive sewage treatment plant discharge from the fast-moving Peconic River to slow-moving groundwater via recharge beds that will further pollute groundwater beneath the Pine Barrens; the largest source of drinking water on long Island. Please issue the following orders to protect the Public because the NYSDEC gave tentative approval of DOE’s application without petitioning ATSDR for a Health Assessment: (I) A Pine Barrens Health Assessment of obvious health hazards associated with diverting radioactive sewage treatment plant discharge from the fast-moving Peconic River to slow-moving groundwater via recharge beds in the Pine Barrens, from which the Suffolk County Water Authority (SCWA) annually pumps millions of gallons; (II) Amendments of all previous ATSDR Health Assessments for Long Island to include known cancer risks of Radon; including the July 6th 2011 BNL Health Assessment that also failed to include cancers known to be caused by Radon seepage into BNL’s buildings where its radioactive daughters Polonium, Lead, Bismuth & Thallium plate out in human lungs. [1] (III) Warnings of vast, undisclosed sources of Radon, based on SCWA test results like those in Objection-Exhibits A & B, because Radon is the 2nd leading cause of Lung Cancer in non-smokers, contributes to cancers in smokers & children that take frequent showers & baths.
Table MW2. Radionuclides in On-Site Monitoring Wells* [From BNL Public Health Assessment (7/6/11)]
Radionuclide Concentration Range (pCi/L)
Drinking Water Standard
(USEPA MCL) (pCi/L)
Location (OU)
Lead-210 130−3,340† 1.2 3,5
Strontium-89 8−24.2 8 3
Strontium-90 8−769 8 ¼, 3, 5
Tritium 245−1,590,000 20,000 1, 3, 5
Potassium-40* 187−660 280 3, 5
Radium-226 17.9−77.3 3 3, 4
*NOTE: ATSDR’s BNL Health Assessment is also defective because it failed to include health effects discussed in early Site Environmental Reports (SERs) dating back to 1947; opened by these links @ www.bnl.gov/ewms/ser/default.asp: 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2006 | 2005 | 2004 | 2003 | 2002 | 2001 | 2000 | 1999 | 1998 | 1997 | 1996 | 1995 | 1994 | 1993 | 1992 | 1991 | 1990 | 1989 | 1988 | 1987 | 1986 | 1985 | 1984 | 1983 | 1982 | 1981 | 1980 | 1979 | 1978 | 1977 | 1976 | 1975 | 1974 | 1973 | 1972 | 1971 | 1967-1970 | 1966 | 1965 | 1964 | 1963 | 1962 | 1947-1961.
SCWA Will Repollute Suffolk County Even More Because of ongoing violations of 40 CFR §300.430(a)(1)(iii)(F) and related CERCLA statutes by managers of
BNL’s Superfund cleanup program, and other misconduct, the SCWA – America’s largest public water company serving 1.2 customers in 2011 - has been allowed to distribute millions of gallons of un-treated, un-tested radioactive water mixtures to millions of men, women & children; including thousands of unsuspecting, out-of-state tourists. Objection-Exhibits A, & B and letters @ www.gfxtechnology.com/CODE&CDC-Letter.pdf indicate EPA, DEC, SCHS, CDC & NYS health officials have concealed long-lived sources of Long Island’s vast Radon supply; including radioactive liquids/coolant from BNL’s reactors. The aforementioned SERs show vast, underground Radon sources were concealed from the Public since 1947 -- including radioactive waste & reactor coolant illegally injected into sole-source aquifers on an island that once had one of lowest average indoor-radon concentrations in NYS. [3]
Amended BNL Assessment All SERs cited above must be included in an Amended BNL Assessment because they contain proof liquid
radioactive waste was pumped into the Peconic River and the ground for decades, thereby creating a vast underground 1 Enclosed Objections also @ www.gfxtechnology.com/DEC-BNL.pdf. 2 See Objection-Exhibit F from The Natural Decay Series of Uranium, Radium & Thorium (Argonne National Laboratory, EVS Health Fact Sheet, August 2003 3 According to a 1988 report, “The counties with the lowest average indoor-radon concentrations are located in the Adirondack Mountains and on Long Island.” [Kunz, C.: Laymon, C.: and Parker, C. Gravelly Soils and Indoor Radon. In: Proceedings for the 1988 International Symposium on Radon and Radon Reduction Technology, Denver, CO, Oct. 1988.
@ www.gfxtechnology.com/PBHA.pdf
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source of Radon that continues to poison Suffolk County; especially when its pumped back to the surface from over 600 SCWA wells. The Public needs to know that neither the SCDHS nor NYDOH test public/private/irrigation-wells, homes or buildings for Radon. Nor do they issue Radon warnings of dangers from the 2nd leading cause of lung cancer.
• The LI & Bethpage Breast Cancer studies are also frauds because they exclude Radon in VOCs. SCWA’s Radon & Lead-210 Test Results Contradict CDC & EPA Officials
Please take notice that SCWA test results in Objection-Exhibits A & B show William Cibulas Jr., Ph.D., CAPT, US Public Health Services, Director, Division of Health Assessment and Consultation lied more than once in response to one of my complaints.
His April 27, 2009 letter is one of several @ www.gfxtechnology.com/CODE&CDC-Letter.pdf, including one dated April 20, 3013 by EPA Chief Tompkins in which she indicated the SCDHS tests NTNC water systems for only Gross Alpha, Beta & Tritium – not Radon, its parents, progeny, or other radionuclides regulated under the Safe Drinking Water Act since 1976. Table A below compares several outright lies by CAPT. Cibulus that were suborned Dr. Gregory Ulirsch; recently contradicted by EPA Chief Tompkins & SCWA test results linked to www.scwa.com.
Table A: Lies & Contradictions About Radon CAPT Cibulas wrote: “Finally, there is the reporting of 329 pCi/L of radon in a sample. The SCDHS, as documented in a report they produced with the NYSDOH in 1988, identified the average level of radon as 340 pCi/L” -- which agrees with SCWA tests shown in Objection Exhibits A & B.
Yet, according to a 1988 report, “The counties with the lowest average indoor-radon concentrations are located in the Adirondack Mountains and on Long Island..” [Kunz, C.: Laymon, supra.] EPA Chieh Tompkins wrote “For the Lambert Avenue well field, Suffolk County has indicated that radiological sampling occurred in 2008 with analytical results showing no detections for gross alpha and radium 228”; another EPA Chief wrote: “On Long Island where uranium, and radium and radon in the ground is low, radon in water borders on being inconsequential.”
CAPT Cibulas wrote: “Moreover, the levels found in SCWA water are consistent with natural background levels in other parts of the country. Although radon at 329 pCi/L is not considered a high value from a national background perspective, there currently is no Federal or New York State Maximum Contaminant Level (MCL) for radon in drinking water for comparison.”
CAPT Cibulas lied: Radon-220 has been covered by the federal Gross Alpha MCL of 15 pCi/L under the Safe Drinking Water Act’s Radionuclides Regulations since 1976 – but the SCWA doesn’t specify which of the 39 known isotopes of radon from 193Rn to 231Rn it captures in sealed containers needed to test for VOCs!
CAPT Cibulas wrote: “The big issue with radon in drinking water is the possibility of volatilization of radon and resulting indoor air contamination.” – without pointing out the dangers to children of taking long showers in water having 329 pCi/L!
CAPT Cibulas lied: 329 pCi/L is extremely high. As shown in Objection-Exhibit C, at this level the EPA action level of 4 mrem/L-Air is exceeded in less than 13 minutes with a 10 liter/minute (LPM) shower running in an un-vented bathroom.
