PB96-963818
                                EPA/ROD/R02-96/285
                                June 1997
EPA Superfund
      Record of Decision:
       Brookhaven National Laboratory,
       (USDOE) Operable Unit 4, Upton, NY
       3/25/1996

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     U. S. DEPARTMENT OF ENERGY
BROOKHAVEN NATIONAL LABORATORY
           OPERABLE UNIT IV
          RECORD OF DECISION
                March 14,1996
                 Prepared by:
         Office of Environmental Restoration
          Brookhaven National Laboratory
                 Building 51
              Brookhaven Avenue
               Upton, NY 11973

             Brookhaven Area Office
            U.S. Department of Energy
                 Building 464
                 Bell Avenue
               Upton, NY 11973

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      U. S. DEPARTMENT OF ENERGY






   BROOKHAVEN NATIONAL LABORATORY




           OPERABLE UNIT IV
I. DECLARATION OF THE RECORD OF DECISION

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             DECLARATION OF THE RECORD OF DECISION
                               OPERABLE UNIT IV
                    BROOKHAVEN NATIONAL LABORATORY
                                   UPTON, NY
                     STATEMENT OF BASIS AND PURPOSE

      This decision document presents the selected remedial action for Operable Unit (OU) IV
of the Brookhaven National Laboratory (BNL) site in Upton, New York. Operable Unit IV
includes the Central Steam Facility (CSF), the Reclamation Facility Building 650 Sump and Sump
Outfall, leaking sewer lines, Recharge Basin HO, and associated environmental media.

      This remedial action was selected in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) as amended by Superfund Amendments
and Reauthorization Act of 1986 (SARA) (hereinafter jointly referred to as CERCLA), and is
consistent, to the extent practicable, with the National OU and Hazardous Substances Pollution
Contingency Plan (NCP).  This decision is based on the Administrative Record for the BNL site.

      The U.S. Environmental Protection Agency (EPA) and the State of New York concur
with the selected remedial action.
                          ASSESSMENT OF THE SITE

      Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present a
potential threat to public health, welfare, or the environment.

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 DESCRIPTION OF THE SELECTED REMEDY

       Operable Unit IV is the first of the five operable units at the she for which remedies will be
 selected in individual RODs. The purpose of this remedy is to address contamination associated
 with a 1977 oil/solvent spill and a fuel unloading area near BNL's CSF and with the Reclamation
 Facility Building 650 Sump and Sump Outfall area. The OUIV remedy consists of a combination
 of treatment and institutional controls.

       The  selected remedy consists of the following major components:

       •      Treatment of chemically contaminated soil using a soil vapor extraction system to
              collect organic contaminants in the vadose zone of the 1977 oil/solvent spill area
              and a fuel unloading area at the CSF.

       •      Fencing around the radiologically contaminated soil at the Building 650 Sump and
              the Sump Outfall area with institutional controls and monitoring.

       •       Treatment of groundwater contaminated with organic compounds at the most
              contaminated portion or "hot spot" of the 1977 oil/solvent spill plume area using a
              combination of soil vapor extraction and air sparging technologies.

              An engineering enhancement option for groundwater contaminated with organic
              constituents may be implemented if it is decided by the DOE, EPA, and NYSDEC,
              based on the performance and monitoring data, that soil vapor extraction and air
              sparging alone will not achieve the desired performance levels. The performance
              levels will be defined during the remedial design phase.  The engineering
              enhancement option consists of groundwater extraction, enhanced biodegradation,
              and re-injection of the groundwater and would be used in combination with soil
              vapor extraction and air sparging.

       The components of the selected remedy for contaminated groundwater, in combination
with the engineering enhancement option, and for the chemically contaminated soils, are final
response actions.  The component of the selected remedy that addresses radiologically
contaminated soil is considered an interim action. This interim action is necessary to reduce the
risk posed by potential exposure to radiologically contaminated soil at OU IV. Final remediation
of these soils will be evaluated in the OU I Feasibility Study (FS) and documented in the OU I
ROD, based upon OU I FS conclusions, future land use, and public comment.
                                           11

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                                   DECLARATION
       The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. The final components of the selected remedy utilize
permanent solutions and alternative treatment technologies to the maximum extent practicable,
and satisfy the statutory preference for remedies that employ treatment that reduces contaminant
toxicity, mobility, or volume as a principal element. The interim action component of the remedy
does not and is not intended to address fully the statutory mandate for permanence and treatment
to the maximum extent practicable. The statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element will be evaluated for the
radiologically-contaminated soil in the OUIFS and ROD for the BNL site.

       A five-year review of the remedial action pursuant to CERCLA § 121 (c), 42 U. S. C.
§962 l(c), will not be necessary, because this remedy will not result in hazardous substances
remaining on-site above health-based levels.
Jeanne Fox          s           ^r         /              /    Date
Regional Administrator, Region:
U.S. Environmental Protection Agency
Dr. Carson Nealy                                                  Date
Area Manager
U.S. Department of Energy, Brookhaven Area Office
Michael J. OToole, Jr.           /                                 Date
Director, Division of Hazardous \yaste Remediation
New York Department of Environmental Conservation
                                           ui

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                         TABLE OF CONTENTS

I.     Declaration	i

      Site Name and Location  	i

      Statement of Basis and Purpose	i

      Assessment of the Site	i

      Description of the Selected Remedy  	ii

      Declaration	iii

      List of Acronyms	ix

n.    Decision Summary 	1

1.     Site Name, Location, and Description	1

2.     Site History and Enforcement Activities  	2
      2.1    Site History	2
      2.2    Enforcement Activities 	7

3.     Highlights of Community Participation 	  8

4.     Scope and Role of Operable Unit and Response Action	10

5.     Summary of Site Characteristics  	10
      5.1    Soil Investigations	12
      5.2    Groundwater Investigations	15

6.     Summary of Site Risks  	17
      6.1    Human Health Risks	17
            6.1.1  Identification of Contaminants of Concern	17
            6.1.2  Exposure Assessment	18

                                   iv

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            6.1.3 Toxicity Assessment	19
            6.1.4 Risk Characterization  	19
      6.2   Ecological Risk Assessment  	21
      6.3   Basis for Response/Remedial Action Objectives	21

7.    Description of Alternatives	23
      7.1   Soil Cleanup Alternatives (Chemical)  	23
      7.2   Soil Cleanup Alternatives (Radiological)	25
      7.3   Groundwater Alternatives	28

8.    Summary of Comparative Analysis of Alternatives 	30
      8.1   Threshold Criteria	31
            8.1.1  Overall Protection of Human Health and the Environment ... 31
            8.1.2  Compliance with ARARs	31
      8.2   Balancing Criteria	32
            8.2.1  Long Term Effectiveness	32
            8.2.2  Reduction of Toxicity, Mobility, or Volume  	33
            8.2.3  Short-Tenn Effectiveness  	33
            8.2.4  Implementability	34
            8.2.5  Cost	34
      8.3   Modifying Criteria	35
            8.3.1  State Acceptance	35
            8.3.2  Community Acceptance	35

9.    Selected Remedy	35

10.   Statutory Determinations	37
      10.1   Protection of Human Health and the Environment	37
      10.2   Compliance with ARARS	37
            10.2.1      Chemical Specific ARARs	37
            10.2.2      Location-Specific ARARs	38
            10.2.3      Action-Specific ARARs  	38
            10.2.4      To be Considered  	38
      10.3   Cost Effectiveness	39
      10.4   Use of Permanent Solutions and Alternative Treatment Technologies
      to the Maximum Extent Practicable  	39
      10.5  Preference for Treatment as a Principal Element	39

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      10.6  Five Year Review	39

ffl.   Responsiveness Summary	40

A.    Introduction	41

B.    Responsiveness Summary Overview	44

C.    Background on Community Involvement and Concerns	47

D.    Comprehensive Summary of Major Questions, Comments, Concerns,
      Responses	51

IV.   References  	70

V.    Tables

VI.   Figures
                                  VI

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                                     TABLES




Table 1 -     BNL Physical Plant Data Sheet




Table 2 -     Maximum Concentrations of VOCs and SVOCs in Soil




Table 3 -     Maximum Concentrations of Radionuclides in Soil




Table 4 -     Maximum Concentration of VOCs and SVOCs in Groundwater




Table 5 -     Summary of Chemicals of Potential Concern in She by Area of Concern




Table 6 -     Summary of Soils Alternative Analysis for TCL Organics




Table 7 -     Summary of Radioactive Alternative Analysis




Table 8 -     Summary of Groundwater Alternative Analysis




Table 9 -     Comparative Costs for Soil and Groundwater Alternatives
                                        Vll

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                                     FIGURES


Figure 1 -     Current Land Use Map

Figure 2 -     BNL Locations of Operable Units

Figure 3 -     Operable Unit IV, Areas of Concern (AOCs)

Figure 4 -     Area! Extent of Soils Contaminated with VOCs

Figure 5 -     Maximum Areal Extent of Soil and Groundwater Remediation for VOCs
             Under OUIV

Figure 6 -     Operable Unit IV, Extent of Radiological Contaminated Soils

Figure 7 -     Approximate Locations of Air Sparging and Soil Vapor
             Extraction Wells
                                        vui

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                               LIST OF ACRONYMS
 AGS
 AOC
 ARAR
 AUI
 BNL
 BTEX
 CERCLA
 CSF
 DOE
 DOT
 EPA
 FS
 GPR
 HEAST
 HFBR
 IAG
 IRIS
 LLW
 MCL
 NCP
 NEPA
 NPL
NYSDEC
 OU
PAH
 pCi/gram
 ppb
 ppm
PRAP
PVC
RA
RAGS
RESRAD
RfD
RI
RI/FS
RI/RA
ROD
RSD
 SARA
 SCDHS
 SPDES
 STP
 SVE
Alternating Gradient Synchrotron
Area of Concern
Applicable or Relevant and Appropriate Requirement
Associated Universities, Inc.
Brookhaven National Laboratory
Benzene, Toluene, Ethylbenzene, Xylene
Comprehensive Environmental Response Compensation & Liability Act
Central Steam Facility
United States Department of Energy
Department of Transportation
United States Environmental Protection Agency
Feasibility Study
Ground Penetrating Radar
Health Effects Assessment Summary Tables
High Flux Beam Reactor
Interagency Agreement
Integrated Risk Information System
Low Level Radioactive Waste
Maximum Contaminant Level
National Oil and Hazardous Substances Pollution Contingency Plan
National Environmental Policy Act
National Priorities List
New York State Department of Environmental Conservation
Operable Unit
Polynuclear Aromatic Hydrocarbon
Picocuries per gram
Parts per billion
Parts per million
Proposed Remedial Action Plan
Polyvinyl Chloride
Risk Assessment
Risk Assessment Guidance for Superfund
Residual Radioactive Material Guideline Computer Code
Reference Dose
Remedial Investigation
Remedial Investigation/Feasibility Study
Remedial Investigation/Risk Assessment
Record of Decision
Response Strategy Document
Superfund Amendments and Reauthorization Act of 1986
Suffolk County Division of Health Services
State Pollutant Discharge Elimination System
Sewage Treatment Plant
Soil Vapor Extraction
                                        IX

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SVOC             Semi-Volatile Organic Compound
TAGM            NYSDEC Technical Assistance Guidance Memorandum
TBC              To Be Considered
TIC               Tentatively Identified Compound
USGS             United States Geological Survey
UST              Underground Storage Tank
VOC              Volatile Organic Compound
WCF              Waste Concentration Facility

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    U. S. DEPARTMENT OF ENERGY




BROOKHAVEN NATIONAL LABORATORY






         OPERABLE UNIT IV
     II. DECISION SUMMARY

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                               DECISION SUMMARY

 1.     SITE NAME, LOCATION, AND DESCRIPTION

       Brookhaven National Laboratory is a federal facility owned by the Department of Energy
 (DOE) and operated by the Associated Universities, Inc. (AUI), a not-for-profit consortium of
 nine universities. The mission of BNL is to provide exceptional research facilities for training and
 research in the diverse fields of science, and to meet the appropriate needs and interests of the
 educational, governmental, and industrial research institutions. Brookhaven National Laboratory
 has three major functions.  The first is the design, construction, and operation of large research
 facilities, such as particle accelerators, nuclear reactors, and synchrotron storage rings.  The
 second major function is the support of the research staff in its efforts to carry out long-term
 programs in the basic sciences which have potential long-term payoffs. The third major function
 involves the contribution by the staff to the technology base of the nation. To cany out this
 mission, BNL has been or is maintained by a full staff of 3,300 to 4,000 research and support
 personnel. In addition, about 1,500 other personnel participate each year in research on short-
 term projects as collaborators, consultants, or students.

       Located about 60 miles east of New York City, BNL is in Upton, Suffolk County, New
 York, near the geographic center of Long Island. Distances to neighboring communities from
 BNL are:  Patchogue 10 miles WSW, Bellport 8 miles SW, Center Moriches 7 miles SE,
 Riverhead 13 miles due east, Wading River 7 miles NNE, and Port Jefferson 11 miles NW. The
 BNL she, formerly Camp Upton, was occupied by the U.S. Army during World Wars I and n.
 Between the wars, the site was operated by the Civilian Conservation Corps.  The site was
 transferred to the Atomic Energy Commission in 1947, to the Energy Research and Development
 Administration in 1975, and to DOE in 1977.

       The BNL property is an irregular polygon that is roughly square, and each side  is
 approximately 2.5 miles long.  A current land use map of the BNL site is provided as Figure 1.
 The site consists of 5,321 acres.  The developed portion includes the principal facilities located
 near the center of the site, on relatively high ground. These facilities are contained in an area of
 approximately 900 acres, 500 acres of which were originally developed for Army use. The
 remaining 400 acres are occupied for the most part by various large research machine facilities.
 Outlying facilities occupy approximately 550 acres and include an apartment area, biology field,
 Hazardous Waste Management Area, Sewage Treatment Plant (STP), fire breaks, and the Landfill
 Area. The site terrain is gently rolling, with elevations varying between 40 to 120 feet above sea
 level. The land lies on the western rim of the shallow Peconic River watershed, with a tributary of
the river rising in marshy areas in the northern section of the tract. Table 1 provides a summary of
the physical plant information, including population, physical data, and utilitrties.

      The aquifer beneath BNL is comprised of three water bearing units: the moraine and
 outwash deposits, the Magothy Formation, and the Lloyd Sand Member of the Raritan Formation.
 These units are hydraulicalry connected and make up a single zone of saturation with varying

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 physical properties extending from a depth of 45 to 1,500 feet below the land surface. These
 three water bearing units are designated as a "sole source aquifer" by the EPA and serve as the
 primary drinking water source for Nassau and Suffolk Counties.

       To allow effective management of the BNL she, the 28 Areas of Concern (AOCs) have
 been divided into discrete groups called Operable Units (OUs) and Removal Action AOCs. The
 criteria used for OU groupings are: relative proximity of AOCs, similarity of site problems,
 similar geology and hydrology, similar phases of action or sets of actions to be performed during
 Remedial Investigation/Feasibility Study (RI/FS), and the absence  of interferences with future
 actions at other AOCs or OUs.  The BNL site is divided into five OUs and eight Removal
 Actions. Operable Unit IV is one of the first OUs studied at the site.

       Operable Unit IV is located on the east-central edge of the developed portion of the site
 (Figure 2). Figure 3 shows the extent of OU IV, which encompasses the CSF, otherwise known
 as AOC 5, Reclamation Facility Building 650 Sump and Reclamation Facility Building 650 Sump
 Outfall (AOC 6), Leaking Sewer Lines (AOC 21), and Recharge Basin HO (AOC 24-D)  The
 CSF is located between North Sixth Street, Seventh Road, Brookhaven Avenue, and Cornell
 Street, and consists of approximately 13 acres, divided equally between developed and
 undeveloped land. The Building 650 Sump is approximately 100 feet north of Cornell Avenue.
 The Building 650 Sump Outfall area is located approximately 800 feet northeast of Building 650
 and consists of a natural depression, approximately 90 feet x 90 feet, bounded by dirt roads.  The
 leaking sewer lines are located south of Building 610; Recharge Basin HO is located
 approximately 250 feet to the northeast of the Building 650 Sump  Outfall area.
2.     SITE HISTORY AND ENFORCEMENT ACTIVITIES

       2.1    Site History

             A brief history of each AOC within OU IV is provided below:

             AOC 5 - Central Steam Facility

             The CSF supplies heating and cooling to all major BNL facilities. It consists of a
network of 21 aboveground receiving and mixing fuel tanks, which are connected via
aboveground and underground pipelines to the boiler building (Building 610) located near the
comer of Sixth Street and Cornell Avenue. The tanks are registered with the Suffolk County
Department of Health Services (SCDHS), and have a Major Petroleum Facility License from the
NYSDEC Division of Water Resources.

             AOC 5 has several subAOCs as described below:

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       1977 Oil/Solvent Spill

       On November 25,1977, approximately 23,000 to 25,000 gallons of waste oil and solvent
were released from a ruptured pipe located southeast of the CSF and west of North Sixth Street.
The mixture was composed of 60 percent Number 6 fuel oil and 40 percent mineral spirits.  The
pipe ruptured when a nearby empty 5,000 gallon underground storage tank (UST), which was
enclosed in a concrete structure, rose off its mount as a result of water accumulating beneath the
tank, shearing the connecting lines.

       The spill, which covered an estimated area of 1.2 acres, was contained with sand berms
and free product was recovered with portable pumps. The cleanup activities were coordinated
with EPA and the steps taken were considered at that time to be appropriate by EPA. The total
amount of the soil/solvent mixture that was recovered is unknown.

       Former Leaching Pit

       On November 6, 1989, excavation began at a location south of Building 610 to install a
1,000 gallon underground propane tank.  Although the current utilities maps showed that there
were no underground utility lines at this location, the backhoe encountered an eight inch vitreous
tile pipe approximately 3 to 4 feet below grade.  A review of design drawings of Building 610,
dating back to the 1950s, showed that the pipe had been connected to a Leaching Pit.

       The Leaching Pit was located approximately  100 feet south of the southwest corner of
Building 610. The pit was installed sometime in the  1950s or 1960s to receive waste oil and
washwater from equipment cleaned inside Building 610. Further excavation  revealed that the
vitreous tile pipe led to a sand trap, and eventually to Building 610.

       The Leaching Pit had an outside diameter of approximately 9 feet and was about 11  feet
deep. Its walls were constructed of concrete cinder blocks, and the cover was a 12 inch thick
concrete slab. The cover was located approximately 1 foot below grade.

       The Leaching Pit contained approximately 53 inches of a thick, black, tar material similar
in appearance to Number 6 fuel oil. Excavation proceeded by removing the oil-stained concrete
blocks and surrounding soil, in addition to the sand filter and piping connecting the Leaching Pit
to Building 610.  The estimated dimensions of the excavation were 20 feet deep by 20 feet in
diameter.  Clean sand and soil were placed into the hole. The soil, construction material, and
tarry residue excavated from the Leaching Pit were classified as non-hazardous. Currently,  an
underground propane tank is located at the excavation site. The excavation and cleanup of the
Leaching Pit was coordinated with the LAG agencies and was performed with oversight by the
NYSDEC Region in Oil Spill Division.

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       Former Undergroum| {raspjine Storage Tank

       In May 1990, an abandoned 550-gaIlon underground gasoline tank was discovered under
 the asphalt on the west side of Building 610.  Brookhaven National Laboratory records show that
 the tank was in operation from 1948 until approximately 1963. Excavation and inspection of the
 tank revealed several large rusted-out holes.  Soil from beneath the tank smelled of petroleum.
 The contaminated soil was excavated until the organic vapor content of the remaining soil was
 less than 50 ppm. The depth and lateral extent of the excavation were not documented; however,
 approximately 12 cubic yards of soil were excavated. The hole was backfilled with clean soil
 under authorization from SCDHS.

       CSF Fuel Unloading Areas

       Fuel is unloaded at eight places around the storage tanks. The unloading areas are
 approximately 4 square feet and are constructed of pavement, bhiestone, and concrete.  The
 secondary containments are concrete boxes. Brookhaven National Laboratory has documented
 several small (1 to 10 gallons) surface spills of fuel oil. On three separate occasions, in 1988,
 1990, and 1993, surface spills of about 60 gallons of Number 6 fuel oil were reported.

       CSF Underground Piping

       Four receiving tanks (1,2, 3, and 4) are located to the west of Building 610.  The tanks
 have a combined capacity of 1.1 million gallons.  The majority of the pipelines are aboveground,
 and have had no history of leaking.  However, there are three sections of piping leading to
Building 610 that are below ground. One section is a 12 inch diameter pipe that carries Number 6
fuel oil from Tank 3 to Building 610, a distance of approximately ISO feet.  Another section of
pipe carries Number 6 fuel oil from Tank 1 to Building 610. The third section of underground
piping connects Building 633 to both Building 610 and Tank 1. There are no documented
releases from the pipes.

       Drainage Area East of CSF

       In September 1977, a tank truck was unloading fuel at a fuel-transfer pipe station;
apparently, the valve was in the "closed" position. As a result, approximately 250 to 500 gallons
of fuel were spilled. The fuel, believed to be Number 6 "Bunker C oil," caused excessive back
pressure in the pipeline and ruptured it.  The fuel spilled onto the ground and entered an adjacent
catch basin, with an outlet in the woods east of Building 610.  The oil reportedly flowed east
along a small drainage ditch to a fence which marks the "Gamma Field." The oil ponded in the
low area, and subsequently was collected with recovery pumps. A bulldozer was used to limit the
spread of the oil.

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       AOC 6 - Reclamation Facility Building 650 Sump and Sump Outfall Area

       The Reclamation Facility (Building 650) was constructed for decontamination of
radiologically contaminated clothing and heavy equipment. As a result, Building 650 was
designed to perform wash operations both outside and inside the building. These operations date
back to at least 1959, with the construction of USTs #650-1 and -2, in 1962 and Tanks 650-3 and
-4 in 1972. The structural integrity of the tanks had never been tested.  At present, Building 650
is not used as a decontamination facility, but is still used by BNL as a laundry facility.

       In the past, all soiled laundry from BNL was delivered to Building 650, where potentially
radioactive laundry was segregated from routine laundry. Contaminated laundry was cleaned with
dedicated equipment and the residual washwater remained in two 2,000 gallon USTs (#650-1 and
-2) until its radioactivity could be monitored. These tanks were located on the north side of the
building.  The contents of the tanks were classified as D-waste, defined by BNL as waste with a
gross beta concentration greater than 90 pico Curies/milliliter (pCi/ml).  The liquid waste was
emptied from the tanks about three times a year and taken to the Waste Concentration Facility
(WCF) by a tank truck.  Approximately six drums of sludge were removed from the tanks in
1983.

       Building 650 also served as a decontamination facility for equipment contaminated with
radioactivity.  Equipment was steam-cleaned on a 30 foot by 30 foot concrete pad behind the
north side of the building.  This decontamination pad was in use by 1959, but the date of hs initial
operation is not known. Contaminated water ran down into a drum in the middle of a sloping
pad, known as the Building 650 Sump.  It was presumed that the effluent was piped into the
sanitary sewer system or into holding tanks. Rinse water that was deemed to be excessively
contaminated was supposed to be routed to two 2,000 gallon USTs (#650-1 and -2), designated
for D-waste. Typically, however, the water was deemed clean enough to be routed to two 3,000
gallon USTs (#650-3 and -4), adjacent to Tanks 1 and 2, and designed for F-waste containment.
Brookhaven National Laboratory defines F-waste as waste with a gross beta concentration less
than 90 pCi/ml.  The contents of these tanks were emptied about twice a year; the waste was
discharged to the STP.  The laundry facility and the decontamination pad area are the only known
sources of D and F waste delivered to the four tanks at Building 650

       The USTs (#650-1, -2, -3, and -4) are included under AOC 12 and were removed under
Removal  Action n, the UST Removal Action, during the summer of 1994.

       Building 650 and the Sump Outfall Area were identified during aerial radiological surveys
of BNL conducted in 1980,1983, and 1990.  Thus, Building 650 is also included as subAOC 16
under the Aerial Radioactive Monitoring System Results and was inadvertently included under
OU n/Vn. The investigations under OUIV satisfy all LAG activities for this AOC.

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       In late 1969, five curies of tritium were accidentally released into the sanitary sewer
 system, via the Building 650 Sump. However, this tritium was not detected at the SIP.  An
 investigation into the incident revealed that the drainage pipe from the outdoor concrete pad
 behind Building 650 led to a natural depression in a wooded area about 800 feet northeast of
 Building 650, rather than to either the sanitary sewer system or to a waste holding tank, as had
 been assumed. The practice of washing radioactive equipment on the concrete pad was
 discontinued after the 1969 incident. The natural wooded depression is referred to as the
 Building 650 Sump Outfall Area; the area of radiological soil contamination is approximately 90
 feet by 90 feet.

       AOC 21 • Sanitary and Storm Sewer Lines

       The sanitary and storm sewer lines at BNL date back as far as 1917. Major repairs were
 made in 1940.  Additional modifications have extended the sewer system to 31 miles. Many of
 the sewer and storm lines are composed of vitrified clay tile pipe and have undoubtedly developed
 cracks.  In the region containing the 1977 Oil/Solvent Spill and Leaching Pit,  there are
 approximately 1,300 feet of sanitary sewer line.

       The sanitary sewer main (a 20 inch diameter tile line) transports effluent to the STP
 located to the north of OUIV. Lines carrying storm water in the vicinity of the CSF (south of
 Temple Place) discharge into a wooded area east of the CSF. The main 20 inch sanitary sewer
 line divides into two lines approximately 80 feet south of Tank 3. The 20 inch tile sewer line
 connects with Building 610, passing beneath the valve house and pumping house and then
 continues east along the south side of Building 610.  A large 21 inch diameter line, constructed of
 polyvinylchloride (PVC), runs east for approximately 100 feet off the sewer main,  and then
 continues to the northeast, passing between the locations of the Former Leaching Pit and the 1977
 Oil/Solvent Spill. A third line, 6 inches in diameter, is connected to the main line at the point of
 division and serves Building 529.

       A single sewer line runs east-west between Cornell Avenue and Building 650; it is an 8
 inch line, constructed of tile. It connects to the 20 inch main east of the CSF near Building 528.

       Storm water from Cornell Avenue and water from several outlets at Building 650, as well
 as the Building 650 decontamination pad, are directed to the Building 650 Sump Outfall area, via
a 15-inch line.  The structural integrity of the sanitary sewer lines is known to be compromised by
fractures and slippage along joints in portions of the line beneath OU IV. To  address the type and
extent of damage, a video camera survey of the sanitary sewer main was made in 1988.  The
 structural integrity of the 15-inch diameter storm sewer line connecting the Building 650 Sump to
the Building 650 Sump Outfall Area was not known before the remedial investigation for OU IV.

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       Sub-AOC 24D - Basin HO

       Basin HO is located approximately 250 feet northeast of the Reclamation Building 650
Sump Outfall. Basin HO is the largest of five recharge basins at BNL, discharging to the water
table aquifer approximately 48 percent or 1,530,000 gallons daily of all of the water that BNL
uses for non-contact cooling and related purposes. Basin HO actually is two adjacent basins
constructed of native material (sand and gravel) on 3.9 acres.

