PB99-963805
EPA541-R99-082
1999
EPA Superfund
Record of Decision:
Brookhaven National Laboratory (USDOE)
OU1
Upton, NY
9/16/1999
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RECORD OF DECISION
OPERABLE UNIT I
AND RADIOLOGICALLY CONTAMINATED SOILS
(INCLUDING AREAS OF CONCERN 6, 8,10,16, 17, and 18)
U. S. DEPARTMENT OF ENERGY
BROOKHAVEN NATIONAL LABORATORY
AUGUST 25,1999
Prepared by
Brookhaven National Laboratory
Environmental Restoration Division
Upton, NY 11973
for
U.S. Department of Energy
Brookhaven Group
Upton, NY 11973
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U. S. DEPARTMENT OF ENERGY
BROOKHAVEN NATIONAL LABORATORY
RECORD OF DECISION
OPERABLE UNIT I
AND RADIOLOGICALLY CONTAMINATED SOILS
(INCLUDING AREAS OF CONCERN 6, 8, 10, 16, 17, and 18)
I. DECLARATION OF THE RECORD OF DECISION
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I. DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
BROOKHAVEN NATIONAL LABORATORY
OPERABLE UNIT I
AND RADIOLOGICALLY CONTAMINATED SOILS
(INCLUDING AREAS OF CONCERN 6,8,10,16,17, and 18)
BROOKHAVEN NATIONAL LABORATORY
UPTON, NEW YORK 11973
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial actions for Operable Unit I, other Areas of
Concern (AOCs) with radiologically contaminated soils and wetland areas with contaminated sediments at
the Brookhaven National Laboratory (BNL) site in Upton, New York. It also serves as documentation for
the final remedy for removal actions that either have been completed or are ongoing.
These remedial actions were selected in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and
Reauthonzation Act of 1986 (hereinafter jointly referred to as CERCLA), and is consistent with the National
Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan), to the extent
practicable. This decision is based on the Administrative Record for the BNL site. The State of New York
concurs with the selected remedial actions.
ASSESSMENT OF THE SITE
Actual or potential releases of hazardous substances including chemical and radioactive materials
from these areas may present a threat to public health, welfare, or the environment if they are not addressed
by implementing the response actions selected in this Record of Decision.
DESCRIPTION OF THE SELECTED REMEDIES
Operable Unit I is one of the six Operable Units at the BNL site. Operable Unit I includes areas
(AOCs 1,2,3, 24E and 24F) where waste was historically managed or disposed of at the site. The main
remaining problem is radiologically contaminated soils and sediment. Remedies for other Operable Units are
or will be, selected in other Records of Decisions. This Record of Decision documents remedies which are
consistent with the overall site cleanup strategy. Remedies have been identified for areas containing
radiologically contaminated soils and sediments, and several other minor Areas of Concern. Removal actions
for some Areas of Concern in Operable Unit I were taken to stabilize environmental problems and accelerate
cleanup. These removal actions are adopted as final actions. The Record of Decision includes a description
of principal contaminants and their representative risks. Cleanup goals have been established to meet
regulatory standards and risk based objectives based on current and future land uses, and are included in this
Record of Decision. The costs for each remedy have been estimated and are also included in this Record of
, Decision.
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The major components of the selected remedies
are:
*"— —
required at the basins to reduce imacts to the Tie "^ mauitena°«
required at the basins to reduce impacts to the eer A
water and sediments will be conduSat ft? wd W™ ^^ mO1Utoring °f Surfkce
•.
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Groundwater contamination associated with the Former Landfill Area (AOC 2) and off-site
groundwater associated with other Operable Unit I AOCs will be addressed in the Operable Unit III Record
of Decision. An evaluation of remedial alternatives for contaminated soil and groundwater associated with
the Brookhaven Linear Accelerator Isotope Producer (BLIP) facility (AOC 16K) is underway. The final
remedy for this AOC will be documented in a subsequent Record of Decision.
DECLARATION
The selected remedies are protective of human health and the environment, comply with federal and
state requirements that are legally applicable or relevant and appropriate to the remedial action, and are cost-
effective. These remedies use permanent solutions and alternative treatment technologies to the maximum
extent practical for this site. However, because treatment of the principal threats of the site associated with
radiologically contaminated soils was not found to be practical, these remedies do not satisfy the statutory
preference for treatment as a principal element.
Since these remedies will result in hazardous substances remaining on-site above health- based levels
for unrestricted use, a review will be conducted every five years after the commencement of remedial action
to ensure that the remedies continue to provide adequate protection of human health and the environment.
George J. Malosh ( Date
Manager, Brookhaven Group
U.S. Department of Energy
Robert P. Gordon Date
Contracting Officer, Brookhaven Group
U.S. Department of Energy
/
Jeanne Fox > />T Dat6
Regional Administrator,/*egion 2
U.S. Environmental Protection Agency
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TABLE OF CONTENTS
I.. DECLARATION OF THE RECORD OF DECISION j
Statement of Basis and Purpose ;
Assessment of the Site j
Description of the Selected Remedies i
Declaration jjj
TABLE OF CONTENTS '.'.'.'.'.'. .iv
LIST OF TABLES vi
LIST OF FIGURES vii
LIST OF ACRONYMS viii
II. DECISION SUMMARY 1
1. SITE NAME, LOCATION, AND DESCRIPTION 1
2. -SITE HISTORY AND ENFORCEMENT ACTIONS 2
2.1 Radiological Contaminated Soil Sites 2
2.2 Other Areas of Concern 2
2.3 Removal Actions 3
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
4. SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION 4
5. SUMMARY OF SITE CHARACTERISTICS 5
5.1 Radiologically Contaminated Soil 5
5.2 Other Areas of Concern 6
5.3 Removal Actions 7
6. SUMMARY OF SITE RISKS 7
6.1 Human Health Risks '. 8
6.1.1 Identification of Contaminants of Concern 8
6.1.2 Assessment of Exposure 8
6.1.3 Assessment of Toxicity 9
6.1.4 Characterization of Chemical Risks •. . .. 9
6.1.5 Characterization of Radiological Risks 10
6.2 Ecological Risk Assessment 10
7. OBJECTIVES OF THE REMEDIAL ACTIONS 1 ]
7.1 Basis for Response 11
7.2 Objectives of the Remedial Actions 12
7.3 Land Use 12
7.4 Cleanup Goals 13
8. DESCRIPTION OF ALTERNATIVES 13
8.1 Radiologically Contaminated Soils 14
8.2 Other Areas of Concern 17
8.2.1 Ash Pit 17
8.2.2 Upland Recharge/Meadow Marsh 18
8.2.3 Recharge Basin HS and the Weaver Drive Recharge Basin HW 18
8.2.4 Wooded Wetland 19
9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
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9-1 Radiologically Contaminated Soils
9.2 Other Areas of Concern .... 19
9.2.1 Ash Pit .'.','.'.'.'.'.'.'.'.".'.'.".'.'.'.'." o?
9.2.2 Upland Recharge/Meadow Marsh Area ' ^
9.3 State and Community Acceptance '"' '
10. SELECTED REMEDIES .'.'.'.'.".".'.'.'.' 24
10.1 Radiologically Contaminated Soils ^f.
10.2 Other Areas of Concern ~5_
10.3 Removal Actions • • . 25
11. STATUTORY DETERMINATIONS ....''.''.......".'.'.''.'' J6
11.1 Protection of Human Health and the Environment 07
11.2 Compliance with ARARs .
11.2.1 Chemical-Specific ARARs os
11.2.2 Location-Specific ARARs ~Q
11.2.3 Action-Specific ARARs "^
11.2.4 To Be Considered Guidance t
11.3 Cost-Effectiveness
11.4 Use of Permanent Solutions and Alternative Treatment Technologies'toYhe" " 3 *
Maximum Extent Practicable *
11.5 Preference for Treatment as a Principal Element ..... -.}
11.6 Documentation of Significant Changes ~
11.7 Five-Year Review "
REFERENCES . 32
TABLES 33
FIGURES 35
III. RESPONSIVENESS SUMMARY ' " " ' 48
TABLE OF CONTENTS .'.'."" •'' **
1. INTRODUCTION '.'.'.'.'.':'"' 56
2. OVERVIEW OF THE RESPONSIVENESS SUMMARY -I
2.1 Site History ^
2.2 Site Description :'' .
2.3 Radiologically Contaminated Soils -0
2.4 Other Areas of Concern -o
2.5 Removal Actions
2.6 Level of Community Support for the Proposed Alternatives /;?
2.7 Changes in the Proposed Plan °
3. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS *
3.1 Community Profile °
3.2 History of Community Involvement
3.3 Summary of Community Participation Activities for OUI /J
4- COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS COMMENTS
CONCERNS, AND RESPONSES ...... CUMMtN l s>
4.1 - Overview
4.2 Summary Questions and Responses
5. RESPONSES TO DETAILED COMMENT LETTERS ' £o
6. CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES -
7. REFERENCES . . /J
SO
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LIST OF TABLES
Table 1 Description of Operable Units at BNL 36
Table 2 Summary of Site History 37
Table 3 Groundwater Standards, Guidance Values and Cleanup Goals for Selected
Parameters 41
Table 4 Soil Remediation Goals for Principal Radiological Contaminants at BNL 42
Table 5 Soil Remediation Goals for Principal Chemical Contaminants at BNL 43
Table 6 Comparative Analysis of Remedial Alternatives for Radiologically Contaminated
Soils 44
Table 7 Summary of Selected Remedies 45
Table 8 Cost-Estimates for Remedial Alternatives 47
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LIST OF FIGURES
Figure 1 BNL Location Map
Figure 2 Record of Decision-Areas of Concern
Figure 3 OUI Areas of Concern
Figure 4 Operable Unit I - RadiologicaJly Contaminated Soils
Figure 5 Actions covered under the OU I Record of Decision
Figure 6 Principal Areas of Contamination within the HWMF
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LIST OF ACRONYMS
ALARA
AOC
ARAR
BLIP
BNL
CERCLA
DOE
EE/CA
EPA
HWMF
LAG
MCL
mg/kg
mrem/yr
NEPA
NYCRR
NYS
NYSDEC
OU
PAH
PCB
PCE
pCi/g
pCi/1
RCRA
RESRAD
SCDHS
SPDES
SVOC
TAGM
TBC
TCA
TCE
ug/1
VOC
As Low As Reasonably Achievable
Area of Concern
Applicable or Relevant and Appropriate Requirement
Brookhaven LINAC Isotope Producer
Brookhaven National Laboratory
Comprehensive Environmental Response Compensation & Liability Act
United States Department of Energy
Engineering Evaluation/Cost Analysis
United States Environmental Protection Agency
Hazardous Waste Management Facility
Jnteragency Agreement
Maximum Contaminant Level
Milligrams per kilogram
Milli rem per year (rem is a measure of human exposure to radiation)
National Environmental Policy Act
New York State Codes, Rules and Regulations
New York State
New York State Department of Environmental Conservation
Operable Unit
Polycyclic Aromatic Hydrocarbon
Polychlorinated Biphenols
Tetrachloroethene
Picocuries per gram
Picocuries per liter
Resource Conservation and Recovery Act
Residual Radioactive Material Guideline Computer Code
Suffolk County Department of Health Services
State Pollutant Discharge Elimination System
Semi-Volatile Organic Compound
NYSDEC Technical Assistance Guidance Memorandum
To Be Considered
1,1,1 -trichloroethane
Trichloroethane
Micrograms per liter
Volatile Organic Compound
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U. S. DEPARTMENT OF ENERGY
BROOKHAVEN NATIONAL LABORATORY
RECORD OF DECISION
OPERABLE UNIT I
AND RADIOLOGICALLY CONTAMINATED SOILS
(INCLUDING AREAS OF CONCERN 6, 8,10,16,17, and 18)
II. DECISION SUMMARY
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II. DECISION SUMMARY
1. SITE NAME, LOCATION, AND DESCRIPTION
near tl?pNL " 'T^ " ^^ Suffolk C^ty, New York, about 60 miles east of New York City
^
Socre H' i Ut °<
550 acres and include an apartment area, Biology Field, Hazardous Waste Manag
Treatment Plant, fire breaks, and the Landfill Area. The terrain is gentlv roll
varying between 40 to 120 feet above sea level. The land
ver watershed' ^ a
The sole-source aquifer beneath BNL encompasses three water-bearing units- the elacial
?Sc^5T^1^f^^
Formation. These units are hydrauhcally connected and make up a single zone of saturation with
varying physical properties extending from a depth of 45-to 1 ,500-Lt below the and
three water-bearing units are designated as a "sole-source aquifer" by the U S
•^ f JyfffJ-V1y manage remediation of the BNL site, 29 Areas of Concern (AOCs) were
identified and d1V1ded into discrete groups called Operable Units (OUs), and Removal Action ^
of Concern. The BNL site is divided into six Operable Units (Table 1 ).
6' 8' !°' 16' 17' ^ 18 as
in Fires u ' ' ' ' ' as °™
m figures 2 through 5. These areas contain radiologically contaminated soils- an ash nit the
SS ™™^W™™Dnvc RechargeBasinHW.theUplandRechargeWearwM'Jsh
and the Wooded Wetland, and areas of concern that have been, or are being addressed as removal
actions.
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2. SITE HISTORY AND ENFORCEMENT ACTIONS
In 1980, the BNL site was placed on New York State's Denamrmnt nf
Conservation (NYSDEC) list of Inactive Hazardous Waste Sites On
site was included on EPA's National Priorities List because of soil and
that resu ted from BNL's past operations. Subsequently, the EPA, NYS«)
a Federal Facilities Agreement (herein referred to as the IAG) that became effective fn May 1 99°
(Adrrnm^auve Docket Number: II-CERCLA-FFA-00201) to coordinate cleanup '
IAG
-- o coornate ceaup a tivfe The
IAG identified areas of concern that were subsequently grouped into Operable Unit, tr hi i t !
" < ~ ^ ac"°ns * *e BNL site ^ b "
CERCL
. A
A Feasibility Study (COM Federal 1999) was prepared to evaluate the altemanVes for
of Decision. In addition, several accelerated cleanup actions were taken as discussed TsTc lion 3
and an intenm action was taken at the Building 650 Sump Outfall Area. The Sump Outfall A^ea was'
fenced off to prevent unnecessary access. P as
2.1 Radiological Contaminated Soil Sites
rarTn ^ *? S6Veral "^ thrOU§hout the BNL site where the soil has become contaminated with
radonuclides from past waste handling operations, spills, or inadvertent use of contSS I wi s
fo±r RaPm/ ( ^ 'L ^ maj°rity °f thC radioacti^y contaminated soils are^ at d a th
former Hazardous Waste Management Facility. These areas are discussed in Table 2.
2.2 Other Areas of Concern
« * rh ^i6 f Trf1^ 0thCr areaS of concem that are bein§ addressed by this Record of Decision They
Ls n Hwtd ?.ech^e/MeadoW Marsh Area, Recharge Basin HS and the Weaver Drive Recharge
Basin HW and Weaver Dnve Recharge Basin, Ash Pit, and the Wooded Wetland A discussion of
these areas is presented in Table 2. uiscussion 01
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2.3 Removal Actions
DOE determined that accelerated cleanup actions, called removal actions, were required for
several areas of concern. The potential removal actions were evaluated in Engineering
Evaluation/Cost Analysis Reports that were prepared pursuant to CERCLA (CDM, 1995a; CDM,
1995b; and CDM, 1997a). These reports were made available for public review and were approved
by the regulatory agencies. The removal actions selected, after considering public comments, were
documented in Action Memoranda (BNL, 1994; BNL, 1996;'BNL, 1997).
Several landfill areas of concern were capped to prevent the migration of contaminations. A
geomembrane cap, constructed pursuant to 6 NYCRR Part 360, was placed over the Current Landfill,
Former Landfill, Slit Trench and Interim Landfill. Construction of the cap was completed in
November, 1995 at the Current Landfill; in October, 1996 at the Former Landfill and Slit Trench; and
in November 1997 at the Interim Landfill. Details are documented in the construction certification
reports (CDM, 1996b; Weston, 1997; and Grosser, 1997). The National Weather Service's soil
stockpile was used as fill on the Former Landfill before placement of the cap. A 55-gallon drum
containing soil with levels of radionuclides greater than cleanup levels is stored at the former HWMF
awaiting off-site disposal.
Contaminated soil, debris, animal remains, laboratory equipment, and intact chemical bottles
were excavated and segregated for treatment and/or disposal from the Chemical/Animals Pits and
Glass Holes. Soil samples were taken at each pit to ensure that all hazardous materials were removed
and cleanup levels were met.
Several actions are being taken to address groundwater contamination resulting from waste-
disposal activities at the former HWMF and the Current Landfill. A groundwater pump- and-treat
system was installed in December 1996 at BNL's southern boundary to extract and treat on-site
groundwater contaminated with Volatile Organic Compounds (VOCs) downgradient of
OUI source areas. The groundwater is recharged upgradient into a recharge basin. Groundwater in
this area is being monitored. Institutional controls will prevent supply wells or other pumping wells
being installed that may mobilize remaining contaminants or otherwise interfere with the remedial
actions. Groundwater contamination associated with the Former Landfill, and contaminated
groundwater that has migrated off-site will be addressed in the remedies for Operable Unit III.
These removal actions are being adopted as final actions in this Record of Decision. They will
be monitored and maintained.
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan was finalized for the BNL site in September, 1991. In accordance
with this plan and CERCLA Sections 113 (k) (2)(B)(I-v) and 117, the community relations program
focused on public information and involvement. A variety of activities provide information and seek
public participation, including a stakeholders' mailing list, community meetings, availability sessions,
site tours, workshops, and fact sheets. An Administrative Record was established, documenting the
basis for selecting the removal and remedial actions at the BNL site, and it is maintained at the local
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libraries listed below. These libraries also maintain current site-reports, press releases, and fact
sheets. ' 4flk
Longwood Public Library
800 Middle Country Road
Middle Island, NY 11953
•ft
Mastics-Moriches-Shirley Community Library
301 William Floyd Parkway
Shirley, NY 11967
BrooJchaven National Laboratory
Research Library
Bldg. 477A
Upton, NY 11973 .
The Administrative Record also is kept at EPA's Region II Administrative Records Room 290
Broadway, New York, NY, 10007-1866. xwu«i,«u
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, the engineering
evaluation/cost analysis documents for the removal actions, risk-assessment documents, remedial A
investigation reports, the proposed plan, and the feasibility study were made available for public ™
review. *
/™ T^JS6?*communitv involvement activities included the review of the OUI Feasibility Study
(COM, 1999a) and Proposed Plan (BNL, 1999). In April 1999, a public notice was published in
NewsdayandSuffolkLifeaimouncingtheavailabilityforreviewandcommentoftheOUIFeasibili^
Study and Proposed Plan, dares of information sessions, and a public meeting date. A Press Release
also was issued. Public comment began April 1,1999 and ended on April 30,1999. AmaiJingwas
sent to the Community Involvement mailing list (2300 homes) which included a fact sheet on the
Feasibility Study and Proposed Plan and a copy of the public notice. Information sessions were held
°u f ™ r' 1999andAPril 14> 1999, andapubHc meeting was held on April 22,1999. An article
about OU I was published in BNL's quarterly newsletter cleanupdatt in December, 1999, and an
article was published in the Brookhaven Bulletin in April 1999. Display advertisements listing the
f £,? , •* PU71C commem Period. information sessions, and the public meeting were placed in
Suffolk Life and Newsday. =. r
4. SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION
To adequately evaluate existing and potential environmental problems at BNL the 29 areas of
concern were grouped into six Operable Units. The scope of these Operable Units is shown in
Table 1. The Operable Units were established under the Response Strategy Document (S AIC, 1992)
based on six criteria: (1) relative proximity of the areas of concern, (2) similar problems, (3) similar
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phases of action or sets of actions, (4) simultaneous actions, (5) absence of interference with future
actions, and (6) similar geology and hydrology.
This Record of Decision selects remedial actions for OUI and areas of concern 6, 8,10,16, 17,
and 18. Radiologically contaminated soil is the principal threat addressed. The majority of the
radiologically contaminated soil containing the highest contaminant levels is located at the former
HWMF. Radiologically contaminated soil poses a risk to human health and ecological receptors from
exposure to waste-site contaminants and from the potential for contaminants to migrate to surface
water, wetlands, and groundwater.
