September 11,
2003
Prepared by:
Brookhaven National Laboratory
Brookhaven Science Associates
Under Contract No. DE-AC0-2-98CH01886 with the
United States Department of Energy
Prepared for:
U.S. Department of Energy
Brookhaven Area Office
Upton, New York 11973
Executive Summary
I. Purpose
II. Site Conditions and Background
A. Site Description
B. Actions to Date
C. National Priorities List Status
III. Threats to Public Health or Welfare and the Environment,
Statutory and Regulatory Authorities
A. Threats to Public Health or Welfare and
the Environment
IV. Identification of Removal Action Objectives
V. Identification and Analysis of Removal Action Alternatives
A. Analysis of Removal Action Alternatives
VI. Comparative Analysis of Removal Action Alternatives
A. Overall Protection of Human Health and
the Environment
B. Compliance with ARARs
C. Long-Term Effectiveness and Permanence
D. Reduction of Toxicity, Mobility, or
Volume through Treatment
E. Short-Term Effectiveness
F. Implementability
G. Cost
H. State Acceptance
I. Community Acceptance
VII. Removal Action Recommendation
A. Proposed Action
B. Contribution to the Remedial Performance
C. Description of Alternative Technologies
D. Project Schedule
VIII. Expected Change in the Situation Should Action Be Delayed or Not Taken
IX. Public Participation
X. Outstanding Policy Issues
XI. Enforcement
XII. Recommendation
List of Figures
Location of the Sediment Targeted for Removal in
the Peconic River
List of Tables
Average Concentrations After Remediation
Cost Comparison
Executive Summary
Brookhaven National Laboratory
(BNL) is a Department of Energy (DOE) facility that was placed on the New York
State Department of Environmental Conservation (NYSDEC) “Inactive Hazardous
Waste Disposal Sites” list in 1980. Subsequently, in 1989, the
Laboratory was included on the U.S. Environmental Protection Agency (EPA)
National Priorities List for cleanup. The Laboratory ranked high on the
EPA rating system and was placed on this list because of the environmental
effects of past practices, some of which could pose a threat to Long Island’s
sole-source aquifer in the vicinity of BNL. The cleanup of BNL is funded
by the DOE and overseen by the DOE, U.S. EPA, and NYSDEC.
The Peconic River is part of
Operable Unit V and has been identified as Area of Concern 30 (AOC 30) in the
Interagency Agreement between the EPA Region II, the DOE, and NYSDEC. This
is a Federal Facility Agreement under the Comprehensive Environmental Response
Compensation, and Liability Act of 1980 (CERCLA) Section 120, Administrative
Docket Number II-CERCLA-FFA-00201.
Contaminants in the sediment of
the Peconic River on the Laboratory property may migrate off of the Laboratory
property, and a non-time-critical removal action is warranted. To help
determine the most appropriate action, the DOE has prepared this Engineering
Evaluation/Cost Analysis (EE/CA) – Action Memorandum. The scope of the
evaluation includes the sediment in the Peconic River on the Laboratory
property. Sediment in portions of the river off of Laboratory property
will be addressed in a separate document.
Wastewater from
Laboratory operations is processed and treated at the BNL Sewage Treatment Plant
(STP). Treated, monitored water is discharged into the Peconic River.
However, past operations and practices resulted in wastewater containing
chemical and radiological contaminants being discharged into the Peconic River;
contaminants were deposited into the sediment. Elevated levels of
metals, and low levels of PCBs, pesticides and radionuclides were detected in
Peconic River sediment. Concentrations were highest in on-site surface sediment
and most prominent in the depositional areas on the Laboratory property located
approximately 0.5 mile, 1 mile, and 1.5 miles downstream of the STP.
This EE/CA –
Action Memorandum has been prepared to document the engineering and cost
analysis of various alternatives and to implement the recommended alternative.
The EE/CA – Action Memorandum scope and contents include a description of the
regulatory framework, basis for the clean up, description of the area under
evaluation, and the identification, analysis and comparison of various removal
action alternatives. The four removal alternatives for the Peconic River
sediment on the BNL property, which are evaluated in this EE/CA – Action
Memorandum, are summarized as follows:
Alternative 1, No Action, is
required by CERCLA and provides the baseline to compare the other alternatives.
Long term monitoring of the surface water, fish, and sediment would be included
in this alternative.
