AOC 4 (Sewage Treatment Plant)

Sub-AOC 4A (Sludge Drying Beds)
Sub-AOC 4B (Sand Filter Beds/Berms)
Sub-AOC 4C (Imhoff Tanks)
Sub-AOC 4D (Hold-up Ponds)
Sub-AOC 4E (Satellite Disposal Area)

AOC 21 (Sewer Lines)

AOC 23 (Eastern Off-site Tritium Plume)

 

Table 1 Operable Unit V Areas of Concern
Table 2 Summary of Selected Remedy and Completed Removal Actions in Operable Unit V
Table 3 Operable Unit V Areas of Concern and Extent of Contamination
Table 4 Cost Summary for Selected Remedies

Figure 1 Regional Site Location Map
Figure 2 Current Land Use at BNL
Figure 3 BNL Operable Units
Figure 4 Sewage Treatment Plant (AOC 4)
Figure 5 Sewer Lines in Operable Unit V (AOC 21)
Figure 6 September 2000 TCE Levels Downgradient from Operable Unit V
Figure 7 Areal Extent of Public Water Hookup In Proximity to Brookhaven National Laboratory

Brookhaven National Laboratory (BNL) is a federal facility owned by the U.S. Department of Energy (DOE). BNL conducts research in physical, biomedical and environmental sciences and 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 (Figure 1). Distances to neighboring communities from BNL are as follows: Patchogue 10 miles west-southwest; Bellport 8 miles southwest; Center Moriches 7 miles southeast; Riverhead 13 miles east; Wading River 7 miles north-northeast; and Port Jefferson 11 miles northwest.

The BNL property, consisting of 5,321 acres, is an irregular polygon, and each side is approximately 2.5 miles long. Figure 2 is a current land-use map of the BNL site. The developed portion of the site includes the principal facilities, located near the center of the site on relatively high ground and contained in an area of approximately 900 acres, 500 acres of which were originally developed for Army use. For the most part, the remaining 400 acres are occupied by various large research machine facilities. The outlying facilities occupy approximately 550 acres and include an apartment area, Biology Field, Former Hazardous Waste Management Area, Sewage Treatment Plant, firebreaks, and the Former Landfill Area. 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 sole-source aquifer beneath BNL comprises three water-bearing units: the Moraine and outwash deposits, the Magothy Formation, 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 extending from a depth of 5 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 source of drinking water for Nassau and Suffolk Counties.

The BNL site, formerly Camp Upton, was occupied by the U.S. Army during World Wars I and II. Between the wars, the site was operated by the Civilian Conservation Corps. It was transferred to the Atomic Energy Commission in 1947, to the Energy Research and Development Administration in 1975, and to DOE in 1977.

In 1980, the BNL site was placed on New York State’s Department of Environmental Conservation's (NYSDEC's) list of Inactive Hazardous Waste Sites. On December 21, 1989, the BNL site was included on EPA’s National Priorities List because of soil and groundwater contamination that resulted from BNL's past operations. Subsequently, the EPA, NYSDEC, and DOE entered into a Federal Facilities Agreement (herein referred to as the Interagency Agreement, IAG) that became effective in May 1992 (Administrative Docket Number: II-CERCLA-FFA-00201) to coordinate the cleanup. The IAG identified areas of concern that were grouped into operable units to be evaluated for response actions. The IAG requires a remedial investigation/feasibility study for Operable Unit V, pursuant to 42 U.S.C. 9601 et. Seq., to meet CERCLA requirements. The IAG also requires cleanup actions to address the identified concerns.

BNL’s Response Strategy Document (SAIC, 1992) grouped the identified areas of concern into seven operable units; several were subsequently combined. Remedial investigations and risk assessments were conducted to evaluate the nature and extent of contamination, and the potential risks associated with the areas of concern addressed in this Record of Decision. A Feasibility Study (IT, 1998) was prepared to evaluate the alternatives for remediating the contaminated groundwater, sediment and soil.

Operable Unit V is located in the northeastern quadrant of the property along the eastern property border. Figure 3 shows its extent. OU V includes the following AOCs and Sub-AOCs:

• Sewage Treatment Plant (STP, AOC 4),

• Sub-AOC 4A: Sludge Drying Beds
• Sub-AOC 4B: Sand Filter Beds/Berms
• Sub-AOC 4C: Imhoff Tank
• Sub-AOC 4D: Hold-up Ponds
• Sub-AOC 4E: Satellite Disposal Area

• Sewer Lines (AOC 21),
• Eastern Off-site Tritium Plume (AOC 23), and
• Peconic River (AOC 30).

Table 1 describes these AOCs. The STP is located adjacent to the Peconic River. Adjacent areas in Sub-AOC 4B include two areas immediately north and south of the sand filter beds and the BNL Firing Range berms (Figure 4). The sewer line runs from East Fifth Avenue to the STP [approximately 3,400 feet (1 kilometer)] and is currently retired and capped (Figure 5). The Eastern Off-site Tritium plume was so named because of an initial concern about tritium migrating off the BNL property in groundwater. However, further characterization indicated that tritium concentrations are well below the drinking-water standard of 20,000 pCi/L. Groundwater sampling during the remedial investigation also detected contamination of volatile organic compounds (VOCs), primarily trichloroethene (or trichloroethylene, TCE) both on and off the BNL property in the vicinity of the Sewage Treatment Plant.

The contamination in soil, sediment and groundwater documented before the Remedial Investigation is described in the Operable Unit V Work Plan (IT, 1994). More detailed descriptions and references are given in the Remedial Investigation Report for Operable Unit V (IT, 1998a).

A Community Relations Plan was finalized for the BNL site 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 informing and involving the public. A variety of activities were used to provide information and to seek public participation, including compilation of a stakeholders mailing list, community meetings, availability sessions, site tours, workshops and the development of fact sheets. An Administrative Record was established, documenting the basis for the selection of removal and remedial actions at the BNL site, and is maintained at the local libraries listed below, and at EPA's Region II Administrative Records Room at 290 Broadway, New York, NY, 10001-1866.