The Upland Recharge/Meadow Marsh Area requires action to address the potential threat to
the Tiger Salamander from chemical contaminants (i.e. metals) in these areas. The Tiger Salamander
is a New York State endangered species. The Wooded Wetland will be monitored to assure that
remnant contaminants from the Current Landfill will not contaminate the wetland. The principal
threat at the Ash Pit is human, expo sure to lead in soil.
The completed and ongoing removal actions address on-site Volatile Organic Compounds in
groundwater and buried wastes in landfills. Groundwater contamination associated with the Former
Landfill Area (AOC 2) and off-site groundwater associated with other Operable Unit I AOCs will be
addressed in the Operable Unit III Record of Decision.
Conducting this remedial action under OU I is part of BNL's overall response strategy and is
expected to be consistent with any planned future actions and actions taken at the other Operable
Units, which are at different phases of the CERCLA process.
5. SUMMARY OF SITE CHARACTERISTICS
The following sections summarize the site characteristics of the various areas of concern
addressed by this Record of Decision. Various investigations were undertaken to evaluate the nature
and extent of contamination. A combination of investigation approaches were utilized including (1)
radiation surveys, (2) soil-vapor surveys, (3) soil borings/soil sampling, (4) monitoring well
installation and groundwater sampling, (5) groundwater modeling, (6) sediment/surface water
sampling, and (9) geophysical investigations. The areas investigated were the landfills, Ash Pit,
Chemical/Animal Pits and Glass Holes, the former Hazardous Waste Management Facility, the Waste
Concentration Facility, Reclamation Facility and other areas of concern. Information on the site's
characteristics also was obtained through implementing of the various removal actions.
5.1 Radiologically Contaminated Soils
The former Hazardous Waste Management Facility Area of Concern contains the majority of
the radioactively contaminated soil. The soil became contaminated with radionuclides and mercury
due to several spills of hazardous and radioactive materials during operations at the facility. The
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predominant radionuclide found is cesium- 137, which emits beta- and gamma-radiation, and is the
primary source of risk from direct exposure. Strontium-90, which emits beta radiation, also is
present. Both radionuclides are relatively short-lived, with half-lives of 30-and 28-years, respectively.
The maximum levels detected during remedial investigations was 810,000 picocuries per gram
(pCi/g) for cesium-137, and 1,300 pCi/g for strontium-90.
Most of the contamination in this area is at, or near, the surface, although in some locations it
extends to 12 feet below the surface. Approximately 35,000 cubic yards of contaminated soil is
anticipated to require remediation at the former Hazardous Waste Management Facility out of a total
of 39,500 cubic yards for all radiologically contaminated sites. Figure 6 illustrates the principal areas
of surface contamination, and relative concentrations within the facility, based on radiation surveys
and surface-soil sampling. There is no significant widespread chemical contamination of soil within
the former Hazardous Waste Management Facility, except for isolated locations where low
concentrations of mercury of 184 mg/kg (maximum concentration), lead (maximum concentration
of 429 mg/kg) and other metals were detected. Mercury and lead are the only chemical constituents
present that require remedial action.
Radiological contaminated surface soils also were found at several locations throughout the site
(AOC 16, 1 7, and 1 8). The contamination resulted from the use, handling, and storage of activated
materials or the use of slightly contaminated landscaping soil. Soils contaminated with low levels
of radionuclides from the former Hazardous Waste Management Facility were inadvertently used as
landscaping material outside several buildings. The dominant radionuclide found in these locations
is cesium-137, with a maximum concentration of 348 pCi/g at AOC 16E (near building 490). One
area (AOC 1 6 S.3) contained elevated lead at 2,3 1 0 mg/kg.
The soils at the Waste Concentration Facility became contaminated with radionuclides as a
result of leaks from a tank. The primary contaminants are cesium-137, with a maximum
concentration of 1,486 pCi/g and strontium-90 with a maximum concentration of 454 pCi/g.
Radionuclides were detected in soil samples to a depth of 12 feet. There are no chemical constituents
present that require remedial action. In addition to soils, the Waste Concentration Facility includes
liquid-waste transport lines and an enclosed concrete vault. The above-ground 'D' tanks have been
removed in a separate removal action. However, six underground tanks containing radioactive sludse
=
remain.
The Reclamation Facility (Building 650) was used to decontaminate radiological- contaminated
clothing and equipment. Soils near this facility and the sump-outfall area have become contaminated
from the activities conducted at this facility. Several radionuclides exceed the soil cleanup goals.
Table 2 identifies the primary contaminants of concern and the maximum concentrations.
5.2 Other Areas of Concern
The Ash Pit, which received ash and slag from a solid-waste incinerator, contains lead above
cleanup goals. Radionuclides were detected at background levels. The Upland Recharge/Meadow
Marsh Area contains low levels of pesticides and metals. The Recharge Basin HS and the Weaver
Drive Recharge Basin HW that receive stormwater effluent operate in accordance with a New York
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State Pollution Discharge Elimination System permit. No contaminants were found at levels that
would impact public health; however, Tiger Salamanders, a New York endangered species, have been
found in both basins. The Wooded Wetland received drainage from the Current Landfill containing
metals below levels of-concern for human health.
5.3 Removal Actions
Groundwater beneath the Current Landfill and the former HWMF is contaminated with
radionuclides, Volatile Organic Compounds, and metals above maximum contaminant levels (MCLs).
The currently operating pump and treat system described in Section 2 is removing the Volatile
Organic Compounds. The portion of the plume that has moved off-site will be addressed in the OU
III Record of Decision.
The contaminants of concern that were dealt with by capping the Current and Former Landfills
are identified in the Landfills Engineering Evaluation/Cost Analysis Report (CDM, 1995a). The
Chemical/Animal Pits and Glass Holes, which were excavated in 1997, contained buried wastes and
low levels of solvents, metals, and radionuclides that required remediation. These areas are
summarized in Table 2.
6. SUMMARY OF SITE RISKS
The risks associated with the Chemical/Animal Pits and Glass Holes were considered through
Engineering Evaluation/Cost Analysis process. Risk assessments are not given for the landfill
removal actions which are presumptive remedies. Risk assessments were conducted for several areas
of radiologically contaminated soils, groundwater and other areas of concern.
A four-step process was used for assessing site-related human-health risks within a reasonable
maximum exposure scenario:
• Hazard Identification - identifies the contaminants of concern based upon factors such
as toxicity, frequency of occurrence, and concentration.
• Exposure Assessment - estimates the magnitude of actual and potential human exposures,
the frequency and duration of these exposures, and the exposure pathways (e.g., external
exposure from gamma radiation of contaminated soil, ingestion of contaminated well
water).
• Toxicity Assessment - determines the types of adverse health effects associated with
exposures, and the relationship between the magnitude of exposure (dose) and severity
of adverse effects (response).
• Risk Characterization - summarizes and combines outputs of the exposure-and toxicity -
assessments to quantify site-related risks.
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Human health nsks were evaluated for exposures to radiological and chemical contaminants
of concern. The chemical Risk Assessment addressed the risk of cancer and non-carcinogenic toxicity
The health risk of concern from radionuclides is cancer. Current federal guidelines for acceptable
exposures are: 1) an individual lifetime excess carcinogenic risk in the range of a one-in-ten-thousand
(1x10 ) to one in-a-million (IxlO'6), and 2) a maximum health Hazard Index equal to 1 0 which
reflects non-carcinogenic effects. A Hazard Index greater than 1.0 indicates a potential for
non-carcinogenic health effects. For radiological risks, EPA's guidance of 15 mrem/yr exposure is
consistent with the acceptable risks range (EPA, 1997).
6.1 Human Health Risks
6.1.1 Identification of Contaminants of Concern
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 2 identifies the primary contaminants of concern.
6.1.2 Assessment of Exposure
Present and potential future-use scenarios were quantitatively evaluated for the following M^
receptor populations: (•
• Present Area Residents (chemical and radiological exposure to trespassers)
• Present and Future Open Space (radiological)
Future Residents (radionuclides and chemicals)
Present and Future Industrial Workers (radionuclides and chemicals)
Future Construction Workers (radionuclides and chemicals).
The areas evaluated included:
• Former HWMF (chemicals)
Building 650 Sump Outfall (radionuclides)
• Ash Pit (radionuclides and chemicals)
Recharge Basin HS and the Weaver Drive Recharge Basin HW (radionuclides and
chemicals)
-Upland Recharge/Meadow Marsh (radionuclides and chemicals)
Ti'OUIROD'oulroda.upd 6122199
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The environmental media evaluated in the risk assessment, as applicable to specific areas, land
use scenarios and exposure pathways included:
Surface soil
Subsurface soil
• Groundwater
Surface Water
Sediment
6.1.3 Assessment of Toxicity
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
chemical carcinogenic slope-factors and reference doses used were obtained from EPA's Integrated
Risk Information System data base. Those not available in that data base were obtained from EPA's
second most current source of toxicity information, Health Effects Assessment Summary Tables.
Radiological slope-factors developed by EPA were used to assess radiological risks. The potential
health hazards from exposure to non-carcinogens was determined by comparing the estimated chronic
or subchronic daily intake of a chemical with the risk reference dose. When toxicity values were not
available for a specific chemical, its effects were qualified. Uncertainties in the toxicity data were
evaluated.
6.1.4 Characterization of Chemical Risks
For carcinogenic chemical contaminants, only groundwater presented an unacceptable risk.
For the OUI/VI ethylene dibromide (EDB) plume, future residential carcinogenic risks were 2.7 x
10"4 (2.7 in 10,000) for adults and 1.6 x 10"4 for children for groundwater ingestion and were largely
due to ethylene dibromide. The 30-year combined risk for adults and children was 4.3 x 1O"4. For the
former HWMF/Current Landfill Plume, the 30-year combined risk for adults and children for future
residential ingestion was 1.6 x 10"4. The principal risk drivers for this plume were ethylene
dibromide, 1,1-dichloroethylene, vinyl chloride, arsenic and beryllium.
For non-carcinogenic chemical contaminants in groundwater, hazard index values for adult and
child ingestion of groundwater from the former HWMF/Current Landfill plume were 2.6 and 6.1 and
were due primarily to manganese and thallium. The hazard index value for child ingestion of
groundwater from the OU I/VI EBD plume was 1.2 and was due primarily to the presence of
manganese.
Accelerated actions were taken to address these plumes. A pump-and-treat system was installed
to treat VOC-contaminated groundwater from the former HWMF/Current Landfill Plume and is
contained in this Record of Decision. The OU I/VI EDB plume was addressed in a separate focused
feasibility study and Record of Decision.
For non-carcinogenic chemical contaminants in surface soils, a hazard index of 3.6 was
calculated for future soil ingestion by children and was due primarily to mercury. Concentrations of
T.'OUIROD'.cmlroih.wpd 6.O2/99 9
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To™ •
6.1.5 Characterization of Radiological Risks
Risks from exposure to surface soils contaminated with radionuclides were calculated for the
Reclamation Facility (Building 650) Sump and Outfall Area (CDM, 1994). Only the risk estimates
for potential future residents (combined adults and children) exceeded EPA's target risk ranee in both
areas with a maximum risk of risk of 4.3 x 10'3 (4.3 in 1,000) (or 5.3 x 10"' when alpha activity is
assumed to measure uranium-23 5). The risk was due almost entirely to the external gamma radiation
pathway with the major contributors being cesium-137 and uranium-?35 Usins the higher
concentrations found in the May 1994 sampling, the future residential risk was about one orde°r of
!TStnc5id! hlgher' 'f'fn th£ 10"'t0 10'2 (1 in 10 t0 l in 100) ran§e- ^fcto on-si* workers usin-
the 1994 data was also one order of magnitude higher. °
Radiological risks at theformer HWMF were not calculated because this facility is a restricted
area and an active handling facility for hazardous and radioactive wastes (CDM, 1996a) Levels of
contamination in soils were high and remediation was assumed to be required Current public access
and exposure to contaminants in this area is not realistic since there are stringent institutional controls
restricting access for the foreseeable future. A radiological worker protection program and
procedures protect current site workers. Since concentrations of contaminants in soil are greater at
the former HWMF than at the Reclamation Facility, potential future residential risks would also be
greater at the former HWMF than the risks described above at the Reclamation Facility.
Radiological risks for AOCs 10, 16, 17 and 18 were evaluated by comparing contaminant
concentrations to cleanup levels developed using a future residential land use and EPA's cleanup goal
of 15 mrem/yr. (IT, 1999) AOC 10 and six of the AOC 16 sites were above the 15 mrem/yr goal for
future residential land use. AOCs 17, 18 and the remaining sites from AOC 16 were below the 15
mrem/year goal for future residential land use. Risks to current site workers and the public at these
areas are controlled by institutional controls, such as fencing, where needed.
Post remediation risks at all areas of concern will meet EPA's acceptable risk range.
6.2 Ecological Risk Assessment
A standard ecological risk assessment (as prescribed by the EPA) consists of a four-step process
used for assessing ecological risks for a reasonable maximum exposure scenario:
• Problem Formulation - evaluates a contaminant's release, migration and fate; identifies
contaminants of concern, receptors, exposure pathways, and known ecological effects of
the contaminants; and, selects endpoints for further study.
• Exposure Assessment - quantifies the release, migration, and fate of the contaminant;
characterizes exposure pathways and receptors; and measures or estimates exposure-point
concentrations.
T,OUlRODoulroda.wpd 6,72/99 10
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1
Ecological Effects Assessment-reviews literature,
contaminants' concentrations to effects o
Risk Characterization - estimates current and future adverse effects.
A Preliminary Ecological Risk Screening was performed (COM 1996^ n, f A -^ J .
no^ctr^
TT i j n , „ ' um&c D^m ni> weaver Dnve Recharpp Racir, tn*7 j t_
Upland Recharge/Meadow Marsh Area due to the ores f , ;_. narge Basin HW> and the
endangered species in New York State. ^^ ° * £ Salamander which is an
The Focused Ecological Risk Assessment and Addendum CCDM 1 QQQ* ™A ^ oom^
potential toxicity risks to the Tiger Salamander in these areas of concern The ™ X eval,uated
that there was an exnn^nn* n'cir ooo^ • * ^ -*u - «^ciii. me assessment concluded
«-ui VAJ^UOUIC iiisK. associaieQ ^vltn various mptal^ "fXt- lot-tf^i ««T j ...
^aiSBfiSBSS-SKfi^S^'-?
830 to 2V hnth ^ 7 ^ 9? data Sh°wed a reduction in the hazard index from
iu ^.j, uuui were aue pnmanly to aluminum The Current r anrif;n ~~ • j •
impacts from leachate from fte cien, LandfiU on thTs wSSd P * deS'gned l° redUCe
7. OBJECTIVES OF THE REMEDIAL ACTIONS
ssSSsS^^^^-awasai
screening evel guidance. Cleanup levels for radionuclides used the industrial land use t i
contained in Table 4. These cleanup levels meet EPA's acceptable risk r^ge ^
7.1 Basis for Response
The actual or threatened releases of hazardous substances from OUI mav
and substantial endangerment to public health, welfare or the environment if th
by implementing the remedial actions selected in this Record of Decision Tl
T:'.OU 1 ROD'oulrodi.«pd 6,~ll:<
11
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cesium-137 in the soil. There also is the potential for strontium-90 to migrate from the soil into the
underlying sole-source aquifer.
7.2 Objectives of the Remedial Actions
The following objectives for remedial action were established for the radioloeicallv
contaminated soils and other areas of concern:
Minimize threats to human health and the environment from site contaminants
Prevent or minimize the leaching of contaminants (chemical and radiological) from the
soils into the underlying sole-source aquifer (Upper Glacial Aquifer) caused by the
infiltration of precipitation,
Prevent or minimize the migration of contaminants (chemical and radiological) present
in surface soils via surface runoff and windblown dusts,
Prevent or minimize human exposure including direct external exposure ineestion
inhalation, and dermal contact (for future residents, trespassers, site workers and
construction workers) and environmental exposure to contaminants (chemical and
radiological) in the surface and subsurface soils,
Prevent or minimize the uptake of contaminants (chemical and radiological) present in
the soils by ecological receptors.
7.3 Land Use
Specific cleanup goals (i.e. acceptable contaminant levels) have been identified to achieve the
objectives identified above. Cleanup goals are based primarily on Applicable or Relevant and
Appropnate Requirements (ARARs), EPA and State guidance in combination with an evaluation of
land use. BNL is currently used by DOE as a research facility with associated support facilities and
is expected to remain so for the forseeable future. Access to the BNL site is currently restricted and
controlled.
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. ' For the purposes of developing
radionuclide cleanup goals for OU I, a future industrial use was assumed for the former HWMF as
opposed to the recreational and open space uses identified in the 1995 study, to give greater flexibility
for potential future uses. A future residential use was identified in the OU I Feasibility Study for
AOCs 6, 10, 16, 17 and 18 even though these AOCs are in the developed portion of BNL This
approach was take'n since the volumes of contaminated soil are smaller and it is cost effective to use
a lower cleanup level. This will also allow greater flexibility in future uses at these AOCs.
An institutional control period of 50 years was also assumed. This is the time period after
which BNL might be available to the public for use.
T.^OUIROD'oulroda.wpd 6/21-99 12
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7.4 Cleanup Goals
The cleanup goal or level established for radionuclides in soil is based on a total dose limit of
15 mrem/yr above background (EPA, 1997). EPA's acceptable risk range will also be met upon the
completion of remedial action. Cleanup levels for specific radionuclides were calculated using the
DOE Residual Radioactive Material Guidelines (RESRAD) computer code, 15 mrem/yr, the assumed
future land use and 50 years of continued DOE control. Examples for cesium-137 are siven in Table
4. The potential for the contaminated soil to impact groundwater is also considered. A cleanup level
for strontium-90 was calculated based on potential impacts to groundwater and is also listed in Table
4. This level is also protective of both residential and industrial uses. A 5 pCi/g cleanup level was
also selected for radium-226 based on DOE Order 5400.5. This level is also commonly used by EPA.
Post remediation sampling and dose assessments will be performed to ensure that the 15 mrem/year
limit will be met for all radionuclides that remain. The NYSDEC guidance of 10 mrem/yr above
background has been adopted as an As Low As Reasonably Achievable (ALARA) goal which will
be considered during the design and construction phase.
While radionuclides are the primary contaminants of concern in soils, some chemical
contamination also exists. Chemical cleanup levels are listed in Table 5. A cleanup level of 1.84
mg/kg for mercury was selected for the former HWMF. This level was calculated using EPA's soil
screening level guidance (OSWER 9355.4-23) and is protective of groundwater and a residential use.
A cleanup level of 400 mg/kg for lead was also selected for the Ash Pit, the former HWMF and AOC
16 S.3 based on EPA's soil screening level guidance. This level is protective of a residential use.
Cleanup goals for groundwater contaminants are based on an evaluation of Federal and State
MCLs and groundwater standards (Table 3). Groundwater treatment will continue until either the
cleanup goals are met in the groundwater or the following performance objective is met. If
monitoring indicates that continued operation of the groundwater treatment system is not producing
significant reductions in the concentrations of contaminants in the groundwater and concentrations
are still above the cleanup goals listed in Table 3, then DOE, NYSDEC and EPA will evaluate
whether operation of this system can be discontinued in accordance with the National Contingencv
Plan (NCP). The criteria for discontinuation will include an evaluation of the operating conditions
and parameters as well as a determination that the groundwater system has attained the feasible limit
of contaminant reduction and that future reductions would be impractical.
8. DESCRIPTION OF ALTERNATIVES
Section 121 of CERCLA requires that each selected 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 way of reducing the toxicity,
mobility, or volume of the hazardous substances.
This section summaries the remedial alternatives evaluated for the radiologically contaminated
soil sites and other areas of concern addressed by this Record of Decision. Details of the alternatives
are given in the Final OU I and Radiologically Contaminated Soils Feasibility Study Report (CDM.
T'OUIROD'.oiilroda.wpd 6/:2.99 13
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1999a). Several technologies, in addition to those described below, were evaluated and screened from
further consideration. Technologies that include processes such as chemical separation,
encapsulation, chemical treatment, and phytoremediation, were considered not to be effective.