Alternative 2, Removal of all
Sediment from the STP to the Property Line. The cleanup would remove
approximately 95% of mercury and PCBs in surface sediment; co-located
contaminants would also be removed. This alternative would require
complete excavation from BNL STP to the BNL boundary. The alternative
includes long-term monitoring of surface water, fish, and sediment to ensure
effectiveness.
Alternative 3, Removal of all
Sediment with Mercury Concentrations Greater than 9.8 ppm. The cleanup would
remove approximately 85% of mercury and 75% of PCBs in surface sediment;
co-located contaminants would also be removed. This alternative includes
long-term monitoring of surface water, fish, and sediment to ensure
effectiveness.
Alternative 4, Removal of
Targeted Depositional Areas. Flow patterns in the Peconic River on the BNL
property have resulted in deposition of most of the contaminants in specific
areas. The cleanup would remove contaminated sediments in depositional areas
identified as Areas A, B, C, and D (see Figure 1 in the document) to achieve an
average concentration of 1 part per million (ppm) mercury through the portion of
the Peconic River on DOE property, with a goal of no sample in any excavated
area exceeding 2 ppm mercury. The cleanup would remove 95% of mercury and 88% of
PCBs in surface sediment; co-located contaminants would also be removed.
This alternative includes long-term monitoring of surface water, fish, and
sediment to ensure effectiveness.
The EE/CA process involves the
evaluation of the characterization data, presents alternatives to address the
contamination, and recommends a preferred alternative. Therefore, the four
alternatives were evaluated against the CERCLA criteria: effectiveness,
implementability, and cost. Based on this evaluation, Alternative 4 is the
recommended alternative.
The recommended alternative,
Alternative 4 involves the removal of the unconsolidated sediment layer (which
is approximately six to 12 inches in depth) from the depositional areas (A, B,
C, and D) with a cleanup goal of 1 ppm average mercury concentration overall in
the portion of the Peconic River on Laboratory property. Contamination
will be removed from the depositional areas with a goal that all post-clean up
confirmation samples from the excavated areas contain mercury concentrations
less than 2 ppm. The major features of this action include stream
dewatering, the excavation and removal of the sediment layer, dewatering of
removed sediment, disposal of sediment at a licensed off-site landfill facility,
wetland restoration as needed and installation of access to the depositional
areas. Construction and long-term monitoring will be conducted to verify
protectiveness. Details will be determined during the preparation of
project work plans. Post-excavation sampling will be performed to
demonstrate the achievement of cleanup goals. Documents supporting this
action are located in the Administrative Record for Brookhaven National
Laboratory.
DOE worked closely with U.S.
EPA, NYSDEC and the Suffolk County Department of Health in developing the
cleanup proposal. The proposed alternative will contribute to overall
protection of public health and the environment of the Peconic River by removing
a significant amount of contaminated sediment. Removal of these contaminated
sediments will limit migration of contaminants off of the Laboratory property
and is expected to contribute to reductions of mercury and PCBs in fish tissue.
This removal action will not be the final cleanup of the Peconic River. A
future Record of Decision will document the final remedy selected. This
action will be consistent with the final remedy.
Acronyms, Abbreviations, and
Units of Measure
AOC | Area of Concern |
ARAR | Applicable or Relevant and Appropriate Requirement |
BER | Brookhaven Executive Roundtable |
BNL | Brookhaven National Laboratory |
CAC | Community Advisory Council |
CERCLA | Comprehensive Environmental Response, Compensation, and Liability Act of 1980 |
CFR | Code of Federal Regulations |
DOE | U.S. Department of Energy |
EE/CA | Engineering Evaluation/Cost Analysis |
EPA | U.S. Environmental Protection Agency |
NYSDEC | New York State Department of Environmental Conservation |
NYSDOH | New York State Department of Health |
PCB | polychlorinated biphenyl |
ppm | parts per million |
RI | Remedial Investigation |
STP | Sewage Treatment Plant |
SCDHS | Suffolk County Department of Health Services |
TBC | To Be Considered |
I. Purpose
The purpose of this Engineering Evaluation/Cost Analysis (EE/CA) – Action Memorandum is to document the decision to remove sediment from the Peconic River on the Brookhaven National Laboratory (BNL) property. The DOE has determined that contaminants in the sediment of the Peconic River on the Laboratory property may migrate off of the Laboratory property, and that a non-time-critical removal action is warranted. To help determine the most appropriate action, the DOE has prepared this Engineering Evaluation/Cost Analysis (EE/CA) – Action Memorandum. The scope of the evaluation includes the sediment in the Peconic River on the Laboratory property. Sediment in portions of the river off of Laboratory property will be addressed in a separate document.