SCWA REPEATEDLY LIES The SCWA routinely reports huge amounts of Radon in dozens of wells, then lies about its dangers, EPA’s
proposed 300 pCi/L MCL, and that Radon-220’s MCL is 15 pCi/L in the absence of other Alpha-emitters, e.g.:
(From Objection-Exhibit A)
Table B: Lies & Contradictions About Radon’s Most Deadly Progeny: Lead-210 In April of 2009 CAPT Cibulas wrote: “The report of lead-210 at 1,240 pico Curies per Liter (pCi/L) is also very suspect.” The result reported is 1,240 plus or minus 1,120 pCi/L. The standard deviation with this measurement is huge and we believe reflective that there is a measurement problem, not a contamination problem.”
But in April 2013, EPA Chief Tompkins contradicted Cibulas as follows: “For the Lambert Avenue well field, Suffolk County has indicated that radiological sampling occurred in 2008 with analytical results showing no detections for gross alpha and radium 228. As per the Radiouclides Rule, the next round of sampling is 2017. This Information also holds for the Lambert Ave well field located in Mastic, long Island.”
It would appear Chief Tomkins wasn’t told numerous SCWA test results, including those in Objection-Exhibit B, show huge Lead-210 & Radon levels have been detected since 2000. [4] 4 www.gfxtechnology.com/Table-A.pdf & www.gfxtechnology.com/Table-B.pdf.
3
They also show many samples were taken showing Lead-210 levels up to 856 pCi/L were detected in 59 tests made in 2011 -- with no average or standard deviation being reported.
Unconscionable Lies The following lie by CAPT. Cibulas is unconscionable: “The standard deviation with this measurement is huge and we believe reflective that there is a measurement problem, not a contamination problem.” because he should know EPA Method 909.0, Determination of Lead-210 in Drinking Water indicates the sensitivity defined in the National Interim Primary Drinking Water Regulations (NIPDWR) is approximately 0.7 pCi/L for a one liter sample size using liquid scintillation counting and 0.2 pCi/L using a low background beta counter. [5] NOTE: In its 2012 AWQR, the SCWA also lied in writing: “In 2011 we monitored 31 wells near Brookhaven National Laboratory for gross alpha and beta particles, tritium, and gamma radiation” because the referenced Table C has no Gross Gamma activity results, inconsistent Gross Beta results, and no Gross Alpha results for Lead-210’s Alpha-emitting progeny: Polonium, Lead, Bismuth & Thallium that can plate out in lungs of SCWA’s 1.2 million customers. [6]
Table C: Huge Lead-210 Levels Up; 713 Times The MCL of Table MW2 Above
(From Objection Exhibit-A & 2012 AWQR)
Accordingly, please no longer turn a blind eye to the plight of Long Islanders being poisoned by Radon &
Radionuclides in our water supply.
Yours truly,
Dr, Carmine F. Vasile
5 Determination of Lead-210 in Drinking Water: EPA Method 909.0
1. Scope and App1ication 1.1. Lead-210 is not regulated by the National Interim Primary Drinking Water Regulations (NIPDWR). However, based upon its maximum permissible concentration (MPC) published in NBS Handbook 69, the maximum concentration level (MCL) calculated by applying the formula in the NIPDWR would be 1 pCi/L or less, depending, upon the choice of critical organ. 1.2. The sensitivity of the method as defined in the NIPDWR is approximately 0.7 pCi/L for a one liter sample size using liquid scintillation counting and 0.2 pCi/L using a low background beta counter.
6 Said Table MW2 shows huge amounts of Lead-210 (210Pb) & Radium-226 (226Ra), yet CAPT Cibulas & SCWA officials ignore the health hazards of 222Rn, which belongs to the radium and uranium-238 decay chain, and has a half-life of 3.8235 days. Its four first products (excluding marginal decay schemes) are very short-lived, meaning that the corresponding disintegrations are indicative of the initial radon distribution. Its decay goes through the following sequence, based on Objection-Exhibit F-2:
Objection Exhibits F-3 & -4 show 219Rn & regulated 220Rn, which belong to the radium, uranium-235 & thorium-232 decay chains, and have respective half-lives of 4 & 56 seconds go through similar decay sequences ending in stable 207Pb & 208Pb isotopes.
www.gfxtechnology.com/DEC-BNL.pdf & www.gfxtechnology.com/DEC-BNL.html FAX to: Mark Carrara, NYSDEC SUNY @ Stony Brook, 50 Stony Circle Road, Stony Brook, NY 11790, 631-444-0352, Fax: 0360
FAX CC: Joe Martens, DEC Commissioner, Albany, NY 12233-3251 (518)-402-8452 FAX: 8541 Nirav R. Shah, MD, M.P.H., Commissioner, NYSDOH (518)-474-2011 FAX: 6608 Gina McCarthy, EPA Administrator, Washington, DC 20460 (202) 564-4700 Fax: 202-501-1450
December 23, 2013 Dr. Carmine F. Vasile 60 Herbert Circle Patchogue, NY 11772 631-758-6271 Cell: 631-07-7839 Fax: 631-730-3918
Corrections & Additions to: Comments & Objections Faxed & Mailed 12/20/13 Re: Application ID:1-4722-60032/00072 Described in Legal Notice Inserted Below
Dear Mr. Carrara and those copied: Please replace my Comments & Objections faxed/mailed 12/20/13 with the corrected version, attached. Please take notice of the following links to Site Environmental Reports (SERs) recently posted after I
These SERs contain proof that liquid radioactive waste was pumped into the ground for decades thereby creating a vast underground source of Radon that continues to poison Suffolk County; especially when its pumped out of the ground by the SCWA and others --- yet neither the SCDHS nor NYDOH test either public, private or irrigation wells, or homes & buildings for Radon. Nor do they issue Radon warnings of dangers from the 2nd leading cause of lung cancer in non-smokers, e.g.:
Table 22 From 1964 ENVIRONMENTAL MONITORING RADIADON LEVELS AT BROOKHAVEN NATIONAL LABORATORY, by A.P. Hull (June 1966) @
www.gfxtechnology.com/DEC-BNL.pdf & www.gfxtechnology.com/DEC-BNL.html FAX to: Mark Carrara, NYSDEC SUNY @ Stony Brook, 50 Stony Circle Road, Stony Brook, NY 11790, 631-444-0352, Fax: 0360
FAX CC: Joe Martens, DEC Commissioner, Albany, NY 12233-3251 (518)-402-8452 FAX: 8541 Nirav R. Shah, MD, M.P.H., Commissioner, NYSDOH (518)-474-2011 FAX: 6608 Gina McCarthy, EPA Administrator, Washington, DC 20460 (202) 564-4700 Fax: 202-501-1450
December 21, 2013 Dr. Carmine F. Vasile 60 Herbert Circle Patchogue, NY 11772 631-758-6271 Cell: 631-07-7839 Fax: 631-730-3918
Corrections & Additions to: Comments & Objections Faxed & Mailed 12/20/13 Re: Application ID:1-4722-60032/00072 Described in Legal Notice Inserted Below
Dear Mr. Carrara and those copied: Please accept and support these comments & objections in opposition to DOE’s application on behalf of the Brookhaven National Laboratory (BNL) site in Upton, NY, to divert sewage treatment plant discharge from the Peconic River to groundwater via recharge beds. This diversion must not be allowed because BNL’s plant discharge is radioactive and its groundwater already has huge amounts of radionuclides, according to:
Table MW2. Radionuclides in On-Site Monitoring Wells [From BNL Public Health Assessment (7/6/11)]
Radionuclide Concentration Range (pCi/L)
Drinking Water Standard (USEPA
MCL) (pCi/L) Location
(OU)
Lead-210 130−3,340† 1.2 3,5
Strontium-89 8−24.2 8 3
Strontium-90 8−769 8 ¼, 3, 5
Tritium 245−1,590,000 20,000 1, 3, 5
Potassium-40* 187−660 280 3, 5
Radium-226 17.9−77.3 3 3, 4
This Table and dozens of others in the BNL Health Assessment show BNL & EPA managers in charge of BNL’s Superfund cleanup violated 40 CFR §300.430(a)(1)(iii)(F), as noted in the box inserted beneath your Notice at the right; entitled “CERCLA GROUNDWATER PROTECTION”. To make matters worse, Exhibits A, B-1 to B-3 show that since at least 2002, the Suffolk County Water Authority (SCWA) – America’s largest public water company serving 1.2 customers in 2011 -- has not treated radioactive water to non-detect levels that has been distributed to over million men women & children since at least 2002. Instead, the SCWA blends untested, untreated radioactive well water from shallow wells with untested, untreated water from less contaminated, deeper well to pass the safe drinking water act. If that doesn’t work, instead of closing wells it falsifies test results and/or federal requirements, as noted in my insert in the lower right corner of Exhibit A-1; the Educational Information page from the 2012 Annual Water Quality Report. Therefore, long-lived, radioactive sewage treatment plant discharge will be recycled and re-pollute much of Suffolk County’s groundwater and DOE’s application must be rejected to protect you me and the general public.