       Since 1958, most of the water discharged to Basin HO, approximately 1,374,000 gallons
per day, is single-use, non-contact cooling and process water from the Alternating Gradient
Synchrotron (AGS). Water from the High Flux Beam Reactor (HFBR) also has been discharged
to Basin HO since 1978. The remainder of the water (approximately 156,000 gallons per day) is
multi-cycle blowdown water from the HFBR's secondary cooling system. These discharges are
permitted by NYSDEC under BNL's State Pollutant Discharge Elimination System (SPDES)
permit.

       Water used for cooling and related processes is derived from process/potable supply wells
for the entire operation of Basin HO.  Poly-electrolytes and dispersant is added to the AGS
cooling and process water to keep the ambient iron in solution.  To control corrosion and
deposition of precipitant, water at the HFBR towers was treated with inorganic potyphosphate
(PO4) and benzotriazole before 1982.  Since then, the HFBR water has been treated with
mercaptobenzothiozene.

       Environmental monitoring at Basin HO consisted of sampling the surface water at the
Basin HO Outfall 003 from 1985 to 1989. No sediment, soil, or groundwater samples were ever
collected in Basin HO before the remedial investigation for OUIV.

       2.2    Enforcement Activities

       In 1980, the BNL site was placed on NYSDEC's Inactive Hazardous Waste Sites. On
December 21, 1989, the BNL  site was included on the EPA's National Priorities List (NPL).
Inclusion on the NPL reflects the relative importance placed by the federal government on
ensuring the expedient completion of environmental investigations and resulting cleanup activities.
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).  The IAG identified AOCs that were grouped into the five OUs to be
evaluated for response actions at the BNL she. The IAG requires the conduct of a RI/FS for OU
TV, pursuant to 42 U.S.C. 9601 et. seq., to meet CERCLA requirements. The LAG also requires
the conduct of cleanup actions to address identified concerns.

       In accordance with the June 1994 DOE Secretarial policy on National Environmental
Policy Act (NEFA), this CERCLA document incorporates NEPA values such as analysis of
cumulative, off-she and ecological impacts to the maximum extent practicable.  In particular, the
LAG is intended to ensure that environmental impacts associated with past and present activities at
BNL are thoroughly and adequately investigated so that appropriate response actions can be
formulated, assessed, and implemented.

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       The IAG identified AOC 5, CSF, for a RI/FS and provided a schedule for near-term work.
 A BNL Response Strategy Document (RSD) was written pursuant to the IAG which grouped
 AOC 5 with AOCs 6, 15, 21, and 24-D and prioritized OUIV as the first OU for RI/FS.

       Remediation at the BNL she will be conducted under CERCL A, as amended by the
 SARA, and the NCP, 40 CFR Part 300.

       Following the issuance of the ROD for the last of the five OUs, the necessity of a final
 assessment from a site-wide perspective will be determined to ensure that ongoing or planned
 remedial actions identified in the ROD for the five OUs will provide a comprehensive remedy for
 the BNL site which is protective of human health and the environment.

 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 Section 113 (k) (2)(B)(I-v) and 117, the community
 relations program focused on public information and involvement.  A variety of activities were
 used to provide  information and to seek public participation.  The activities included:
 compilation of a stakeholders mailing list, community meetings, availability sessions, site tours
 and the development of fact sheets. An Administrative Record, documenting the basis for the
 selection of removal and remedial actions at the BNL site, has been established and is maintained
 at the local libraries listed below. The libraries also maintain site reports, press releases, and fact
 sheets. The libraries are:

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

             Mastic-Moriches-Shirley Library
             301 William Floyd Parkway
             Shirley, NY 11967

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

       The Administrative Record is also maintained at the EPA's Region n Administrative
Records Room at 290 Broadway, New York, New York, 10001-1866.

       A chronological summary of the significant community participation activities to date for
OU IV is provided below:

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       September 26, 1991: A Site Specific Plan and 5-Year Plan informational meeting was
held at BNL where the OUIV draft RI/FS Work Plan was also presented to the public.
Presentation handouts on the draft Work Plan were provided to community members at that time.
Although the community was informed by a press release to the local newspapers, attendance at
this meeting was low. A question and answer period was held at the end of the meeting.

       February 17, 1992:  A public notice was published in two local newspapers (Newsdav and
Suffolk Life^ announcing the availability of the OU TV RI/FS Work Plan at local repositories. The
comment period began on February 17, 1992 and concluded on March 17,1992. One community
member commented by letter in April  and was responded to by BNL.

       August 3, 1994: A public notice was published in two local newspapers (Newsday and
Suffolk Life! announcing availability of an Engineering Evaluation Report and Action
Memorandum at local repositories for an OU IV soil interim removal action.  An informational
letter, with public notice attached, was sent to the community mailing list. Two phone calls from
community members were received concerning the disposal of soils.

       January 17, 1995: A public notice was featured in local newspapers announcing the
availability of OU IV Remedial Investigation/Risk Assessment (RI/RA) Report at local
repositories.  The comment period began on January 18,1995 and concluded on February 20,
1995.

       January 25, 1995: An informational letter was sent to community members on the mailing
list concerning the OU RI/RA Report. A civic association requested an extension to the comment
period. Comments were received in April 1995, which focused primarily on groundwater
concerns.  A meeting to discuss these  concerns with the civic association was held on June 5,
1995. A written response to the civic association comments was provided by DOE.

       November 18,1995: An informational letter was sent to community members on the
mailing list announcing the OU IV FS/Proposed Remedial Action Plan (PRAP) public meeting. A
public notice, meeting invitation/PRAP fact sheet, and she tour invitation was attached.

       November 22, 1995: A public notice was published in Newsday and Suffolk Life (on
November 29,  1995) announcing the availability of the FS/PRAP at local repositories for review
and comment.  A 30-day public comment period was held beginning November  22,1995.

       December 6,  1995:  A public meeting was held at BNL for the OU IV FS/PRAP along
with  an afternoon site tour of OU IV.  At this meeting, representatives from EPA, NYSDEC,
BNL, and DOE answered questions and accepted comments on the remedial alternatives under
consideration for OU IV. A response  to comments received during the public comment period is
included in the Responsiveness Summary, which is part of this ROD. This decision document
presents the selected remedial action for OU IV at the BNL site in Upton, New  York, chosen in
accordance with CERCLA,  and to the extent practicable, the NCP.

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       December 22, 1995: Seven community members provided written comments.

       In addition to traditional public involvement activities at CERCLA sites, DOE worked
with stakeholders in identifying a range of future use options for the BNL she.  Final Draft of the
Future Land Use Report was presented to the public in August, 1995. The Final Report was
prepared in September, 1995. Stakeholder preferred future uses identified in this report will assist
with the establishment of acceptable risk and remediation levels for the entire BNL site.

4.     SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION

       In order to adequately evaluate BNL's existing and potential environmental problems, and
to group these problems for such a large she into workable units that could be properly scheduled
and funded, the 28 AOCs have been grouped into five OUs and eight Removal Actions.  This
grouping was performed under an RSD based on the six criteria: (1) relative proximity of AOCs,
(2) similar site problems, (3) similar phases of action or sets of actions, (4) simultaneous actions,
(5) absence of interference with future actions, and (6) similar geology and hydrology.

       The RSD assigned OUIV the first priority based on a preliminary risk assessment and
since an OU IV RI/FS was already underway. Operable Unit IV is the first OU to undergo a
RI/FS. Pursuant to the findings documented in the RI/RA Report, FS Report, and the PRAP, OU
IV addresses remediation of soil contaminated with Volatile Organic Compounds (VOCs) and
Semi-Volatile Organic Compounds (SVOCs) at AOC 5 (1977 oil/solvent spill area), soil
contaminated with radionuclides at AOC 6, and groundwater contaminated with VOCs and
SVOCs from AOC 5 (1977 oil/solvent spill). Conducting this remedial action under OU IV is
part of the overall BNL response strategy and is expected to be consistent with any planned future
actions.

       The other OUs are currently in different phases of RI/FS. The nature, magnitude, and
extent of contamination as well as associated risks will be evaluated and the appropriate response
actions will be implemented under the respective OU.

5.     SUMMARY OF SITE CHARACTERISTICS

       The RI was conducted in accordance with the approved OU IV RI/FS Project Plans.  The
main purposes of the RI were to determine the nature, magnitude, and extent of contamination
due to the AOCs included hi OU IV, and to characterize the potential health risks and
environmental impacts of any contaminants present. The RI included: (1) video camera survey of
a pipeline from Building 650 to the Sump Outfall area, (2) geophysical survey, including magnetic
and Ground Penetrating Radar (GPR) around several buildings within OU IV, (3) soil-vapor
survey of the CSF area, (4) soil borings/soil sampling, (5) monitoring well installation and two
rounds of groundwater sampling, (6) sediment sampling hi the Recharge Basin HO, (7) aquifer
testing hi the form of slug tests, (8) analysis of soil and groundwater samples for various chemical
and radiological constituents, and (9) additional radiological surface soil sampling and survey
                                         10

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 (1994) of AOC 6. The video camera survey and geophysical surveys were conducted in July
 1992. Fifty-seven soil borings and 23 monitoring wells were installed during the RI for OUIV.

       Classification of the nature and extent of soil and groundwater contamination was based
 on the following Applicable or Relevant and Appropriate Requirements (ARARs), such as those
 for groundwater, or guidance/criteria To Be Considered (TBC), such as cleanup goals for soils:

       (1)     Since the groundwater is a federally designated sole source aquifer and is classified
              as a source of potable water by New York State, the most restrictive of the state
              and federal Maximum Contaminant Levels (MCLs) were selected as ARARs.

       (2)     The soil cleanup goals for protection of groundwater contained in the NYSDEC
              Technical Assistance Guidance Memorandum (TAGM) HWR-92-4046 entitled
              "NYSDEC Soil Cleanup Objectives and Cleanup Levels," November 1992, were
              selected for organic compounds found in groundwater.

       (3)     The cleanup goal selected for radiologically contaminated soils, with the exception
              of Radium-226, is the annual dose rate of 10 millirem above background,
              contained in the NYSDEC TAGM 4003 entitled "NYSDEC Soil Cleanup
              Guidelines for Radioactive Materials", September 1993.  This goal, along with the
              assumption of a future industrial land use and an institutional control period of SO
              years, was used to develop soil cleanup guidelines using the DOE Residual
              Radioactivity (RESRAD) computer model.

       (4)     Radium-226 concentrations were compared to the 5 pCi/gram generic cleanup
              guideline contained in DOE Order 5400.5.

       Tables 2, 3, and 4 show the selected ARARs or cleanup goals and the maximum
concentrations of VOCs and SVOCs in soil, radionuclides in soil, and VOCs and SVOCs in
groundwater, respectively.
                                          11

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       5.1    Soil Investigations

              The findings of RI and Risk Assessment (RA) are detailed in the RI/RA Report. A
 summary of the findings of the soil investigations and determinations on remedial actions are
 discussed next.

       AOC 5 • Central Steam Facility:

       1977 Oil/Solvent Spill

       Elevated levels of VOCs and SVOCs are present in the soils in the area adjacent to the
 Oil/Solvent UST, down gradient of the UST, and in the area known to be covered by the 1977
 Oil/Solvent spill. Figure 4 shows the area! extent of soils contaminated with VOCs and SVOCs.
 VOC levels are highest near the Oil/Solvent UST.  The VOCs and SVOCs were detected
 throughout the vadose zone, and are present at elevated concentrations at the water table. The
 most common  VOCs detected include tetrachloroethylene and petroleum-related compounds,
 such as toluene, ethylbenzene, benzene, and xylenes. The most common SVOCs detected include
 a variety of Porynuclear Aromatic Hydrocarbons (PAHs) and phthalates.

       As an interim action, and with the concurrence of the LAG agencies, the Oil/Solvent UST
 and associated  piping were removed in October 1993, along with visibly contaminated soil. The
 excavated soil was stockpiled near the UST location, and soil samples from the piles were
 analyzed in February 1994 to determine disposal options. The results showed that while
 numerous VOCs and SVOCs were present in the stockpiled soil above the cleanup goals, the soil
 was non-hazardous.  On June 10, 1994, BNL disposed of the excavated soils at the Town of
 Brookhaven Landfill after having obtained permission from both the town and the regional
 NYSDEC office. Thirty-four truckloads of contaminated soil and debris totaling 1,413 tons were
 transported to the Town Landfill. Each truckload was screened through BNL's radiological
 vehicle monitor before leaving the she and no radioactivity was detected.

       The vadose zone in the Oil/Solvent UST and spill area will require further remediation due
to the presence of VOCs and SVOCs above cleanup goals.

       Former Leaching Pit

       Low levels of VOCs and SVOCs are present in the soils adjacent to the Former Leaching
Ph. They most likely represent residual materials discharged into the pit from Building 610. The
low levels of tetrachloroethylene may have resulted from the 1977 Oil/Solvent Spill, since that
compound is commonly associated with the spill. The Former Leaching Pit and the Sand Filter
Trap area do not require further remediation since concentrations are below cleanup goals.
                                          12

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       Former Gasoline UST Location

       Low levels of petroleum-related VOCs and SVOCs are present in the soils at
 approximately the subsurface level, i.e., 8 to 10 feet deep, of the Former UST. They represent
 residual compounds from the UST. When the UST was removed, approximately 12 cubic yards
 of soil were excavated, until the organic-vapor content was less than SO parts per million. No
 VOCs or SVOCs were detected in soil samples collected from below 16 feet, indicating that the
 small amount of residual organics in the subsurface soil is not migrating deeper into the vadose
 zone. The Former Gasoline UST will not require further remediation since concentrations are
 below cleanup goals.

       CSF Fuel Unloading Areas

       The VOCs and SVOCs are present in soils adjacent to six of the eight CSF Fuel
 Unloading areas, generally in the shallower portion of the vadose zone. The presence of these
 compounds indicates that minor spills occurred as the fuel was transferred from tank trucks to the
 CSF tanks. Most of these compounds are in the upper portion of the vadose zone, indicating that
 such spills probably were small and have not penetrated far through the unsaturated zone into the
 water table and groundwater.  Elevated levels of VOCs and/or SVOCs above soil cleanup goals
 were detected near one of the eight Fuel Unloading areas. Contaminated soils will need to be
 remediated at this Fuel Unloading Area (see Figure 4).

       Underground Pipes

       Very low levels of VOCs in soil samples at the bottom invert of the fuel pipelines indicate
 that leakage from the pipes adjacent to the boring locations is minimal; none of the organic
 compounds exceed cleanup goals.  The analyses show that the soils adjacent to the pipes will not
 require remediation.

       Drainage Area

       Acetone was the only VOC and phthalate was the only S VOC detected in soil samples
from the Drainage Area; both were below cleanup goals.  The vadose-zone soils along the
pipeline and downgradient of the concrete headwall will not require remediation.

       AOC 6 - Reclamation Facility Building 650 and Sump Outfall

       Reclamation Building 650 Sump

       Acetone was the primary VOC detected in the soil samples in the Sump/Decontamination
Pad area behind  Building 650. The concentrations are below the cleanup goals. Several
chlorinated solvents were detected in soil borings SB38, located on the west side of the
decontamination pad.  Polynuclear Aromatic Hydrocarbons were the primary SVOCs detected in
the soil samples below cleanup goals.  Inorganic contamination was found above  background

                                          13

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 levels, primarily in surface soil samples.  No remediation will be required for inorganics based on
 the risk assessment, as described in Section 6 of this report. While the 0 to 2 foot composite
 samples did not show radionuclide contamination above the cleanup goals, the 0 to 6 inch surface
 soil samples in this area indicate that there is shallow radiological surface soil contamination.  The
 contaminant concentrations in this area exceed the soil cleanup goals for Cesium-13 7, Europium-
 152, and Europium-154.  Therefore, radiologically contaminated surface soils will need to be
 evaluated further.

       Reclamation Building 650 Sump Outfall

       Acetone was the only VOC detected in soil samples at the Sump Outfall and was below
 the soil cleanup goal.  A wide variety of PAHs were the primary SVOCs detected; they were
 present primarily in the surface soil. Inorganic contamination was found above background levels,
 primarily in surface soil samples. No remediation will be required for inorganics based on the risk
 assessment. Two borings (SB48 and SB49) closest to the pipe headwall, had the highest levels in
 surface samples from the Outfall Area. Gross alpha, and gross beta radiation was detected in
 many samples from the Sump Outfall area; both were present in all five surface-soil samples.
 Cesium-137, Strontium-90, Europium- 152 and 154, Radium-226, and Phitonium-239 and -240,
 were found at levels above the RESRAD cleanup guidelines. In addition, the gamma radiation
 level within the sump produces a potential risk that exceeds EPA's target risk level; therefore, the
 vadose soils in the sump outfall also require remediation.  Figure 5 shows the area! extent of
 radiologically contaminated soils in the Sump Outfall area.

       Because the Storm Sewer connecting Building 650 and the Sump Outfall was leaking
 (video camera survey), the pipeline and the surrounding soil will require  remediation.

       AOC 21 Leaking Sewer Line

       Low levels of chloroform and SVOCs were detected in soil samples adjacent to the sewer
line (SB53). This boring is located at the western end of the sewer line and close to the 1977
Oil/Solvent UST Spill. It is likely that this contamination is related to the spill. Since levels are
below cleanup goals and groundwater has not been impacted, the soils around SB53 will not be
remediated.

       SUB-AOC24D  Recharge Basin HO

       No VOCs, SVOCs, Tentatively Identified Compounds (TICs), or Pesticides/PCBs were
detected in the sediment samples from Basin HO, and no inorganic analytes exceeded cleanup
goals.  No remediation will be required.
                                           14

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       5.2    Groundwater Investigations

              The findings of RI and RA are detailed in the RI/RA Report.  A summary of the
findings of the groundwater investigations and determination of remedial actions is discussed next.

              Data from two rounds of groundwater sampling indicates that there were two
primary sources of VOCs: the 1977 Oil/Solvent Spill and UST, and the decontamination pad
behind Building 650. The VOC plume emanating from the northern side of Building 650 is
composed primarily of 1,1,1- trichloroethane at 5.10 ppb and 8.5 (estimated) ppb in the second
round of sampling, only slightly above the NYSDEC MCL of 5 ppb. The plume associated with
the 1977 Oil/Solvent Spill and UST is composed of numerous VOCs and SVOCs which are
predominantly hydrocarbon-related, such as benzene, toluene, ethylbenzene,  xylene (BTEX)
compounds, chlorinated VOCs, and PAHs.  The center of the plume is near the UST, with the
highest levels of VOCs and SVOCs in monitoring wells immediately downgradient. The
contaminants that exceed the selected cleanup goals are listed in Table 4. The highest levels were
observed in the vicinity of the UST.  The farthest downgradient wells in the ballfields contained
only 4 ug/1 of tetrachloroethylene in the second round of sampling, which is below the MCL.
Several of these wells contained low levels of TICs, indicating either that the plume is very diluted
and degraded at the downgradient end of OUIV, or that the plume travels preferentially between
the monitoring well clusters at the southern end of OU IV.  Tentatively Identified Compounds
were identified at all levels of the Upper Glacial aquifer, suggesting that there are no hydraulic
barriers or clay layers within the glacial aquifer in OU IV. Based on site-specific flow, h is
estimated that it would take about 7.8 years for 1,2 dichloroethane (the most mobile of the
organic contaminants) to reach the downgradient wells, located at  approximately 1,800 feet,
while the duration for tetrachloroethylene to travel this distance is calculated as 11.2 years. Using
the hydraulic conductivity value estimated by the U.S. Geological Survey (USGS), travel times
for tetrachloroethylene and 1,2-dichloroethane are 2.1 years and 3 years, respectively.

              The results of inorganic analyses show that no primary MCLs were exceeded for
inorganic compounds in groundwater beneath OU IV. Two radiological parameters exceeded
MCLs for groundwater. In the first round, the monitoring action level for gross beta of 50 pCi/1
was exceeded in monitoring wells 76-091 (88 pCi/1) and 76-20S (120 pCi/1); neither exceeded 50
pCi/1 in the second round. In the second round, Strontium-90 exceeded the federal MCL of 8
pCi/1 in Well 66-19S (53 pCi/1).  In the first round, the Strontium-90 value of 5.2 pCi/1 did not
exceed the MCL. The monitoring action level for gross beta was exceeded in the second round in
Monitoring Well 66-20S (110 pCi/1).

              While isolated spots of radionuclide contamination in groundwater have been
observed, the data for two rounds of sampling and analysis do not indicate any consistent MCL
violations, and therefore, no groundwater remediation for radiological contamination will be
required under OU IV. In addition, there were localized exceedances of secondary MCLs for
iron, manganese, sodium, and aluminum.  The inorganic contamination appears to be localized
and stationary. The contamination is primarily due to VOCs and SVOCs. Groundwater cleanup
will be  required for VOCs and SVOCs for the most contaminated portion of the 1977 oil/solvent

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    spill plume shown in Figure 6. Groundwater monitoring for radionuclides, organics, and
    inorganics will be required.
    and 5.2.
                 The following is a summary of findings of the OUIV RI described in Sections 5.1
                   Area of Concern

       AOC-5:      Central Steam Facility

                   - 1977 Oil/Solvent Spill
                   - Former Leaching Pit
                   - Former Gasoline UST Location
                   - CSF Fuel Unloading Areas
                   - Underground Pipes
                   - Drainage Area

       AOC-6:      Reclamation Facility Building 650
                   and Sump Outfall

                   - Building 650 Sump Area
                   - Sump Outfall Area

       AOC-21:     Leaking Sewer Lines

       AOC-24D:   Recharge Basin HO
SoU
Remediation
Required
Yes
No
No
Yes*
No
No
**
**

No

No
Groundwater
Remediation
Required
Yes
No
No
No
No
No
**
**

No

No
*Only one of the eight fuel unloading areas will require soil remediation.
**Further evaluation is required.

      Tables 2, 3, and 4 provide a summary of the types of contaminants, their maximum concentration,
and their locations. Figures 4 and 5 show the area! extent of chemical and radiological contamination,
respectively, above soil cleanup goals.
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 6.     SUMMARY OF SITE RISKS

       As part of the OUIV RI, an analysis was conducted to estimate the human health risks
 that could result from exposure to OU IV areas if no remediation is performed beyond that
 accomplished to date. This analysis is referred to as a baseline risk assessment. The human health
 risk assessment evaluated both present and future potential exposures to contaminants. Findings
 of the risk assessment are documented in the OU IV RI/RA Report (Volume II), dated December
 7, 1994.

       6.1  Human Health Risks

            The reasonable maximum human exposure was evaluated. A four-step process was
 used for assessing OU IV-related human-health risks for a reasonable maximum-exposure
 scenario: Hazard Identification - identifies the contaminants of concern at the she based on
 several factors such as toxicity, frequency of occurrence, and concentration.  Exposure
 Assessment - estimates the magnitude of actual and/or potential human exposures, the frequency
 and duration of these exposures, and the pathways (e.g., contaminated well water) by which
 humans potentially  are exposed. Toxicity Assessment -  determines the types of adverse health
 effects associated with chemical exposures, and the relationship between magnitude of exposure
 (dose) and severity of adverse effects (response). Risk Characterization - combines the outputs
 of the exposure and toxicity assessments to provide a quantitative (e.g., one-in-one-million excess
 cancer risk) assessment of OU FV-related risks.

            The EPA uses a reference dose (RfD) and a slope factor, respectively,  to calculate
 the non-carcinogenic and carcinogenic risk attributable to a particular contaminant.  An RfD is an
 estimate of a daily exposure level that is unlikely to cause any appreciable risk from  deleterious
 effects during a person's lifetime. A slope factor establishes the relationship between the dose of a
 chemical and the response, and is commonly expressed as a probability of a response per unit
 intake of a chemical over a human life span.

            To assess the overall potential for carcinogenic effects, EPA calculates excess cancer
 risk. Excess cancer risk is the incremental probability of an individual developing cancer over a
 lifetime from exposure to the potential carcinogen. Current federal guidelines for acceptable
 exposure are an excess carcinogenic risk ranging from approximately one-in-ten-thousand to one-
 in-one-million (1E-04 to 1E-06).

      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 (RAGS), Part A and professional judgment, where
appropriate.  The primary consideration for selection  or elimination were frequency  of detection
in analyzed medium, historical site information/activities, chemical concentration, sample chemical
detections relative to blank chemical detections, chemical toxichy (potential carcinogenic and
                                           17

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 non-carcinogenic effects), chemical properties, and significant exposure routes. Table 5 provides
 a summary of chemicals of potential concern at this she by AOC.

       6.1.2  Exposure Assessment

            As part of the risk assessment, present and potential future-use scenarios were
 quantitatively evaluated for the following receptor populations:
            • Area residents (trespassers)
            • Residents
            • Site Workers
            • Construction workers.
       The AOCs evaluated included:

            • Sump Outfall
            • Drainage area
            • Central Steam Facility
            • Building 650 area.

       The environmental matrices evaluated in the risk assessment included:

            • Surface soil
            • Subsurface soil
            • Groundwater

       Present-use scenarios: Under present she conditions, area residents (trespassers) in the
Sump Outfall, she workers in the CSF, and Building 650 area, and construction workers at the
CSF were quantitatively evaluated for surface soil exposure. The exposure routes selected for
evaluation included ingestion, dermal contact, and inhalation of suspended particulates.

       Additional present-use scenarios included site worker (employee) and construction worker
exposures to subsurface soil exposure.  The exposure routes selected for evaluation included
ingestion, dermal contact, and inhalation of suspended particulates.
                                           18

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       No groundwater scenarios were selected for quantitative evaluation under present site
conditions since the water supply is obtained from the potable water system.

       Future-use scenarios: Under potential future she conditions, residents in the Sump
Outfall, Drainage area, CSF, and Building 650 area were quantitatively evaluated for surface soil
and subsurface soil exposures.  The exposure routes selected for evaluation included ingestion,
dermal contact, and inhalation of suspended particulates. Site workers and construction workers
in the CSF and Building 650 area were quantitatively evaluated for surface soil and subsurface soil
exposures.  The ingestion, dermal contact, and inhalation of suspended paniculate routes of
exposure were selected for evaluation.  The only groundwater scenarios quantitatively evaluated
included residential ingestion and inhalation of VOCs exposure.

       Only Sump Outfall surface soil and CSF subsurface soil could be quantitatively evaluated
for dermal contact exposure in the risk assessment. These AOCs/matrices included PCBs and
cadmium as chemicals of potential concern, the only chemicals within OUIV with established
dermal absorption factors.

