#97-76
July 15, 1997

STATEMENT BY PETER BOND, INTERIM DIRECTOR
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 at BNL.

The findings in each of the EPA's audit categories, along with the actions we have taken or are taking to address them, are listed below.

• 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 years.
• 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 locations.
• 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 issues.

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