BNL Also Contaminated The Peconic River Wthh Radon-Producing Radionuclides
The ATSDR’s Health Assessment for BNL fails to address cancers caused by radon and its decay products identified in Exhibit F, and the 22 cancers covered by the Energy Employees Illness Occupation Act of 2000 (EEOICPA); notwithstanding the EEOICPA has paid billions of dollars in compensation to thousands of employers and their survivors nationwide – including BNL workers/survivors. ATSDR also ignored RADON; the 2nd leading cause of lung cancer in non-smokers and the only reference to RADON appears on pg. 90 as follows:
• “For example, ATSDR recommends that the radon emanation method be used in conjunction with the gamma spectroscopy scan when elevated or inconsistent gamma levels are detected.”
On page 4, ATSDR indicates the sewer treatment plant’s discharge accounts for approximately 90% of the water flow in the Peconic during the spring and almost 100% during the late summer and fall; e.g.:
• “The Peconic River enters BNL property northwest of the Sewage Treatment Plant (STP) outfall and exits the property to the southeast. The discharge from the STP accounts for approximately 90% of the water flow in the Peconic during the spring and almost 100% during the late summer and fall. When the water table is below the bottom of the riverbed, the effluent from the STP flows into the Peconic River and into the surrounding aquifer. In the general vicinity of the STP outfall, the Peconic is a gaining stream. That is, it receives groundwater seepage from the surrounding aquifer. This situation reverses as the downstream distance from the STP outfall increases.”
But ATSDR ignored health threats posed by radionuclides like those in Exhibits D-1, -2; Table SD1: Contaminants in On-Site Sediments. NOTE:
• Table SD1 has two columns entitled “On-site Peconic River” & “On-Site Recharge Basins, Wetlands, and Agricultural Fields” showing significant amounts of parents and decay products of radon remain in the Peconic River; including:
• 228, 234Th; 233, 234, 235, 238U; 226Ra; 228At, 210, 212, 214Pb & 208Tl identified in Exhibits F-1 to 4; “Natural Decay Series: Uranium, Radium, and Thorium”, Argonne National Laboratory, EVS Human Health Fact Sheet, August 2005.
ATSDR also failed to estimate cancer risk of the radionuclides listed in the tables in Exhibits B-1 to 3 & C (“Unregulated Lung-CancerThreats From Radon-219/220/222”) They even disregarded states like Vermont that issue radon warnings and guidelines like those in Exhibits E-1, -2 for thousands of private well owners – unlike the NYSDOH & SCDHS.
RADON LEVELS WILL RISE & MORE WILL DIE According to a 1988 report, “The counties with the lowest average indoor-radon concentrations are located in the Adirondack Mountains and on Long Island..” [Kunz, C.: Laymon, C.: and Parker, C. Gravelly Soils and Indoor Radon. In: Proceedings for the 1988 International Symposium on Radon and Radon Reduction Technology, Denver, CO, Oct. 1988. [From:
www.aarst.org/proceedings/1994/1994_06_Identifying_High_Risk_Areas_in_New_York_State--Mappi.pdf] Although the “EPA expects to return usable ground waters to their beneficial uses whenever practicable”
harmful levels of radionuclides – including Radon and its most carcinogenic daughter Lead-210 (210Pb) -- have risen since 1988 and have contaminated dozens of public wells south of BNL according to Exhibits A & B from the SCWA’s Annual Water Quality Reports for 2003, 2010 & 2012. There are 39 known isotopes of radon (Rn) from 193Rn to 231Rn with dozens of decay products, including Lead-210, which is also found in huge amounts hundreds of times the MCL cited in Table MW2, both on and off-site. Exhibit F shows:
(1) The most stable isotope 222Rn, with a half-life of 3.823 days, is the 6th decay product of 238U and the 1st decay product of 226Ra. It produces Lead-210 (210Pb)
(2) The 6th decay product of 232Th is 220Rn, which has a half-life of 56 seconds, is the 1st decay product of 219Ra; 4th decay product of 228Ra.
(3) The 8th decay product of 235U is 219Rn, which has a half-life of 4 seconds, is the 1st decay product of 223Ra. Proof BNL Contaminated The Peconic River Wthh Radon-Producing Radionuclides
As proof BNL is responsible for contaminating our drinking water, take notice of the following false & misleading statements from the SCWA’s 2012 Annual Water Quality Report (AWQR; pg. 5) @ www.scwa.com; Exhibits A-1:
(a) “Some radionuclides emit gamma (also called photon) radiation. Radioactivity in water is measured in picoCuries per liter (pCi/L). The EPA has set the maximum contaminant level (MCL), the highest level allowed in drinking
water, for gross alpha (all alpha emitters except uranium and radon) at 15 pCi/L. – which is false because Radon-220 is not exempt from the 15 pCi/L Gross Alpha MCL,
(b) NYS considers 50 pCi/L to be the level of concern for gross beta. Due to differences in energy levels, the MCL in pCi/L for a particular photon emitter will depend on the type of radionuclide present.” – which is also false; “The Radionuclides Rule uses a “sum-of-the-fractions” method to determine whether a system is in compliance with the MCL for beta particle and photon radioactivity (40 CFR 141.66(d)). This method is used because each photon emitter targets a different organ of the body, which results in a different magnitude of risk. The sum of the beta and photon emitters shall not exceed 4 millirems/year (40 CFR 141.66(d)(2)).” [Quote from pp. II-5, -6, EPA’s Implementation, Guidance for Radionuclides Exhibits G-1, -2]
(c) “In 2011 we monitored 31 wells near Brookhaven National Laboratory for gross alpha and beta particles, tritium, and gamma radiation. The table below lists a summary of the 2011 test results by distribution area.” --- but the “table below” has no Gross Gamma activity; only Alpha & Beta.
SCWA Misrepresents Dangers of Radon
Said 2012 AWQR misrepresents the dangers of Radon & misrepresents the MCL of Radon-220, e.g.:
Contrary to the aforementioned misrepresentation “Currently there is no established state or federal MCL for radon”, the EPA Table “Attachment A” below shows there is indeed a federal MCL for Radon-220 and 54 other Alpha emitters under the 15 pCi/L gross alpha MCL standard; shown in the decay chains in Exhibit F-2 to F-4.