II. Site Conditions and Background
A.
Site Description
1.
Physical Location
BNL
is owned by the DOE and is located in the Town of Brookhaven in Suffolk County,
New York. The Laboratory carries out basic and applied research in the
fields of high-energy nuclear and solid-state physics, fundamental material and
structure properties and the interaction of matter, nuclear medicine, biomedical
and environmental sciences, and selected energy technologies.
BNL
contains 5,265 acres of which 75 percent is wooded. The remainder is
developed and includes office buildings, research facilities, residential areas,
and parking lots. BNL is located near the western boundary of the
Manorville drainage basin. The principal drainage feature of the
Manorville drainage basin is the Peconic River, which is a coastal plain stream.
BNL forms part of the upper drainage area or headwaters of the Peconic River.
The surface drainage is poor in the Manorville drainage basin, and accounts for
much of the land near the river being swampy. East of the Manorville
drainage basin, the Peconic River valley widens and forms the Riverhead basin.
The Peconic River drains in an easterly direction and then flows into Flanders
Bay, an arm of the Great Peconic Bay. The western branch of the Peconic
River enters BNL in the northwest section. The Sewage Treatment Plant
(STP) outfall marks the start of constant flow and the river exits the property
to the southeast near North Street. (The northern branch joins the river
off-site, approximately 0.5 miles upstream of Schultz Road).
2.
Removal Site Evaluation
Past
operations and practices at BNL resulted in the discharge of wastewater
containing chemical and radiological contaminants to the STP, and then to the
Peconic River causing contamination of sediments and fish in the river.
On
Laboratory property, the Peconic River contains four major depositional wetland
areas: Area A, Area B, Area C, and portions of Area D (Figure 1). Elevated
levels of metals, and low levels of polychlorinated biphenyls (PCBs) and
radionuclides are present in Peconic River sediment in these areas.
Figure 1.
Location of the Sediment Targeted for Removal in the Peconic River
The contaminant of greatest concern is mercury, with a maximum concentration in sediment of 39.7 parts per million (ppm), and the PCB aroclor-1254, with a maximum concentration in sediment of 1.5 ppm, since these contaminants have been shown to bioaccumulate in fish. Radiological contaminants are below levels requiring cleanup, but are largely co-located with the other contaminants and will be removed with the other contaminants. Contamination is highest in surface sediment and is most prominent in the depositional areas.
B. Actions to Date
1.
Previous Actions
BNL has taken numerous actions to reduce the discharge of contaminants. Numerous upgrades to the BNL STP have been performed and a proactive Pollution Prevention/Waste Minimization program has been implemented to reduce the generation of wastes at the source and the discharge of contaminants. The quality and contaminant levels in the Peconic River surface water, sediment, and fish have been characterized as part of BNL’s cleanup and environmental monitoring programs. Pilot studies were conducted in March 2002 to demonstrate the effectiveness of two cleanup technologies. A high capacity vacuum/guzzler was tested in Area A and Sediment Removal/Wetland Restoration was demonstrated in Area D. Extensive screening of other more innovative technologies, such as electrochemical and phytoremediation, were also conducted. Information about these technologies and the pilot projects may be found at http://www.bnl.gov/erd/peconic.html.
2. Current Actions
Continued surface water, sediment, and fish monitoring is part of BNL’s routine environmental management programs.
3.
Planned Actions
A Proposed Remedial Action Plan, which proposes the final remedy for the Peconic River, is being prepared for public review and comment. The final Peconic River remedy, once selected, will be documented in a Record of Decision and implemented. This removal action will be a component of the final remedy. Surface water, fish, and sediment monitoring will continue as part of BNL’s environmental programs.
C.
National Priorities List Status
Brookhaven National Laboratory was added to the National Priorities List in 1989.
III. Threats to Public Health or Welfare and the Environment, Statutory and Regulatory Authorities
A.