To evaluate remedial alternatives, information is needed related to future land use and the
cleanup standards. For all areas except the former HWMF, residential land use and corresponding
cleanup goals, as identified in Section 7, were assumed. Industrial land use cleanup goals were
assumed for the former HWMF (Section 7). For some of the alternatives evaluated where
contaminated soils will be left on-site, it was necessary to set a secondary action level to determine
which soil may require additional treatment or disposal (the principal threat was waste). Cesium-13 7
was the primary radiological contaminant for all the soils; therefore, the secondary action level is
based on this constituent. In the event that institutional controls failed and an inadvertent intruder
built a dwelling near to the radiological soil left on-site (e.g., above a capped or engineered cell), the
secondary-action level would ensure that the exposure to this waste was not in excess of 75 mrern/yr.
Based upon these considerations, this secondary-action level was set at 600 pCi/g of cesium-137*.
To estimate costs for the alternatives presented below, assumptions about the institutional
control period were developed. This period is assumed to be 100 years, except for radiological
contaminated soil alternative 4, where a 50-year institutional control period is assumed. Other
common elements for the radiplogically contaminated soil alternatives include reconstructing the
former HWMF wetland after remediation for all alternatives except alternative 1. Structures (such
as pipes, foundations, and tanks) at the Reclamation Facility ( Building 650 Sump and Outfall Area)
and the Waste Concentration Facility will also require removal to access the contaminated soils.
Some buildings at the former HWMF also must be removed to gain access to contaminated soils.
8.1 Radiologically Contaminated Soils
Alternative 1: No Action with Monitoring and Institutional Controls
Capital Cost: $ 52,000
Annual Operation &Maintenance (O&M) Cost: $55,513
Total O&M Cost (present worth): $792,000
Total Present Worth: $844,000
Under the "No Action" alternative, no remedial action would be taken and the sites would
continue in their current state except that a fence would be installed around the former HWMF
wetland. Groundwater monitoring and surface-water sampling would be conducted in certain areas.
The existing institutional controls would remain in place.
Alternative 2: Engineered Cell. Monitoring and Institutional Controls
Capital Cost: $7,487,000
Annual O&M Cost: $ 81,380
Total O&M Cost (present worth): $1,161,000
Total Present Worth: $8,648,000
T'OUIRODJ.oulro
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This alternative includes excavating all of the radiologically contaminated soils exceeding the
soil cleanup goals, staging most of the soils at the former HWMF, constructing an engineered cell
which includes a leachate collection and removal system, a composite cover, placing the contaminated
soils in the engineered" cell and covering the area with a composite cover. Approximately 35,000
.cubic yards of soils from the former HWMF and approximately 3,450 cubic yards of soils from the
other radiologically contaminated areas would be excavated that are above soil cleanup levels in
Table 4, and disposed in the cell. Soils contaminated with long half-life radionuclides from the
Reclamation Facility (Building 650) Sump and Outfall Area (approximately 1,040 cubic yards) would
be excavated and disposed off-site. Long-term monitoring of the cover and groundwater would be
conducted along with maintaining of the cover. Institutional controls would be put hi to place to limit
access to the site, to ensure that the cover is not disturbed, and to prevent the installation of drinking-
water wells in contaminated groundwater.
Alternative 3: Moderate Excavation. Off-Site Disposal and RCRA Cap
Capital Cost: $14,005,000
Annual O&M Cost: $ 63,710
Total O&M Cost (present worth): . $ 909,000
Total Present Worth: $14,914,000
Alternative 3 involves excavation and off-site disposal of all soils over the secondary action
level (600 pCi/g of cesium-137) at the former HWMF. Approximately 14,585 cubic yards of soil and
debris will be excavated and disposed off-site. A Resource Conservation and Recovery Act (RCRA)
cap will be constructed over the former HWMF soils that are below the secondary action level
(19,490 cubic yards). Soils contaminated above the soil cleanup levels with cesium-137 and/or
strontium-90 from other areas (approximately 3,450 cubic yards) will be excavated and consolidated
under the RCRA cover at the Former HWMF. Approximately 1,040 cubic yards of soils
contaminated with long half-life radionuclides from the Reclamation Facility (Building 650) Sump
and Outfall Area will be disposed at an off-site facility. Long-term monitoring of the cover and
groundwater would be conducted, and the cover maintained. Institutional controls would be put in
to place to limit access to the site, to ensure that the cover is not disturbed, and to prevent the
installation of drinking water wells in contaminated groundwater.
Alternative 4: Large Scale Excavation and Off-Site Disposal
Capital Cost: $23,615,000
Annual O&M Cost: $ 45,470
Total O&M Cost (present worth): $ 417,000
Total Present Worth: $24,032,000
Alternative 4 involves excavating of contaminated soils above cleanup goals (industrial goals
for former HWMF and residential goals for other areas) and off-site disposal, and monitoring the
remaining contaminated soils. A 50-year institutional control period is assumed for cost estimating
purposes. Approximately 39,500 cubic yards of contaminated soils would be excavated and staged
at the former HWMF. Certain waste Will likely required pretreatment (e.g., stabilization.
T. OU I ROD' on I roda.wpd 6-12,99 15
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solidifcation) to meet the waste acceptance criteria at the disposal facility. Groundwater monitoring !•
would be conducted in specific areas. Institutional controls would be put in to place to ensure that
land uses remain protective of human health, limit access to the site, to ensure that the cover is not
disturbed, and to prevent the installation of drinking water wells in contaminated groundwater.
Alternative 5: Moderate Excavation. Soil Washing. Off-Site Disposal and RCRA Cap
Capital Cost: $14,395,000
Annual O&M Cost: $ 63,710
100 year O&M Cost (present worth): $ 909,000
Present Worth: $15,304,000
Alternative 5 is identical to Alternative 3 in scope, except that all excavated soils with
concentrations of radionuclides greater than the secondary action levels (600 pCi/g of cesium-13 7)
and less than 2,800 pCi/g of cesium-137 would be washed on-site to reduce the volume of
contaminated material that is shipped off-site for disposal. Approximately 6,030 cubic yards of soil
would be washed.
The approximately 24,490 cubic yards of soil below the secondary action level of 600 pCi/g of
cesium-137 but above the soil cleanup level of 67pCi/g of cesium-137, together with clean soil from
the treatment process, will be consolidated at the former HWMF and capped with a RCRA cap, as
described in Alternatives.
With this alternative, approximately 11,404 cubic yards of material will be disposed off-site.
Long-term monitoring of the cover and groundwater would be conducted, along with maintenance
of the cover. Institutional controls would be put in to place to limit access to the site, to ensure that
the cover is not disturbed, and to prevent the installation of drinking-water wells in contaminated
groundwater.
Alternative 6: Moderate Vitrification and RCRA Cap
Capital Cost: $ 18,645,000
Annual O&M Cost: $ 65,710
100-year O&M Cost (present worth): $ 909,000
Present Worth: $19,554,000
Under Alternative 6, soils from the former HWMF with concentrations greater than the
secondary action level of 600 pCi/g cesium-137 (approximately 14,585 cubic yards) and
approximately 1,040 cubic yards of contaminated soil with long-lived radionuclides from the Building
650 and the Sump Outfall would be treated by vitrification followed by geomembrane capping. All
other soils contaminated above the cleanup goal, but below the secondary action level, would be
consolidated at the former HWMF under a geomembrane cap. Long-term monitoring of the cover
and groundwater would be conducted along with maintenance of the cover. Institutional controls
would be put in to place to limit access to the site, to ensure that the cover is not disturbed, and to
prevent the installation of drinking water wells in contaminated groundwater.
T OUI ROD'on I rndaivpd 6/2199 16
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8.2 Other Areas of Concern
8.2.1 Ash Pit
Three alternatives were evaluated for the Ash Pit (AOC 2F).
Alternative 1: No Action with Monitoring
Capital Cost: $ Q
Annual O&M Cost: $ 2 000
50-year O&M Cost (present worth): $ 99*000
Present Worth: $ 29,'oOO
Under the first alternative, no further action would be taken and the Ash Pit would be left in its
current status. Long-term monitoring (visual observation of the Ash Pit). A 50-year institutional
control period is assumed for cost estimating purposes.
Alternative 2: Soil Cover
Capital Cost: $ nim
Annual O&M Cost: $ 2 000
50-year O&M Cost (present worth): $ 29^00
Present Worth: $ 146j'000
For the second alternative, the Ash Pit would be covered with a 12-inch layer of soil in
accordance with EPA guidance. The Ash Pit would be visually inspected to ensure that ash is not
exposed at the surface. Institutional controls would be put in place to limit access to the site and
prevent disturbance of the soil cover. A 50-year institutional control period is assumed for cost
estimating purposes.
Alternative 3: Excavation with Off-site Disposal
Capital Cost: $ 3,197,000
O&M Cost: $ o
Present Worth: $ 3,197,000
Alternative 3 would involve excavating and disposing of the 13,960 cubic yards of ash off-site
The area would be backfilled and a portion of the road impacted during remedial construction
activities would be replaced.
T.-OU I ROD oul-roda wpd 6/22/99 17
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8.2.2 Upland Recharge/Meadow Marsh
For the two artificial basins at the Upland Recharge/Meadow Marsh Area, the following three
remediation alternatives were evaluated to protect the Tiger Salamander:
Alternative 1: No Action with Monitoring
Capital Cost: $ 0
Annual O&M Cost: $ 3,000
50-year O&M Cost (present worth): $ 44,'oGO
Present Worth: $ 44,'oOO
Under the first alternative, no further action would be taken and the current status of the ponds
will remain. Long-term ecological monitoring would be performed.
Alternative 2: Excavation with On-Site Disposal and Reconstruction of the Wetlands
Capital Cost: $ 184,000
Annual O&M Cost: $ 3^000
50-year O&M Cost (present worth): $ 44^000
Present Worth: $ 228*000
Under the second alternative, water would be removed from the ponds (if necessary) and
transported to the BNL wastewater treatment plant, the sediments (1,270 cubic yards) and plastic
liners (42 cubic yards) would be removed and placed in an approved on-site clean-fill site. The ponds
then would be restored as a wetland. Long-term ecological monitoring would be performed.
Alternative 3: Excavation with Off-site Disposal and Reconstruction of the Wetland q
Capital Cost: $ 398,000
Annual O&M Cost: ' $ 3^00
50-year O&M Cost (present worth): $ 44,000
Present Worth: $ 442,'oOO
Under the third alternative, water would be removed from the ponds (if necessary) and
transported to the BNL wastewater treatment plant, the sediments (1,270 cubic yards) and plastic
liners (42 cubic yards) would be removed and disposed of off-site at an approved landfill. The ponds
would then be restored as a wetland. Long-term ecological monitoring would be conducted.
8.2.3 Recharge Basin HS and the Weaver Drive Recharge Basin HW
Alternatives were not evaluated for the Recharge Basin HS and the Weaver Drive Recharse
Basin HW because they are operated and monitored according to NYSDEC permits. The basins
would continue to be operated, maintained, and monitored in accordance with permit requirements
and in a manner to reduce negative impacts to Tiger Salamanders. A Tiger Salamander Habitat
T-OUIRODoiilroJa.upd 6.^2«)9 IS
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Management Plan will be prepared in coordination with the NYSDFr ,« A u •
routine maintenance of the basin NYSDEC to reduce the ,mPacts of
routine maintenance of the basins on the animal.
8.2.4 Wooded Wetland
9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
(a) Threshold criteria that relate directly to statutory findings and must be satisfied bv each
"" °f h™° -" Ch
(b) Primary balancing criteria that include lone-
j-Pi-entabiliV; reduction of toxiciry, mobility,
™*"'"
^
9.1 Radiologically Contaminated Soils
soils: Th£ f°IIOWing Sk remedial aItematiVeS W6re C°nSidered for the radiologically contaminated
Alternative 1 : No Action with Monitoring and Institutional Controls
Alternative 2: Engineered Cell, Monitoring, and Institutional Controls
Alternative 3: Moderate Excavation, Off-Site Disposal, and RCRA Can
Alternative 4: Large Scale Excavation and Off-Site Disposal
- Alternative 5: Moderate Excavation, Soil Washing, Off-Site Disposal, and RCRA Cap
Alternative 6: Moderate Vitrification and RCRA Cap P
Table 6 summarizes the comparative analysis.
Overall Protection
Overall protection of human health and the environment addresses whether or not an alternative
^
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Alternative 1 relies on natural dispersion and decay processes to reduce levels of soil (Ik
contamination. It does not meet the goals for remediating soil and is not effective in reducing risks ^^
to human health, if federal control of BNL is lost. In addition, contaminated soil would continue to
be a source of groundwater contamination.
All other alternatives protect human health and the environment. For alternatives 2, 3, 5, and
6, long-term maintenance of the cap or cell and institutional controls are required for 100 vears for
it to remain protective of human health and the environment. Alternative 4 achieves protection of
human health and the environment by removing contaminated soils above cleanup levels, with 50
years of institutional controls to reduce risk to acceptable levels.
Compliance with Applicable, or Relevant and Appropriate Requirements
These criteria consider if a remedy meets all applicable or relevant and appropriate requirements
of federal and state environmental statutes, including provisions for invoking a waiver.
Alternatives 2 through 6 would meet the principal ARARs (i.e., the cleanup goals such as 15
mrem/yr above background levels for radionuclides as identified in Section 7, if control of the site
is maintained by DOE). The NYSDEC guidance of 10 mrem/yr also was adopted as an As Low As
Reasonably Achievable (ALARA) goal, which will be considered during the design and construction
phase. Alternative 1 would not meet these remedial goals.
Alternative 2 is expected to meet these requirements for the 100-year period of institutional *mr
control. A potential remains for future exposure above federal and state requirements, because all
soil, though capped, remains in the former Hazardous Waste Management Facility area and is
otherwise untreated.
The alternatives for excavation and off-site disposal (Alternatives 3 and 4) and the alternative
for soil washing (Alternative 5) involve removing a large fraction of the contaminated soil from the
site and would lessen the chance of future exposures above federal and state requirements.
Cap or cell maintenance would be required for alternatives 2, 3, 5, and 6 to remain in
compliance.
Alternatives in which soils are left on-site (Alternatives 1, 2, 3, 5, and 6) also would result in
the creation of a radioactive waste disposal facility and would be subject to applicable state and
federal regulations. State regulations do npt allow the siting of a radioactive'waste disposal facility
on Long Island or over a sole-source groundwater recharge area.
Lonu-Term Effectiveness and Permanence
Long-term effectiveness and permanence relates to the amount of risk involved and addresses
the ability of an alternative to protect human health and the environment over time, after the ^~.
remediation goals have been met. . lit
T OUtROD'ouIrodawpd 6-22/99 20
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Alternative 1 is not effective in the long-term because all contaminated soils are left in place.
Alternative 2 is effective in meeting future-use federal and state requirements by preventing
access to contaminated soils as long as institutional controls are maintained. However, the highest
levels of contamination remain on-site and rely on the effectiveness and continued maintenance of
an engineered barrier. Should that barrier fail or institutional control be lost, the long-term
effectiveness of this alternative would be compromised.
Alternatives 3,5, and 6 are more effective than alternative 2 in that the most contaminated soils
are either removed from the site (Alternatives 3 and 5) or immobilized (Alternative 6). However, they
also rely to some degree on the maintenance of an engineered barrier and continued institutional
controls to assure long-term effectiveness.
Alternative 4 is considered the most effective and permanent alternative in the long-term since
all contaminated soil above the soil remediation goals is removed and disposed of off-site.
Reduction of Toxicitv. Mobility or Volume
Reduction of toxicity, mobility, or volume addresses the anticipated performance of treatment
that permanently and significantly reduces toxicity, mobility, or volume of waste.
Alternative 1 provides no active reduction in on-site toxicity, mobility, or volume. There is a
natural reduction in toxicity over time due to radioactive decay.
Alternative 2 provides no treatment of the contaminated soils and, hence, no reduction of
toxicity and volume. Shielding of gamma radiation is provided by the cap, and the barrier provides
a reduction in mobility.
Alternatives 3 and 5 provide a reduction of toxicity, mobility and volume through off-site
disposal. In both alternatives, shielding of gamma radiation, as well as a reduction in radionuclide
mobility, is provided by the cap. Soil washing provides an additional reduction in volume by
treatment.
Alternative 4 provides a substantial reduction in toxicity, mobility, and volume throuah off-site
disposal; however, no treatment is provided.
Vitrification in Alternative 6 provides the greatest reduction in the toxicity, mobility, and
volume of the most contaminated soil through treatment into a glass monolith. The cap provides
further shielding of the gamma radiation as well as a reduction in radionuclide mobility.
Short-Term Effectiveness and Environmental Impacts
Short-term effectiveness and environmental impacts addresses the effect to the community and
site workers during construction and implementation of the remedy, and includes the time needed to
finish work.
T.-OU I ROD-.oulrnda.wpd 6/22:99 21
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Risks to the community were evaluated for both radiological risk and transportation accidents W
associated with off-site disposal of contaminated soils. All alternatives are considered protective of
the community in the short-term. There are no significant pathways of exposure to contaminated soils
and dust from excavating and constructing the cap can be easily controlled. Alternatives 2, 3, 4 and
5 involve disposal of various volumes of contaminated soils off-site and do have some risks
associated with railcar and traffic accidents. These risks can be controlled by federal (i.e., Department
of Transportation) shipping requirements and are considered negligible. Alternatives f and 6 do not
involve any off-site disposal and associated transportation risks.
Risks to remediation workers include both radiation risks and non-radiation construction
accident^risks. Alternative 1 provides the least risks to workers since there is no active remediation
Alternatives 2 and 5 are expected to provide the highest radiation exposures to remediation workers.
Alternatives 3, 4, and 6 result in less exposures than Alternatives 2 and 5.
Implementabilitv
Implementability addresses both the technical and administrative feasibility of an alternative,
including the availability of materials and services required for cleanup.
Alternative 1 could be readily implemented with limited technical and administrative
requirements.
^ Alternative 2 is technically feasible. However, it involves extensive excavation and complex
administrative requirements for regulatory permits and approvals of an engineered disposal cell.
^Alternatives 3 and 5 involve partially intrusive remediation activities. Alternative 3 is
technically feasible and uses technologies that can be readily implemented with average
administrative requirements, since only limited off-site shipment of waste is involved. Alternative
5 is less technically feasible, since the technology for soil washing has not been demonstrated on
cesium-137 contaminated soils.
Alternative 4 involves excavating of large volumes of soils. It is technically feasible and could
be readily implemented. Alternative 4 is expected to have above-average administrative requirements
due to extensive procedures for documentation involved in the transport and off-site disposal of soil
as low-level radioactive waste.
Alternative 6 is less intrusive, except for the consolidation activities. Vitrification has only
limited full-sca!e-use and may not be implementable. This alternative would have above- average
administrative requirements. Overall, this alternative is considered very complex.
Cost compares the differences in cost, including capital, operation and maintenance. For
estimated current costs of all alternatives, see Section 8.1.
TVOUIROD'oulraUa.upiI 6 :
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9.2 Other Areas of Concern
This section summarizes the comparative analysis of the alternatives identified for the Ash Pit
and the Upland Recharge/Meadow Marsh Area. Section 8.2 shows the costs. A comparative analysis
was not conducted for the Recharge Basin HS, the Weaver Drive Recharge Basin HW, and'the
Wooded Wetland, as only one alternative was identified for these basins.
9.2.1 Ash Pit
The following three remedial alternatives were considered for the Ash Pit:
Alternative 1: No Action with Monitoring
Alternative 2: Soil Cover
Alternative 3: Excavation with Off-site Disposal
For the Ash Pit, the no action alternative would not protect human health and the environment
and did not comply with EPA's soil guidance for lead. In addition the toxicity, mobility, and volume
would not be reduced.
For the second alternative, a soil cap would protect workers, the public, and wildlife and meet
EPA's guidance. It is relatively simple to implement, would reduce the mobility of contaminants of
concern, and is also cost-effective.
The third alternative, excavation and off-site disposal, would protect workers, the public, and
wildlife. It is relatively simple to implement, would reduce the mobility of contaminants of concern,
but is relatively costly for the limited benefits received.
