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What's been said...

about radiation at the Uniontown Industrial Excess landfill (IEL)

May 21, 1997 letter to Greg Coleridge, Director of American Friends Service Committee (AFSC), Akron, Ohio from David Ullrich, Deputy Regional Administrator USEPA:

"The US Environmental Protection Agency (USEPA) has gone to great lengths to determine whether radiological contamination is present at the IEL site. The work performed to address that issue over the past several years has undergone extensive public scrutiny, with intense regulatory oversight. A variety of entities including the Ohio EPA, the Ohio Department of Health, the Nuclear Regulatory Commission (NRC), the Agency for Toxic Substances and Disease Registry (ATSDR), and the Science Advisory Board (SAB) have participated in a thorough review of all issues raised and the substantial volume of data collected to date. Based upon the comprehensive sampling, analyses, and reviews conducted by leading radiological experts, USEPA has concluded that the levels of radioactivity detected at the IEL site are indicative of naturally occurring radiation, are not a public health concern, and that no additional sampling is warranted. This conclusion has been supported by the Ohio EPA, the Ohio Department of Health, and ATSDR."

September 28, 2001 Memo from John Griggs, Chief Monitoring and Analytical Services Branch, National Air and Radiation Environmental Laboratories (NAREL):

"The results strongly indicate that Pu-238 and Pu-239/240 are not present in the samples. This is further supported by the fact that the results for Pu-238 and Pu-239/240 for a quality control blank sample, which was prepared at NAREL using laboratory ionized water and the chemicals used in the analysis procedure, were equal to or greater than the results for Pu-238 and Pu-239/240 in the two samples. In other words, the plutonium analysis of the two IEL samples generated measured results which are typical of material prepared to be free of plutonium as part of a quality control process, i.e., laboratory blanks."

October 9, 2001 Memo to Sue Ruley from Ross del Rosario, Region V, USEPA:

"Here's NAREL's explanation: Essentially, the response (levels) we got from the samples analyzed (MWell 01-D and MW-01-I) were the same in the situation where the instrument was reading a response without a sample placed on it. In other words, we found no evidence that Plutonium was present in the samples:

July 6, 1993 Memo to Louise Fabinski, USEPA Region V representative to the Agency for Toxic Substances and Disease Registry (ATSDR) from Laura Barr, Environmental Health Scientist, DHAC, (ATSDR):

POSITION: "ATSDR does not support further testing of soil core samples for radiation or inorganic and organic contaminants in the northwest corner of the landfill. Groundwater and air are the more appropriate media for characterization of contaminants that could migrate off site and lead to human exposure."

April 23, 1997 letter to Congressman Tom Sawyer from Timothy Fields, Jr., Acting Assistant Administrator, Washington office USEPA:

"The USEPA has made extensive efforts to determine whether radiological contamination is present at the IEL site. The work performed over the past several years to address this issue has undergone intense scientific review and public scrutiny. The Ohio EPA, the Ohio Department of Health, the Nuclear Regulatory Commission, the Agency for Toxic Substances and Disease Registry (ATSDR), and the EPA's Science Advisory Board (SAB) have participated in a thorough and public review of the data. Based on these reviews, EPA has concluded that the levels of radioactivity detected at the IEL site are naturally occurring, are not a public health concern, and that additional sampling is not scientifically warranted. Ohio EPA, the Ohio Department of Health, and ATSDR support this conclusion.

Sun Journal Article 1997 letter to editor from Donald Schregardus, Director, Ohio EPA Columbus office:

"In response to concerns expressed by the Concerned Citizens of Lake Township, U.S. EPA and Ohio EPA, along with other state and federal agencies, have also performed extensive investigations and sampling aimed at determining whether radiological contamination was present at IEL. The agencies agreed that sufficient data had been generated during the investigation phase of the project to move toward implementation of a protective and cost effective remedy at the site."

"These efforts took place several years ago under extensive public scrutiny, accompanied by intense regulatory and legislative oversight. Because of allegations that radiological data had been improperly evaluated, U.S. EPA's activities related to radiological data collection, analysis and interpretation were examined by an ad hoc committee of the science Advisory Board (SAB). The State and federal agencies involved in this investigation, which included the Agency for Toxic Substances and Disease Registry (ATSDR), The Ohio Department of Health (ODH), the Nuclear Regulatory Commission ( NRC) and USEPA's National Air and Radiological Environmental Laboratory (NAREL), unanimously agreed with the conclusions of the SAB report."

October 27 1995 letter to Chris Borello, President of CCLT, from Ohio Attorney General Betty Montgomery: Signed by Christopher Jones, Chief, Environmental Enforcement Section

"I have reviewed information provided by Agency for Toxic Substances and Disease Registry (ATSDR) USEPA, Ohio EPA, and the Ohio Department of Health regarding this issue [radioactivity]. My review of this information indicates that all of these parties have agreed with the Science Advisory Board (SAB) report issued in the fall of 1994. This report, and these agencies, have concluded that radioactive contamination is not present at the IEL site and that no radiation health risks are posed at the site."