Longwood Public Library
800 Middle Country Road
Middle Island, NY 11953

Mastics-Moriches-Shirley Community Library
301 William Floyd Parkway
Shirley, NY 11967

Brookhaven National Laboratory
Research Library
Bldg. 477A
Upton, NY 11973

Consistent with CERCLA guidance and state requirements, community involvement and participation was solicited for all significant documents and decisions associated with this Record of Decision. The final scope of work, the work plan, quality assurance plan, risk assessment documents, remedial investigation reports, the proposed plan and the feasibility study were made available for public review.

The latest community involvement activities included the review of the Operable Unit V Feasibility Study (IT, 1998b), the Plutonium Contamination Characterization and Radiological Dose and Risk Assessment Report (IT, 2000) and the Proposed Plan (BNL, 2000). A public comment period for the review of the OU V Proposed Plan began on February 15, 2000. An eight-page summary of the proposed plan was mailed to about 2,500 homes on the Environmental Restoration Division mailing list. Two roundtable meetings to discuss the proposed remedy were held on February 23^rd and 29^th at BNL and Riverhead High School, respectively. Over 30 members of the community attended these two meetings. A public meeting, attended by approximately 40 people, was held on March 2, 2000 in Berkner Hall Auditorium at Brookhaven National Laboratory. Copies of the Proposed Plan, the eight-page summary, and other related information material were available. Based upon the concern of the community that adequate time be provided to conduct a comprehensive review and comment on this remedial action decision, a 60-day extension to the public comment period was granted. The public comment period ended on May 15, 2000. The Responsiveness Summary section of this document summarizes the written and oral comments and DOE’s responses on the preferred alternatives.

During the ninety-day public comment period, hundreds of written comments were received on the OU V documents. The majority of the comments received was opposed to the plan of excavating areas of the Peconic River with sediment above cleanup goals and focused on minimizing wetland damage from the proposed excavation and sediment dispersion during remediation of the river sediment. Few comments were focused on the sewage treatment plant and groundwater.

In response to these comments, DOE deferred the decision on how to address the Peconic River. A final remedy for the Peconic River cleanup will be documented in a separate Record of Decision.

The proposed remedy for the sewage treatment plant and groundwater, which is documented in the Record of Decision, was largely supported. There were no significant comments in opposition to these remedies.

The following modifications were made to the preferred remedial alternative based on the concerns and input of the EPA and the New York State Department of Environmental Conservation after the public comment period in the spring of 2000.

• The cleanup goal for cesium-137 was changed from 67 pCi/g to an average concentration of 23 pCi/g with hot spots no greater than three times the cleanup goal to allow greater flexibility in future land use. This change in cleanup goal did not alter the cost of remedy.

• Excavation and off-site disposal of soil above the cleanup goals will be performed at the Sludge Drying Beds. This additional work will involve a minimal cost increase.

• Sludge from ten manholes associated with the Sewer Lines (AOC 21) will be removed.

Response actions for Operable Unit V will be addressed in two separate Records of Decision. This Record of Decision selects remedial actions for some AOCs and sub-AOCs in OU V, including a localized removal of soil contaminants at the Sewage Treatment Plant (Sub-AOC 4B) and Sludge Drying Beds (Sub-AOC 4A), continued monitoring of contaminants in groundwater (AOC 23), and removal of sludge from 10 manholes along the retired sewer line that lead to the STP (AOC 21). The remedy also includes a completed removal action at the Imhoff Tanks (Sub-AOC 4C). Soil and groundwater associated with the Hold-up Ponds (Sub-AOC 4D) do not pose an unacceptable risk. However, additional groundwater monitoring well be conducted. Post-remediation monitoring will verify soil cleanup levels across all sub-AOCs.

Based on public and local official comments, as well as the EPA's and NYSDEC's recommendations, DOE decided to defer its decision on the cleanup remedy for the Peconic River sediment. A final remedy for the Peconic River (AOC 30) cleanup project will not be completed until further environmental evaluation and community involvement is completed and will be documented in a separate Record of Decision. A new proposed plan will be prepared and a public comment period will be conducted as part of this process.

The main purposes of the Remedial Investigation (IT, 1998a) were to determine the nature, magnitude, and extent of soil, sediment, groundwater and surface water contamination from the AOCs included in Operable Unit V, and to characterize the potential health risks and environmental impacts of any contaminants present. The investigation included: geophysical and biological surveys, sampling of soil, groundwater, surface water, sediment and sewer pipes; chemical and radiological analyses; benthic invertebrate toxicity testing; fish bioaccumulation studies; and data validation. The contaminants analyzed for in the Remedial Investigation were metals, pesticides, PCBs, volatile organic compounds, semi-volatile organic compounds, and many radionuclides. An additional study (IT, 2000) further characterized the extent of radiological contamination, particularly for plutonium, in the Peconic River's sediment, surface water, and fish; for soil in the sand filter beds/berms and adjacent areas at the STP; for the retired and capped sewer line; and for groundwater in the vicinity of the STP.

Classification of the nature and extent of soil and groundwater contamination was based on screening criteria for chemicals and radiological constituents in various media. The specific screening criteria used for the BNL OU V study area are detailed in section 4.2 of the Remedial Investigation Report (IT, 1998a). Whenever possible, established regulatory criteria known as "chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs)" were used to screen the analytical data. ARARs were used as screening criteria for groundwater, where state and/or federal drinking-water standards exist for many chemicals. In the absence of ARARs, non-enforceable regulatory guidance values, known as "to be considered" criteria, or "TBCs" were used to screen the data. This was the case for soil, which have no established state or federal ARARs. Radionuclides in soil, for which there are no individual ARAR or TBC concentrations, were screened against site-specific levels calculated using a risk model (RESRAD; ANL, 1993) that allowed a dose limit of 15 millirem/year above background. Screening criteria for sediment were selected as the higher of site background levels or the most stringent sediment screening criteria available (NYSDEC sediment screening criteria, Long and McDonald (1995) screening criteria).

A more recent investigation that characterized plutonium and other radionuclides in soil, sediment, surface water, fish and groundwater included, for comparison, samples of surface water and sediment from a reference location (Connetquot River) and groundwater from wells located 18-30 miles west of BNL.

Table 3 summarizes the primary contaminants and maximum concentration found in each Area of Concern addressed by this Record of Decision.