9.2.2 Upland Recharge/Meadow Marsh Area
The following three remedial alternatives were considered for the Upland Recharse/Meadow
Marsh Area:
Alternative 1: No Action with Monitoring
Alternative 2: Excavation with On-site Disposal and Reconstruction of the Wetlands
Alternative 3: Excavation with Off-site Disposal and Reconstruction of the Wetlands
For the two man-made basins at the Upland Recharge/Meadow Marsh Area, the no action
alternative would not protect breeding Tiger Salamanders. In addition, the toxicity, mobility, and
volume of the contaminants of concern would not be reduced.
For the second alternative, Tiger Salamanders would be protected. It is technically feasible and
would reduce the toxicity, mobility, and volume of contaminants in the ponds by removing and
disposing the sediments off-site. However, this alternative involves complex administrative
requirements for regulatory permits and approvals for on-site disposal.
T'-OU I ROD'.oulroda.wpd 6/72/99
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The third alternative would also protect Tiger Salamanders. It is easy to implement and would
reduce the toxicity, mobility and volume of contaminants in the ponds by disposing of the sediments
off-site. This alternative is the most costly though it is only slightly more expensive than the second
alternative and off-site.disposal is readily available.
9.3 State and Community Acceptance
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 selection of remedial actions described
in this Record of Decision.
Community Acceptance
Community acceptance addresses the issues and concerns that the public may have on each of
the alternatives. Information sessions were held on April 13 and 14,1999, and a public meeting was
held on April 22, 1999 about the proposed plan and feasibility study supporting this Record of
Decision. The results of the public meeting and the public comments on the feasibility study and
proposed plan indicate overall general acceptance and support of the preferred alternatives.
Community response to the remedial alternatives is presented in the Responsiveness Summary in
Section III, which addresses questions and comments received during the public comment period.
10. SELECTED REMEDIES
Remedies have been selected based on consideration of CERCLA requirements, the analysis
of alternatives and public comments. The selected remedies are believed to provide the best balance
of tradeoffs among the alternatives with respect to the nine CERCLA evaluation criteria used to
evaluate the remedies (Section 9).
In addition to the remedies discussed below, institutional controls will be maintained to ensure
that uses are protective of public health and the environment and that the remedy is not negatively
impacted. Examples include land use restrictions (i.e. some areas are not suitable for residential use)
and controlling the types of activities that can be performed at certain areas such as limiting
construction on the top of capped landfills. In addition, any sale or transfer of BNL properties will
also meet the requirements of 120(h) of CERCLA to ensure that future users are not exposed to
unacceptable levels of contamination. For example, deed restrictions may be used to limit uses of a
particular site and to prevent the installation of drinking water wells into contaminated groundwater.
The selected remedies address three distinct components: radiologically contaminated soils;
other Areas of Concern; and removal actions adopted as final actions. The following is a description
of the selected remedial actions, which is also summarized in Table 7. Table 8 summarizes the costs.
T'OUIROD'oulroda.wpd 6/21-99
24
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10.1 Radiologically Contaminated Soils
The selected remedy for radiologically contaminated soils is Alternative 4 and involves
excavation and off-site disposal of soils above cleanup goals, institutional controls and Ions-term
monitoring. The major components of this remedy are:
• Radiologically and chemically contaminated soils and sediments above the
cleanup goals identified in Section 7 will be excavated from AOCs 1, 6, 10, 16, 17 and
18. Wetlands at the former HWMF Facility (AOC 1) will be reconstructed.' Soils and
sediments will be disposed of off-site at a permitted facility. The two likely disposal
facilities are DOE's Hanford Facility in Washington and Envirocare of Utah. Post
remediation sampling and dose assessments will also be performed to ensure that the
cleanup goals are met.
« Out-of-service underground storage tanks (six) and associated piping, the D
Tanks pad area at the Waste Concentration Facility (AOC 10), and out-of-service
equipment and facilities at the former HWMF (AOC 1) will be removed. Disposal
options will be determined during design and will be in compliance with federal and state
requirements. Radioactive wastes will likely be disposed of at either DOE's Hanford
facility or Envirocare.
• An As-Low-As-Reasonably-Achievable (ALARA) analysis will be performed
during the remedial design and implementation of the remedy to identify cost effective
measures for further reducing exposure to residual contamination below cleanup goals.
Examples of ALARA activities include the consolidation of residual contamination
below cleanup goals at one location and the use of a clean soil cover.
• Techniques which minimize waste volumes or further stabilize wastes to meet disposal
facility waste acceptance criteria may also be identified during remedial design and
implementation.
• Post remediation monitoring and institutional controls of residual contamination
will also be performed in accordance with a Long-term Monitoring and Maintenance
Plan. This Plan will ensure that land uses remain protective of public health and the
environment.
10.2 Other Areas of Concern
Remedies for the other Areas of Concern are described below:
• A 12 inch soil cap will be installed at the the Ash Pit (AOC 2F) to address metal
contamination. Institutional controls, monitoring and maintenance of the soil cap will
occur to limit access to the site and prevent erosion to the soil cap. Recreational and
Tr.OU I ROD.oulroda.wpd 6/3199 25
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residential uses will be prohibited. These activities will meet EPA guidance on lead
contaminated soil (OSWER Directive No. 9355.4-12).
Chemically contaminated sediments from the two eastern basins at the Upland
Recharge/Meadow Marsh Area (AOC 8) which serve as breeding grounds for the Tiser
Salamander will be excavated, processed if needed to meet disposal facility waste
acceptance criteria and disposed of off-site. The excavated wetland areas 'will be
reconstructed. Ecological monitoring will also be performed.
Operation and monitoring of Recharge Basin HS and the Weaver Drive Recharse
Basin HW (AOCs 24 E and 24 F) will continue in accordance with BNL's State Pollutant
Discharge Elimination System (SPDES) permit. A Tiger Salamander Habitat
Management Plan will detail the routine maintenance required at the basins to reduce
impacts to the Tiger Salamander. Annual monitoring of surface water and sediments will
be conducted at the Wooded Wetland to ensure that the cap at the Current Landfill
remains effective in preventing leachate from contaminating this wetland area.
10.3 Removal Actions
In addition, several removal actions that either have been completed or are ongoing are being
selected as final remedies. Each was selected in an Action Memorandum and subject to public
participation.
• Geomembrane caps, constructed in accordance with 6 NYCRR Part 360, were
placed on the Current Landfill (AOC 3), Former Landfill (AOC 2A), Interim Landfill
(AOC 2D) and Slit Trench (AOC 2E). Inspections, monitoring (e.g. groundwater,
methane, etc.) and maintenance are underway in accordance with approved Operations
and Maintenance Manuals. Institutional controls will also be maintained to prevent
activities that may compromise the geomembrane caps.
• One drum of soil containing cesium- 137 above cleanup goals from the National
Weather Service soil stockpile (AOC 16 S) was segregated and will be disposed of off-
site. The remaining soil was used as grading material for the Former Landfill cap.
• Buried chemical and radiological wastes and soils above cleanup goals were
excavated from the Chemical/Animal Pits (AOC 2B) and Glass Holes (AOC 2C). Soil
samples collected at each pit location demonstrated that cleanup goals were met. Off-site
disposal of the excavated materials is underway.
• A pump-and-treat system was installed at BNL's southern boundary to treat on-
site Volatile Organic Compounds in the groundwater from the Current Landfill (AOC 3)
and the former Hazardous Waste Management Facility (AOC 1 ). This system became
operational in December 1996 and will continue to operate until the one of the folio wins
performance objectives is met. ~
TV OU I ROD -on I roifo «pd 6X2/99 1 6
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1
1) Concentrations of contaminants in the groundwater have reached the cleanup
goals listed in Table 3; or
2) I£monitoring indicates that continued operation of the groundwater treatment
system is not producing significant reductions in the concentrations of
contaminants in the groundwater and concentrations are still above the cleanup
goals; then DOE, NYSDEC and EPA will evaluate whether operation of this
system can be discontinued in accordance with the National Contingency Plan
(NCP). The criteria for discontinuation will include an evaluation of the operatina
conditions and parameters as well as a determination that the groundwater system
has attained the feasible limit of contaminant reduction and that future reductions
would be impractical.
In addition, institutional controls will be maintained to prevent the installation of
drinking water wells into contaminated groundwater and to prevent the installation of
supply or other pumping wells that may mobilize remaining contaminants or otherwise
interfere with the cleanup.
Groundwater contamination associated with the Former Landfill Area (AOC 2) and off-site
groundwater contamination associated with other Operable Unit I AOCs will be addressed in the
Operable Unit III Record of Decision. An evaluation of remedial alternatives for deep contaminated
soil associated with the Brookhaven Linear Accelerator Isotope Producer (BLIP) facility (AOC 16K)
is underway. The final remedy for this AOC will be documented in a subsequent Record of Decision.
11. STATUTORY DETERMINATIONS
Selection of a remedy is based on CERCLA, and its amendments, and the regulations in the
National Contingency Plan. All remedies must meet the threshold criteria, protect human health and
the environment, and comply with ARARs. CERCLA also requires that the remedy uses permanent
solutions and alternative technologies for treatment to the maximum extent practicable, and that the
implemented action is cost-effective. Finally, the statute includes a preference for remedies that
employs 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.
11.1 Protection of Human Health and the Environment
The selected remedy for the radioactively contaminated soils protects human health and the
environment by removing and disposing of contaminated soils and associated structures and by
implementing monitoring and institutional controls to prevent exposure to contaminants that pose a
risk. Removing these wastes minimizes both risks of expose 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.
T 'OU I ROD'cmlroda.wpJ 6/22/99 27
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Reconstructing and monitoring the Upland Recharge/Meadow Marsh Area and the routine OP
maintenance and monitoring of Recharge Basin HS and the Weaver Drive Recharge Basin HW will
minimize potential risks to the Tiger Salamander and other ecological receptors. A Tiger Salamander
Habitat Management Elan will be developed to minimize the impacts to the Tiger Salamander from
continued operation of the Recharge Basin HS and the Weaver Drive Recharge Basin HW under
N'YSDEC permits.
The soil cover that will be placed at the Ash Pit eliminates the potential for direct exposure to
the ash. v
_ The covers placed at the Current Landfill, Former Landfill, Interim Landfill, and Slit Trench
eliminate the potential for direct exposure to the landfill's contents, control landfill gases, and
minimize the infiltration of precipitation and migration of contaminants to subsurface soils, surface '
water, and groundwater. The excavation of buried wastes and contaminated soils' at the
Chemical/Animal Pits and Glass Holes has removed the potential for further contamination of
underlying soils and groundwater.
Potential future risks to human health and the environment due to contaminated eroundwater
will be eliminated through extraction and treatment. For contamination presently"on-site, the
groundwater cleanup goals will be met by extracting groundwater contaminated with VOCs from the
Current Landfill/former HWMF plume.
No unacceptable short-term risks or cross-media impacts will be caused by implementatine ^^
these remedies.
11.2 Compliance with ARARs
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.
11.2.1 Chemical-Specific ARARs
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 for establishing goals for
remediating groundwater.
2. New York Water Quality Standards, 6 NYCRR Part 703. This requirement establishes
standards of quality and purity for groundwaters of the State and effluent guidelines.
T :-OU I ROD on I f oda wpd 6-22 99 28
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5
^
6. 10 NYCRR Part 5, New York State Department of Health Drinking Water Standards.
11.2.2 Location-Specific ARARs
. No location-specific ARARs were identified.
11.2.3 Action-Specific ARARs
L fn°r r °dt6 °.f ?***? R*sulations Pa« 835' ™* regulation establishes the requirements
for controlling and managing radiologically contaminated areas. r^^rements
!:101!^^^^^^ .The landfills were and will be
will be
2.
3. RCRA (40 Code of Federal Regulations parts 260-268). As described above.
StatC HaZard°US WaSte Regulatio^ (6 NYCRR Part 370 - 373). As described
^^
of hazardous air pollutants, including radionuclides.
11.2.4 Guidance To Be Considered
In implementing the selected remedy, the following significant guidance will be considered
Those which are not promulgated are not legally binding. considered.
1. NYSDEC Technical and Administrative Guidance Memorandum "Remediation
Gu.delme for Soils Contaminated with Radioactive Materials" (#4003), September 1 993
T.'.OU I ROD.oulrjda.wpd 6.Z2 99 09
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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.
2. NYSDEC Division of Air Guidelines for Control of Toxic Ambient Air Contaminants,
Air Guide 1. This guide will be use.d to evaluate the impacts of air emissions from the
air-stripping portions of the selected remedy, and to assist with evaluating the need for
air-emissions control equipment.
3. N YSDEC Technical and Administrative Guidance Memorandum: Determination of Soil
Remediation Objectives and Remediation Levels (# 4046), January 1994. The
recommended soil remediation objectives for Volatile Organic Compounds, chromium
and cadmium were selected as remediation goals to guide excavations at the
Chemical/Animal Pits and Glass Holes.
4. U. S. EPA Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective
Action Facilities, OSWER Directive No. 9355.4-12, PB94-963282, August 1994.
Guidance for remediating soil for lead at the Ash Pit.
5. U.S. EPA Soil Screening Guidance: User's Guide, EPA/540/R-96/018, April, 1996.
Goals for remediating soil for lead and mercury were developed using this guidance.
These goals were used to guide excavations at the Chemical/Animal Pits and Glass
Holes.
6. 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. The basic public dose limit for
exposure to residual radioactive material for DOE facilities such as BNL, is 100 mrem/yr
above background plus application of the As Low As Reasonably Achievable "(ALARA)
policy. Based on BNL site-specific conditions and ALARA, 15 mrem/yr above
background was selected. This level is consistent with risk requirements under CERCL A
and EPA guidance.
7. N YSDEC Technical and Administrative Guidance Memorandum: Accelerated Remedial
Actions at Class 2, Non-RCRA Regulated Landfills. HWR-92-4044, March 9, 1992.
This memorandum defines the Chemical/Animal Pits and Glass Holes as "hot spots",
which contain concentrated wastes and meet criteria to consider source removal as an
option.
8. U.S. EPA Presumptive. Remedy for CERCLA Municipal Landfill Site (Office of Solid
Waste and Emergency Response. Directive No. 93555.0-49 Feasibility Study, EPA 540-
F-93-035 September, 1993). Capping of the landfills was an appropriate remedy. This
directive considers wastes found in the Chemical/Animal Pits and Glass Holes as not
appropriate for capping.
T>OUIRODonlroda.«pd 62^99 30
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9. U.S. EPA Establishment of Cleanup Levels for CERCLA Sites
Contamination. OSWER Directive 9200.4-18, August 1997 This
blck^nf ^ al!°Wable. fP°SUre to radionuclides to ISmrem/vr above" namral
background as consistent with EPA's acceptable risk range.
11.3 Cost-Effectiveness
Based on the expected performance standards, the selected remedies were determine t« K,
cost-effective because they provide overall protection of human health ^^n^ent lono
and short-term effectiveness, and compliance with ARARs, at an acceptable coT TabT*
summanzes the total costs for Operable Unit I. "-epiaoie cost. Table 8
11.4 Use of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable »i«&ies 10 me
The selected remedies represent the maximum extent to which permanent
treatment technologies can be used cost-effectively. The selected remedies p^vfde L
vnlnade°fftm Tu °f loung-tenn effectiveness and permanence; reduction in toxicity
staZrv'n f" ,°Ugh tieatment; Sh0rt-temi effectivenes^ implementability; ^
statutory preference fnr tr^™^ *s a penpal element as well as State an '
0
cos The
r31' CXCaVation ^ °ff-site disP°saI of Biologically contaminated soils is apermanent
t removes contamination from the areas of concern. Treatment tecfano?oS^foJ
Permanent solutions also were selected for the other areas of concern to the ex
considenng Ae best balance in trade-offs. Removing sediments and reconstructing
the Upland Rechanrge/Meadow Marsh Area represents a permanent solution tha? wu protet he
Tiger Salamander. The Tiger Salamander will also be protected at the Recharge S HS Id he
WeavwDnveRech^BasinHW^^
Plan. Soil cover of the Ash Pit eliminates direct exposure. Management
T J^ "eTmedies Previously implemented of capping the Current Landfill, Former Landfill Slit
Trench, and Intenm Landfill, and bulk excavation and off-site disposal of the Chemical/A^fm , P is
and Glass Holes, are solutions for source control and minimizing the migration of contaminant
Groundwater solutions include treating Volatile Organic Coumpounds at the BNL southern bTund^'
monitoring, and institutional controls. Groundwater treatment for Volatile Organic Compounds
represents a permanent solution and implementation of treatment technology.
T:'OL'I ROD-.oiilroJa.upd 6/23.99 . 3|
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11.5 Preference for Treatment as a Principal Element
Treatment of radiologically contaminated soils was not found to be practical since there are no
techniques to reduce radioactivity. Techniques which minimize waste volumes or further stabilize
wastes to meet disposal facility requirements may be identified during remedial design.
The components of the selected remedy for groundwater are final actions and satisfy the
statutory preference for treatment as a principal element. Groundwater contaminated with'total
Volatile Organic Compounds is being extracted and treated by air-stripping before recharge back to
the aquifer. •' "
11.6 Documentation of Significant Changes
Comments received during the public comment period for the proposed plan and feasibility
study that support this Record of Decision were reviewed. No significant changes to the selected
remedy, as originally identified in the proposed plan, were necessary.
11.7 Five-Year Review
Five-year reviews will be needed to evaluate the effectiveness of the institutional control period
to achieve total reduction in risk at the radiological contaminated waste sites, to evaluate the activities
taken to protect the Tiger Salamander, and to evaluate the effectiveness of landfill caps and the
groundwater treatment system.
T 'OU I ROD'oulroih upd 6.21'99
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1
REFERENCES
BNL, 1994. Action Memorandum Landfill Closure Removal Action Phase I - Current Landfill.
December, 1994.
BNL, 1995. Future Land Use Plan. August, 1995.
BNL, 1996a. Action Memorandum Landfill Closure Removal Action Former Landfill Area.
April 8, 1996.
BNL, 1996b. Action Memorandum Operable Unit I Groundwater Removal Action and Operable
Units & III Public Water Hookups. December, 1996.
BNL, 1997. Final Action Memorandum Phase III - Landfill Closure Removal Action.
June 16, 1997.
BNL, 1999. Proposed Plan for Operable Unit I and Radiologically Contaminated Soils.
April 1999.
CDM, 1994. Final Remedial Investigation/Risk Assessment Report, Operable Unit IV. December
1994.
CDM, 1995a. Final Engineering Evaluation/Cost Analysis for Landfill Closure Action, Operable
Unit I. March 1995.
CDM, 1995b. Final Engineering Evaluation/Cost Analysis for Groundwater, Operable Unit I.
September 1995.
CDM, 1996a. Final Remedial Investigation/Risk Assessment Report, Operable
Unitl/VI. June 14, 1996.
CDM, 1996b. Final Construction Certification Report for Current Landfill Capping. May 1996.
CDM, 1997. Chemical/Animal Pits and Glass Holes, Final Evaluation of Alternatives Report. April
1997.
CDM, 1999a. Final Feasibility Study Report Operable Unit I Radiologically Contaminated Soils.
February 26, 1999.
CDM, 1999b. Final Focused Ecological Risk Assessment Operable Units I/VI. Appendix L, Final
Feasibility Study Report Operable Unit I Radiologically Contaminated Soils. March 31, 1999.
CDM, 1999c. Addendum, Focused Ecological Risk Assessment Operable Units I/VI. June 9, 1999.
T:'OUlROD\oulroda.\vpd 6.32,'99 33
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EPA, 1989. Risk Assessment Guidance for Superfund; Human Health Evaluation Manual
Part A. U.S^Enyironmental Protection Agency, Office of Solid Waste and Emersency and Remedial
Response, OSWER Directive 9285.701 A.
EPA, 1994. Guidance on Residential Lead-Based Paint, Lead Contaminated Dust, and Lead
Lontammated Soil. U.S. Environmental Protection Agency. July 1994.
