From Bob Howe, Deputy Manager, Environmental Restoration Division
The Environmental Restoration Division (ERD) has been a very busy place over the past three months, as the staff has played a major role in the tritium plume investigation while continuing work on several other projects.
In the long term, ERD will have the responsibility for remediating the groundwater plume. The tritium plume has been designated "Area of Concern 29" (AOC 29) and has been incorporated into the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund) process. The Superfund investigation has been going on at the Lab since 1989, when BNL was added to the U.S. Environmental Protection Agency's (EPA) National Priorities List. While the Lab has been looking for contamination for a long time, ERD was created in 1991 to formally carry out the cleanup, and its primary responsibility includes locating and remediating contamination found on- and off-site which could impact human health and the environment. We've been aggressively looking for contamination and we're still finding it.
New area of concern
The plume will be the fifth area to be added to the AOC list since January 1992, when the original 24 were designated in the BNL Site Baseline Report. The last time an area was added was back in 1994, when groundwater contaminated with ethylene dibromide was discovered in an undeveloped area of Manorville just south of the Lab's southern boundary.
The process by which an area is added to the Superfund list is relatively simple. When BNL/ERD or an agency such as the Suffolk County Department of Health Services locates an area of contamination, a determination is made whether the discovery is significant enough for the area to be considered for inclusion in the CERCLA process.
There are situations at BNL where small, accidental spills are immediately cleaned up by Lab personnel (with appropriate regulatory oversight) and do not impact the soil or groundwater. These areas are not included in the CERCLA process.
If it is a significant find, one of the three agencies that are parties to BNL's Interagency Agreement (U.S. Department of Energy, EPA, and N.Y. State Department of Environmental Conservation) writes a letter to the others requesting that the discovery become a new area of concern. If no objection is made by any party within 15 days, the new AOC is created.
Process adds benefits
By designating the tritium plume as an AOC, it enters the normal timeline of the Superfund process. For the public, this a benefit because it gives stakeholders opportunities to participate in review and comment on remediation plans. It is also good for the parties of the IAG overseeing the Lab's cleanup, because it institutes a formal procedure for oversight of the entire remediation process.
The pump-and-recharge system now under construction is being carried out as a time-critical "removal action," and four informational workshops were held in March and April to solicit the public's opinion on this proposed "interim" action. AOC 29 is being included in the ongoing Operable Unit III study, and final remediation alternatives for the tritium plume will be evaluated in the Operable Unit III Feasibility Study, expected to be released in the spring of 1998 for public review and comment.