Memo from Peter Bond, Interim BNL Director

[Andy Hull <hull@mail.sep.bnl.gov>]

While this is a bit long for a Radsafe item, there has been so much recent
interest in and discussion of the Brookhaven situation that I have asked for
and received Melissa's OK to forward it to all of you.

Date: Fri, 19 Sep 1997 11:42:05 -0400
To: "BNL Labwide Broadcasts" <broadcast-l@bnl.gov>
Subject: Memo from Peter Bond, Interim BNL Director

                BROOKHAVEN NATIONAL LABORATORY

                        M E M O R A N D U M

DATE:           September 19, 1997
TO:             All BNL Employees
FROM:           Peter Bond, Interim BNL Director
SUBJECT:        Response to Congressman Michael Forbes's letter

Although I did not personally receive a copy in the mail, it was with great
concern that I learned about the letter U.S. Representative Michael Forbes
sent out to many residents of the First Congressional District dated
Monday, September 8, 1997.

While the Congressman's decision to push for permanent shutdown of the High
Flux Beam Reactor is itself disappointing, there were many statements in
the letter that indicated the Congressman had been misinformed about issues
at BNL. I would like to clarify or correct some of those raised in
Congressman Forbes's letter:

* Congressman Forbes: "This note is necessary because of the independent
decision I have made to force the permanent shutdown of the leaking HFBR
nuclear reactor at Brookhaven National Laboratory. Senator Al D'Amato is
also joining me and supporting this effort."

 FACT:  The HFBR is not leaking. The tritium plume discovered on the
Laboratory site last January is coming from a leak in the pool used to
store spent fuel from the reactor. This pool is filled with water
containing 130 microcuries per liter of tritium. While the pool is located
next to the reactor vessel, in the same building, it has nothing to do with
the way the HFBR operates. The HFBR could have continued operating safely
at 30 megawatts.

* Congressman Forbes: "In comparison [to the 31-year-old HFBR], the
Nation's first nuclear-powered warship, "The Nautilus," was taken out of
service after 26 years at sea; and to date, many of the other 100 nuclear
submarines since taken out of commission were operational a similar amount
of time."

FACT: Reactor failures are not the reason that nuclear submarines are taken
out of service. The driving reasons to replace submarines are hull fatigue
and advances in technology, both unrelated to the reactor. As a
counter-example, the aircraft carrier, The U.S.S. Enterprise, was
commissioned in 1962 and has eight nuclear reactors, each similar in power
to the HFBR. That ship has a projected lifetime of over 50 years, when the
concern will be hull fatigue, not the reactors.

* Congressman Forbes: "To date there have been two areas identified on the
site that contain radiological contamination from tritium and strontium-90;
and five with chemical contamination (including a 25,000 gallon oil spill
dating back to 1977!). That's seven (!) troubling plumes on the BNL
property."

FACT: Largely through long-standing and ongoing Superfund remediation
efforts, BNL has known about these seven plumes of contaminants on the Lab
site for some time. Only one of the plumes - the tritium plume from the
spent-fuel pool - is related to any activity at the HFBR. The five chemical
plumes have been under active investigation and remediation since 1992; for
example, sources have been eliminated and three groundwater treatment
systems are in place. A small plume of strontium-90, is also being
remediated under Superfund. No BNL or off-site water supply well has been
contaminated by any of these plumes.

* Congressman Forbes: "After a delay in advising the public, Lab officials
further admitted to another tritium discovery and to a tritium
concentration of three (3) times the drinking water standard leaking into
the usually dry river bed considered part of the ecologically-sensitive
Peconic River!"

* FACT: The first finding that the Congressman refers to was of low levels
of tritium - at about half the U.S. Environmental Protection Agency's (EPA)
drinking water standard - in groundwater just south of BNL's smaller
research reactor, the Brookhaven Medical Research Reactor (BMRR). This
finding was reported to DOE promptly but not as a press release because
tritium levels were well below the drinking water standard. It was
mentioned at a public meeting on July 28 and is addressed in the report of
our recently completed sitewide review of Laboratory facilities.