,; SoilScreening.Guidance: User's Guide. U.S. Environmental Protection Agency Office
of bolid Waste and Remedial Response. OSWER Directive 9355.4-23, 1996
EPA 1 997. Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination
U.S. Environmental Protection Agency, Office of Solid Waste and Remedial Response OSWER
Directive 9200.4- 1 8, August 1997. . . "
IT, 1999. Final Operable Unit II/VII Remedial Investigation Report. February 1999.
J. Meersman, BNL to J. Lister, NYSDEC, 1 999. Operable Unit I I/VII Supplemental Surface Sampling
- Preliminary Metals Results. June 1, 1999.
J. Meersman, BNL to J. Lister, NYSDEC, 1999. Operable Unitll/VII Supplemental Surface Samplin-
-Preliminary Radiological Results. May 18, 1999. =
NYSDEC, 1994. Technical and Administrative Guidance Memorandum: Determination of Soil
Remediation Objectives and Remediation Levels. HWR-94-4046, New York State Department of
Environmental Conservation, Division of Hazardous Waste Remediation. January 24, 1 994 (revised).
P.W. Grosser, 1997. Interim Landfill Closure Report. November, 1997.
SAIC, 1992. Brookhaven National Laboratory Response Strategy Document. 1992.
Weston, 1997. Former Landfill Closure Construction Certification Report. March 1997.
T OU I ROD'-oiiltoih upd 6;2
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TABLES
35
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Table 1
Description of Operable Units at BNL
Operable Unit
Description
Operable Unit I is a relatively undeveloped 950-acre area in the southeastern part of
the site. It includes historical waste handling areas, such as the Former and Current
Landfills (AOCs 2 and 3), and the Former Hazardous Waste Management Facility
(AOC I). It also includes the Ash Pit (AOC 2F) and two recharge basins (AOCs 24E
& 24F).
Operable Unit I contains six areas covered by accelerated removal actions: the Current
and Former Landfills, Chemical/Animal Pits and Glass Holes, the Interim Landfill, the
Slit Trench and Groundwater.
Ill
Operable Unit III contains the south central and developed portions of the site. This
operable unit contains most of the site's contaminated groundwater.
II/VII
Operable Unit II/V1J consists of several AOCs located in the developed central
portion of the site. It includes contaminated soils and out-of-service underground
storage tanks and pipelines proposed for removal at the Waste Concentration Facility
(AOC 10), along with various isolated areas of contaminated surface soils (AOC
16,17,18). It also includes the BLIP facility (AOC 16K).
IV
Operable Unit IV is located on the east-central edge of the developed portion of the
site. It includes the 1977 Oil/Solvent Spill (AOC .5) as well as the Reclamation
Facility Building 650 and Sump Outfall Area (AOC 6), where radio logically
contaminated soils have been found. A Record of Decision has been issued for this
Operable Unit and an Interim Remedy of access restrictions and monitoring has been
implemented for AOC 6. The final remedy for the radiologically contaminated soils
(AOC 6) is included in this Record of Decision.
V
Operable Unit V is located in the northeast portion of the site and includes the Sewage
Treatment Plant (AOC 4) and releases to the Peconic River.
VI
Operable Unit VI is located on the southeastern edge of the site. It is a largely
wooded area which contains various agricultural research fields and human made
experimental basins (AOC 8). No contaminated soils of concern have been found in
this operable unit, however, contaminated sediments in two of the human made basins
pose an 'ecological risk to the Tiger Salamander. Ethylene dtbrorriide, a pesticide, has
been found in groundivater south of BNL's southern boundary, and is addressedJn a
separate Record of Decision. '' -
T 'OC I ROD'RoJ T.iblcs-Tjhlc I xx
36
-------
Table 2
SUMMARY OF SITE HISTORY
AOC
No.
Name
Waste
Contaminated
Media
Primary
Contaminants of
Concern
Maximum
Concentration
Reference
Radiologically Contaminated Soils
1
6
10
16
Former Hazardous
Waste Management
Facility (ItWMF)
Reclamation Facility
(Building 650) sump
and outfall area
Waste Concentration
Facility (Building
811)
Aerial Radiation
Survey Results/
Landscape Soils
Processing, storage and shipping of hazardous and
radioactive wastes from 1947 to 1977. Twelve acres
containing approximately 35,000 cubic yards of
contaminated soil and debris (i.e. concrete and asphalt).
Contains buildings and structures with no planned
future use. Also, an adjacent wetland contains
contaminated sediments.
Equipment decontamination pad at Building 650
drained into a sump. :>ipe from sump drained into an
outfall area 800 feet northeast of Building 650.
Contaminated soil exists near the decontamination pad
and at the outfall area. The sump outfall area was
fenced off as an Interim Remedy under the Operable
Unit IV ROD.
Facility for processing and concentration liquid
radioactive wastes since 1947. Liquid wastes were
stored in 100,000 gallon above- ground D tanks from
1947 to 1987. Several leaks were documented in the
1980s. Tanks were dismantled in 1995 and disposed of
off-site. Consummated concrete, asphalt pad and soil
remain. Out-cf-service piping and six 8,000 gallon
underground tanks also remain.
Radiologicaliy contaminated soils were found near
several buildings. The source of the contaminated soils
was originally from the former 11 WMF, which was used
for landscaping.
Soil
Sediment
Soil
Soil
Soil
Cesium- 137
Strontium-90
Lead
Mercury
Cesium- 137
Aroclor-126
Aluminum
Zinc
Cesium- 137
Strontium-90
Plutonium-239/240
Cesium- 137
Strontium-90
Cesium-137
Slrontium-90
.ead
810.000 pCi/gm
1,300 pCi/gm
429 nig/kg
184 mg/kg
13 pCi/g
36 ug/kg
8, 150 mg/kg
14 mg/kg
2,800 pCi/gm
140 pCi/gm
170 pCi/gm
1.486 PCi/gm
454 pCi/gm
348 pCi/gm
2 pCi/gm
2.310 mg/kg
CDM. I996a.
CDM, I999a.
UNL. 1999.
CDM, I999a.
CDM, 1994.
CDM, 1999a.
BNL. 1999.
IT, 1999.
CDM, I999a.
HKII 1OOO
IT, 1999.
CDM, I999a.
BNL, 1999.
37
-------
Table 2
SUMMARY OF SITE HISTORY
(Continued)
AOC
No.
17
18
Name
Low Mass Criticalily
Facility
Alternating Gradient
Synchrotron Storage
Yards
Waste
Slightly elevated levels of radiation were found near the
former Low Mass Criticalily facility, which was in
operation from 1955 through mid 1960s. The facility
was dismantled in 1994. The former silo area is
currently a recharge basin for the OU 1 groundwater
treatment system.
Two of the three yards are used for more than 20 years
to store activated steel used in the synchrotron
accelerator facilities. The third yard is used to store
non-activated steel.
Contaminated
Media
Soil
Soil
Primary
Contaminants of
Concern
Cesium-137
None
Maximum
Concentration
0.5 pCi/gm
Not Applicable
Reference
IT, 1999.
CDM, I999a.
HNL, 1999.
IT, 1999.
CDM, I999a.
BNL, 1999.
Removal Actions
ID
2A
&
2E
OU I Groundwatcr
(IIWMF/Current
Landfill)
l-ormer Landfill and
Slit Trench
In 1984, radiological and volatile organic compounds
associated with AOC 1 and AOC 3 were found in the
groundwater in the southeast portion of the BNL site.
In 1 992, VOCs were found in groundwater at the site
boundary 130-150 feet below the surface and arc
migrating off-site. Tritium is also co-located with the
VOCs. A pump and treat system for the VOCs is
currently in operation. The stronliurn-90 remains on the
BNL site.
This eight-acie landfill was operated by the U.S. Army
during World War II and by BNL from 1947 to 1966.
Used primarily for disposal of sanitary, municipal-type
and construction wastes. Limited amounts of low-level
radioactive waste and some laboratory chemical wastes
also were disposed in this landfill. The landfill,
including adjacent Slit Trench, was capped in 1996.
Groundwater
Groundwaler
Buried Waste
1,1 Dichloroethane
Chloroelhane
1,1,1 Trichlorocthane
1,1 Dichlorocthene
Tritium
Strontium-90
Slrontium-90
N/A
360 ppb
210 ppb
62 nnb
r r"
34 ppb
37,000 pCi/l
150 pCi/l
!50pCi/l
N/A
CDM, I995b
CDM, I995a.
BNI I9<)6
i-rl^t lj, 1 J /U.
-------
Table 2
SUMMARY OF SITE HISTORY
(Continued)
AOC
No.
.211
&
2C
2D
3
I6S
Name
Chemical Animal
Pils/ Glass Holes
Interim Landfill
Current Landfill
National Wealher
Service Stockpile
Wasle
These disposal pits were used from the late 1950s to
1 98 1 . Wastes consisted of laboratory glassware,
equipment, chemical bottles, laboratory animal
carcasses, and other laboratory wastes. Fifty-five pits.
were excavated in 1997, and wastes were sorted and
stockpiled. They arc currently being disposed of off-
site.
This three-quarter acre landfill was operated I3NL from
1966 to 1967. Used temporarily for municipal-type,
sanitary and construction waste disposal until the
Currerv. Landfill was built. Limited amounts of low-
level radioactive waste and some laboratory chemical
wastes also were disposed of in this landfill. The
landfill was capped in 1997.
1 his eight-acre landfill was operated by BNL from 1967
to 1990. Used primarily for municipal-type, sanitary
and construction waste disposal. Limited amounts of
low-level radioactive waste and some laboratory
chemical wastes also were disposed in this landfill.
The landfill was capped in 1995.
In 1992, soil excavated from the National Wealher
Service site at BNL was found to contain low levels of
radioactive contamination. About 127 cubic yards of
soil was below cleanup goals and one drum of soil was
above cleanup goals. The drum is being stored at the
former Hazardous Waste Management Facility and the
127 cubic yards was used as fill under the cap of the
Former Landfill.
Contaminated
Media
Soil
Groundwater
Buried Waste
Groundwater
Buried Waste
•
Groundwater
Buried Waste
Soil
Primary
Contaminants of
Concern
Mercury
Slrontium-90
Trichloroelhene
Carbontetrachloride
N/A
Slrontium-90
N/A
1,1 Dichloroelhane
1,1,1 Trichloroethane
Chloroethanc
N/A
Ccsium-137
Maximum
Concentration
O.ISmg/ki,
2-10 pCi/l
09 nnli
-' PP°
6 ppb
N/A
!50pCi/l
Kl/A
48 ppb
6 ppb
J4 ppb
N/A
greater than 23 pCi/gm
(one drum)
Reference
^DM. 1,997.
UNL, 1997.
COM, 1995a.
UNI,, iy96a.
COM. 1995a.
BNL, 1994.
COM, I995a.
BNL, I996a.
39
-------
Table 2
SUMMARY OF SITE HISTORY
(Continued)
AOC
No.
Name
Waste
Contaminated
Media
Primary
Contaminants of
Concern
Maximum
Concentration
Reference
Other Areas of Concern >
2F
3
8
24li
&
24I;
Ash Pit
Wooded Wetland
Upland and Recharge
Meadow Marsh
Recharge Basin IIS
Recharge Basin IIW
This three-acre area was used for disposal of incinerator
ash from 1943 to 1963. No records indicate
incineration of radiological or hazardous wastes.
Portions of the ash pit are covered with a fire break and
a paved road.
This two-acre wetland is adjacent to the capped Current
Landfill. Runoff contaminated with leachate for the
landfill drained into the area before capping the landfill
in 1995. Elevated levels of metal below human health
concerns may be a potential threat to the New York
State endangered Tiger Salamander.
Used for experiments in the 1960s and 1970s on use of
natural ecosystems for treatment of sewage and recharge
to groundwater. The sewage contained metal and
radionuclide contaminants. The area currently contains
abandoned artificial basins and ponds. No chemicals of
concern exceed human health risk criteria; metal
concentrations are a potential concern for the New York
Slate endangered Tiger Salamander.
These two recharge basins receive storm water effluent
from the center of the BNL site and warehouse area.
They are New York State permitted basins. No
chemicals of concern exceed human health risk criteria.
Metal concentrations are a potential concern for the
New York State endangered Tiger Salamander.
Soil
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Lead
Aluminum
Copper
Zinc
Copper
Lead
Aluminum
Cadmium
Copper
Zinc
Cadmium
Copper
Mercury
Silver
Aluminum
Copper
Zinc
Cadmium
Copper
Lead
Zinc
2,100 mg/kg
38,600 n%/\
56 /ig/1
252 ugfl
8 mg/kg
28 mg/kg
5,110 Mg/l
73 j
-------
Table 3
Crountlivater Quality for GA
Waters 6NYCRR 703.5
USEl'A Primary Drinking
Water Standards
Partl4l,MCL
'ne/J.
Selected Cleanup Goal
Notes
NS - No Standard
Principle Organic Containinaiit
cis isomer = 70 ug/l, trans isomer = 100 ug/1
Based on USEPA 1996 Drinking Water Regulations.
Based on NYSDOHMCLs-Jamnuy 1992. Current MCLs
on the last revision of Hie Safe Drinking Water Act
p.
[II-
12]-
13]-
based
4imllirem/year(40CFRMI.16a). ye.
-------
Table 4
Soil Cleanup Levels for
Principal Radiological Contaminants at BNL
1
Radionuclidec
Cesium- 137
Strontium- 90
Radium-226
Soil Cleanup Level
Residential Land Use
(pCi/g)
23 a
15 c
5d
Soil Cleanup Level
Industrial Land Use
(PCi/g)
67 b
15C
5d
c.
d.
e.
Acceptable soil concentration for 15 mrem/yr above background exposure and
residential land use with 50 years of institutional control of the site. This Goal
applies to areas other than the Former Hazardous Waste Management Facility.
Acceptable soil concentration for 15 mrem/yr above background exposure and
industrial land use with 50 years of institutional control and residential land use with
100 years of institutional control of the site. This Goal applies to the Former
Hazardous Waste Management Facility.
The Strontium-90 goal is based on an evaluation of groundwater impacts. It also is
protective of residential and industrial use.
DOE Order 5400.5 Radiation Protection of the Public and the Environment. Also,
commonly used by EPA.
In addition to the radionuclide specific levels, a post remediation sampling and a dose
assessment will be performed to ensure that the dose from the remaining
concentrations of all radionuclides present is less than 15 mrem/year above
background considering 50 years of institutional control for the selected land use.
42
-------
Table 5
Soil Cleanup Levels for Principal Chemical Contaminants at BNL
Soil Cleanup Level
(mg/kg)
a. Based on EPA's soil screening level guidance (OSWER 9355.4-23) Protective of
residential use. *»&
-------
I AHI.K (>
( OMPARATIVK ANALYSIS OK REMEDIAL ALTERNATIVES KM KADIOI.OWCAI.I.Y (ON IAMINA TKI) SOILS
Alternative
1. No Action with
Monitoring
. Engineered OH
• Dispose soils above
cleanup goals On Site
X Midi-run; Ku-avation.OU-
Mtc Disposal, and HCKA
Cap
• K\ca vale/Dispose
soils above secondary
action level
• Cap remaining soils
above cleanup goals
4. targe-Scute Excavation
and OfTsile Disposal
• Ktcavate'Dlspoie
soils above cleanup
K°*H
5. Moderate Excavation, Soi
Washing, Offslle Disposal,
and RCRA Cap
• Dispose >2BW pCi/g
• W«sh above secondary
action level
• (.'ap remaining soils
above cleanup goals
6. Moderate Vitrification
and HI RA Cap
• Vitrify soil above
srrundary action level
• t ap remaining soil
abuvc cleanup K°*'&
1. Protection of Human Health &
Environment '
(after Federal
• Remedial aUmn otyeelcles, mil
met
Residujl Rl>.k ID tuturc HWMK users:
Uve;irs (i3r--l)>((i lb-02)
Wvears 2,01: -02 (2.UF.-M2)
• Remedial actnm objective met
tesiduul Risk to future HWMK users
Drears 4.SL-U5(l.5tMM|
(IfKearv 1 5i:.<)5<4-U:-<)5)
• Remedial acium uh|txti\Ch met
tcsiiiual Risk lt> luluic IfWMI users
sovears 4 sK-i»5i5 l!--n5i
nilveurs: 1.41: <>5 tUMi-USl
• Rcniedi.il action objective-, me!
Residu.il Rirvk 10 future HWMT u^fv
51)}Kiis (7 1! .(15|
MHl \ears 2ilR»5l2 IK-uS)
• KLinctli.il jctum objectives met
Resu)u.il KiA in lutuic HWMI users.
5«ycjTv45l--ii5(S.lh-OSi
l(Mi>tfar». I 4t-u5(l SL-il5i
* Remedial .ilium nhiccuvciiiiu
KcMdudl Rhk u> luiure HWMI users
MUeats 4SI-05(52l-d5j
ItH) \ears 1 4HI5M nr--05)
2. Compliunce with ARARs
• OIKS not meet ARAK.-. cither
during or tiilluwirig rcmedialion
• Uemeditiiion L\rK\ted
Ltimpluiice Milti Llcaiiungiul
• Pi>it-Uetuulia(inn INuetilial siting
issue with State us all media
retiutiis on site in do t.n-lo rad
waste JisjMisal taeiliiy Wai\ei
required
• Kcmali.iluiii Kpeeled
vtunphant-u ^uli ttc.ntup -.:IM|
• I'oii-RuiMCiluiliim McJu
rcm.iinini; itti site meets -.eLoiul.ir\
jLHiin level, however, potential
MlniU i-isuc uilli State, rtlitt.li ma>
require waiver
• Remediutiun. I:Apeeied
eompliunce uilli ele-anup goal
• fust -Remedial ion: E:\peeted
emtipluinec smi:e.ill soils jbtrve
remedulion iionls-remmctl Iioni
• Remediation l*\|xxii:il
eiHtiplluiiec witli cleanup t;tul
• Iyo-,i-Ki-iiiedij!u>n Media
remaining tin %ilc meets seetindaix
iiLiion level. ImueuT. rh.iemiiil
-,111111; issue with StJte. \vbicli nu>
require umver
• Remetll.iliiin l.vpeited
oumpliatue will) v-ltMiiup >;».il
" I'. ^ - Reined Ml n m Hitfioi sutK
vitntled .iniU-;i|)|wil ,uu!
potcitliiil siimy issue wuli si.ite.
winch mav rcquKc waiver ,
3. Lontt-Term Effectiveness
and Permanence1
allowable cxposuie levels
• M.iii;mallv l-IkTtive
• Hmhesi LuntaimnateLl soil remains
within (.ell
» Ceniianeiieelii pievenl ilireet exlein.il
exposure to all aimanimated MiiK
de|x.-ndcnl uii cover numienaiKe .nid
/iimnvi etttilinK tor peipeiuilv
• 1 Itetliveitl tap m.iini.niu'dl
• Hi=:liesi iDiii.mmi.iled -oiu
peniiaiientlv renoived
• I'eimanetue to prevent duei.1 eMenul
exposure 10 Inwer ,tenv ny
com aim n j led soiK dependent on cap
iinniileiiaiiLL1 lur tlH) \i_-.if-.
