Operable Unit I Record of Decision

September 1999

Background

In 1989, BNL was added to 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 containing radiological or chemical contamination. These areas became known as Areas of Concern (AOCs) and included Solid Waste Management Units (SWMUs) that had been identified earlier by the 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 one OU.).

As cleanup projects were undertaken, the Laboratory quickly realized it would be more efficient to group together similar types of contamination. This ensured effective management and facilitated the cleanup process. Radiologically contaminated soils from areas originally included in OU II/VII, IV, and VI were cleaned up at the same time as soils from OU I and are documented in the OU I Record of Decision (ROD).

Within OU I, a fast-track project known as Removal Action V was initiated to pump-and-treat groundwater at BNL's southern boundary and to hook up homeowners south of the Lab to public water as a precautionary measure when contamination was found in private wells tested by Suffolk County. The contamination found in the wells was eventually traced back to a business in an industrial park just south of the LIE, and was unrelated to operations at BNL. Public water hookups to nearly 1,500 homes began in January 1996, and the first treatment system began operation in December 1996. Contamination from BNL did travel beyond the southern boundary, but it was deeper in the aquifer than the homeowners wells and was addressed by the OU I treatment system (Click on the Public Water Hookups Offered and the OU I South Boundary GW Treatment System Begins Operation listings found under the Topological Index for additional information.).

Operable Unit I

Operable Unit I was originally defined as a 950-acre area in the southeastern portion of the Laboratory and included AOCs 1, 2, 3, 24E and 24F. These AOCs, for the most part, were locations where waste was historically managed or disposed of. They included the Former Hazardous Waste Management Facility (FHWMF), the Former and Interim Landfills, the Chemical Pits, the Glass Holes, the Current Landfill, and two recharge basins. Prior to finalizing the ROD, portions of AOCs 6, 8, 10, 16, 17, and 18 were included under the OU I soil cleanup.

The principal radiological soil contaminants found in OU I included tritium, thorium-232, cesium-137, and strontium-90. Elevated levels of metals such as copper, lead, and mercury were also found in some locations. Rainwater percolating through the soil of these areas, particularly the landfills and at the FHWMF, carried tritium and other radiological contaminants and contamination from volatile organic compounds (VOCs) into the groundwater beneath them. Because the contamination posed a threat to groundwater, top priority was assigned to defining the extent of contamination and taking corrective measures.

The Remedial Action objectives were to prevent or minimize movement of contaminants from soil into groundwater; human exposure from surface and subsurface soil; and uptake to ecological receptors. The cleanup goal for radionuclides in soil was based on a total dose limit of 15 mrem/yr above the background level. Chemical cleanup levels for mercury (1.84 mg/kg) and lead (400 mg/kg) were calculated using EPA's soil screening level guidance. The cleanup goals for groundwater contaminants were based on New York State drinking water standards.

The following is an article outlining the highlights of the OU I ROD that was published in the December 1999 edition of the stakeholder newsletter cleanupdate.

DOE, Lab Reach Milestone in On-site Cleanup

EPA and State agree to cleanup plan

The U.S. Department of Energy (DOE), the U.S. Environmental Protection Agency (EPA), and the New York State Department of Environmental Conservation (DEC) have agreed to a cleanup plan for contaminated soils at Brookhaven National Laboratory (BNL). DOE, EPA, and DEC have signed the Operable Unit I Record of Decision (ROD). This document describes the final plan to address Operable Unit I, which includes soils at the Lab that contain radioactive materials. The approval of the ROD represents a significant milestone in the Brookhaven Lab cleanup. It clears the way for the final soil cleanup to begin.

Community Input

DOE held three information sessions and a public meeting on Operable Unit I in April of 1999. Participants were asked to provide comments on the proposed cleanup, as described in the Operable Unit I Proposed Plan. Public comments from these meetings, as well as comments from EPA and DEC, supported the proposed cleanup. Therefore, DOE adopted the proposed cleanup plan in the ROD.

"To reach this milestone, many people and organizations worked very closely and diligently," said George Malosh, manager of the Department's office at Brookhaven. "The community, our environmental regulators, and the Laboratory deserve a lot of credit. Congratulations and let's get this cleanup going."

Next Steps

The first priority in this cleanup is the removal of landscaping soils that contain low levels of Cesium-137. Plants that grow in these soils can absorb the cesium, thereby becoming contaminated. These plants may be consumed by deer on Lab property. The Lab plans to remove the radioactively contaminated soils, thereby removing the source of plant contamination. This cleanup should be completed by the summer of 2000.

Following the landscaping soils, the Lab will excavate and remove the other areas of radioactively contaminated soils in Operable Unit I. All of these areas are on Lab property. They include the Lab's former Hazardous Waste Management Facility, the Waste Concentration Facility, the Reclamation Facility sump and sump outfall, and tanks at Building 811.

In addition, areas on Lab property with low concentrations of metals will be addressed. An area that was used to dispose of incinerator ash will be capped with soil and monitored. Two basins that are used by tiger salamanders, a state endangered species, will be excavated and restored. The Department expects to complete the Operable Unit I cleanup by 2005.