Past operations and practices led to waste water containing radionuclides and chemicals being discharged at the Sewage Treatment Plant. The contaminants were subsequently sequestered in the sand filter beds. Periodic scraping of the filter beds up onto the berms resulted in the distribution of contamination on the bermed areas surrounding the beds.

The contaminants found most frequently and at the highest concentrations relative to screening levels were mercury and cesium-137. Levels of both were highest in the sand filter berms and areas adjacent to the sand filter beds. The maximum concentration of mercury was 19.1 mg/kg reported from the supplemental sampling of the RI (BNL, 2001). Cesium-137 was present at a maximum concentration of 98.8 pCi/g (IT, 1998a). Mercury and cesium-137 are the only constituents present that require remedial action.

The RI also found other inorganic constituents (silver, chromium, and lead) and radionuclides (americium-241 and plutonium-239/240) above screening levels in surface and subsurface soil at the sand filter beds and sand filter berms although not at concentrations requiring cleanup.

Supplemental sampling in the vicinity of the Sewage Treatment Plant in September 2000 identified an area at BNL’s Firing Range (located in the eastern portion of the property directly north of the STP sand filter beds – Figure 4) with elevated levels of mercury and cesium-137 (BNL, 2001). The maximum concentrations were 13.9 mg/kg for mercury and 35.1 pCi/g for cesium-137. Based on this information, the BNL Firing Range will be included in the overall remedy for the sewage treatment plant.

The Laboratory sampled the soil surrounding the areas where leaks were identified along the sewer line during the Operable Unit V investigation. The results of the investigation identified only 8 inorganic analytes at concentrations that exceeded the screening concentrations. With the exception of nickel and thallium (maximum concentrations of 215 mg/kg and 1.8 mg/kg, respectively), the elevated concentrations of inorganics were detected at a low frequency (i.e., less than twice) or at concentrations that only slightly exceeded screening levels.

As part of a more recent investigation, sludge was collected from the bottom of manholes along the retired and capped sewer line and analyzed for radionuclides. The results identified elevated activities of a few radionuclides. Americium-241 (maximum 22 pCi/g) and cesium-137 (12.85 pCi/g) were found at the highest activities relative to screening levels. Plutonium was also detected, generally at low levels (plutonium-238 maximum 0.63 pCi/g; plutonium-239/240 maximum 3.42 pCi/g). The current status of the sewer line (retired and capped at both ends) is such that no exposure pathway presently exists which could pose a risk to workers or the public.

Past operations and practices led to waste water containing radionuclides and chemicals being discharged at the Sewage treatment Plant. While most of the contaminants were sequestered in the sand filter beds, some of the most mobile contaminants (tritium and trichloroethene) migrated to the groundwater.

Current groundwater sampling results indicate that levels of tritium in the groundwater are well below the drinking water standard. The highest concentration of trichloroethene (TCE) found on the BNL property during the Remedial Investigation was 32 ug/l. The maximum level found during the Remedial Investigation off of the BNL property was 8.5 ug/l, slightly greater than the drinking water standard of 5 ug/l. The highest concentration of TCE reported previously off of the BNL property was 12 ug/l. Samples collected in 2000 (BNL, 2001) found a maximum TCE concentration on the property of 17.9 ug/l and a maximum concentration off the property of 10.7 ug/l (Figure 6).

The elevated levels of TCE in groundwater off the BNL property were found at depths of approximately 200 feet below land surface. Homes and businesses in the OU V area were offered public water in 1997 (Figure 7).

Both soil and groundwater samples were collected in the area of the Sludge Drying Beds (Sub-AOC 4A), Imhoff Tanks (Sub-AOC 4C), Hold-up Ponds (Sub-AOC 4D) and Satellite Disposal Area (Sub-AOC 4E). With the exception of the Sludge Drying Beds, no contaminants were detected at levels requiring remediation. One elevated sample of mercury (8.4 mg/kg) was reported at the surface of the Sludge Drying Beds that will require cleanup. The Hold-up Ponds will be monitored. No further action is planned for the remaining areas.

As part of the Operable Unit V Remedial Investigation/Risk Assessment, a baseline risk assessment was done to estimate the human-health and ecological risks that could result from exposure to contaminants in Operable Unit V if there were no remediation beyond that accomplished to date. The human-health risk assessment evaluated both present and future potential exposures to contaminants. The findings of the risk assessment are documented in the Operable Unit V Remedial Investigation/Risk Assessment Report (IT, 1998a). An additional radiological-risk assessment was done that combined the data collected in the Remedial Investigation with those collected in another study that further characterized the extent of radiological contamination in Operable Unit V (IT, 2000). The following sections address the risk assessment relative to the Sewage Treatment Plant.

A Superfund baseline human health risk assessment is an analysis of the potential adverse health effects caused by hazardous substance releases from a site in the absence of any actions to control or mitigate these under current and future land uses. A four-step process is utilized for assessing site-related human health risks for reasonable maximum exposure scenarios.

Hazard Identification: In this step, the contaminants of concern at the site in various media (i.e., soil, groundwater, surface water, air, etc.) are identified based on such factors as toxicity, frequency of occurrence, fate and transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility, persistence, and bioaccumulation.

Exposure Assessment: In this step, the different exposure pathways through which people might be exposed to the contaminants identified in the previous step are evaluated. Examples of exposure pathways include incidental ingestion of and dermal contact with contaminated soil. Factors relating to the exposure assessment include but are not limited to the concentrations that people might be exposed to and the potential frequency and duration of exposure. Using these factors, a reasonable maximum exposure scenario, which portrays the highest level of human exposure that could reasonably be expected to occur, is calculated.

Toxicity Assessment: In this step, the types of adverse health effects associated with chemical exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects (response) are determined. Potential health effects are chemical-specific and may include the risk of developing cancer over a lifetime or other non-cancer health effects such as changes in the normal functions of organs within the body (e.g., changes in the effectiveness of the immune system). Some chemicals are capable of causing both cancer and non-cancer health effects.