« \en l.tleciive
• Peiui;iiient
• All eoni.tmmiited smK jhtive itsk-
based reinedialloii jtiuli rentoveil
• liittitution.il eonlrol |HTUH! s{| WM^
tvs KM) >ears lor other alternatives)
• r-lleetivedt uij) iii.niiMincdi
• ltii*liest ainiJiIimated ^oll^ (enioved
• 1'enu.ment.e to pievenl direct eMenul
exposure to towei .tclt\il>
Limt.immaied soils dependou oti cap
nunilenance lor KM) ve.ils
• i-lleLlivclil v,ap iii.iini.iinedl
• Ui)-lu-si >.o]iiaiiuiiated -mils
pcniuouitK imim'hili/ed.nid iheo
Llpplll
evposuie ilepeiideni «n cj|>
maiiiieiutiue toi IIKJ \eais
• PermaiieiKv lu prevent le.Klmii! and
in.idvetleol inlitisiui) panuU-d hv
\iliitk-d iu.ls>
4. Reduction of Toniuty, MubUily or
Volume (TMv) by Treatment
• Ni>.nIivereduciiMnot IM\ All
iiiiit.iiniii.iii.-il mcdiii leinanis on -.iii.-
• Ni.iturat tetliK'iion ol toxieitv l>>
i.idu>at.nve deeav and iii-.pv'IMuii oiilv
• Ovenill Von- Inn
• No reduction ol 1 MV iln.umh
hCMtiiienl
« N,nur.tl rcduetniii ol IOVKIIV ova
timeldet.a>l
• SmiiiL- ot dnei.-l extern.il evpoture
shielded .Hid ctmuimuiaiit nuiliitiiv
reduced In eover and liner s\-.iein
• Oveiull low
• Rcdiu-iumol !\t\ tlii.ui/li.ilMu-
ui .posal
• \ddittim.iho\iutv .itidiiiolnliiv
reduction \ ia cap
• Ovcr.ill. Medium
• SulKl.inu.il tetluction .«t I\IV
ihiuutjh dltiiie di-jiu--.il lume\cr. no
Iteiliment is pntvuled
• Overall. Ver> Hiiill
a Kcduclumo! 1 MV llirnutih ntt-ile
• Additional reduction in vntunu.' via
•.oil washing
• Addiiiniial toxietlv and niohihlv
reduction vu cap
• (nv.iteM teduLlionol IMV VM
• No MtiN ir.msterretl oil ^ie
• -\ddii i.-ii.if tovtuK .uid nuihiliiv
• Overall \erv Mmh
5. Short- Term KfTecttvetms1
{emcdiatum Risk Rankme
^oikei - 1 lt( (K'tson u'uii
(.\iiiimuniiv 1 None
(emediation Ui-.k K.iiikui^
\\.nkci • di Ins put son icim
t ommimiiy - 3 (4 -JI--HH
Uvim-ilLiiion ivi-.k R-inkmi:
U..iker- 2<4^|iciMiiiivitit
( ommtitntv ,*> l-.t.l- n't
Remediation Risk Kankiiu::
^ Wtirker • 4 I'X) person renn
t'oinmumtv - f>i5.3 L-lt"i
Ucincdi.it ion Kitk Katikmu
VXoiker • 5 ( Ulipeisnn rciut
{'ommutnlv -4|S,Si usi
Remediation Risk Raiikmu
\\.Kkei • ir$pviMinmni
Conimuiniv 2tNotnri
6. hiiplt'invnlaliiUt)
• lU.udiv miplenu-ntal
• 1 umicil tcilinu.il icifunemedts
• 1 nmu-d.KliiiimMi.Hion
• (tvei.dl \i-iv. Sinipli-
1
• KcjdiK iinnK-incriicd icJiiik.ilK
le.isdile
• ( omp!e\ .iiliiiinivit.iliiiii iL-iiiiiiL-iiK-nis
due 10 peimiitnit: r-tnntii issues im «,ell
• (heull MtKlofjtcK t tmipkx
• Uv.uliK n.ipu-iiutiuiiuJiiiu.iK.
le.i-.ml*
rei|iuieiiiL'iiis due to oitxti.' ili-.pi»,il
\otumes and c.tp pei nmini;:
• Ovetall Moder.itelv (\le
• -\oove aver:iee .ulimni-u.iui'ii
lequnemenl iluc to l.nee oIKne Jisp«>ia]
• Overall Mmk-Mtdv I miipk-x
• I'aniallv uuiu-nc (ciliediatuui
• Rvatlilv nnpk-im-iiu-d 1 i-.sU-ilinu.ill-.
kMMbk-.|s%.i||-A ,sllllrj,.1 1 -Otol
deiiion>iia(ei) llr.'li rviiKili.il (KVM
• -\ho\e-.i\i.-i.u'i' [iiiiiiiiisti.iii.iti
,IIHl..l|l|K-l 1111111111:
• iKa.ill ( ..nipk-v
> 1 1-~ rn.i\f iotu.-ili.ilii 1 InJicM
hlilK.lllllll.llol M>|U
• 1 iiiuinl liill.>.-jl.. ii'..- I'niiiir.ini: rii-KI
-luih K--UII-. HiL'll IWSI .iii.l
,,-iii,',li.ii mi,-
• \lnivc .1*^-1.11:^ .iifinnti.ii.tiii ui
IVtlullL-tlltlll-. Idl U't.lllu.|l>i:N .UK) l.l|>
• (Ka.ill ^a\ I .uni'lo
7. ( ,,sl
^^^4 IMH)
^A ((-l^.uiiii
Ml.'ll^lillil
^t.ll^.ltlld
M5..HIII1IH)
VI'i.'.'.J IKIII
' I iniiii.- M\VMf'n-.ci IN .^Miiucil M IK- imliiMri.il nHiiuti-a-ial KisU.iu- N|I..\\H h.»ih \snli ihciliuikiui; rt.it
lcda.il HSI Minli.iNjsNUliii1Jli>lx..cll«li\tfduriili!SII-\wlci'iilii>ll'ai>«ll>1l jl1 Mlcrnjlucs
I In- Koiialijliuli RIN!. Rankiliv! li« Iwn piru'lllal limn UmcM 111C" lii|!lKsl (In
ill I \M)KM>lliliHil( \II\-«)M \MIN.\III)S(HIS
-------
TaMc7
SUMMAUV OFSKLI-CTED REMEDIES
AOC
No.
1
(,
10
16
16
17
18
Name
Former 1 lazardous Waste
Management Facility
(I I WMF)
Reclamation Facility
(Building 650) Sump nnd
Outfall Area
Facility
Results (Sub-AOCs 161;,
I6F, 160, lfiS.I-4and
!6S.6a-0
(Sub-AOCs I6A-IJ, 161.
l6Jamll6M-Q)
Facility
Synchrotron Storage Yard
Proposed Hentedfal Actions
Uails for Action
Itadiolugitally Contaminated Soils
Excavation with off-site disposal of approximately 35,WiO
cubic yards of contaminated soil, debris and sediments.
Habitat restoration ofllic wetland. Demolition and disposal
of facilities and buildings. Institutional controls and
monitoring.
Excavation with off-site disposal ofsoil contaminated with
long-lived radionuclides near Building 6SO and at the sump
outfall area. Excavation with off-site disposal of pipe (and
associated contaminated soils) between the
decontamination pad and outfall area. Excavate and
consolidate soils contaminated with short-lived
radionuclide with AOC 1 soils for off-site disposal.
Remove contaminated concrete at decontamination pad and
dispose of off-site. Post-excavation soil sampling and dose
assessment. Institutional controls and monitoring.
asphalt pad at D Tanks Area, out-of-service piping and six
8,000 gallon underground tanks. Excavate/consolidate
soils with AOC 1 for off-site disposal. Post- excavation
soil sampling and dose assessment. Institutional controls
and monitoring.
Excavate soils above cleanup goals and/consolidate soils
with AOC 1 for off-site disposal. Extent of excavation lo
be determined during design phase. Post-excavation soil
sampling and dose assessment. Institutional controls and
monitoring.
Active facilities that will be monitored. Institutional
controls. Facilities will be decontaminated and
decommissioned upon closure.
Institutional controls and monitoring
Institutional controls and monitoring.
Protect gtoundwaler from
Stronliurn'90. Achieve 15 mrein/yr
cleanup goal for future industrial
land use.
Protect groundwuter from
Slrontium-90. Achieve 15 mrem/yr
remediation goal for future
residential land use.
Protect groundxvaler. Achieve
1 5 mrem/yr remediation goal for
future residential land use.
Achieve 15 mrem/yr remediation
goal for future residential land use.
Achieve 400 mg/kg cleanup level
forleadalAOCI6S.3.
Monitor active facilities to insure
that unacceptable environmental
releases do not occur.
Achieve 15 mrem/yr remediation
goal for future residential land use.
Achieve 15 nirein/yr remediation
goal for future residential land use.
Current Status
Planned action upon ROD
approval.
Interim Remedy (fencing and
access restrictions) in place.
Planned action upon ROD
approval.
I) Tanks removed. Planned
action upon ROD approval
Planned action upon KOD
approval.
Planned action upon KOI)
approval.
Planned action upon ROD
approval.
Planned action upon ROD
approval.
Remedial Action
Reference
COM. I999a
DNL. 1999
COM, 1999a
DHL, 1999
COM, I99!>a
UNL, 1999
IT, 1999
CUM, I999a
BNI-, 1999
IT, 1999
BNL, 1999
IT, 1999
IT, 1999
If, 1999
T -(XII KOIi-Kod Iit)kiVuble7Epl \v)i
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Table 7
SUMMARY OF SELECTED REMEDIES (Continued)
No.
Name
Proposed Remedial Actions
Basis for Action
Current Status
Remedial Action
Other Areas of Concern
2F
3A
8
2-1 E
&
24I:
Meadow Marsh
IIW
exposed at surface. Institutional controls and monitoring.
water and sediments.
disposal. Reconstruction of the wetlands. Maintenance
and monitoring.
current NYSDEC SI'DES permit and BNL Implementation
of Tiger Salamander Habitat Management Plan.
Protection from direct exposure to
lead.
Protection of State endangered
species,
Protection of Stale endangered
species.
Protection of State endangered
species.
Planned action upon ROD
approval.
Monitoring performed with '
current landfill monitoring.
Planned action upon ROD
approval.
Planned action upon ROD
approval.
COM, I999a
COM, I999b
BNL, 1999
COM, I999a
CDM, I999b
BNL, 1999
CDM, I999a
BNL, 199'J
Removal Actions Selected is Final Actions
&
2E
3
16S
in
2C
213
anil Slit Trench
Stockpile
Glass Mules
including methane monitoring, groundwater sampling,
monthly inspections.
including methane monitoring groundwater sampling,
monthly inspections.
contaminated portion.
contaminated soils.
including methane monitoring, groundwal'er sampling,
monthly inspections.
Protect groundwater. Presumptive
remedy for landfills.
Protect groundwater. Presumptive
remedy for landfills.
Achieve 15 mrem/yr remediation
goal for future residential land use.
Prevent migration of off-site
contaminant and achieve MCLs for
groundwater.
Piotecl groundwaler. Presumptive
remedy for landfills.
Groundwater protection.
Presumptive remedy for landfills.
Completed October 1996.
Completed November 1995.
Completed October 1996.
Pump-and-treal system
completed December 1996.
Excavation completed
September 1997.
Completed,
CDM, I995a
BNL, I996a
CDM, I995a
BNL, 1994
COM, 1995a
CDM, I995b
BNL, I996b
CDM, I997a
UNL, 1997
CDM, I995a
UNI.. 1996a
I Mid I HtlD.B,.! I ,lil0'J,ijlt7F|,l »
46
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Table 8
Cost Summary for Selected Remedies
II REMEDIATION TASK
1 Radiologically Contaminated Soils
|| Radiological Soils
HWMF Demolition & Disposal
1 Bldg. 81 1-D Tanks
|j Bldg. 8 1 1 -Underground A and B Tanks
Sub Total
1
I Other Areas of Concern
1 Ash Fill
|j Meadow Marsh Basins
Sub Total
| Removal Actions
t ___
Current Landfill*
| Former Landfill and Slit Trench*
| Chemical/Animal Pits & Glass Holes*
| Interim Landfill*
OU I Groundwater Pump and Treat System*
Sub Total
====================================== L
REMEDIATION COSTS
24,032,000
1,380,000
1,440,000 1
1,008,000 I
527,860,000 ]
146,000 1
' :
442,000
$588,000 ~|
zl
3,300,000 I
6,460,000 1
6,587,000 1
1,590,000
4,076,000 I
522,013,000 1
* Incurred costs
T 'OU I ROD**) Tiblo'.Tabk
47
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FIGURES
T'.OUlROD'.oulroda.wpd 6,22/99 43
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New York State
Area Of Detail
(Long Island)
Queens
Brooklyn —J
Brookhaven
National
Laboratory
MID- 11/08/96
gis3/(Jwgs/bnl nys.rnap
Figure 1
BNL Location Map
-------
BBOOKHnUEN
NANONAI. I.AHOKA10RY
EnvJtonmonlnt Hi'slornlton Division
Figure 2
\
MM- (IVM/'i'J
fii.ifitiicVtill (fmil|nti)i nocr, 15
1
18
i /
/ - \
I
Is
sS
s
SCALE
motors
1000 200U
loot
Record of Decision
. Areas Of Conqern (AOC)
LEGEND
1 O Radlologlcally Contaminated Soils
it
J 1 Hazardous Wasle
1 Management Facilily
ii 6 Building 650 Sump and
' Oulfall Area
1 10 Waste Concentration Facility
ll '6 Aerial Rad Survey Results
'j '7 Low Mass Crilicalily Facilily
1 18 Alternating Gradienl
p Synchrolron Storage Yards
~i
/ r. (-; Removal Actions
r
1 1b Groundwaler
"| 2a Former Landfill
^ 2b,c Cheinical/Animal/Glass Holes
^ 2d Slit Trench
' 2e Interim Landfill
3 Current Landfill
• Other AOCs
21 Ash Pit
3a Wooded Wollnnd
B Upland rtechaiye and
Meadow Marsh
2-le.l Rpcliaige Basins
-------
: W-^'^r^'W'" '••"'
OUI - REMOVAL ACTIONS AND
OTHER AREAS OF CONCFRN
-------
StMdo Soils
Aoiial Rod Survey (AOC 16]
Allsrnaling Gradient
Synclnotinn Facilly (AGS)
filotago Yards
(AOC 18)
Fiynre
Opciahlo Unit I
RarJiologlcolly Contaminated Soils
-------
Other
Ares of Concern
Ash Pit
(AOC 2F)
Upland Recharge/
Meadow Marsh
(AOC 8)
Recharge
Basins
(AOCs 24E, 24F)
Wooded
Wetland
(AOC 3A)
OUI
Record of Decision
Radiological
Contaminated Soils
Building 650 Sump
and Outfall
(AOC 6)
former Hazardous
Facility
Waste Mangement
(AOC 1)
Waste Concentration
Facility
(AOC 10)
Low Mass
Criticality Facility
(AOC 17)
AGS Storage
Yard
(AOC 18)
Landscaping
Soils
(AOC 16)
Current Landfill
(AOC 3)
Removal Actions
Former Landfill
(AOC2)
Former
Landfill
(AOC 2A)
Interim
Landfill
{AOC 2D)
Glass
Holes
(AOC 2C)
Groundwater
(AOCs1B&3)
Slit
Trench
(AOC 2E)
Chemical/
Animal Pits
(AOC 2B)
National
Stockpile
Weather Service
(AOC 16s)
Figure 5: Actions covered under the OU I Record of Decision
AOC: Areas of Concern
T vpijmanagm\biower\()UI jipi
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BfUTOKJIfffltN
NAMD'MI IAIIOKAIOKV
Environmental
Restoration
Division
Figqre 6
PRINCIPAL
AREAS OF
CONTAMINATION
WITHIN THE
HWMF
LEGEND
||}ijj Areas exceeding 67 pCi/g Cs-137
g|| Areas exceeding 600 |jCi/g Cs-137
| I Areas exceeding 2800 pCi/gCs-137
•H Aroas wilh pninniinr |O exceed
*™ TCLP liazaidou? limils
[ J Wetlands
Duildiiigs
Fences
(Ml I) tiiygKloiil/indsorK piap'ligl
(AIM ocinl|UratilitcvUUI/rigrj-tWVMF Radsolls
-------
U. S. DEPARTMENT OF ENERGY
BROOKHAVEN NATIONAL LABORATORY
RECORD OF DECISION
OPERABLE UNIT I
AND RADIOLOGICALLY CONTAMINATED SOILS
(INCLUDING AREAS OF CONCERN 6, 8, 10, 16, 17, and 18)
III. RESPONSIVENESS SUMMARY
T:'OU I ROD'.oiilroda.wpd 6/22/99
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TABLE OF CONTENTS
1. INTRODUCTION
57
2. OVERVIEW OF THE RESPONSIVENESS SUMMARY 58
2.1 Site History 5g
2.2 Site Description 50
2.3 Radiologically Contaminated Soils 59
2.4 Other Areas of Concern 59
2.5 Removal Actions g0
2.6 Level of Community Support for the Proposed Alternatives 61
2.7 Changes in the Proposed Plan 6j
3. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 61
3.1 Community Profile g j
3.2 History of Community Involvement §->
3.3 Summary of Community Participation Activities for OUI 64
4 COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS
CONCERNS, AND RESPONSES '. 67
4.1 Overview gy
4.2 Summary Questions and Responses 67
5. RESPONSES TO DETAILED COMMENT LETTERS 68
6. CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES 73
7. REFERENCES 80
T:'OU I ROD\ouIroda.wpd 6G1;99 56
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1. INTRODUCTION
This Responsiveness Summary of the Record of Decision presents the public comments and
concerns and the U.S. Department of Energy's (DOE) responses to those comments and concerns that
address the Feasibility Study Report (FS) and the Proposed Plan for Operable Unit I (OU I) and
several areas of radiologically contaminated soils at Brookhaven National Laboratory (BNL).
The Responsive Summary serves the following two functions:
It provides decision-makers with information about the views of the community
regarding the proposed remedial action and feasible alternatives; and
It documents how public comments have been considered during the decision-making
and provides answers to major comments.
A public comment period for the review of the OU I Proposed Plan and the OU I Feasibility
Study began on April 1,1999 and ended on April 30, 1999. A public meeting was held on April 22,
1999 at 7:3 0 p.m. in the Berkner Hall Auditorium at Brookhaven National Laboratory. Approximately
40 people attended this meeting. Copies of the Proposed Plan and other related infomational material
were available. Copies of the OU I Proposed Plan and the Feasibility Study were provided at the
following Administrative Record/Information Respositories for public review:
U.S. EPA Region II, Administrative Records Room, New York, NY
• . Longwood Public Library, Middle Island, NY
BNL Research Library, Upton, NY
Mastic-Moriches-Shirley Library, Shirley, NY
Based on the comments received during the public meeting and comment period, the DOE
believes that the EPA, NYSDEC, BNL, local government officials and residents were responsive to
the Proposed Plan and generally support DOE's preferred remedial alternatives. No major objections
to the preferred remedy were raised at the public meeting or during the comment period. Section 4
of this Responsiveness Summary summarizes responses to all comments pertaining to the Proposed
Plan and Feasibility Study.
The Responsiveness Summary is divided into the following sections:
2. OVERVIEW OF THE RESPONSIVENESS SUMMARY
This section briefly describes the site background and DOE's proposed alternatives.
3. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
This section provides the history of community concerns and describes community
involvement in selecting a remedy for OU I.
T: '.Of I ROD' ou 1 roda.wpd 6,?Z'W 5 7
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4. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS AND
CONCERNS, AND DOE RESPONSES
This section summarizes the written comments DOE received during the public comment
period, the oral and written comments received during the public meeting, and DOE's
responses.*
5. RESPONSES TO DETAILED COMMENT LETTERS
This section contains specific written responses to the significant comment letters.
Comments from these letters also are given in the summaries in Section 4 of this
document.
6. CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES
This section gives a chronology of the significant Community Relations activities that
pertain to OU I.
7. REFERENCES
2. OVERVIEW OF THE RESPONSIVENESS SUMMARY
2.1 Site History
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 1 947, to the Energy Research and Development Administration
in 1 975, and to DOE in 1 977.
In 1980, the BNL site was placed on 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
contamination of soil and groundwater that resulted from past operations of the facility.
Subsequently, the EPA, NYSDEC, and DOE entered into a Federal Facilities Agreement (herein
referred to as the IAG) that became effective in May 1992 (Administrative Docket Number: II-
CERCLA-FFA-00201) to coordinate cleanup activities. 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 OU I, pursuant to 42 U.S.C. 9601 et. seq., to meet CERCLA
requirements. The IAG also requires cleanup actions to address the identified concerns. Cleanup at
the BNL site will be conducted pursuant to CERCLA, 40 CFR Part 300.
BNL's Response Strategy Document (S AIC, 1 992) grouped the identified areas of concern into
seven Operable Units. OU II and VII were subsequently combined. Remedial investigations and risk
assessments (CDM Federal 1996a, IT 1999a) were conducted. In addition, several accelerated
cleanup actions were taken as discussed in Section II and an interim action was taken at the Building
650 Sump Outfall Area. The Sump Outfall Area was fenced off to prevent unnecessary access. Risk
assessments were conducted to evaluate the nature and extent of contamination, and potential risks
associated with the areas of concern are addressed in this Record of Decision. A Feasibility Study
T '.Ot."l ROD' oulroda.wpd 6i2i*)9 58
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2.2 Site Description
An overview of the areas of concern addressed in this Record of Decision is presented below.
