FAX to: Steve Gavitt & Cindy Costello:
c/o Commissioner Zucker, MD: [email protected]
518-474-2011 F: 518-474-6608
cc: Hon: Andrew Cuomo
Tel: (518) 474-8390 Fax:(518) 474-1513
(www.gfxtechnology.NYSDOH.pdf)
January 30, 2015
Dr. Carmine F. Vasile
Ph.D. Electrophysics
Typos corrected 2/20/15
60 Herbert Circle
Patchogue, NY 11772
631-758-6271 (Cell: 631-807-7839, F: 730-3918)
1/21/15 Conference Call Re: Polonium Contamination in Donna Wexler’s, Tom Brinkman’s & My Tap Water
Dear Mr. Gavitt & Ms. Costello: Have you followed up on our 1/21/15 conference call with the Bureau of Water Supply
Protection to confirm Polonium is covered by the State’s 15 pCi/L Gross-Alpha (α) MCL (GA-MCL)? If not, please see
Table 7. Radiological Maximum Contaminant Level Determination in Exhibit A, from Part 5 of the NYS Sanitary
code. Exhibit A also contains a Cancer Risk Table for some of the decay products shown in Figs. A & B for two
radionuclides included in Table 7: Ra-226 & Ra-228. I modified Table 7 to indicate there’s an MCL for Polonium-210
(Po-210) & Lead-210 (Pb-210); two deadly, naturally occurring decay products of Rn-222; “RADON” in Fig. A.
Table 7 indicates the “Gross alpha activity (including radium-226 but excluding radon and uranium)” is 15
pCi/L and expressly includes Po-210 pursuant to Table 16, in addition to all the alpha emitters shown in Figs. A & B.
Fig. A shows Pb-210 is the 1st decay product of Po-214 & Po-210 is produced by Bi-210; the 1st decay product of
Pb-210. Tables 7 set a 4 mrem per year MCL for “Beta [β] particle and photon [γ] radioactivity from manmade
radionuclides”, but unlike the EPA’s Radionuclides Rule of 1976, Table 16 effectively set a 4 mrem/yr MCL for Pb210. Footnote 8 of Table 7 states: “A system must determine compliance with the MCL for beta particle and
photon radioactivity by using the calculation described below:
• pCi/L found in sample (from laboratory results) divided by the pCi/L equivalent of 4 mrem of exposure
equals the fraction of the maximum 4 mrem/year exposure limit”. [For Pb-210, the “pCi/L equivalent of 4
mrem of exposure” is 1.2 pCi/L, according to Table MW2. Radionuclides in On-Site Monitoring Wells in the
BNL Health Assessment.]
Radium-228 Decay Chain
Fig. A. Radionuclides in the Radium-226 Decay Chain regulated by
NYS & EPA -- except Rn-222.
Fig. B. Radionuclides in the Radium-228 Decay Chain regulated by NYS
Sanitary Code & EPA’s Radionuclides Rule of 1976.
POLONIUM CANCER RISK
Exhibit A also includes cancer risk factors for several radionuclides found in LI groundwater, including Ra-228,
Pb-210, Bi-210 & Po-210. Lead-210 has the highest cancer risk factor of all Beta/Gamma emitters found in LI drinking
water, yet its cancer risk factor is only 47.9% of Po-210’s -- the 7th and most deadly decay product of Rn-222.
• Exhibits B indicates my water supply had 387 pCi/L of “RADON” on November 12, 2014.
Exhibit C shows 387 pCi/L of Rn-222 produces Gross Alpha activity above NY State’s GA-MCL of 15 pCi/L and
the likely source the SCWA’s Barton Ave. well field; located ~ ¾ of a mile from my house. It has no aeration tower.
Exhibit D from www.gfxtechnology.com/Po.html indicates the proposed EPA GA-MCL for Radon of 300 pCi/L & its
proposed Alternative MCL (AMCL) of 4,000 pCi/L must be rejected by Governor Cuomo because a 300 pCi/L MCL will
not meet NY State’s GA-MCL and a 4,000 pCi/L AMCL will not meet NY State’s 4 mrem/yr MCL for Lead-210.
