Operable Unit IV Record of Decision
In 1989 BNL was included on the U.S. Environmental Protection Agency's (EPA) National Priorities List under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, more commonly known as the Superfund Act, as the result of contamination found during a 1988 Department of Energy (DOE) Environmental Survey. Investigators initially identified 28 areas at the Laboratory with some contamination. These areas became known as Areas of Concern (AOCs) and included Solid Waste Management Units (SWMUs) that had been identified earlier by the New York State Department of Environmental Conservation (NYSDEC) under the Resource Conservation and Recovery Act (RCRA) permitting process. Cleanup operations at the Laboratory were geographically subdivided into seven Operable Units (OUs) to focus efforts and assign priorities. Later, OU II and OU VII were combined into OU II/VII.
Operable Unit IV
Operable Unit IV is located on the east-central edge of the developed portion of the BNL site. It encompasses the Central Steam Facility, the Reclamation Facility, the Building 650 Sump and Sump Outfall, leaking sewer lines, and a recharge basin. The Areas of Concern are AOC 5, 6, 21, and 24D and are associated with contamination from a 1977 oil/solvent spill at the Central Steam Facility or radiological contamination from laundry and vehicle washing activities at the Reclamation Facility.
The primary contaminants of concern in OU IV were volatile organic compounds and semi-volatile organic compounds in the soil and groundwater from the 1977 spill at the Central Steam Facility and radionuclides (Cesium-137, Strontium-90, Plutonium 239/240, and Europium) in the soils at the Building 650 Sump Outfall.
The remedial action objectives for OU IV are to restore groundwater quality to maximum contaminant levels for drinking water (MCLs) or background, and prevent or minimize: leaching of contaminants from soil into groundwater; human exposure from surface and subsurface soil; and the uptake of contaminants in soil by plants or animals.
The following is an article outlining the highlights of the OU IV ROD that was published in the summer 1996 edition of the stakeholder newsletter cleanupdate.
Lab's First Record of Decision Reached
The March 1996 signing of the first Record of Decision reached as part of the Superfund process at Brookhaven National Laboratory has set in motion the cleanup of the area around the Central Steam Facility near the center of the Lab. This Record of Decision, or ROD, documents the final selected remedy for the area.
This investigation was conducted under the administrative name of Operable Unit IV-Central Steam Facility, and is referred to as "OU IV." A "fast track" cleanup operation known as an interim soil Removal Action was conducted in 1994 as part of OU IV's remediation.
Removal Actions seek to remove contamination sources as quickly as feasible in order to eliminate any potential threat to the public or environment. Sometimes, however, a longer, more detailed investigation is conducted before final cleanup decisions are made, resulting in a ROD.
This ROD was signed by the U.S. Department of Energy, the U.S. Environmental Protection Agency, and the N.Y.S. Department of Environmental Conservation; all of which oversee the Lab cleanup. The ROD identifies the extent of contamination and/or potential contamination, assesses health and environmental risks (Remedial Investigation/Risk Assessment Report), evaluates cleanup alternatives (Feasibility Study Report), and describes regulatory and public comments on the proposed remedy (Proposed Remedial Action Plan) made at a December 1995 public meeting attended by approximately 100 community members, as well as other comments submitted during the comment period.
The ROD documents several previous Removal Actions, including excavation of a leaching pit and removal of an underground fuel storage tank, piping, and surrounding contaminated soils.
It also addresses the remaining soil and groundwater contamination from a 1977 oil/solvent spill, soil contamination near one of the Central Steam Facility's fuel unloading areas, and radiologically contaminated soil surrounding the Reclamation Facility (used for cleaning radiologically contaminated clothing and heavy equipment).
The selected cleanup method involves using a combination of various treatment techniques to remove groundwater contaminants. The cleanup is scheduled to start in April 1997, following the completion of the design of the system.
There were numerous opportunities for the community to participate in the decision-making process for the OU IV clean up throughout the process. In accordance with CERCLA, a Community Relations Plan had been finalized in September 1991 and Administrative Record repositories to hold cleanup documents were established in three local libraries as well as the EPA Library. The Community Relations program focused on public information and involvement. A variety of activities including direct mailings, community meetings, poster sessions, tours, workshops, and public meetings were held on the cleanup actions.
The OU IV draft RI/FS Work Plan was presented to the public at an informational meeting held on September 26, 1991. A public comment period was held on the OU IV RI/FS Work Plan from February 17, 1992 through March 17, 1992. An informational letter, with a public notice attached, was sent to the community mailing list on August 3, 1994 announcing the availability of an Engineering Evaluation Report and Action Memorandum at local repositories, for the OU IV Soil Interim Removal Action. A public notice was published and a comment period was held in January 1995 on the OU IV Remedial Investigation/Risk Assessment (RI/RA) Report. A letter on the Report was also sent out to community members.
In November 1995, an informational letter was sent to community members announcing the OU IV Feasibility Study/Proposed Remedial Action Plan (FS/PRAP) public meeting. The public notice (published in local newspapers), meeting invitation, PRAP fact sheet, and a site tour invitation were attached. A 30-day public comment period on the PRAP began on November 22, 1995. The public meeting and a site tour for the OU IV FS/PRAP took place at BNL on December 6, 1995. The meeting was attended by over 100 people. Representatives from the EPA, NYSDEC, BNL, and DOE answered questions and accepted comments on the cleanup plan.
The types of communications listed above were repeated for each of the Operable Units and the Removal Actions. The BNL Environmental Restoration Division (ERD) mailing list, at the height of the cleanup, included addresses for more than 2,300 stakeholders. The cleanupdate newsletter was sent to the mailing list several times a year from 1996 to 2003. It kept stakeholders up-to-date on the projects. BNL employees were updated regularly through articles in the Monday Memo and the Bulletin.
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