Based upon a draft Nuclear Regulatory Commission (NRC) letter dated August 16, 1994, obtained from OEPA records:

"This is in response to your letter received April 12, 1994, and your letter dated July 20, 1994, in which you indicated that radioactive material may have been disposed at the Uniontown Landfill."

"On August 4 and 12, NRC staff evaluated radioanalytical reports from sampling done by the USEPA. This sampling period (quarterly samples collected) was from May 1992 to March 1993. Our review of the EPA data revealed only the presence of naturally occurring radionuclides at environmental levels and did not reveal any man-made radionuclides."

Memo to Ross del Rosario from Scott Telofski, PE, NAREL, Environmental Studies Branch, dated October 3, 2001:

"I've completed a review of the 2000-2001 sampling results in comparison to the 1992-1993 results from NAREL. The attachment has the report of my findings". "The assessment of plutonium at IEL must be considered inconclusive, but it seems unlikely that plutonium is present, or if it is, it is at very low levels that are essentially indistinguishable from background".

Undated U.S. EPA Office of Inspector General, Report in Response to Congressman Sawyer's letters of November 6, 1997 and December 22, 1997:

"We reviewed five ATSDR Health Consultations Addressing IEL: [May 15, 1992; April 5, 1994; December 13, 1994; August 21, 1995 and July 25, 1996] ATSDR did not identify radioactive contamination at IEL as a health threat in any of these five reviews. We also reviewed a July 10, 1996 letter to CCLT in which ATSDR responds to CCLT's comments on its April 1994 radiation consultation. This letter includes the summary statement: "We have not received any data or information that ATSDR believes would warrant changing our conclusion of no public health threat." The letter also encloses detailed ATSDR responses to sample acquisitions, analyses and data interpretation issues raised by CCLT, some of which are listed in Congressman Sawyer's letters. (e.g. sample filtration and core sampling)…NRC (Nuclear Regulatory Commission) states: "we are aware of EPA analysis of previously collected samples, which they concluded did not show evidence of radiological contamination. We agree with that conclusion. Consequently, our agency will not conduct the sampling as requested in your letter."

Letter to Christine Borello (CCLT) from Timothy J. Kern, Assistant Attorney General Ohio Environmental Enforcement Section dated February 5, 1999:

"Upon review of the gross alpha and gross beta radiation it was decided that additional evaluation was not needed. The levels of radioactivity at the IEL are within background levels for Ohio and other areas in the United States, and that these levels are not a public health concern."

Letter dated December 11, 2000 to Lawrence Antonelli, Department of Emergency & Remedial Response Ohio EPA, from J. Eric Denison, Health Physicist Ohio Department of Health:

"Ohio Department of Health Bureau of Radiation Protection (ODH/BRP) staff have reviewed the results of radiological testing on ground water samples collected from the above site in August, 2000. We have also reviewed correspondence and results of several sampling campaigns dating from 1988 to the present."

"It is our considered opinion that the evaluation provided by Auxier & Associates in the Sharp & Associates project report is correct, and that radionuclides found in the ground water samples are consistent in identity and concentration with naturally-occurring materials found in this region of the state."

February 9, 1995 letter to Sue Ruley, Lake Township Trustee, from Eliott P. Laws, Assistant Administrator and counter-signed by Valdas V. Adamkus Regional Administrator U.S. EPA Region V:

"U.S. EPA is confident in the sampling that has been conducted at the IEL site. The radiological issues have received substantial attention within this Agency, as well as by a variety of independent parties including the Ohio Environmental Protection Agency, the Agency for Toxic Substances and Disease Registry (ATSDR), and the Nuclear Regulatory Commission (NRC). In addition, former Administrator William Reilly empanelled a special committee of the Science Advisory Board (SAB) to review the radiological issues at the IEL site. The SAB is an independent group of qualified scientists from academia, research institutions, and industry who act as consultants to the Administrator."

"In closing, I would like to acknowledge that the SAB concluded that "…the tests performed were appropriate and adequate to detect the occurrence of radionuclides that might be expected based on experience at sites that are contaminated with the most common radionuclides. Thus, the current weight of evidence argues that the issue of radioactive contamination should not be pursued further and the confirmed issue of chemical hazards and remediation thereof should proceed expeditiously".

January 29, 1999 letter to Ohio Senator Scott Oelslager from Jennifer Tiell, Interim Director Ohio EPA:

"At the request of the CCLT during the radiological sampling, special attention was given to the potential presence of plutonium within the landfill. Radionuclides of plutonium do not occur naturally; however, low levels of plutonium are dispersed over the surface of the earth from upper atmospheric disintegration and past atmospheric weapons testing programs. When analyzing samples for plutonium, the USEPA-NAREL methods require a preliminary round of sampling which determines whether plutonium may be present. There must be a minimum amount to statistically verify its presence. The sample results taken from ground water at IEL were reported by the NAREL to be too low in activity to confirm with precision the quantities present. Regardless of the levels detected during preliminary analysis, each sample was re-analyzed to confirm any initial detection. All samples that measured detection on the first test showed no detectable levels when tested again."

