For Immediate Release
October 01, 2025
Draft Report on the 650 sump outfall;
independent investigation conducted by STAR
I. Overview:
Early this year, STAR was approached by Bob Ramirez, a former employee at BNL. Mr. Ramirez came to STAR because he believed, from his experience, that problems at BNL needed independent investigation and part of STAR's mission is to "promote independent oversight."
Bob Ramirez is a hydrogeologist/geochemist who was employed at BNL between 1988-1996. Between 1993 and 1996, Ramirez was employed by the Office of Environmental Restoration as Project Manager for the Sitewide Hydrogeologic Characterization Project. Before leaving BNL, Mr. Ramirez was involved in all aspects of the hydrogeology at BNL and worked on all of the Operable Units. In 1995, he learned of an elevated level of gross beta at a test well along the southern boundary of the site. The elevated gross beta was above background levels and therefore raised a concern about its origin because the well was not near any obvious source of radioactive contamination.
The contamination discovered at the well was below the Maximum Contaminant Level (MCL) for gross beta. However, in his opinion, Mr. Ramirez determined that this could have been a tracer, or the residue, of contaminated groundwater that had flowed past the well. Therefore, when the well is tested at a later date the contamination would not be detected at such high levels because the contamination had migrated downgradient. Thus, a lower level in subsequent tests would not mean that a problem did not exists. This could account for the elevated level that had been detected earlier and would mean that the contamination had now traveled beyond the southern boundary of the site.
Another concern was that this "tracer" could also indicate that the contamination that had passed by the well may have been concentrated at higher levels than those detected in the original tests. This is feasible because well samples downgradient of the 650 sump have shown levels of Strontium-90 and gross beta that have been well above the MCL. The elevated level of gross beta could suggest that these possible "packets" of radionuclides were migrating off-site and into the residential areas South of BNL at drinking water well depth (85-105 feet).
II. Independent verification:
When approached by Mr. Ramirez, STAR contracted Kevin Phillips, of Fanning, Phillips and Molnar (a firm then unaffiliated with BNL/DOE) to review all of Mr. Ramirez's work and assertions. Mr. Phillips has a Phd in Hydrogeology from the Massachusetts Institute of Technology (MIT) and is extremely familiar with Long Island hydrogeology. Moreover, Mr. Phillips has recently been contracted to review the hydrogeology of Operable Unit III at BNL.
Excerpts from Mr. Phillips report to STAR are noted where appropriate. Moreover, BNL officials have stated that this theory is plausible.
Therefore, STAR believes that further investigation is the responsibility of the Potentially Responsible Party (PRP). We believe that greater attention should be given to this theory in order to adequately determine the extent of the contamination. It is the responsibility of BNL to investigate this theory to the satisfaction of independent experts and the affected community. Towards this end, we would like the DOE/BNL to proceed in this investigation with independent oversight as well as full cooperation and disclosure. Only then will we achieve results that the community can begin to believe.
STAR has summarized the problem and our conclusions based upon input, review and consideration by the abovementioned as well as other STAR board members, associates, and members of our technical advisory board. STAR submits the following for consideration:
III. Background:
Building 650 was used as a decontamination facility for the removal of radioactivity from clothing and equipment. Between 1959 and 1969, Building 650 discharged radioactive wastewater into a drain that was believed to go to one of four underground storage tanks, depending on the degree of contamination. Tanks designated as 650 #1 and 650 #2 held "D" level waste and 650 #3 and 650 #4 held less contaminated "F" level waste. The tanks containing "F" level waste were then able to discharge waste to the sewage treatment plant.
However, this was not the case for operations at the Bldg. 650 Decontamination Pad. The effluent never went to any of the storage tanks. Instead, in 1969, after a release of five curies of tritium, it was discovered that the drains leading from the decontamination pad were being carried out a pipe and discharged onto the ground. This omission occurred from at least 1959, until the problem was discovered in 1969.
The effluent from the decontamination pad contained virtually every sort of toxic chemical and radionuclide produced at BNL. Indeed, the soil in the 650 outfall is known to contain plutonium, cobalt, cesium, europium, radium and strontium, as well as arsenic, lead, mercury and other contaminants.