Community Input

The community had several opportunities to participate in the decision-making process for the OU I clean up throughout the process. In accordance with CERCLA, a Community Relations Plan was finalized in September 1991, and the Laboratory established Administrative Record repositories to hold cleanup documents in three local libraries. The Community Relations program focused on public information and involvement. A variety of activities were held on the cleanup actions, including direct mailings, community meetings, poster sessions, tours, workshops, and public meetings.

In October 1993, BNL held public meetings on the "OU I Remedial Investigation/Feasibility Study, Sampling and Analysis Plans and Site Health and Safety Plan" and a public comment period ran from October 25 to November 26, 1993. A Notice of Availability was published in local newspapers in January 1995 for Removal Action VI, the "Current Landfill Action Memorandum." In May 1995 a Public Notice for the Removal Action VI "Engineering Evaluation/Cost Analysis for Landfill Closure" was published in local newspapers and a 60-day comment period was held.

The Lab held a public meeting on January 16, 1996 on the Engineering Evaluation/Cost Analysis" (EE/CA) for OU I and the contamination found at the southern boundary area of the site. Monitoring data from BNL and private well testing results from Suffolk County Department of Health Services were also discussed at this meeting. The County found several wells with contamination (eventually found to be unrelated to BNL operations) and subsequently, DOE offered water hookups to homeowners. Summary sheets were sent to stakeholders; nearly 700 people attended the meeting. The public comment period was extended to 90 days. A presentation was given to the Community Work Group regarding the public water hookups and a briefing on the "Groundwater EE/CA" was held at BNL. Two on-site briefings (January 4, 1996 and February 8, 1996) regarding the proposed groundwater treatment system were given to the National Weather Service staff.

A Suffolk County legislator hosted a meeting to brief elected officials on the public water hookup project and BNL groundwater contamination. Two question-and-answer sessions (February 5 and 6, 1996) were held for BNL employees on Operable Unit I groundwater issues. Also, four fact sheets about this project were published and distributed, as well as articles in six editions of the Brookhaven Bulletin (between February and March 1996).

In July 1996, the Removal Action VI "Former Landfill Action Memorandum" was made available for public review; a Public Notice was published in local newspapers. In June 1997, a Notice of Availability for review and comment on the Operable Unit I "Action Memorandum Phase III Landfill Closure Removal Action" was published in local newspapers.

A Public Notice for the OU I/VI "Remedial Investigation/Risk Assessment" was published in July 1996. The public comment period began July 29, 1996 and was originally scheduled to end August 30, 1996. Upon a request from the Community Group, it was extended to September 30, 1996. An article about the upcoming meeting was published in cleanupdate in the spring 1996 issue, and a Notice of Availability of the reports was published in the summer 1996 issue.

The Operable Unit II/VII Remedial Investigation Report was made available for public review and comment on February 17, 1999. A Public Notice and a display ad were published in local newspapers. A DOE press release announcing the comment period and providing a summary of the report was issued to media contacts. Two information/poster sessions were held in Berkner Hall, BNL. Total attendance at the two information sessions was 48, including 8 members of the public and 40 BNL employees.

The OU I Feasibility Study and Proposed Plan were made available for public review and comment on April 1, 1999. A Public Notice and a display ad announcing the public comment period, the dates of the information/poster sessions, and the date of the public meeting were published in local newspapers. A DOE press release that announced the comment period and summarized the report was issued to media contacts.

A mailing was sent to the stakeholders, to all BNL employees, and to others who worked on-site. The mailing included a summary of the report, mentioned the dates and locations of the information/poster sessions and public meeting, and provided a phone number to call to receive a copy of the entire OU I Proposed Plan. Two additional display ads announcing meeting dates were published in local newspapers. The Executive Summary of the Feasibility Study and the entire Proposed Plan were made available on the BNL web site, along with the dates and times of the information sessions and public meeting.

Two Laboratory-wide e-mails reminded BNL employees of the information sessions and the public meeting dates just before each occurred. An article in the Brookhaven Bulletin explained the proposed plan briefly and gave meeting dates and the web address. Flyers announcing the upcoming poster sessions and public meeting were sent to all the public libraries in Suffolk County to be posted on their community bulletin boards. Five local civic organizations were briefed on the upcoming events and the flyers were distributed at the meetings. One civic association president was briefed by phone. The flyers also were distributed at the April 1999 meeting of the Community Advisory Council. The Brookhaven Executive Roundtable was provided with an update and overview of OU I in December 1998 and a comprehensive status report in March 1999. The Community Advisory Council was given an overview of all the Operable Units in December 1998 and a budget update in January 1999.

An outreach letter was sent to elected officials in February 1999 offering personal briefings with them, if that was desired. The staffs of Congressman Forbes and Senators Moynihan and Schumer were briefed by representatives of BNL and the local DOE-Brookhaven office in March of 1999.

BNL held two poster/information sessions, one at lunchtime and one in the evening, and a public meeting was held on April 22, 1999. Approximately 75 people attended the three sessions, including 19 members of the public.

Documents / Links

OU I Record of Decision