The Responsiveness Summary Section of the Record of Decision (ROD) summarizes public comments and concerns on the Feasibility Study Report (FS) and the Proposed Remedial Action Plan (PRAP) for Operable Unit III, and the Department of Energy 's (DOE) responses to them.
The Responsiveness summary serves two functions:
1. It provides decision-makers with information about the views of the community on the proposed remedial actions and any alternatives; and
2. It documents how public comments were considered during the decision-making process, and provides answers to the major comments.
The public comment period for the review of the OU III FS report and the Proposed Remedial Action Plan began on March 1, 1999 and was extended through April 30, 1999. A public meeting was held on March 24, 1999 in Berkner Hall at Brookhaven National Laboratory. This document summarizes the written and oral comments on the preferred remedial alternatives and the OU III RI/FS, the DOE's responses, and the changes made to the proposed remedial action.
Approximately 75 people attended the public meeting. At the public meeting DOE and BNL distributed copies of the PRAP and other related information. Copies of the FS and PRAP were available at the following Administrative Record Repositories for public review during the comment period:
1. U.S. Environmental Protection Agency - Region II Library, Administrative Records Room, New York, NY
2. Longwood Public Library, Middle Island, NY
3. Research Library, Brookhaven National Laboratory, Upton, NY.
4. Mastics-Moriches-Shirley Community Library, Shirley, NY.
The preferred remedial alternative was modified as follows based on the concerns and input of regulators and the public:
The Responsiveness Summary is divided into the following sections:
1. RESPONSIVENESS SUMMARY OVERVIEW
Brookhaven National Laboratory (BNL) is a multidisciplinary scientific research center owned by the DOE and operated by Brookhaven Science Associates (BSA). BNL conducts basic and applied research in the fields of high-energy nuclear and solid-state physics, fundamental material and structural properties and the interactions of matter, nuclear medicine, biomedical- and environmental-sciences, and selected energy technologies.
BNL is located about 60 miles east of New York City, in Upton, Suffolk County, New York, near the geographic center of Long Island. The BNL site, formerly Camp Upton, was occupied by the U.S. Army during World Wars I and II. The site was transferred to the Atomic Energy Commission in 1947, to the Energy Research and Development Administration in 1975, and to the DOE in 1977.
The BNL property is an irregular polygon of 5,321 acres that is roughly square, each side of which is approximately 2.5 miles long. The terrain is gently rolling, with elevations varying between 40- to 120-feet above sea level. The land lies on the western rim of the shallow Peconic River watershed, with a tributary of the river rising in marshy areas in the northern section of the tract.
The aquifer beneath BNL is comprised of three water bearing units: the moraine and outwash deposits (known as the Upper Glacial Aquifer), the Magothy Aquifer, and the Lloyd Sand Member of the Raritan Formation. These units are hydraulically connected and make up a single zone of saturation with varying physical properties from a depth of approximately 45 feet to 1,500 feet below the land surface. These three water-bearing units are designated as a "sole-source" aquifer by the U.S. Environmental Protection Agency (EPA) and serve as the primary drinking water source for Nassau and Suffolk Counties.
As a result of historical operations at the site, BNL was placed on the EPA National Priorities List in December, 1989. In May, 1992, DOE entered into an Interagency Agreement (IAG) for the BNL site with the EPA and New York State Department of Environmental Conservation (NYSDEC) under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The IAG established the framework and schedule for characterizing, assessing, and remediating the site in accordance with CERCLA.
BNL has 29 Areas of Concern (AOCs). To ensure their effective management, these areas were grouped into six distinct Operable Units (OU). The OUs are areas for which independent removal or remedial actions may be performed as part of the overall site remediation.
Operable Unit III
OU III is bounded by the northern, southern, and western property boundaries of BNL and encompasses approximately 50 percent of the Laboratory's total area. OU III was developed to address groundwater contamination in the central and southern portion of the site and in the off-site areas where groundwater contamination has migrated. Thirteen AOCs assigned to OU III were investigated as suspected source areas of groundwater contamination. Also, as the work for OU III was proceeding, groundwater contamination from other OUs and Additional Areas of Investigation (AAIs) was included in the investigation and assessment.
These AOCs and AAIs were investigated in the Remedial Investigation/Risk Assessment (RI/RA) for OU III. Based on the findings of this RI/RA, DOE, BNL, EPA, and NYSDEC determined that the groundwater is the only environmental medium in OU III that requires an action to protect human health. The contamination in the groundwater that requires remedial action includes volatile organic compounds (VOCs) in on-and off-site groundwater, and strontium-90 and tritium in on-site groundwater.
Selected Remedial Alternatives for OU III
Groundwater contamination issues at BNL include volatile organic compounds (VOCs) in on- and off-site groundwater, and strontium-90 and tritium in on-site groundwater. Several alternatives were evaluated for each of the contaminated groundwater plumes.
The remedy ultimately selected by DOE and approved by EPA and NYSDEC will be implemented in a timely manner. The approved remediation facilities are expected to be installed within two to five years after the final remedy is selected.
The design, off-site land access, and construction are the primary tasks that will need to be completed for installing the groundwater treatment systems. Their installation will be prioritized to address the highest VOC concentrations and those portions of the plume with the greatest potential to impact receptors.
The following selected remedy for tritium, strontium-90 and VOCs in groundwater is a combination of groundwater treatment and monitoring and that restores to maximum contaminant levels (MCLs) the portion of Long Island's sole source aquifer contaminated by BNL in a timely manner.
Volatile Organic Compounds (VOCs)
Several accelerated actions already have begun to address VOC contamination and are part of the selected remedy:
In addition to these activities, the selected remedy, Alternative V10c, includes a groundwater-treatment system on-site at Middle Road to prevent migration and further contamination of the deeper Magothy Aquifer, and to reduce the duration of remediation in the Upper Glacial Aquifer. Also included is a source removal system using re-circulation wells with air stripping treatment near Building 96. Finally, additional off-site groundwater treatment systems are planned to capture and treat VOCs; they will be located at the LIPA right-of-way, North Street, the Brookhaven Airport, downgradient of North Street East, the eastern portion of the Industrial Park and in the western OU III low-level VOC plume. The specific number of treatment systems and the locations needed to meet the performance objective will be determined during the design process.
At present, limited characterization has been performed in the Magothy, so additional characterization and installation of groundwater monitoring wells are planned. This work will be done during the design of the remedy, and will be included in the site records. When this characterization and monitoring is completed, the need for a remedy for the Magothy Aquifer, will be evaluated by DOE, EPA and NYS DEC. If a remedy for the Magothy Aquifer is necessary, either this record of Decision will be modified or another decision document will establish the selected action. In either case, the public wil have and opportunity to review and comment in accordance with CERCLA.
This selected remedy (V10c) is not the one proposed in the PRAP. The proposed remedy (V10b) did not include the treatment system located on-site for the western low-level VOC plume. The additional system was added in response to community and regulator concerns about potential impacts to the Carmans River.
A pump and recharge system, which includes three pumping wells located on-site along Princeton Avenue, was installed in May 1997 to extract the tritium contaminated groundwater and discharge it further north to a recharge basin on-site. Pumping at the leading edge of the plume was taken as a precautionary measure to inhibit contaminated groundwater from advancing towards the site's boundary and allow more time for the tritium to decay. A carbon filtration unit also was included in the pump and recharge system to remove VOC's that are also present.
The selected remedy is a modification of alternative T4, as originally proposed in the PRAP. The remedy will combine extraction of groundwater in response to specific contingencies and extensive monitoring and reporting to assure that the cleanup objectives are met. Three specific contingencies were identified in the PRAP, and a fourth has been added in this ROD to address regulatory concerns. Other actions will be evaluated and implemented, as necessary, to ensure that the cleanup objectives are met. Additional monitoring wells will supplement the existing groundwater monitoring network downgradient of the High Flux Beam Reactor's (HFBR) spent fuel pool.
The first and second contingencies were developed to ensure that the tritium plume would migrate no further downgradient above drinking water standards. After an evaluation period established during design of the selected remedy, the tritium pump and recharge system on Princeton Avenue will be put on stand-by and later operated as needed as an integral component of these contingencies. The evaluation period will extend up to a maximum of one year after ROD finalization and will include an analysis of the data against the following two contingency criteria. These two specific contingencies identified are 1) to evaluate the need to reactivate the Princeton Avenue IRA if tritium concentrations exceed 25,000pCi/l at the Chilled Water Plant Road, and/or 2) reactivate the Princeton Avenue IRA if tritium concentrations exceed 20,000 pCi/l at Weaver Drive.
A third contingency was developed to ensure that if the most concentrated part of the plume were to act as a source of continuing contamination, active remediation would remove this problem. This contingency proposed a low flow extraction system to be installed in the most concentrated area of tritium contamination near the HFBR and activated if concentrations exceed 2,000,000 pCi/l at the front of the reactor. This system then would be used to remove groundwater containing the highest concentrations of tritium from the aquifer. The extracted tritium contaminated water will be disposed of offsite. Technologies to reduce the volume of water that requires off-site disposal may be identified during design. Since the PRAP was issued to the public, groundwater near the HFBR has exceeded 2,000,000 pCi/l. DOE is currently in the process of constructing some of the wells for this low flow extraction system on Cornell Avenue and developing plans to extract the most concentrated part of the plume in front of the HFBR. The detailed operational parameters for this system will be developed during design.
In addition to the ones originally identified in Alternative T4 and proposed in the PRAP, a fourth contingency, an additional low flow extraction system will be installed and operated near Temple Place. This additional system was added in response to regulatory concerns about potential plume migration. The exact location, operational parameters and treatment and disposal options for the extracted water will be developed during design. Operation of the Temple Place extraction system will continue for up to one year. As these extraction wells operate, extensive monitoring will occur to evaluate the effect of extraction locally, as well as on the entire plume. Because of the inherent uncertainties of predicating plume behavior based on groundwater modeling, the actual monitoring data will be evaluated and used to help determine whether continued operation of this extraction system is needed to achieve the cleanup objectives. The criteria to continue system operation beyond one year will be developed during design and based on the attainment of the cleanup objectives.