2.3 RadioIogicaHy Contaminated Soils
Record^? Dedsio? C°Maminattd s°ils *» *< fo"°™8 «» »f concen, are included in Ms
the former Hazardous Waste Management Facility (AOC 1)
the Waste Concentration Facility Building 8 1 1 (AOC 1 0)
the radiologically contaminated surface soils (Areas of Concern 1 fi 1 7 a«^ i ON j
• the Reclamation Facility Building 650 and Sump OutLll L™AOC 6)
msmuuonal controls be implemented. Some assorted an^^*** *«
All wastes will be transported off-site to a permitted disposal facility.
2.4 Other Areas of Concern
" ^^ ""^ "^ '°W ««-««» of me«a,s as the
Upland Recharge/Meadow Marsh Area
evn.n.t th Rech^e/Meadow Marsh Area (AOC 8) was the site of an experiment for
ZS£&Z^£^^~^'^ZZ£
H~p°S^^^^^^
salamanders by exposure to metals. Groundwater contaminated with ethylene d?bromide id
contammated soils is addressed in a separate Record of Decision for dibromide and
,cav± "r.r^l^l'01: ""*?* !" thlUPland ^charge/Meadow Marsh
Area
two
T.'OU [ROD-.oulroda.wpd 6/22/99 59
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Recharge Basins ^^
Recharge Basins HS (AOC 24E) and Weaver Drive Basin HW (AOC 24F) receive storm water
effluent, and are included in the BNL State Pollution Discharge Elimination System (SPDES) The
recommended remedy.is operational maintenance and monitoring for the recharge basins A Tiger
Salamander Habitat Management Plan is being prepared in conjunction with the NYSDEC to orotect
this snecies frnm rrmtin* h**;* ™.,;r,+^o,,<,= oi^v_ LU piuuci_i
this species from routine basin maintenance.
Ash Pit
f io. disP°sinS of ^ ™d sla§ from a solid waste incinerator that operated
from 194j to 1963. The proposed remedy is to cover the Ash pit with a soil cap and provide
institutional controls and maintenance to prevent exposures.
Wooded Wetland
The Wooded Wetland received runoff from the Current Landfill when it was operating The
proposed remedy is institutional control and monitoring.
2.5 Removal Actions
DOE determined that accelerated cleanup actions, called removal actions, were required for
several ^ areas of concern. The potential removal actions were evaluated in Engineering
Evaluation/Cost Analysis Reports that were prepared pursuant to CERCLA (COM Federal 1995a
COM Federal, 1995b; and CDM Federal, l?97a). -These reports were made available for public'
review and were approved by the regulatory agencies. The removal actions selected, after considering
public comments, are documented in Action Memorandum (BNL, 1994; BNL, 1996; BNL, 1997)°
Several landfill areas of concern were capped to prevent contaminates from migratin*
Geomembrane caps, constructed pursuant to 6 NYCCR Part 360, were placed over the Current
Landfill, Former Landfill, Slit Trench, and Interim Landfill. Its construction was completed in
November, 1995 at the Current Landfill, in October 1996 at the Former Landfill and Slit Trench and
m November 1997 at the Interim Landfill. Details are documented in construction certification
reports (CDM Federal, 1996b; Weston, 1997; and P.W. Grosser, 1997). The National Weather
Service stockpile was used as fill for the Former Landfill cap. A 55-gallon drum containing soil with
levels of radionuclides too high to place under the cap is stored at the former HWMF and will be
disposed of off-site.
Contaminant soil, debris, and intact bottles were excavated and segregated for treatment and/or
disposal from the Chemical/Animals Pits and Glass Holes. Samples were taken at each pit to ensure
that cleanup levels of soil were met.
Several actions are being taken to address contamination of groundwater resulting from waste
disposal at the former HWMF and the Current Landfill. A groundwater pump and treat system was
installed in December 1996 at the BNL southern boundary to extract and treat Volatile Organic
Compounds (VOC) that contaminate groundwater downdgradient of OUI source areas. The system
T'OUI ROD'uulrcxbupd 6.22.99 60
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These removal'actions are being adopted as final actions in this Rscord of Decision.
2.6 Lev el of Community Support for the Proposed Alternatives
*"
contaminated with cesium-137. transportation accidents, and deer
2.7 Changes in the Proposed Plan
^^^
3. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
3.1 Community Profile
BNL is located in Brookhaven Town at the geographic center of Snffhiv r *. u- L
encompasses the central and eastern part of Lone Island w;t£ , - OUnty' which
Many villages and hamlets dot Brookhaven Town's 260 square miles and BNI « „, A A
T:'OUIROD^oiilroda.vvpd 6/22.'99
-------
council government, which maintains professional planning, development and environment
departments, plus a planning board.
3.2 History of Community Involvement
Historically, public involvement in BNL's environmental restoration activities was low. but
after the establishment of a Community Relations program in 1991, public interest and contact with
BNL increased. Evidence of the'growth of community involvement can be measured by the steady
increase in the size of the Environmental Restorations Division's (BNL) stakeholder mailing list.
which currently numbers 2,312. BNL has made concerted efforts to inform and involve the
community in its remediation efforts since its formation, and OU I has been routinely included in
community involvement efforts.
On March 1,1998 Brookhaven Science Associates became the management group responsible
for BNL. Since then, interaction with the community has been a major focus of BNL's administration
and employees.
Two established mechanisms for community involvement meet monthly at BNL. 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 meetings and an opportunity for public comment is on agenda. The
BER was created to facilitate and expedite the flow of information from BNL to some of its key
stakeholders on significant environmental, operational and/or regulatory/oversight issues. An
independent Community Advisory Council has been meeting since September 1998. Composed of
representatives of established stakeholder groups on Long Island, BNL employees and several
individuals, the council meets to learn about and discuss issues relating to the laboratory and to offer
recommendations to BNL's director.
Community relations activities concerning BNL CERCLA activities have echoed the new
emphasis on community involvement at the decision-making level. Since August 1998, ten
roundtables and workshops have been conducted to solicit community input on groundwater
remediation and sampling of the Peconic River before the final remedies or plans were selected by
BNL. To emphasize the importance of environmental issues, BNL's Director scheduled a BNL
"Environmental Fair Day" in the fall of 1998, which 3,600 community members attended, including
many families with children. As part of the festivities BNL sponsored a "photo opportunity" for
children (and adults) to have their picture taken on a huge drill rig, staffed a display about each of the
Operable Units, and led tours of remediation-sites. Volunteers from BNL staffed the display, the drill
rig, and the tours.
T»OUIROD'oulroda,«.p
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The goals of the Community Relations program are the following:
To solick input from stakeholders about these issues
To provide stakeholder input to DOE/BNL senior management and regulators to be
used as one of the decision-making criteria for evaluating cleanup alternates
To develop relationships with on-site employees, community members a^d leaders and
community environmental activists ieaaers, ana
******* *""<*
A Community Relations Plan was finalized for the BNL site in September 1 99 1
f±ed^uTr CEf LA Secti°" !13 (k) (2)(B)(I-V) •"" 1 17' *e ~on
focused on public information and involvement. A variety of activities was used to provhfc
information and to seek public participation, including the following. P
The compilation of a'stakeholder mailing list
• The regular issuance of the newsletter cleanupdate.
• Meetings held with stakeholders in the form of roundtables, workshops, public meeting
or individual stakeholder contacts. P meetln§s
• Maintenance of the BNL home page on the internet.
• Attendance at and updates provided to civic organization monthly meetings
• Mailings of fact sheets about specific projects.
" ^^f nistrative *"»*• documenting the basis for the selection of removal and
remedial actions at the BNL site, has been established and is maintained at the local
hbranes listed below. The libraries also maintain site reports, press releases, Ld fac
sneets. I he libraries are:
Brookhaven National Laboratory
Research Library
Middle Island, NY 1 1953 Bldg. 477A
Upton, NY 11 973
Mastic-Moriches-Shirley Library EPA Region II
30 1 William Floyd Parkway Administrative Records Room
Shirley, NY 1 1 967 290 Broadway
New York, New York 10001-1866
T .GUI ROD'oulroda.wpd 6:22:99 63
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3.3 Summary of Community Participation Activities for OUI
Listed below are the major areas of community relations activities relating to the remedial
activities that are covered by the OU I Feasibility Study and the Proposed Plan. Section 6 provides
a detailed chronology of all the community relations activities for OU I.
Operable Unit I - Sampling and Analysis Plans
A public notice of availability for review and comment for the "OU I Remedial
Investigation/Feasibility Study, Sampling and Analysis Plans and Site Health and Safety Plan" was
published in local newspapers in October 1993. The public comment period for these documents was
October 25 to November 26, 1993. A public meeting at BNL was held to discuss these reports.
Removal Action VI - Landfills and Chemical Holes
The Removal Action VI "Current Landfill Action Memorandum" was available for public
review in the Administrative Record in January 1995, and a public notice of availability was
published in local newspapers. In May 1995 a public notice for review and comment of Removal
Action VI "Engineering Evaluation/Cost Analysis for Landfill Closure" was published in local
newspapers. A 3 0-day extension of the comment period was requested, and the extension was granted
and noted in an article published in cleanupdate.
A presentation was made to the Community Work Group (an independent citizen group which
looked into operations at BNL during 1996) in May 1996 about the cleanup methods under
consideration for the "chemical/animal/glass holes." An article about the meeting was published in
cleanupdate. In April 1997 a letter was sent to stakeholders advising them that the
"Chemical/Animal Pits and Glass Holes Final Evaluation of Alternatives Report" was available for
public review and comment. A fact sheet on the document also was enclosed. A public notice
appeared in local newspapers. In the spring of 1997 an article about the initiation of the excavation
and remediation of the former waste pits was included in cleanupdate.
In July 1996 the Removal Action VI "Former Landfill Action Memorandum" was available
for public review, and a public notice was published in local newspapers. An extensive article about
the capping of the oldest inactive landfill was published in cleanupdate. The article included photos,
a "cutaway", and a description of the capping process. In June 1997 a public notice of availability for
review and comment of Operable Unit I "Action Memorandum Phase III - Landfill Closure Removal
Action" was published in local newspapers.
Removal Action V Operable Unit I - Groundwater Removal Action and Operable Units I and III
Public Water Hookups
A press release titled "Brookhaven Laboratory to Hold Public Meeting on Environmental
Remediation, January 16, 1996" was issued in December 1995. A public notice for review and
comment of the "Engineering Evaluation/Cost Analysis" (EE/CA) was published in January 1996.
The 30-day public comment period for this document began January 2, and as a result of requests
•nOUIRODVoulroih.upd &3Z99 64
-------
from the community, was extended twice, ending on March 18
January 16, 1 996 public meeting also was include in
to the stakeholders.
A
^^^^f of the
' Summary sheets were sent
e Removal
A public meeting was held on January 16, 1996 at BNL to diVn«tk
Action EE/CA. Approximately 700 peopteattended the meeting USS
A Suffolk County legislator hosted a meeting to brief elected official* «„ A u,-
the community and responded to by DOE. re received •
Or
T \OU I ROD'.oti 1 roda.wpd O/22/99
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cover letter, fact sheet and a copy of the public notice. The cover letter mentioned the dates and
locations of the information/poster sessions.
An article in the Brookhaven Bulletin briefly summarized the topic and provided dates and
times for information/poster sessions.
Two information/poster sessions were held in Berkner Hall, BNL. Total attendance at the two
information sessions was 48, including 8 members of the public and 40 BNL employees. One written
comment was received on the RI Report, and was responded to by DOE.
OU I Feasibility Study and Proposed Plan
The lead story of the December 1998 issue of cleanupdate "Meeting Scheduled on Lab Soil
Cleanup" focused on the OU I Feasibility Study, detailing the cleanup options under consideration
and announcing that the documents would be available for public review shortly. The OU II/VTI
Remedial Investigation Report also was featured in the article.
The Operable Unit I Feasibility Study and Proposed Plan was made available for public
review and comment on April 1,1999. A public notice and a display advertisement announcing the
public comment period, the dates of the information/poster sessions, and the date of the public
meeting were published in local newspapers. A DOE press release that announced the comment
period and summarized the report was issued to media contacts. MB
A mailing was sent to the stakeholders, to all BNL employees, and to others who work on-site.
The mailing, which was formatted in a fashion similar to the newsletter cleanupdate, included a
summary of the report, mentioned the dates and locations of the information/poster sessions and
public meeting, and provided a phone number to call to receive a copy of the entire OU I Proposed
Plan. Two additional display advertisements announcing meeting dates were published in local
newspapers. The Executive Summary of the Feasibility Study and the entire Proposed Plan were
available on the BNL web site, along with the dates and times of the. information sessions and public
meeting.
Two laboratory-wide e-mails reminded BNL employees of the information sessions and the
public meeting dates just before each occurred. An article in the Brookhaven Bulletin explained the
proposed plan briefly and gave meeting dates and the web address.
Flyers announcingthe upcoming poster sessions and public meeting were sent to all the public
libraries in Suffolk County to be posted on their community bulletin boards. Five local civic
organizations were briefed on the upcoming events and the flyers were distributed at the meetings.
One civic association president was briefed by phone. The flyers also were distributed at the April
1999 meeting of the Community Advisory Council.
The Brookhaven Executive Roundtable was provided with an update and overview of
OU I in December 1998 and a comprehensive status report in March 1999. The Community Advisory
T'.OUIROD-uulrodawpd 6/22/99 66
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Council was given an overview of all the Operable Units in December 1998 and a budoet uodate in
January 1999. °
Elected officials were briefed in a letter sent in February 1999, and offered a personal briefing
if that was desired. The staffs of Congressman Forbes and Senators Moynihan and Schumer were
briefed by representatives of BNL and the local DOE-Brookhaven office in March of 1999.
Two poster/information sessions were held at BNL, one at lunchtime and one in the evenine
The public meeting was held at Berkner Hall, BNL on April 22, 1999. Approximately 75 people
attended the three sessions, including 19 members of the public.
4. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS
CONCERNS AND RESPONSES
4.1 Overview
Public comments on the Feasibility Study and the Proposed Plan were submitted durino the
public comment period. These comments are presented in the following two categories:
1- Summary of questions and responses from the OUI Public Meeting held
April 22,1999. These comments were addressed by the panel at the public meeting
and are summarized below.
2. Responses to written public comments received during the public comment period
between April 1 and April 30,1999. These are presented in Section 5, Responses to
Detailed Comments.
4.2 Summary Questions and Responses
Similar questions and comments from different sources were combined and summarized for
a common response. These general topics include the following:
1. Transportation off Long Island
2. Contamination of deer at BNL
3. Off-site disposal of wastes
4. Proposed cleanup remedies
1- Transportation off Long Island
The concerns expressed relate to the planned mode of transportation of contaminated soils
by truck or rail and associated safety concerns and community acceptance.
At present no final decision has been made to use rail or truck. Some wastes will require truck
transportation. Overall it is more cost-effective and safer to transport by rail. The concern of public
acceptance of trucks going through Long Island communities was raised. BNL currently ships
7VOU I ROD'oulroda.wpd 6/21/99 67
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II
hazardous and radioactive wastes by truck off Long Island. Where appropriate, BNL will notify
authorities of large shipments of wastes.
2. Contamination of deer at BNL
Several comments were received regarding contamination of deer with cesium-J 3 7. It was
recommended that all areas with contaminated soils be fenced to keep deer away from these areas.
The NYS Department of Health has concluded that hunters who are potentially exposed to
levels of cesium-137 are not exposed to be a health hazard. Since plans are to cleanup these areas as
a first priority, there is no need to fence these areas now.
3. Off-site disposal of wastes
There were several comments expressing approval of the proposed remedy for excavation and
off-site disposal of the radiologically contaminated soils. There was concern expressed for persons
that may be living near the disposal facility.
The two available facilities, DOE's Hanford, Washington facility and Envirocare of Utah are
fully permitted and licensed by their respective states and comply will all Federal and State
requirements for protection of public health and the environment.
4. Proposed cleanup remedies
Although excavation was generally accepted as the preferred remedy, there was a
recommendation that either "vitrification " or soil washing be adopted.
Vitrification or melting the wastes into a glassy form was evaluated by BNL. Leaving vitrified
wastes in place would require approval by NYSDEC as a low-level radioactive waste disposal facility.
Such a facility would not be permitted over a sole source aquifer or on Long Island under NY State
law. Soil washing also was evaluated in the Feasibility Study and was found to be not cost effective.
The smaller volume of wastes would have the radionuclides concentrated in the fine soil particles and
would require disposal off-site.
5. RESPONSES TO DETAILED COMMENTS
Comment: As a community member, I am very concerned with the specifics in addressing the
cle.anup of hazardous waste sites located in BNL. This newsletter has been concise
in the explanation of the cleanups and proposed cleanups of the sites in question-.
Upon reading this newsletter, I feel that the methods described herein are all
appropriate. Please keep me posted in this regard with future newsletter mailings.
Response: None required.
T.'OU I ROD'uulroth.wpd 6/22/99 68
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
After reading your brochure and the efforts you are making to right the years that
where not concerned with contamination, it seams to me that BNL should continue
to exist for the good that is serves the public. The off-site disposal should go a long
way to protect us who live in the area.
None required.
You are doing a great job of keeping public informed of your progress.
None required.
As a resident of Yaphank for 30 years, I feel betrayed by the BNL. I do not believe
that contaminants in the soil at the Lab were not known for years. My faith is totally
destroyed and I feel real anger. Why is the cleanup taking so long? What else is
being hidden? I'm sure everyone at the Lab hid their heads in the sand and looked the
other way. All our lives are in danger, so Lab employees paychecks are not disturbed.
Contaminants in the soil outside of the Hazardous Waste Management Facility were
first discovered as the result of aerial radiation surveys in 1980 and 1983. In the 1960s
sensitivity of instruments and guidelines for exposure to radiation were less stringent.
BNL was placed on the National Priorities List of Hazardous waste sites in 1989.
However, the full extent and nature of the contamination was not known in 1989.
Under U.S. Environmental Protection Agency requirements, BNL is required to
follow a process of planning and investigations to characterize the nature and extent
of contamination and its associated health risks. One of the objectives of these
investigations is to find any additional areas of contamination that might exist or find
any potential sources of contamination. According to these investigations, the
radiologically contaminated soils on the BNL site are not a current health hazard to
nearby residents. While cleanup is still in the planning stage for some of the areas,
action has been taken on others. For example, the three landfills were capped between
1995 and 1997, and the 55 pits of laboratory wastes were excavated in 1997 to protect
the groundwater.
Proceed with the proposed remedies.
None required.
Regarding the cleanup actions on radiologically contaminated soils on v arious BNL
sites, I'm concerned about the excavation and disposal off-site. What if people live
around the off-site disposal? That includes animals, such as deer, tiger salamander,
etc. They could consume those soils or deer meat after eating them. I suggest that
they should do either of 2 methods: soil washing or vitrification (breakdown the soil).
If you wash or breakdown the soil, that should remove all of the contaminants and
heavy metals in order to make it clean and healthy for those people. Like I said, they
should be recycled.
T:\OUlRODouIroih.wpd 6/22/99
69
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Response: Currently, the available off-site disposal areas for low level radiologically
contaminated soils are the DOE Hanford site in the state of Washington and
Envirocare of Utah. Both sites are in remote desert areas. The disposal facilities
comply with all state and federal requirements for protection of human health and the
environment. The facility design is also protective of wildlife to ensure that they are
not exposed to the waste soils. On-site vitrification (melting waste into glass) was
examined and rejected as an alternative because it would be considered by the
NYSDEC to be a low-level radioactive waste facility which are banned on Long
Island over its sole source aquifer. Approval of an application for such a permit would
be difficult to obtain under current laws. Also, the most cost effective vitrification
alternative would be to vitrify only the most contaminated soils with disposal of the
remaining soils off-site. Soil washing was considered but was not too effective in
removing all of the radioactivity. Also the radioactive contaminants are not broken
down and are concentrated in the fine soil particles which would then be disposed of
off-site.