Conclusion If DOE’s application is granted, radon levels in drinking water will continue to rise above 2011 levels
levels because radon-producing radionuclides will be diverted from the Peconic River into Suffolk County’s aquifers via the Pine Barrens. BNL must not be allowed to divert sewage treatment plant discharge from the Peconic River to groundwater via recharge beds that will further contaminate the three or four aquifers used by the SCWA for blending, as indicate in Exhibit B, e.g.:
• “Tables 1-6 from the SCWA’s 2003 Annual Water Quality Report @ http://gfxtechnology.com/WQR-03.pdf indicate the SCWA had: (a) 213 wells in the Upper Glacial Aquifer, (b) 309 wells in the Magothy Aquifer, (c) No wells in the Raritan Aquifer, (d) 4 wells in the Lloyd Aquifer (526 total). In 2003 they tested for unspecified Radon isotopes in and undisclosed number of locations. Test results in Tables 1-6 for unspecified Radon isotopes and Radium-226’s most deadly decay product, Lead-210, indicated huge radon concentrations between 209 & 549 pCi/L in Distribution Areas 1B, 5, 6, 8, 9, 10, 11, 12, 15, 18, 20, 23, 26, 30, 35 & CHWD. Lead-210 levels over 750 times its Beta/Photon MCL of 4 mrem/yr were found. The SCWA falsely claims there is no established federal MCL for Radon or Lead –210. In fact, if only Radon-220 and Lead-210 are present their respective MCL’s are 15 pCi/L & 4 mrem/yr. The tables below show depraved-indifferent violations of the EPA’s Radionuclides Rule include: No Radium-226/228 test results and No Beta/Photon test in mrem/yr for Lead-210 + Cesium-137.” [From Exhibit B-1]
• “Tables 1-6 From the SCWA’s 2011 Annual Water Quality Report @ www.scwa.com indicate the SCWA had: (a) 268 wells in the Upper Glacial Aquifer, (b) 329 wells in the Magothy Aquifer, (c) 3 wells in the Raritan Aquifer, (d) 3 wells in the Lloyd Aquifer (603 total). In 2010 they tested for radon 85 locations. Test results for radon ranged from non-detect to 296 pCi/L. SCWA falsely alleges there is no established state or federal MCL for radon – the second leading cause of lung cancer after smoking. If only Radon-220 is present and no other alpha emitters; the MCL is 15 pCi/L. Many violations of the EPA’s Radionuclides Rule include: No Radium 226 test results; No Beta/Photon test in mrem/yr.” [From Exhibit B-2]
• “Tables 1-7 From the SCWA’s 2012 Annual Water Quality Report @ www.scwa.com indicate the SCWA had: (a) 268 wells in the Upper Glacial Aquifer, (b) 333 wells in the Magothy Aquifer, (c) 3 wells in the Raritan Aquifer, (d) 3 wells in the Lloyd Aquifer (607 total) & virtually all private wells draw from the Glacial Aquifer. In 2011 they tested for radon, and gross alpha and beta particles at 87 locations. Test results for radon ranged from non-detect to 303 pCi/L. SCWA officials falsely allege there is no established Federal MCL for radon – the second leading cause of lung cancer after smoking. If only Radon-220 is present and no other alpha emitters; the MCL is 15 pCi/L. Many violations of the EPA’s Radionuclides Rule include: No Radium 226/228 test results; No Beta/Photon test in mrem/yr.” [From Exhibit B-3]
WHEREFORE, long-lived, radioactive sewage treatment plant discharge must not be diverted from the Peconic River to be recycled and re-pollute much of Suffolk County’s groundwater by the SCWA, Riverhead Water District, other public water companies, private well users, irrigation well users, etc., and, therefore DOE’s application must be rejected to protect men, women, children, farmers, tourists, the general public and yours truly.
Yours truly,
Dr. Carmine F. Vasile Ph.D. Electrophysics
Exhibit A-1
Exhibit A-2
Tables 1-6 from the SCWA’s 2003 Annual Water Quality Report @ http://gfxtechnology.com/WQR-03.pdf indicate the SCWA had: (a) 213 wells in the Upper Glacial Aquifer, (b) 309 wells in the Magothy Aquifer, (c) No wells in the Raritan Aquifer, (d) 4 wells in the Lloyd Aquifer (526 total). In 2003 they tested for unspecified Radon isotopes in and undisclosed number of locations. Test results in Tables 1-6 for unspecified Radon isotopes and Radium-226’s most deadly decay product, Lead-210, indicated huge radon concentrations between 209 & 549 pCi/L in Distribution Areas 1B, 5, 6, 8, 9, 10, 11, 12, 15, 18, 20, 23, 26, 30, 35 & CHWD. Lead-210 levels over 750 times its Beta/Photon MCL of 4 mrem/yr were found. The SCWA falsely claims there is no established federal MCL for Radon or Lead –210. In fact, if only Radon-220 and Lead-210 are present their respective MCL’s are 15 pCi/L & 4 mrem/yr. The tables below show depraved-indifferent violations of the EPA’s Radionuclides Rule include: No Radium-226/228 test results and No Beta/Photon test in mrem/yr for Lead-210 + Cesium-137.
(1) Distribution Areas 1B, 5 & 6: 329, 377 & 425 pCi/L of Radon; Gross Alpha Activity in 1B& 4
(2) Distribution Area 8, 9, 10, 11: 276, 299, 274 & 308 pCi/L of Radon; Gross Alpha Activity in only 8
(3) Distribution Areas 12, 15, 18, 20: 245, 549, 209 & 232 pCi/L of Radon; Gross Alpha Activity in only 18 & 20 with Cesium-137 & huge amounts of Lead-210 over 750 times the 4 mrem/yr MCL as calculated by the EPA’s Sum-of-the-Fractions method.
(4) Distribution Areas 23, 26, 30: 257, 307 & 289 pCi/L of Radon; NO Gross Alpha Activity
(5) Distribution Area 35: 265 pCi/L of Radon; Gross Alpha Activity in only 8
(6) Distribution Areas CHWD: 291 pCi/L of Radon; No Gross Alpha or Beta Activity
Exhibit B-1
Tables 1-6 From the SCWA’s 2011 Annual Water Quality Report @ www.scwa.com indicate the SCWA had: (a) 268 wells in the Upper Glacial Aquifer, (b) 329 wells in the Magothy Aquifer, (c) 3 wells in the Raritan Aquifer, (d) 3 wells in the Lloyd Aquifer (603 total). In 2010 they tested for radon 85 locations. Test results for radon ranged from non-detect to 296 pCi/L. SCWA falsely alleges there is no established state or federal MCL for radon – the second leading cause of lung cancer after smoking. If only Radon-220 is present and no other alpha emitters; the MCL is 15 pCi/L. Many violations of the EPA’s Radionuclides Rule include: No Radium 226 test results; No Beta/Photon test in mrem/yr.
(1) Distribution Areas 5 & 6: 254 & 201 pCi/L Radon, No Gross Alpha Activity
(2) Distribution Area 12: 296 pCi/L Radon, No Gross Alpha Activity
(3) Distribution Areas 18, 20: NO Radon, Gross Alpha Activity Detected
(4) Distribution Areas 23, 26, 30, 32, 34: NO Radon, No Gross Alpha Activity
(5) Distribution Areas 35, 39, 44, 53, 54: NO Radon
(6) Distribution Areas 55, RSWD, SBWD, EFWD: No Radon or Radon-220 from Ra-228, No Gross Alpha or Beta Activity
Exhibit B-2
Tables 1-7 From the SCWA’s 2012 Annual Water Quality Report @ www.scwa.com indicate the SCWA had: (a) 268 wells in the Upper Glacial Aquifer, (b) 333 wells in the Magothy Aquifer, (c) 3 wells in the Raritan Aquifer, (d) 3 wells in the Lloyd Aquifer (607 total) & virtually all private wells draw from the Glacial Aquifer. In 2011 they tested for radon, and gross alpha and beta particles at 87 locations. Test results for radon ranged from non-detect to 303 pCi/L. SCWA officials falsely allege there is no established Federal MCL for radon – the second leading cause of lung cancer after smoking. If only Radon-220 is present and no other alpha emitters; the MCL is 15 pCi/L. Many violations of the EPA’s Radionuclides Rule include: No Radium 226/228 test results; No Beta/Photon test in mrem/yr.