       6.13  Toxicity Assessment

       The toxicity assessment consisted of presenting lexicological properties of the selected
chemicals of potential concern using the most current lexicological human health effects data.
Toxicity profiles for each of the chemicals of potential concern are presented in Appendix 1-2 of
the RI/RA Report. Many carcinogenic slope factors and reference doses used in this assessment
were obtained from EPA's Integrated Risk Information System (IRIS) data base. Slope factors
and reference doses/concentrations not available on IRIS were obtained from EPA's second most
current source of toxicity information, Health Effects Assessment Summary Tables (HEAST).
The determination of the potential health hazards associated with exposure to non-carcinogens
was made by comparing the estimated chronic or subchronic daily intake of a chemical with the
RfD  Numerous VOCs, SVOCs, pesticides, and inorganics could not be quantitatively evaluated
in this risk assessment due to the lack of established toxicity values.  These were qualitatively
evaluated.  Uncertainty related to the chemical toxicity data was addressed.

       6.1.4  Risk Characterization

       Chemical Risks

       Present and/or potential future area residents (trespassers) in the Sump Outfall Area,
residents (adults and children) in the Sump Outfall, Drainage Area, CSF, and Building 650 area,
and site workers (employees) and construction workers in the CSF and Building 650 area were
evaluated for their exposure to surface soil via ingestion, dermal contact, and inhalation.  All
estimates of carcinogenic risk fell wilhin or outside and below the EPA target risk ranges of one-
in-ten=thousand to one-in-one-million (1E-04 to 1E-06)  All non-carcinogenic hazard-index
values fell below the target level of one.
                                            19

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       Present and/or potential future area residents (adults and children) in the Sump Outfall,
 Drainage Area, CSF, and Building 650 area, and she workers (employees) and construction
 workers in the CSF and Building 650 area were quantitatively evaluated for exposure to surface
 soil via ingestion, dermal contact, and inhalation routes. All estimates of carcinogenic risk fell
 within or outside and below the EPA target risk ranges of one-in-ten-thousand to one-in-one-
 million (1E-04 to 1E-06). All non-carcinogenic hazard-index values fell below the target level of
 one.

       Potential future exposures of residents to groundwater ingestion and inhalation of VOCs
 (shower model) were quantitatively evaluated for OUIV as a whole, assuming that a residential
 well could be installed in any AOC in the future. All estimates of carcinogenic risk fell within or
 outside and below the EPA target risk range of one-in-ten-thousand to one-in-one-million (1E-04
 to 1E-06).  Only the hazard-index value of 1.3 for children exposed by drinking the groundwater
 slightly exceeded EPA's target level of one. The exceedance were almost entirely due to
 manganese. While potential future exposure due to manganese contamination in groundwater
 only slightly exceeds the hazard index target level, groundwater data show that the manganese
 contamination is localized and stationary, therefore, no remediation will be required.

       Radiological Risks

       Present area residents (trespassers) and potential future residents in the Sump Outfall and
 potential future residents, present and future site workers (employees) and potential future
 construction workers in the Building 650 area were quantitatively evaluated for exposures to
 surface soil. The risk estimates for potential future residents in both areas exceeded the EPA
 target risk level. The highest risks were for the future residents in the Sump Outfall Area with a
 total combined (adult and child) carcinogenic risk of 1 in 10 to 1 in 100, when the results from the
 1994 sampling are included.  The major contributor to the risk was from the external gamma-
 radiation pathway. The risk estimate for present site workers in the Building 650 area also
 exceeds the EPA target risk level with a risk of 4 in 1,000. However, the exposures are within the
 occupational exposure standards. All other carcinogenic risk estimates fell within the EPA target
 risk range of one-in-ten-thousand to one-in-one-million (1E-04 to 1E-06).

       Potential future residents in the Sump Outfall and Building 650 areas and present and
 potential future  she workers (employees) and construction workers in the Building 650 area were
 quantitatively evaluated for exposure to subsurface soil via the ingestion, inhalation, and external
 gamma-radiation pathways.  AJ1 carcinogenic risk estimates fell within  or below the EPA target
 risk range of one-in-ten-thousand to one-in-one-million (1E-04 to 1E-06). The highest risk, 8 in
 100,000 or 1 in  10,000 occurred for future residents in the Sump Outfall Area. Again, the
 external gamma-radiation exposure was the pathway with the predominant radiological risk, and
the major contributor was Cesium-13 7.

       Potential future residents sitewide were quantitatively evaluated for exposure to
 groundwater via ingestion.  The carcinogenic risk estimate was within the EPA target risk range
 of one-in-ten-thousand to one-in-one-million (1E-04 to 1E-06).
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       6.2  Ecological Risk Assessment

       The reasonable maximum environmental exposure was evaluated. A four-step process
was used for assessing OU IV-related ecological risks for a reasonable maximum exposure
scenario: Problem Formulation - a qualitative evaluation of a contaminant's release, migration,
and fate; identification of contaminants of concern, receptors, exposure pathways, and known
ecological effects of the contaminants; and selection of endpoints for further study.  Exposure
Assessment - a quantitative evaluation of the release, migration, and fate of the contaminant;
characterization of exposure pathways and receptors; and measurement or estimation of exposure
point concentrations.  Ecological Effects Assessment - literature reviews, field studies, and
toxicity tests, linking contaminant concentrations to effects on ecological receptors. Risk
Characterization - measurement or estimation of both current and future adverse effects.  Unlike
assessments of human-health risk, assessments of ecological risk focus on the wildlife population
and ecosystem levels. Because there is little toxicity data relevant to wildlife, it is difficult to draw
inferences at the population and ecosystems level. Thus, this ecological assessment is largely
qualitative.

       The ecological risk assessment indicated that there are no natural wetlands, threatened,
protected or endangered species, or habitats of special concern within the boundaries of OU IV.
Although wetlands and areas which may support species of concern occur within the two-mile
radius of OU IV, these areas are not affected by contamination confined within the OU IV area.
The preliminary lexicological screening suggests that contamination in OU IV is not having a
significant adverse impact on receptors identified during the site surveys.  During the four site
visits, no visible signs of adverse ecological effects were observed.
       6.3  Basis for Response/Remedial Action Objectives

       Actual or threatened releases of hazardous substances from OU IV, if not addressed by
implementing the response actions selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment. The following is a summary of the
remedial action objectives:

       The objectives of remedial action are specific goals that protect human health and the
environment; they specify the contaminants of concern, the exposure routes, receptors, and
acceptable levels of contaminant for each exposure route.  These objectives are based on available
information and standards, such as ARARs and TBCs established in the risk assessment.

       As indicated by the RI/RA, there is no risk posed by the surface and subsurface soil
contamination due to organics and inorganics within OU IV above the acceptable range. Since
the primary concern is the protection of the sole source aquifer which underlies OU IV, soil
remediation of VOCs and SVOCs will be addressed using the Cleanup Goals contained in
NYSDEC Soil Cleanup Objectives and Cleanup Levels, NYSDEC TAGM HWR-92-4046,
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November 1992, which are designed to be protective of groundwater. NYSDEC TAGMs are not
promulgated standards but are TBCs.

       The radiological risk is primarily from possible direct exposure to gamma-radionuclides
emitting in soil of Building 650 and Sump Outfall areas. Cleanup goals are contained in the
NYSDEC TAGM 4003 (TBC), NYSDEC Soil Cleanup Guidelines for Radioactive Materials,
September 1993.

       There are no current unacceptable risks due to groundwater contamination at OUIV
because the groundwater is not being used. However, the aquifer is designated as a sole source
aquifer under the Safe Drinking Water Act and classified by the New York State as GA, i.e.,
groundwater whose best use is as a potable water supply.  The overall objective of the
groundwater remediation is to preserve the aquifer as a future drinking water resource and
prevent exposures due to future use.  As such, the goals selected for groundwater remediation are
the most restrictive of the federal and state MCLs. The proposed remediation will focus on the
"hot spot," i.e., the most heavily contaminated portion of the groundwater associated with the
1977 oil/solvent spill.

       The following objectives for remedial action were established for OU IV:

       •   Prevent/minimize the leaching of chemical and radiological contaminants from the
           vadose zone soils into the underlying sole-source aquifer (Upper Glacial aquifer) due
           to the infiltration of precipitation.

       •   Restore the water quality of the part of the Upper Glacial aquifer at the most
           contaminated  portion of the AOC 5 plume within the OU IV boundaries to MCLs or
           background levels, as appropriate.

       •   Prevent/minimize the volatilization of chemical and radiological contaminants from
           surface soils into the ambient air.

       •   Prevent/minimize the migration of chemical and radiological contaminants from the
           surface soils via surface runoff and windblown dusts.

       •   Prevent/minimize human exposure, including ingestion, inhalation, and dermal
           contact for present and future residents (trespassers), site workers (employees), and
           construction workers, and environmental exposure to chemical and radiological
           contaminants in the surface and subsurface soils and groundwater.

       •    Prevent/minimize the uptake by plants and animals of chemical and radiological
           contaminants present in the soils and/or groundwater.
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       Comprehensive Environmental Response Compensation & Liability Act requires that each
selected site remedy protects human health and the environment, is cost effective, complies with
other statutory laws, and uses permanent solutions, alternative treatment technologies, and
resource recovery alternatives as fully as practicable.
7.     DESCRIPTION OF ALTERNATIVES

       A detailed description of soil cleanup alternatives and groundwater cleanup alternatives is
provided in the OUIV FS Report. The following is a summary of these alternatives.

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

       The OU IV FS Report evaluates, in detail, five remedial alternatives for addressing the
chemical contamination in soil, four radiological soil cleanup alternatives for the soil, and six OU
IV cleanup alternatives for groundwater.  The numbering of alternatives in this ROD corresponds
to the numbering in the FS Report.

       Alternatives retained for comparative analysis in the OU FV FS Report are:

       7.1   Soil Cleanup Alternatives (Chemical)

       The alternatives discussed below were developed to address the leaching of contaminants
from the vadose zone soils into the underlying sole-source aquifer due to infiltration by rainwater.
The present cost includes the 5-Year review cost for all alternatives.

       Alternative S-l: No Further Action:

       Estimated Capital Cost:             $0
       Estimated Annual O&M Costs       $46,400
       Estimated 5-Year Review Cost:      $15,000
       Estimated Present Worth Cost:       $36,400
       Estimated Construction Time:       N/A

       The CERCLA and NCP require the evaluation of a "No Action" alternative to compare
with other remedial-action alternatives. The "No Action" alternative for the OU IV  chemically
contaminated soil consists of a single sampling event which includes soil-vapor survey and
groundwater sampling and analysis for TCL compounds and a review of site conditions at the end
of five years to determine whether the contamination in the vadose zone has spread horizontally
and vertically.

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       Alternative S-2: Limited Action

       Estimated Capital Cost:            $0
       Estimated Annual O&M Costs:      $ 33,200
       Estimated 5-Year Review Cost:      $ 15,000
       Estimated Present Worth Cost:      $511,000
       Estimated Construction Time:        1 month

       This alternative includes an annual sampling consisting of a soil-vapor survey and
groundwater sampling to conduct a monitoring program which would track the migration of the
contaminant into the aquifer for at least 30 years. The samples would be collected annually at the
same locations as in Alternative S-l. Groundwater samples would be collected from four shallow
monitoring wells within or immediately downgradient of the contaminated soil. All samples
would be analyzed for TCL organics.

       Alternative S-3: No Excavation - Soil Vapor Extraction

       Estimated Capital Cost:            $373,700
       Estimated Annual O&M Costs:      $141,900
       Estimated 5-Year Review Cost:      $ 15,000
       Estimated Present Worth Cost:      $638,000
       Estimated Construction Time:       3 months

       This remedial alternative consists of installation and operation of a soil-vapor extraction
(SVE) system. The SVE component is expected to operate for approximately two years. The
SVE would remove most of the volatile organics present in the soil.

       Alternative S-4: Total Excavation - On-Site Treatment or On-Site/Off-Site Disposal
       of Excavated Soils

       Estimated Capital Cost:
        Option S-4A:                    $2,574,500
        Option S-4D:                    $4,864,600
       Estimated Annual O&M Costs:      $0
        (Options A&D)
       Estimated 5-Year Review Cost:      $0
       Estimated Present Worth Cost:
        Option S-4A:                    $2,570,000
        Option S-4D:                    $4,860,000
       Estimated Construction Time:        6 Months
        (Options A&D)
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       The major features of this remedial alternative are the complete excavation of 6,770 cubic
yards of contaminated vadose-zone soils, followed by on-site treatment or off-she disposal of
those soils. On-site treatment consists of low-temperature thermal desorption in Option S-4A.
Option S-4D consists of disposal of non-hazardous soils at the off-she landfill, such as the Town
ofBrookhaven.

       Alternative S-S: Partial Excavation/Soil Vapor Extraction

       Estimated Capital Cost:
        Option S-5A:                    $1,798,600
        Option S-5D:                    $2,757,400
       Estimated Annual O&M Costs:      $   70,000
        (Options A& D)
       Estimated 5-Year Review Cost:     $   9,000
       Estimated Present Worth Cost:
        Option S-5A:                    $1,930,000
        Option S-5D:                    $2,890,000
       Estimated Construction Time:        6 months

       The major features of this remedial alternative include the partial excavation of 3,290
cubic yards of contaminated vadose-zone soils down to a maximum depth of 16 feet, followed by
their on-site treatment or off-she disposal. The unexcavated deeper soils will undergo treatment
with SVE.  The SVE system will be similar to the one in Alternative S-3 but considerably smaller.
The excavated soils are either treated on she or disposed of off site, exactly as in Alternative S-4.
On-site treatment for Alternative S-5 consists of low-temperature thermal desorption in Option S-
5 A.  Option S-5D consists of disposal of non-hazardous soils at the off-she landfill such as the
Town ofBrookhaven.

       7.2  Soil Cleanup Alternatives (Radiological)

       The alternatives described below are developed to prevent and minimize radiological
exposure from surface and subsurface soils contaminated with radionuclides whhin AOC 6.

       Alternative R-l: No Further Action

       Estimated Capital Cost:             $39,215
       Estimated Annual O&M Costs:      $49,500
       Estimated 5-Year Review Cost:      $ 15,000
       Estimated Present Worth Cost:      $78,000
       Estimated Construction Tune:        N/A

       Under the "No Action" alternative, no remedial action would be taken and AOC 6 would
continue in its current state.  A single sampling and a review of she conditions would be made
after five years to determine whether contamination has spread. The sampling event would
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 consist of alpha, beta/gamma, and gamma radiation survey, and groundwater sampling.
 Groundwater monitoring would be conducted for radiological parameters.

       Alternative R-2: Limited Action

       Estimated Capital Cost:            $  76,300
       Estimated Annual O&M Costs:      S  37,950
       Estimated 5-Year Review Cost:     $  15,000
       Estimated Present Worth Cost:      $769,000
       Estimated Construction Time:        1 month

       This alternative includes installing a fence to prevent access to the sites, and annual
 sampling (same as Alternative R-l) to determine whether radiation levels have decreased with
 time and to track migration of the contaminant into the groundwater.  Institutional controls
 consisting of restrictions on construction and personnel access at the sites would be instituted.
 Eight existing and two new monitoring wells from and downgradient of the Sump Outfall will be
 monitored semi-annually for radiological parameters.  The natural decay of radionuclides and
 migration of contaminants would be assessed and reports would be written every five years using
 the data collected during annual monitoring.

       Alternative R-3: Total Excavation - On-Site Storage/OfT-Site Disposal of Excavated
       Soils

       Estimated Capital Cost:
        Option R-3 A:                    $ 3,205,630
        Option R-3B:                    $33,632,850
       Estimated Annual O&M Costs:      $    33,600
       Estimated 5-Year Review Cost:      $    15,000
       Estimated Present Worth Cost:
        Option R-3 A:                    $ 3,820,000
        Option R-3B:                    $34,200,000
       Estimated Construction Time:        6 months

       The major features of this remedial alternative include the excavation of 6,510 cubic yards
of soil in AOC 6 with radionuclides above the selected action levels, followed by on-site
storage/off-site disposal of this contaminated soil. This alternative also includes excavating
contaminated debris, including the concrete decontamination pad at Building 650, the Storm
Sewer pipe, and the concrete Storm Sewer pipe headwall at the outfall area.  For the on-site
storage option (Option R-3 A), soil and debris contaminated with radionuclides excavated from
these areas would be placed into a temporary storage structure consisting of a steel frame and a
concrete base. The structure would store contaminated soil and debris pending the selection of
remedial alternatives for the other OUs at BNL.  The purpose of storing these soils on site is to
combine all  radiologically contaminated soils at BNL into one sitewide remedial action.  The off-
                                          26

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site disposal option (Option R-3B) consists of transporting excavated soils in approved containers
to the DOE Hanford facility for disposal as low-level radioactive waste (LLW).

       Groundwater monitoring of 10 wells would be conducted semi-annually for the first 20
years and every 5 years thereafter. Radiological surveys would be conducted on the same
schedule. The data would be summarized in a report every five years.

       Alternative R-4: Partial Excavation • Oil-Site Storage/Off-Site Disposal Excavated
       Soils and Capping

       Estimated Capital Cost:
        Option R-4A:                    $2,737,900
        Option R-4B:                    $18,210,370
       Estimated Annual O&M Costs:      $    37,354
        (Options A&B)
       Estimated 5-Year Review Cost:     $    15,000
       Estimated Present Worth Cost:
        Option R-3 A:                    $3,420,000
        Option R-3B:                    $18,900,000
       Estimated Construction Time:        6 months

       The major features of this alternative include the excavation of 3,320 cubic yards of the
most significantly radiologically contaminated soil, followed by on-site storage/off-site disposal.
This alternative also includes excavating contaminated debris, including the concrete
decontamination pad at Building 650, the Storm Sewer pipe,  and the concrete Storm Sewer pipe
headwall at the outfall area. The soils would be excavated from the Building 650 area and the
Storm Sewer Outfall to a depth of 2 feet, and from the Storm Sewer at the elevation of the buried
pipe down to 4 feet below the bottom of the pipe.  The excavated areas would be filled with clean
soil to grade, and a single layer cap would be constructed for Building 650 and Storm Sewer
Outfall area. Run-on/run-off water from the Storm Sewer Outfall cap would be diverted to a
concrete pipe that would be connected to the sewer line at Cornell Avenue and North Sixth
Street.  Control of runon/runoff will not be necessary at the Building 650 area since there already
is an adequate stormwater diversion system.  A cap would not be placed over the excavated
Storm Sewer pipe because the area is too narrow.

       Options R-4A with on-site storage and R-4B with disposal at the Hanford facility
conceptually are the same as Options R-3 A and R-3B.
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 7.3    Groundwater Alternatives

       The alternatives described below are developed to meet the remedial objectives described
 above with a focus on hot spot remediation of the most contaminated portion of the AOC 5
 plume.

       Alternative GW-1: No Further Action

       Estimated Capital Cost:                   $0
       Estimated Annual O&M Costs:            $52,100
       Estimated 5-Year Review Cost:            $ 15,000
       Estimated Present Worth Cost:            $40,900
       Estimated Construction  Time:              N/A

       This alternative includes a single sampling event and a review of site conditions at the end
of five years to determine whether the contamination has spread. For the Former Oil/Solvent
UST area, samples would be collected from monitoring wells.  All samples would be analyzed for
TCL organics.

       Alternative GW-2: Limited Action

       Estimated Capital Cost:                   $  59,500
       Estimated Annual O&M Costs:            $ 39,500
       Estimated 5-Year Review Cost:            $  15,000
       Estimated Present Worth Cost:            $667,000
       Estimated Construction Time:              N/A

       This alternative includes an annual long-term groundwater monitoring program which
would track the migration of the contamination in the aquifer for at least 30 years. Every five
years a report would be prepared to assess the migration and contaminant concentrations in the
plume.

       Alternative GW-3A: Chemical Precipitation, Air Stripping, and Polishing with
                          Activated Carbon - Infiltration Through Recharge Basins

       Estimated Capital Cost:
       Option GW-3A:                      $2,074,500
       Estimated Annual O&M Costs :
           Option GW-3A:                   $ 541,950
       Estimated 5-Year Review Cost:           $   15,000
       Estimated Present Worth Cost:
       Option GW-3A:                      $6,070,000
       Estimated Construction Time:              1 year
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       The major features of this remedial alternative include extracting the groundwater from
the AOC 5 plume, pretreatment to remove metals from groundwater, treating it to MCLs or
natural background as appropriate discharging the treated water, and undertaking a performance-
monhoring program which would include the AOC 6 plume. It is expected that a series of
pumping tests will be conducted during the remedial design stage to verify withdrawal and
recharge rates prior to actual engineering design of the extraction system.

       Treating the extracted groundwater would consist of chemical precipitation to remove
inorganics; this would be followed by air-stripping to remove VOCs. The final treatment step
includes polishing with activated carbon to remove SVOCs. Treated groundwater would be
discharged to a new recharge basin (Option GW-3A).

       Alternative GW-4A: Chemical Precipitation and Chemical Oxidation Enhanced
                           with UV Photolysis - Infiltration Through Recharge Basins

       Estimated Capital Cost:                   $2,264,470
       Estimated Annual O&M Costs:            $  599,450
       Estimated 5-Year Review Cost:            $    15,000
       Estimated Present Worth Cost:
        Option GW-4A:                        $6,670,000
       Estimated Construction Tune:              1 year

       The major features of this remedial alternative include extracting groundwater from the
AOC 5 plume, treating the groundwater to MCLs or natural background, as appropriate,
discharging the treated water, and setting up a performance-monitoring program which would
include the AOC 6 plume.

       Treating the extracted groundwater would consist of chemical precipitation to remove
inorganics, followed by chemical oxidation enhanced with UV photolysis to remove VOCs and
SVOCs. Treated groundwater would be discharged to a new recharge basin (Option GW4A).

       Alternative GW-5A: Chemical Precipitation and Carbon Adsorption - Infiltration
                           Through Recharge Basins

       Estimated Capital Cost:
        Option GW-5A:                     $2,028,200
       Estimated Annual O&M Costs:         $  558,000
       Estimated 5-Year Review Cost:         $   15,000
       Estimated Present Worth Cost:
        Option GW-5 A:                     $6,140,000
       Estimated Construction Time:            1 year
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       The major features of this remedial alternative include extracting the groundwater
 (pumping and collection) from the AOC 5 plume, treating it to MCLs or natural background, as
 appropriate, and discharging the treated water, and a performance-monitoring program would be
 adopted which would include the AOC 6 plume.

       Treating the extracted groundwater would consist of chemical precipitation to remove
 inorganics, followed by carbon adsorption to remove VOCs and SVOCs. The discharge of
 treated groundwater would be infiltration through a new recharge basin (GW-SA).

       Alternative GW-6  Air Sparging (AS) and Soil Vapor Extraction (SVE)

       Estimated Capital Cost:                   $  886,000
       Estimated Annual O&M Costs:            $  427,000
       Estimated 5-Year Review Cost:            $   15,000
       Estimated Present Worth Cost:            $ 1,062,000
       Estimated Construction Time:              1 year

       The major features of this alternative include in-situ groundwater treatment using a
 combination of AS and SVE.

       The VOCs in the groundwater plume would be transferred into the vadose zone using air
 sparging, where they would be captured by the SVE wells and treated as appropriate before
 discharge to air.

       Upon review of the performance and monitoring data, if it is decided by DOE, EPA and
NYSDEC, that SVE and air sparging alone will not achieve desired performance levels, Enhanced
Biodegradation may be implemented along with the S VE/AS system as an engineering
enhancement option. The desired performance levels will be defined during the remedial design
phase.  The engineering enhancement option consists of: groundwater extraction using extraction
wells located downgradient of the VOC plume, addition of nutrients, and reinjection into the
saturated zone using injection wells and/or recharge basins located upgradient of the Oil/Solvent
Spill area. This option would promote the in-situ biodegradation of organic compounds. The
present worth cost of SVE/AS with the engineering enhancement option is $3,110,000.

8.     SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

       The CERCLA guidance requires that each remedial alternative be compared according to
nine criteria. Those criteria are subdivided into three categories: (a) threshold criteria that relate
directly to statutory findings and must be satisfied by each chosen alternative; (b) primary
balancing criteria that include long- and short-term effectiveness, implementability, reduction of
toxicity, mobility, volume, and cost; and (c) modifying criteria that measure the acceptability of
the alternatives to state agencies and the community. The following sections summarize the
evaluation of the candidate remedial alternatives according to these criteria.
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       A detailed comparative analysis of all alternatives is provided in Chapter 5 of the FS
Report. Tables 6, 7, and 8 provide a summary of comparative alternative analysis for soil and
groundwater alternatives. A summary of comparative analysis of alternatives, based upon the
evaluation criteria noted above, is given below.

   8.1 Threshold Criteria

       The remedial alternatives were evaluated in relation to the threshold criteria: overall
protection of human health and the environment and compliance with ARARs.  The threshold
criteria must be met by the remedial alternatives for further consideration as potential remedies for
the ROD.

       8.1.1 Overall Protection of Human Health and the Environment

            Alternatives S-l and S-2 rely on natural processes of biological reactions and
washing by infiltration of rainwater to restore quality. In the long term, there is potential risk of
exposure to future residents from the groundwater which has a potential to be contaminated by
the chemically contaminated soils. Alternatives S-3, S-4, and S-5 would eliminate the toxicity and
the exposure pathways from excavation/treatment of soils.  Since Alternatives S-4 and S-5 rely on
land disposal of untreated soils, they could adversely affect the environment.

            Alternative R-l relies on natural dispersion and decay processes to improve soil
contamination levels, does not meet cleanup goals and would not be effective in reducing
potential risks to human health and the environment since the contaminated soil would continue to
be a source of groundwater contamination.  Alternative R-2 reduces risks to the public health by
eliminating access and exposure to the contaminated soils. However, Alternative R-2  is less
certain in the longer term since the contaminated soils would remain in place.  Alternatives R-3
and R-4 are protective of human health and the environment.

            Alternatives GW-1 and GW-2 rely on natural processes of dilution and biological
reactions to restore groundwater quality, therefore, have a longer restoration time frame than the
other alternatives. All of the groundwater alternatives fully protect human health and the
environment because the groundwater quality is restored to MCLs.

       8.1.2 Compliance with ARARs

            There are no federal or state ARARs that contain specific soil cleanup levels for
chemical and radiological contaminants. The NYSDEC TAGM cleanup goals are not
promulgated standards and are classified as TBCs under CERCLA These NYSDEC TAGMs are
therefore utilized as cleanup goals for chemically and radiologically contaminated soil.
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          Alternatives S-l and S-2 would not meet the organic, chemical-specific TAGM
     cleanup goals for the soils over a very long time and would continue to be a source of
     groundwater contamination. Alternative S-4 would achieve the organic chemical-specific,
     state cleanup goals in months. Alternatives S-3 and S-5 are expected to achieve the
     organic chemical-specific state cleanup goals in about two years.  Alternatives S-4 and S-5
     would comply with ARARs and TBCs for disposal of contaminated soils.

          Alternative R-l would not meet the soil cleanup goal of NYSDEC TAGM (TBC).
     Alternative R-2 would meet the cleanup goal by restricting access to the soil by fencing
     and institutional control.  Alternative R-3 would meet the soil cleanup goal and allow
     industrial use of the area after 50 years.  Alternative R-4 would meet the cleanup goal by a
     combination of soil removal, capping, and institutional controls.