Approximately 200 feet across the street from the 650 sump outfall is the HO Recharge Basin (HO). The HO receives 1.53 million gallons of water a day when the Alternate Gradient Synchrotron (AGS) is operating. The AGS operates, on average, for six to eight months out of the year. The large amount of water flowing into the recharge basin creates a mounding effect. Very simply, this means that the water is piling up on itself. The amount of water being discharged into the HO cannot recharge into the ground quickly enough to avoid mounding.
Metal complexing chemicals, such as, chelating agents, or polyelectrolytes, are added to the cooling water at the AGS. These agents have always been added to the water since the machine began operating. Unfortunately, the AGS operated during the years that the 650 sump outfall was receiving unknown quantities of contaminated effluent.
The chelating agents allow metals to remain soluble and to travel with water and therefore not clog the AGS heat exchangers and pipe system. Radionuclides are also metals. This could mean that the radionuclides may have been solubilized and could have traveled with the groundwater. This rate of travel would have greatly exceeded the speed with which metals typically travel in the groundwater. Conservatively, the contamination from the 650 sump outfall could have traveled at the speed of the groundwater (approximately .75 feet a day). At this rate, contamination that began migrating in 1959 may have traveled a mile in 15-20 years. This would mean that it may have traveled 2 miles in 30-40 years. Therefore, any such contaminant may be beyond the Laboratory's boundary and into the neighborhoods of North Shirley.
It must be understood that the scenario presented is a theory. However, based on the compilation of data and validated work this theory proves to be sound. Radionuclides carried by chelating agents into Long Island's sole source acquifer could present a grave threat to public health and safety. Therefore, the interaction between the chelated water and the unknown quantities of radionuclides that have percolated into the sump outfall are unknown variables that raise significant questions.
Moreover, this theory may have broader implications at BNL. As we have been told, the full extent of the use of chelating agents is not known. Indeed, the Office of Environmental Restoration has been unable to determine whether or not these agents were employed in any manner at the Brookhaven Graphite Research Reactor (BGRR). Therefore, the contamination that is emanating from the BGRR may not be fully understood and we feel that it is imperative to determine the influence that these agents may be having upon contaminants at BNL.
IV. Concerns:
A. Contaminant Migration:
It is our belief that current monitoring around Operable Unit IV is of residual contamination, remnants of the initial spilling of radioactive decontamination waste at the Bldg. 650 Sump Outfall. Hence, the radioactivity in the groundwater downgradient from the sump shows only a slight problem.
The initial slug of contamination from 1959-1969 rapidly moved downward through the soils to the groundwater because of solvents mixed with the radionuclides used during decontamination operations. The radionuclides were then further complexed, solubilized, and made mobile by the treated water coming from the HO. Thus, after 40 years the contamination has already moved out of the area and probably off site. Moreover, this is supported by the fact that the 5 curies of tritium that was released in 1969 has never been located. This is most likely because tritium moving at the speed of groundwater has already left the site after 30 years.
Therefore, we take issue with the contention that the radioactive contamination, at the Bldg. 650 Sump Outfall, is after 40 years localized and migrating very slowly. This belief is largely based on column studies performed on average Upper Glacial Aquifer sands. In the Upper Glacial Aquifer, strontium-90, one of the more soluble radionuclides, normally moves roughly 20 times slower than groundwater. Based upon the introduction of chelating agents, we believe that the contaminants in the Bldg. 650 Sump Outfall area may have traveled much faster than normal. Therefore, site specific solubility studies need to be performed in order to understand contaminant mobility.
A variety of factors affect the mobility of metals in soil/water systems. The major factors include:
i) the presence of water (soil moisture content);
ii) the presence of other complexing chemicals in solution;
iii) the pH and oxidation/reduction potential, which affect the speciation of all metals and complexing agents;
iv) the temperature, and soil properties, such as cation exchange, the presence of hydrous oxides of iron and magnesium, and the presence of organic matter.