(1) Distribution Area 6: 234 pCi/L Radon, No Gross Alpha Activity
(2) Distribution Area 9: 303 pCi/L Radon, No Gross Alpha Activity
(3) Distribution Area 12: 233 pCi/L Radon, No Gross Alpha Activity
(4) Distribution Areas 18, 20, 21, 22: NO Radon, No Gross Alpha or Beta Activity
(5) Distribution Area 26: 256 pCi/L Radon, No Gross Alpha
(6) Distribution Areas 39, 44, 53, 54: NO Radon, No Gross Alpha or Beta Activity
(7) Distribution Areas 55, RSWD, SBWD, EFWD: No Radon, No Gross Alpha or Beta Activity
Exhibit B-3
Exhibit C
Radon Table A: Key Radon Parents & Progeny Covered by Safe Drinking Water Act Since 1976 222Rn Progeny U-238 Series
Half Life: 4.5 Billion Years [1] [2]
219Rn Progeny U-235 Series Half Life: 0.7 Billion Years [2]
220Rn Progeny Th-232 Series Half Life: 14 Billion Years [2]
222Rn belongs to the radium-226 and uranium-238 decay chain, and has a half-life of 3.8235 days. Its four first products (excluding marginal decay schemes) are very short-lived, meaning that the corresponding disintegrations are indicative of the initial radon distribution. Its decay goes through the following sequence:[25]
219Rn belongs to the radium-223 and uranium-235 decay chain, and has a half-life of 4 seconds. Its decay goes through the following sequence:
220Rn belongs to the radium-228/224 and thorium-232 decay chain, has a half-life of 56 seconds, and is the only radon isotope covered by the Gross Alpha MCL of 15 pCi/L. [3] Its decay goes through the following sequence:
222Rn, 3.8 days, alpha decaying to... 218Po, 3.10 minutes, alpha decaying to... 214Pb, 26.8 minutes, beta decaying to... 214Bi, 19.9 minutes, beta decaying to... 214Po, 0.1643 ms, alpha decaying to... 210Pb, which has a much longer half-life of 22.3 years, beta decaying to... 210Bi, 5.013 days, beta decaying to... 210Po, 138.376 days, alpha decaying to... 206Pb, stable.
Note: The following radionuclides in Table A have been regulated by the Radionuclides Rule of the SDWA since 1976: Ra-219, Ra-224, Ra-226, Rn-220 [not Rn-219/222], Bi-211, Bi-212, Bi-214, Po-210, Po-212, Po-214, Po-215, Po-216, Po-218, Th-232, U-235 & U-238. [3]
LI Wells & Landfills Contain Radon & Radioactive Fly Ash From Oil/Gas-Fired Power Plants & Incinerators That Burn Radioactive Waste From BNL & Hospitals
High concentrations of radon can be found in some spring waters and hot springs.[65] The towns of Boulder, Montana; Misasa; Bad Kreuznach, Germany; and the country of Japan have radium-rich springs that emit radon. To be classified as a radon mineral water, radon concentration must be above a minimum of 2 nCi/L (74 kBq/m3).[66] The activity of radon mineral water reaches 2,000 kBq/m3 in Merano and 4,000 kBq/m3 in Lurisia (Italy).[63] [1]
Radon is found in some petroleum. Because radon has a similar pressure and temperature curve to propane, and oil refineries separate petrochemicals based on their boiling points, the piping carrying freshly separated propane in oil refineries can become radioactive because of decaying radon and its products.[70] [1] [1]
Residues from the petroleum and natural gas industry often contain radium and its daughters. The sulfate scale from an oil well can be radium rich, while the water, oil, and gas from a well often contains radon. Radon decays to form solid radioisotopes that form coatings on the inside of pipework.[70] [1]
References [1] From: http://en.wikipedia.org/wiki/Radon#cite_note-autogenerated1-25 [2] “Natural Decay Series: Uranium, Radium, and Thorium” Argonne National Laboratory, EVS Human Health Fact Sheet, August 2005 @ http://www.gfxtechnology.com/ArgonneRadFacts.pdf [3] Attachment A: List of Man-made and Naturally-Occurring Radionuclides addressed by 15 pCi/L gross alpha particle activity MCL standard. [EPA CERCLA Directive no. 9283.1-14 “Use of Uranium Drinking Water Standards under 40 CFR 141” @ http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/9283_1_14.pdf]
Exhibit D-1
Exhibit D-2
Exhibit E-1
Exhibit E-2
Exhibit F-1
Exhibit F-2
Exhibit F-3
Exhibit F-4
Exhibit G-1
Exhibit G-2
UNITED STATeS ENVIRONMENTAL PROTeCTION AGENCYREGION 2
290 BROADWAYNEW YORK, NY 10007·18ll6 I thank you for your Interest In safe drinking water. Ifyou have further questions, please do not hesitate
to ca" me at (212) 637-3680, or Michael Lowv, of my staff, at (212) 637-3830.
SEP 30 ;mp
Carmine F. Vasile60 Herbert Circle
Patchogue, NY 11772
Dear Dr. Vasile:
This is in response to your Freedom of Information (FOI) Act Request AX·13·000-9030 received Al.lgust19, 2013, by United States Environmental Headquarters (EPA), regarding radiological drinking water
issues at Plum Island and the Suffolk County Water Authority's Lambert Ave well system, The FOIrequest was referred to the U.S. Environmental Protection Agency Region 2, as we have geographic
jurisdiction for the areas indicated In your request.
Regarding Plum Island, from the drinking water perspective, there Is one pUblic water supply serving theIDeation, (Plum Island Animal Disease lab) aFjd it is classified as a non-transient non-eommunity watersystem (NTNC). As per the Radionuclldes Rule, this system is not required to perform radiological
sampling, and therefore there would typically be no radiological results available. EPA Region 2 has
learned that even though Plum Island system is not reqUired 'to monitor for radlonuclldes, the SuffolkCounty Health Department has performed some sampling for all 14 wells for this system within the past5 years. In terms of radionuclides, sample results for gross alpha, beta and tritium are all Within the
applicable drinking water standards.
For the Lambert Avenue well field, Suffolk County has indicated that radiological sampling occurred In2008 with analytical results showing no detections for gross alpha and radium 22g. As per theRadlonuclides Rule, the next round of sampling is 2017. This Information also holds for the Lambert Avewell field located in Mastic, long Island.
For additional information, you may wish to contact the New York State Health Department, at the
following contact point:
Roger Sokol, Chief
Bureau of Public Water ,Supply ProtectionNew York State Department of Health.
Corning Tower
Empire Slate PlazaAlbany, NY 12237
518.402.7650
I"tame' Address (URl). ht1p:/_,ope.goyRaqlc::'-dlR.fCJOI8bt8 • Printed with VegetlbMi 011 SaMet Inks on Recwded P_per (Minimum SO% Poet:e:onsurner content)
~f/pAnitaM.Thomp~~Orinkil\ll Water Municipal Infrastructure Branch
cc: RogerSokof, NVSDOH
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 2
290 BROADWAYNEWYORK, NY 10007·1866
MAY 1 9 2011Dr. Carmine F. Vasile60 Herbert CirclePatchogue, NY 11772
Dear Dr. Vasile:
This letter is in response to your concerns regarding the Suffolk County WaterAuthority's compliance with the Radionuclides Rule and SCWA's practice ofblendingsource"water to achieve compliance with Maximum Contaminant Levels (MCLs) indrinking water.