Exhibit E indicates the EPA is responsible for our cancer pandemic by regulating Rn-220 while excluding Rn-222.
Exhibit F indicates County Executive Bellone was made aware of excessive Radon & Lead-210 levels, but chose
to lie about this problem, rather than take actions to protect our health & welfare.
Therefore, I hereby demand that you ask Governor Cuomo to intervene to protect Suffolk County residents by
ordering Suffolk County health officials to take immediate action to reduce Rn-222 levels in the water main feeding the
4 dozen homes on Herbert Circle to 5 pCi/L; the level at which Gross Alpha activity from Rn-222; Po-218, Po-214 &
Po-210 will never exceed the 15 pCi/L GA-MCL, as shown in Fig. 2, Exhibit D from www.gfxtechnology.com/Po.html.
Yours truly,
Dr. Carmine F. Vasile
NYS Drinking Water Regulations for Radionuclides
(Excerpts from Part 5 of the New York State Sanitary Code, Subpart 5-1)
Table 7. Radiological Maximum Contaminant Level Determination
(www.health.ny.gov/environmental/water/drinking/regulations/)
Contaminant
MCL
Type of Water System
Determination of MCL Violation2
Combined radium-226 and radium-228
Gross alpha activity (including radium- 5 picocuries per liter
226 but excluding radon and uranium)
[Including Polonium-210
15 picocuries per liter
Pursuant to Table 16]
Community
A violation occurs when a sample or the
annual average of samples at any sampling
point exceeds the MCL3,4,5,6,7.
Uranium
Community
A violation occurs when a sample or the
annual average of samples at any sampling
point exceeds the MCL3,4,5,6,7.
30 micrograms per liter
Beta particle and photon radioactivity
from manmade radionuclides [but
including Lead-210 pursuant to
Table 16]
A violation occurs when a sample or the
Community Water Systems designated
annual average of samples at any sampling
by the State as vulnerable
point exceeds the MCL3,4,5,7,9,10.
Four millirems per year as the
annual dose equivalent to the
total body or any internal organ8. Community systems designated by the A violation occurs when a sample or the
State as utilizing waters contaminated annual average of samples at any sampling
by effluents from nuclear facilities.
point exceeds the MCL3,4,5,7,9,10.
1. The Radionuclides Rule including the MCLs and minimum monitoring requirements applies only to community water systems.
2. To judge compliance with the maximum contaminant levels, averages of data shall be used and shall be rounded to the same number of significant figures as
the maximum contaminant level for the substance in question.
3. For systems monitoring more than once per year, compliance with the MCL is determined by a running annual average at each sampling point. If the average
of any sampling point is greater than the MCL, then the system is out of compliance with the MCL.
4. For systems monitoring more than once a year, if any sample result will cause the running average to exceed the MCL at any sample point, e.g., a single
sample result is greater than four times of the MCL, the system is out of compliance with the MCL immediately.
5. If a system does not collect all required samples when compliance is based on a running annual average of quarterly samples, compliance will be based on
the running average of the samples collected.
6. If a sample result is less than the detection limit, zero will be used to calculate the annual average, unless a gross alpha particle activity is being used in lieu of
radium-226 and/or uranium. If the gross alpha particle activity result is less than detection and is substituted for radium-226 and/or uranium, 1/2 the detection
limit will be used to calculate the annual average.
7. If the MCL for radionuclides in this Table is exceeded, the community water system must give notice to the State.
8. A system must determine compliance with the MCL for beta particle and photon radioactivity by using the calculation described below:
pCi/L found in sample (from laboratory results) divided by the pCi/L equivalent of 4 mrem of exposure equals the fraction of the maximum 4 mrem/year
exposure limit
9. To determine compliance with the MCL, a system must monitor at a frequency as described in Table 12.
10. If the results show an MCL violation for any of the constituents, the system must conduct monthly monitoring for all species at any sampling point that
exceeds the MCL. Monitoring must be conducted in accordance with Table 12 in this section. A system can resume quarterly monitoring if the rolling average of
three months of samples is at or below the MCL.