Thus, we believe that BNL failed to utilize and account for most of the basic factors mentioned above in their predictions for the fate and transport of the radionuclides found at the Bldg. 650 Sump Outfall.
B. Examples:
i) Complexing Chemicals: As mentioned in the Background Section of this report, the Bldg. 650 Sump Outfall lies approximately 200 Ft. away from the largest recharge basin on the site; the Basin HO. This recharge basin disposes of almost 50% of BNL's process water and has a major hydrodynamic impact on all of Operable Unit IV. Water from this basin is treated with complexing chemicals/chelating agents (polyelectrolytes) designed to keep metals mobile and in solution.
However, we can find NO mention of the chelating agents or its properties in the Remedial Investigation documentation (RI/RA, RI/FS, PRAP, ROD, etc.), nor can we find mention of an investigation of this relationship. This mechanism alone can significantly increase the mobility of radionuclides. If complexed completely the radionuclides could move at the speed of groundwater.
In the Operable Unit IV RI/RA Vol. I, Section 8.1.2.1 it is acknowledged that based on the analyses of sludge from the Bldg. 650 Underground Storage Tanks it is highly likely that cleaning solvents were utilized in decontamination operations. This means that the radionuclides solubility were already increased and that the mobility of the radionuclides down through the soil was greatly enhanced. Instead of moving slowly downward through the soil the cleaning solvents could become a mechanism that can greatly speed up the process. However, the relationship is unknown because there are still no studies to indicate which radioactive contaminants were effected by these solutions and how this influenced its mobility.
ii) Temperature: The Basin HO water has been in contact with heat exchangers and is significantly warmed. It is recharged back in to the groundwater at a higher temperature than the normal groundwater temperatures. This can have two possible affects:
the higher temperatures can increase the solubility of metals it contacts and;
warmer water recharging back into the colder groundwater will not mix as expected due to thermal/density differences. This is significant because a warmer layer of "metal complexing" recharge water can ride very close to the top of the water table. This concentrated "metal complexing" layer, separated thermally and not being diluted by the surrounding groundwater, could easily remain intact long enough to travel the distance from Basin HO to the Sump Outfall complexing the radionuclides there. It would only take a few degrees difference in temperature to achieve this affect, e.g. the Gulf Stream and the Atlantic Ocean. This warm water current moves thousands of miles in the very upper layer of the colder Atlantic Ocean, mixing very little with the surrounding waters to the point of having a different nutrient makeup than the Atlantic. The above mechanisms involving temperature were never validated or accounted for.
iii) pH: Testing indicates that the pH testing of Basin HO water periodically dropped below the minimum NYS DWL of 6.5. The long term impact of the variance for this parameter was never accounted for since solubility testing for the different radionuclides that contaminate the 650 Sump Outfall was never performed.
C. Fate and Transport Modeling
Besides assumptions regarding site specific contaminant mobility estimates, DOE/BNL/CDM Federal have also relied on modeling to support the theory that the radioactive contamination is localized and will not travel far. BNL has transmitted to STAR the most recent data package dated March 20, 1998, containing mostly groundwater screening data.
Very basically, numerical modeling relies on many assumptions about the natural world to give the modeler a simplified way of visualizing very complex systems. However, modelers should make every attempt to make sure that they are simulating the natural world as closely as possible. Failure to do so can greatly impact the results.
In groundwater modeling the construction of the simulation begins with the structural framework of the model, or put simply the geology has to be accurate. In Figure 4 of the packet submitted to STAR on March 20,1998, a cross section is shown covering 2000 horizontal feet. In this cross section, almost ALL of it from the HO Basin down to Brookhaven Ave, has a layer beneath the Upper Glacial, marked in Red labeled in the legend as "Gardiners Clay".
There is NO evidence in any literature or geologic log that the Gardiners Clay is continuous under Operable Unit IV. As stated in the Operable Unit IV RI/RA report, the Gardiners Clay exists as a continuous unit South of BNL property. However, if this is not the case under Operable Unit IV, then placing a unit that restricts water migration such as the Gardiners Clay in the analysis will seriously affect the hydrodynamics and modeling results. Therefore, the full extent of the Gardiners Clay must be characterized before conclusions are accepted.