          Alternatives GW-1 and GW-2 have a longer restoration timeframe. All other
     groundwater alternatives are expected to achieve the federal and state MCLs.
     Alternatives GW-3, GW-4, and GW-5 would comply with ARARs for disposal of filter-
     cake wastes from the treatment processes.

8.2  Balancing Criteria

     Once an alternative satisfies the threshold criteria, five balancing criteria are used to
evaluate other aspects of the potential remedial alternatives. Each alternative is evaluated
using each of the balancing criteria. The balancing criteria are used in refining the selection of
the candidate alternatives for the site. The five balancing criteria are:  (1) long-term
effectiveness and permanence; (2) reduction of toxicity, mobility, or volume through treatment;
(3) short-term effectiveness; (4) implementability; and (5) cost.
    8.2.1 Long Term Effectiveness

         Alternatives S-l and S-2 provide the fewest controls for protection of human health
    and the environment, and no physical control of the contaminated soils, including any type
    of land-use restrictions. Alternatives S-3, S-4, and S-5 would restore the soils to organic
    chemical-specific state cleanup goals and eliminate the long-term risks to future residents
    from contaminants leaching into the groundwater from the soils.

         Alternative R-l, "No Action", would not be protective in the long term, since the
    baseline risk assessment indicates that the no action for radiologically contaminated soil
    under current site conditions would not, in the long term, be protective of human health
    and the environment. Alternative R-2 provides protection to site workers and public
    health by fencing and implementing institutional controls. Alternative R-3 relies on
    removal of radiologically contaminated soil above the radiological cleanup goals and
    would be effective in the long-term. Alternative R-4 relies on a combination of soil
    removal, capping and institutional controls which also would be reliable in the long term.

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Short-term risk for R-3B and R-4B would be higher for the off-she disposal component
due to the increased risk of transportation accidents.

      All of the groundwater alternatives would ensure long-term protectiveness to human
health and the environment through restoration of groundwater quality.

8.2.2  Reduction of Toxicity, Mobility, or Volume

      Alternatives S-l and S-2 rely on biological processes and washing of the soils by
infiltration of rainwater to reduce their toxicity; they do not reduce the mobility of the
contaminants. Neither alternative reduces the volume of the contaminated soil.
Alternatives S-3 and S-5 would reduce mobility by removing organic contaminants from
the soil, thereby reducing migration of contaminants to the sole source aquifer.
Alternative S-4 provides the most assurance of eliminating toxicity, and organic
contaminants; however, Alternatives S-3 and  S-5 also achieve the organic, chemical-
specific state cleanup goals.

     None of the alternatives for the radiologically contaminated soil reduce the toxicity,
 mobility, or volume since they do not include treatment. Alternatives R-3 and R-4
 would isolate the contaminated soil from the environment through excavation and
 disposal at an off-site location.

     Alternatives GW-1 and GW-2 rely on biological processes and dilution to reduce the
 toxicity of the groundwater; they do not reduce the mobility of the contaminants.
 Neither alternative reduces the volume of the contaminated groundwater. Alternatives
 GW-3, GW-4, GW-5, and GW-6 eliminate the toxicity and volume of contamination
 from the organic compounds when remediation is completed. The mobility of the
 contaminants is controlled by Alternatives GW-3, GW-4, and GW-5.

 8.23 Short-Tenn Effectiveness

       Alternatives S-l and S-2 do not pose risk during implementation.  Alternatives S-
 2, S-4, and S-5 pose a low-level risk of exposure to site workers during construction;
 however, this risk can be managed by appropriate health and safety measures.

       Alternatives R-l and R-2 offer no short-term risks to the community during the
 remedial action and minimal risks to workers during remedial action. Alternatives R-3
 and R-4 offer minimal risk to the community and workers during the remedial action.
 The risks to workers during implementation  can be managed by appropriate health and
 safety measures.

       All the alternatives are effective in the  short term in protecting site workers and
 neighboring communities. Alternatives GW-3, GW-4, and GW-5 pose a low-level risk
 to site workers during construction; however, this risk can be managed by appropriate

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  health and safety measures.  Alternative GW-6 uses an innovative technology (air
  sparging) which is being used at several sites.

8.2.4 Implementability

     . Alternatives S-l through S-5 are technically and administratively feasible and all
  services needed to implement the alternatives are available.

      Alternatives R-l and R-2 are technically feasible and all services needed to
  implement the alternatives are available.  Administratively, R-3 and R-4 would require
  additional coordination with and approval from federal, state, and local agencies.
  Alternatives R-3B and R-4B may not be implementable due to the potential unavailability
  of the off-she facility for soil disposal.

      All groundwater alternatives are technically and administratively feasible and all the
  services needed to implement the alternatives are available. However,  alternatives GW-
  3, GW-4, and GW-5 contain a metals-recovery system that makes them more complex
  than alternative GW-6 which does not require metals treatment. Alternatives GW-3,
  GW-4, and GW-S require the most services since they involve operating a recovery unit
  for the metals and arranging to dispose of the filter cake. Alternative GW-6 is readily
  implementable, however, pilot tests are necessary to determine effectiveness and design
  parameters.

8.2.5 Cost

     A summary of estimated capital, O&M, 5-year review, and present worth costs is
  provided in the Summary of Remedial Alternatives Section of this ROD. Table 9
  provides a  summary of the capital, O&M, and present worth costs. A detailed cost
  breakdown for each alternative is provided in Chapter 4 of the FS Report.

     The present worth costs associated with groundwater alternatives  range from
  $40,900 for Alternative GW-1 to $6,670,000 for Alternative GW-4A.  For chemically
  contaminated soil, the present worth cost range from $36,400 for Alternative S-l to
  $4,860,000 associated with Alternative S-4. For the radiologically contaminated soil,
  the costs range from $78,000 for Alternative R-l to a cost of $34,200,000 for
  excavation and  disposal in Alternative R-3. There is a high cost associated with
  excavation and  storage of radiologically contaminated soil from OUIV and uncertainty
  in disposal  options.

     Alternatives S-3, R-2, and GW-6 are the most cost-effective remedies for soil and
  groundwater, while also meeting the remediation objectives.
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       8.3 Modifying Criteria

           The modifying criteria are used in the final evaluation of remedial alternatives. The
       two modifying criteria are state and community acceptance. For both of these criteria, the
       factors that are considered include the elements of the alternatives that are supported, the
       elements of the alternatives that are not supported, and the elements of the alternatives
       that have strong opposition.

       8.3.1   State Acceptance

           New York State, based on its review of the FS and Proposed Plan, has concurred
       with the preferred alternatives.

       8.3.2 Community Acceptance

              Written and verbal comments received from the community during the public
       comment period and at the public meeting held on December 6,  1996 have been evaluated.
       The Responsiveness Summary Section of the ROD contains the  comments from the
       community and the appropriate responses.

9.     SELECTED REMEDY

       The selected remedy consists of three major components: a final action for the soils
contaminated with chemicals (S-3), an interim action (R-2) for radiologically contaminated soils,
and a final remedy with a contingency option (GW-6) for groundwater contaminated with VOCs
and SVOCs. Alternative R-2 is an interim action because the radiologically contaminated soils
will be evaluated in a BNL-wide context as part of OU I. The following is a brief description of
the selected remedy:

For Soils:

       For dealing with organic chemical contamination in soils, an SVE system will be installed
to collect VOCs and some SVOCs in the vadose zone soils in two areas: (1) the 1977 Oil/Solvent
Spill Area, particularly in the vicinity of the UST location, and (2) one fuel unloading area. The
SVE wells will be located in the hatched areas shown in Figure 4. After .operating for about one
year, the concentration of the organic contaminants in the vapor extracted from the vadose zone
would be expected to stabilize at a very low value.

       To address the radiological contamination of soils at Building 650 and the Sump Outfall
area, as an interim remedy, fencing, institutional control, radiological surveys, and groundwater
monitoring will be performed. Fencing of radiologically contaminated soil areas around Building
650 and at the  Sump Outfall area has been completed in the Summer of 1995 due to risk from
external gamma radiation.  Fencing will not be required for the storm sewer pipe.  Figure 5 shows
the extent of old and new fencing.

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       The selected remedy R-2 proposes a potential groundwater monhoring program.
 However, radiological groundwater contamination from the Sump Outfall area will further be
 characterized using geoprobe in FY-96 under OU I.  The final monitoring program will be
 designed by DOE in consultation with EPA and NYSDEC, using all data.

       The volume of radiologically contaminated soils to be managed under OU IV is relatively
 small when compared to estimated soil volumes from OU I at BNL. To be cost effective, final
 remedy for these soils will be evaluated in the OU IFS and ROD, which concerns large volumes
 of radiologically contaminated soils. In the interim, fencing, institutional controls, and monitoring
 (R-2) will be implemented and will be protective of human health.

       Figure 6 shows the maximum areal extent of soil remediation for VOCs.

 For Groundwater:

       To deal with the volatile and semi-volatile contaminants in groundwater, SVE, and air
 sparging would be used. Air sparging would strip volatile and some semi-volatile contaminants
 from the groundwater into their vapor phase. The SVE will collect both the sparged air and
 volatile organics from the vadose zone.

       Upon review of the performance and monitoring data, if it is decided by DOE, EPA, and
 NYSDEC, that SVE and air sparging alone will not achieve desired performance  levels, Enhanced
 Biodegradation may be implemented along with the SVE/AS system as an engineering
 enhancement option. The desired performance levels will be defined during the remedial design
 phase.  The engineering enhancement option consists of: groundwater extraction using extraction
 wells located downgradient of the VOC plume, addition of nutrients, and reinjection into the
 saturated zone using injection wells and/or recharge basins located upgradient of the Oil/Solvent
 Spill area. This option would promote the in-shu biodegradation of organic compounds.

       Figure 6 shows the maximum areal extent of groundwater remediation for volatile organic
 compounds. Figure 7 shows the approximate locations of AS and SVE wells. Extraction and
 reinjection wells shown in Figure 7 will not be installed unless required as an engineering
 enhancement to the AS/SVE system. The final number and locations of AS/SVE wells will be
 specified in the OU IV remedial design.

       If monitoring indicates that continued operation of the components of the selected remedy
is not producing significant further reductions in the concentrations of contaminants in soils and
groundwater, in accordance with the NCP, DOE, NYSDEC, and EPA will evaluate whether
discontinuance of the remedy is warranted. The criteria for discontinuation will include an
evaluation of the operating conditions and parameters as well as a determination that the remedy
has attained the feasible limit of contaminant reduction and that further reductions would be
impracticable.
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 10.    STATUTORY DETERMINATIONS

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

   10.1 Protection of Human Health and the Environment

        The selected remedy satisfies the criterion of overall protection of human health and the
 environment by preventing/minimizing the risk of potential contaminant migration. As determined
 by the RA, there is no risk posed by the surface and subsurface soil contamination due to organics
 and inorganics within OUIV above the acceptable range. The NYSDEC TAGM cleanup goals
 which are designed to be protective of groundwater will be met in AOC 5 by extraction of VOCs
 from the soil by a SVE system (S-3). The interim remedy of fencing, institutional controls, and
 monitoring (R-2) will be effective in reducing risks to humans and environmental receptors by
 controlling the significant direct exposure and ingestion/inhalation pathways.  The remediation of
 radiologjcally contaminated soils will be evaluated as part of OU I ROD. Potential future risks to
 human health and the environment due to contaminated groundwater will be eliminated through
 air sparging of the groundwater and extraction of the volatile organics by SVE.

        No unacceptable short term risks or cross-media impacts will be caused by
implementation of the remedy.

   10.2 Compliance with ARARs

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

       10.2.1 Chemical-Specific ARARs

             The chemical-specific ARARs that the selected remedy will meet are listed below:

             1. Groundwater:

               A.  Safe Drinking Water Act, Public Law 95-523, as amended by Public Law
                   96502, 22 USC 300 et. seq. This requirement is applicable to the
                   component GW-6 of the selected remedy. This ARAR sets limits to the
                   MCLs.

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          B. New York Water Quality Standards, 6 NYCRR Part 703. This applicable
            requirement establishes standards of quality and purity for ground waters of
            the state.

       2.  Air

        C. 6 NYCRR Part 212, General Process Emission Sources. This state regulation
           will be used to establish the need for air emission control equipment for the  '
           SVE (S-3) and air sparging (GW-6) portions of the selected remedy.

10.2.2 Location-Specific ARARs

       No location-specific ARARs have been identified.


10.23 Action-Specific ARARs

       10 CFR 835. This regulation establishes requirements for controlling and
       managing radiologically contaminated areas.  Compliance with this regulation is
       required as of January 1996.

10.2.4 To Be Considered Guidance

       In implementing the selected remedy, the following significant guidances which are
       not promulgated, therefore not legally binding, will be considered:

       1. NYSDEC Soil Cleanup Objectives and Cleanup Levels, NYSDEC TAGM
         HWR-92-4046. The soil cleanup goals based on groundwater protection
         contained in this TAGM were selected for organic compounds that were found
         in the groundwater for the SVE (S-3) component of the selected remedy.

       2. NYSDEC Soil Cleanup Guidelines for Radioactive Materials, NYSDEC
         TAGM 4003. The institutional controls and access restrictions contained in
         component R-2 of the selected remedy will meet this guidance by eliminating
         exposure pathways to the radiologically contaminated soil.

     3. NYSDEC Division of Air Guidelines for Control of Toxic Ambient Air
        Contaminants, Air Guide 1.  This guide will be used to evaluate the impacts of air
        emissions from the SVE (S-3) and air sparging (GW-6) portions of the selected
        remedy and to assist with the evaluation of the need for air emissions control
        equipment.
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   10.3  Cost Effectiveness

         Based on the expected performance standards, the selected remedy (S-3, R-2 and GW-6)
has been determined to be most cost-effective because it would provide overall protection of
human health and the environment, long- and short-term effectiveness, and compliance with
ARARs, at the least cost.

         Table 9 provides a comparison of capital, O&M, and present worth costs for all soil and
groundwater alternatives.

   10.4  Use of Permanent Solutions and Alternative Treatment Technologies to the
         Maximum Extent Practicable

         The NCP prefers a permanent solution whenever possible. Components S-3 and GW-6
of the selected remedy are final actions which utilize permanent solutions to the maximum extent
practicable for OUIV. Component R-2 is an interim action and is not designed or expected to be
a final action. These components, however, provide the best balance of tradeoffs with respect to
this criteria, given the limited scope of these actions. Because of the large volume of low
concentration VOCs and SVOCs in soil and groundwater that can be treated in place, in-situ
remedies (air sparging, SVE) and alternative treatment technologies (air sparging) are selected.
Final remedial decisions for the radiologically contaminated soil will be addressed in the final
decision document for OU I.

   10.5  Preference for Treatment as a Principal Element

         Components S-3 and GW-6 of the selected remedy are final actions and satisfy the
statutory preference for treatment as a principal element.  Soil in the 1977 Oil/Solvent Spill Area
near the UST location and a fuel unloading area contaminated with VOCs and SVOCs will be
treated with SVE. Groundwater at the most contaminated portion of the oil/solvent spill plume
area will be remediated using a combination  of soil vapor extraction and air sparging technologies.
Component R-2 is an interim action. For the interim action component of the selected remedy,
the preference for treatment as a principal element will be addressed in the final decision
document for OU I.

   10.6 Five Year Review

        The selected remedy for the radiologically contaminated soils is an interim remedy.  The
final remedy for these soils will be selected under the OU I ROD.  Therefore, the need for a five-
year review will depend on the selected remedy and will be addressed in the OU I ROD.

        The selected remedial actions for VOCs in soil and groundwater will meet the desired
performance levels within five years from the initiation of the selected remedy under OU IV.
Therefore, a five-year review is not required because the remedy will not leave hazardous
substances on-site above hearth-based levels.

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    U. S. DEPARTMENT OF ENERGY




BROOKHAVEN NATIONAL LABORATORY
        OPERABLE UNIT IV
   III. RESPONSIVENESS SUMMARY

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                          RESPONSIVENESS SUMMARY
                               OPERABLE UNIT IV
                 BROOKHAVEN NATIONAL LABORATORY SITE
                               UPTON, NEW YORK
A. INTRODUCTION:

   The Responsiveness Summary Section of the Record of Decision (ROD) summarizes the
public comments and concerns and the Department of Energy's (DOE) responses to
comments/concerns which address the Feasibility Study Report (FS) and the Proposed Remedial
Action Plan (PRAP) for Operable Unit (OU) IV.

   The DOE's preferred remedial alternatives for OU IV are as follows:

For Soils:

   (1)  Treatment of organic contamination in sub-surface soils using soil vapor
       extraction/treatment.

   (2)  As an interim measure, use of fencing and institutional controls to prevent exposure to
       radiologically contaminated soil until such time as a final remedy is evaluated and
       implemented under OU I. As a preventive action, the U. S. Department of Energy (DOE)
       has completed fencing and posting of the radiologically contaminated soil areas in July,
       1995. Groundwater monitoring will also be performed during this interim period.

For Groundwater:

   (3)  To address volatile and semi-volatile contaminants in groundwater, Air Sparging (AS) and
       Soil Vapor Extraction (SVE) treatment will be used.  Air sparging would strip volatile and
       some semi-volatile contaminants from the groundwater into their vapor phase, further
       promoting bioremediation.

       An engineering enhancement system consisting of groundwater extraction, nutrient
       addition, and reinsertion may also be implemented, if it is determined by the DOE, U. S.
       Environmental Protection Agency (EPA), and New York State Department of
       Environmental Conservation (NYSDEC), based on system performance and groundwater
       monitoring data, that AS/SVE alone would not achieve the cleanup goals.

   A public comment period for the review of OU IV PRAP and the FS Report began on
November 22, 1995 and ended on January 10,1996.  A public meeting was held on December 6,
1995 at 7:30 p.m. in the Hamilton Conference Room located in Brookhaven National
Laboratory's (BNL's) Chemistry Building. Approximately 140 people attended the meeting. The
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 DOE distributed copies of the PRAP and other related informational material. Copies of the
 PRAP were provided at the following locations for public review:

 Administrative Record/Information Repositories:

   (1) USEPA - Region n, Administrative Records Room
   (2) Longwood Public Library, Middle Island
   (3) BNL Research Library, Upton
   (4) Mastic-Moriches-Shirley Library, Shirley

   Based on the comments received during the public meeting and comment period, the DOE
 believes that the EPA, NYSDEC, BNL, local government officials, and the residents were
 responsive to the PRAP and generally support DOE's preferred remedial alternatives. At the
 public meeting, some citizens commented that contaminated soils should be excavated.  One letter
 received during the public comment period recommended that a clay or a concrete cap be installed
 at the Sump Outfall Area during the interim period, before the fate of the radiologically
 contaminated soils is decided in Operable Unit I.  The interim measure of fencing, institutional
 controls, and groundwater monitoring is protective of human health. No other major objections
 to the DOE's preferred alternatives were raised by the attendees.  Responses to all comments that
 pertained to OUIV PRAP have been summarized in Section ffl of this Responsiveness Summary.

   Citizens asked several other questions at the public meeting which were not related to the OU
 IV PRAP. These questions were related to: disposal of radiological wastes generated under
 other removal action projects; the reasons for delay in cleanup under CERCLA; extent of fencing
 around the BNL site boundary; pollution prevention and waste minimization measures that have
 been taken to avoid recurrences of environmental releases; releases of biological contaminants at
 the BNL she; nature and extent of groundwater contamination off-site, rate of groundwater flow,
 horizontal and vertical extent of known groundwater contamination farthest from BNL, off-site
 groundwater sampling and analysis, off-site public health risks, and DOE's remedy for off-site
 groundwater contamination; and affiliation of personnel who served on the panel at the public
 meeting.  The panel members provided responses to these questions. A transcript of the
December 6, 1995 public meeting is available for review in the Administrative Record and the
 information repositories.

   The NYSDEC, based on its review of the FS and the PRAP, has concurred with the preferred
 alternatives.

   The Responsiveness Summary is divided into the following sections:

B.    RESPONSIVENESS SUMMARY OVERVIEW: This section briefly describes the site
      background and DOE's preferred remedial alternatives.
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C.    BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
      section provides the history of community concerns and describes community involvement
      in the process of selecting a remedy for Operable Unit IV.

D.    COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
      CONCERNS AND RESPONSES: This section summarizes the comments DOE received
      during the public comment period. Oral comments received at the public meeting and
      written comments received during the public meeting and public comment period, are
      included with the appropriate DOE responses.  A transcript of the proceedings of the
      public meeting is available in the Administrative Record and the information repositories.
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 B. RESPONSIVENESS SUMMARY OVERVIEW:

    Site History

    Brookhaven National Laboratory (BNL) is a federal facility operated for the DOE by
 Associated Universities, Inc. (AUI), a not-for-profit consortium of nine universities.  The mission
 of BNL is to provide research facilities for training and research in the diverse fields of science
 and to meet the appropriate needs and interests of the educational, governmental, and industrial
 research institutions. Brookhaven National Laboratory has three major functions.  The first is the
 design, construction, and operation of large research facilities, such as particle accelerators,
 nuclear reactors, and synchrotron storage rings.  The second major function is the support of the
 research staff in its efforts to carry out long-term programs in the basic sciences which have
 potential long-term payoffs.  The third major function involves the contribution by the staff to the
 technology base of the nation.  To carry out this mission, BNL has a staff of 3,300 to 4,000
 research and support personnel. In addition, about 1,500 other personnel participate each year in
 research on short-term projects as collaborators, consultants, or students.

    Located about 60 miles east of New York City, BNL is in Upton, Suffolk County, New York,
 near the geographic center of Long Island. Distances to neighboring communities from BNL are:
 Patchogue  10 miles WSW, Bellport 8 miles SW, Center Moriches 7 miles SE, Riverhead 13 miles
 due east, Wading River 7 miles NNE, and Port Jefferson 11 miles NW.  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. The site was transferred to the Atomic
 Energy Commission in 1947, to the Energy Research and Development Administration in 1975,
 and to DOE in  1977.

    The BNL property is an irregular polygon that is roughly square, and each side is
 approximately 2.5 miles long. The site consists of 5,321 acres. The developed portion includes
 the principal facilities located on relatively high ground near the site. These facilities are
 contained in an area of approximately 900 acres, 500 acres of which were originally developed for
 Army use.  The remaining 400 acres are occupied for the most part by various large research
 machine facilities.  Outlying facilities occupy approximately 550 acres and include an apartment
 area, biology field, Hazardous Waste Management Area, Sewage Treatment Plant (STP), fire
breaks, and the Landfill Area. The she terrain is gently rolling, with elevations varying between
40 to 120 feet above sea level.  The land lies on the western rim of the shallow Peconic River
watershed, with a tributary of the river rising in marshy areas in the northern section of the tract.

    The aquifer beneath BNL is comprised of three water bearing units:  the moraine and outwash
deposits, the Magothy Formation, and the Lloyd Sand Member of the Raritan Formation. These
units are hydraulically connected and make up a single zone of saturation with varying physical
properties extending from a depth of 45 feet to 1,500 feet below the land surface. These three
water-bearing units are designated as a "sole source aquifer" by the EPA and serve as the primary
drinking water source for Nassau and Suffolk Counties.
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    In 1980, the BNL site was placed on the NYSDEC's list of Inactive Hazardous Waste Shes.
In 1989, h was included on the EPA's National Priorities List under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), otherwise known as the
Superfund Law. Environmental restoration at the BNL she is being conducted under CERCLA in
accordance with a May 1992 Interagency Agreement among DOE, EPA, and the NYSDEC.

    To allow effective management of the BNL she, the 28 Areas of Concern (AOCs) have been
divided into discrete groups called Operable Units (OUs) and Removal Actions. The criteria used
for OU groupings are: relative proximity of AOCs, similarity in nature of contamination, similar
geology and hydrology, similar phases of action or sets of actions to be performed during
Remedial Investigation/Feasibility Study (RI/FS), and the absence of interferences with future
actions at other AOCs or OUs. The BNL she is divided into five OUs and eight Removal
Actions. Operable Unit IV is one of the first OUs studied at the she.

    Operable Unit IV is located on the east-central edge of the developed portion of the site. OU
IV encompasses the Central Steam Facility (CSF), otherwise known as AOC 5, Reclamation
Facility Building 650 Sump and Reclamation Facility Building 650 Sump Outfall (AOC 6),
Leaking Sewer Lines (AOC 21), and Recharge Basin HO (AOC 24-D)  The CSF is located
between North Sixth Street, Seventh Road, Brookhaven Avenue, and Cornell Street, and consists
of approximately 13 acres, divided equally between developed  and undeveloped land. The
Building 650 Sump is approximately  100 feet north of Cornell Avenue. The Building 650 Sump
Outfall area is located approximately 800 feet northeast of Building 650 and consists of a natural
depression, approximately 90 feet x 90 feet, bounded by dirt roads. The leaking sewer lines are
located south of Building 610; Recharge Basin HO is located approximately 250 feet to the
northeast of the Building 650 Sump Outfall area.

Remediation of Operable Unit IV

    The selected remedy consists of three major components: a final action for the soils
contaminated with chemicals (S-3), an interim action (R-2) for radiologically contaminated soils,
and a final remedy with a contingency option (GW-6) for groundwater contaminated with Volatile
Organic Compounds (VOCs) and Semi-volatile Organic Compounds (SVOCs).  Alternative R-2
is an interim action and the fate of radiologically contaminated  soils will be evaluated under OU I.
The following is a brief description of the selected remedy:

For Soils:

   For dealing with organic chemical contamination in soils, an SVE system will be installed to
collect VOCs and some SVOCs in the vadose zone soils in two areas: (1) the 1977 Oil/Solvent
Spill Area, particularly in the vicinity of the Underground Storage Tank (UST) location, and (2)
one fuel unloading area.  After operating for about one year, the concentration of the organic
contaminants in the vapor extracted from the vadose zone would be expected to stabilize at a very
low value.
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    An interim measure of fencing and institutional controls, radiological surveys, and
 groundwater monitoring has been selected to address the radiological contamination of soils at
 Building 650 and the Sump Outfall Area.  Fencing of Building 6SO and Sump Outfall areas was
 completed in the Summer of 1995 to mitigate the risk from external gamma radiation. Fencing
 will not be required for the storm sewer pipe.

    The selected remedy R-2 proposes a potential  groundwater program.  However, radiological
 groundwater contamination from the Sump Outfall area will be further characterized using
 geoprobe in FY-96 under OU I.  The final monitoring program will be designed by DOE in
 consultation with EPA and NYSDEC, using all data.

    The volume of radiologically contaminated soils to be managed under OU IV is relatively
 small when compared to estimated soil volumes from OU I. To be cost effective, final
 remediation of these soils will be evaluated in the OU IFS  and ROD. In the interim, fencing,
 institutional controls, and monitoring (R-2) will be implemented. This interim action will be
 protective of human health.
For Groundwater:

    To deal with the volatile and semi-volatile contaminants in groundwater, S VE, and AS will be
used. Air Sparging will strip volatile and some semi-volatile contaminants from the groundwater
into their vapor phase. Soil Vapor Extraction will collect both the sparged air and volatile
organics from the vadose zone.