Cancer Risk Tables*
Radionuclide
Morbidity Risk Coefficients
Cancer Risk per pCi/L in
Cancer Risk Relative to
210
(per Bq)
drinking water
Po in Drinking Water
3
-12
-9
0.00276%
H [Tritium]
1.37 x 10
2.59 x 10
106
2.30%
Ru/Rh
1.14 x 10-9
2.16 x 10-6
134
2.30%
Cs
1.14 x 10-9
2.16 x 10-6
137
1.53%
Cs/Ba
8.22 x 10-10
1.55 x 10-6
210
47.9%
Pb
2.38 x 10-8
4.50 x 10-5
210
0.485%
Bi
2.41 x 10-10
4.56 x 10-7
210
Po
4.97 x 10-8
9.40 x10-5
Reference
226
Ra
N/A
N/A
N/A
228
20.1%
Ra
1.04 x 10-8
1.97 x 10-5
228
5.8%
Th
2.90 x 10-9
5.48 x 10-6
* From: Table 1. Federal Guidance Report No. 13 Cancer Risk Coefficients, Unit Risk Quantities for Drinking Water Concentrations, and the Concentrations
Yielding a 1 in a Million Lifetime Cancer Risk for Environmentally Significant Radionuclides @ http://oehha.ca.gov/water/reports/grossbetahealth.pdf
EXHIBIT A
Alpha Activity (0 to 800 pCi/L) vs Time (0 to 300 minutes)
Fig. A. ETR test report for sample taken on 11/12/14 of radioactive water supplied by
the SCWA to 60 Herbert Circle shows 387 pCi/L of Rn-222.
Table A. Diseases Caused or Worsned By:
(a) Radon & Polonium in Air 2
(b) Radon & Polonium in Water 3
1. lung cancer (typically bronchogenic)
12. liver cancer
13. bladder cancer
2. squamous cell carcinoma
14. stomach ulcer
3. small cell carcinoma
15. leukemia
4. adenocarcinoma
16. cirrhosis of liver
5. large cell carcinoma
17. cardiovascular diseases
6. emphysema
7. pulmonary fibrosis
8. chronic interstitial pneumonia
9. Silicosis
10. respiratory lesions
11. chromosomal aberrations
Fig. B. Graphs show Alpha activity of Po-218 & Po-214 quickly exceeds
the NYS Gross Alpha MCL given in Table B after 387 pCi/L of Rn-222 is
added to a liter of pure water; based on Moral’s equations 1-21(d). [1]
Fig. C. Radionuclides in the Radium-226 Decay Chain regulated by
NYS Health Code. (See Table B)
Table B. Excerpts from Table 7. Radiological Maximum Contaminant Level Determination
Contaminant
MCL
Type of Water System
Gross alpha activity (including radium-226 but excluding
radon and uranium)
15 picocuries per liter (pCi/L)
Community
Gross alpha activity (including radium-226 but excluding
radon and uranium)
15 picocuries per liter
Community
Beta particle and photon radioactivity from manmade
radionuclides
Four millirems per year as the annual dose equivalent
to the total body or any internal organ8
Community Water Systems designated by the State as vulnerable
Community systems designated by the State as utilizing waters
contaminated by effluents from nuclear facilities
8. A system must determine compliance with the MCL for beta particle and photon radioactivity by using the following calculation: pCi/L found in sample (from laboratory results)
divided by the pCi/L equivalent of 4 mrem of exposure equals the fraction of the maximum 4 mrem/year exposure limit. [NOTE: BNL had 3 leaky nukes covered by this MCL.]
Tale C. Radionuclides Table for SCWA’s Barton Ave Well Field Located About ¾ Miles From Herbert Circle
(From Table 2 @ http://www.gfxtechnology.com/Radon.html)
2-BARTON AVE -- 5 wells: S-21247. S-28767, S-103447, S-37494, S-62022 in North Patchogue in 2001; Dist Area 1B in 2002
serving: Bayport, Bellport, Blue Point, Bohemia, Brookhaven, East Patchogue, Hagerman & Holbrook.