Risk Characterization: This step summarizes and combines outputs of the exposure and toxicity assessments to provide a quantitative assessment of site risks. Exposures are evaluated based on the potential risk of developing cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancer is expressed as a probability. For example, a 10^-4 cancer risk means a one-in-ten-thousand excess cancer risk; or one additional cancer may be seen in a population of 10,000 people as a result of exposure to site contaminants under the conditions explained in the Exposure Assessment. Current federal Superfund guidelines for acceptable exposures are an individual lifetime excess cancer risk in the range of 10^-4 to 10^-6 (corresponding to a one-in-ten-thousand to a one-in-a-million excess cancer risk). For non-cancer health effects, a hazard index (HI) is calculated. An HI represents the sum of the individual exposure levels compared to their corresponding reference doses. The key concept for a non-cancer HI is that a threshold level (measured as an HI of less than or equal to 1) exists below which non-cancer health effects are not expected to occur. A Hazard Index greater than 1.0 indicates a potential for non-carcinogenic effects.

Human-health risks were evaluated for potential exposures to radiological and chemical contaminants of concern. The chemical risk assessment addressed the risk of cancer and non-carcinogenic toxicity associated with exposure to chemical contaminants. The radiological risk assessment evaluated the potential carcinogenic risks associated with exposure to radionuclides.

Chemicals of potential concern were selected based on procedures specified in EPA's Risk Assessment Guidance for Superfund, Part A (EPA, 1989). Contaminants evaluated in the risk assessment exceeded screening levels based on their degree of toxicity, concentration, frequency of detection, chemical properties important to potential release, transport, and exposure, and significant exposure routes. Table 3 identified contaminants of potential concern.

As part of the risk assessment, present and potential future-use scenarios were quantitatively evaluated.

For Current Land Use, two on-site exposure scenarios were investigated: an on-site worker who could be exposed to surface soil through inhalation, ingestion, and direct contact; and an older child trespasser who might come into contact with contaminated soil, sediment and surface water in the Peconic River headwaters.

For Future Land Use, two scenarios were investigated: an on-site construction worker, and future hypothetical residents living in the area of the current Sewage Treatment Plant. The construction worker was assumed to be exposed to contaminants through inhalation of soil particulates and dusts; incidental ingestion of soil; and direct dermal contact with soil. The hypothetical future resident was assumed to be exposed to contaminants in soil, sediment, surface water and groundwater after a loss of institutional control in the future. Exposure to contaminants in home-grown food and deer meat was considered as a pathway in the radiological risk analysis.

The toxicity assessment consisted of examining the toxicological properties of selected chemicals of potential concern using the most current data on human-health effects. Many of the carcinogenic slope-factors and reference doses used were obtained from EPA's Integrated Risk Information System database. Those that were not available in that database were obtained from EPA's Health Effects Assessment Summary Tables. The potential health hazards associated with exposure to non-carcinogens were determined by comparing the estimated chronic or subchronic daily intake of a chemical with the reference dose. A toxicity profile for each chemical of potential concern was developed using EPA toxicity assessments and accompanying values. When toxicity values were not available for a specific chemical, the chemical was qualitatively evaluated. Uncertainties in the chemical toxicity data were also considered. Some toxicity values in the risk assessment are extremely conservative estimates, and include uncertainty factors that may reduce the estimated safe exposure concentrations by up to 1,000 times.

For Current Land Use, all risks for chemical contaminant exposures to the on-site worker and the trespasser, assuming no cleanup, were within EPA’s acceptable risk range for carcinogenic risks and below the acceptable Hazard Index of 1 for non-carcinogenic hazards.

Under the Future Land Use Scenario, all risks for chemical exposures to future workers were within EPA’s acceptable risk range for carcinogenic risks and below the acceptable Hazard Index of 1 for non-carcinogenic hazards. For hypothetical future on-site residents living near the Sewage Treatment Plant, the non-carcinogenic Hazard Index is greater than 1.0 (1.8 and 4.9 for adult and young child, respectively). Manganese (not VOCs or radionuclides) in the unfiltered groundwater would contribute the majority of this potential health hazard. The carcinogenic risks for these hypothetical future on-site residents (5 x 10 ^-5 and 3 x 10 ^-5 for an adult and young child, respectively) were within EPA’s acceptable risk range. The majority of any potential cancer risk would be from arsenic in unfiltered groundwater.

Radiological risks to the current on-site industrial worker using upper bound exposure estimates exceeded EPA’s acceptable risk range with a maximum risk of 3.0 x 10^-4, but were within control levels established for workers trained in radiation protection. The risk was due almost entirely to the external gamma radiation pathway with the major contributor being cesium-137 contamination in the soil at the sewage treatment plant.

Under the Future Land Use Scenario, radiological risks to the hypothetical future on-site resident living at the sewage treatment plant, assuming no remediation and using upper bound exposure estimates, exceeded EPA’s acceptable risk range with a maximum risk of 3.4 x 10^-4 (using a 95% upper confidence level, or UCL). As with the current land use scenario, the risk was due almost entirely to the external gamma radiation pathway with the major contributor being cesium-137 contamination in the soil at the sewage treatment plant.

The Ecological Risk Assessment was performed to determine whether historical activities at Operable Unit V resulted in levels of chemical and radiological contamination that could adversely affect the ecosystems there.

A standard ecological risk assessment (as prescribed by the EPA) uses a four-step process to assess ecological risks for a reasonable maximum-exposure scenario:

Problem Formulation – a qualitative evaluation of a contaminant's release, migration and fate; identification of contaminants of concern, receptors, exposure pathways and known ecological effects of the contaminants; and selection of endpoints for further study.

Exposure Assessment – a quantitative evaluation of the release, migration and fate of the contaminant; characterization of exposure pathways and receptors; and measurement or estimation of exposure point concentrations.

Ecological Effects Assessment – literature reviews, field studies and toxicity tests linking contaminant concentrations to effects on ecological receptors.

Risk Characterization – measurement or estimation of current and future adverse effects.

Unlike assessments of human health risk, which are concerned with effects on individuals, assessments of ecological risk focus on wildlife populations and ecosystem-level effects. It is difficult to draw inferences at the population and ecosystems level, and the ecological assessment for Operable Unit V was largely a qualitative one.