Threats to Public Heath or Welfare and the Environment
This action is being undertaken as a voluntary removal action under an Interagency Agreement between the DOE, U.S. Environmental Protection Agency (EPA), and New York State Department of Environmental Conservation (NYSDEC). This action will address regulatory agency concerns, including those of the New York State Department of Health (NYSDOH) and Suffolk County Department of Health Services (SCDHS), about contamination in Peconic River sediment and bioaccumulation of mercury and PCBs in fish. The appropriateness of the removal action is based on the following factors listed in 40 Code of Federal Regulations (CFR) 300.415 (b) (2) of the regulations implementing the National Contingency Plan.
- Other
situations or factors that may pose threats to public health or welfare of the
United States or the environment.
- Actual or potential contamination of drinking water supplies or sensitive ecosystems.
IV. Identification of Removal Action Objectives
Removal action objectives for
the sediment of the Peconic River on the Laboratory property are based on the
available contaminant data. In general, the scope of the removal action is to
reduce the potential of further contaminant migration in the Peconic River off
of the Laboratory property.
Based on
the results of the Remedial Investigations, the following Removal Action
Objectives have been identified for sediment:
- Reduce site-related contaminants (e.g., mercury) in fish to levels protective of
human health.
- Reduce or mitigate, to the extent practicable, existing and potential adverse
ecological effects of contaminants in the Peconic River.
- Prevent, or reduce to the extent practicable, the migration of contaminants off
the BNL facility.
V. Identification and Analysis of Removal Action Alternatives
The overall objective of BNL is
the safe, timely, and cost-effective cleanup of the Peconic River. The Area of
Concern (AOC) 30 removal alternatives described and evaluated by this EE/CA –
Action Memorandum were developed with consideration and input from the DOE, U.S.
EPA, New York State, Suffolk County, and community members. Community
feedback solicited at routine meetings of the BNL Community Advisory Council (CAC)
and the Peconic River Working Group has been considered in developing this EE/CA
– Action Memorandum. This EE/CA – Action Memorandum also reflects regulatory
and community input on parallel issues and decisions that have been provided in
connection with other BNL environmental restoration projects. It is also
reflective of the community values obtained during roundtable sessions conducted
for the Peconic River.
Four
AOC 30 alternatives have been identified, which span the entire range from No
Action through complete excavation of the onsite portion of the Peconic River.
The No-Action Alternative is used as the baseline against which the other
alternatives are evaluated and is required to be considered under the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).
The sections below describe each of these alternatives.
- Alternative 1, No Action
- Alternative 2, Removal of all sediment from the STP to the Property Line
- Alternative 3, Removal of all sediment with mercury concentrations greater than 9.8 ppm
- Alternative 4, Removal of Targeted Depositional Areas
A. Analysis of Removal Action Alternatives
Alternative 1, No Action
Alternative 1 is
the “no action” alternative and will not include the implementation of any
remedial action. Monitoring of surface water and sediment would be
conducted for a minimum of five years to establish that contaminant deposition
is not recurring and that contamination is not migrating downstream.
Annually, surface water and sediment samples would be collected and analyzed for
the constituents of concern (mercury, PCBs, and cesium-137). It is assumed
that samples would be collected at approximately 500-foot intervals over the
length of the Peconic River from the STP discharge point to the end of the
Laboratory property.
This alternative
was not recommended because it leaves a continuing source for bioaccumulation of
mercury and PCBs in fish and transport downstream. The no action
alternative is used as the baseline against which the other alternatives are
evaluated, and it is required to be considered under CERCLA.
Alternative 2, Removal of all
Sediment greater than 1.06 ppm from the STP to the Property Line
Alternative 2
would remove greater than approximately 95% of mercury and PCBs in surface
sediment and would require complete excavation from BNL Sewage Treatment Plant
to the end of BNL property; the co-located contaminants would also be removed.
The alternative includes long-term monitoring of surface water, sediment, and
fish. Alternative 2 includes the following:
1. The removal of all sediment greater than 1.06 ppm mercury will require the
complete removal of the unconsolidated sediment layer (approximately six to 12
inches) down to sand from the Peconic River. Conventional earth moving
equipment would be utilized, supplemented as appropriate by the use of vacuum
guzzling technologies.
2. Stream dewatering as necessary would be performed.
3. Dewatering of sediment prior to packaging and transportation to a licensed
disposal facility.
4. Sediment control to prevent downstream migration during removal.
5. 7,200 linear feet of haul roads would be constructed as appropriate to access
those areas requiring remediation.