The second "tritium concentration" refers to the July "spike" in tritium
levels at the Lab's sewage treatment plant. That release was reported
promptly on July 29, in a press release and at a public meeting that night.
Incidentally, that announcement produced little reaction at the meeting.

* Congressman Forbes: "We live on a unique Island where our principal water
supply depends on a healthy, uncompromised sole-source aquifer."

FACT:  This is certainly a true statement, and it is important to note that
BNL is working aggressively to clean up our known contaminated areas over
our small part of the aquifer.

Within his letter, Congressman Forbes included a box discussing "Other
Environmental Problems Revealed at Brookhaven Lab."

* Congressman Forbes: "In the mid-1980s, BNL found tritium in an on-site
drinking water well. The well was closed and the source of tritium never
investigated. Originally, Lab officials assumed it came from a leaking
sewage pipe but now believe it to be part of the plume traced to the spent
fuel canal of the closed down nuclear reactor."

FACT: It is untrue that the source of the tritium found in a BNL drinking
water that was closed in 1986 was never investigated.

First, the pumping well was closed because of chemical contamination, not
because of tritium. Even though tritium concentration in the well was never
higher than about one-third the drinking water standard, we undertook a
three-year study and upgrade of our sewage piping system, and drilled
monitoring wells near the pumping well. Only very low levels were observed,
so it was concluded that the issue was resolved.

* Congressman Forbes: "[BNL] became a designated 'Superfund' site in 1989
because of the errant waste disposal practices it followed for much of its
50-year history and thus became eligible for priority clean up. The Lab's
management began to address known problems as part of its routine
operations but made little attempt to investigate the existence of any
other potential contamination."

FACT: The waste-disposal practices followed at BNL and which led to its
being named a Superfund site in 1989 were in accord with regulations at the
time.  Farmers, dry cleaners, gas stations - all disposed of used chemicals
or had spills that would never be permitted or go unheeded today. Prior to
1989, BNL had been evaluating areas near known contamination areas, such as
the hazardous waste facility. In that year, we drilled 51 monitoring wells
to look for possible contamination elsewhere on the site. We have also had
extensive efforts to remove tanks, clean up drums, install hazardous
material storage areas and reconnect floor drains to the Lab's sanitary
system.

* Congressman Forbes: "In 1992 after concerns were raised about the slow
pace of clean-up at BNL, an agreement was reached between DOE, the EPA, and
the State Department of Environmental Conservation to ensure proper
compliance at BNL with Superfund requirements."

FACT: The 1992 agreement among BNL, DOE, EPA and New York State Department
of Environmental Conservation was not prompted by the "slow pace of cleanup
at BNL." This agreement was the culmination of a three-year period of
negotiation and public involvement, a process that must follow after a site
is named as a Superfund site.

* Congressman Forbes: "At that time, Lab officials acknowledged the need
for extensive groundwater monitoring but assigned it a very low priority.
The little monitoring that did occur detected tritium in a number of wells
on the property. In 1991, levels of strontium at 150 times the drinking
water standard were uncovered in a 50-year old single-lined concrete tank
near an inoperative graphite reactor."

 FACT: BNL recognized the need for extensive groundwater monitoring and, in
1992, began to install a network of additional monitoring wells, but
concentrated on our southern borders to determine whether any contaminants
were going off site. That focus on the southern border led to
characterization of chemical plumes moving south of the Lab, which were
fortunately so deep as not to affect residential wells off site.

Beginning in 1995, our monitoring program began to focus on the central
portion of the site. This effort led to the detection of strontium in an
underground collection tank, which was always intended to store such
material. The area around the tank, which did leak, is now being cleaned up
as part of Superfund remediation.

* Congressman Forbes: "The Suffolk County Health Department notified [BNL]
that the spent fuel canal did not comply with county code requirements.
Management promised the County that they would install two monitoring wells
south of the offensive nuclear reactor. Unfortunately, they delayed their
action for nearly a year. Once again, the health and safety of the
community was given a very low priority."