There are concentrated areas of strontium-90 contamination in the groundwater at three on-site locations; the Chemical Holes area, the Brookhaven Graphic Research Reactor (BGRR) Pile Fan Sump Area, and the Waste Concentration Facility. Strontium-90 is a radioactive element with a half-life of 29.1 years.
The selected remedy, alternative S5a, involves installing extraction wells and using ion exchange to remove the strontium-90 from the extracted water. Residual waste from the treatment process that contains strontium-90 will be disposed of at a licensed facility off-site.
Level of Community Support for the Preferred Alternative
From the comments received during the public-comment period, DOE and BNL believe that the public and local elected officials are in general agreement with the selected remedial alternatives.
Community members had the opportunity early in the process to discuss their concerns directly with the BNL and DOE project managers (BNL, 1998). Some of their input was incorporated into the Feasibility Study. For example, stakeholders requested consideration of an option that would complete VOC cleanup faster (in approximately ten years). This alternative was added to the list of those evaluated in the Feasibility Study. Concern was also expressed about the impact of VOCs on the Carmans River, and additional groundwater modeling was done and a new cleanup alternative developed which included possible treatment systems for the western low-level VOC plume.
During the sixty-day comment period, 28 written comments were received on the OU III documents. The majority of them focused on general concerns, such as the length of time required for cleanup, the length of the comment period, the volume and complexity of material, and the issue of property value. Concern was also voiced about the limited characterization of groundwater in the Magothy Aquifer and the potential for human exposures to VOCs transferred to air in the VOC air stripping and in-well stripping treatment processes. Several commentors wanted more specific information on the location of treatment wells and on the location and frequency of monitoring. There was some concern about using natural attenuation as part of the remedy, and some people felt that more active treatment in a shorter time should be undertaken. Several commentors also requested more detailed information on performance standards for the proposed treatment systems.
The modest number of comments received may reflect the level of outreach that has been undertaken by BNL and DOE. Over 2,300 people are on the ERD mailing list, and they receive the newsletter cleanupdate along with frequent mailings about specific remediation activities. Invitations to roundtables, information sessions or public meetings are often included in the mailings. BNL employees and retirees (a combined total of nearly 5,000) also receive cleanupdate and articles in the Brookhaven Bulletin which update them on specific remediation topics. The recently formed Community Advisory Council and the new Community Involvement Plan are avenues for stakeholder groups to have access to BNL and DOE management and to learn about BNL. While the public continues to be concerned about the contamination that BNL caused and is interested in tracking the progress of cleanup, trust appears to be growing that the contamination is being addressed appropriately.
Changes to the Proposed Alternatives
In response to requests by stakeholders, the comment period was extended an additional 30 days.
The following modifications were made to the preferred remedial alternative based on regulators' and the public's concerns and input include:
2. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
BNL is located in Brookhaven Town at the geographic center of Suffolk County, which encompasses the central and eastern part of Long Island. With a population of approximately 430,000, Brookhaven Town accounts for about sixteen percent of Long Island's 2.6 million residents. Suffolk County is operated by a county executive and an 18-member legislature. Brookhaven Town employs a town council (six at-large councilors) and a supervisor. Both governments maintain professional planning, development and environment departments, plus planning boards.
Many villages and hamlets dot Brookhaven Town's 260 square miles, and BNL is surrounded by the unincorporated communities of Yaphank, East Yaphank, Ridge, Middle Island, and Manorville. Most of these villages and hamlets have citizen-run civic- or taxpayer-organizations with large, active memberships. Most organizations join one or both of the area's two umbrella civic groups, Affiliated Brookhaven Civic Organization, and the Longwood Alliance. These same communities support service clubs, which represent the businesses, churches, and other aligned interests within the community.
The town of Riverhead is another Suffolk County town where BNL's activities generate interest. Located to the east of BNL beyond the Town of Brookhaven, it has a population of about 24,500 and an area of about 60 square miles of which 41 percent is farmed. Riverhead employs a supervisor-town council government, which maintains professional planning, development and environment departments, plus a planning board.
History of Community Involvement
Historically, public involvement in BNL's environmental restoration activities was low, but after a Community Relations program was established in 1991, public interest and contact with BNL increased. Two major "events" spiked public interest in the Laboratory restoration activities. First, the free public-water hookups offered to residents directly south of BNL in January, 1996 prompted over 700 people to attend a public meeting. Second, the identification of a leak in the spent-fuel pool of the High Flux Beam Reactor brought significant media attention and stakeholder concern. Interaction with the community has been a major focus of BNL's administration and employees. Surveys of employees and the community have provided a baseline of information on the status of community relations and revealed avenues for improving them: these avenues are being actively pursued.
Laboratory-wide, several new venues for community involvement were established. BNL employees now can join an "Envoy" program and represent BNL in community groups to which they already belong. The BNL Speaker's Bureau was re-instituted and employees are going out into the community and speaking on a wide variety of topics. An independent Community Advisory Council, composed of representatives of established stakeholders' groups on Long Island, BNL employees, and several other individuals, meets monthly to learn about and discuss Laboratory issues and to offer recommendations to BNL's Director. A new "Community Involvement Plan" was jointly developed by community members, BNL's staff and the Department of Energy in April, 1999. The plan provides a framework for involving the community in decision-making at the Laboratory.
Established venues for exchanging information continue. The Brookhaven Executive Roundtable (BER), established in August 1997, is composed of elected officials (or their representatives), regulators, and the Suffolk County Water Authority. Community members routinely attend the monthly meetings and an opportunity for public comment is available at each meeting. The BER was created to facilitate and expedite the flow of information from BNL to some of its key stakeholders on significant environmental, operational, regulatory, and oversight issues. It has been very successful by providing up-to-date information (background, status, steps forward) and doing so early in the process.
Community-relations activities concerning the Environmental Restoration Division (ERD) have echoed the new emphasis on community involvement at the decision-making level. Ten roundtables and workshops were conducted to solicit input on groundwater remediation and sampling of the Peconic River before the final remedies or plans were selected. To emphasize the importance of environmental issues, BNL's Director scheduled an "Environmental Fair Day" in the fall of 1998 which 3,600 community members attended, including many families with children. Volunteers from ERD sponsored a "photo opportunity" for children (and adults) to have their photo taken on a huge drill rig, staffed a display about each of the Operable Units, and led tours of remediation sites.
The goals of the community relations program have been, and are, the following:
A Community Relations Plan was finalized for the BNL CERCLA activities in September 1991. In accordance with this plan and CERCLA Section 113 (k) (2)(B)(I-v) and 117, the community relations program focused on public information and involvement. A variety of activities were used to provide information and to seek public participation, including the following:
Longwood Public Library
800 Middle Country Road
Middle Island, NY 11953
301 William Floyd Parkway
Shirley, NY 11967
Brookhaven National Laboratory
Upton, NY 11973
The Administrative Record also is maintained at the EPA's Region II Administrative Records Room at 290 Broadway, New York, New York 10001-1866.
Summary of Community Participation Activities
There were five major areas of community-relations activities for OU III:
Section 4 gives a chronology of the major community-relations activities for each of the above areas. A Community Relations Plan was developed for Operable Unit III and for the OU III Off-site Groundwater Removal Action.
Removal Action V / Operable Unit I Groundwater Removal Action and Operable Units I and III Public-Water Hookups
A public notice was published for review of and comment on the "Engineering Evaluation/Cost Analysis" (EE/CA). The 30-day public comment period for this document began on January 2, 1996 and, as a result of requests from the community, was extended twice, ending on March 18, 1996. The January 16, 1996 public meeting also was announced in the public notice. Summary sheets were sent to the people on the stakeholder mailing list.
A public meeting was held on January 16, 1996 at BNL to discuss the findings of the OU I EE/CA; approximately 700 people attended. A press release was issued titled "U.S. Department of Energy Offers Public Water Hookups to Residences Just South of Brookhaven Lab".
An announcement of the extension of the public comment period was sent to the mailing list. A presentation to the Community Work Group about the public-water hookups and a briefing on the "Groundwater EE/CA" was held at BNL. An on-site briefing on the proposed groundwater treatment plant was given to the staff of the National Weather Service.
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 offered to BNL employees on issues regarding Operable Unit I groundwater. Also, four fact sheets on this project were distributed, as well as articles in six editions of the Brookhaven Bulletin (between February and March 1996). Several letters were received from the community and responded to by DOE.
HFBR Tritium Remediation Project
On January 18, 1997, the U.S. Department of Energy (DOE) and Brookhaven National Laboratory (BNL) announced that routine monitoring had identified tritium concentrations exceeding the drinking water standard in groundwater at the center of the Laboratory site, just south of BNL's High Flux Beam Reactor. This announcement, in combination with previously discovered groundwater contamination by volatile organic chemicals, led to a lack of public confidence in the Laboratory's commitment to public health and safety and the protection of the environment.
In response to this public concern, DOE and BNL actively sought and received feedback from stakeholders, and responded to the media to ensure that accurate information was disseminated in a timely and consistent manner. The following community outreach activities took place:
January - June 1997: To understand the community's concerns and to keep people informed, Community Relations representatives and subject-matter experts attended meetings of civic associations that surround BNL. Approximately 50 presentations and updates on tritium were given from January through June. In addition, presentations were given to numerous elected officials, regulators, environmental committees, Rotary clubs and chamber-of-commerce groups.
The community-at-large received two mailings that included a briefing page and a letter, and a question and answer fact sheet about tritium and letter. Five information / poster sessions were held in the surrounding area, including one at BNL for employees. These provided stakeholders the opportunity to interact one-on-one with BNL management and subject matter experts so that BNL would be aware of the concerns of the community and could answer questions. All information sessions were advertised in local newspapers and in businesses, and announcement posters were sent to all Suffolk County libraries. Community Relations personnel visited local businesses to respond to their concerns.
Two input sessions were held to gather feedback from community leaders on the tritium remediation proposal, and briefings were conducted with regulators for input on the final discussion and approval of pump-and-recharge and public communication and involvement.
August - November 1997: A community involvement plan, "Deciding the Future of HFBR--Outreach, Involvement and Independent Verification Plan," was distributed to the community for comments. The plan outlined outreach and involvement activities in which BNL/DOE would participate to keep the community informed and involved in the decision regarding the HFBR.