As you know, New York State Department ofHealth (NYSDOH) administers the PUblicWater. Supply Supervision Program in the State ofNew York pursuant to Section 1413 ofthe Safe Drinking Water Act (SDWA). Like many other states, New York delegatesSOWA implementation to the local health units, in this case the Suffolk CountyDepartment ofHealth Services. In response to your concerns, EPA bas undertaken itsown investigation of the alleged violations by performing an extensive review ofthe datayou provided as well as an audit of SCWA compliance records.
Radionuclides in drinking water; specifically gross alpha, Radium-226/228, andbeta/photon emitters, have been federally regulated since 1976. Subsequent revisions tothese regulations were incorporated into the Radionuclides Rule, enacted on December 7,2000, the federal standard under which radionuclides are regulated to this day. Tosummarize, the Radionuclides Rule retained previous MCLs for Combined Radium226/228, gross alpha, and beta/photon emitters, and set an MCL of30 ugIL for uranium.It also established revised monitoring requirements for radionuclides in drinldng water,standardizing the monitoring framework in addition to requiring entry point to thedistribution system (EPTDS) monitoring.
Please be advised that the Radionuclides Rule applies to Community Water Systemsonly. Monitoring wells, such as the ones you reference at Brookhaven NationalLaboratory (BNL), are not subject to these federal requirements. Please note also that theRadionuclides Rule does not set specific MCLs for Strontium-89, Strontium-90 or Lead210 but rather an aggregate MCL for beta/photon emitters.
A search of the EPA's Safe Drinking Water Information System (SDWlS), which can beaccessed at htt,p://www.epa.gov/enviro/factslsdwisl, shows one Radionuclides Ruleviolation for SCWA. The violation report (attached) indicates that during the 2008calendar year, SCWA failed to take some of its required samples for Radiwn-228. As
" you can see, a Notice of Violation was issued to sewA on April 13, 2009 and therequired additional samples had been taken as ofJuly 5, 2010.
Internet Add (URL). ht1p:lIwww.epe.gov~bIe .Prlnt8d with V....... 0ll 1nIla on ItK)'CIed Paper(Mllllmum 10%P~_cocant)
Additionally, a hydrogeologic evaluation was conducted by CDM in 1998 to assess thevulnerability of SCWA wellfields to potential contamination originating from the BNLproperty. The groundwater flow model demonstrated that the Lambert Avenue wellfieldis the only SCWA wellfield that could potentially be affected by contaminants migratingfrom the BNL site. As a precautionary measure, SCWA maintains a network ofmonitoring wells at intermediary locations between the BNL site and SCWA wellfields.These monitoring wells are sampled quarterly and analyzed for a variety ofparameters,including radionuclides.
You also expressed concern regarding SCWA's practice ofblending water from differentsources to achieve MCL compliance. Under New York State Sanitary Code, Part 5, theblending ofa source that exceeds drinking water standards with another source ispennitted, subject to the operational and monitoring conditions outlined in EnvironmentalHealth Manual Item No. WSP 68 TR. EPA has reviewed the conditions ofNew YorkState's blending poticy, and is not aware ofany violation of its conditions on the part ofSCWA.
I thank you for your inquiry, and trust that the above addresses your concerns. Please beadvised that EPA, NYSDOH and SCDHS are committed to working together to ensurecompliance with the Safe Drinking Water Act and its implementing regulations.
Sincerely,
oughlas McKenna, ChiefWater Compliance Branch
Enclosure
cc: Walter Dawydiak, SCDHSRoger C. Sokol, NYSDOHAnna Stamm, NYSDOH
Dr. Carmen F. Vasile60 Herbert CirclePathogue, NY 117722
Dear Dr. Vasile:
This is in response to your November 16, 2011 letter to New York State Department ofHealth Commissioner Nirav Shah, M.D., M.P.H. regarding the blending of source water by theSuffolk County Water Authority (SCWA).
Your note, affixed to the letter, indicated that blending source water to achievecompliance with the Radionuclide Rule Maximum Contaminant Level (MCL) was an illegalpractice. Please be advised that both federal and NY State drinking water regulations do notprohibit the practice of source blending to achieve drinking water MeL compliance. In fact,guidance developed by EPA suggests that water systems first explore non-treatment options,such as blending, to achieve compliance with the Radionuclide Rule. This option can be a costeffective and environmentally sound alternative that provides public health protection.
More detailed information about options to address low level of radionuclides in waterother than treatment can be accessed at:http://cfpub.epa.gov/safewater/radionuclides/radionuclides.cfm?action=Rad Non Treatment
Thank you for your inquiry and your interest in the delivery of safe drinking water.
Sincerely,
Roger C. Sokol, Ph.D.DirectorBureau of Water Supply Protection
Dr. Cannine F. Vasile60 Herbert CirclePatchoque, New York 11772
Dear Dr. Vasile:
APR 2 J 2009bUREAU Uf ENViRONMENTAL
EXPOSURE INVESTIGATION
April 2, 2009
I am responding for Dr. Howard Frumkin, Director of the National Center for EnvironmentalHealth!Agency for Toxic Substance and Disease Registry (NCEH/ATSDR) regarding severalissues of concern to you..We have been in contact with our partners at the New York StateDepartment of Health (NYSDOH) and with the Suffolk County Department of Health Services(SCDHS) regarding the following issues disclissed in your correspondence to Dr. Frumkin, asfollows:
1) Blending of water from different sources when at least one of the sources hascontamination.
The national safe drinking water act authorizes the United States Environmental ProtectionAgency (EPA) to oversee the drinking water program. In many states, including New York, theUS Environmental Protection Agency (US EPA) has delegated primacy for implementation of theprograms to the state, and New York State uses the model ofdelegating implementation of theregulations to the County or other local health unit. Suffolk County New York has an activeDepartment of Health Services and as such has primary responsibility for enforcing drinking waterprograms in the county. The Suffolk County Water Authority (SCWA) is the water supplier in thepart of Suffolk County SUbject to this enquiry and is subject to oversight regulation by the SCDHSand, therefore, by the NYS DOH and US EPA.
Water suppliers use several approaches to provide water that meets the standards described inSubpart 5-1 of the State Sanitary Code under NYCRR Title 10. These approaches include usingthe highest quality of source water available, water treatment, and source blending. If a source iscontaminated, the supplier should explore whether new sources can be located at a reasonable cost.Use of a contaminated source should be kept to a minimum and treatment of the contaminatedwater is preferred over blending. Although blending may be allowed, the water supplier must beactively pursuing permanent corrective measures to provide unblended drinking water. If a watersupply source is considered vulnerable or is contaminated, monitoring requirements are increased.According to the NYSDOH, the water provided by the SCWA meets these requirements.
ZJ Exposure to I11gn KaalOloglcal LevelS reponeo In ~UllOIK ,--oumy "nuer 11.UIUoruy(sewA) Annual Water Quality Reports.
The Annual Water Quality report from Suffolk County Water authority incorrectly reportedfindings from a US EPA Method 200.8 analysis as being Strontium 89. The analysis is notspecific for Strontium 89, but is for total Strontium. In support of this is the fact that the grossbeta measurements did not show an increase as one would expect if the findings were indeedStrontium 89. The report oflead-21O at 1,240 pico Curies per Liter (pCi/L) is also very suspect.The result reported is 1,240 plus or minus 1,120 pCi/L. The standard deviation with thismeasurement is huge and we believe reflective that there is a measurement problem, not acontamination problem. Finally, there is the reporting of329 pCilL ofradon in a sample. TheSCDHS, as documented in a report they produced with the NYSDOH in 1988, identified theaverage level of radon as 340 pCiIL. Moreover, the levels found in SCWA water are consistentwith natural background levels in other parts of the country. Although radon at 329 pCi/L is notconsidered a high value from a national background perspective, there currently is no Federal orNew York State Maximum Contaminant Level (MCL) for radon in drinking water forcomparison. The big issue with radon in drinking water is the possibility of volatilization of radonand resulting indoor air contamination. Ifpersons are concerned, we recommend that they havetheir indoor air tested; this has become a common test and routine during home transactions inNew York State.