Moreover, the "Historical Analysis" modeling gives a snap shot of the contaminant plume in 1969. Pump rate data for the wells that eventually discharge in to Basin HO for the critical years 1959-1969, during the radioactive release, do not exist. Therefore, this effect cannot be accurately modeled. This assumption is never stated nor the large uncertainty introduced by this data gap.
The model assumes a constant source of contamination through out the modeling exercise. This is not an accurate representation of the system and demonstrates a lack of understanding of the processes involved, and additional uncertainties introduced. Simple estimates of discharges of stormwater runoff to the Sump Outfall were used, and "no evidence that overflows from the sump area occurred historically".
From 1971-1973 , seven monitoring wells were installed. Purge water from the well development, which can be quite considerable, was discharged over the area flooding it. This flooding provides more downward forcing, causing the contaminants to migrate further vertically, and possibly spreading horizontally as well.
On the other hand, if the modeling is to be believed, one scenario outlined is very troubling. Under the section, "Approximate the Extent of Contamination as of 1996, 2000 2020: Retardation=1", by the year 2000 the OU III groundwater recovery system may not provide complete capture of the plume. By this time, the plume will have migrated into the Magothy aquifer at elevations of -400 to -125 ft. below mean sea level. Thus, it would appear that BNL may very well have contaminated the aquifer from which the Suffolk County Water Authority receives most of their supply water. However, this contamination of long lived radionuclides at a depth that will make remediation prohibitive is still not understood. Therefore, we believe that the implications of these possibilities demand that this scenario receive further study.
Finally, Fate and Transport modeling performed during the RI/RA phase of OU IV exemplifies problems associated with modeling. Acetone was found to be the major solvent found in the subsurface soils at the Sump Outfall area.
Since acetone is sometimes found as a laboratory introduced contaminant, the CDM Federal data validators thoroughly reviewed the data sets and confirmed that indeed the acetone was from the environmental samples and existed in the soils. The fate and transport model predicted that if this was the case, acetone should be found in the groundwater samples as well. However, there was no acetone detected in the groundwater samples. This same example applies to phenol and other solvents at the 650 Sump Outfall. Several theories were presented as to why acetone was not present in the groundwater samples but none were verified. It is obvious that complex mechanisms can exist at this site that are not well understood and overlooked by assumptions inherent in modeling.
D. Building 650 Sump Outfall Contaminant Characterization
The tests performed on the sludge found in the Underground Storage Tanks can be used as an indicator of the types of radionuclides that can be expected in the 650 sump. With this information it will be possible to have a complete characterization of the soil and groundwater at the 650 Sump Outfall that has not been performed.
Two important radionuclides, Technetium-99 and Carbon-14, both strong beta emitters, have not been analyzed. Carbon-14 is found in nature in small quantities, but Technetium-99 is a product that could only have been produced by BNL. Remember that it was an elevated gross beta reading from a well at the BNL southern boundary, with no obvious contamination source close by, that sparked this whole investigation.
In addition Iodine-129, iron-59, nickel-59&63, and the long lived alpha emitter curium-242&244 have been omitted. Special radiochemical analyses were not performed for these compounds.
STAR's main concern and the issue at hand is what has not been accomplished. This is more thoroughly addressed in the "Recommendations" section which follows:
V. Recommendations:
A. Independent Investigation of OU IV, AOC 6, Bldg. 650 and Bldg. 650 Sump Outfall
Since 1969, even though considerable time and taxpayer money has been spent, little more has been added to the knowledge base to confidently state that BNL knows the nature and extent of the contamination at AOC 6. We feel that at this time, a focused Remedial Investigation, overseen by an organization independent of DOE/BNL, should be instituted picking up where CDM Federal investigation left off. Any new scope of work for this investigation should at a minimum include the following:
I) The initial slug of contamination from 1959-1969 rapidly moved downward through the soils to the groundwater because of solvents mixed with the radionuclides used during decontamination operations. The radionuclides were then further complexed, solubilized, and made mobile by the treated water coming from the HO. Thus, after 40 years the contamination has already moved out of the area and probably off site. Moreover, this is supported by the fact that the 5 curies of tritium that was released in 1969 has never been located. This is most likely because tritium moving at the speed of groundwater has already left the site after 30 years.