Four information / poster sessions were held, and four roundtables with civic groups, interested individuals, and special interest groups were conducted to get feedback from stakeholders. Numerous presentations were given to the Brookhaven Executive Roundtable, elected officials, regulators, civics, chambers of commerce, and Rotarians. The High Flux Beam Reactor was opened to the public during Community Day and Family Day, as well as for numerous tours for interested groups and individuals. Over 900 people visited the facility.
Feedback on whether or not to restart the reactor was gathered from throughout the community and included in a "scrapbook" that was forwarded to Secretary of Energy Federico Pena. Once it was decided that an Environmental Impact Statement should be completed on the HFBR, information on this process was included in all outreach activities.
Superfund Activities: When the tritium remediation project was phased into BNL's Superfund activities, an Action Memorandum describing the pump-and-recharge system was issued. This Action Memorandum included a public notice, a newspaper advertisement, fact sheets and a community letter.
Three issues of the Office of Environmental Restoration's newsletter cleanupdate included information on tritium remediation. Two information / poster sessions (mentioned above) were conducted. In addition, a tritium-remediation poster was included and subject-matter expert attended all subsequent information sessions / poster sessions held on the HFBR, and at the Accelerated Cleanup 2006 poster session in July 1997.
Well over a dozen tours of the monitoring-well areas and remediation system were given to community groups.
Media Relations: Between January and December, 1997, media relations issued approximately 40 press releases on the tritium remediation project. Personnel from Public Affairs and Community Relations informed stakeholders before distributing these releases in order to maintain an open dialogue.
Approximately six press conferences/media availabilities, and approximately 1000 media requests were coordinated and handled. Briefing pages and fact sheets were written. Over 250 calls from concerned citizens were answered.
Internal Communications: Between January and December, 1997, employees were kept up-to-date on tritium remediation activities and related newsworthy developments through articles in the Bulletin, board displays, e-mails, and news briefs via Laboratory mail.
The most concentrated effort to communicate with employees took place between March and April, 1997. During March, representatives of all on-site groups were contacted to prepare for employee information meetings that were then held during April. Twenty-three employee information meetings were held. An HFBR Tritium Information Center was set up as a space for all employees to obtain answers to questions and receive the latest updates on the issues.
OU III Off-site Groundwater Removal Action
A community-relations plan for this removal action was prepared by the community relations staff in the Environmental Restoration Division and submitted to the DOE in March 1998.
Activities for the OU III Off-site Removal Action focused on informing stakeholders (the public and BNL employees) about the proposed construction of a groundwater treatment system in an industrial park south of the Laboratory.
The "Pre-Design Report for OU III Off-Site Removal Action" was entered into the Administrative Record on February 20, 1998. On June 24, 1998, the Final Action Memorandum for Operable Unit III Off-Site Groundwater Removal Action was entered into the Administrative Record.
An article in the January 1998 issue of the newsletter cleanupdate detailed the proposed cleanup technology. An update on progress of the construction was published in the May 1998 and the December 1998 issues.
The Project Manager for OU III Off-Site Groundwater Removal Action gave a presentation about the removal action to the Brookhaven Executive Roundtable in January, 1998, and elected officials were briefed during March 1998.
A mailing was sent to the people on the stakeholder mailing list and one to the tenants of the industrial park where the system was to be constructed. These mailings invited stakeholders to attend information/poster sessions to learn about the treatment system and included a fact sheet. Advertisements of the poster sessions were placed in local papers, and a BNL press release was issued. Twenty-two homes near the construction area were visited to be certain they knew about the poster sessions and the impending construction. Three poster sessions were held in early April--two in a local school and one at BNL; attendance at the poster sessions was very low.
Early Community Input on OU III Cleanup Alternatives
In the late summer and fall of 1998 BNL sought community input on the cleanup options being considered for groundwater contamination (BNL, 1998). The August 1998 issue of the newsletter cleanupdate featured an article titled "Lab to seek input from area residents on cleanup options" which detailed these cleanup options. Three approaches for gathering community input were used: roundtables, canvassing, and a workshop.
Four roundtables were held between August 25 and October 7 to which were invited key stakeholders and residents of the area directly south of the Laboratory, BNL employees, businesses, and local environmental groups such as "Trout Unlimited", which has "adopted" the nearby Carmans River. Twenty-four stakeholders in all attended the roundtables. Before the meetings, a fact sheet describing the contamination and the options being considered was mailed to each attendee. At the roundtables, OU III project managers introduced the cleanup options being considered. A question and answer period followed, during which the stakeholders were asked for input.
Canvassing was conducted of those people living south of the Laboratory in the area where groundwater treatment systems could be placed. One hundred and seventy residents were called--152 were reached on the phone. Sixty-nine were willing to provide input in some way--immediately on the phone, by attending a roundtable or the workshop, or by mailing comments back after receiving a fact sheet. Follow-up visits to gather their input were made to the homes of the 48 residents who were sent a fact sheet.
An update was provided to the Brookhaven Executive Roundtable on the Early Input initiative in September, 1998.
A Community Information Workshop was held on October 22, 1998. The workshop was advertised in local newspapers (Suffolk Life and Pennysaver), a flyer was mailed to the stakeholder mailing list and to 1,100 homes located south of the Laboratory. The meeting also was announced at three local civic organization meetings, and listed in the local school district PTA calendar. A presentation on the cleanup options was made by the OU III Project Manager followed by a question and answer period, and technical staff was available to explain posters, which detailed the cleanup options. Twenty-seven members of the public attended. Community input was gathered through comment cards left at the meeting or mailed in, and by recording the questions asked during the session.
An article in the December 1998 issue of the newsletter cleanupdate detailed both the process and the input gathered.
OU III Remedial Investigation/Risk Assessment Report, Feasibility Study and Proposed Plan
The Operable Unit III Remedial Investigation/Risk Assessment Report, Feasibility Study and Proposed Plan were released for public comment on March 1, 1999. A Public Notice and a display advertisement appeared in Newsday and in Suffolk Life. A mailing was sent to the stakeholder mailing list and to 1,100 homes south of the Laboratory containing a cover letter, fact sheets on the remedial investigation and on the feasibility study, and a complete copy of the Proposed Plan. A DOE press release announcing the beginning of the comment period was distributed to media contacts.
Several avenues were made available to the public and to employees for learning about the documents and commenting on them. The Executive Summary of the Remedial Investigation, the Executive Summary of the Feasibility Study, and the entire Proposed Plan were put on the ERD internet web page, and comments could be entered via e-mail.
The Brookhaven Executive Roundtable had a presentation on OU III tritium groundwater monitoring and project status in January 1999. The Community Advisory Council made OU III the only topic of their April 8, 1999 meeting. Eight civic associations were updated on the OU III meeting schedule, and questions from those attending the meetings were answered. Individual community members were briefed on request.
Elected officials were briefed in a letter in February. BNL and DOE representatives briefed the staffs of Congressman Forbes and Senators Schumer and Moynihan in March. An article about the OU III cleanup plan was printed in the Brookhaven Bulletin on March 5, 1999. The article included details about how employees could obtain a copy of the Proposed Plan and comment on the proposed remedy.
Three information/poster sessions were held: one lunchtime and one evening session at BNL and one evening session at the local high school. Laboratory-wide e-mails were sent out to remind employees of the dates for the poster sessions and the public meeting. Display advertisements, which detailed poster session and public meeting dates and gave the phone number to call for additional information were published in local newspapers.
The public meeting on OU III was held in Berkner Hall at BNL on March 24, 1999. One hundred and twelve people attended the poster sessions and/or the public meeting, including members of the public and BNL employees.
Following a request from several members of the public, the public-comment period was extended by thirty days, through April 30, 1999. An advertisement to this effect was placed in Newsday on March 31, 1999. The announcement was also made on the front page of the mailing about Operable Unit I which was sent to the stakeholder mailing list and to all BNL employees on March 31, 1999.
3. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, AND CONCERNS AND DOE RESPONSES
Several written questions and comments were received and others were made during the public meetings that did not relate to the proposed cleanup action that is the subject of this Record of Decision. These comments were addressed by the panel at the public meeting, and are being followed up through community meetings. Only those questions and comments directly related to the OU III proposed remedial action are addressed in this Responsiveness Summary (RS).
Written comments and questions on the preferred remedy, and the OU III RI/FS received during the public-comment period and oral comments made during the public meeting are summarized and addressed below. The format of this RS combines similar questions or comments from different sources for a common response. The written comments are reproduced in Appendix A. A copy of the transcript of the public meeting is available in the Administrative Record.
Summary and Response to Questions and Comments
Questions and Comments
1. Cleanup Objectives
1a. It is incumbent on DOE, the Laboratory and the State to do everything possible and reasonable to accelerate the cleanup of contamination. The treatment wells could be installed more rapidly than the plan anticipates.
BNL and DOE would like to implement the remedy faster than the plan indicates (2-5 years). Accordingly, BNL will try to do this, and will begin installing treatment systems in the highest priority areas first.
1b. As groundwater assessments proceed and improved technologies become available, bolder strategies should be considered or adopted.
The remedy will be periodically evaluated, and may be modified if new technologies become available. Should new information become available on the cost-effectiveness of new technologies during the remedial design or remedial action that could affect how the selected remedy is implemented, it may be modified and documented if the change does not constitute a fundamental change in the remedy.
1c. The remedies should meet drinking water standards in groundwater for volatile organic compounds, strontium-90, and tritium in a timely manner.
BNL plans to meet drinking water standards in a timely manner. The following are the cleanup objectives for Operable Unit III:
1d. The cleanup goals must seek to achieve the lowest contaminant levels attainable. If groundwater can be cleaned up beyond relevant standards it must be. A cleanup goal other than MCLs, such as the Maximum Contaminant Levels Goals (MCLGs) should be considered.
The cleanup goal is to achieve Maximum Contaminant Levels (MCLs) within 30 years in the Upper Glacial Aquifer. The achievement of MCLs will be confirmed through extensive groundwater monitoring. Once MCLs are met, natural attenuation will continue to reduce contaminant concentrations to levels that are below drinking water standards.
