• As referenced in your
e-mail, the EPA ollows the Multi-Agency Radiation Survey and Site Inspec-tion Manual (MARSSIM). Te CAG Executive Committee stated in its e-mail that “[t]he ﬁrst observation regarding testing is that sodium iodide scintillation detectors or low count rate testing like BMAC can have a,“…reading error o 50%.” (U.S. Environmental Protection Agency; Multi-Agency Radiation Survey and Site Inspection Manual (MARSSIM), Revision 1. EPA 402-R-97-016, Rev. 1. August, 2000).” Te quoted text above is part o a sen-tence which in whole reads “[t]he reading error o 50% can occur at low count rates because o a large needle swing, but this decreases with increased count rate.”
• Tis sentence is referring to a detector with an ana
-log “needle type” display gauge. Te 50% error results rom the equipment operator’s inability to accurately read the display due to the wide swing o the needle during relatively low count rates.
• Te potential reading error of 50% cited by the
Executive Committee does not apply to the equip-ment used by EPA to conduct the gamma survey at BMAC because the equipment EPA used was digital and not analog and does not require a person to read the needle as it swings rom one level to the next since a computer captures the readings automatically. Te more technical reasons are as ollows:that eﬀort and the act we are not certain o their QA/QC procedures we have not included this inormation in our decision making and public comments. Te same group later conducted a “Gamma PAL” screen-ing that indicated the presence o Lead-210 at a level that would not require any remediation by the EPA but caused concern in the public afer media reports. Again, because o the QA/QC questions we could not use this inormation as a basis or any agency deci-sion. Instead, what we chose to do was test in the exact same locations. Te EPA Region 7 consulted with the leader o that group on the speciﬁc locations where soil samples were taken. Although she wasn’t able to point out those locations during a site visit she was able to later produce the locations by email, which we have tested.
• EPA Region 7 reviewed existing data from credible
scientiﬁc and technical experts as part o a holistic eﬀort to understand the conditions o the complex and surrounding area. Te MDNR dust samples pro- vided an important recent assessment but were in-complete on their own. Te 2005 MDNR haul road data provided important acts. Te third set o tests came rom the Department o Energy sampling cited in the Record o Decision or the North St. Louis County Sites issued by the U.S. Army Corps o Engineers, St. Louis District Oﬃce FUSRAP Program on September 2, 2005. EPA’s citation o that sampling came rom a scientiﬁcally valid oﬃcial decision document created by the USACE, another credible technical agency. Tis report indicated the roads were suitable or use and also provided important acts about the surrounding area that were valuable in ascertaining the suitability o BMAC. As EPA indicated at the time, there was no scientiﬁc basis rom a credible source to indicate BMAC was anything but suitable or use.
• Regarding the USACE report, the EPA believes this
oﬃcial FUSRAP decision document is a scientiﬁcally valid source. By citing these three sampling eﬀorts, EPA demonstrated that areas around BMAC did not contain levels o radiation requiring remediation and that there was no indication that conditions within the park would be any diﬀerent.
• EPA’s statements about the usability of the complex
were based on valid, scientiﬁc sources which EPA shared with the community. All statements regarding BMAC by EPA Region 7 were based on the body o evidence, which was made public at the time, and in so doing ulﬁlled its obligation to ensure that accurate inormation was available to the public.