# Chapter Contents {#chapter-contents .KRob-heading-1}

Section Page

8.1 Fish, Shellfish, Aquatic Vegetation, and Sediment 8.1-1

8.2 Peconic River Post-Cleanup Monitoring 8.2-1

8.3 Farm and Garden Vegetables and Soils 8.3-1

8.4 Precipitation Monitoring 8.4-1

8.5 Terrestrial Vegetation and Soil Monitoring 8.5-1

8.6 Deer and Small Mammal Sampling 8.6-1

*Intentionally Left Blank*

Fish, Aquatic Vegetation, and Sediment

**[DQO Start Date]{.smallcaps}** January 1, 2003

**[Revision Number/Date]{.smallcaps}** Rev. 4, November 24, 2008

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section .KRob-heading-1}

Summary of Proposed Changes

# BNL has not evaluated shellfish since 2002; therefore all references to shellfish in the title and throughout the text were removed.  {#bnl-has-not-evaluated-shellfish-since-2002-therefore-all-references-to-shellfish-in-the-title-and-throughout-the-text-were-removed. .KRob-heading-1}

#  {#section-1 .KRob-heading-1}

Description and Technical Basis

BNL has historically carried out surveillance monitoring of fish,
aquatic vegetation, sediment, and water within the Peconic River and
control locations. The purpose of the surveillance monitoring has been
in support of reactor operations, Sewage Treatment Plant (STP)
operations, environmental management programs (Comprehensive
Environmental Response, Compensation and Liability Act \[CERCLA\]), and
the Peconic Estuary Program. Historic data typically indicates the
presence of cesium-137 (Cs-137), various heavy metals, polychlorinated
biphenyls (PCBs), and certain pesticides within the various aquatic
media at locations on site, with declining concentrations downstream of
the Laboratory. PCBs and pesticides have also been detected in control
locations. Historic data consistently indicates that there is no effect
from BNL operations far downstream of the site boundary and suggest that
a reduction in the surveillance monitoring is justified. This DQO
establishes the decision criteria to decrease or increase aquatic
surveillance monitoring, as necessary. This balanced approach will
provide flexibility to the monitoring program.

Fish have been sampled since the early 1990s to support reactor
operations, as well as discharge, monitoring, and environmental
restoration activities. Fish sampling has historically occurred at
several locations along the Peconic River, including on-site reaches,
Swan Pond, Donahue's Pond, Forge Pond, and at Lower Lake on the Carmans
River (a control location). Annual sampling on site between 1990 and
1999 had resulted in a depletion of the number and size of fish
available for sampling. As a result, sampling was suspended to allow the
fish population to recover. Drought and clean-up operations had
prevented the re-establishment of sufficient fish populations for
sampling, and the suspension of on-site sampling continued until the
populations recovered. In 2007, sufficient numbers and sizes of fish
were present on site to allow sampling. Continued presence of water
throughout the year within the Peconic River suggests that fish sampling
can now be supported. Results of sampling at other areas along the
Peconic River have shown a decline in the levels of Cs-137 found in
fish, both over time and distance from the Laboratory. However, fish
sampling has also consistently shown the presence of PCBs, pesticides,
and some heavy metals, attributable to historical BNL practices, in fish
tissues along the Peconic River.

Drivers for Monitoring Being Conducted Under This Program

#   {#section-2 .KRob-heading-1}

  ------- ---------------------------------------------------------------
          Compliance

  x       Support compliance

  x       Surveillance

  x       Restoration
  ------- ---------------------------------------------------------------

-   DOE Order 450.1A, Environmental Protection Program (2008), requires
    that DOE sites maintain surveillance to monitor the effects, if any,
    of DOE activities on environment and natural resources, both on and
    off site. DOE Order 5400.5, Radiation Protection of the Public and
    Environment (1990), requires DOE sites to maintain surveillance
    monitoring for determining radiological impacts to the public and
    environment.

-   Surveillance monitoring to determine impacts from discharges from
    the STP can also be considered a "best management practice" to
    ensure the early detection of potential contamination in order to
    better protect the public and environment.

-   Surveillance monitoring to document continued effectiveness of
    environmental cleanup operations and trends of changing levels of
    contaminants in fish is also considered a "best management
    practice."

#  {#section-3 .KRob-heading-1}

Data Quality Objective Analysis

Step 1: State the Problem

Past practices at BNL have resulted in contaminants being released to
the Peconic River System. These contaminants were released from the STP
and entered the river at the discharge point, with eventual migration
downstream. Upgrades to the STP include treatment to a tertiary level
and have greatly reduced the potential of future releases of
contaminants (conventional and radiological). Radiological effects may
have been lessened due to the E-ALARA process, as well as sewer cleaning
and remediation of the sand filter beds at the STP. However, there is
always a slight potential that contaminants could be released in an
"upset" situation (tritium and other contaminants are continually
released, under permit). Problems in the monitoring program include:
documentation of the continued decline in existing contaminants,
documentation of the success of cleanup operations along the river, and
having a mechanism to complete additional sampling of sediment,
shellfish, and aquatic vegetation far downstream in the Peconic River
and Peconic Estuary, should the need arise.