FACT: Even though the spent-fuel pool did not meet the Suffolk County code,
the Laboratory had no reason to believe that it was leaking. The pool had
been monitored for leakage, but the leak turned out to be so small and so
slow that it was undetectable by the methods then in use. In hindsight,
yes, we did miss the leak.

But be assured: The health and safety of the community has always been a
high priority at BNL.

* Congressman Forbes: "Last October, a routine sampling of wells near the
nuclear reactor uncovered extraordinarily high levels of tritium, one
measuring 32 times the drinking water standard. That's bad enough but when
Lab authorities failed to notify the public until this past January, it
precipitated the crisis that has gripped the Lab to date."

 FACT: BNL did not delay notification about the tritium leak. The first
indication that there was tritium in the groundwater near the HFBR came
last December (not October), when results from sampling of monitoring wells
near the HFBR showed tritium at a maximum of about one-tenth the EPA
drinking water standard. Since we did not expect to find any tritium above
background, we resampled within a week.

The results that came back on January 8, showed tritium at about twice the
drinking water standard in one well. Because such a dramatic change had
taken place, we sampled again on January 9, and confirmed the high level on
January 10. As soon as we realized that there was a problem we went
forward: We notified DOE on Monday, January 13. After DOE officials were
fully briefed, we notified regulators and public officials - including
Congressman Forbes - on January 16, our employees on January 17, and the
media on January 18.

BNL then sunk a series of temporary monitoring wells to define the extent
of the tritium plume. The highest concentration of tritium, 32 times the
drinking water standard, was found in an area about 50 feet south of the
HFBR in early February. The leading edge of the plume has not extended
beyond two-thirds of a mile from the HFBR, which is another two-thirds of a
mile from the site's southern boundary.

* Congressman Forbes: "Additional testing continues to reveal disturbing
levels of tritium. One analysis showed tritium at 40 times the drinking
water standard, another noted the presence of Cobalt 60 just 800 feet from
the research reactor."

FACT:  High levels of tritium exist directly adjacent to the HFBR
spent-fuel pool. However, the tritium levels drop to about one-third the
drinking water standard at the plume's leading edge, where interim
remediation will prevent the plume from the HFBR spent-fuel pool from
impacting either BNL employees or the public.

A very low level of cobalt-60, about one-third the drinking water standard,
was found about 800 feet from the HFBR. This was an isolated finding,
unrelated to the HFBR, and is not a plume.

* Congressman Forbes: "Finally, at our urging the [EPA] launched a
comprehensive investigation at BNL this past May that found numerous
violations of environmental rules and regulations, including the federal
research facilities' repeated failure to properly store certain types of
waste by-product. They uncovered the existence of a pipe discharging into a
nearby wetland from the on-site hazardous waste management building where
mixed wastes, solvents, acids, and other toxins are stored! They were cited
for exceeding by more than 50 percent the mandatory Clean Air safety
standards in steam that results from the operation of a boiler used to burn
waste."

FACT: None of the violations noted in the preliminary findings of the EPA's
compliance audit of BNL, conducted at Energy Secretary Federico Peņa's
request, pose a threat to workers, the public or the environment. When
these preliminary findings were released this past July, the EPA's
Administrator for Region II, in which BNL sits, noted, "The violations EPA
uncovered during our multi-program inspection of the facility are instances
of poor operations maintenance and housekeeping. . . . none of the
violations appear to present an imminent endangerment."

The pipe discharging into a wetland is a storm-water drain under a road,
which BNL reported to both the EPA and New York State in 1992. The EPA did
not respond, and New York State did not believe it necessary to include the
drain on our discharge permit. Incidentally, the area is not designated as
a wetland. Also, the boiler emissions results that the Congressman cited
came while a new boiler was being tested to see if it was acceptable for
use at BNL. Since it failed to meet the safety standards, the boiler was
not accepted.