Comment: You continually refer to health hazards for humans. Has there been or is there in
progress any study done on effects to vegetation in the immediate area and the
surrounding drainage basin (Peconic drainage) for the area? I live on 9 Scudder
Avenue in Manorville, due east of BNL.
Response: A site-wide biological inventory was prepared in 1994 and is in the Administrative
Record. An assessment of general vegetation stress was presented hi that report. No
visible stress to plants was noted that could be associated with on-site contamination.
Also an ecological risk assessment of vegetation .and wildlife was made on the
Peconic River area in the 1998 Operable Unit V Remedial Investigation Report.
Potential risk to vegetation at some on-site locations was identified for metals such
as chromium, silver and mercury. No off-site impacts to vegetation have be identified.
Comment: My comment about the ongoing cleanup actions the Brookhaven National Laboratory
is taking is that in order to get the best technicians to do the cleanup, the Lab must pay
in according to other facilities pay around the country. Currently the wages'are too
low. In order to get the best technicians, you have to pay for the best.
Response: The BNL compensation pottey is to pay rates which are competitive with the job
market based upon the type of job performed.
Comment: What is "institutional control?" (Top p.6) How will this cleanup a wetland? I could
see that it could prevent further pollution, but it's not clear how this will help the
salamanders deal with current contamination. Along with monitoring, this hardly
sounds like a remedy. It makes more sense for the recharge basins, assuming they are
still in use. Wetland reconstruction should be done carefully, it's often unsuccessful.
What measures will ensure its protection.
T OU I ROD'OiilroJawpd 6,1199
70
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Response:
Comment:
Response:
Institutional control refers to the controls and procedures that BNT PV -
and prevent exposures. These include fences L gateTto restSc *
and procedures on digging and excavation, p£^ ^^T'^^
monitoring and maintenance of areas InstimtioSj0nTrnT ^ ^
cleanup the wetlands but are meant to jJS^±^ % ***? ,'°
that contain contaminants below levels that are not liSv to noT ^ °?l ^
monitored and controlled. TTaose wetlands that WtoSS^A ^ Wl11 *
ri~-lamanderS areproposed^^^
and approved before any wetlands are reconstructed. eta'ledplans Wl11 be Prepared
Critique of material mailed to stakeholders about OU I 1) Please. Hnn't ,,c
m documents for public. I couldn't find a defmit J 'of VOC ^
it doesn't hurt to spell it out, people shouldn't have to search
easy for people to look at and they may not read
contaminations are should be on nfap.
Response to Comments
deer issue on page 1-17 and surarize
cone us,ons. Although severa! deer have been found with elevated fevels of ^si™
on contaminated grass, woody plants and soil in open areas of k
T. OU I ROD-ouIroda.wpd 6/22,99 71
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contamination. At present the concentrations found in the deer on-site cannot be
completely explained based on the known concentrations in the soil, grass and areas of
surface contamination. Site specific bioconcentration factors for cesium in BNL deer
are not adequately known. The number of deer samples distant from BNL is small. The
amount of contaminated soil consumed by deer is unknown and level of potassium
which competes with cesium uptake in the soil is unknown.
Comment 2: Though the levels (of cesium-137) detected so far have not reached a sufficient level to
be considered a public health concern, it would seem a prudent act, in somewav, to
restrict the ability of plants to grow in the contaminated areas, or restrict the access of
the animals to the contaminated plants. The easiest way to accomplish this would
probably be to surround the sites with temporary fencing until remediation can take
place. It is somewhat puzzling why this was not done long ago when contamination was
first discovered.
Response: Areas considered to contain levels of cesium-137 of public and worker health concerns
have been fenced and restricted. The landscaping soils associated with buildings 30,
490, 355, 515, 510, 555, and 930 have levels of cesium-137 below public and worker
health concerns that would require posting or fencing. A review of DOE and BNL
requirements by BNL health physicists and environmental restoration staff found that
these areas do not require postings or restrictions. In addition NYSDEC staff surveyed
these areas in the fall of 1998 and concur with the
current BNL policy.
Comment 3: Since this is a potential health problem, this Department requests that positive action be
taken now to restrict the access of grazing animals to contaminated areas of BNL
property.
Response: The recent March 1999 NYSDOH study of deer on and near the BNL site concludes that
the contaminated deer are not a health hazard and do not require any special restrictions
on hunting although they plan to issue a deer advisory to local hunters. Once the Record
of Decision is approved, BNL and DOE plan to remediate these landscape soils as a
priority in 2000. Therefore, immediate fencing of these areas does not seem warranted
at this time.
Comment 4: If it is thought there is some additional means of animal exposure that might account for
the elevated levels, then this should also be discussed.
Response: Based on the aerial radiation surveys, ground confirmatory radiation surveys, extensive
sampling and analysis and historical site reviews; BNL has not found any significant
areas of additional surface soil contamination that might expose animal populations.
Contaminated grass, woody browse and ingested soil are thought to be the principal
source of deer contamination. Except for the Building 650 sump outfall (which is now
fenced) and the locust trees and grass at Building 830 (which soils and plants are now
removed), no additional areas are known where grass or woody plant browse would be
4ft
T OU IROD'onlroJa«TXi 6.7^-
72
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1
a significant source of contaminated food. Other additional sources of animal exposure
are unknown.
Comment 5: Since it seems apparent that the grass in the contaminated areas has been successfully
taking up the cesium, the grass mowing practices in these areas should be examined to
see if inadvertent further distribution has been occurring. If the grass has been simply
cut and left in place, there is of course, no problem. But if the grass has been collected
and transported elsewhere, there might now be another area of unexpected
contamination. r
Response: The standard practice at BNL is to cut the grass and leave it in place. Ground radiation
surveys and sampling and analysis conducted for the OUII/VII Remedial investigation
do not show any appreciable spreading of contamination by grass beyond the areas of
maximum soil contamination. Although grass does take up low levels of cesium-137
it does not bioconcentrate at levels that would result in significant spreading of
contamination. Bioconcentration estimates by BNL staff show levels in grass that are
a fraction of the amount of cesium-137 found in the soil.
6. CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES
Following is a chronology of general and OU I focused community relations activities at BNL.
1991
September 11 BNL Interagency Agreement Final Site Community Relations Plan was
prepared based on community and other stakeholder interviews to summarize
public concerns and DOE's plan for addressing them. The document was
finalized and placed in the Administrative Record.
September 26 A public meeting was 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." As part of the
meeting, additional presentations were made regarding the status of BNL's
environmental restoration activities. Public input and comments were
requested on the draft "Response Strategy Document," the draft "Site
Community Relations Plan," and the draft "Remedial Investigation/Feasibility
Study Work Plan" for OU I. A 30-day public comment period was provided.
October 14-
November 15
1992
February 28
The public comment period for review and comment on BNL's "Response
Strategy Document" and "Community Relations Plan" was held. A public
notice was published.
Superfund fact sheets were made available to the public and entered in the
Administrative Record.
T. OU I RODvoulroda.wpd 6.219
73
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1993
October 25 -
November 26
The public comment period for review and comment on the "OU I Remedial
• Investigation/Feasibility Study, Sampling and Analysis Plans and Site Health
and Safety Plan" was held. A public notice was published.
November 17 A public meeting at BNL was held to discuss the OU I PJ/RA plans.
1995
January 17
May8-
JulyS
December
1996
January 2 -
March 18
January
January 16
February
February
February -
March
Public notice announcing availability of "Removal Action VI Current Landfill
Action Memorandum" was published.
Public comment period for review and comment on the "Removal Action
VI Engineering Evaluation/Cost Analysis (EE/CA) for Landfill Closure."
Public notice was published.
A press release titled "Brookhaven Laboratory to Hold Public Meeting on
Environmental Remediation, January 16, 1996" was issued.
The public comment period for the "Engineering Evaluation/Cost Analysis"
(EE/CA) for, OU I Groundwater was held. A full-page public notice
was published in Part II of Newsday and in the LI Advance, which also
included an announcement of the January 16, 1996 public meeting. Two
summary sheets were sent to the stakeholder mailing list. An announcement of
the extension of the comment period also was sent to the stakeholder mailing
list.
A presentation to the Community Work Group regarding the public water
hookups and a briefing on the "Groundwater EE/CA" was held at BNL.
r
A public meeting was held at BNL to discuss the findings of the OU I EE/CA.
A Suffolk County legislator hosted a meeting to brief elected officials on the
public water hookup project and BNL groundwater contamination in OU I.
Four fact sheets regarding the OU I groundwater contamination were published and
.distributed.
Articles on the OU I groundwater contamination appeared in six editions of the
Brookhaven Bulletin.
February 5, 6 Two question-and-answer sessions were offered to BNL employees
regarding OU I groundwater issues.
T'OU ! ROD'outioJj v.jui 6:22 99
74
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February 8
Spring
May
July 24
July 29 -
September 30
Summer
August 5
1997
Winter
January 8
April 22
Briefing regarding the proposed groundwater treatment plant was given to the
National Weather Service staff.
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholders, all BNL employees, and to BNL retirees.
"Comment period extensions facilitate community inquiries"
"Investigation progressing in Laboratory's central area"
Presentation made to Community Work Group by BNL staff on Chemical/Animal/
Glass Holes."
Public notice announcing availability of "Removal Action VI Former Landfill
Action Memorandum" was published.
The public comment period for review and comment on the "OU I/VI
RI/RA Report" was held. A public notice was published.
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"Design set, construction underway for groundwater cleanup operation"
"Autumn public meeting anticipated at Lab"
"Chemical Holes cleanup discussed with work group"
Stakeholder mailing list sent a cover letter, copy of the public notice and fact sheet
on the OU I/VI RI/RA Report and information on the "Annual Schedules
Update/Report for Site Removal and Remedial Actions" and the Action
Memorandum for Landfill Capping Removal Action, Phase II."
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"Community concerns voiced at Manorville public meeting"
"Soils remedy anticipated during 1997"
"BNL's oldest landfill receives a geo cap"
"Responsiveness Summary (for OU I Groundwater Removal Action) release
expected soon"
Public notice of availability for Action Memorandum for OU I Groundwater
Removal Action and Operable Units I and III Public Water Hookups was published.
Letter sent to stakeholder mailing list informing them of the public comment
period for "Chemical/Animal/Glass Holes Final Evaluation of Alternatives
Report". A summary sheet and a copy of the public notice were included
in the mailing.
T:\OU I ROD\oulroda.wpd 6/21'99
75
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April 23 -
May 23
Spring
June 18
July
August 14
September
November
1998
January
Public comment period was held for review and comment on the
"Chemical/Animal/Glass Holes Final Evaluation of Alternatives Report."
A public notice was published.
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"How wells, sampling track contamination"
"Lab's second pump-and-treat system readied for scheduled June start-up"
"Waste pit cleanup planned to begin in June"
"Agency to assess local health concerns"
"ATSDR formed through, for Superfund"
Public notice of availability of the "Operable Unit I Action Memorandum Phase
III - Landfill Closure Removal Action (Chemical/Animal Pits and Glass Holes
Removal Action)" was published.
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"OER shifts focus to remediation"
"Waste pit cleanup begins at landfills"
"Public meeting expected this fall regarding radioactive soils cleanup"
"BNL's second Record of Decision undergoing final regulator review"
Brookhaven Executive Roundtable given update on Superfund activities including
GUI.
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"Summer projects set stage for fall"
"Solvents are key concern in aquifer"
"BNL applies technologies to plumes"
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"Health agency: Water not a risk to area residents"
"Cleanup work continues independent of report"
"Completed projects adding up as Lab cleanup moves forward"
The following articles were published in the newsletter cleanupdate, which is
mailed to the stakeholder mailing list, all BNL employees, and to BNL retirees.
"Sampling underway in Manorville"
"Waste pit excavation completed"
T^.OU IROD'uulrwJa.wpd eC
76
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April 17 Request from community member for information on OU I/VI.
May
May 6 visited sixteen homes south of the Laboratory to inform them about rh •
installation of a groundwater monitoring well. "* imPendm§
•vj i _ _
cleanup. n raca^Animal/Glass Holes
December 16
1999
January 15 Rcques, from community member for information on public water hookups.
February 17
MaTh^n19" ^icACommentPeri^ for the "Operable Unit IWII Remedial
KJSK Assessment Reoort" A ™ w <•' j • *""*
on the documents and citing the dates fo^infon^alion sessions.
February 19
February 19 Elected officials notified, sent letter
v
February 19 BNL Web page updated to include Executive Summary of OU II/VII RI/RA
dates and locations for information sessions, and publk '
February 23 Brookhaven Executive Roundtable given update on OU I Schedule.
February 25 Information Session #1 on OU II/VII RI/RA Report held in Berkner Hall, BNL.
T'OUlROD\oulroda.wpd 6/2i'99 77
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February 26 Article in Brookhaven Bulletin on OU II/VII RI/RA Report, giving information
session dates.
March 3
March 19
March 23
March 31
March 31
April 1
April
April?
April 8
April 9
April 11
April 12
Information Session #2 on OU II/VII RI/RA Report held in Berkner Hall, BNL.
Staffs of Congressman Forbes, Senator Moynihan and Senator Schumer were
briefed by representatives of BNL and DOE-Brookhaven Group.
Brookhaven Executive Roundtable given presentation on OU I Feasibility Study and
Proposed Plan.
"Booklet" mailed to: l.)the stakeholder mailing list; 2.)all BNL employees; and
3.)others who work on-site but are not BNL employees informing them of
BNL's plans for the "Cleanup of Contaminated Soils." The booklet
summarized information from the "Operable Unit I Feasibility Study Report
and Proposed Plan," and announced the public comment period from April 1,
1999 through April 30, 1999. Dates and locations for the public meeting and'
information sessions also were included.
BNL Web page updated to include Executive Summary of Feasibility Study and
entire Proposed Plan. Also listed were the dates and locations of the information
sessions, the public meeting, and the comment period dates.
Public notices and display advertisements were published in local newspapers,
announcing the public comment period and meeting dates. DOE issues press release
titled "DOE seeks public comment on Brookhaven Lab contaminated soils report."
Five civic associations briefed on upcoming OU I meetings and flyer distributed
with meeting dates listed was distributed. OU I mailing also was made available.
Flyers about meetings taken to Suffolk cooperative Library Services for distribution
to all the libraries in Suffolk County. Libraries were, requested to put the flyers on
the Community Bulletin Boards.
Flyers distributed at the monthly meeting of the Community Advisory Council.
Article in Brookhaven Bulletin on OU I reports and upcoming meetings.
Advertisement of upcoming OU I information sessions and public meeting
published in Sunday edition of Newsday.
Laboratory-wide e-mail reminded employees of the dates and times for information
sessions and the public meeting.
TV.OU I ROD'.ouUoda.wpJ 6£:;9
78
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April 13 Lunchtime Information Session on OU I Feasibility Study and Proposed Plan held
at Berkner Hall, BNL.
April 14 Evening Information Session on OU I Feasibility Study and Proposed Plan held at
Berkner Hall, BNL.
April 22 Public meeting on OU I Feasibility Study and Proposed Plan held from 7'00 - 9'00
p.m. at Berkner Hall, BNL.
April 26 Tour/talk for class from Nassau County Community College, including visit to
landfill
May 17 Tour/talk for class from Nassau County Community College, including visit to
landfill
T:\OU I ROD^ou I roda.wpd 6/3199 79
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7. REFERENCES
Brookhaven National Laboratory, 1994. Action Memorandum Landfill Closure Removal Action
Phase I - Current Landfill. December, 1994.
Brookhaven National Laboratory, 1996a. Action Memorandum Landfill Closure Removal Action
Former Landfill Area. April 8, 1996.
Brookhaven National Laboratory, 1996b. Action Memorandum Operable Unit I Groundwater
Removal Action and Operable Units I & III Public Water Hookups. December, 1996.
Brookhaven National Laboratory, 1997. Final Action Memorandum Phase III - Landfill Closure
Removal Action. June 16, 1997.
Brookhaven National Laboratory, 1999b. Final Proposed Plan for Operable Unit I and
Radiologically Contaminated Soils. March 1999.
COM Federal Programs Corporation, 1995a. Final Engineering Evaluation/Cost Analysis for
Landfill Closure Action, Operable Unit I. March 1995.
CDM Federal Programs Corporation, 1995b. Final Engineering Evaluation/Cost Analysis for
Groundwater, Operable Unit I. September 1995.
CDM Federal Programs Corporation, 1996a. Final Construction Certification Report for Current
Landfill Capping. May 1996.
CDM Federal Programs Corporation, 1996b. Final Remedial Investigation/Risk Assessment Report,
Operable Unit I/VI. June 14, 1996.
CDM Federal Programs Corporation, 1997a. Chemical/Animal Pits and Glass Holes, Final
Evaluation of Alternatives Report. April 1997.
CDM Federal Programs Corporation, 1997b. Current Landfill Annual Monitoring Report. 1997.
CDM Federal Programs Corporation, 1999a. Final Feasibility Study Report Operable Unit I
Radiologically Contaminated Soils. February 26, 1999.
Grosser, 1997. Interim Landfill Closure Construction Certification Report. November 1997.
International Technology Corporation, 1995. RI/FS Work Plan for Operable Unit II and Operable
Unit VII. April 1995.
International Technology Corporation, 1999a. Final Operable Unit II/VII Remedial Investigation
Report. March 1999.
. . 80
-------
International Technology Corporation, 1999b. Final Operable Unit III Remedial Investigation
Report. March 1999. c
SAIC, 1992. Brookhaven National Laboratory Response Strategy Document. 1992.
Science Applications International Corporation, 1993a. Work Plan for Remedial
Investigation/Feasibility Study Operable Unit I, Brookhaven National Laboratory. October 1993.
Science Applications International Corporation, 1993b. Sampling and Analysis Plan for the Landfills
Closure Removal Action Project at Brookhaven National Laboratory. October 1993.
Science Applications International Corporation, 1993 c. Sampling and Analysis Plan for the Spray
Aeration Area project, Operable Unit I, Brookhaven National Laboratory. October 1993.
Weston, 1997. Former Landfill Closure Construction Certification Report. March 1997.
T'-OU 1 ROD oulroda.wpd 6/22/99
SI
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ROD FACT SHEET
SITE
Name: Brookhaven National Laboratory
Location/State: Upton, Suffolk County, New York
EPA Region: 2
HRS Score: 39.92 (7/89)
Site ID #: NY7890008975
ROD
Date Signed: 9/16/99
Remedies: excavation and off-site disposal of contaminated soils
and sediment; removal of out of service facilities; wetland
reconstruction; monitoring and institutional controls
Operable Unit Number: OU-1
Capital cost: $ 23,615,000 (in 1999 dollars)
Construction Completion: 12/2004
O & M annually: $ 45,470 (in 1999 dollars)
Total O & M (present worth): $417,000
Present worth: $ 24,032,000 (number of O & M years assumed - 50)
LEAD
Federal Facility
Primary contact (phone): Mary Logan (212) 637-4321
Secondary contact (phone): Bob Wing (212) 637-4332
Main PRP(s): Department of Energy (DOE)
PRP Contact (phone): Gail Penny (516) 344-3429
WASTE
Type: radiological (cesium-137, strontium-90)
Media: soil and sediment
Origin: leaks and spills
Est. quantity: 39,000 cubic yards
-------
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About NTIS
NTIS collects scientific, technical, engineering, and business related
information — then organizes, maintains, and disseminates that
information in a variety of formats — from microfiche to online services.
The NTIS collection of nearly 3 million titles includes reports describing
research conducted or sponsored by federal agencies and their
contractors; statistical and business information; U.S. military
publications; multimedia/training products; computer software and
electronic databases developed by federal agencies; training tools; and
technical reports prepared by research organizations worldwide.
Approximately 100,000 new titles are added and indexed into the NTIS
collection annually.
For more information about NTIS products and services, call NTIS
at 1-800-553-NTIS (6847) or (703) 605-6000 and request the free
NTIS Products Catalog, PR-827LPG, or visit the NTIS Web site
http://www.ntis.gov.
NTIS
Your indispensable resource for government-sponsored
information—U.S. and worldwide
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