Component
Low Value
High Value
Avg. Value
Number of Tests
Gross Alpha Activity pci/l
NA
NA
NA
0
Gross Beta Activity pci/l
NA
NA
NA
0
Cesium-137 pci/l
NA
NA
NA
0
Lead-210 pci/l
NA
NA
NA
0
Radon
ND
329
221
6
(378 in 2001)
NOTE (1): This well field has 5 radioactive wells but only one Radiological table containing high peak and average values of Radon, but no
alpha test results; clear violations of the Radionuclides Rule & Monitoring Requirements.
•
NOTE (2): Rn-222 levels reported by the SCWA for 2001 & 2002 (378 & 329 pCi/L) are consistent with the 387 pCi/L measured on a sample taken
11/12/14; indicating the Barton Ave Well field has been poisoning about 4 dozen homes on Herbert Circle with radioactive decay products of Ra-226 for at least
14 years; including Pb-210 & Po-210 which have respective cancer risk factors >17,000 & 36,000 times Tritium’s; the only radionuclide the Suffolk County
Health Department (SCDHS) will test tap water for. The cancer risk factor of Cesium-137 is only about 1.5% of Po-210’s; 3.4% of Pb-210’s, yet the SCWA tests
for Cs-137 & Pb-210 – NOT Polonium-210 or Lead-210’s parent: Polonium-214.
1
Curves in Fig. B & C from equations 20(a) to 21(d) in Algebraic approach to the radioactive decay equations, L. Moral and A. F. Pacheco, Am. J. Phys. 71, July
2003 @ http://users.df.uba.ar/sgil/physics_paper_doc/papers_phys/modern/radiactive_dacay.pdf .
2 University of Minnesota Web page: http://enhs.umn.edu/hazards/hazardssite/radon/radonharm.html
3
NOTE: Former Surgeon General C. Everett Koop stated that radioactivity, rather than tar, accounts for at least 90% of all smoking-related lung cancers. The
Center for Disease Control concluded "Americans are exposed to far more radiation from tobacco smoke than from any other source." [Quote from “Health
effects of polonium.” @ http://www.lenntech.com/periodic/elements/po.htm]
EXHIBIT C
Polonium Pollution @ Vermont’s 5 pCi/L Action Level vs
EPA’s Proposed Alternative MCL (AMCL) for Radon-222 in Drinking Water of 4,000 pCi/L1
Activity (0-6pCi/L) vs Time (0 to 60 min & 3 days)
Fig. 1. Ra-226 Decay Chain includes one radioactive gas
(Rn-222), seven radioactive metals (Po-218, Pb-214, Bi214, Po-214, Pb-210, Bi-210, Po-210) & one nonradioactive metal Pb-206. 2
Fig. 2. Alpha acivity in drinking water produced by 5 pCi/L
of Rn-222, Po-218 & Po-214; predicted by Moral’s
equations 1-21(d).3
Activity (0-12,000 pCi/L) vs Time (0 to 180 min)
Activity (0-15pCi/L) vs Time (0 to 180min)
Fig. 3. Top curve shows total Alpha activity
produced by Rn-222 in tap water will never
exceed EPA’s Gross-Alpha MCL of 15 pCi/L at
Vermont’s 5 pCi/L action level.
Fig. 4. Top curve shows total Alpha activity
produced by Rn-222 will exceed EPA’s
Gross-Alpha MCL of 15 pCi/L less than a
minute after 4000 pCi/L of Rn-222 is added
to tap water.
Activity (0-5000pCi/L vs Time (0 to 60 min & 3 day)
Activity (0-5000 pCi/L) vs Time (0 to 60 min & 3 days)
Activity (0-2 pCi/L) vs Time (0 to 50 & 1000 days)
Radiation Energy (MEV) vs Time (minutes)
Fig. 5 Alpha Activity from 4000 pCi/L of Rn-222 and its
fastest decaying Alpha emitters: Po-218 & Po-214.
Fig. 6. Beta & Photon Activity from 4000 pCi/L of Rn-222
and its fastest decaying, carcinogenic Beta/Photon
emitters: Pb-214, Bi-214, Bi-210.
Fig. 7 Alpha/Beta/Photon Activity from 4000
pCi/L of Po-214 and its progeny: Pb-210, Bi-210
& Po-210.*
Fig. 8. Relative Alpha, Beta & Gamma
Radiation-Energy) emitted by each atom of
Rn-222, Po-218, Pb-214, Bi-214 & Po-214.