"In summary, the few samples that detected plutonium at trace levels were subjected to additional confirmatory testing which showed no measured plutonium activity. One of the samples which showed a detection of plutonium was a field blank which is distilled water not collected from the site and theoretically "clean" and free from contamination. Field blanks are used to monitor quality control processes during sampling activities. The multiple testing procedure is always performed due to the inherent statistical uncertainty in the process when dealing with low levels of a parameter such as plutonium."

February 14, 2001 letter to William J. Franks, Commissioner, Stark County Health Department, from Ross del Rosario, Remedial Project Manager, Region V, U.S. EPA:

"I am enclosing information concerning the August 2000 groundwater sampling event at the Industrial Excess Landfill (IEL) Superfund Site in Uniontown, Ohio. In summary, U.S. EPA conducted a review of the data generated by the IEL responsible parties and have determined it to be usable. Although U.S. EPA, OEPA, and Lake Township have commented on the contents of the attached summary report, it does not appear that contaminants connected with the landfill pose any danger to the surrounding community. The analytical data shows most of the contaminants to be below method detection limits. This is also true with the radiation data collected during this survey."

January 22, 2001 letter to Richard Laubaucher, Environmental Engineering, Goodyear Tire & Rubber Company from John R. Frazier, PhD, CHP, President, Auxier & Associates, Inc., Radiological Health, Safety and Environmental Consulting:

"The analytical results for August 2000 groundwater sampling have been reviewed by the Ohio Department of Health with their conclusion that the identities and concentrations of all radionuclides are consistent with natural background levels. The U.S. EPA radioanalytical laboratory, NAREL, also reviewed the August 2000 data and reported the results of their review in a letter dated January 11, 2001. The NAREL review "found the data packages to be well organized as well as informative in terms of the amount and type material and documentation provided. The results of the NAREL review support the conclusions of the Ohio Department of Health and my own findings, namely, radionuclides in IEL samples are no different from background levels found in any other Northeast Ohio water/soil."

March 21, 1997 letter to Greg Coleridge, Director, Economic Justice Program, American Friends Service Committee from David Ullrich, Deputy Regional Administrator U.S. EPA:

"U.S. EPA believes that it has made a sincere effort to engage CCLT in technical discussions in an attempt to resolve CCLT's outstanding issues concerning radiation at this site [IEL]. U.S. EPA has expended resources to facilitate these discussions on numerous occasions and for whatever reasons CCLT has chosen not to participate. The Agency believes it has performed to the best of its ability with respect to addressing the radiological issues at the site."

What's been said...

about the water flow direction at the Industrial Excess Landfill:

June 30, 2001 Beacon Journal Article:

"Some scientists familiar with both sites have also ruled out the hypothesis that PCE and TCE could have traveled roughly seven miles from the closed Industrial Excess Landfill in Uniontown to East Maple [City of North Canton] three connecting aquifers. Maps do not show a connection, they say "IEL is a separator watershed," said Scott Bair, a professor of geology at Ohio State University and former US Geological Survey scientist. "Metzger's ditch and the water bodies near IEL flow to the north and west. The (East Maple) (North Canton) well field kind of straddles the West Branch of Nimishillen Creek, which flows south. So there is a surface water divide between. What that means is water doesn't flow uphill."

September 22, 2000 Letter to Sue Ruley, from Ross del Rosario, U.S. EPA:

"Regional groundwater flow is east to west around the landfill. The proposed housing developments (on Mogadore Rd.) are located about a quarter or half mile east of the landfill. Consequently, the location of the landfill makes it an improbable source of contaminants that may be found in the groundwater underneath the developments. Also, there hasn't been any history of elevated radiation readings of residential wells tested in the area."

May 2001 Sampling Event at IEL prepared by Sharp and Associates, Inc., Environmental Engineers & Scientists:

"Groundwater flow patterns in the uppermost continuous groundwater unit are similar to those from the previous three quarters: there is no groundwater mound on-site. The regional east-to-west groundwater gradient flattens beneath the site but maintains its east to west pattern."

July 27, 2001 Letter to Sue Ruley from Ohio EPA Larry Antonelli:

"In summary, a review of the top of bedrock maps indicate there is no known buried valley aquifer between North Canton and Greentown, and the bedrock contour map by Vorbau (1996) suggests the bedrock valley system associated with Industrial Excess Landfill (IEL) in Uniontown slopes to the west and northwest. There is no apparent bedrock valley connection between IEL and Greentown."

May 23, 2001 letter to David Herbert, Lake Township Additional Legal Counsel, from Jim Bauder, Bauder Certified Earth Sciences, Inc., North Canton, Ohio:

"It has never been my opinion that it is possible for underground water to travel from the immediate site of the Uniontown Industrial Excess Landfill located in Uniontown, Ohio to the North Canton municipal water well fields located along Freedom Avenue NW and Dressler Avenue NW."


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