    The desired performance levels will be defined during the remedial design phase.  Upon
review of the performance and monitoring data, if h is decided by the DOE, EPA, and NYSDEC
that S VE and AS alone will not achieve desired performance levels, Enhanced Biodegradation
may be implemented along with the S VE/AS system as an engineering enhancement option.  The
engineering enhancement option consists of: groundwater extraction using extraction wells
located downgradient of the VOC plume; addition of nutrients; and reinjection into the saturated
zone using injection wells and/or recharge basins located upgradient of the Oil/Solvent Spill area.
This option would promote the in situ biodegradation of organic compounds.

    When monitoring indicates that continued operation of the components of the selected remedy
is not producing significant further reductions in the concentrations of contaminants in soils and
groundwater, in accordance with the National Contingency Plan (NCP), DOE, and the EPA will
evaluate whether discontinuance of the remedy is warranted. The criteria for discontinuation will
include an evaluation of the operating conditions and parameters as well as a determination that
the remedy has attained the feasible limit of contaminant reduction and that further reductions
would be impracticable.
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C.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Community Profile:

    Brookhaven National Laboratory is located in Brookhaven Town at the geographic center of
Suffolk County, which encompasses the central and eastern part of Long Island. Brookhaven
Town accounts for almost a third of Long Island's 1.3 million residents with a population of
408,000.

    Suffolk County is operated by a County Executive and an 18-member legislature, while the
town employs a Town Council and a Supervisor.  Both county and town governments maintain
professional planning, development and environment departments, in addition to planning boards.

    Many hamlets dot Brookhaven Town's 428 square kilometers (260 square miles).  Located
within a 5-mile radius of BNL are the unincorporated communities of Yaphank, Middle Island,
Ridge, East Shoreham, Wading River, Calverton, Manorville, Center Moriches, Moriches, Mastic,
and Shirley. Most of these villages or hamlets have citizen-run civic or taxpayers organizations
with large and active memberships. Their goal is to benefit their community. Most organizations
join one or both of the area's two umbrella civic groups, Affiliated Brookhaven Civic
Organizations and the Longwood Alliance. These same communities support Rotary and other
service clubs, which represent the business people and other aligned interests within the
community.

    The town of Riverhead is another Suffolk County town where BNL activities generate
interest. The town of Riverhead, located to the east of BNL beyond the Town of Brookhaven,
has a population of about 23,457 and an area of just over 108 square kilometers (about 60 square
miles of which 62 percent is farmed). Riverhead employs a supervisor-town council government
which maintains professional planning, development and environment departments, plus a
planning board.

History of Community Involvement

    Historically, public involvement in BNL's environmental restoration activities has been low,
but after the establishment of a Community Relations program in 1991, public interest and contact
with BNL has increased. Community attendance at public meetings has increased from a handful
in 1991 to over 100 attendees at the OUIV meeting in December 1995.  Each week, more than
50 calls from civic leaders, school officials, or citizens are received, each wanting to know
something about environmental restoration activities. The focus of the Community Relations
program for the last four years has been the following:

    •  To develop relationships with on-site personnel, community members and leaders, and
      community health-safety activists.
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    •  To expand the mailing list.

    •  To attend regular monthly civic meetings to gain awareness of citizen issues and concerns.

    •  To increase communication with interested individuals by newsletters, public meetings,
       home page on the Internet, and maintaining the Administrative Record at local libraries.

    A Community Relations Plan was finalized for the BNL site in September 1991. In
accordance with this plan and CERCLA Section 113 (k) (2)(B)(I-v) and 117, the community
relations program focused on public information and involvement. A variety of activities were
used to provide information and to seek public participation.  The activities included: compilation
of a stakeholders mailing list, community meetings, availability sessions, site tours and the
development of fact sheets. An Administrative Record, documenting the basis for the selection of
removal and remedial actions at the BNL site, has been established and is maintained at the local
libraries listed below. The libraries also maintain she reports, press releases, and fact sheets.  The
libraries are:

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

       Mastic-Moriches-Shirley Library
       301 William Floyd Parkway
       Shirley, NY  11967

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

    The Administrative Record is also maintained at the EPA's Region n Administrative Records
Room at 290 Broadway, New York, New York, 10001-1866.

Summary of Community Participation Activities for OU IV

    A chronological summary of the significant community participation activities to date for OU
IV is provided below:

    September 26, 1991: A She Specific Plan and 5-Year Plan informational meeting was held at
BNL where the OU IV draft RI/FS Work Plan was also presented to the public.  Presentation
handouts on the draft Work Plan were provided to community members at that time. Although
the community was informed by a press release to the local newspapers, attendance at this
meeting was low.  A question and answer period was held at the end of the meeting.
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    February 17, 1992: A public notice was published in two local newspapers (Newsday and
 Suffolk Life^ announcing the availability of the OUIV RI/FS Work Plan at local repositories.  The
 comment period began on February 17, 1992 and concluded on March 17, 1992. One community
 member commented by letter in April and was responded to by BNL.

    August 3, 1994: A public notice was published in two local newspapers (Newsday and
 Suffolk Life) announcing the availability of an Engineering Evaluation Report and Action
 Memorandum at local repositories for an OU IV soil interim removal action.  An informational
 letter, with public notice attached, was sent to the community mailing list. Two phone calls from
 community members were received concerning the disposal  of soils.

    January 17, 1995:  A public notice was featured in local  newspapers announcing the
 availability of the OU IV Remedial Investigation/Risk Assessment (RI/RA) Report at local
 repositories. The comment period began on January 18 ,1995 and concluded on February 20,
 1995.

    January 25,1995:  An informational letter was sent to community members on the mailing list
 concerning the OU RI/RA Report. A civic association requested and was granted an extension to
 the comment period.  Comments were received from the civic association in April 1995, which
 focused primarily on groundwater concerns. A meeting to discuss these concerns with the civic
 association was held on June 5, 1995 and DOE provided a written response thereafter.

    November 18, 1995:  An informational letter was sent to community members on the mailing
 list announcing the OU IV FS/PRAP public meeting.  A public notice, meeting invhation/PRAP
 fact sheet, and site tour invitation was attached.

    November 22,1995:  A public notice was published in Newsday and Suffolk Life (on
November 29, 1995) announcing the availability of the FS/PRAP at local repositories for review
 and comment. A 30-day public comment period was initiated on November 22, 1995.

    December 6, 1995: A public meeting was held at BNL for the OU IV FS/PRAP along with an
 afternoon-she tour of OU IV.  The public meeting was attended by over 100  people.  At this
meeting, representatives from the EPA, NYSDEC, BNL, and DOE answered questions and
 accepted comments on the remedial alternatives under consideration for OU IV. A response to
comments received during the public comment period is included in Section HI  of this
Responsiveness Summary.

    January 10, 1996:  Community members provided written comments.

    In addition to traditional public involvement activities at  CERCLA sites, the DOE worked
with stakeholders in identifying a range of future use options for the BNL site.  The Final Draft of
the Future Land Use Report was presented to the public in August, 1995. The Final Report was
                                         49

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prepared in September, 1995. Preferred future uses identified in this report will help determine
the acceptable risk and remediation levels for the entire BNL site.

   Highlights of other significant community relations activities are attached at the end of this
Responsiveness Summary.
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D. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS
   CONCERNS AND RESPONSES

   Public comments on the FS and Proposed Plan submitted during the public comment period
are summarized and addressed below. These comments are presented in the following three
categories:

   1. Summary of Questions and Responses from the Public Meeting Concerning
      Operable Unit TV: Oral questions and comments received during the public meeting held
      on December 6, 1995 are summarized in this section by the following topics:

         •  Site History
         •  Flow of Ground water at BNL
         •  Extent of Contamination
         •  Site Risks
         •  Comparative Analysis of Alternatives
         •  Preferred Remedy
         •  Compliance with ARARs
         •  Community Participation and Acceptance

      Similar comments and responses on a topic were consolidated to avoid redundancies.

   2.  Responses to Written Public Comments Received on Comment Cards at the Public
      Meeting: The DOE responses to the written public comments received at the Public
      Meeting on December 6,1995 are provided in this section.

   3.  Responses to Written Comments Received During the Public Comment Period:  The
      DOE responses to written comments from the community are provided in this section.
1.  SUMMARY OF QUESTIONS AND RESPONSES FROM THE PUBLIC MEETING
   CONCERNING OPERABLE UNIT TV

   SITE HISTORY

      A citizen asked whether BNL has found any contamination in the clean backfill
      material which was placed in the area where contaminated soil was removed.

      Response:  Historically, when contaminated soil was excavated at OUIV spill sites,
      BNL/DOE, with concurrence from the regulatory agency (NYSDEC), ensured that the
      soil at the bottom of an excavation was determined to be "clean" based on the prevailing
      standards.  After this determination was made, the pit was backfilled with clean sand.
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 The results of subsequent soil investigations did not indicate contamination of the clean
 backfill material from the original spill.

 A citizen inquired about the source of the cooling water discharged to the Recharge
 Basin HO.

 Response:  The cooling water that is discharged to the Recharge Basin HO is primarily
 non-contact cooling water that is used to cool large research facilities and equipment at
 BNL.

 Citizens inquired about the OUIV interim soil removal action, requested
 documentation, and expressed concern over disposal of the soil at the  Town of
 Brookhaven Landfill

 DOE Response:  In  1993, during the remedial investigation, the underground storage
 tank which was the subject of the 1977 oil/solvent spill was found abandoned in the
 ground. Evidence of soil contamination from the 1977 oil/solvent spill was also observed.
 The tank was removed.  Visually stained soil underneath the tank and around the
 associated piping was also removed. Treatment/disposal alternatives for the excavated
 soil including incineration and on-site thermal treatment, were studied in the Engineering
 Evaluation of Soil Piles Near Former Oil/Solvent UST. This study report and an Action
 Memorandum, which are part of the Administrative Record, were made available for
 public comments.  The NYSDEC and the Town of Brookhaven were also provided the
 study report and the analytical data. Upon receipt of written concurrence from the Town
 of Brookhaven and NYSDEC in 1994, 1,413 tons of soil and debris were disposed of at
 the Town of Brookhaven Landfill.  A written response was provided to the commenter
 with regard to the request for documentation.
FLOW OF GROUNDWATER AT BNL

A citizen inquired whether the Suffolk County had groundwater flow maps around
the BNL site and whether such a map could be obtained.

Response:  Groundwater contour maps are available. They vary in detail. Some are
limited to the BNL she, and others are regional groundwater flow maps. The Suffolk
County Water Authority clarified that the Suffolk County Division of Health Services
(SCDHS) produces groundwater contour maps on an annual basis based on its network of
monitoring wells. These maps are available to the public. Brookhaven National
Laboratory has produced more detailed maps which are based on several BNL monitoring
wells on-site and outside the BNL site boundary. These maps can be obtained by the
public from the DOE or BNL.
                                  52

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EXTENT OF CONTAMINATION

A citizen asked about the impact of remedial actions, such as installation of wells
and air sparging, on increasing the extent of groundwater contamination.

Response:  The contamination is not likely to spread during the implementation of the
remedial action due to the nature of the given aquifer media, sand and gravel.  During air
sparging, localized mounding and the potential for creation of preferential pathways due
to improper design or operation of the air injection system exists, but will be avoided.
Necessary design and operational monitoring measures will be taken to ensure that this
will not occur.

A citizen asked exactly what is being done to determine the extent of off-site
contamination from the 1977 oil/solvent spill.

Response:  Additional groundwater modeling is being performed to determine the area!
extent of groundwater contamination and to guide placement of additional monitoring
wells as part of Operable Unit I. These wells will also be used to track the 1977 plume.
Off-site residential wells are also being sampled south and east of BNL in cooperation
with the Suffolk County Department of Health Services.

SITE RISKS

A citizen asked what would happen to the chemically and radiologically
contaminated soil in the event of a major flood; would it be displaced off-site.

Response:  It is not likely that the residual contaminated soil from OUIV will be
transported off-she in the event of a major flood, since the runoff is minimal on-site, even
after a major storm event.

The interim measure of fencing, institutional controls, and groundwater monitoring for the
radiologically contaminated soil is currently protective of human health. A final remedy
for these radiologically contaminated soils is expected within a year.

A citizen inquired about the impact of future potential wildfires on the spread of
radiological contamination from the Building 650 Sump Outfall Area. The citizen
recommended that such a contingency be included in the safety planning during the
implementation of the interim measure for this area.

Response:  There are several trees in the Building 6SO Sump Outfall area. While the dust
from a potential fire may contain small amounts of radiological activity, it would be in
concentrations that will not be of concern from the standpoint of health impacts or risks.
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However, the impacts of such a contingency will be evaluated, and appropriate preventive
measures will be taken during the implementation of the interim measure.
TOMPARATIVE ANALYSIS OF ALTERNATIVES

A citizen asked for assistance in visualizing 7,000 cubic yards of soiL

DOE Response: It is approximately a large 10 foot high room, 150 feet long, and 125
feet wide.  Alternately, h is the quantity of soil that would fill about 700 ten-wheeler dump
trucks.


PREFERRED REMEDY

A*     Preferred Alternatives for Soil

       A citizen inquired about how long it will take for the Soil Vapor Extraction
       system to meet the soil cleanup standards and for that area to become safe.

       Response: The SVE is expected to take about two years before the OUIV area is
       restored to the New York State standards.

       A citizen asked how the interim measure (of fencing) for radiologically
       contaminated soils will prevent runoff from the Sump Outfall Area, in case of
       a flood, to reach the Recharge Basin HO which is designed to recharge to the
       aquifer.

       Response: The layout of the Sump Outfall area  is such that the runoff from this
       area will not contaminate the Recharge Basin HO. Also, due to the localized
       mounding of the groundwater  at the Recharge Basin, the ground water flow is
       radially away from and eventually downgradient of the Basin HO.

       A citizen inquired about the frequency  of groundwater monitoring  of the
       Building 650 Sump Outfall Area.

       Response: Groundwater will  be monitored semi-annualty during the interim
       action period. A final remedy  for the radiologically contaminated soils is being
       studied and a proposed remedy is expected within a year. This final remedy will
       address long-term monitoring at the Building 650 Sump Outfall Area.
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B.     Cost of Preferred Alternatives for Soil

       A citizen inquired about how the costs for the preferred alternatives for
       chemically contaminated soils and groundwater were computed.

       Response:  These costs reflect the present worth of the remedial action costs. A
       rate of 5% has been used for the 30-year life of the proposed remedy. Costs of
       long-term monitoring are also reflected in these costs.

C.     Cost Effectiveness

       Citizens inquired if there is actually a limitation under the Superfund Law,
       or has DOE set any restrictions in terms of money that can be spent for
       cleanup.  Citizens also asked why not excavate all contaminated soils,
       regardless of the price, in the interest of long-term safety.

       Response:  Cost is one of nine criteria that is used in the detailed evaluation of
       remedial alternatives. Eight other criteria are used in the remedy selection process.
       Cost alone is not an index of protectveness of human health and the environment.
       The cleanup is performed with the use of taxpayer money. Therefore, efficient use
       of these funds in the cleanup process is warranted.  A remedy which meets the
       cleanup objectives at the lowest cost is preferred. A table at the end of the PRAP
       was cited to illustrate that the cheapest remedy is not necessarily proposed as
       DOE's preferred remedy.

       From both a technical and cost effectiveness point of view, the SVE would be
       effective in the remediation of the chemically contaminated soils. This technology
       has been tested at numerous sites across New York State and has been determined
       to be effective.  It is a proven technology and will remediate this site to the cleanup
       standards.

       A citizen requested that someone on the panel compare the 1977 oil/solvent
       spill with the gasoline spill at the Northville gasoline spill site in Long Island.

       Response: The Northville spill was significantly larger in volume and extent, and
       was all gasoline  None of the Northville spill was recovered by soil excavation.
       More than a million gallons of gasoline went into the ground and contaminated the
       groundwater.

       The OUIV  spill was closer to the surface.  Soil contaminated with the oil was
       excavated.  Air Sparging is now a proven technology, h is being used around the
       country, and is effective in  cleanup of such spills.
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 COMPLIANCE WITH ARARs

 A citizen inquired about how the cleanup standards are derived.

 Response:  Cleanup standards are selected based upon a review of federal and state
 regulations and guidance. The groundwater cleanup standards are selected based on a
 comparison of Federal and State Drinking Water Standards. The most stringent of the
 Federal and State standards are selected. Guidance on soil cleanup goals has been
 developed by the NYSDEC and is based upon an analysis of potential exposure routes,
 i.e., ingestion, inhalation, or impacts on groundwater that might one day be consumed.

 A citizen expressed concern over applicability of the drinking water standard set
 about 10 years ago.

 Response: Drinking water quality standards are established based on known health
 effects and other technical data obtained over time.  These standards are reviewed
 regularly by the EPA and updated as new information becomes available.

 COMMUNITY PARTICIPATION AND ACCEPTANCE

 A citizen inquired if citizens could observe sampling of the wells and related field
 work being performed by BNL/DOE.

 Response: It was stated that BNL/DOE has not received such requests in the
 past, but would be glad to show the citizens how this work is done. However,
 there are safety protocols associated with each field activity which need to be
 followed. Citizens can call BNL's Community Relations Coordinator to set up  an
 appointment.

 2.    Responses to Written Comments Received on Comment Cards at the Public
      Meeting

Comment:    Specifically, what authority does the County have over this  [cleanup
             program]?

Response:    Environmental restoration work at BNL is performed under an Interagency
             Agreement (LAG) among the DOE, EPA, and NYSDEC. The DOE is
             required by the IAG to consult with and obtain the review of the EPA and
             NYSDEC during various stages of the clean-up, with EPA having the final
             decision regarding the cleanup remedy in case of disagreement.  Suffolk
             County has the right to participate in the process of determining the
             appropriate action to be taken regarding remediation and is provided the
             opportunity to review and comment on reports. Suffolk County
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Comment:

(A)

Response:

(B)

Response:

(Q

Response:
Comment:

(A)

Response:



(B)

Response:
representatives also inspect work and obtain split samples for analysis at
their own laboratories. The County is cooperating with DOE and BNL
regarding groundwater sampling and public water supply, and other aspects
of the environmental restoration program.

When you sent contaminants to Hanford did they go through:

Manhattan?

No.

On the Orient Ferry?

No.

Across the Triboro Bridge?

No.

We believe that you are referring to the low level radioactive waste
shipments.  Applicable Department of Transportation routing, shipping and
packaging requirements were followed when these low level radioactive
wastes were transported to Hanford.
Whose wells have you sampled?

Only on-site monitoring wells were sampled during the OUIV remedial
investigation. Off-site wells were sampled as a part of Operable Unit V,
Removal Action V, and Operable Unit ffl.

How far from BNL property have you sampled?

To the North-East: Residential wells as far as David Terry Street to the
North-East of BNL have been sampled.

To the South-East: Residential wells as far as Wading River Road to the
South-East of BNL have been sampled.

To the South: Residential wells as far as Flower Hill Drive to the South of
BNL have been sampled.
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              To the South-West:  Residential wells as far as River Road on the South-
              West of BNL have been sampled.

 Comment:    How much "Superfund" money do yon have?

 Response:    Environmental Restoration work under CERCLA (Superfund Law) is
              being performed with funds provided by the U.S. Department of Energy to
              BNL. The EPA's "Superfund money" is generally not available for use by
              federal facilities such as BNL.

 Comment:    How can you, with a straight face, make such a big fuss about a plan
              to build an ordinary fence?

 Response:    Based on the results of remedial investigation and risk assessment, it has
              been determined that the primary pathway of exposure is via direct
              exposure.  To prevent exposure from this, the most significant pathway,
              and as an interim measure, fences have been installed.  Radiological surveys
              and groundwater monitoring will also be performed in the interim period
              until the final remedy for the radiologically contaminated soil areas is
              selected under the Operable Unit IFS.

 Comment:    It seems that the responsibility for this radiological contamination of
              the soil and the chemical contamination of the groundwater is
              Brookhaven Labs. I fed you're taking the cheapest way out. A fence
              can't control all routes of exposure - example - inhalation, and what
              about direct contact by animals who leave the area?  This is
              unacceptable. Abo, doesn't groundwater need to be  cleaned or
              removed?  Gronndwater travels and so do these dangerous chemicals.
              The Mastic Shirley areas have been through enough  pollution of their
              drinking water and hopefully will fight this pollution once again.

              I don't fed you have done enough on the local levd to make people
              aware of this meeting or these problems and proposals. I myself only
              found out from an article in Suffolk Life that was delivered today.
              Thank yon.

Response:    The fence was installed only as an interim measure. The fence is, as an
              interim measure, effective in preventing exposure to humans and animals.
              The primary route of exposure is from direct exposure, not from ingestion
              or inhalation.  The final remedy for the radiologically contaminated soil
              areas will be further studied and addressed by a Feasibility Study being
              conducted under OU I. The final proposal for this area will be available for
              your comments by February, 1997.
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                    Cost is one of the nine criteria that is used in the detailed evaluation of
                    remedial alternatives. Eight other criteria are used in the remedy selection
                    process. Cost is not an index of protectiveness of human health and the
                    environment. To be cost effective, a remedy which meets the cleanup
                    objectives at a lower cost is preferred.

                    Any contaminated groundwater which may potentially be migrating off-site
                    is being addressed under other BNL projects (OU I, HI, and V).

                    Efforts to better inform the community of the environmental restoration
                    activities at BNL, such as, expanding mailing list and newsletters, are being
                    initiated.

3.     Responses to Written Comments Received During the Public Comment Period:

Letter from Cancers Cure

Questions/Comments Regarding the 1977 Oil/Solvent Spill:

Comment:   The tank floated and ruptured, giving reason to believe that groundwater
             contamination was occurring with each rainfall (specially record rainfall
             early nineties), what was stopping soil from 1977 to 1993 from being
             contaminated (see Question 4A)? How did you come up with the 25,000
             gallon amount?

Response:    In November 1977, BNL's Plant Engineering (PE) used sand berms to contain the
             spread of oil and used portable pumps to retrieve the oil.  Test borings performed
             at that time at several locations within the spill area revealed a heavy clay layer
             approximately 0.25 to 0.3 meters below the topsoil.  Sampling of the soil at
             different depths conducted by BNL's Safety and Environmental Protection
             Division (S&EP) indicated that the oil had not reached the clay layer but was
             confined to the top 0.3 meters. Some oil soaked soil was removed, but the
             location or amount of the soil was not documented. Clean top soil was added to
             this area, followed by fertilization and tilling. In a December 1977 meeting with
             EPA, EPA expressed satisfaction that the steps taken were appropriate.   Thus, the
             soil contamination was thought to be confined.

             As a condition of the New York State Major Petroleum Storage Facility Permit
             and CSF expansion, BNL installed soil borings in the spill area.  The results of soil
             borings indicated presence of chemical odor. Following this finding, a soil and
             groundwater investigation was initiated  by BNL. Monitoring wells were installed
             in the spill area and were sampled.  Residual oil/solvent contamination from the
             1977 spill was found in the soil at the spill area, and an oil sheen was observed on
                                         59

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             a water table soil sample.  Based on these follow-up studies, it was determined that
             soil contamination was not confined to the top 0.3 meters below the topsoil.

             The 25,000 gallon spill amount was estimated from observations made before and
             after the spill on the level gauges on the large storage Tank #4 which was feeding
             the 5,000 gallon underground storage tank.

Comment:   Are there photographs of the spill which covered 1.2 acres (before and after
             sand benns)?

Response:    Photographs taken by BNL personnel at the time of the spill are available and were
             sent to the commenter.

Comment:   In cleanup coordinated with EPA, who else participated with the cleanup
             (other agencies such as DEC and other companies such as Marine Pollution
             Control)?

Response:    BNL Divisions performed the cleanup with the approval of EPA. The New York
             State Department of Transportation (NYSDOT) also was informed, since they
             administered the oil spill program for the New York State in 1977.

Comment:   Why is the amount of oil and solvent recovered by portable pumps
             unknown?

Response:    The recovered amount is unknown because there is conflicting documentation of
             recovery. One document indicated that about 2,900 gallons were recovered and
             the other indicated that about 20,000 gallons were recovered.

Comment:   In  the interim action taken by DOE with the EPA and NYSDEC approval:

      A.     Why did DOE wait until October 1993 to remove visibly-contaminated soil?

Response:    Until 1987, it was believed that the oil had not reached the clay layer but was
             confined to the top 0.3 meters above the clay layer (See Response to first
             comment).  It was not visible at the surface. As of 1987, further investigations
             were required to determine the extent of contamination prior to initiation of any
             further response actions. In 1987, at the request of BNL, IT Corporation (TIC)
             conducted an investigation of the extent of soil and groundwater contamination.
             IT  Corporation  developed a conceptual remediation plan in 1989. On December
             21,1989, the BNL she was placed on the National Priority List under Section 120
             of CERCLA (Superfund Law).

             Subsequently, an IAG addressing the environmental contamination and restoration
             at BNL was negotiated by the DOE, EPA, and NYSDEC. The IAG was finalized
             in February 1992 and became effective in May 1992. The IAG established that the
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             OUIV, which contains the subject spill, be subject to a RI/FS process.  Planning
             for the OU IV RI/FS was initiated in 1991.  Only during the excavation of the
             5,000 gallon UST, an interim removal action, and associated piping in 1993, visibly
             stained soils were found around the tank and associated piping.  These soils were
             excavated with the approval of the IAG agencies.

       B.    Where was the soil until June 1994, when after sampling and analysis and
             with approval of DEC and Brookhaven Town, the soil was disposed of in the
             Town of Brookhaven Landfill

Response:    The excavated soils and debris were stored on-site in piles.  The piles were placed
             on top of a liner and were securely covered with tarpaulins just west of North
             Sixth Street.  The soil piles remained in place until June of 1994.  Alternate
             treatment/disposal options were studied by Camp Dresser & McGee (CDM), at
             the request of BNL.  Upon written concurrence from NYSDEC  and the Town of
             Brookhaven, a total of 1,413 tons of excavated soil and debris were disposed of at
             the Town of Brookhaven Landfill.

       C.    Where in the Landfill was soil deposited and how much was deposited?

Response:    Brookhaven National Laboratory hired a NYSDEC licensed contractor to
             transport the soil/debris to the Town of Brookhaven Landfill.  Disposal was
             performed by the contractor per direction from the Town of Brookhaven Landfill
             officials.  We are not aware of the exact location in the Landfill where this soil is
             deposited.  The exact location may be obtained from the Town of Brookhaven.
             The amount deposited was 1,413  tons of soil and debris.

       D.    I would also like to know who performed the excavation process, and who
             performed the analysis of the above mentioned soiL

Response:    The excavation was performed by BNL personnel. The sampling was conducted
             by CDM and the analysis was performed by PACE Laboratories, under a contract
             with CDM.
Questions/Comments Regarding the Former Leaching Pit:

Comment:   For how long was wastewater and waste oil from equipment cleaned inside
             Building 610 sent into this leaching pit?