Risk to terrestrial wildlife was assessed through modeling exposure of wildlife to contaminated soil at the Sand Filter Beds and Berms. The opportunity for exposure is limited, based on the habitat potential of the Sand Filter Beds, so this actually represents a hypothetical future scenario. The greatest potential risk was found to be due to mercury and silver, which could be translocated to plants from the soil, and accumulate in small mammals or invertebrates which could then be consumed by predators such as fox and hawk. However, the habitat at the Sand Filter Beds significantly reduces the exposure to mercury and silver by wildlife.

This section identifies the basis for taking remedial actions, the objectives of the remedial actions, land-use considerations and cleanup goals.

The actual or threatened releases of hazardous substances from OU V may present an imminent and substantial endangerment to public health, welfare or the environment if they are not addressed by implementing the remedial actions selected in this Record of Decision. The major concern in this operable unit is radiological due to cesium-137 in the soil of the sewage treatment plant berms. Radiological risks to the hypothetical future on-site resident living at the STP using upper confidence level (95% UCL) exposure estimates exceeded EPA's acceptable risk range. Mercury was also selected as a contaminant of concern because of the frequency of occurrence at concentrations exceeding the soil screening criteria.

Remedial action objectives (RAOs) are specific goals to protect human health and the environment. They are based on available information and standards, such as the applicable or relevant and appropriate requirements (ARARs) and risk-based levels established in the risk assessment. After evaluating the nature and extent of contamination in the soil and groundwater, and assessing the chemical and radiological risks associated with exposure to contaminants of potential concern, the following RAOs were developed for groundwater and soil at the sewage treatment plant:

• Protect public health and the sole source aquifer.
• Continue to collect the data needed to characterize and monitor levels of groundwater contamination.

• Reduce the levels of contamination in the sand filter beds/berms and adjacent areas.
• Prevent or minimize the migration of contaminants present in the surface soil via surface runoff and windblown dusts.
• Prevent or minimize human and environmental exposure to contaminants in the surface and subsurface soil. This includes site workers, construction workers, trespassers, and future residents.
• Prevent or minimize the potential for uptake of contaminants present in the soil by ecological receptors.
• Prevent or minimize the potential for migration of contaminants (chemical and radiological) from the soil to groundwater.

BNL is currently used by the DOE as a research facility with associated support facilities and is expected to remain so for the foreseeable future. Access to the BNL site is currently restricted and controlled. It is assumed that this institutional control will continue for at least the next 50 years.

A future land use study was undertaken and published by BNL in 1995 (BNL 1995). Potential land uses that could occur after BNL closes as a national laboratory were identified as a mix of open space, industrial/commercial, recreational and residential uses. DOE’s future land use for the Sewage Treatment Plant is expected to remain industrial/commercial for the near future (i.e., at least 50 years).

Soil in the Sand Filter Beds and Berms at the Sewage Treatment Plant contains elevated concentrations of mercury, silver, chromium, lead, and radionuclides (primarily cesium-137). The remedial investigation identified mercury and cesium-137 as the most frequently occurring contaminants that exceeded the soil screening criteria. In addition, cesium-137 was determined by the radiological risk assessment to be the major contributor to risks posed to human health by the radionuclides and mercury was shown to bioaccumulate in fish in the Peconic River. Therefore, the cleanup levels for remediation of the sand filter beds and berms are based on mercury and cesium-137. Also, the remedial investigation determined that the elevated concentrations of silver, chromium, lead and other radionuclides are co-located within the soils containing elevated concentrations of mercury and cesium-137. Soil remediation will be conducted using best management practices such that all contaminants are reduced and that no residuals will contribute a risk to human health.

The mercury cleanup goal for the localized removal of soil in the sand filter beds and adjacent berms was chosen based on the EPA action level for the protection of groundwater for mercury (2 mg/kg) (EPA, 1996).

The cleanup goal for cesium-137 at the sewage treatment plant was calculated using the DOE Residual Radioactive Material Guidelines (RESRAD) computer code and is based on the following:

• A total dose limit of 15 mrem/yr above background;
• Assuming a future residential land use; and
• 50 years of institutional control of the area.

Based on this information, the cleanup goal within the affected areas of the sewage treatment plant will be such that the remaining average concentration for cesium-137 will be less than 23 pCi/g. A hot spot criterion of three times the cleanup goal of 23 pCi/g will also be applied. Contaminant concentrations above this criterion would be removed even if the average concentration were less than the 23 pCi/g. This cleanup goal allows for current industrial use without controls and future residential land use after the assumed 50-year period of institutional control. These goals replace the proposed goal of 67 pCi/g contained in the Proposed Plan and Feasiblity Study in response to concerns expressed by the EPA and NYSDEC after the public comment period.

In the unlikely event the property is transferred, specific requirements outlined in section 120 (h) of CERCLA will be met. These requirements ensure that future users of the property are not exposed to unacceptable levels of contamination.

An As-Low-As-Reasonably-Achievable (ALARA) analysis will be performed during the remedial planning to identify cost-effective measures for further reducing exposure to residual contamination below the above-mentioned cleanup goals. Post remediation sampling and dose assessments will be performed to ensure that the limit of 15 mrem/year above background will be met for all radionuclides that remain. The NYSDEC guidance of 10 mrem/yr above background has also been adopted as an ALARA goal that will be considered during the planning and construction phase.

Section 121 of CERCLA requires that each selected site remedy protects human health and the environment, is cost-effective, complies with other statutory laws, and uses permanent solutions, alternative treatment technologies and resource-recovery alternatives as fully as practicable. In addition, the statute includes a preference for treatment as a principal element for reducing the toxicity, mobility, or volume of the hazardous substances.

Four potential scenarios for the remediation of contaminated soils at the STP were evaluated in Appendix F of the OU V Feasibility Study Report (IT 1998b). These scenarios are summarized below. They varied in the proposed cleanup goal for mercury, which ranged from 0.1 ppm to 9.8 ppm; and for cesium-137, which included 23 pCi/g as the average concentration goal and 67 pCi/g as the hot spot criterion of three times the cleanup goal level. A hot spot criterion level for cesium-137 of 67 pCi/g was used for three scenarios; a cleanup goal for cesium-137 of 23 pCi/g was used for Scenario 2. The cost estimates for each scenario listed below are still reasonable for this revised cleanup goal.