We understand from the SCDHS that the SCWA periodically samples certain public water supplywells, at least annually, for various radiological analytes, including the wells that serve your areafor the isotopes ofconcern to YQU. We further understand that none ofthe recent results haveshown any radiological contaminants above state and federal standards or guidelines. We willcontinue to work with the NYSDOH and the SCDHS to monitor future results.
3) Alleged Illegal Dumping of Radioactive Waste at Long Island Landfills.
As you know, ATSDR, and our partners at the NYSDOH, do not have jurisdiction on these typesof investigations. We understand from our partners at the NYSDOH, that the New York StateDepartment ofConservation (NYS DEC), who does have jurisdiction, is evaluating the allegationsof illegal disposal ofradiological materials. We will monitor the progress of this evaluation and ifinformation becomes available that will assist us in reevaluating the exposures at sites or releaseswhere ATSDR has conducted public health assessment activities, then we will reevaluate ourhealth determinations.
Other issues ofconcern to you related to the Brookhaven Landfill (i.e., private well contaminationand exposures at the Hamlet Organic Farm) are being processed by my office as a formal petitionand you should expect to receive a letter from me within the next several weeks with our decision.
If you have any questions, please contact Dr. Gregory Ulirsch, ATSDR, at (770) 488-3731.
Sincerely,
n~('~1;;;)William tibulas Jr., Ph.D.CAPT, US Public Health ServicesDirectorDivision of Health Assessment and Consultation,
4This list includes only those radionuclides with half lives exceeding 4 days.
- 8 -
Attachment A: List of Man-made and Naturally-Occurring Radionuclides addressedby 15 pCi/L gross alpha particle activity MCL standard4
Proof of Fraud: The Table & Footnote 4 below are from EPA CERCLA Directive no. 9283.1-14, with notes showing obvious fraud. For example, of the 55 gross alpha particle emitters listed, many have lives much less than 4 days; contrary to Footnote 4 & despite many complaints to correct this to Stewart Walker, the subject matter specialist for this (703-603-8748). Walker and his superiors have allowed corrupt water companies to fraudulently subtract all alpha emitters and falsify compliance with the Radionuclides Rule of 1976 and its 2000 Amendment, which allow deductions limited to alpha emissions from Uranium & Radon, notwithstanding Radon-220 is listed below and NYS 1990 Radon report defines Radon as Radon-222; ignoring its other 38 isotopes.
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Bi-214: 20 min Po-210: 140 days Po-212: 310 ns Po-214: 160 us Po-215: 1.8 ms Po-216: 0.15 sec Po-218: 3.1 min
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Half Lives of Only Radon Progeny Bi-210: 5 days Bi-211: 2.1 min Bi-212: 61 min
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NOTICE of FRAUD The additions to the above Table contradict the following section inserted from Page 3 below because water companies are subtracting all gross alpha particle activity from the gross alpha test results; including radium 226, uranium & radon. See many examples in my Petition for a Radon Health Assessment @ www.gfxtechnology.com/PBHA.pdf. RADIONUCLIDE MCLs: “On July 9, 1976, EPA promulgated 40 CFR Part 141 Drinking Water Regulations:Radionuclides (1976 MCL rule). This 1976 MCL rule included the following MCLs: 5 pCi/L for radium-226 and radium-228 combined; 15 pCi/L for gross alpha particle activity (including radium 226, but excluding uranium and radon); and a concentration that produces a dose equivalent of 4 mrem/yr or less to the total body or any internal organ for the sum of the doses from man-made beta particles and photon emitters. A list of radionuclides that are addressed by the gross alpha MCL are provided in Attachment A to today's memorandum. Also, provided in Attachment B to today's memorandum is a list of radionuclide concentrations calculated using the 4 mrem/yr beta particles and photon emitters MCL standard. On December 7, 2000, EPA amended 40 CFR Part 141 (65 FR 76708, December 7, 2000) National Primary Drinking Water Regulations; Radionuclides (2000 MCL rule). This 2000 MCL rule established requirements for uranium, and retained the existing requirements for combined radium-226 and radium-228, gross alpha particle radioactivity, and beta particle and photon radioactivity. The 2000 MCL rule did include MCLGs of zero for the last four contaminants (see 40 CFR § 141.55). The 2000 MCL rule established an MCL for uranium of 30 micrograms per liter (μg/L)”.[Quoted from pg. 3]
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Half Lives of: Ra-219: 4 sec Ra-223: 11 days Ra-224: 3.7 days Ra-226: 1600 yr Rn-220: 56 sec Missing Rn-219: 4 sec Rn-220: 3.8 days
Unregulated Lung-CancerThreats From Radon-219/220/222 [1] [2] [3] Radon (Rn) & [Radium Parents] From Natural
Decay Series of Uranium-238/235 & Thorium-232
Half Life Specific Activity Curie/gram
Isotope Mass @ Proposed EPA MCL
of 300 pCi/L-water for Radon Gas
Picograms (pg)
Corresponding Volume of Shower
Water To Reach Radon Action Level of 4 pCi/L-air (Liters)
Parents & Daughters Radioactivity MCL Mass MCL Ra-226 1,600 yr 1.0
(Alpha/Beta/Gamma) 5 pg minus Ra-228
Concentration N/A N/A
Ra-228 5.8 yr 280 (Beta) 5 minus Ra-226 “ “ Ra-224 3.7 days 0.158 Million
(Alpha/Beta/Gamma) N/A “ “
Ra-223 11 days 53 Thousand N/A “ “ Lead-210 [From Rn-222] 22 yr 77 0.0156 @ 4 mrem has highest cancer risk of all Radon daughters Lead-206 [From Pb-210] Infinite Not Radioactive 15 E+6
[1] Only Radon-220 is regulated by 15 pCi/L Alpha MCL, according to: “Use of Uranium Drinking Water Standards under 40 CFR 141 and 40 CFR 192 as Remediation Goals for Groundwater at CERCLA sites” EPA CERCLA Directive no. 9283.1-14, Attachment A: List of Man-made and Naturally-Occurring Radionuclides addressed by 15 pCi/L gross alpha particle activity MCL standard @
http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/9283_1_14.pdf [2] Vermont's Radon Guidelines -- If alpha radiation is detected at or above 5 pCi/L in your home well, additional testing is
needed to pinpoint the source. The U.S. Environmental Protection Agency has set 15 pCi/L as the maximum contaminant level for public drinking water supplies. This level is calculated as the total alpha radiation minus uranium and radon. If radon is present in your drinking water, test the air in your home as well. Consider treatment for your well water if the radon from the water is causing the level of radon in the air in your home to rise above the recommended indoor air action level of 4 pCi/L. It generally takes 10,000 pCi/L in water to increase the radon level in air by 1.0 pCi/L. Aeration removes radon from water. In this treatment method, large volumes of air are blown through the water or the water is sprayed so that it is exposed to the air. In this way, the radon gas leaves the water and enters the air. The air is vented outside, and the treated water is repressurized and piped to faucets…What is Vermont’s drinking water standard? Alpha radiation is measured in picocuries per liter (pCi/L). If alpha radiation is detected at or above 5 pCi/L in your home well, additional testing is needed to pinpoint the source. The U.S. Environmental Protection Agency has set 15 pCi/L as the maximum contaminant level for public drinking water supplies. This level is calculated as the total alpha radiation minus uranium and radon. [http://healthvermont.gov/enviro/rad/Radon.aspx]
[3] California’s Health Code exceeds New York & EPA standards by including Maximum Contaminant Levels (MCLs) for natural and man-made radioactivity including the most carcinogenic radionuclides: --- including Lead-210 & Radon.. (According to a September 13, 2013 letter from an EPA Chief Anita M. Tompkins, and other documents, the Suiffolk County Health Department tests private & irrigation wells and wells used in Community & NTNC water systems for only Alpha, Beta & Tritium. CURRENT CALIFORNIA REGULATIONS AND GUIDANCE: The primary drinking water standards for the State of California include Maximum Contaminant Levels (MCLs) for natural and man-made radioactivity (California Code of Regulations Title 22, Division 4, Chapter 15, Article 5). Section 64441 of the California code addresses Natural Radioactivity and states the following: a) All community water systems shall monitor their water supplies for radium-226, radium-228 and uranium at least once every four years. Compliance with maximum radioactivity levels shall be based on the average of the analysis of four consecutive quarterly samples. b) Gross alpha particle measurement may be substituted for measurement of radium-226 and radium-228. (1)The supply is considered to be in compliance with maximum radioactivity levels if the gross alpha particle activity does not exceed 5 picocuries per liter (pCi/L). (2) If gross alpha activity exceeds 5 pCi/L, measurement of radium-226 shall be made. (3) If radium-226 exceeds 3 pCi/L, measurement of radium-228 shall be made. (4) The sum of the radium-226 and radium-228 shall not exceed 5 pCi/L. c) If the average maximum contaminant level for gross alpha particle activity, total radium or uranium exceeds the levels shown on Table 4, the water supplier shall report this information to the Department within 48 hours.