Response:    The leaching pit received wastewater from equipment cleaning operations inside
             Building 610 from 1948 to 1980.
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Comment:   Was the entire pit covered with 53 inches of tar-like substance?

Response:   The bottom of the pit was covered with S3 inches of tarry sludge material.

Comment:   Where was this waste and surrounding soil taken? (DEC Region 1 Oil
             Division documentation would be sufficient).

Response:   Approximately 100 cubic yards of soil and debris was excavated from the pit, was
             transported, and disposed of at the Town of Brookhaven Landfill.  Clean sand was
             placed into the excavated area.

Questions/Comments Regarding Former Underground Gasoline Storage Tank:

Comment:   Who from SCDHS gave authorization for removal?

Response:   Both the NYSDEC Spill Unit in Stony Brook and the SCDHS in Farmmgville
             were notified of the discovery of the abandoned underground storage tank by BNL
             personnel on April 9, 1990. A representative of SCDHS, Mr. D. Obrig, came to
             BNL to inspect the tank and examine the excavation on April  11,1990.  SCDHS
             authorization was not required for removal of the tank.

Comment:   Where can documentation regarding the soil and tank be retrieved for
             viewing or photocopying?

Response:   The abandoned tank and surrounding area were remediated using the services of a
             local contractor. A representative sample was collected from the excavated soil
             and analyzed for the hazardous waste characteristic test of ignitability and the
             extraction procedure toxicity test for lead. The analytical results indicate that the
             soils were not hazardous for the parameters tested. The documentation can be
             obtained from the Administrative Record and information repositories.  Based on
             these results, approval was obtained from the Town of Brookhaven and the
             NYSDEC to dispose of the soils at the Town of Brookhaven Landfill. This was
             performed by the contractor in May, 1990.  The tank was removed from BNL and
             disposed as scrap by the contractor.

Questions/Comments Regarding Fuel Unloading Areas:
Comment:
Response:
I would like to obtain documentation of spills, what action was taken, what
agency documented these spills, and what action has been taken as far as
groundwater contamination.

Several spills have occurred during the unloading of fuel at the CSF. The spills
documented on BNL's Chemical and Oil Spill Reporting Forms, prior to the
                                        62

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              remedial investigation, indicate that six spills have occurred during the delivery of
              fuel. The spills range in size from 2 to 60 gallons and were, in the most part, No. 6
              fuel oil, with one instance of No. 2 fuel oil and incident of gasoline spillage.  All of
              the spills were remediated using absorbents and where the volume was sufficient,
              fuel was recovered by pumping into storage tanks.

              Reportable spills that occurred after the NYSDEC started administering the oil
              spill program are documented with the NYSDEC Spill Unit in Stony Brook.

              During the RI, one soil boring was installed at each of the eight unloading areas.
              The purpose of the borings was to determine if soil contamination was present in
              the vadose zone. Additional monitoring wells were also installed south of the CSF
              tank farm area to detect any groundwater contamination from this area.

Questions/Comments Regarding Drainage Area:

Comment:    Where was oil (No. 6 fuel oil, 250-500 gallons) taken after collection, and by
              whom was it collected?

Response:    The spill amount was estimated to be 250-500 gallons. The oil ponded in the low
              area was collected by BNL with recovery pumps. A BNL bulldozer was used to
              limit the spread of the oil. The recovered oil was placed back in an oil storage
              tank.

Questions/Comments Regarding Reclamation Facility Building 650 Sump and Outfall
Area:

Comment:    Wastewater drained into two of four underground storage tanks. What was
              the purpose of the two remaining tanks?

Response:    Wastewater from the laundry operation inside Building 650 was contained in two
              2,000 gallon underground storage tanks (#650,1 and 2) until it could be
              monitored for radioactivity. Rinse water from the decontamination pad that was
              deemed excessively contaminated (liquid with gross beta concentration greater
              than 90 picoCuries per milliliter, otherwise called "D" waste) was also supposed to
              be routed to these tanks with the use of appropriate valves.

              Tanks 3 and 4, designated as T" waste tanks, were used to contain liquids from
              the decontamination pad operation having gross beta concentration less than 90
              pCi/ml. Typically, rinse water from the decontamination pad, was deemed clean
              enough to be routed to these two 3,000 gallon underground storage tanks (#650, 3
              and 4), located adjacent to Tanks 1 and 2.
                                          63

-------
 Comment:   Contents of clothing decontamination tanks were regularly transferred by
             track to BNL's Waste Concentration Facility.

       A.    What was done with contaminated clothes? (Please provide information as to
             who wore these clothes, in writing if possible. If Freedom of Information
             needed for this, please inform me).

 Response:    Clothing received at this facility was first washed. After washing, clothes were
             monitored for contamination. If it was determined that the clothes were
             contaminated, they were sent back for a rewash.  If these clothes after rewash were
             determined to still be contaminated, they were disposed of as low level radioactive
             waste. The clean clothes were reused by personnel working in radiologically
             controlled areas. It would be inappropriate to identify such personnel by name.

       B.    What is BNL's Waste Concentration Facility (WCF)? Where is it located?
             What else is brought there from BNL and any other waste from anywhere
             else.

Response:    Aqueous radioactive wastes are received and were processed at the WCF, located
             at Building 811 for volume reduction prior to disposal off-site. Above ground
             holding Tanks D-l, D-2, and D-3 were used to store the waste between 1952 and
             1987.  Since 1987, generated "D" Waste (defined previously) is stored in two new
             tanks located north of the "D" waste tanks. Only BNL waste is received  and
             processed at this facility.

       C.    Are contents discharged from Building 650 to the Sewage Treatment Plant,
             and then discharged into the Peconic River?

Response:    Contents of the "F" waste tanks (Tanks 3 and 4) described previously were
             emptied about twice a year and were discharged to the Sewage Treatment Plant.

       D.    In 1969, five curies of tritium were released, supposedly, in BNL's sanitary
             sewer system.  However, an investigation followed and revealed that the
             drainage pipe from Building 650 Sump discharged into a natural depression
             into a wooded  area 800 feet northeast of Building 650. (I'm lead to believe
             that this discharge was into the ground, not into four tanks, is this true?)

Response:    The discharge was into a natural depression, an area called the "Sump Outfall
             Area" which was addressed in the remedial investigation for OUIV.  A valve, if
             correctly operated, would have directed the liquids to the "F" waste tanks. The
             valve was positioned, at the time of this release, to direct the liquids to a storm
             sewer line which discharged into the Sump Outfall Area.
                                         64

-------
       £.    In the Summer of 1994, Building 650 Sump's four underground storage
             tanks were removed and determined to have not leaked. What was done
             with these radioactive tanks? Who disposed of them?

Response:   The underground storage tanks (#650-1, -2, -3, and -4) were no longer in use. In
             the Slimmer of 1994, as part of the UST Removal Action, the tanks and associated
             piping were removed, and upon determining that the tanks had not leaked, the
             holes were filled with clean sand.  The tanks were cut up as a part of Removal
             Action I ("D" Tanks Removal Action), packaged in approved containers, and
             disposed of by DOE at its facility in Hanford, WA

Questions/Comments Regarding Leaking Sewer Lines:

Comment:   All decontamination of contents of the equipment decontamination tanks
             were discharged into these sewer lines. This was radioactive material. Are
             there any tests from the leaky sewer lines? Please send any material you can
             send me (Please send separate comments not references in catalog of data.
             References would be appreciated from specific people responsible for each
             area).

Response:   The liquids from the Building 650 decontamination pad area which discharged via
             a storm sewer line to the Sump Outfall Area.  During the Remedial Investigation, a
             video camera survey of this storm sewer  line was performed. The survey results
             were utilized to locate four soil borings along the pipeline. Soil boring samples
             collected along this storm sewer pipeline indicated no contamination above the
             cleanup goals.

             Soil borings were also installed along the section of the sanitary sewer line
             included in OUIV which was known to have leaked.  The results of soil testing
             indicated that there was no contamination above the New York State standards.
             The requested material was provided to the commenter.

Questions/Comments Regarding Recharge Basin HO:

Comment:   Why was sediment not tested? All contamination would presumably settle to
             bottom sediment I don't understand why, if you are looking for
             contamination, why you would not test where the final products of
             contamination would be?

Response:   Primarily, non-contact cooling water was discharged to the basin and the water
             was sampled periodically. Since there was no testing done on the sediment
             previously, six sediment samples were collected during the 1993 Remedial
                                         65

-------
              Investigation in the Recharge Basin HO (two basins). A composite sediment
              sample was analyzed for organics, inorganic pesticides/PCBs, and radionuclides.

              Results of the soil analysis indicate that the soil cleanup goals for the respective
              compounds were not exceeded.

Letter From Suffolk Conntv Water Authority

Comment:    The SCWA made the following comment on the preferred alternative of
              fencing and using institutional controls to monitor access to the radiologically
              contaminated soil areas, identified in the Proposed Remedial Action Plan
              (PRAP).  "Recognizing the nature of the contamination in the area of
              concern, we recommend that in addition to fencing in the area, a layer of
              solid clay or concrete be placed over the area. This will act as a cap and
              minimize the potential for water percolating through the area from becoming
              contaminated and reaching the aquifers underlying the site.  This interim
              action is a cost effective method of reducing the risk this area poses to the
              aquifer and allows you time to formulate a more complete course of remedial
              action as part of the final action to be implemented under Operable Unit I
              remediation (as noted on Page 12 of the PRAP)."

Response:     As an alternative, installation of a solid clay or concrete cap over the radiologically
              contaminated areas, in addition to the fencing, is being studied under the OUIFS.
              The Proposed Plan for this area is expected to be available for public comment by
              February, 1997.  Considering that a final remedy for this area is in process, that the
              human health and environmental risks from direct exposure are, in the interim,
              eliminated by installation of the fence, and that groundwater contamination from
              this source area is further being evaluated, we believe that these steps are
              responsive and will be protective of human health.

              Should a clay or concrete cap be installed within the next few months, and should
              the final remedy selected under Operable Unit I be excavation and treatment/
              disposal, the cost of installation and dismantlement of the cap as well as
              characterization and treatment/disposal of additional radiological wastes would not
              be justified.
Letter From Ridge Civic Association

Comment:   "Considering potential costs and risks, the preferred alternatives for the
             cleanup operations that are specified on Page 12 and 13 of the PRAP seem
             reasonable over the short term. It is important, however, that serious
             consideration be given to eventual removal of radiologically contaminated
             soil, as is mentioned on Page 12.
                                         66

-------
             In addition, it should be taken into account that a substantial number of
             homes to the north, the south, and the west of BNL receive their water
             through private wells. There remains the risk that contaminants that have
             already escaped into the groundwater system win have an impact upon these
             wells. The area to the west of BNL will soon be receiving a HUD block grant
             that will provide access to public water. The recent proposal by DOE to
             provide public water hookups to the area south of BNL will help address
             concerns in that area. However, the residential area to the north of BNL and
             south of Middle Country Road also contains a number of homes with private
             wells. While groundwater issuing from OUIV is of the greatest concern to
             the community to the south of BNL, OU IV is considerably closer to the
             residential area to the north. Although the process of evaluating cleanup
             alternatives for OU IV has not yet officially commenced, the present might be
             an opportune time to consider providing public water to the area north of
             BNL.

             While providing access to public water will address some of the concerns
             regarding contaminants released into the environment at BNL, the Ridge
             Civic Association  is committed to the protection of the natural environment
             as well. Even after residential areas adjacent to BNL have been granted
             access to public water, proposals for preventive and remedial action should
             continue to consider the protection of the Peconic River, Peconic Bay, and
             other natural areas to be high priority".

Response:    As recommended, excavation and removal of these soils is an alternative being
             evaluated as a part  of a FS under OU I. The OU IFS Report will be prepared by
             BNL/DOE and reviewed by EPA and NYSDEC. Upon concurrence from these
             agencies, we expect to propose a final remedy for these soils by February,  1997 for
             public review.

             The groundwater flow at BNL is generally from north to south. Ridge is located
             north of BNL site.  There is no evidence or potential for any groundwater
             contamination in Ridge from BNL. Any potential groundwater contamination
             from BNL will travel towards the south. Therefore, providing public water to
             areas north of the BNL she could not be justified as part of this remediation
             project.

             It is the intent of DOE to address both human health and environmental risks
             through environmental restoration activities that are being planned. Brookhaven
             National Laboratory & DOE are committed to seeking public involvement in the
             environmental restoration process and addressing community concerns.
                                         67

-------
           Hihlihts of Other Communit  Relations Activities at the BN  Site
 Specific community relations activities related to Operable Unit IV are detailed in the Record of
 Decision, Decision Summary Section 3 and in the Responsiveness Summary. The following is a
 list of other significant community relations activities under CERCLA conducted to date at the
 Brookhaven National Laboratory She:

 - 1991 :  The Administrative Record and information repositories for the site were established.  All
 documents referenced herein are a part of the Administrative Record.

 - September 1991 :  A 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 was placed in the Administrative Record.

 - September 1991 :  A public meeting was held and a fact sheet was distributed to receive public
 comments on BNLs She Specific Plan for Environmental Restoration and Waste Management.
 Presentations were conducted on the status of BNLs environmental restoration activities. Public
 input was requested and comments on the draft Response Strategy Document, draft Site
 Community Relations Plan, and the draft Remedial Investigation/Feasibility Study (RI/FS) Work
 Plan for Operable Unit IV were requested.  A 30-day public comment  period was provided.

 - April 1993: A public meeting was held and fact sheets were distributed to receive public
 comments on BNLs Site Specific Plan for Environmental Restoration and Waste Management.  A
 presentation was conducted on the status of BNLs environmental restoration activities and
 upcoming public involvement milestones. A 30-day public comment period was provided.

 - July 1993: A public notice of availability was issued to announce the availability of the
 Engineering Evaluation/Cost Analysis for the "D" Tanks Removal Action for public comment. A
 30-day public comment period was provided.

 - November 1 993 : A public meeting was held and fact sheet was distributed for the Operable
Unit I RI/FS Work Plan, the Spray Aeration Field Investigation Sampling and Analysis Plan, and
the Landfills Sampling and Analysis Plan to allow the public an opportunity for comment on the
proposed activities. A 30-day public comment period was provided.

- February 1994: A public notice of availability was issued to announce the availability of the
Engineering Evaluation/Cost Analysis for the Cesspools Removal Action as well as the Action
Memorandum for the Bldg. 464 Mercury-contaminated Soil Removal Action for public comment.
A 30-day public comment period was provided.

- October 1994:  A public meeting was held and a fact sheet was distributed for the Operable Unit
V RI/FS Work Plan to allow the public an opportunity for comments on the proposed activities.
A 30-day public comment period was provided.
                                         68

-------
- May 1995: A public notice of availability was issued to announce the availability of the
Engineering Evaluation/Cost Analysis for the Landfills Removal Action for public comment.

. January 1996: A Community Forum was established to provide a mechanism for community
residents to express their views and concerns to BNL staff about BNL activities and plans for the
future. The first meeting was held January 29,1996.

- January 1996: Briefings to local elected officials and regulatory agencies on the status of
residential public water hookups at the south boundary.

- January 1996: A public meeting was held for the Operable Unit I Groundwater Removal Action
to discuss the findings of the Engineering Evaluation/Cost Analysis Report and to allow the public
an opportunity to comment on the proposed cleanup activities. The document is part of the
Administrative Record.  A public notice of availability for the meeting was issued, along with fact
sheets, summary sheets, and a press release distributed to the public. Also presented at the
meeting was an update of other BNL environmental restoration activities, including the on-going
field investigation work for Operable Unit HI. A 30-day public comment period was provided
and an extension was provided.

- Other on-going community relations activities which were initiated in 1990 include holding
meetings with local community civic associations and umbrella groups, meetings with BNL
Departments, Divisions, and apartment area residents (the on-site community) to update them on
the status of the Environmental Restoration activities, meetings with NYSDEC Hazardous Waste
Advisory Group, area of concern tours, mailings, Brookhaven Bulletin articles, press releases,
quarterly updates to the Administrative Record, presentations and tours for local colleges,
elementary and high school presentations, and responding to community phone calls and
correspondence.
                                          69

-------
                                 REFERENCES
COM Federal Programs Corporation.  1993. Final Report Engineering Evaluation Oil/Solvent
Underground Storage Tank, Brookhaven National Laboratory, OUIV, October 29.

Ecology and Environment, Incorporated. 1993a. Video Camera Survey of Drainpipe
Between Building 650 and Building 650 Sump Outfall Area, OU IV, Brookhaven National
Laboratory.  April. Prepared for Brookhaven National Laboratory.

Ecology and Environment, Incorporated. 1993b. Geophysical Survey, OU IV, Brookhaven
National Laboratory. April. Prepared for Brookhaven National Laboratory.

IT Corporation. 1991a. Remedial Investigation/Feasibility Study Work Plan, OU IV,
Brookhaven National Laboratory, Upton, Long Island, New York.  Prepared for Brookhaven
National Laboratory.

FT Corporation. 1991b. Remedial Investigation/Feasibility Study Sampling and Analysis Plan.
OU IV, Brookhaven National Laboratory, Upton, Long Island, New York. Prepared for
Brookhaven National Laboratory.

New York State Department of Environmental Conservation (NYSDEC). 1992. Division
Technical and Administrative Guidance Memorandum: Determination of Soil Cleanup Objectives
and Cleanup Levels at hazardous Waste Sites.

New York State Department of Environmental Conservation (NYSDEC). 1993. Division of
Hazardous Substances Regulation Technical and Administrative Guidance Memorandum:
Cleanup Guidelines for Soil Contaminated with Radioactive Materials.

CDM FEDERAL PROGRAMS CORPORATION. 1994.  Draft FS Report, Brookhaven
National Laboratory, OU IV, December 27.

OERR/USEPA. 1989. Interim Final Guidance on Preparing Superfund Decision Documents.
Office of Emergency and Remedial Response June.

CDM FEDERAL PROGRAMS CORPORATION. 1994.  Final Remedial Investigation/Risk
Assessment Report, OU IV, December 7.

BROOKHAVEN NATIONAL LABORATORY. 1995. Operable Unit IV, Proposed
Remedial Action Plan, November, 1995.

BROOKHAVEN NATIONAL LABORATORY. 1995. Transcript OU IV Public Meeting for
FS/PRAP, December 6, 1995.
                                      70

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TABLES

-------
                                                   Table 1

                                BROOKHAVEN NATIONAL LABORATORY
                                     PHYSICAL PLANT DATA SHEET
                                                  STEAM UmiTf fCOMTP)
POPULATE*!
St
01
To
        JMuvy 1.1947
                I bM^k^^tf^A ^KA
                URMMDM. MC.
                       3S7B
                       3JOO
                                                                       600.000.000 fetfyr
                                                  wOTBiununr
                                      O2
Tokd-
BuR-tpmB-
LVBCIMGHnH •
FBroxnouMiQ.
•A*wM ahm !• •••
•VX IlLflDDIWlB
BoundBd by.
                       5421
200 ao
 son
120ft
                                     2.183
                                       •1 !•
                                       24m
                                       37 m
              soom-u
                                                                              11
                                                                             125
                                                                               emgd
                                                                            1200 gpmi
                                                                         LOOOOOOgri
                                                                              2
                                                                          250.000 gri

                                                                          SStoTOpri
                                                                             12 mod
                                                                             ijOmgd
                                                                             oamgd
                                                                             ZOmgd
                                                                             31
                         Und
PcnwMnt-107
T«mpeofy-I2i
TeM    -318
Toftm   -214

ROAPSAWAUC8
                                   343.1Mm2
                                                                            IjSOtarat
                                                                            1250km
                                                                           15400 gpn
                      87X100 tf
                          14
                          11
                          48
                                                   ptentmpip*
                         1.7
                         14
                                       47km
                                       23km
                                       it km
                                       74km

                                       34 l»
                                      £7 km
                                       23km
                                                  COMMeSSEDABIUnUTY
                                                           .2®-
ULCOFMdm.2®-
IMnSutaMiam.2®—
OMttutan Undvgraund -
                         WkVm.
                         00 KVAM.
                      13400 VWKJZ400V
                         47MW(
                  220400400 KWKVyr
                                                                >A72Styki7
                                                    -to
                                                                              7SO«elm<
                                                                              125 pri
                                                                              US)
                                                                            8400
                                                                            5200
                                                                            5460
                                                                            1400
                                                                            20400
                                                                             3400
STEAM OnUTY
    14®-
                      180400
                      125400
Furi-
                                        23koA
                                        I8kg/i
        -oirtoag*    3400400 gri   11470400 L
                                                  WASTE DtSPOSAl
                                                          i A Said
                                                                     - T<
                                                                       e
                                                                                            272.1SM64 k
                                                                                                  221

                                                                                                  18k
                                                                                                  2831
                                                                                                   781
                                                                                              1.182.180 I
                                                                                              3.780UOOOI

                                                                                               8474001
                                                                                                   721
                                                                                              379 to 4831
                                                                                              101 to 1311
                                                                                                  szei
                                                                                                  43J8I
                                                                                                  35.1 I
                                                                                                  87JBI
                                                                                                   80)
                                                                                                4.400 I
                                                                                                4.400 I
                                                                                                  8L7!
                                                                                                  14
                                                                       toreff-
• Bddngt wtth an ana of 200 »qJL or I

                  t»-
                  kg«

              DON«O1M
                            i •• not Indud^l in flw count

                                          L«Btn
   " cubic
                                          U»
                                      i or im MTDWMmM.1
                                                                                               040294

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                              Table 2

                          Operable Unit IV

          Maximum Concentration of VOCs and SVOCs in Soil
                              
-------
                             Table3
                         Operable Unit IV

                     Maximum Concentrations
                      of Radionuclides in Soil
                             (pCi/g)
Compound
Plutonium 239/240
Strontium - 90
Cesium - 137
Europium- 152
Europium- 154
Radium - 226
Selected Cleanup
Guidelines*
60
42
31
70
260
5
Maximum Detected
Level
170
140
1,800
580
350
63
AOC-6
Location
Sump Outfall
Sump Outfall
Sump Outfall
Sump Outfall
Sump Outfall
Sumo Outfall
*Above Background

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                                                  Table 4

                                              Operable Unit IV

                          Maximum Concentrations of VOCs and SVOCs in Groundwater

Compound

Detected TCL VOCs
1,2-Dichloroethene

1,1,1 -Trichloroethane
Trichloroethene
Tetrachloroethene
Toluene
Ethyibenzene
Xylenes (total)
Detected TCL SVOCs
1,2-Dichlrobenzene
Federal Standard
or Guideline
MCL

70 (cis)
100 (trans)
200
5
5
1000
700
10000

600
NYS Standard or
Guideline
MCL

5

5
5
5
5
5
5

5
Selected Cleanup
Goal


5

5
5
5
5
5
5

5
Maximum*
Detected Level


64

14
20
43
2700
590
2200

12
Well**
No.


76-04


76-04
76-04
76-04
76-04
76-04

76-04
GA: Class GA Groundwater Quality Standard.
MCL:  Maximum Contaminant Level.
 *Maximum Detected Level among all shallow wells which were monitored.
**Well locations are shown in Figure 7.

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                                                                                         Table 5
                                                                         Brookhaven National Laboratory
                                                                                   Operable Unit IV
                                          Summary of Chemicals of Potential Concern in Site Matrices by Area of Concern

Sump Outfall
VOCs
None Selected
SVOCs
Benzo(a)aiithracene
Bertzo(b)f1uoro*nthene
BenzoOOpyrene
Indeno( 1 ,2,3-co)pvrene
Pesticides/PCBs
None Selected
Inorganics
Anenic
Barium
Beryllium
Cadmium
Chromium VI
Manganese
Mercury
Nickel
Vanadium
Zinc
Surface Soil
Drainage Area
VOCs
None Selected
SVOCs
None Selected
Pesiticides/PCBs
None Selected
Inorganics
Arsenic
Barium
Beryllium
Chromium VI
Manganese
Nickel
Vanadium
Central Steam Facility
VOCs
Ethylbenzene
Tetrachloroethylene
Toluene
Xylenes (Total)
SVOCs
Benzo(a)anthracene
Benzo(b)bluoroanthene
Benzo(a)pyrene
Pesticides/PC Bs
4.4-DDT
Inorganics
Anenic
Barium
Beryllium
Chromium VI
Manganese
Mercury
Nickel
Vanadium
Bldg.. 650", „
Present and Future
VOCs
None Selected
SVOCs
Benzo(a)an1hracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Pesticides/PCBs
None Selected
Inorganics
Arsenic
Barium
Beryllium
Manganese
Mercury
Thallium
Vanadium

Sump Outfall
VOCs
None Selected
SVOCs
None Selected
Pesticides/PCBs
None Selected
Inorganics
Arsenic
Barium
Chromium VI
Manganese
Mercury
Nickel

Drainage Area
VOCs
None Selected
SVOCs
None Selected
Pesticides/PCBs
None Selected
Inorganics
Anenic
Barium
Chromium VI
Manganese
Vanadium
Subsurface Soil
Central Steam Facility
VOCs
None Selected
SVOCs
Benzo(a)anthracene
Benzo(b)fluonnthene
Benzo(a)pyrene
IndenoO ,2,3-co)pyrene
Pesticides/PCBs
Arochlor 1248
Inorganics
Arsenic
Barium
Beryllium
Chromium IV
Manganese
Nickel
Thallium
Vanadium
E&,630'
VOCs
U-Dichloroethene
SVOCs
None Selected
Pesticides/PCBs
None Selected
Inorganics
Arsenic
Beryllium
Manganese
Thallium
Vanadium

Bldg.. 630
Future
VOCs
None Selected
SVOCs
None Selected
Pesticides/PCBs
None Selected
Inorganics
Arsenic
Barium
Beryllium
Manganese
Nickel
Thallium
Vanadium
Groundwater
Site Wide
VOCs
1,1-Dichoroethene
Trichlroeothylene
Bromodichloromethane
Tetrachloroethylene
SVOCs
None Selected
Pesticides/PCBs
None Selected
Inorganics
Arsenic
Manganese
'Surface soil exposure scenarios are different for present and potential future site workers in the Bldg.. 650 area. For both exposure scenarios, however, the same chemicals of potential concern were selected.
'No present site or construction worker exposures to subsurface soil are occurring; therefore, the scenarios will only be qualitatively addressed.
'Subsurface soil exposure scenarios are different and potential future site and construction worken in the Bldg.. 650 area. The future-use scenario will be quantitively evaluated as construction and/or maintenance work involving excavation
activity may occur. The chemicals of potential concern differ from those selected under the present-use scenario.

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                                                                                                                               Table 6
                                                                                                     SUMMARY OF SOILS ALTERNATIVE ANALYSIS FOR TCI ORGANICS
                                                                                                                               (Page 1 of 3)
Assessment Fadors
Key.Componenls







Sltort-Jerm Effectiveness
Protection of Community During
Remedial Adions
Protection ol Workers During
Remedial Actions

Environmental tmpads


Time Until Remediation


Altemaltve SI
Single son vapor survey end
groundwater samptng event and
review aline end of live (5)
years.