State and Federal Maximum Contaminant Levels (MCLs) were identified as relevant and appropriate to groundwater in OU III. The NYSDEC groundwater standards set forth standards based on the classification of the water body. Groundwater in OU III is classified as Class GA (fresh groundwaters). The Federal maximum contaminant levels (MCLs) in 40 CFR 141 (primary MCLs) and 40 CFR 143 (secondary MCLs) are promulgated standards applicable to public water systems. The stricter of the Federal and State standards were identified as appropriate cleanup goals for OU III groundwater.
1e. The statement that the proposed remedy restores the contaminated aquifer "as a source of drinking water" is misleading, since such areas are unlikely to ever again be used for potable purposes.
The statement was meant to convey that the goal is to restore the aquifer to drinking water standards.
1f. What specific VOCs were found in the Magothy aquifer? What was their concentration and at what depth were they found? Do concentrations in the Magothy exceed drinking water standards?
The VOCs found in the Magothy aquifer above the drinking water standard off-site in the OU III groundwater plume were carbon tetrachloride at 7090 ppb, chloroform at 45 ppb, and trichlorothene (TCE) at 30 ppb. These data are from the 1998 and 1999 sampling of an off-site monitoring well located 275 to 285 feet below land surface within the Magothy Aquifer that was sampled as part of our going groundwater monitoring program. The depth of the monitoring well is 275 to 285 feet below land surface (approximately 187 to 197 feet below mean sea level). The data reported in the OU III Remedial Investigation report which was collected in 1996 showed carbon tetrachloride from the same monitoring well at 970 ppb, chloroform at 15 ppb, and trichloroethene at 19 ppb. These data represent the highest concentrations of VOCs in the Magothy in the OU III groundwater plume. Lower concentrations of other volatile organic compounds have also been detected in the Magothy Aquifer. Additional characterization of the Magothy is planned.
1g. The proposed plan is completely inadequate and unacceptable with respect to protection and remediation of the Magothy Aquifer. Has an analysis of remedial alternatives been done? How long will it take to meet Remedial Action Objectives (RAOs)? A complete delineation of all plumes affecting the Magothy should be determined, including full lateral, vertical and downgradient extent. It is unreasonable to seek informed public opinion in the absence of relevant information.
The Remedial Investigation primarily focused on the Upper Glacial Aquifer because there was known contamination in the Upper Glacial Aquifer, the water moves much faster in the Upper Glacial Aquifer, and there is a higher potential for surface-water impacts and human exposure to contaminants in groundwater. Any potential exposure to the public from contamination in the Upper Glacial Aquifer was significantly reduced by the public water hookups instituted by DOE in 1996-1998. At present, limited characterization has been performed in the Magothy, so additional characterization and installation of groundwater monitoring wells are planned. This work will be done during the design of the remedy, and will be included in the site records. When this characterization and monitoring is completed, the need for a remedy for the Magothy aquifer, will be evaluated by DOE, EPA, and NYS DEC. If a remedy for the Magothy aquifer is necessary, either this record of Decision will be modified or another decision document will establish the selected action. In either case, the public will have an opportunity to review and comment in accordance with CERCLA. The on-site treatment system planned for the Middle road will prevent further migration of contaminants to the Magothy aquifer.
1h. The statement that the industrial groundwater treatment system "will address further migration of the highest concentrations of the deep VOC plume" ignores the presence of high concentrations (4,180 ppb) of carbon tetrachloride in the upper Magothy south of BNL in well 000-130 at 205 feet below MSL. The extent of this contamination, and the need for remediation, still need to be determined.
The statement in the PRAP refers to the deep VOC plume in the Upper Glacial Aquifer. The proposed alternative will prevent migration and further contamination of the deeper Magothy Aquifer. As discussed in response 1g above, additional characterization of the Magothy aquifer is planned. Based on this new information the need for a remedy for the Magothy aquifer will be evaluated.
1i. Sixty years is far too long a time to wait for cleanup of the Magothy. Either further analysis of potential cleanup strategies for the Magothy layer should be performed or a more complete evaluation of why such strategies have been rejected should be provided. The record should be kept open on the issue of Magothy remediation so that there can be comment by the public.
Because of limited characterization, no remedy or time frame for the Magothy aquifer is being chosen at this time. One of our main objectives for the Magothy is to minimize plume growth through treatment systems located at Building 96 and at Middle Road. The treatment system to be constructed on-site at Middle Road will address an area which has been identified as a major pathway for the Magothy contamination. Additional groundwater monitoring will further evaluate the extent of this contamination. If the results suggest that further actions are required, alternatives for cleanup of the Magothy aquifer will be evaluated, including appropriate time frames.
1j. The Suffolk County Water Authority (SCWA) is concerned about contamination that is present in or may reach the Magothy Aquifer. The SCWA currently operates two shallow Magothy wells at Lambert Avenue, Mastic. We are concerned that these wells may be impacted by groundwater contamination from the BNL site. The SCWA prefers active remediation of Magothy contamination unless it can be demonstrated that the SCWA wells will not be impacted.
A treatment system as part of the proposed remedy will be located on the Middle Road on the Laboratory property. This treatment system will treat the Upper Glacier Aquifer before any contamination can enter the Magothy at this location. The groundwater modeling that was conducted as part of the Feasibility Study modeled the progression of the VOC contamination in the Magothy aquifer for 60 years. The modeling that was performed showed no impact to the SCWA Lambert Avenue supply wells. At present, limited characterization has been performed in the Magothy aquifer, so additional characterization and monitoring well are planned. Upon completion of this characterization and monitoring, the need for a remedy for the Magothy aquifer will be evaluated as discussed above.
1k. Please define what you mean by the time to cleanup.
The time to cleanup is the length of time it takes for the groundwater to meet drinking water standards. It includes the time during which active treatment is carried out, and the time needed for natural attenuation to reduce concentrations to drinking water standards.
1l. Why does it take 30-60 years to clean up the contaminants? The proposal for cleanup of contamination over a 30 year period is unsatisfactory and should be rejected by the EPA, NYSDEC, DOE and local residents. Couldn't it be done more quickly?
The time necessary for cleanup depends on both the concentration of the contaminant, and its mobility in groundwater. For example, strontium-90 is not mobile - it tends to stick to the soil, so extracting it takes longer than extracting VOCs, which are more soluble and mobile in groundwater.
The question of "a quicker cleanup" was raised during the community roundtables last fall. One alternative considered for VOCs was to clean them up in ten years to drinking water standards. This would have required installing approximately 120 treatment systems, which was not a reasonable alternative when all nine EPA decision criteria (which must be considered) were analyzed. The installation of this many treatment wells in the community south of the Laboratory was perceived to be intrusive and disruptive. This view was supported by community comments received during the Early Community Input roundtables held by the Laboratory in the Fall of 1998.
The current technologies available for cleanup make 25-30 years a realistic goal for the Upper Glacial Aquifer. BNL and DOE believe that the proposed alternatives represent the best way to effectively cleanup the groundwater contamination.
1m. The report says that it will take 30 years to complete the cleanup of groundwater. Does that mean the contamination will continue to travel in the groundwater for 30 years? How far will it move? What areas will be monitored during this period?
Even though the groundwater will continue to move at a rate of approximately .75 to 1 foot per day in the Upper Glacial Aquifer not all the groundwater will contain concentrations above the drinking water standards. For example, the majority of cleanup (amount of contaminant mass removed) for VOCs in the Upper Glacial Aquifer will take place in the first 5 to 15 years during the active treatment of the more highly concentrated areas.
The cleanup objective is to meet drinking water standards in groundwater for volatile organic compounds, strontium-90, and tritium. The cleanup objectives for VOCs and strontium-90 will include active treatment for the areas with higher concentrations of contaminants and natural attenuation for areas with lower concentrations that are above the drinking water standards. The groundwater velocity is affected by several parameters, such as geology, gradient, and depth within the aquifer. Even though the groundwater velocity varies from location to location, a useful range for the Upper Glacial Aquifer is about .75 to 1 foot per day.
Many areas will be monitored during the 30 year cleanup period for the Glacial Aquifer, including on-site and off-site locations. The exact location of the monitoring wells will be determined during the design phase.
1n. The Proposed Plan fails to include an analysis of the alternative to install approximately 100 sparging wells that would result in cleanup within 5 years. The residents of the community have the right to have a complete range of alternatives presented to them.
This alternative was included in the initial list developed for remediating VOCs in groundwater. The alternative was screened out early in the Feasibility Study, primarily because community input suggested that this number of wells in a residential area would be intrusive and unacceptable. This decision is documented in the Feasibility Study. The PRAP documents only those alternatives that received a full, detailed evaluation.
1o. Why haven't you done something to cleanup the groundwater yet?
Several actions were taken to remove sources of groundwater contamination. These included removing cesspools and cesspool contents, excavating contaminated soil and piping, removing underground storage tanks, replacing leaking sewer pies, and capping landfills.
In addition, the following seven interim removal actions have been, or are being, undertaken to immediately reduce the concentrations of, migration of and exposure to groundwater contaminants.
1. On-site OU III Southern Boundary Groundwater Interim Removal Action
2. Off-site OU III Industrial Complex Groundwater Interim Removal Action
3. Off-site Public Water Hookup Interim Removal Action
4. Tritium Groundwater Interim Removal Action
5. Building 830 Underground Storage Tanks Removal Action
6. On-site Removal Action V Southern Boundary Groundwater Interim Removal Action
7. Carbon Tetrachloride On-site Groundwater Interim Removal Action
1p. CERCLA includes a strong preference for using treatment as a principal element of any remediation plan. Natural attenuation is not a treatment and therefore should not be utilized as a guiding principle. The proposed plan distinguishes between no action and natural attenuation by including monitoring of the plumes in the natural attenuation alternative. It is misleading to separate these two alternatives; they should be listed as one. The plan relies all too heavily on natural attenuation and not enough on active, aggressive groundwater cleanup. We do not support those aspects of the plan that rely on natural attenuation. It is worth noting that some VOCs degrade into chemicals that are more potent carcinogens than the original contaminant.
DOE separated the "No Action" and "Natural Attenuation with Monitoring" alternatives because CERCLA requires that all evaluated alternatives be compared to a true "No Action" alternative. No action would include the natural attenuation that will take place, but does not include any monitoring.
Natural attenuation is one component of the selected remedy. However, we do agree that it cannot really be considered a "treatment".