In Table 4 of section 64441, the MCLs for naturally occurring radioactivity are listed, including uranium, radium-226 and -228, and gross alpha particle radioactivity. This table is reproduced below as Table 1… USE OF THE GROSS ALPHA PARTICLE MEASUREMENT SCHEME FOR SCREENING: Another consideration could be to include more natural beta emitters to be assessed under the gross alpha particle measurement scheme. Perhaps it would be reasonable to abandon the “gross alpha particle” title and simply address the whole category as “natural radionuclides,” as is done in the California regulations (Title 22, Division 4, Chapter 15, Article 5). For example, radon-222 is a gas that is included in the gross alpha measurement scheme. Its daughter product, lead-210, could be measured as a beta particle emitter under the gross beta particle measurement or under the gross alpha scheme. The gross beta particle/photon measurement is required to be assessed only for certain communities that utilize surface water supplies. Supplies that include groundwater, a major source of natural radioactivity, are not necessarily screened for the natural beta emitters like lead-210. Therefore, natural beta emitters would be more appropriately measured under the conditions specified for the gross alpha particle screening scheme. {Excerpts from “Health-Protective Considerations Regarding Measurement of Gross Alpha Particle Activity in Drinking Water”, Office of Environmental Health Hazard Assessment Sacramento and Oakland, California Gross Alpha in Drinking Water, December 2003 @ http://oehha.ca.gov/water/reports/grossbetahealth.pdf)
1.1. Lead-210 is not regulated by the National Interim Primary Drinking
Water Regulations (NIPDWR). However, based upon its maximum
permissible concentration (MPC) published in NBS Handbook 69, the
maximum concentration level (MCL) calculated by applying the
formula in the NIPDWR would be 1 pCi/L or less, depending, upon the
choice of critical organ.
1.2 The sensitivity of the method as defined in the NIPDWR is
'approximately 0.7 pCi/L for a one liter sample size using liquid
scintillation counting and 0.2 pCi/L using a low background beta
counter.
2. Summary of Method
2. 1 Lead carrier is added and concentrated by precipitation as the
chromate. It is further purified from its bismuth-210 daughter by
selected dissolution of lead sulfide from a 1.S! hydrochloric acid
solution. Lead is finally converted to the carbonate and the
lead-210 concentration calculated by either counting the lead-210
beta emission ~y liquid scintillation technique or counting the
ingrown bismuth-2l0 daughter activity by low background end window
counting.
3. Sample Handling and Preservation
3. 1 If the sample cannot be analyzed within 24 hours, it is recommended
ENVIRONMENTAL HEALTH MANUAL
NEW YORK STATE DEPARTMENT OF HEALTH ITEM NO: WSP 68 TR DATE: 08/06/07
OFFiCE OF PUBLIC HEALTHCENTER FOR ENVIRONMENTAL HEALTH SUBJECT: Blending Policy for Use
Sources of Drinking WaterTECHNICAL REFERENCE
Page 1 of 2
POLICY
Public water supply systems must use the highest quality water available for drinking waterpurposes. Blending of a source of drinking water, which exceeds established drinking waterstandards or chemical guidelines, with an acc.eptable source may be allowed provided theconditions outlined in this Technical Reference are met. A source of drinking water shall beconsidered contaminated when a follow-up sample verifies the initial sample result, which showedthat the source had failed to meet New York State Sanitary Code maximum contaminant level(MCL) requirements for drinking water and/or New York State Department of Health establishedchemical guidelines. For the purpose of this Technical Reference, a source of drinking water willbe considered no longer contaminated when two consecutive samples, taken at least 24 hoursapart, meet the established MCL and/or chemical guidelines.
GENERAL CONDITIONS
I. The blending policy shall apply to all inorganic and organic chemicals for which MCL orchemical guidelines are established.
2. Bacteriological problems must be corrected at the source via appropriate disinfectiontreatment. Blending shall not be used to correct bacteriological problems.
3. If an acceptable source of drinking water is not available for use, treatment is the preferredoption over blending. Blending shall not be allowed if a generally acceptable and availabletreatment technology or new source exists at a reasonable or lesser cost.
4. Local public health agencies may adopt more stringent requirements for blending sources ofdrinking water, based on local conditions and/or site specific issues.
5. If the contamination is the result of organic chemicals, the public water supply system must beactively pursuing permanent corrective measures to provide an unblended drinking waterwhich meets the MCLs and/or chemical guidelines.
ENVIRONMENTAL HEALTH MANUAL
NEW YORK STATE DEPARTMENT OF HEALTH ITEM NO: WSP 68 TR DATE: 08/06/07
OFFICE OF PUBLIC HEALTHCENTER FOR ENVIRONMENTAL HEALTH SUBJECT: Blending Policy for Use
Sources of Drinking WaterTECHNICAL REFERENCE
Page 2 of 2
OPERATIONAL CONDITIONS
I. Blending must be accomplished at a point prior to any consumptive use.2. The drinking water shall be blended in such a manner that all consumers receive drinking water
which does not exceed established MCLs and/or chemical guidelines.
3. A water conservation program, acceptable to the local public health agency, must be in effectso that use of the contaminated source of drinking water is kept to a minimum.
MONITORING CONDITIONS
I. Sufficient samples must be collected, by the supplier of water or his designatedrepresentative, and analyzed by an approved laboratory to determine the variation incontaminant levels and to verifY that blending is feasible and effective.
2. The local public health agency shall establish the monitoring locations and the frequency ofsampling necessary to ensure that consumers receive drinking water which does not exceedthe MCLs and/or chemical guidelines.
3. The public water supply purveyor shall ensure that samples are collected and analyzed at thefrequency established by the local public health agency. A report of the results of blendingshall be submitted as required by the local public health agency.
4. The New York State Department of Health may require additional monitoring of the publicwater supply system to the extent deemed necessary so as to provide additional data fordecision-making purposes.
REFERENCES
A. New York State Sanitary Code, Part 5, Drinking Water Supplies
B. Environmental Health Manual Item PWS 152, Procedure for Handling Community Watersystem Emergencies.