Each scenario described below requires continued groundwater monitoring to confirm reduction of VOC concentrations to MCLs. Groundwater monitoring data will be reviewed at least annually. Any proposed changes to the remedy will be based on the monitoring data.

Under this scenario, soils at the sand filter beds/berms and adjacent areas containing levels of mercury exceeding 0.1 ppm or cesium-137 exceeding 67 pCi/g would be excavated. Soil removal would take place at all eight sand filter beds, as well as the sand berms. Excavated portions of the sand filter beds would be replaced with clean sand or gravel, and excavated areas on the berms backfilled with clean fill, compacted and graded. Excavated materials would be disposed of in a licensed off-site disposal facility. This scenario would involve removal of the greatest amount of material among the four scenarios evaluated.

Under this scenario, soils at the Sand Filter Beds and Berms and adjacent areas containing levels of mercury exceeding 2 ppm (EPA level for protection of groundwater) or cesium-137 exceeding 67 pCi/g would be excavated. Soil removal would take place only in sand filter bed #7, as well as the sand berms. Excavated portions of the sand filter bed would be replaced with clean sand or gravel, and excavated areas on the berms backfilled with clean fill, compacted and graded. Excavated materials would be disposed of in a licensed off-site disposal facility.

Modified Scenario 2 was included in response to regulator comments during the review of the draft Record of Decision to incorporate an average cleanup goal of 23 pCi/g for cesium-137 as described in Section 7.4. The estimated costs and description of remediation activities are similar to Scenario 2 with the exception that soil with cesium-137 at levels exceeding 23 pCi/g would be excavated.

Under this scenario, soils at the sand filter beds/berms and adjacent areas containing levels of mercury exceeding 4.9 ppm (one-half the sediment toxicity based level) or cesium-137 exceeding 67 pCi/g would be excavated. As in scenario 2, soil removal would take place only in sand filter bed #7, as well as the sand berms. Excavated portions of the sand filter bed would be replaced with clean sand or gravel, and excavated areas on the berms backfilled with clean fill, compacted and graded. Excavated materials would be disposed in a licensed off-site disposal facility.

Under this scenario, soils at the sand filter beds/berms and adjacent areas containing levels of mercury exceeding 9.8 ppm (the sediment toxicity based level) or cesium-137 exceeding 67 pCi/g would be excavated. No sample locations in the sand filter beds exceeded these cleanup levels, therefore excavation would take place only in the sand berms. Excavated areas on the berms would be backfilled with clean fill, compacted and graded. Excavated materials would be disposed of in a licensed off-site disposal facility. This scenario would involve removal of the least amount of material among the four scenarios evaluated.

A comparative analysis of the scenarios was conducted to evaluate the relative performance of each scenario mentioned above with respect to the following three criteria: effectiveness, implementability and cost. The purpose of this analysis was to determine the advantages and disadvantages of each scenario, which provides the rational for selecting a preferred alternative. Cost estimates for each scenario varied depending on the waste disposal scenario assumed.

Of the four alternatives, Scenario 1 is the most effective in reducing contaminant levels because the greatest amount of soil volume would be removed in order to achieve the cleanup levels. The reduction of contamination within the sand beds is identical for Scenarios 2 and 3; however, Scenario 2 results in a greater reduction of contamination in the sand berms than Scenario 3. Scenario 4 is the least effective because it will result in the lowest volume of soil removed, and therefore the lowest level of contaminant reduction.

All four of the scenarios discussed at the sewage treatment plant are technically feasible and implementable. They all involve excavation and disposal methods that are well developed, proven, and conventionally used. The short-term risks posed to workers and the community during the removal would be highest for Scenario 1 because of the extensive amount of material handling involved. Risks decrease as the amounts to be removed decrease. Using standard health and safety practices and engineering controls to reduce airborne particle generation and exposure pathways will minimize short-term risks to workers and the community.

Scenario 1 is the most costly due to the large amounts of soil that would have to be removed. Scenario 2 is somewhat more expensive than Scenario 3 due to the larger soil volumes removed from the berms. Scenario 4 is the lowest in cost.

The modifying criteria are used in the final evaluation of remedial alternatives. The two modifying criteria are State and community acceptance. For both criteria, the factors that are considered include the elements of the alternatives that are supported, those that are not supported and those that are strongly opposed.

State Acceptance

State acceptance addresses whether the State agrees with, opposes, or has no comment on the preferred alternative. The State of New York concurs with the selected remedial actions for the Sludge Drying Beds (AOC 4A), Sewage Treatment Plant soil (AOC 4B), OU V groundwater (AOC 23) and Sewer Lines (AOC 21). The State of New York also concurs with the decision to take no further action at several other sub-areas of concern associated with Operable Unit V (Sub-AOC 4C, 4D, and 4E).

Community Acceptance

Community acceptance addresses the issues and concerns the public may have regarding each of the alternatives. A variety of activities were used to provide information to the public and to seek their participation, including compilation of a stakeholders mailing list, community meetings, availability sessions, site tours, workshops, and the development of fact sheets.

The written and verbal comments received from the public and local government officials during the public comment period and at the public meeting on March 2, 2000 have been evaluated. The results of the evaluation indicate that local government officials and the community support the preferred remedial alternative for the Sewage Treatment Plant soil (AOC 4B), OU V groundwater (AOC 23) and Sewer Lines (AOC 21) as well as the decision to take no further action at several other sub areas of concern associated with Operable Unit V (Sub-AOC 4A, 4C, 4D, and 4E). No major objections to the preferred remedies discussed in this Record of Decision were raised at the public meeting or during the public comment period.

This section documents the selected remedial actions for Operable Unit V. Table 2 summarizes the selected remedies for the AOCs and Table 4 summarizes the associated costs. The remedy has been selected based on consideration of CERCLA requirements, public comments and feedback from the regulatory agencies.