4
* NOTE: The horizontal line in Fig. 6 is 1.2 pCi/L; the activity at which Pb-210 in drinking water delivers a dose of 4 mRem/yr to an average person; the EPA MCL for Beta and/or Photon emitters adopted in 1976.
The 2012 water quality report Suffolk County Water Authority (SCWA) sates: “In 2011 we monitored for radon, and gross alpha and beta particles at 87 locations throughout our distribution system. The results for
each distribution area are noted on pages 13 through 19. Overall, the test results for radon ranged from non-detect (no radon found) to 303 pCi/L. Currently there is no established state or federal MCL for
radon. EPA is proposing to require water suppliers to provide water with radon levels no higher than 4,000 pCi/L." Quote from
http://65.36.213.246/DWQR2012/SCWA_2012_AWQR_page5_educational%20info.pdf. See SCWA Radionuclides Tables @ http://www.gfxtechnology.com/Radon.html -- with a link to a Petition to Governor Cuomo
entitled: “Adopt Vermont's 5 pCi/L action level as a NYS MCL for Radon gases in each water well used for drinking, bottling, irrigation, or any other use.”
2 List of Alpha emitters regulated by the EPA’s Radionuclides Rule of 1976 in CERCLA Dirctive No. 9283.1-14.includes Ra-226, Po-218, Po-214, Po-210 NOT Rn-222.
[http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/9283_1_14.pdf
3 Curves in Fig. B & C from equations 20(a) to 21(d) in Algebraic approach to the radioactive decay equations, L. Moral and A. F. Pacheco, Am. J. Phys. 71, July 2003 @
http://users.df.uba.ar/sgil/physics_paper_doc/papers_phys/modern/radiactive_dacay.pdf .
4 NOTE: One MeV is equal to 0.16 trillionth of a joule, 1 rad equals 0.01 joules/kg, radiation energy levels and other parameters from pages 42 & 78, EVS Human Health Fact Sheet for Radium (Argonne National Laboratory,
August 2005)
EXHIBIT D (This page @ www.gfxtechnology.com/Po.html)
1
EXHIBIT E
Suffolk County Executive Steven Bellone commented on your post. [Notes added on 2/5/15 by Dr. Carmine F. Vasile]
1. 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. [False]
2. 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). [False: See NOTE A]
3. 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. [Misleading, the SCDHS doesn’t test for Radon]
4. 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. [False, Table 19 below shows a 14-test average was 77.1; 64 times the 4 mrem/yr MCL in the NYS Sanitary Code]
5. 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. [False]
6. 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. [False, the NYSDEC never tests groundwater for radionuclides produced by Radon-222, for example.]
January 29 at 2:44pm · Like
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-222; 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?”
NOTE A: Exhibit A, Table 19 & Fig. 19 below from www.gfxtechnology.com/Radon.html show Bellone lied when he wrote: “…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).”
Table 19: LAMBERT AVE -- 2 wells: S-71881, S-71882 in Mastic in 2001; Dist Area 20 in Fig. 19: Fraudulent Table from 2003 AWQR shows 232 pCi/L Alpha
2002 serving: Mastic, Mastic Beach, Moriches, North Shirley, Ridge, Shoreham, South Manor, activity from Radon, but only 4.0 pCi/L Alpha activity from Radon
South Ridge, Westhampton Beach.
progeny.
Component
Low Value
High Value
Avg. Value
Number of Tests
Gross Alpha Activity pci/l
ND
1.5
ND
14
Gross Beta Activity pci/l
ND
2.0
ND
14
Cesium-137 pci/l
ND
ND
ND
14
Lead-210 pci/l
ND
1080.0
77.1
14
Radon
ND
ND
ND
5
NOTE: More obvious examples of violations of the Radionuclides Rule & Monitoring Requirements
suborned by County Executive Bellone who wrote on his Facebook page “there have been no
confirmed significant detections of lead-210”; falsely alleging the 1080 pCi/L entry in Fig. 19 is merely
an “anomaly of the analysis” made by the SCWA’s laboratory; not the County’s.
EXHIBIT F