6. Post-excavation sampling of the riverbed will be conducted to confirm the
cleanup objective has been met.
7. Wetland and upland restoration, as needed, will be performed following sediment
removal.
8. 14,444 cubic yards of sediment would be removed and disposed of at a cost of
$9.6 million.
Alternative 3,
Removal of all Sediment with Mercury Concentrations Greater than 9.8 ppm
Alternative 3
would remove approximately 85% of mercury and 75% of PCBs in surface sediment;
co-located contaminants would also be removed. The alternative includes
long-term monitoring of surface water, sediment, and fish. Alternative 3
includes the following:
1. The removal of the unconsolidated sediment layer (approximately six to 12
inches) down to sand from the Peconic River in areas known to contain mercury at
concentrations that exceed the removal trigger. Conventional earth moving
equipment would be utilized, supplemented as appropriate by the use of vacuum
guzzling technologies.
2. Stream dewatering as necessary would be performed.
3. Dewatering of sediment prior to packaging and transportation to a licensed
disposal facility.
4. Sediment control to prevent downstream migration during removal
5. 4,200 linear feet of haul roads would be constructed as appropriate to access
those areas requiring remediation.
6. Post-excavation sampling of the riverbed will be conducted to confirm the
cleanup objective has been met.
7. Wetland and upland restoration, as needed, will be performed following sediment
removal.
8. 7,979 cubic yards of sediment would be removed at a cost of $5.6 million.
Alternative
4. Removal of Targeted Depositional Areas
Alternative 4
would remove contaminated sediments in Areas A, B, C, and D to achieve an
average concentration of 1 part per million (ppm) mercury through the portion of
the Peconic River on the DOE property, with a goal of no sample in any excavated
area exceeding 2 ppm mercury. The cleanup would remove 95% of mercury and 88% of
PCBs in surface sediment. The co-located contaminants would also be removed.
The alternative includes long-term monitoring of surface water, sediment, and
fish. Alternative 4 includes the following:
1. The removal of the unconsolidated sediment layer (approximately six to 12
inches) down to sand from the Peconic River in the targeted depositional areas
containing the highest contamination. Conventional earth moving equipment
would be utilized supplemented as appropriate by the use of vacuum guzzling
technologies.
2. Stream dewatering as necessary would be performed.
3. Dewatering of sediment prior to packaging and transportation to a licensed
disposal facility.
4. Sediment control to prevent downstream migration during removal.
5. 4,200 linear feet of haul roads would be constructed as appropriate to access
those areas requiring remediation.
6. Post-excavation sampling of the riverbed will be conducted to confirm the
cleanup objective has been met.
7. Wetland and upland restoration, as needed, will be performed following sediment
removal.
8. 12,080 cubic yards of sediment would be removed at a cost of $7.8 million.
VI. Comparative Analysis of Removal Action Alternatives
This section
evaluates the removal action alternatives against the nine CERCLA criteria: (A)
overall protection of human health and the environment, (B) compliance with
applicable or relevant and appropriate requirements, (C) long-term effectiveness
and permanence, (D) reduction of toxicity, mobility, or volume through
treatment, (E) short-term effectiveness, (F) implementability, (G) cost, (H)
state, and (I) community acceptance.
A. Overall Protection of Human Health and the Environment
Alternative 1 requires no
disruption of the wetlands, forested areas, or biota; however, the contaminants
present will remain and continue to be a source for bioaccumulation in fish
presenting a potential health hazard to people or wildlife eating locally caught
fish in the Peconic River and will continue to impact ecological receptors.
Contaminants will remain that may be subject to transport to other areas.
Table 1. Average
Concentrations After Remediation
|
Alternative
One |
Alternative
Two |
Alternative
Three |
Alternative
Four |
Mercury
(ppm) |
8.3 |
0.3 |
1.5 |
0.5 |
PCBs
(ppm) |
0.9 |
ND*-0.03 |
ND-0.04 |
ND-0.03 |
Cesium-137
(picoCuries/gram) |
7.0 |
0.4 |
2.0 |
0.5 |
*ND
= non-detectable
The high percentage of removal in these
alternatives is expected to significantly reduce bioaccumulation in fish.
The long-term monitoring component of the remedy will ensure long-term
protection.
