"Additional information", in and of itself, is not only not compelling, it is totally irrelevant. The quantity of "information" in the original submittal was impressive. Its the quality of the information that needs a blood transfusion. The information in the original submittal was mostly falsehoods, as, no doubt, is the additional material supplied by the same KAPL falsifiers. Hard to believe, but new information from the same Laboratory that lied through its teeth on a CERCLA submittal, and the EPA is still willing to believe them.
The use of a new HRS scoring system goes beyond being totally irrelevant since the input to the new scoring system is the same falsified input as fed to the original HRS. The existence of a new scoring system is meaningless for KAPL submittals unless it can recognize and correct falsified input. Our allegation did not take issue with the HRS, but rather with the falsified information input to the HRS.
July 23 2001
Mr. John P. Shannon
Physicist. Nuclear Engineer
262 Jones Road
Saratoga Springs, New York 12866
Mr. Robert D. Stater, P.E.
Nuclear Engineer
105 Pashley Rd.
Scotia, New York 12302
Re: Knolls Atomic Power Laboratory
Niskayuna, New York
Dear Mr. Shannon and Mr. Stater:
This is in reference to your letter dated May 18, 2001 to Administrator Whitman of the United States Environmental Protection Agency (EPA) regarding the Knolls Atomic Power Laboratory (KAPL), in Niskayuna. New York. Your letter has been forwarded to me for response.
You allege possible "falsification" by the Department of Energy (DOE) of 1988 Site Assessment documents (inch ding the Hazard Ranking Score (HRS) that were submitted to EPA for the purpose of evaluating whether the site would qualify for listing on the National Priorities List (NPL) under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The allegations of your letter are serious in nature and of great concern to our agency.
We have reviewed our files and found that substantial information was provided by the facility at our request subsequent to the 1988 documents. For example, our latest evaluation of the facility included a 1993 Expanded Site Inspection (ESJ) report and Environmental Monitoring reports from 1985-1992. These additional reports included information on radioactivity, groundwater flow, and re-estimates of hazardous waste landfill quantity (all of which are matters that you are concerned had not been reported or had been misrepresented). In addition, it is significant to note that the facility's 1988 HRS was conducted utilizing an early version of the HRS. The facility's 1993 ESJ included re-evaluation of the site with a more comprehensive newer version of the HRS that is still currently in effect.
After review of all of the additional information submitted by DOE subsequent to 1988, EPA still determined that the facility did not qualify for inclusion on the NPL under CERCLA.
With regard to the former Peek Street facility that you note in your letter, you raise into question DOE's credibility in closing the site in the 1950's when later cleanup was found to be necessary in the late 1980's. It is our understanding that the facility was closed out to the standards in effect at the time of closure in the 1950's and that the subsequent cleanup was conducted to meet the succeeding standards in effect in the late 1980's. We further understand that the latter cleanup, which was completed in the early 1990's, was independently verified by New York State.
It would appear from your letter that you may have been unaware that DOE had submitted additional information to EPA subsequent to the 1988 reports. If you would like to review this additional information, still believe that DOE has misrepresented information that has been provided to EPA, or otherwise have further questions, please contact Mr. Robert Wing at (212) 637-4332 or Ms. Helen Shannon at (212) 637-4260 of my staff.
Sincerely,
Kathleen C. Callahan
for William Muszynski, P.E.
Acting Regional Administrator
cc: E. Crotty, Commissioner, NYSDEC
R.Marino, NYSDEC