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.

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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.

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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:

1. 222Rn, 3.8 days, alpha decaying to... 2. 218Po, 3.10 minutes, alpha decaying to... 3. 214Pb, 26.8 minutes, beta decaying to... 4. 214Bi, 19.9 minutes, beta decaying to... 5. 214Po, 0.1643 ms, alpha decaying to...

6. 210Pb, which has a much longer half-life of 22.3 years, beta decaying to...

7. 210Bi, 5.013 days, beta decaying to... 8. 210Po, 138.376 days, alpha decaying to... 9. 206Pb, stable.

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

complained to Congressman Bishop @ http://www.bnl.gov/ewms/ser/default.asp because the DOE FOIA Officer Miriam Bartos demanded about $12,000 for documents obtained free from the BNL Library. 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

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) @

http://www.bnl.gov/ewms/ser/PDF/OldSERs/SER_1964.pdf (pg. 28) Yours truly,

Dr. Carmine F. Vasile Ph.D. Electrophysics

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.

219Rn, 4.0 seconds, alpha decaying to... 215Po, 1.8 milliseconds, alpha decaying to... 211Pb, 36 minutes, beta decaying to... 211Bi, 2.1 minutes, alpha decaying to... 207Tl, 4.8 minutes, beta decaying to... 207Pb, stable.

220Rn, 56 seconds, alpha decaying to... 216Po, 0.150 iseconds, alpha decaying to... 212Pb, 11 hours, beta decaying to... 212Bi, 61 minutes, (64%) beta & (36%) alpha decaying to... 212Po & 208Tl, 310 nanoseconds & 3.1 minutes, alpha & beta decaying to... 208Pb, 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