Based upon the introduction of chelating agents, we believe that the contaminants in the Bldg. 650 Sump Outfall area may have traveled much faster than normal. Therefore, we believe that tests and models must be conducted to determine the location of the 5 curies of tritium and the elevated levels of radionuclides that existed in the soil and groundwater under the 650 sump outfall. Where are the contaminants now? ii) A complete characterization of the soils and groundwater around AOC 6, using special radiochemical analyses, not screening tests, for the suite of radionuclides found present in the sludge of the Underground Storage Tanks (650 #1, #2), together with a basic understanding of fission/activation products known to be produced throughout the BNL complex. The sites selected by CDM Federal should be revisited and determined if they are still applicable.
iii) Pipe Sampling: The samples that were taken of the unsaturated soil around the pipe between Building 650 and the sump outfall were not taken by the pipes joints, and may be giving somewhat of a false sense of security of what is actually there. However, it is our opinion that the samples were taken in the wrong spot, that the pipe should be uncovered and sampled at each of the joints where leakage could have occurred. Of course, if high levels show up, the nearby groundwater should be investigated as well. An accredited radiological laboratory other than BNL's, performing tests utilizing the highest data quality objectives should be used.
iv) Site specific solubility testing of all radionuclides uncovered in the above #1. The solubilities should be tested using two different scenarios.
Scenario #1: how the solubility changes with each radionuclide species for the chemical solutions used during the decontamination operations, and
Scenario #2: how the treated water from the HO Recharge Basin changes the solubilities of the radionuclides, taking into account all the parameters affecting solubility such as, temperature, pH, etc., as outlined in this report under section III Concerns, A. Contaminate Migration. Moreover, it must be determined what types of chemical additions were made to the cooling water. What were the injection rates and resultant concentrations of these chemicals in the cooling water?
v) A more thorough understanding of vadose zone processes as illustrated by the acetone example must be in place. Moreover, BNL should revisit the subsurface geology, before any modeling takes place.
vi) The modeling effort should include the pulsation of the HO recharge basin. It is understood that the recharge basin only receives the effluent eight months out of the year and that four months out of the year the effluent is not discharged into the recharge basin. This inconsistent discharge will change the localized pattern of groundwater flow. In addition, any pumping data from other areas must be included in the model. The model must be a time variant model that can be verified and calibrated to the extent that it produces believable results.
"Moreover, the study must proceed with a better conceptual model. For example, the cooling water discharged 8 months of the year on (with chemically altered water) and 4 months off. This is clearly acknowledged as a significant factor in the groundwater flow patterns. Such a pattern must be modeled to determine the true contaminant transport over this 30 to 40 year period. This model then must be calibrated and verified. It must be a transient model since many of the inputs are variable. If knowledge of these pumping operations and discharge operations is imperfect, then scenarios must be used to look at the potential pathways and potential concentrations that could develop. These "what if" scenarios should be used to identify observation wells that can confirm or deny the position of the contamination."
Presently, the radioactivity in the groundwater downgradient from the sump shows levels much lower that those reported in the past. This obviously suggests that the elevated levels have migrated. Where are the elevated levels of strontium and the other radionuclides that were shown to exist at elevated levels? Specifically, where is the 5 curies of tritium that was spilled in 1969?
VI. Conclusion:
Mr. Ramirez's theory raises serious questions that have not been answered. While there are several possible answers to these questions, the severity of its ramifications-migration of some of the deadliest contaminants known-warrants further investigation. The fact that the contamination is not fully understood mandates that the theory be tested to the satisfaction of the community.
Moreover, the influence of chelating agents at other highly contaminated facilities, such as the BGRR, is unknown. Thus, we feel that it is imperative to determine the influence that these agents may be having upon all contaminants at BNL.
We look forward to a response to the questions raised. If you have any questions please contact Scott Cullen at (516) 324-0655, or fax (516) 324-0655, or email [email protected].
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