Active treatment of the groundwater is part of the selected remedy where it will work. The selected remedy includes treatment by in-well stripping at locations where the concentrations of VOCs in the groundwater are high. In-well stripping or other active treatment technologies cannot efficiently reduce concentrations of VOCs in the aquifer to MCLs. This is the reason that the selected remedy also includes natural attenuation to reduce the concentrations to MCLs after active treatment is no longer effective, and provision of public water to ensure that there is no exposure to people living in the path of the plume.
Vinyl chloride is the degradation product of VOCs that is of most concern in terms of potential risks to human health. It results from the biological degradation of VOCs. BNL has seen no evidence of vinyl chloride in the area impacted by the Laboratory. It is also important to note that no exposure to contaminants nor to their by-products is likely to occur because of the public-water hookups in the area.
1q. The plan's use of the term "cleanup objectives" on page 2 is misleading, since attainment of these objectives relies heavily on natural attenuation for areas not subject to direct cleanup. A better term, which is used in Sections II and VIII, and elsewhere in the text, is "remedial action objective".
BNL and DOE use both terms to mean specific goals to protect human health and the environment. These objectives are based on available standards, such as applicable or relevant and appropriate requirements (ARARs), and risk-based levels established in the risk assessment. These "remedial action objectives" or "cleanup objectives" are independent of the means used to achieve them, which may include active remedies or a reliance on natural attenuation.
1r. BNL and BSA need to have a community forum focused on Superfund education emphasizing natural attenuation as a method of remediation.
As the Superfund process progresses at BNL, the need for continuing community outreach will be evaluated. Information about the cleanup and technologies to remediate groundwater will continue to be presented to the public through mailings, the newsletter cleanupdate, workshops, and information sessions.
1s. Information on the success ratios of the various cleanup processes might be helpful.
Air stripping is a reliable and efficient method of treating contaminated groundwater. Pump- and-treat methods also are reliable ways to remove compounds that partition to the aqueous phase. The OU III Feasibility Study reviewed remedial technologies and outlined the pros and cons of each. Pump-and-treat technologies that are being used to remediate the groundwater contamination along the Laboratory's southern boundary have been shown to be highly effective in removing large amounts of contaminant mass from contaminated groundwater. This information was used to select the preferred alternatives for treating VOCs, tritium and strontium-90 in groundwater.
2. Public Outreach and the Proposed Plan
2a. The 30-day period provided for public comments is insufficient to allow a full review of the massive documentation.
The public comment period was extended by an additional 30 days.
2b. The material is extremely complicated and hard to follow. A better description is needed of the technical terms and abbreviations.
The characterization and remediation of groundwater contamination in Operable Unit III is a complex task. BNL tried to make the material accessible and understandable to the public. Many of the technical terms used in the RI and FS documents are explained in more detail in the PRAP.
2c. The Libraries that hold the Administrative Record are not convenient for me and are not set up for serious research. Why aren't the documents available in the Library at the State University of New York at Stony Brook? Why wouldn't you send me my own copy? You are adhering only the letter of the law here but is seems that you don't really want a serious public review of the document.
The Administrative Record is available in three local libraries: Mastic-Shirley, Longwood, and the Research Library at BNL. Material can be made available at other libraries if the request is made early in the review process. BNL would like to send copies of the documents to everyone who has an interest - but this is not practical considering the amount of material and the costs of copying and distributing it.
2d. The documents are poorly organized and it is hard to find referenced tables and figures.
The OU III Remedial Investigation/Risk Assessment and Feasibility Studies are long, complicated documents. We tried to organize the material in a way that will facilitate the public's review and analysis of them. Specific suggestions for organizing and presenting future documents would be appreciated.
2e. It would help to have a timetable figure for the actions planned for Operable Unit III.
Under the Inter-Agency Agreement, BNL is required to begin construction of the remedy within 15 months after the ROD is signed. After the ROD is approved, BNL will develop a Remedial Design Workplan outlining the timetables for designing the remedy, and a Remedial Action Workplan that will give timetables for implementing it. In general, the plan is to identify areas of highest priority and to address these first, with all treatment systems installed within 3-5 years.
2f. The proposed plan does not have enough detail and should be revised. Another table is needed that lists the work completed and remaining in each AOC and AAI, and to show the results of samples taken after cleanup was completed. The proposed plan should show contours above and below the drinking water standards both on and off-site as well as illustrated estimates of the impact of the various remedial alternatives on the groundwater contamination over time.
The Proposed Plan cannot contain the details of the Remedial Investigation, Risk Assessment and Feasibility Study performed for Operable Unit III. These extensive documents are available for review in the Libraries that hold the Administrative Record. The PRAP was developed to summarize the results of these reports, and present to the community, and to our regulators, DOE's proposed plan for remediating groundwater contamination in OU III. The PRAP is final and cannot be revised. However, the ROD will contain a table that lists the work completed and remaining in each AOC and AAI.
2g. I no longer trust the Laboratory. There should be more public meetings, more public notices, and more information in the news.
Significant efforts have been made during the past year to increase communication with the local communities and provide information on BNL's environmental restoration program. Both DOE and BNL have tried to improve communications with the community and have formally adopted policies of openness over the past few years. Brookhaven National Laboratory's mailing list has been greatly expanded and information and notices of important events are routinely distributed to keep the community up-to-date. Most reports and documents generated by BNL's environmental restoration program are made available for public review, and strong efforts are underway to make this information both understandable and easily available to the public. Publication of the BNL newsletter cleanupdate began in 1996, with a distribution of more than 5000 copies to BNL employees, local residents, the general public, and public officials. BNL's community-relations staff regularly attend local civic association meetings to hear community concerns. Informal roundtables have been held in the community, where local residents can question DOE's and BNL's staff in a friendlier environment; more are planned.
2h. The staffs at BNL and DOE are the experts. Why are you asking for our opinion?
DOE believes that the proposed alternatives represent the best way to remediate contaminated groundwater in OU III. The CERCLA law requires that public input be considered in choosing an alternative. Community acceptance is one of the criteria used in selecting cleanup alternatives. Your input is important in selecting remedial alternatives for OU III. Because of the importance of the remedy and the implications for groundwater quality off-site, DOE would have sought public involvement even if CERCLA did not require this step.
3. Human and Ecological Risk from Contaminants in Air and Groundwater
3a. Why hasn't my water been tested? There should be more testing of our drinking water.
Drinking-water wells south and east of BNL have been extensively tested, both by BNL and by the Suffolk County Department of Health Services. If you want to have your water tested, call the Suffolk County Department of Health Services. Plumes from BNL will not affect homes located north of the Laboratory because the groundwater and any contamination in the groundwater moves from north to south. For people still using private wells in the area south of the laboratory that was connected to public water, BNL will arrange for monitoring at the request of the homeowner.
3b. BNL should provide public-water hookups or bottled water.
BNL provided public-water hookups in the areas south of the Laboratory that may have been affected by groundwater contamination from BNL.
3c. Will BNL extend public water to future residents downgradient of BNL?
BNL will not provide hookups to new developments downgradient of the site. Suffolk County Code requires that new developments with access to water mains be connected to public water. At the request of the homeowner, DOE may provide hookups to new residents in existing homes in the area that already was offered public-water hookups.
3d. Who is responsible for helping to get public water?
Public water in the area near BNL is provided by the Suffolk County Water Authority (SCWA). DOE paid for hookups to public water in the area south and east of the Laboratory that may be affected by groundwater contamination from BNL. The public water hookups were offered as a precautionary and preventative action to try and eliminate potential future exposures through use of private wells.
3e. How do I know the publicly supplied water is safe?
Public water is supplied by the SCWA. This water is tested regularly for a large number of contaminants. The SCWA monitors its wells for organic contaminants on a quarterly basis. The SCWA also monitors for radionuclides, and the frequency of monitoring was increased for wells in the vicinity of BNL to twice per year.
3f. Why should I have to pay for public water? If BNL hadn't contaminated the groundwater, I could have continued to use my private well.
The NYS Department of Health has recommended that homeowners in the area south of the Laboratory connect to the public water supply. This will prevent future exposures to contamination associated from BNL, as well as other contamination from private cesspools and industrial sources. Costs of maintaining a private well and paying for public water are comparable.
3g. The human health risk assessment found that the presence of VOCs in groundwater could present a public health concern to residents south of the Laboratory who have declined publicly supplied water. BNL should immediately supply those homes with on-site water-purification systems and then maintain them.
BNL offered a hookup to public water to residents who may be affected by VOC contamination from BNL. The characterization of the plumes of VOCs coming from the BNL property indicates that they are deeper in the Upper Glacial Aquifer than the depth of the typical private well. The public water hookups were offered to ensure that no exposure would occur in the future. BNL will not provide water purification systems. Residents concerned about the quality of their drinking water should be hooked up to the public water supply system. Residents who maintain a private well should have their drinking water tested periodically.
DOE and BNL also are concerned about homeowners who did not know about the offer to hookup their homes to public water, and new homeowners moving into the area. DOE will consider expanding its hookup program to include these people.
3h. The vertical depth of contamination in the plumes containing VOCs, tritium and strontium-90 is not consistently described. To understand the adequacy of methods for remediation, the vertical and horizontal extent of the plumes should be known. It would be best to have the description given in terms of both depth below land surface and depth below the water table.
The vertical and horizontal extents of the plumes are given in more detail in the Remedial Investigation Report (RI) for Operable Unit III. In the RI, there are tables that show sample locations in terms of both Below Mean Sea Level (BMSL) and/or Below Land Surface (BLS). Plume maps are always given in units of BMSL. We know that this can be difficult to understand, but it is standard practice. In future documents, we will try to provide additional information to help visualize contaminant plumes in terms of depth below land surface.
3i. How long has the VOC contamination from BNL been off-site?
Data from groundwater monitoring of off-site wells show that the high concentrations of solvents (above approximately 1,000 ppb) started to reach Carleton Drive over the last two to three years. From the current southern extent of contaminant migration from BNL and average groundwater-flow rates, we estimated that the low concentrations of solvents (above drinking water standards) may have migrated beneath Carleton Drive approximately thirteen to twenty years ago. Along Sleepy Hollow Drive, high concentrations of solvents have been offsite for 15-20 years and are now located near Strather Drive at a depth of approximately 200 feet. Low concentrations are beginning to reach Crestwood Drive and are estimated to have been off-site for 35-40 years. Further east, beneath the undeveloped property, moderate solvent concentrations have been off-site for approximately 10 years. Because the contamination is deep in the Glacial Aquifer before it reaches the BNL site boundary, we do not believe that people off-site have been exposed to this contamination.