Institutional controls at BNL, which ensure that workers and the public are not exposed to unacceptable levels of contamination, include existing DOE orders and site-specific procedures. DOE Orders such as 5400.1 (General Environmental Protection Program) and 5400.5 (Radiation Protection of the Public and Environment) govern the management of radioactive waste and other waste types not regulated under RCRA or CERCLA at DOE facilities. Site-specific procedures such as BNL ESH 1.3.6 (Work Planning and Control for Operations) ensure that all work at BNL is planned and implemented properly, hazards and risks are identified and controlled, resources are scheduled and coordinated, and appropriate feedback mechanisms are in place. In addition, BNL ESH 1.1.18 (Excavation Safety) ensures that, prior to conducting excavation work, the Project Manager will check site maps and investigate, as appropriate, the potential for soil/pavement/floor contamination (radioactive or chemical). A background check that includes the history of activities in the vicinity is also required as part of this procedure.

In addition, any sale or transfer of BNL properties will also meet the requirements of 120 (h) of CERCLA to ensure future users are not exposed to unacceptable levels of contamination.

The major components of the selected remedies include:

A localized removal of soil contamination (Modified Scenario 2) will be performed to remove mercury and cesium-137 above the cleanup goals identified in Section 7.4. The cleanup goal within the affected areas of the Sewage Treatment Plant will be such that the remaining average concentration for cesium-137 will be less than 23 pCi/g. A hot spot criterion of three times the cleanup goal of 23 pCi/g will be applied. The cleanup goal for mercury is 2 ppm, based on the EPA action level for protection of groundwater.

This removal of contamination will reduce the potential for leaching and subsequent migration to groundwater and the Peconic River, and will reduce potential risks associated with cesium-137 in soil. Soil from the Sand Filter Beds, Sludge Drying Beds, and adjacent areas exceeding cleanup goals will be removed through excavation. Excavated portions of the sand beds will be replaced with sand or gravel. Excavated areas on the sand filter berms will be backfilled with clean fill, compacted and graded. Excavated materials will be disposed of in a licensed disposal facility. Post-remediation sampling and dose assessments, including a DOE independent survey, will be performed to ensure that the cleanup goals are met.

An As-Low-As-Reasonably-Achievable (ALARA) analysis will be included in the Remedial Action Work Plan to identify cost effective measures for further reducing exposure to residual contamination below cleanup goals. Techniques that minimize waste volumes or further stabilize wastes to meet disposal facility waste acceptance criteria may also be identified in the Remedial Action Work Plan.

Long-term institutional controls and monitoring will occur to ensure that planned uses remain protective of public health. In addition, any sale or transfer of BNL property will meet the requirements of 120(h) of CERCLA to ensure that future users are not exposed to unacceptable levels of contamination.

Groundwater contaminated with low levels of volatile organic compounds (VOCs) associated with this AOC will be monitored. This remedy is subject to a five-year review until MCLs are reached. Groundwater monitoring data will be reviewed at least annually. Any proposed changes to the remedy will be based on the monitoring data. Institutional controls will be maintained on the BNL site to prevent the installation and operation of drinking water and other pumping wells that may increase the potential for exposure to contaminated groundwater or interfere with the groundwater monitoring program.

Public water was provided to the off-site area containing contaminated groundwater from BNL in 1997 as part of a larger hookup program conducted by the U.S. Department of Energy through the Suffolk County Water Authority and will reduce the potential for exposure to contaminated groundwater. In addition, Suffolk County Department of Health Services private water system standards (Article 4 of the Suffolk County Sanitary Code) require the connection to public water for new construction where public water mains exist off the BNL property and will limit the installation of additional drinking water wells.

The Remedial Investigation detected elevated levels of metals and low levels of radioactivity within the sludge collected at the bottom of the Imhoff Tanks. No leakage of contaminants from the Imhoff Tank to surrounding soil and groundwater was detected. The sludge in the Imhoff Tank was removed, treated and disposed of off site by transporting it to Envirocare in Utah. In March, 1997, the remaining Imhoff tank concrete structure was tested and determined to be clean; demolished; and backfilled with clean fill and covered with concrete. No further action is required for this sub-AOC.

Both soil and groundwater samples were collected in the area of the Hold-up Ponds during the investigations, and no evidence of leakage was found. No further action is required under the BNL CERCLA program. These ponds will remain as part of BNL’s operating Sewage Treatment Plant and a groundwater monitoring network has been put in place as an institutional control to assure continued effectiveness of the Hold-up Ponds.

In 1985, bromine trifluoride cylinders and two boxes of laboratory chemicals were removed from this area. The soil and groundwater in the Satellite Disposal Area were thoroughly characterized and exploratory excavations were conducted. No evidence of contamination was found which required further action. No further action is required for this area.

The Laboratory sampled the soil surrounding the areas where leaks were identified along the sewer line during the initial Remedial Investigation. The results of the investigation identified only a few areas with low concentrations of inorganic constituents. As part of a more recent investigation, sludge was collected from the bottom of manholes along the retired and capped sewer line and analyzed for radionuclides. The results of this investigation identified elevated activities of a few radionuclides. The current status of the sewer line (retired and ends capped) is that no exposure pathway presently exists which could pose a risk to workers and the public.

Removal of sludge from 10 manholes along the retired sewer line that lead to the STP will be performed. Long-term institutional controls and monitoring will be conducted to ensure and protect public health and the environment. Institutional controls for the retired and capped sewer lines will be implemented to ensure that they remain intact and are not excavated.

Remedy selection is based on CERCLA and its amendments, and the regulations contained in the National Contingency Plan. All remedies must meet the threshold criteria: protection of human health and the environment, and compliance with ARARs. CERCLA also requires that the remedy use permanent solutions and alternative treatment technologies to the maximum extent practicable, and that the implemented action must be cost-effective. Finally, the statute includes a preference for remedies that employ treatment that permanently and significantly reduces the volume, toxicity or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedy meets these statutory requirements.

The selected remedy for the contaminated soil at the Sewage Treatment Plant protects human health and the environment by removing and disposing of contaminated soil. Removing the contaminated soil minimizes both risks of exposure to on-site workers and risks associated with future-use scenarios, as well as minimizing the potential for migration of contaminants into the underlying groundwater and ultimately the Peconic River.

Implementing the remedy will cause no unacceptable short-term risks or cross-media impacts.

The National Contingency Plan Section 300.430 (P) (5) (ii) (B) requires that the selected remedy attains the federal and state ARARs or obtains a waiver of an ARAR.

The chemical-specific ARARs that the selected remedies will meet are listed below.