B. Compliance with ARARs
The
National Contingency Plan, Section 300.430 (e)(9)(iii)(B), requires that removal
attain the Federal and State Applicable and Relevant and Appropriate
Requirements (ARARs) to the extent practicable. While there are no
promulgated Federal or State cleanup standards for contaminated sediment, there
are requirements that apply to the selected action. The significant ARARs
are highlighted below.
1. Chemical-Specific ARARs
Federal and State
regulations define hazardous wastes. All wastes classified as hazardous will be
handled, stored, and disposed of off-site at a permitted facility in accordance
with these regulations. State regulations pertaining to air emissions
control requirements will also be followed (6 New York Codes, Rules, and
Regulations Part 212, General Process Emission Sources).
2. Location-Specific ARARs
Federal
and State wetland regulations require that impacts to wetlands be minimized
unless no other viable option exists. The pilot studies conducted on the
Peconic River have demonstrated that the sediment removal techniques described
for this alternative are effective at minimizing disturbance to sensitive
wetland environments. Wetland restoration techniques have also been
demonstrated to be effective through a pilot study. This removal will use
the same techniques to minimize damage to the wetlands. As the Peconic
River is a New York State designated Wild and Scenic River, equivalency permit
requirements will be reviewed with NYSDEC for land access and the wetland
excavation and restoration.
3. Action-Specific ARARs
Action specific
requirements include 33 CFR 320.2 Dredge and Fill Operations and state and
federal discharge regulations.
4. To-be-Considered (TBC) Guidance
In
implementing this Removal Action, the important non-promulgated guidance, known
as TBCs, will also be followed.
C. Long-Term
Effectiveness and Permanence
Alternative 1 does not provide
a permanent remedy. Under the No Action alternative, the contaminants will
remain in place and rely on the occurrence of natural sedimentation or reduction
through dispersement from transport to reduce the bioaccumulation in fish and
the exposure of aquatic life to contaminated sediment.
Alternatives 2, 3, and 4
involve the removal of contaminated sediment from the Peconic River.
Alternative 2 would remove all the contaminated sediment for the onsite portion
of the river and would be effective. Alternative 3 would remove the sediment
with mercury greater than 9.8 ppm. The remaining sediment could provide a
mercury source for potential fish bioaccumulation or for migration.
Alternative 4 removes the contaminated sediment from the four depositional areas
and would remove 95% of the mercury and also be nearly as effective as
Alternative 2 with less incremental damage to the wetlands and upstream areas.
Since residual
contamination will remain in the Peconic River with any remedy selected,
monitoring will be used to assess the long-term effectiveness in meeting
remedial action objectives. The results of the monitoring will be assessed
as part of the five-year review, and the need for additional actions would be
evaluated in the event of unacceptable residual risk.
D. Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 1 does not reduce
the volume or toxicity of the contaminants contained in the Peconic River
sediment.
Alternatives 2,
3, and 4, through removal rather than treatment, reduce the volume, mobility,
and toxicity of contaminated sediment that is available for bioaccumulation in
fish or for direct exposure to aquatic life.
E. Short-Term Effectiveness
There will be a
short-term impact to the environment as sediment is removed and the areas are
restored. Additionally, upland areas where access roads are installed will
be impacted for at least a five-year period until the remedy review is complete.
This criterion
also assesses the impact to the community and site workers during construction
or implementation, and includes the time needed to finish work.
Alternative 1 involves no remedial actions that have the potential to impact
worker health and safety or the surrounding community. Alternatives 2, 3, and 4
pose minimal risk to workers during removal, cleanup, and waste disposal, and
these are minimized through BNL’s health and safety practices.
Similarly, because of these health and safety practices, there are minimal risks
to the public. Additional protection will be provided through ongoing
controls that reduce the potential for sediment migration during the sediment
removal process.
F. Implementability
All of the alternatives are
readily implementable using established, field-proven practices and standard
construction practices. Industry technologies and equipment designed to
reduce the ecological impact during the implementation will be used.
G. Cost
Table 2 lists the
cost for each of the alternatives.
Alternative |
Cost
(Includes 25% Contingency) |
Alternative One – No Action |
$137,992 |
Alternative Two |
$9,552,388 |
Alternative Three |
$5,602,360 |
Alternative Four |
$
7,838,590 |
H. State Acceptance
The regulatory
acceptance criterion evaluates whether the technical and administrative concerns
of State have been addressed. The NYSDEC has reviewed and commented on
this EE/CA – Action Memorandum. Additionally, the NYSDEC will review
this action for acceptance as a final action when the Record of Decision is
presented at a future date.