3j. The public-water hookups will prevent future exposure to VOCs in groundwater. What about exposures to contaminants that occurred before BNL provided public water?
The characterization of the plumes of VOCs coming from the BNL property indicate that they are deeper in the Glacial Aquifer than the depth of the typical private well. We believe that residents south of BNL were not exposed to VOCs from BNL in their drinking water. The public water hookups were offered to ensure that no exposure would occur in the future.
3k. I can't make sense of the contour maps. I want to know what the levels in groundwater are near my house, and whether I am being exposed to these contaminants.
Contour maps can be difficult to interpret, but they are the best way to represent the concentrations of contaminants in the aquifer. The Remedial Investigation report contains more detailed maps and tables to help you interpret these data and locate your house.
3l. The Proposed Plan should detail the results and significance of any soil gas testing to evaluate the potential off-gassing of VOCs from contaminant source or plume areas. The potential for accumulation of such vapors in basements or within structures should be reviewed.
Under the right conditions of a solvent product floating on the shallow water table (such as in a gasoline spill), migration of contaminants in the soil and to the ground surface would be likely. However, this is not the case for BNL related VOC contamination in off-site groundwater. There is no floating product and the higher concentrations of solvents are located in the deep aquifer. The upward migration of solvents in the gas phase is further restricted because the aquifer above the contamination acts as a barrier. Because of these considerations, soil gas testing has not been done off-site.
3m. The impacts of releasing contamination from on-site stripping operations must be further examined. There must be an analysis of pathways of airborne contaminants to humans and the environment before the plan is approved. Air stripping is not adequately protective of the environment, nor does it comply with the third cleanup objective stated in the public comment information document - prevention and minimization of further migration of contaminants. Local agencies and private entities generally use granulated activated carbon filter towers to remove VOC contamination. There must be carbon filters on all systems.
Emissions from existing OU III on-site stripping operations are below New York State air emissions standards and BNL permits. These standards were developed by considering potential pathways of exposure to humans and the environment, and are considered safe levels of release. The BNL permits take into account the cumulative effect of all BNL permitted operational emissions. Many air-stripping operations on Long Island are operating without carbon filters. New on-site systems will be evaluated on a case-by-case basis to determine whether carbon filters will be needed. All off-site systems will have a closed loop design and will include carbon filters.
3n. I'm worried about my health. I need better information on the health effects of the contaminants.
The DOE and BNL understand the deep concern that people have for their health and that of their children. This is the reason that DOE took the precaution of connecting residents in the area south of BNL to public water.
The Agency for Toxic Substances and Disease Registry (ATSDR) is completing a groundwater public-health consultation. As an independent agency, ATSDR will be looking at environmental contamination and potential pathways of exposure, and addressing community concerns.
Government and private-sector scientific and medical organizations have generated substantial amounts of information and many studies of the characteristics and health effects of the chemicals of concern in BNL's Environmental Restoration Program.
The following is information to assist community members in learning more about the possible health and environmental effects of the chemicals of concern in BNL's cleanup. Five of the contacts are County, State, and Federal government agencies involved in public-health administration. Three of the contacts are databases (two governmental, one private).
Resources for scientific and health information on chemicals and radionuclides include:
1) ATSDR Public Health Statements
Agency for Toxic Substances and Disease Registry
Division of Toxicology
1600 Clifton Road, NE, Mail Stop E-29
Atlanta, GA 30333
Phone: (404) 639-6000, Fax: (404) 639-6315
Internet address: http://www.atsdr.cdc.gov/
2) The Centers for Disease Control and Prevention
1600 Clifton Road, NE
Atlanta, Ga 30333
Phone: (404) 639-1623
Internet address: http://www.cdc.gov/
3) U.S. Environmental Protection Agency
Public Information Center, 3404
401 M Street, SW
Washington, DC 20460
Phone: (202) 260-2080
E-mail address: firstname.lastname@example.org or email@example.com
4) Suffolk County Department of Health Services
Bureau of Drinking Water
225 Rabro Drive
Hauppauge, NY 11788
Phone: (516) 853-3092
5) New York State Department of Health/Bureau of Toxic Substance Assessment
2 University Place
Albany, NY 12203
Phone: (800) 458-1158 ext.373 for Chemical Selection
6) Several databases available, and some of these are listed below. You can access the information by calling the source directly. Many local libraries and/or universities have the databases available for the general public.
a. IRIS (Integrated Risk Information System)
U.S. EPA Environmental Health and Safety Series, 1995
Public Information Center, 3404
401 M Street, SW
Washington, DC 20460
Phone: (202) 260-2080
E-mail address: firstname.lastname@example.org or email@example.com
b. HSDB (Hazardous Substances Databank)
Produced by the National Library of Medicine
8600 Rockville Pike
Bethesda, MD 20894
Phone: 800-272-4787 or (301) 496-6308
Internet address: http://www.nlm.nih.gov
c. CHRIS (Chemical Hazard Response Information System)
Produced by the U.S. Coast Guard (Hazardous Materials Branch, Office of Marine Safety)
U.S. Coast Guard
2100 Second St. SW
Washington, DC 20593
Phone: (202) 267-1577
3o. The proposed plan by BNL should address the new findings on low level radiation damage to DNA recently discovered by researchers at Columbia University's College of Physicians and Surgeons. Their findings were reported in the last issue of the Proceedings of the National Academy of Sciences. This study may be especially relevant for exposure through inhalation and ingestion, common pathways for radiation exposure originating at Brookhaven.
There is no current pathway for exposure to radionuclides in groundwater from BNL. Hookup of nearby offsite residents to the public-water supply will ensure that there is no future exposure. On-site groundwater contamination will be remediated to below drinking water standards. Many studies have been published discussing the effects of exposure to low level radiation. EPA and other agencies are continuously evaluating these studies and using them to update the dose-response functions that must be used in assessing potential risks at Superfund sites.
3p. The description of the risk assessment is superficial. A more detailed description including discussion of the conservative nature of the risk assessment might alleviate concerns about the credibility of the analysis.
A more detailed description of the risk assessment is given in the RI/RA Report for Operable Unit III. The PRAP is a summary document and cannot provide the entire risk assessment. The process used in the risk assessment is proscribed by EPA, and gives a conservative estimate of the risks associated with contamination in OU III. The conservative, or worst-case assumptions, included in the risk assessment include the land scenarios (e.g., future on-site residential use), exposure concentrations (mean or maximum levels over a lifetime), other standard exposure parameters (e.g. 2 liters/day drinking water), and the EPA's toxicity factors that include safety factors and other conservatisms.
3q. How will the VOC plume affect the New York State Department of Transportation's recharge basins located along the Long Island Expressway? We are concerned about potential health hazards for workers, as well as effects on wildlife, particularly the tiger salamander. Are there any potential impact studies completed for wildlife, and, if not, are they included within the management plan?
The VOC plume associated with BNL is too deep (150-200 feet BLS) to affect the water or sediment concentrations of VOCs in the DOT recharge basins. Consequently, there is no pathway for exposure to workers or to wildlife. Any hydraulic effects of the DOT recharge basins on the plume will be considered during design and construction of the remediation systems. Additionally, DOE will ensure that there are no short term effects on the DOT basins resulting from construction of the remediation systems.
The Remedial Investigation /Risk Assessment for OU III included an ecological risk assessment for the site. This analysis concluded that the only potential risk to on-site wildlife is from metals and PAHs in recharge basins, but that the benthic community expected to live in these basins is limited due to low water levels, the intermittent presence of water, high temperatures, and low oxygen levels. BNL is preparing a habitat management plan with the New York State Department of Environmental Conservation that will detail the routine maintenance of the on-site recharge basins.
4. Other Sources of Pollution and the Monitoring Plan
4a. Some of the pollution south of BNL comes from a source in the industrial park. BNL seems to be taking responsibility for groundwater contamination for which it is not responsible.
VOC contamination in the shallow Upper Glacial Aquifer south of BNL is from an industrial park and not from the Laboratory. The treatment systems proposed in the PRAP focus only on contamination coming from BNL. However, BNL provided public water to residents south of BNL who may have been be affected by contamination from a source other than BNL. This was to ensure that residents would not be exposed to VOC contamination from any source in the future.
4b. Where does excavated contaminated soil go? I am concerned over the issues of off-site disposal of the resin and soils being removed.
The contaminated soil excavated in OU III is being staged and stored pending shipment off-site later this year. The material will be sent to a licensed disposal facility. For any off-site disposal of CERCLA waste, such as resins from the strontium-90 treatment system, BNL must comply with EPA's Off-Site Policy. This Policy requires that the waste generator (BNL) contact EPA prior to shipment of the waste. EPA will then verify that the licensed disposal facility is in compliance with environmental laws. If acceptable, EPA will then provide approval to ship the waste.
4c. Verification of the cleanup action through monitoring is extremely important. I would like to know the location of the monitoring wells, the frequency of sampling, and how often the data will be reviewed. It is likely that a growing population in Brookhaven Town will cause a significant increase in water withdrawal within the planning horizon of 30-60 years. Therefore, a continued monitoring program of at least four times per year will be necessary to safeguard public health. There should be a clear statement that if contamination levels do not decrease, monitoring will increase and further active treatment will be provided.
We currently monitor the groundwater for all BNL's environmental restoration activities, which includes Operable Unit III, in accordance with the existing BNL Environmental Restoration Division Groundwater Monitoring Program Sampling and Analysis Plan. This plan identifies the number of monitoring wells that are sampled for the various plumes within Operable Unit III, the frequency of sampling, and the parameters analyzed. For most of the Operable Unit III plumes, we perform quarterly monitoring of these wells, but the frequency is certainly subject to change as the plume changes.
