July 15, 1997
STATEMENT BY PETER BOND, INTERIM
BROOKHAVEN NATIONAL LABORATORY,
ON PRELIMINARY FINDINGS OF EPA AUDIT
I thank EPA for their diligence in conducting
this thorough, independent inspection of Brookhaven, just as I thank BNL's
environmental staff for their cooperation throughout the process. We at
Brookhaven accept fully that while our operations are in compliance with
many of EPA's environmental laws and pose no immediate threat to environment,
safety and health, there are areas where we need to improve. We have already
begun addressing the issues they have raised.
Our next step is to begin the second and third
phases of this multimedia review. The second phase, which will help us
minimize the amount of waste we produce and reduce our emissions, will begin
tomorrow with the arrival of an EPA team on site. The third phase, a review
of environmental management issues at Brookhaven, will begin later this
year. These efforts, combined with the Management Systems Improvement Plan
now being undertaken by the Laboratory's top administration and the U.S.
Department of Energy's 30-Day Action Plan, will improve environmental management
The findings in each of the EPA's audit categories,
along with the actions we have taken or are taking to address them, are
- Radiation - BNL
is in compliance with EPA's air emissions standards for radioactive elements.
The Laboratory will further evaluate low-level activation of concrete
accelerator shielding blocks.
- Emergency Planning and Community Right-to-Know
- BNL is in compliance; the Lab is now
voluntarily conducting a sitewide chemical inventory.
- Underground Injection Wells - BNL is in compliance for cesspools and dry wells. EPA
has stated that DOE needs to better survey the Laboratory's injection wells
to ensure compliance with the Safe Drinking Water Act.
- Toxic Releases -
BNL is in compliance with these guidelines, also known as SARA Form R emissions.
EPA has requested information of the Lab's chemical use from previous
- Water Discharges -
BNL is largely in compliance, except for a concern involving permitting
of stormwater at the Hazardous Waste Management Facility, and a concern
over a valved pipe at the Sewage Treatment Plant that the Laboratory has
now agreed to seal to prevent accidental unpermitted discharge. The Laboratory
is now pursuing a permit for the stormwater discharge at the Hazardous
Waste Management Facility, which is in the process of being decommissioned
and transferred to BNL's Superfund cleanup program. A new, state-of-the-art
facility with modern stormwater controls has been built to handle the Laboratory's
hazardous waste beginning this fall.
- Air Emissions -
BNL was largely in compliance with EPA's Clean Air Act standards, with
the exception of compliance and reporting requirements for oil-burning
boilers at the Central Steam Facility that provides steam heat to some
Laboratory buildings; this concern has since been addressed. Also noted
were labeling requirements for gasoline pumps at the BNL gas station; timely
leak repairs on refrigeration equipment; and notification for removal of
asbestos. BNL is working to improve these areas.
- Underground Petroleum Storage Tanks - BNL has delivered to EPA 6 of 8 reports on underground
tanks that were decommissioned in 1990-1991; the remaining two reports
will be delivered to EPA.
- Toxic Substances Management - BNL was found to have been improperly storing 15 gallons
of waste containing polychlorinated biphenyls, or PCBs. The waste has
since been disposed at an approved off-site facility. An EPA inspector
also noted occasional, but not significant, violations of a requirement
to move PCB wastes to proper storage within 30 days; BNL was commended
for responding quickly and appropriately to the discovery of PCBs in unexpected
- Hazardous Waste Handling and Disposal - Brookhaven's violations in this area were largely concerned
with storage of hazardous waste at the point of generation, and training
and record keeping for those who generate hazardous wastes. The concerns
centered on just 6 of the over 3,500 containers of hazardous waste handled
at BNL each year. BNL has since corrected many of these deficiencies and
will work to correct them all. Waste handling and training at the Hazardous
Waste Management Facility were found to be in compliance.
- Spill Prevention Controls - EPA had concerns over administrative issues related to
BNL's Spill Prevention Control and Countermeasures plan. BNL has resolved
many of those issues, and has provided a schedule to resolve outstanding
- 30 -