No short-lean risks lo
contmunrly.
Minlmil risk lo workers
performing one-time sol vapor
survey and wel sampling.
Personal protection equipment
required during operations

Contamlnaled sons continue lo
be a source lo groundwater
contamination.


Alternative rales on natural
bloremedlatlon, which Is
unpredictable it this stage.
Alternative S2
Sol vapor survey and
grounowater sampling once (1) •
year for 10 years. Reviews at
(he end ol every live (5) yeara.








No short-term risks to
Minimal risk lo workers
performing sol vapor survey and
wel sampling once (1) • year.
Personal proledion equipment
required during operations.

Contaminated aols continue lo
be a source to groundwater
contamination.


Alternative relies on natural
btoremedlaUon, which Is
unpredidable al this stage.
Alternative S3
No excavation ol soils.
Contaminated soils are
remediated by SoS Vapor
Exlradion for two (2) yeers.








No short-lerm risks lo
community.
Minimal risk lo workers during
installation of aofl vapor
extradlon and bloventing
systems. Personal proledion
equipment required during
drilling of vertical vapor wels.

Subsurface win be disturbed
during Instalatfon of horizontal
vapor welts. However, careful
and coned backflttng win
mitigate same. Practically no
adverse environmental impads.
2 years


Alternative S4A
Total excavation of sols.
Excavated soils are remediated
by On-Site Low Temperature
Thermal Oesorplion. Treated
soils are used as backM.








Minimal risk to communiiy from
Increased construdron and
treatment system traffic.
Personal protection equipment
required against direct contact,
Ingesllon. and Inhalation
hazards.

Sue wiS be disturbed (cleared).
Also, subsurface wig be
disturbed. However, careful and
coned backlUling win mitigate
same.

Six (6) months


Alternative StD
Total excavation ol sols.
Excavated non-hazardous soils
•re disposed of at the Town of
BrookhavenLandMand
hazardous sols are disposed of
at an Off-Site Hazardous
(O-wasle)LandM. Virgin soils
are used as backlW.





Minimal risk lo community from
Increased construction Irsffic
and transportation of sols.
Personal protection equipment
required against dired contact.
Ingesllon, and Inhatallon
hazards.

Sue war be disturbed (cleared).
Also, subsurface wll be
disturbed. However careful and
coned backfilling wffl mitigate
same.

Six (6) months


Alternative S9A
Partial excavation ol soDs (up lo
16' deolhs). Excavated sou are
remediated bv On-Site Low
Temperature Thermal
DesorpBcn. Treated sols art
used as tack«. (Six (6) months
for these tasks.)


Unexca>aled contaminated sols
(deeper than 18') are remediated
by Sol Vapor Extradlon for two
(2) years.
Minimal risk lo oommurvn/ from
increased construdlon and
treatment system traffic.
Personal proledion equipment
required against conlad and
Inhalation hazards during
excavation and treatment.
Personal proledion equipment
required during Insulation ol son
vapor extradlon system.
Site wffl be disturbed (deartd).
Also, subsurface w» bt
disturbed. However, careM and
aame.

2 years


Altematlvt 850
Partial excavation of sols (up to
It' depths). Excavated
non-tujzardous sols art
disposed of al Iht Town ol
Brookhaven LandM and
hazardous sols are disposed of
at an Off-Sile Hazardous
(D-wasle)lendM. Virgin sols
are used as backM. (Six (8)
Unexcavated contamlnaled sols
(deeper than 101 are remediated
by Sol Vapor Extradlon for two

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                                                                                                                                 Table 6

                                                                                                      SUMMARY OF SOILS ALTERNATIVE ANALYSIS FOR TCI OROANICS
                                                                                                                                 (Page 2 of 3)
 Assessment Factors
                                  Alternative SI
                                                                    Alternative S2
                                                                                                      Altenutlve S3
                                                                                                                                        Altemitlve S4A
 Reduction ol Toxicfly. MoWity.a
 Volume.
 Treatment Process and Remedy     No treatment provided.
 Amount of Huaidous Materials
 Treated or Destroyed
Irreversibility of Treatment

Type and Quantity ol Residual
None by treatment: natural
bkxemedlallon would continue to
reduce the loxWIy ol
contaminated sols.
Not applicable.

No waste generated by
treatment; contamination
remains on slle.
                                  No treatment provided.
None by treatment: natural
Moremedlatlon would continue to
reduce the toxtcfly ol
contaminated soils.
Not applicable.

No waste generated by
treatment: contamination
remains on site.
                                                                     Reduction In toilcrty. mobility.
                                                                     and volume by vapor extraction
                                                                     and bloveniing.
Estimated volume ol hazardous
sorts treated • 3.515 cu yd.
Estimated votume ol
non-hazardous soils treated •
3.255 cu yd. Total • 8.770 cu
yd.
Ineversible

Residual concentrations In sods
are expected to be low and the
soils are expected to cease
being a source for groundwaler
contamination.
                                                                                                                                        Reduction In mobility of potential
                                                                                                                                        leachale because ol source
                                                                                                                                        removal.  Reduction In loxidty
                                                                                                                                        and votume by treatment.
Estimated volume ol hazardous
soils treated • 3.515 cu yd.
Estimated volume of
non-hazardous soils treated •
3.255 cu Yd  Total • 6.770 cu
yd.
Ineversible

None
                                                                                                                                                                           Alternative S40
                                                                                                                                                                                                              Alternative SiA
                                                                                                       Reduction In loxldty. moblity.
                                                                                                       and volume because of source
                                                                                                       removal.
Estimated volume of haiardous
sons treated' 3.515 cu yd.
Estimated votume ol
non-haz ardous soils treated •
3.255 cu yd. Total' 6.770 cu
yd.
Irreversible

None. Excavated sons w» be
Undraw In Town of Brookhaven
Landfill (lor non-hazardous soils)
and In Off-Site Hazardous
(0-wasle) landIM (lor hazardous
soils).
Reduction In toidcfty, mobility.
and volume because ol partial
excavation and treatment ol
contaminated sons. Reduction In
loxldty mobility, and volume of
remaining contaminated aofs by
soft vapor extraction.
Estimated votume of haiardous
sons (rested (in-situ and ex-sltu)
• 3.515 cu yd.  Estimated
votume of non-hazardous soils
treated (In-silu and ex-sftu) •
3.255 cu yd. Total ° 6.770 cu
yd.
Irreversible

None for excavated and treated
sols. For sols remaining kvsrlu,
residual concentrations are
expected to be low and the sols
are expected to cease being e
source for groundwaler
conlamtniuon after completion
of son vapor extraction.
Reduction n loxldty, moblity.
and volume because of partial
excavation and treatment of
contaminated soils.  Reduction In
loxrcHy. mobility, and volume of
remaining contaminated soils by
son vapor extraction.
Estimated volume of huantous
sons treated (in-sltu) • 1 ,«25 cu
vd. Estimated votume of
hazardous sons disposed of at
Off-Site Hazardous (0-waste)
land«l« 1.690 cu yd.
Estimated votume of
non-hazardous sons treated
(In-sltu) -1.65501 yd.  Estimated
volume of non-hazardous sons
disposed ol at Town ol
Irreversible

None for excavated sots. which
wVbelandffiledlnTownef
Brookhaven or Off-Site
Hazardous (O-wasta) Landfils.
For sols remaking h-altu.
residual concentrations are
expected to be low and DM sols
are expected to cease being a
source for groundwaler
contamination after  complellon
Ability to Construe! and Operate
Technology
Reliability of technology
Ease of Undertaking Additional
Remedial Action It Necessary

Monitoring Considerations
                                 Hot applicable.
                                 Not applicable.
                                 Easy to undertake
                                  Monitoring Is reliable In
                                  evaluating the extent and natural
                                  attenuation level of
                                  contamination.
                                                                    Monitoring la ratable In
                                                                    evaluating the extent and natural
                                                                    attenuation level of
                                                                    contamination.
                                  Easy to undertake
                                 Single son vapor survey and          Sol vapor aurvey and
                                 gioundwaler sampling event and      grounoVvaler sampling once (I) a
                                 review at the end ol five (5)           year tor 30 years. Reviews it
                                 years.                             the end of every five (5) years.
Easy to construct and operate
Soil Vapor Extraction System.
Some site clearing required.




Theoretical principles for soil
vapor extraction are reliable.



Can easily accommodate
addHlonaf soil contamination.
None
EstaMshed excavation
techniques. Standard
commercial treatment
technologies. Win be easy to
operate. Some site clearing
required.

Wel developed and proven
technologies. A slack lest may
be needed.


Can easily accommodate
additional son conlamtnallon.
Post-excavation sampling and
sampling of treated soils.
Established excavation
techniques.





Notapptcable. Excavated soils
wffl be landflDed In Town ol
Brookhaven lendIM (tor
non-hazardous soHs) and In
Ofl-Site Hazardous (0-wasle)
landltl (for hazardous soils).
Can easily acoommodale
additional son contamination.
Post-excavation sampling and
sampling ol soil pDes prior to
dlsposaf
Established excavation
techniques. Standard
commercial treatment
lechnoloc.les. For soils
remaining In-sltu, son vspor
extraction technology rs wel
eslabnshed. AR systems are
Wel developed and proven
lechnologlea for treatment of
excavated soils. For sols
remalnlnc kvsltu, theoretical
principles for sol vapor
extraction are ratable.
Can easly accommodate
additions, soil contamination.
Post-excavation sampling and
sampOng of treated soils.
Established excavation
techniques. For sola remaining
kvsltu, sol vapor extraction
technology Is wel established.
Al systems are simple to
construct and eesy to operate.
Some site dealing required.
Excavated srjfls wfll be landfined
at the Town of Brookhaven and
Off-Site Hazardous (D-wasle)
Landfills. For sots remaining
In-silu. theoretical prlndplee lor
sol vapor extraction are reliable.
Can easily accommodate
addrUonalsol contamination.
Post-excavation sampling and
sampling of soil piles prior to

-------
                                                                                                                            Table 6
                                                                                                   SUMMARY OF SOILS ALTERNATIVE ANALYSIS FOR TCL ORGANICS
                                                                                                                            (Page DolO)
 Assessment Factors
 Ability to obtain approvals          Permits not required.
 Availability ol Services sndMslertali
Availability of Treatment Capacity   Not applicable.
and Disposal Services
Availability ol Necessary Equipment Equipment and manpower lor
and Specialists                   one-lime sampling and analyses
                                Is readily available.
Costs
lativeSt
tostlon among Federal.
and local authorities
red for 5 year review.
Us not required.
Alternative 52
Coordination among Federal,
Stale and local authorities
required In the review of
monitoring data and
deissemination of information.
Permits not required.
Alternative S3
Coordination among Federal,
Slate and local authorities
required.
VWI need substantive
compliance wilh air emissions
permit.
Alternative S4A
Coordination among Federal,
Stale and local authorities
required.
Vv» need substantive
compliance wilh air emissions
permit.
Alternative S4D
Coordination among Federal,
State and local authoritlea
required.
W8 need approvals from landfills
and agencies for transportation
and disposal ol hazardous end
Alternative S5A
Coordination among Federal.
Sine and local authorities
required.
WW need substantive
compliance with air emissions
permit.
Alternative S5D
Coordination among Federal,
Slate and local authorities
required.
WU need approvals from landlB
and egendea for bansportatlon
and disposal ol hazardous and
 Total Capital Cost
                                $0
Annual Operation and Maintenance  $46.420
Cost


Net Present Worth (5%)            $36.400


CompJanw.wiih. ARSRs

CompGance with                  Does no) meet
Coniamrnant'Spedflc.             conlamlnanl-spedfic and
Adion.Spedfc. and               tocalton-specifc ARARi and
LocaHon-Specfflc ARARs and TBCs  TBCs.
Appropriateness of Waivers
                                Not applicable.
Overall Piolectloaot Human Health  Sob contamination is expeded
and the Environment               lo attenuate only over a long
                                period of lime. This alternative is
                                Ineffective In reducing the
                                potential risks posed lo human
                                health and the environment.
                                                                                                                                                                                                                                      non-hazardoua aofls. WM need
                                                                                                                                                                                                                                      substantive complance with air
                                                                                                                                                                                                                                      emissions pemw for fcvsltu soils.
Not applicable
Equipment and manpower for
monitoring, sampling and
analyses Is readily available.
$0
$33,120
$511.000
Does not meet
contamlnanl-spedfic and
tocalion-spedflc ARARs and
TBCs. Monitoring wOl comply
wilh actkxvspeeilic ARARs.
Not applicable.
Sous contamination Is expeded
lo attenuate only over a long
period of lime, this alternative Is
Treatment systems (Catalytic
Oxidation) are commercially
avaHabte. Disposal services are
not required
Equipment and manpower Is
readily available.
$373,719
$141.075
$636.000
AR organic, chemical spedfic
ARARs and TBCs would be
complied wilh.
Not applicable.
Soils wffl cease lo be a
continuing source of
contamination lo grouncHvaler.
Treatment systems (Low
Temperature Thermal
Desorplion) are commerdaDy
available. Disposal services are
not required.
'Equipment and manpower Is
readily available.
$2.574.465
$0
$2.570.000
Al organic, chemical spedflc
ARARs and TBCs would be
complied with.
Ha applicable.
ttshs lo human health and
invfronment would be
ruminated.
Transportation and disposal
services available.
Equipment and manpower Is
readily available.
$4.664.621
$0
$4.660.000
Al organic, chemical specific
ARARs and TBCs would be
complied with.
Not applicable.
Risks lo human health and
environment would be
eliminated.
Treatment systems (Low
Temperature Thermal
Desorplion and Catalytic
OxMelion) are commercially
available. Disposal services are
Equipment and manpower is
readily available.
Jl. 798.596
$70.000
$1.930.000
Al organic, chemical spedflc
ARARs and TBCs would be
compiled with.
Not applicable.
Risks to fuman health and
environment would be aknosl
ellmlniieo.
Treatment systems (Catalytic
Oxidation) are commerdalry
available. Transportation and
disposal services are available.
Equipment and manpower Is
readily available.
$2.757.403
$70.000
$2,690.000
Al organic, chemical spedflc
ARARs and TBCs would be
compiled with.
Not applicable.
Risks lo human health and
environment would be almost
eSmlnaled.
                                                                 Ineffective In reducing the
                                                                 potential risk* to (na environment
                                                                 and only partially effective in
                                                                 reducing lha risks lo human
                                                                 health, posed by future use of
                                                                 ground water and (ngestlon of
from 108 ingeslion and residual
risks lo environment may
remain.

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                                                                                                                                      TABLE 7

                                                                                                         SUMMARY OF RADIOACTIVE ALTERNATIVE ANALYSIS
                                                                                                                                   Page 1 of 4
                            Assessment Factors
                                                                          Alternative R-1
                                                                                                                      Alternative R-2
                                                                                                                                                                  Allarnatlva R-3
                                                                                                                                                                                                             Allernallva R-4
                 Key Components
                                                             Single groundwater sampling event, soil
                                                             radiation survey, and review al the end of 5
                                                             years.
                                            Institutional controls (or 50-year Industrial
                                            use.  Installation of fence. Annual
                                            grounrtwaler sampling and soil radiation
                                            survey for 50 years. Review every 5 years.
                 Short-Term Effectiveness

                 Protection of Community During Remedial
                 Actions
                 Protection of Workers During Remedial
                 Actions
                 Environmental Impacts
                 Time Until Remediation
                 Long.Term Effectiveness

                 Magnitude of Residual Risks
                 Adequacy of Controls
No short-term risks to community.
Minimal risk to workers performing
monitoring well Installation and one-time
groundwaler sampling and soil radiation
survey.  Personal protection equipment
required during activities.

Contaminated soils would continue to be a
source for direct contact, Inhalation, and
Ingestlon hazards and a source for
groundwater contamination.
                                                             Alternative relies on natural dispersion and
                                                             decay which cannot be predicted.
Human health risk from soil Ingesllon,
Inhalation, and direct contact and from future
use of groundwaler (due to continuing source
of soils) remains. Risks to the environment
would also remain.
No controls olher than one-time monitoring
after 5 years.
                                            No short-term risks to community.
Minimal risk to workers performing fence
Installation, monitoring well Installation and
annual groundwaler sampling and soil
radiation survey. Personal protection
equipment required during activities.

Minimal clearing and backfilling required for
fence installation.
                                            Alternative relies on fence to mitigate
                                            exposure to gamma radiation. Alternative
                                            also relies on natural dispersion end decay
                                            which cannot be predicted. However, 50-
                                            year Industrial use controls alone are not
                                            expected to be sufficient.
The fence would eliminate human health risk
from direct exposure to gamma radiation.
Risk from soil Ingesllon and Inhalation would
be reduced. Future use of groundwaler (due
to continuing source of soils) and risks to the
environment would remain.

Combination offence and 50-year Industrial
use Institutional controls restricts direct
exposure by human and large mammal
environmental receptors. Annual monitoring
provides potential for warning.
                                           Institutional controls for 50-year Industrial
                                           use. Installation of fence. Excavation of
                                           6,510 cubic yards of soil. Excavation of
                                           contaminated debris. On-slte storage at
                                           HWMF (Option R-3A) or off-site disposal at
                                           DOE Hanford (Option R-3B). Annual
                                           groundwater  sampling and soil radiation
                                           survey for 20 years and every 5 years for
                                           years 25 to 50. Review every 5 years.
Minimal risks to community from Increased
(raffle due to construction (both options) and
of'slle soil transportation (Option R-3B only).

Personal protection equipment and dust
suppression measures required to protect
against direct contact and Inhalation hazards.
Site and subsurface (to varying depths)
would be disturbed (cleared). Careful and
correct backfilling and revegetatlon would
mitigate.
                                            Six months for removal combined with 50-
                                            year Industrial use controls.
Human health risk from soil Ingesllon,
Inhalation, direct contact and future use of
groundwaler would be mitigated through
removal of virtually all soil contaminated
above RESRAD action levels. Risks to the
environment would be mitigated.

Excavation, fencing, 50-year Industrial use
Institutional controls and monitoring would
removal virtually all soil above action levels,
providing adequate control.
                                            Institutional controls (or 50-year Industrial
                                            use. Installation of fence. Excavation of
                                            3,320 cubic yards of soil. Excavation of
                                            contaminated debris. Installation of single
                                            layer cap.  Onslte storage al HWMF (Option
                                            R-4A) or offsile disposal al DOE Hantord
                                            (Option R-4B).  Annual groundwater
                                            sampling and soil radiation survey for first 20
                                            years and every 5 years from year 25 to 50.
                                            Review every 5 years.
Minimal risks to community from Increased
traffic due to construction (both options) and
offsile soil transportation (Option R-4B only).

.Personal protection equipment and dust
suppression measures required to protect
against direct contact and Inhalation hazards.
Site and subsurface (lo varying depths)
would be disturbed (cleared). Single layer
cap would be Installed al two locations.
Backfilling and revegelallon would be
installed al third location.

Six months for removal combined with 50-
year Industrial use controls.
 Human health risk from soil Ingesllon,
 Inhalation, direct contact and future use of
 groundwafer would be mitigated through
 removal of the majority of the radlologlcally
 contaminated soils and capping. Risks lo
 the environment would be mitigated.

 Excavation would remove (he majority of the
 soil above actions levels. Capping, fencing,
 50-year Industrial use Institutional controls
 and monitoring would protect against
 exposure to any residual soils, providing
 adequate control.
WP2H

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                                                                                                                      TABLE 7

                                                                                             SUMMARY OF RADIOACTIVE ALTERNATIVE ANALYSIS
                                                                                                                      Page 2 of 4
           Assessment Factors
                                                          Alternative R-1
                                                                                                      AllernallveR-2
                                                                                                                                                  Allernallvo R-3
                                                                                                                                                                                             Alternative R-4
Reliability of Controls




Reduction of Toxlcltv. Mobility, or Volum»

Treatment Process and Remedy
Amount of Hazardous Materials Treated or
Destroyed
Irreverslbllily of Treatment

Type and Quantity of Residual Waste
Imolemenlabllitv-Technlcal Feasibility

Ability to Construct and Operate Technology
 Reliability of Technology
Monitoring would provide reliable one-lime
Identification of change In conditions, but no
control of contaminant migration.
                                            No treatment provided.
None by treatment. Natural dispersion and
decay would very slowly reduce the loxlcity of
contaminated soils.
Not applicable.

No waste generated by treatment.
Contamination remains on site.
Oroundwaler monitoring and radiation
surveys would be Implemenlable. However,
a single event would not offer sufficient data
to control exposure to risk.
Oroundwater monitoring and radiation
surveys reliably evaluate lha extent of
radiological contamination and natural decay.
However, a single event would not offer
sufficient data lo control exposure to risk.
Fencing and Institutional controls are reliable
deterrents. Monitoring would provide reliable
annual Identification of change In conditions
but no control of contaminant migration.
                                            No treatment provided.
None by treatment. Natural dispersion and
decay would very slowly reduce the loxlcily of
contaminated soils.
Not applicable.

No waste generated by treatment.
Contamination remains on tile.
Oroundwater monitoring and radiation
surveys would be Implemenlable. Fencing
and Institutional controls for a 50-year
Industrial use scenario are well established
and would be easy to maintain.
Oroundwaler monitoring and radiation
surveys reliably evaluate tha extent of
radiological contamination and natural decay.
 Fencing and Institutional controls are
reliable methods of reducing exposure to
contaminated soils.
                                                                                                                                    Reliable.
                                            No treatment Is provided.  The contaminated
                                            soil Is excavated and controlled at an off-site
                                            location.
None by treatment. Estimated volume of
radlologlcalry contaminated soils to be
excavated Is 6.510 cubic yards of which 90%
Is estimated lo have a specific activity less
than 2,000 pCI/g (DOT non-radioactive) and
10% Is estimated lo be greater than 2,000
pCI/g (DOT low specific activity).

Not applicable.

No wasle generated by treatment. Residual
concentrations In soils would be below
RESRAD action levels assuming 50-year
Industrial use scenario. One sampling
location at depth would remain above action
levels. However, risk of 24-26 fool deep
contaminant hot spot Is minimal, since dust
would not be a significant pathway.
Established excavation techniques Including
use of sheet piling. Groundwater monitoring,
radiation surveys, fencing, and Institutional
controls for a 50-year Industrial use scenario
are well established and would be easy lo
maintain.

Well-developed and proven methods for
excavation and storage/disposal of
radlologlcally-contamlnaled soils.
Groundwater monitoring, radiation surveys,
fencing and Institutional controls for 50-year
Industrial use scenario are also reliable.
Disposal at Hanford may not be available for
soils.
                                                                                                                                                                                Reliable.
No treatment Is provided. A majority of the
contaminated soil Is excavated and
controlled at an off-site location. The area
would be capped off.

None by treatment. Estimated volume of
radlologlcally contaminated soils lo be
excavated Is 3,320 cubic yards of which 90%
Is estimated lo have a specific activity less
than 2.000 pCI/g (DOT non-radloacllve) and
10% Is estimated to be greater lhan 2,000
pCI/g (DOT low specific activity).

Not applicable.

Residual concentrations In soils are below
RESRAD action levels assuming cap and 50-
year Industrial use scenario. One sampling
location at depth remains above action
levels. However, risk of 24-26 foot deep
contaminant hot spot Is minimal, since dual
would nol be a significant pathway.
Established excavation techniques Including
use of sheet piling and capping.
Oroundwaler monitoring, radiation surveys,
fencing, and Institutional controls for a 50-
year Industrial use scenario arc well
established and would be easy lo maintain.

Well-developed end proven methods for
excavation and storage/disposal of
radiologlcalfy-conlamlnaled soils.  Single-
layer capping with runon/runoff controls Is
well established. Oroundwater monitoring,
radiation surveys, fencing and Institutional
controls for 50-year Industrial use scenario
are also reliable. Disposal at Hinford may
not be available for soils,

-------
                                                                                                                     TABLE 7

                                                                                             SUMMARY OF RADIOACTIVE ALTERNATIVE ANALYSIS
                                                                                                                     Page 3 of 4
           Assessment Factors
                                                         Alternative R-1
                                                                                                     Alternative R-2
                                                                                                                                                AllernaHv8R-3
                                                                                                                                                                                            Alletnallve R-4
Ease of Undertaking Additional Remedial
Action If Necessary
Monitoring Conslderallons
Administrative Feasibility

Coordination wllh Other .Agencies
Easy to undertake.
Single radiological survey (alpha.
beta/gamma, and gamma) and groundwaler
sampling evenl and review at the end of 5
years.
Coordlnallon among Federal, Slate, and
local authorities for 5-year review.
 Ability lo Obtain Approves
Availability of Services arid Materials

Availability of Treatment Capacity and
Disposal Services

Availability of Necessary Equipment and
Specialists
                                            Permits not required.
Not applicable.
Equipment and staffing for one-lime
groundwaler sampling and radiation survey
are readily available.
                                                                                       Easy lo undertake.
Radiological survey (alpha, bela/gamma and
gamma) and groundwater sampling annually
for 50 years. Review every 5 years.
Coordination among Federal. Slate, and
local authorities required In the review of
annual groundwaler monitoring and radiation
survey data and dissemination of Information.
Institutional controls for 50-year Industrial
use must be established and enforced.
                                            Permits not required.
                                            Not applicable.
Equipment and staffing for fence
maintenance and annual groundwaler
sampling and radiation survey are readily
available.
Can easily accommodate additional soil
contamination. Sheet piling will be
necessary with excavations at depth.

Annual radiological survey (alpha,
bela/gamma, and gamma) and groundwaler
sampling annually for first 20 years, Ihen
every 5 years for years 25 to 50.  Review
every 5 years.
Coordlnallon among Federal, Stale, and
local authorities required for data review and
dissemination and 50-year Industrial use
Institutional controls.  On-slle storage of
excavated soil and debris (Option 3-A) would
require regulatory concurrence. Off-site
disposal al DOE Hanford (Option 3-B) would
require significant administrative
Coordlnallon lo Implement.

Would need approvals from Federal, State,
and local agencies for transportation and
disposal of radlologlcally contaminated soil
and debris al  lha DOE Hanford facility
(Option  3-B).
Transportation and disposal services are
available.

Equipment and staffing for fence
maintenance, groundwater sampling,
radiation surveys, excavation and
storage/disposal are readily available.
Can easily accommodate additional soil
contamination. Sheet piling will be
necessary wllh excavations at depth.

Annual radiological survey (alpha,
beta/gamma, and gamma) and groundwate
sampling annually for first 20 years, Ihen
every 5 years for years 25 to 50.
Coordination among Federal, State, and
local authorities required for data review and
dissemination and 50-year Industrial use
Institutional controls. On-slte storage of
excavated soil and debris (Option 4-A) would
require regulatory concurrence. Offsile
disposal at DOE Hanford (Option 4-B) would
require significant administrative
coordination to Implement.

Would need approvals from Federal, Slate,
and local agencies for transportation and
disposal of radlologlcally contaminated soil
and debris at the DOE Hanford facility
(Option 4-B).
 Transportation and disposal services are
 available.