For the existing groundwater-treatment systems, we monitor their performance in accordance with the relevant discharge permit and the criteria developed during the design of each remedy. The criteria for how the system is monitored and its effectiveness evaluated is presented in the Operations and Maintenance Manual for each operating system. We typically monitor the system on a daily basis for operational parameters. System performance results are evaluated and submitted to the regulators quarterly at a minimum, and monthly for some systems. A detailed annual report also is prepared and submitted to the regulators which evaluates the system's performance and the effectiveness of its operation.
For the treatment systems that have yet to be installed, and the monitored natural attenuation remedies for Operable Unit III, details of the groundwater monitoring well program will be identified during the design of the project. The design typically includes collection of additional groundwater data in the specific area that is needed to support the detailed design of the system, as well as the associated network of monitoring wells. After the detailed monitoring network is determined, it will be added to the Groundwater Monitoring Program Sampling and Analysis Plan.
4d. A major failing of the entire Superfund process at BNL has been the reliance on groundwater modeling to the detriment of monitoring efforts. Three years ago (1996) the plume investigations discovered contamination in the Magothy Aquifer south of BNL. There has not yet been a major effort to characterize the contamination. Over the three-year time period, the model has been extensively exercised - but the groundwater has not been sampled. Similarly, years after the discovery of off-site contamination, the plume characterization still relies on "vertical profile well" samples to describe most of the plume characteristics. Use of vertical profile wells was quite correctly described as suboptimal in the Remedial Investigation report.
The lack of definition for the monitoring portion of the remedial program seems to be part of the overall lack of enthusiasm for sampling (except when under intense public pressure, as in the initial tritium plume investigation). Other RI/FS studies also have called for plume monitoring - as in the EDB plume resolution of some five years ago. Have reports been issued yet on the monitoring portion of that remediation effort? If so, they certainty have not been extensively publicized, nor were they evident at the Longwood library.
Since monitoring is identified as an important part of the remediation - the one part that actually determines if the remedial effort is working as anticipated - it should be carefully and explicitly spelled out. Locations, parameters, action levels and monitoring frequencies should all be specified. The remedial plan, as specified to date, is flawed absent such information.
BNL and DOE agree that monitoring is an important part of the remediation plan. We do not believe that we have relied too heavily on modeling analysis to the detriment of monitoring. BNL has an extensive monitoring network in place. A large number of geoprobes and vertical profile (both temporary wells) were drilled and sampled as part of the OU III Remedial Investigation. The data from these temporary wells helped determine the location and depth of the permanent monitoring wells. We used these data, along with groundwater modeling to help guide our decisions and formulate questions, not to make any final decisions when actual data would be more useful. The exact location and monitoring frequencies will be developed during the design phase. Monitoring data and additional groundwater modeling will be used to determine when cleanup goals have been reached.
The focus in the RI for OU III was on the Glacial Aquifer because there was known contamination in the Glacial Aquifer, water moves much faster in the Glacial Aquifer and there is a higher potential for surface water impacts, and there is more potential for human exposure to groundwater. Vertical profile wells were used in the initial characterization to help determine the location and depth of permanent wells. We are continuing to monitor the groundwater quality both on- and off-site, and plan additional monitoring and characterization of the Magothy Aquifer.
The EDB plume is being, and will continue to be, monitored. Reports have been submitted to the regulatory agencies. The 1997 BNL ERD Groundwater Monitoring Report presents the CERCLA monitoring data for all the projects, including the EDB plume. This document is available for review in the local libraries. All future annual groundwater monitoring reports will also be made available in the libraries.
5. Effect on Property Values
5a. My property values have been affected by the groundwater contamination from BNL. Brookhaven Town has assessed my property at a higher value than local real estate agents say I can get for my house. BNL should acknowledge the economic impact of the groundwater contamination and compensate homeowners for the reduction in property values.
It is our understanding that property values in the vicinity of BNL have not been affected. In a recent New York Times article (Sunday March 21, 1999), it was indicated that the property values directly south of BNL, in the area most impacted by groundwater contamination, actually increased 4% to 8% in 1998 compared with the previous year (1997). This increase is consistent with property values across Suffolk County. In the long term, the proposed groundwater cleanup efforts and the connections to public water will further benefit neighborhoods near BNL.
6. Remedial Action Alternatives
6a. How does in-well air sparging work?
The technology being implemented in the industrial park is called in-well air stripping. This system uses a groundwater pump and an air stripper tray located in the well vault to pump and treat the VOCs. Air stripping involves exposure of the extracted groundwater containing volatile organic compounds to the air. This allows the volatile components in the water to volatilize into the air stream. If concentrations of contaminants in the air exiting on-site air strippers exceed emissions criteria, the air is treated to remove these contaminants before release. All offsite systems will include a carbon filter.
6b. Once the water is cleaned, what prevents it from becoming contaminated again?
In the industrial park, contaminated water will be removed from the aquifer at depths of 125 to 240 feet. The clean water will be returned to the aquifer at the top of the zone of contaminated groundwater. This system is designed to treat all groundwater within the contaminated zone and the clean water above this area will not be impacted by the operation of this system.
6c. The proposal to use air sparging wells instead of extraction wells in combination with air stripping to remove contamination should be explained in the proposed plan. Extraction wells with air stripping treatment may remove contaminants more effectively by causing their movement towards the extraction well compared to the use of sparging wells which recirculate treated water and promote contaminant dilution within the aquifer.
The pump-and-treat systems were evaluated in detail in the OU III Feasibility Study. Extraction wells would require a recharge basin and an air-stripping tower on-site, and piping to transfer the extracted water to the recharge basin. The off-site area impacted by the VOC plume is in a residential area, and installing a groundwater recovery system piping network would involve disturbing properties and major roadways (i.e. the Long Island Expressway). Property acquisitions and permission would be required to install system components in certain areas. Performance data from the operation of in-well air stripping systems in similar hydrogeologic conditions has shown that they may be more effective at restoring the aquifer than pump-and-treat technology. These were the major reasons that the in-well air stripping systems were chosen. In addition, the effectiveness of the in-well air stripping system in the industrial park will be evaluated before installing other in-well air stripping systems.
6d. The treatment plan for VOCs doesn't go far enough. More air-stripping wells are required along the LIPA right of way, and the line of wells at the Industrial Park should be extended eastward and westward to completely cover the entire plume.
The exact number and placement of air-stripping wells for each location will be determined during the design phase for the remedy. During this step we will evaluate the need for additional wells. The number selected will be that required to meet the cleanup objectives (i.e. achieve MCLs within 30 years for the Glacial Aquifer).
6e. The plan should include the number of air stripping devices that will be utilized at each location, criteria to determine when the air stripper is unable to attain the groundwater standards and what the next step should be to meet standards, and criteria to determine the effectiveness of each treatment system.
Active treatment in the in-well stripping systems will be stopped when groundwater monitoring data show that the system is no longer effective, and concentrations of VOCs in the groundwater are no longer being significantly reduced. Specific decision criteria and performance standards will be developed during the design phase.
The performance goal for groundwater is the remediation of groundwater in OU III to Maximum Contaminant Levels (MCLs) or until monitoring indicates that continued operation of the in-well air stripping systems is not producing significant further reductions in the concentrations of contaminants in groundwater (i.e. until an asymptotic condition with respect to a decrease in contaminant concentrations is approached).
The results of groundwater sampling will be evaluated to predict rates of mass removal and to monitor the system's effectiveness. If monitoring indicates that continued operation of the air-stripping wells is not producing significant further reductions in the concentrations in the contaminants in groundwater, in accordance with the National Contingency Plan (NCP), DOE, NYSDEC and EPA will evaluate whether discontinuance of the remedy is warranted. The criteria for discontinuation will include an evaluation of the operating conditions and parameters as well as a determination that the remedy has attained the feasible limit of contaminant reduction and that further reductions would be impractical.
6f. Brookhaven National Laboratory's goal should be, wherever possible, to use active measures to clean up all groundwater in proposed volatile organic compounds in-well air stripping systems to New York State Drinking Water Standards or better. Complete cleanup of groundwater should be attained for the plumes. The drinking water standard of 5 ppb for VOCs should be the minimum standard accepted.
The selected alternatives will use active in-well air stripping systems to remove contaminants until the treatment systems are no longer effective. The goal is to reach drinking water standards, but we expect that these systems may not be able to reduce concentrations of VOCs all the way to drinking water standards. Natural attenuation will reduce the levels to drinking water standards within 30 years.
6g. Why are you treating the contaminated groundwater at the chemical holes for only five years, while other plumes will be treated for longer periods of time?
The Sr-90 plume at the chemical holes is smaller and requires treatment for a shorter period of time.
6h. How would the barrier work for Sr-90?
A permeable reactive barrier wall would be installed around the higher concentrations of groundwater contamination. The wall would consist of a three-foot thick bed of granular clinoptilolite that extends 1 foot above the water table to 40 feet below the water table surface. As the groundwater flows through the clinoptilolite, strontium will be adsorbed on the bed, and the exiting groundwater will contain less than 8 pCi/l of strontium.
Clinoptilolite is a naturally occurring zeolite mineral that is mined at several sites in the western United States. It is a natural ion-exchange material that exchanges sodium and potassium for the strontium in the groundwater. Clinoptilolite also acts as a molecular sieve, removing strontium by adsorption due to surface charge effects on the interior surfaces of the clinoptilolite micropores. The barrier was not selected to treat the strontium-90 groundwater plumes due to difficulties associated with the installation of a barrier wall near the BGRR and Pile Fan Sump. Also the barrier wall does not reduce the time for contamination to be reduced to below MCLs. The barrier wall traps the strontium-90 in place and holds it in place while it decays to below MCLs.
6i. There should be further discussion of what endpoint contamination levels will be required for the shut-down of the BGRR and WCF pumps as well as the pumps to be located in the chemical holes area.
Active treatment for strontium-90 will be stopped when groundwater monitoring data show that the system is no longer effective, and concentrations of Strontium-90 are no longer being significantly reduced. Specific decision criteria and performance standards will be developed during the design phase. No termination of active treatment will occur until it is approved by DOE, EPA, and the NYS DEC.