1. Safe Drinking Water Act, Public Law 95-523, as amended by Public Law 96502, 22 USC 300 et. seq. National Primary Drinking Water Regulations (40 Code of Federal Regulations 141) and National Secondary Drinking Water Regulations (40 Code of Federal Regulations 143). This establishes MCLs and secondary MCLs for public drinking water supplies that are relevant and appropriate at the BNL facility.

2. New York Water Quality Standards, 6 NYCRR Part 703. This requirement establishes standards of quality and purity for groundwaters of the State.

3. RCRA (40 code of Federal Regulations parts 260-268): Defines hazardous wastes. All wastes classified as hazardous will be handled, stored, and disposed of in accordance with these regulations. Hazardous wastes will be disposed of at a permitted facility.

4. New York State Hazardous Waste Regulations (6 NYCRR Part 370 - 373): Defines hazardous wastes in New York State. All wastes classified as hazardous will be handled, stored, and disposed of in accordance with these regulations. Hazardous wastes will be disposed of off site at a permitted facility.

No location-specific ARARs were identified.

The action-specific ARARs that the selected remedies will meet are listed below.

1. 10 Code of Federal Regulations Part 835. This regulation establishes the requirements for controlling and managing radiologically contaminated areas. Compliance with this regulation is required as of January 1996.

2. RCRA (40 Code of Federal Regulations parts 260-268): As described above.

3. New York State Hazardous Waste Regulations (6 NYCRR Part 370-373): As described above.

4. NESHAPS (40 CFR 61, Subpart H.) This requirement sets forth the permitting process for remedial action.

5. 6 NYCRR Part 211. This regulation requires control of fugitive emissions from excavation and transport.

In implementing the selected remedy, the following guidance will be considered.

1. U.S. EPA, May 1996, "Soil Screening Guidance: Technical Background Document," EPA/540/R-95/128, Appendix A, Generic Soil Screening Levels for Superfund. Soil remediation goal for mercury was developed using this guidance.

2. DOE Order 5400.5 and draft 10 Code of Federal Regulations 834 "Radiation Protection of the Public and the Environment": This order, and its current draft rule-making, were used to develop radiological soil-remediation levels for Operable Unit I and will apply to the soil remediation at the Sewage Treatment Plant. The basic public dose limit for exposure to residual radioactive material for DOE facilities such as BNL is 100 mrem/year above background plus application of the As Low As Reasonably Achievable (ALARA) policy. Based on BNL site-specific conditions and ALARA, 15 mrem/year above background was selected. This level is consistent with risk requirements under CERCLA.

3. NYSDEC Technical and Administrative Guidance Memorandum "Remediation Guideline for Soils Contaminated with Radioactive Materials" (#4003), September 1993. This memorandum contains State guidance for remediating radiologically contaminated soils. The State’s value of 10 mrem/yr above background serves as an additional goal for remediation to be evaluated during remedial design and implementation.

Based on the expected performance standards, the selected remedies were determined to be cost effective because they provide overall protection of human health and the environment, long- and short-term effectiveness, and compliance with ARARs, at an acceptable cost. Table 4 provides a cost summary of the selected remedies.

The National Contingency Plan prefers a permanent solution whenever possible. The selected remedy is a final action that uses permanent solutions to the maximum extent practicable.

The Sewage Treatment Plant remedial action involves the removal and disposal of contaminated soil that poses a potential risk to exposed populations, and, therefore, is a permanent remedy for the existing contaminants of interest. The waste generated from this remedial action will be disposed of in a licensed facility off the BNL property.

This alternative does not meet the USEPA’s statutory preference for treatment as a principal component. There will be no treatment to reduce the toxicity, mobility, or volume of the contaminants in soil. Because of the small volumes of soil involved and the contaminants of concern, treatment is not cost-effective.

Comments received during the public comment period for the proposed plan were reviewed. No significant changes to the selected remedy for the AOCs covered by this Record of Decision, as identified in the Proposed Plan, were necessary. Minor changes were made in response to concerns expressed by the EPA and NYSDEC after the public comment period and are described in Section 3.

Five-year reviews will be necessary to evaluate the effectiveness of the institutional control to restrict inappropriate land use at the Sewage Treatment Plant. Five-year reviews will also be necessary for OU V groundwater until MCLs are reached.

ANL, 1993. Manual for Implementing Residual Radioactive Material Guidelines Using RESRAD, Version 5.0. Environmental Assessment Division, Argonne National Laboratory, Draft ANL/EAD/LD-2.

BNL, 1995. Future Land Use Plan. Brookhaven National Laboratory, Upton, N.Y. (BNL-62130).

BNL, 2000. Operable Unit V (Sewage Treatment Plant) Proposed Remedial Action Plan. Brookhaven National Laboratory, Upton, N.Y.

BNL, 2001. Operable Unit V (Sewage Treatment Plant) Supplemental Geoprobe Soil Sampling Letter Report. Brookhaven National Laboratory, Upton, N.Y., March 2001.

EPA, 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual. EPA/540/1-89/002 Office of Emergency and Remedial Response, United States Environmental Protection Agency.

EPA, 1996. Soil Screening Guidance: Technical Background Document. Appendix A. Generic Soil Screening Levels for Superfund. EPA/540/R-95/128. Office of Solid Waste and Emergency Response, United States Environmental Protection Agency, May 1996.

IT, 1989. Soil Sampling and Analysis Plan. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

IT, 1994. Operable Unit V Remedial Investigation/Feasibility Study Work Plan. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

IT, 1997. Operable Unit V Toxicity Testing Study of Peconic River Sediments Report. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

IT, 1998a. Operable Unit V Remedial Investigation Report. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

IT, 1998b. Operable Unit V Feasibility Study Report. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

IT, 2000, Plutonium Contamination Characterization and Radiological Dose and Risk Assessment Report. Prepared by IT Corporation for Brookhaven National Laboratory, Upton, N.Y.

NYSDEC, 1994. Technical Guidance for Screening Contaminated Sediment. New York State Department of Environmental Conservation, July 1994.

SAIC, 1992. Brookhaven National Laboratory Site Baseline Report, Volumes I, II, III, IV. Prepared by SAIC Corporation for Brookhaven National Laboratory, Upton, NY.