As it turned out, however, the Federal Government wanted to review CERCLA1 during 1987/1988 and prepare site inspections. Another document was quickly prepared, which we now refer to as CERCLA II, which falsifies the real record and shows virtually no contamination in the KAPL landfills. This second document, dated 15 April 1988 (RHEP-90-194), states that: " As a result of the Preliminary Assessments, KAPL concludes that none of the three sites are appropriate candidates for further action under CERCLA and that site Inspections (SIs) need not be prepared." This second document was also signed by J.A. McHugh.
It would appear that KAPL management was and is prepared to lie about any subject, no matter the consequences.
January 13, 1986 RHEP-55R-1030
The Manager
Schenectady Naval Reactors Office
U. S. Department of Energy
Schenectady, New York
Subject: STATUS OF CERCLA REVIEW AT KAPL SITES
References: (a) DOE Order 5480.14, dated April 26, 1985
(b) DOE Order 5820.2, dated February 6, 1984
Enclosure: Status of the KAPL Phase I Review of Disposal Practices for DOE
Order 5480.14, dated January 13, 1986
Dear Sir:
Reference (a) implements the DOE Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) program to identify and evaluate inactive hazardous waste disposal sites o DOE installations. This letter submits, for SNR information, KAPL's progress to date and plan of action to complete the Phase I installation assessment required by Reference (a).
The purpose of Phase I is to identify and assess sites potentially contaminated with hazardous substances. This includes past landfills and burial sites, as well as sites possibly contaminated from spills and releases of hazardous substances. As a minimum, Phase I involves the review of records, interviews of personnel knowledgeable of current and past waste management practices, inspection of suspect areas, and the rating of sites where contamination from hazardous substances including radioactivity, possibly exists. The rating indicates the relative potential for environmental impact at each site. Sites showing an insignificant potential require no further action under the remaining phases (Phases II through V) of the DOE program.
The information obtained by KAPL through a combination of record reviews, interviews, inspections and monitoring is presented in the Enclosure. Several areas are identified at the Knolls and Kesselring Sites where hazardous substances may have been disposed. In general, available records are insufficient to identify the specific substances and quantities involved or to accurately define the boundaries of disposal areas. With respect to chemicals, water monitoring in the vicinity of the current landfills at the Knolls and Kesselring Sites has in isolated instances indicated the possible presence of low levels of hazardous substances: Cyanide, propanoic acid, butanoic acid, tetrahydrofuran, and chromium at the Knolls Site and trichloroethylene, dichloroethylene and chlorcyclonexane at the Kesselring Site. However, there are accounts that suggest unknown quantities and types of radioactive materials may be deeply buried in the present landfill, the abandoned landfill, and/or the wooded area described above. Thus, the results of the 1985 surveys in these areas should only be considered to be radiologically characteristic of the uppermost 2 meters of areas of fill material that potentially extends to depths of 15 meters or more. Descriptions of chemical disposal in the landfill area have included accounts of disposed glass containers and steel drums affixed with radioactive labels.
Very truly yours,
J. A. McHugh, Manager
RADIATION, HEALTH AND ENVIRONMENTAL PROTECTION
/jhs
Enclosure
cc: D. J. Hamilla SMR FOR INFORMATION
J. J. Mangeno NR FOR INFORMATION
R. L. Kingsbury WMFO FOR INFORMATION
P. I. Herman WFO FOR INFORMATION