The performance goal is the remediation of groundwater in OU III to Maximum Contaminant Levels (MCLs) or until monitoring indicates that continued operation of the treatment systems is not producing significant further reductions in the concentrations of contaminants in groundwater (i.e. until an asymptotic condition with respect to a decrease in contaminant concentrations is approached). If after at least one year of groundwater treatment, concentrations of contaminants in designated monitoring and recovery wells appear to have leveled off, an assessment will be conducted to determine if further operation of the remediation system will yield any significant reductions in the levels of contaminants (i.e. whether an asymptotic condition has been reached). The assessment will consider whether complete and effective source control has been attained, an evaluation of the operating parameters and a determination that the remedy has attained the feasible limit of contaminant reduction.
6j. We are not in support of the Department of Energy's preferred alternative for tritium, T4. First, it appears than alternative T4, while meeting the cleanup objective of thirty years (20-25 years) is less aggressive in cleanup that alternative T5 (15-20 years). Second, it also appears that the cost of implementing T4, although less expensive in capital cost than T5 ($456,000:$853,000) is, overall, more expensive than T5 ($4,890,000: $3,669,000). Thus, it appears that the Department has chosen a more costly and time-consuming cleanup. It would appear prudent and protective to choose the more aggressive T5 alternative. The basis for preferring alternative T4 is unclear. If there is additional information why T4 should be preferred over T5, such information should be provided to the public.
BNL and DOE chose alternative T4 over T5 because it includes a contingency plan that considers uncertainties associated with the behavior of the tritium plume over the next 15-20 years. The cost of the contingency remedies was included in the total cost of the T4 alternative, even though these contingencies may not be activated. The cost of alternative T4 without the contingencies was estimated to be $1,997,000.
6k. The operation of the low-flow extraction system is contingent upon finding greater than 2,000,000 pCi/l at the front of the reactor. It should be indicated whether concentrations less than this are likely to trigger removal contingencies farther downgradient, i.e., 25,000 pCi/l at the Chilled Water Plant Road and/or 20,000 pCi/l at Weaver Drive.
The elements of the proposed tritium remedy address the remedial action objectives including limiting significant plume growth. To achieve this objective, concentration levels that would trigger one or more of the contingencies of the proposed remedy were identified for three transects of the plume (at the HFBR, at the Chilled Water Plant Road (CWPR), and at Weaver Drive). If 2,000,000 pCi/L is exceeded at the HFBR then the low-flow pumping contingency is triggered. If 25,000 pCi/L is exceeded at the CWPR then the evaluation to turn on the interim pump and recharge system is triggered. If 20,000 pCi/L at Weaver Drive is exceeded then the interim pump and recharge restart is triggered. These contingencies are independent of each other so that a concentration less than 2,000,000 pCi/L at the HFBR will not trigger the downgradient contingencies. Concentrations at the downgradient locations would trigger the activities described above at each downgradient location. In addition to the ones originally identified in the PRAP, a fourth contingency, an additional low flow extraction system, will be installed and operated near temple Place. The exact location and operational parameters will be developed during the design.
6l. The statement that "tritium will decay sufficiently to avoid off-site migration" is misleading; tritium contamination from the HFBR will eventually travel off-site, and the timing and ultimate concentration of this contamination need to be stated explicitly.
This statement meant that BNL expects tritium to be well below drinking water standards before it reaches the site boundary. The details of the modeling analysis are given in the RI/RA for OU III. The tritium plume is expected to reach its maximum extent, based on the 1,000 pCi/L concentration, approximately 10 years after the spent fuel pool is emptied. Subsequently, the plume is expected to shrink back towards the source. The furthest downgradient distance that the plume (as defined by the 1,000 pCi/L concentration) is expected to reach at 10 years is half way between Princeton Avenue and the site boundary (1,200 feet north of the site boundary). From decay alone, after traveling to the boundary, the concentration then is expected to be approximately 800 pCi/L and dispersion will reduce this concentration further. Therefore, concentrations of tritium greater than 1000 pCi/l are not expected to ever cross the site boundary. The elements of the selected tritium remedy address the remedial action objectives including limiting significant plume growth. To achieve this objective, concentration levels that would trigger one or more of the contingencies of the proposed remedy were identified for three transects of the plume (at the HFBR, at the Chilled Water Plant Road (CWPR), and at Weaver Drive). If 2,000,000 pCi/L is exceeded at the HFBR then the low-flow pumping contingency is triggered. If 25,000 pCi/L is exceeded at the CWPR then the evaluation to turn on the interim pump and recharge system is triggered. If 20,000 pCi/L at Weaver Drive is exceeded then the interim pump and recharge restart is triggered. A concentration level that would trigger a fourth contingency remedy of low flow pumping near Temple Place will be identified in the design. These contingencies are independent of each other so that a concentration less than 2,000,000 pCi/L at the HFBR will not trigger the downgradient contingencies. In addition, the OU III South Boundary pump-and-treat system will be in operation at the time (15 years) that the tritium is expected to cross the site boundary. Any remaining tritium will be captured by this system and recharged further north on the site property where it will be able to decay much below detectable levels before returning to the site boundary.
6m. Alternative T4 should be protective of public health, given the hookup of private wells in the downgradient area. The proposed monitoring network and removal contingencies, however, can not guarantee that all tritium that could migrate off-site at levels exceeding drinking water standards will be detected and captured. It is therefore recommended that all known tritium contamination in excess of 100,000 pCi/l be removed with low-flow pumps and disposed off-site, so that tritium levels leaving the site in 25 years (2 half lives) will not exceed standards. It is also recommended that the proposed monitoring using permanent wells be augmented periodically with profile wells using short screens to reduce the likelihood that maximum plume concentrations and downgradient migrations will go undetected.
In response to regulatory concerns about potential plume migration, a fourth contingency was added consisting of a low flow extraction system near Temple Place. The operational parameters will be developed during design. The proposed remedial alternative addresses the cleanup objective of limiting significant plume growth. Stated another way, this objective means that concentrations higher than those measured today will remain at their current locations or shrink in the upgradient direction. Downgradient migration of the higher concentrations would violate the cleanup objective. If higher than anticipated concentrations are detected then one of the contingency remedies may be triggered. The DOE agrees that this remedy depends on an adequate monitoring system. The existing network of 88 permanent monitoring wells is being enhanced by installing up to 34 additional permanent monitoring wells preceded by an assessment by 42 temporary wells with short screens (BNL 1999 Draft MNA Work Plan). This type of assessment may be undertaken periodically, if necessary, to verify the location of the higher plume concentrations. The method to determine when the trigger levels have been exceeded will be determined during the design phase.
6n. Alternative S5a should be protective of public health and the environment. It is important that the proposed additional monitoring wells be carefully placed so as to accurately characterize recovery system efficacy and plume migration control.
BNL and DOE agree that monitoring of the remedial action is important. Thirty-five monitoring wells were recently installed, and the location of any additional monitoring wells will be determined during the design phase.
6o. Why is the VOC cleanup so much more expensive than the tritium or Sr-90 cleanup?
The cleanup of VOCs is more expensive primarily because the plume is so much larger than the Strontium-90 and tritium plumes.
6p. Anecdotes suggest iron fouling as a serious problem at deeper production wells operated by the Suffolk County Water Authority (SCWA). Has this phenomenon been addressed in the choice of technology? Fouling of the well screens in the pumping wells and the creation of iron precipitates as anoxic water becomes oxidized (if that occurs in this treatment) may be anticipated from others' experiences on Long Island.
Iron fouling was considered in selecting the technology and it was determined that these concentrations could be managed through normal routine maintenance of the systems. The basis of this evaluation was the following. Two groundwater pump-and-treat systems have been operating on the BNL site since January 1997 and June 1997. Both systems have operated without any maintenance problems related to iron fouling. The system being used in the industrial park is a closed-loop air system with carbon treatment to remove VOCs from the air. The carbon will also substantially reduce the amount of oxygen present in the air. This oxygen reduction will reduce the extent of any iron fouling. Other in-well air stripping systems that have been operating have not had significant iron fouling problems.
4. COMMUNITY RELATIONS ACTIVITIES
Following is a chronology of the major general and OU III focused community relations activities at BNL.
September 26, 1991
Public meeting held on September 26, 1991 at BNL to solicit comments and questions on the "DOE Environmental Restoration and Waste Management five-year Plan" and the "BNL Site Specific Plan." Additional presentations were made at the meeting and a 30-day public comment period was held on the draft "Response Strategy Document," the draft "Site Community Relations Plan," and the draft "Remedial Investigation/Feasibility Study Work Plan" for OU IV.
March 26, 1993
"Final Scope of Work for Operable Unit III Remedial Investigation/Feasibility Study Work Plan" entered in Administrative Record.
October 16, 1994
"Operable Unit III Final RI/FS Work Plan", "Health and Safety Plan for Operable Unit II RI/FS Work Plan", and "Sampling and Analysis Plan for Operable Unit III RI/FS Work Plan" entered in Administrative Record.
January 16, 1996
Public meeting held at BNL on the OU I EE/CA.
January 8, 1997
Public notice of availability for Action Memorandum for OU I Groundwater Removal Action and Operable Units I and III Public Water Hookups published.
May 14 and 21, 1997
Public notice of availability of the "Action Memorandum for Tritium Removal Action" published in local Newspapers.
February 20, 1998
Pre-Design Report for OU III Off-Site Removal Action entered into Administrative Record.
June 24, 1998
Final Action Memorandum for OU III Off-site Groundwater Removal Action placed in Administrative Record.
February 16, 1999
Entered OU III Carbon Tetrachloride Action Memo into Administrative Record.
March 1- April 30
Public comment period held for the OU III RI/RA, FS and Proposed Plan. Public notice and a display advertisement about the documents were published in Newsday and Suffolk Life. Upon request from several stakeholders, the public comment period was extended through April 30.
Public Meeting on OU III Proposed Plan held at Berkner Hall, BNL.
BNL, 1998. Final Report, OU III Early Community Input. Prepared by the Community Involvement/Public Affairs Division, Brookhaven National Laboratory.
BNL, 1999. OU III Proposed Remedial Action Plan. Brookhaven National Laboratory, Upton, New York.
IT , 1999a. Operable Unit III Remedial Investigation Report. Prepared by International Technology Corporation for Brookhaven National Laboratory, Upton, New York.
IT, 1999b. Operable Unit III Feasibility Study Report. Prepared by International Technology Corporation, prepared for Brookhaven National Laboratory, Upton, New York.