 Equipment and staffing for fence
 maintenance, groundwater sampling,
 radiation surveys, excavation,
 storage/disposal, and capping are readily
 available.

-------
                                                                                                                  TABLE 7

                                                                                          SUMMARY OF RADIOACTIVE ALTERNATIVE ANALYSIS
                                                                                                                  Page 4 or 4
           Assessment Factors
                                                        Alternative R-1
                                                                                                   Alternative R-2
                                                                                                                                             Alternative R-3
                                                                                                                                                                                        Alternative R-4
Costs
Total Capital Cost
Annual Operation and Maintenance Cost
Net Present Worth (5%)

$39,215
$49,500
$78,000

$76,274
$37.950
$769,000

$3,205,630 (Option A)
$33.632,843 (Option B)
$33,604 (Option A)
$33,604 (Option B)
$3,820,000 (Option A)
$34,200,000 (Option B)

$2.737,893 (Option A)
$18,210,388 (Option B)
$37,354 (Option A)
$37,354 (Option B)
$3.420,000 (Option A)
$18,900.000 (Option B)
Compliance with ARARs

Compliance with Contaminant-Specific,
Action-Specific, and Location-Specific
ARARs and TBCs
Appropriateness of Waivers

Overall Protection o( Human Health and the
Environment
There are no ARARs for radiological soil
cleanup.  The NYSDECTAGM which
Identifies the cleanup goal as a dose tale of
10 mllllrem/year Is a TBC. R-1 would not
meet this cleanup goat.
Not applicable.
                                           Soil contamination would attenuate very
                                           slowly over a very long period of lime. The
                                           risk for potential contaminant migration to
                                           groundwaler would remain.  This alternative
                                           would be Ineffective In reducing the potential
                                           risks posed to human health and the
                                           environment.
There are no ARARs for radiological soil
cleanup.  The NYSDEC TAOM which
Identifies the cleanup goal as a dose rate of
10 mlllirem/year Is a TBC. This cleanup goal
would be met through Installation of a fence
and Institutional control, which would
mitigate the most significant direct exposure
pathway.
                                                                                     Not applicable.
                                           Soil contamination would attenuate very
                                           slowly over a very long period of time. The
                                           fencing, Institutional controls, and monitoring
                                           In this alternative would be effective In
                                           reducing risks to humans and large
                                           environmental receptors.
There are no ARARs for radiological soil
cleanup.  The NYSDEC TAGM which
identifies the cleanup goal as a dose rate of
10 mllllrem/year Is a TBC. This cleanup goal
would be met through source removal,
Installation of a fence, and Institutional
control, which would mitigate the most
significant direct exposure pathway.
                                                                                      Not applicable.
                                           Soils would cease to be a source of
                                           contamination to groundwaler. Residual
                                           risks to human heallh and environmental
                                           receptors would be eliminated with
                                           Institutional controls and monitoring.
There are no ARARs for radiological soil
cleanup. The NYSDEC TAOM which
Identifies the cleanup goal as a dose rate of
10 mllllrem/year Is a TBC.  This cleanup goal
would be met through partial source removal,
Installation of a fence, Installation of a cap.
and Institutional control, which would
mitigate the most significant direct exposure
pathway.

Not applicable.
                                           Soils would cease to be a source of
                                           contamination lo groundwater. Residual
                                           risks to human heallh and environmental
                                           receptors would be  eliminated with
                                           Institutional controls and monitoring.

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                                                                                                                           Table 8

                                                                                                      SUMMARY OF GROUNOWATER ALTERNATIVE ANALYSIS
                                                                                                                           (Pag»1oM)
 Assessment factors
                                    Alternative GW1
                                                                          Alternative GW2
                                                                                                                Alternative GVWA
                                                                                                                                                      Alternative GW4A
                                                                                                                                                                                           Alternative GW5A
                                                                                                                                                                                                                                 Alternative GW8
 Kay Components
                                    Single sampling event and review at
                                    Ihe end of Five years.
 Short-T,qrm

 Prelection of Community During
 Remedial Actions
 Protection of Workora During
 Remedial Actions
 Environmental Impacts
Time Until Remediation



Long-Tern) Effectiveness

Magnitude at Residual Risks




Adequacy of Controls
 No short-term risks lo community.
 Minimal risk lo worker* performing
 one-lime well sampling. Personnel
 protection equipment required during
 operations.
Continued migration of contaminants
In ground waler.
Approximately 140 yean. Alternative
relies on natural attenuation, which Is
unpredictable at this stage.
Human health risk from future use of
ground wtor remains.  Risks lo the
•nvlronmeot would not be reduced
even after na plume migrates.

No uxitfws.
                                       Monitoring Well Installation,
                                       Long• . . long lean risks.

Tree', innl system Is proven effective.
Monllc Ing will be necessary for 14
jeers.
                                       Ground waler extraction from Ihe
                                       pK-me followed by chemical
                                       predprlallon and UWOxIdallon.
                                       T.ealed water discharged lo onsKe
                                       ground waler recharge basin.
Minimal risk lo community from
Increased construction (raffle and
transportation of residuals.

Personal protection equipment
required egainsl direct contact and
Inhalation hazards.
Ground water table will be lowered
due to pumping. Discharge (o the
ground waler via .•echarge basin
reduces this effect.
Treatment plant operational within a
year.  Nine yeare of treatment and
five years of additional monitoring.
ATI of the contaminated aquifer would
be (ruled lo meel organic, chemical
specific ARARs. The land disposed
filter cake has some long term risks.

Treatment syslem Is proven effective.
Monitoring will be necessary for 14
years.
                                      Ground waler extraction from the
                                      plume followed by chemical
                                      precipitation and liquid phase carbon
                                      adsorption. Treated waler
                                      discharged 10 onsHe g: Mind water
                                      recharge basin.
Minimal risk lo community from
Increased construction traffic and
transportation of residuals.

Personal protection equipment
required against direct contact and
Inhalation hazards.
Ground water (able win be lowered
due lo pumping. Discharge lo the
ground waler via recharge basin
reduces this effect
Treatment plan! operational within •
year. Nine years of treatment and five
years ol additional monitoring.
ATI of Ihe contaminated aquifer would
be treated lo mwt organic, chemical
specific ARARs. The land disposed
(liter cake has some long (arm risks.

Treatment system Is proven effective.
Monitoring will be necessary for 14
years.
                                     Insitu treatment of ground water by
                                     air sparging/soil vapor extraction.
                                     Ground water extraction
                                     downgradlenl of Ihe plume, followed
                                     the addition of nulHenls end
                                     reinfection of Ihe groundwater
                                     upgradlenl of Ihe plume.
Minimal risk to community from
Increased construction traffic and
transportation of residuals.

Personal prelection equipment
required egainsl direct contact and
Inhalation hazards.
Ground water labte may be
heightened due lo Ihe Injection of air
lo Ihe aquifer and the vacuum
applied lo unsaluraled soils.
Discharge lo Ihe ground waler via
reinfection weds may Increase this
effect.  Ground waler extraction
downgradlent of Ihe plume will lower
Ihe ground waler table.

Treatment plant operational within a
year. Two years of treatment and
five yean of additional monitoring.
AD of Ihe conlam'naled aquifer would
be treated lo mee'. organic, chemical
specific ARARs.
fnsKu treatment Is relatively simple lo
control. Two vapor phase carbon
units operating In series win control
air emissions. Monitoring win be
necessary for 7 yean.

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                                                                                                                          Table 8

                                                                                                     SUMMARY OF GROUNDWATER ALTERNATIVE ANALYSIS
                                                                                                                          (Page 2 o(4)
 Assessment Factor*
                                   Alternative OW1
                                                                         Alternative GW2
                                                                                                               Alternative OW3A
                                                                                                                                                    Altemallve GW4A
                                                                                                                                                                                          ARemativeGWSA
                                                                                                                                                                                                                               Alternative GW6
 Reliability of Controls
 Reduction of Toxiclly. Mobililv or
 VOllHM

 Treatment Process and Remedy
 Amount of Hazardous Materials
 Treated or Destroyed
Irreversibllilyof Treatment
                                   No controls.
 Reduction In loxteHy by natural
 broremodiation.
 None by treatment; Natural
 attenuation would continue to reduce
 the loxWty of contaminated
 groundwaler but would probable
 Increase the volume.

 Not applicable.
Type and Oiianllly of Residual Waste  No waste generated by treatment;
                                  contamination remains on site.
molemenlabllity - Technical Feasibility
                                       Monitoring will tree* contaminant
                                       migration but not control it.
Reduction In tcxltily by natural
MoremedlaUon.
None by treatment: Natural
attenuation would continue to reduce
(he loitoty of contaminated
groundweler but would probable
Increase the volume.

No) applicable.
                                       No waste generated by treatment;
                                       contamination remains on site.
                                      Reliable. Standard maintenance
                                      required. Equipment Trie expectancy
                                      (s longer than the treatment duration.
Reduction In mobility by extraction.
reduction In loxlcily and volume by
treatment.

GroundwalerwID be treated at the
rale of 252.000 gallons per day.
Total aquifer volume treated will be
approximately 1.000 minion gallons.
                                      Ground water treatment hi
                                      Irreversible; due to assumed
                                      absence of residual soN
                                      oonli fniraUon.
                                      Treeled effluent wM meet discharge
                                      requirements. Inorgank; sludge will
                                      be generated al 0.04 TPD. Air
                                      stripping option will generate spenl
                                      vapor phase carbon al 25 Ibs/day
                                      and liquid phase carbon at 4 Ibs/day.
                                      Reliable. Standard maintenance
                                      required. Equipment life expectancy
                                      rs longer than the treatment duration.
Reduction In mobility by extraction.
reduction In loxlclty and volume by
treatment.

Groundwater win be treated al the
rale of 252.000 gallons per day.
Total aquifer volume treated will bo
approximately 1.000 million gallons.
                                      Ground water treatment If
                                      Irreversible; due lo assumed
                                      ebsence of residual soil
                                      contamination.
                                      Treated effluent wM meet discharge
                                      requirements. Inorganic sludge win
                                      be generated at 0.04 TPD.
                                                                                                                                                                                          Reliable. Standard maintenance
                                                                                                                                                                                          required. Equipment life expectancy
                                                                                                                                                                                          Is longer than the treatment duration.
Reduction hi moMMy by extraction,
reduction In loxldly and volume by
treatment.

Groundwater wilt be treated at the
rale of 252.000 galons per day.
Total aquifer volume (reeled will be
approximately 1.000 minion gallons.
                                      Ground water treatment Is
                                      Irreversible; due lo assumed
                                      absence of residual soil
                                      contamination.
                                      Treated affluent wil meet discharge
                                      requirements. Inorganic sludge win
                                      be generated al 0.04 TPD.
                                                                           Reliable. Standard maintenance
                                                                           required. Redevelopment of
                                                                           reinfection wells win be required.
                                                                           Equipment life expectancy Is longer
                                                                           than the treatment duration.
Reduction In toxidly and volume by
InsHu treatment. Reduction In plume
migration by extraction.

Approximately 300 pounds of
contaminant In the aquifer win be
votaliliied al an estimated rate of
0.80 pounds per day.
                                     Ground water treatment Is
                                     Irreversible; due lo assumed
                                     ebsenoa of residual soil
                                     contamination.
                                     Spent vapor phase carbon win be
                                     generated from the vestment of soil
                                     vapors al a rale of 100 pounds per
                                     day.
\bilityloConsmjct and Operate       Not applicable.
'echnology
(eliabililyof Technology
Not applicable.
                                       Monitoring Is reliable h evaluating
                                       the exlanl of contamination.
                                                                        Monitoring Is reliable In evaluating
                                                                        the extent of contamination.
                                      Standard commercial technologies.
                                      Several process components require
                                      well (rained operators.
                                                                            Well developed and proven
                                                                            technologies.
                                     Standard commercial technologies.
                                     Several process components require
                                     well trained operators. UV oxidation
                                     win need additional training of
                                     operators.

                                     Well developed and proven
                                     technologies.  Avealabllilyleslmay
                                     be needed for UV oxidation.
                                      Standard commercial technologies.
                                      Will be easy lo operate.
                                                                                                                 Well developed and proven
                                                                                                                 technologies.
                                     This technology Is easy lo construe!
                                     and operate.
                                                                           Air sparging Is an Innovative
                                                                           technology. Anohsltepllolieslwin
                                                                           be required lo determine design
                                                                           parameters.

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                                                                                                                           Table 8

                                                                                                     SUMMARY OF GROUNDWATER ALTERNATIVE ANALYSIS
                                                                                                                          (Pag* 3 o(4)
Assessment Factors
                                   Alternative GW1
                                                                         Alternative GW2
                                                                                                                Alternative GW3A
                                                                                                                                                     Alternative GW4A
                                                                                                                                                                                           Alternative GW5A
                                                                                                                                                                                                                                Alternative GW8
Ease of Undertaking Additional
Remedial Action II Necessary
Monitoring Consideration*
                                   Easy to undertake.
                                                                         Easy to undertake.
Single review at the end ol 5 years        5-year review and long-term
required.                              monitoring required.
Administrative Feasibility

Coordination wan Other Agendas     Coordination among Federal. Stale
                                   and local authorities required lor 5
                                •   year review.
Ability to obtain approvals            Permits not required.
Availability ol Services and Materials

Availability ol Treatment Capacity and  Not applicable.
Disposal Services
Availability ol Necessary Equipment    equipment and manpower for
                                   readily available.
and Specialists


Cult

Total Capital Cosl
Annual Operation and Maintenance   152.100
Cosl
                                                                         Coordination among Federal, State
                                                                         and local authorities required m (he
                                                                         review ol monitoring data and
                                                                         delssemlnaUon ol Information.

                                                                         Permits not required.
                                                                         Not applicable.
                                                                         Equipment and manpower for
                                   one-time sampling and analyses Is        monitoring, sampling and analyses Is
Net Prawnt Worth (5*)
                                  140.900
                                                                         readily available.



                                                                         $59.500

                                                                         $39.500


                                                                        $667.000
                                                                                                               Can easily ecoomodal* additional
                                                                                                               ground water; but should not be
                                                                                                               necessary.
                                                                                                               Monitoring of ground water.
                                                                                                               discharged water, dr emissions.
                                                                                                               frequency of vapor phase carbon
                                                                                                               changeoul and slm^e required
                                                                                                               during the operations.
                                                                                                               Coordination among Federal. Slate
                                                                                                               and local authorities required.
                                                                                                               Will need substantive compliant*
                                                                                                               with  ground water discharge permit
                                                                                                               and air emissions permit.
                                                                                                               Off-site disposal lacSUes for sludge
                                                                                                               are available. Off-slje carbon
                                                                                                               regeneration ladliUej are available
                                                                                                               for spent carbon.

                                                                                                               Equipment and manpower Is readily
                                                                                                               available.
                                                                                                               $2.074,474

                                                                                                               $541.950"



                                                                                                               $6.070,000
 Can easily accomodale additional
 ground water; but should not be
 necessary.
                                                                                                                                                     Monitoring of ground water,
                                                                                                                                                     discharged water, and sludge
                                                                                                                                                     required during the operations.
 Coordination among Federal, Stale
 and local authorities required.
                                                                                                                                                     Will need substantive compliance
                                                                                                                                                     with ground water discharge permit.
                                                                                                                                                     Otl-jKe disposal faculties for sludge
                                                                                                                                                     are available. UVKMdauon does not
                                                                                                                                                     produce any spent carbon.
Equipment and manpower Is readily
available. UVrthMallon win need
•ddKionany trained operators.
$2.264.470

$599,450"


$6,670,000
                                                                                                                                                        Can easily accomodate additional
                                                                                                                                                        ground water but should not be
                                                                                                                                                        necessary.
                                      Monitoring of ground water,
                                      discharged water, air emissions, end
                                      sludge required during the
                                      operations.
                                                                                                                                                        Coordination among Federal. Stale
                                                                                                                                                        and local authorities required.
                                      Win ne«d substantive compliance
                                      with groundwater discharge permit.
                                                                                                                                                        Off-site disposal lacffiUes for sludge
                                                                                                                                                        are available. Off-site carbon
                                                                                                                                                        regeneration farifflles are available
                                                                                                                                                        for spent carbon.

                                                                                                                                                        Equipment end manpower Is readily
                                                                                                                                                        available.
                                                                                                                                                       $2,028.200

                                                                                                                                                       $557.950"


                                                                                                                                                       $6.140.000
                                                                                                                                                                                                                                Installation of additional air sparging
                                                                                                                                                                                                                                and vapor extraction wells win be
                                                                                                                                                                                                                                required to remediate other areas of
                                                                                                                                                                                                                                contamination. Additional piping
                                                                                                                                                                                                                                from the wells to the treatment
                                                                                                                                                                                                                                system will be required.

                                                                                                                                                                                                                                Monitoring ol ground water win be
                                                                                                                                                                                                                                required during the operations.
                                                                                                                                                                                                                               Coordination among Federal. Slate
                                                                                                                                                                                                                               and local authorities required.
                                                                                                                                                                                             Wineed substantive compliance (or
                                                                                                                                                                                             ground water discharge and air
                                                                                                                                                                                             emissions pormlt.
                                                                           Off-sle carbon regeneration lacililles
                                                                           are available (or spent carbon.
                                                                                                                                                                                                                               Equipment and manpower Is
                                                                                                                                                                                                                               avaiabfe.
                                                                                                                                                                                                                               $1,671.147

                                                                                                                                                                                                                               $630,671"'  '



                                                                                                                                                                                                                               $3.110.000
" Annual CAM during 9 years of operation. Annual O*M during additional 8 years of monitoring Is $42.160.
— Annual (MM during 2 years ol operation. Annual (MM during additional 5 yean ol monitoring Is $54.637.

-------
                                                                                                                     Table 8

                                                                                                 SUMMARY OF GROUNDWATER ALTERNATIVE ANALYSIS
                                                                                                                     (Pig* 4 of 4)
Assessment Factors
                                 AltomaUv* GW1
                                                                      Alternative GW2
                                                                                                          Alternative GW3A
                                                                                                                                               Alternative GW4A
                                                                                                                                                                                   Alternative OWSA
                                                                                                                                                                                                                       Alternative GW6
Compliance with ARARl

Compliance with                   Oo*s not meet contamlnanl-spscrTIc
Conlaminan|.Sp*cif)c. Actlon-Sp*c«c, and location-specific ARARs and
and Location-Specific ARARs and    TBC>.
TBCj
Approprtaleness of Waivers
                                 Not applicable.
Overall Protection of Human Haallh   Ground water quality la not expected
and lha Environment                lo change over e long, period o( time.
                                 This aflamattv* b ln*ff*dlv* In
                                 reducing "« potential risks posad lo
                                 human health and th* anvlronrnanl.
Oo*s not m»«l conlimlnanl-spodflc
and locallon-ipcdlle ARARs and
TBCl Monltortnj will comply with
acUon.sp«dfIcARA95.

NotappHcaWr
Ground wal*r quality It nol 
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                      TABLE 9
COMPARATIVE COSTS FOR SOIL AND GROUNDWATER ALTERNATIVES
tive















Alternative
No Further Action
Limited Action
No Excavation - Soil Vapor
Extraction
Total Excavation - On-Site
Treatment (S-4A) or Off-Site
Disposal of Excavated Soils (S-4D)
Partial Excavation (S-SA)/Soil
Vapor Extraction (S-5D)
No Further Action
Limited Action
Total Excavation - On-Site Storage
(R-3A)/Off-Site Disposal of
Excavated Soils (R-3B)
Partial Excavation - On-Site Storage
(R-4A)/Off-Site Disposal Excavated
Soils and Capping (R-4B)
No Further Action
Limited Action
Chemical precipitation, air stripping
and polishing with activated carbon-
infiltration through recharge basins.
Chemical precipitation and chemical
oxidation enhanced with UV
photolysis - infiltration through
recharge basins
Chemical precipitation and carbon
adsorption - Infiltration through
recharge basins.
Air sparging, soil vapor extraction
and enhanced biodegradation.
Capital Cost ($)
SO
$0
$373,700
$2,574,500 S-4A
$4,864,600 S-4D
$1, 798,600 S-5A
$39,215
$76,300
$3,205,630 R-3A
$33,632,850 R-3B
$2,737,900 R-4A
$18,2 10,370 R-4B
$0
$59,500
$2,074,500
$2,264,470
$2,028,200
$886,000
Annual O&M
Cost ($)
$46,400
$33,200
$141,900
$0 (A &D)
$70,000(A&D)
$49,500
$37,950
$33,600
$37,354
$52,100
$39,500
$541,950
$599,450
$558,000
$427,000
Net Present Worth
@ 5% Rate
$36.400
$511,000
$638,000
$2,570,000 S-4A
$4,860,000 S-4D
$1, 930,000 S-5A
$2,890,000 S-5D
$78,000
$769,000
$3,820,000 R-3A
$34,200,000 R-3B
$3,420,000 R-3A
$1 8,900,000 R-3B
$40,900
$667,000
$6,070,000
$6,670,000
$6,140,000
$1,062,000
(Chemical), *R = Soil (Radiological), *GW = Groundwater

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            Figure 1
Brookhaven National Laboratory
Current Land Use
                                                                   LEGEND
                                                                  Open Space
                                                                  Industrial/Commercial
                                                               j   Agricultural
                                                               |   Residential
                                                               I   Recreational
MID -10/17/95
                    /hame4/oerair.l/«ielu

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OFFICE OF ENVIRONMENTAL RESTORATION
  BROOKHAVEN  NATIONAL LABORATORY
                          Figure 2

                OPERABLE   UNITS



                          LEGEND
                         Waste Management Areas,
                         Landfills, and Upland Recharge
                     :|    Alternating Gradient Synchrotron
                         Scrapyard and Aerial Survey
                         Cesspools, Storage Tanks,
                         Dry Wells (may Be multiples)
                         Potable and Supply Wells
                         and Spills
                         Central Steam Facility
                         Sewage Treatment Plant
  SCALE
   meters
0   300  600
I-J : '':-'..^.'.. i
0   1000 2000
    feet
                                     Mill- III/12M

-------
  /Fuel
Unloading  -^ i

            AOC 5
                         Pit
                                                                                               : AQC 24D

                                                                                                    Recharge
                                                                                                    Basin, HO   .
                                                                                                 A
                                                                      Sump      \ \',

                                                                     Outfall        \)
                                                                                                         OUIV
                                                                                                     V-
                                                                                                               BNI SilB
                                                                        :'-t-:—••. Leaking Sewer Line
                                                                         '	^
                                   .1977011       ...'   .''.'!
                                  //Snlvent    /;(;  >..    BWB528

                                  ' '  Spill  ;  /J ,'\      .  '.';
                                            /  /'    Former UST
                                             '''
                                                                                        Figure 3
                                                                                  Operable Unit IV
                                                                           Areas of Concern (AOCs)
III
8f°°
-------
OutiaUOrainage .,.,,7-

    Pipe
,  /  *  .     Bldg 526
                                                            Recharge
                                                            'Basin HO

                                                             '
                               Sump

                              Outfall
                                         vLeakingSewer Line
                   Bldg 528


      /  A  v Former UST
                                                 Fiuure 4
                                            Operable Unit IV
                                        Area! Extent of Soils

                                    Contaminated With VOCs
                                                                SCAIF
                         ;1
                                      VOC Contaminated Soils


                                      OU IV Boundary
                                                                     150

-------
                                                                        . Recharge
                                                                         'Basin. HQ    ,.-.   :
                                    Sump' '
                                    Outfaif
                                                                                       RNI. Site
.   ' •'"'.• / ~:-~ • -  -
                                            -'.-.-~ vLeakins Sewer Line
         '  ' '!^-•;:;.-.
              ,. / / J1**-,- -••
              v  /  •••'   :-
1977 Oil      /\/..
.'Solvent      / !\
'  spiii     r /•      :;'*J
           ,   /"    Former UST

         /   '     '•'.. ~'-:--t •• »'-'-, •
             Bldg526
                •'/'
                ' Jr
               / /
            Bldg527
                                                           Figure 5
                                                       Operable Unit IV
                                                 Extent of Radiologically
                                                    Contaminated Soils
                                                     Rad Contaminated Soils

                                                     Original Fencing

                                                     New Fencing

                                                     OU IV Boundary
    SCAIF

0   mmen  50
        '
     feet
         I5°

-------
                    Central
                    Steam >
."""•"' -^'p?*?^--'" '  <-    Facility     //,'
:^-.-J-. ••.:--.,         (Bldg610)  i '•
  ,Fuel
Unloading  -•
 .••Areas
                 spin  ;.--.-/r/.- \
                      !--IJll-   Former UST
                                                                              Recharge
                                                                              Basin HC>
                                                 Sump

                                                Outfall
                                                                                                            BNl Site
                                     Bldg 528
                                                        r~": Leaking Sewer Line
                                                                    I Dr.
                                                                   Figure 6
                                                  Maximum Areal Extent of Soil and
                                                Groundwater Remediation for VOCs
                                                           Under Operable Unit IV
                                                      Groundwater


                                                      Soil

                                                      OU IV Boundary
                                                                                  SCAIF
                                                                                                      le«t

-------
         T
APPROXIMATE EXTENT OF
PLUUE AS DEFINED IN
W REPORT	
 Note: Approximate locations of Wells for Estimate Only.

 O    Air Sparging (AS) Well SO' Radius of Influence
(A)    Soil Vapor Extraction (SVE) Well I001 Radium of
       Influence.

       Extraction and Reinjection Wells will
       not be Installed, Unless Required as
       an  Engineering Enhancement to the
       AS/SVE System.


       Final Location and Number of Wells
       will be Specified in the Remedial
       Design.

        LEGEND

   •-•-•    row of
   ••"'••>    TRtt UMT,
   	OUT MMD
    .6     rnz
    Q     fST UNUMDMG MCA
           onuieto sewn
           UMMU
           CATCH BtSM
  —^  UNDOKROUNO PVMG
  	AaovEcxouNO PIPMJ
    u     REMOVCD STRUCTURE
    0     OaSTWB S1RUCTURC
  —^—  araiMU UMT H BOUKOWT
     •     ixsnm sumr nu.
 m-tt B     OCTMC UOMTORMG WO1
    B     omucnaH mu (TOTAL 4)
    B     RDMCCnm «U. (TOTM. »
 —	  STORM snrat caNsnucTto or vmoaus nz Ptt
 ..	  STOSK StWOI CONSTRUCTED Of P.V.C OR IMXNOKN
 	SAMTAUr SCTCT OJKSIKU.ILU Cf VITROUS TU Pfl
 — -  —  SAMTAirr stwai CONSTRUCTCD or P.V.C. OR UNKMOW
                                                                                                                                                  W-1MO
                                                                                                                                                     caa
                                                                                                                                                                              SCALE: I*  . JOO1
                                                                                    Brookhaven National Laboratory
                                                                                          Operable Unit IV

                                                                                 Approximate Locations of Air Sparging
                                                                                    and Soil Vapor Extraction Wells
                                   Figure 7

-------