I.
Community Acceptance
The community acceptance
criterion evaluates whether the concerns of public have been addressed.
The community will have the opportunity to review and comment on the removal
alternatives in a 30-day public comment period. Public comments will be
formally addressed. Additionally, the public will have the opportunity to review
this action for acceptance as a final action when the Record of Decision is
presented at a future date.
VII. Removal Action Recommendation
A. Proposed Action
Alternative
4 is the proposed removal action. The action involves the removal of
contaminated sediments in Areas A, B, C, and D to achieve an average
concentration of 1 part per million (ppm) mercury through the portion of the
Peconic River on the DOE’s BNL property, with a goal of no sample in any
excavated area exceeding 2 ppm mercury. Co-located contaminants will also be
removed. The major features of this action include stream dewatering, the
excavation and removal of the sediment layer, dewatering of removed sediment,
disposal of sediment at a licensed off-site landfill facility, wetland
restoration as needed and installation of access roads for removal equipment.
Details will be determined during the preparation of project work plans.
Post-excavation sampling will be performed to confirm that cleanup goals have
been met. Construction and long-term monitoring of surface water,
sediment, and fish will ensure effectiveness.
B. Contribution to the Remedial Performance
This
removal action will contribute to the overall cleanup of the Peconic River by
removing a significant amount of contaminated sediment. The Peconic River is
identified as Area of Concern 30 in the Interagency Agreement. A future
Record of Decision will document the final remedy selected. This action
will be consistent with the final remedy.
C. Description of Alternative Technologies
In
December 2000, BNL hosted a Peconic River cleanup workshop that involved
national and international environmental restoration companies. Regulatory
agency personnel, the DOE and BNL staff and community members attended the
workshop. The workshop focused on the identification of alternative
technologies that might be capable of reducing wetland damage while achieving
the necessary cleanup objectives.
D.
Project Schedule
The
current working schedule calls for the removal action including all waste
disposal to be initiated late in 2003 and completed by spring 2004.
Long-term monitoring will continue at least until the five-year remedy review.
Lessons learned from the removal action will be applied to the remainder of the
Peconic River cleanup.
VII.
Expected Change in the Situation Should Action Be Delayed or Not Taken
A
delayed action or no action will increase the potential for additional
contaminants to migrate off Laboratory property and for continued
bioaccumulation of contaminants in fish. This removal action allows for an early
start before the Record of Decision is finalized. This action is best performed
during the dry season (typically late summer to early winter) when water levels
are low and sections of the river are dry.
IX. Public Participation
Extensive
public participation on this project has been conducted over a period of several
years. This remedy reflects many aspects of that participation.
Public
participation for this Removal Action will include issuing a public notice of
availability in a local newspaper coinciding with the submission of this Action
Memorandum to the Administrative Record. The public will also have an
opportunity to re-evaluate this action as final when the Feasibility Study
Addendum and Proposed Remedial Action are issued for public review and comment
at some future date.
Peconic
River updates will continue to be provided to the BNL Community Advisory Council
and Brookhaven Executive Roundtable. Additional Peconic River-related
information is available to the public from the Peconic River project website
(http://www.bnl.gov/erd/peconic.html) and cleanupdate newsletter.
The
public is invited to attend information sessions to be held
at the times noted below. These activities will take place during the
thirty-day public comment period. Responses to formal comments received
during the comment period will be responded to and considered as part of the
final Action Memorandum.
Public
information session: October 7, 2003 at Cornell Cooperative Extension
Public
information session: October 15, 2003 at Brookhaven National Laboratory, Berkner Hall Room
B.
X.
Outstanding Policy Issues
There
are no outstanding policy issues identified for this removal action.
XI. Enforcement
BNL
is owned by the DOE and the DOE will fund this removal action. The removal
action will be conducted in accordance with CERCLA and National Contingency Plan
requirements, the Interagency Agreement, and applicable New York State
regulations.
XII. Recommendation
This
decision document represents the removal action for the Peconic River on
Laboratory property. This decision document was developed in accordance
with CERCLA as amended, and is consistent with the National Contingency Plan.
This decision is based on the Administrative Record for the site.