Step 2: Identify the Decision

The desired decisions for the fish, vegetation, and sediment
surveillance monitoring programs can be represented through the
following questions:

-   Are contaminants attributable to Laboratory operations present in
    fish, vegetation, and sediment within the Peconic River System?

-   Are fish populations and fish sizes on site large enough to support
    surveillance monitoring?

-   Are the levels of known BNL-contributed contaminants declining in
    fish, vegetation, and sediment within the Peconic River System?

-   Are cleanup actions reducing contaminants in fish, vegetation, and
    sediment within the Peconic River?

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   DOE-established dose guideline of 10 mrem/year for the general
    public

-   STP discharge monitoring data

-   New York State Department of Environmental Conservation (NYSDEC)
    consumption guidelines: 15 lb/year/person of fish for dose
    assessment

-   Field Sampling Team field logs and records maintained by field
    sampling personnel

-   Environmental Monitoring Standard Operating Procedures (SOPs)

-   Documented remediation of contaminated river sediment

-   Records of Decision (RODs) for the STP remediation in Operable Unit
    (OU) V

-   Closeout reports for the STP and Peconic River Cleanup Projects

-   Historic aquatic vegetation sampling results

-   Historic sediment sampling results

-   Historic Peconic River surface water sampling results

-   Historic shellfish results

-   Historic fish results

Step 4: Define the Study Boundaries

The boundaries of this study include the Peconic River system from the
STP outfall on site, extending downstream to the Peconic Bay. Control
locations for comparison data are Lower Lake on the Carmans River for
fish, sediment, and vegetation. Sampling is carried out during the
spring and summer months when oxygen levels support the presence of fish
in the shallow waters of the Peconic River.

Step 5: Develop the Decision Rule

Decision 1

*Are contaminants attributable to BNL operations present in fish,
vegetation, and sediment within the Peconic River System?*

**If** surveillance monitoring of fish, shellfish, vegetation, and
sediment detect BNL-attributed contaminants such as heavy metals,
Cs-137, PCBs, or pesticides, **then** surveillance monitoring will
continue.

**If** historic data for fish, vegetation, and sediment in an area of
the Peconic River System indicates that BNL-attributed contaminants are
not present or are at background levels or below, **then** surveillance
monitoring will be suspended. In a situation where surveillance
monitoring in a section of the Peconic River is suspended, the following
decision rule will apply:

**If** upstream surveillance monitoring of any media indicates
increasing levels of a contaminant of concern, **then** an evaluation
will be conducted under the EPD Environmental Event Response Procedure.

**If** during the evaluation it is determined that additional monitoring
is necessary, **then** monitoring at downstream locations, with
appropriate control locations, will be reinstituted.

Decision 2

*Are fish populations and fish sizes on site large enough to support
surveillance monitoring?*

**If** annual fish population and size surveys indicate that sufficient
numbers of fish exist at sizes large enough for sampling, **then**
surveillance monitoring of fish will occur on site.

**If** annual fish population and size surveys indicate insufficient
numbers of fish and/or fish are not of significant size for sampling,
**then** surveillance monitoring will be suspended and annual population
and size surveys will continue to facilitate population recovery.

Note: In the above decision rules, "sufficient" body and population size
means that enough fish exist to (1) support the preparation of a
1-kg-sample of each species desired and (2) be taken without disrupting
the population. This requires that enough fish of reproductive age
remain in the river for the population of each species to survive and
reproduce, so that surveillance samples can be obtained the following
year.

Decision 3

*Are the levels of known BNL-contributed contaminants declining in fish,
vegetation, and sediment within the Peconic River System?*

Historic sampling of river flora and fauna has typically indicated that
radionuclide concentrations are declining, while other contaminants have
no consistent pattern of increase or decline.

**If** trending continues to show declining levels of contaminants in
fish, vegetation, and sediment, **then** re-evaluation of the monitoring
program will occur when values reach background.

**If** trends in contaminant concentrations in fish, vegetation, and
sediment are found to be increasing, **then** an evaluation will be
conducted under the EPD Environmental Event Response Procedure to review
the data and determine any changes in the environmental monitoring
requirements and whether further action should be taken.

Decision 4

*Are remediation actions resulting in reduction of contaminants in fish,
vegetation, and sediment within the Peconic River?*

Since cleanup of the upper reaches of the Peconic River is complete,
surveillance monitoring should document the effectiveness of the
cleanup.

**If** surveillance-monitoring trends indicate a decline in contaminants
in fish, vegetation, and sediment in the Peconic River, **then**
surveillance monitoring will continue until values reach the background
levels (found in control locations). When values are at background
levels, the need for further surveillance will be evaluated.

**If** surveillance-monitoring trends indicate a flat or climbing trend,
**then** the data will be reviewed and the need for modifications to the
monitoring program will be assessed.

**If** the assessment indicates that further monitoring is necessary,
**then** an evaluation under the EPD Environmental Event Response
Procedure will be completed to identify all aspects of the continued
presence of contaminants in the Peconic River System.

Step 6: Specify Acceptable Error Tolerances

Because the upper reaches of the Peconic River are typically fed by
discharges from the BNL STP, the effects of these discharges must be
monitored. Historic discharges have resulted in various contaminants
accumulating in river sediment. Monitoring data will be of sufficient
quality to measure constituents to the same level of detection used for
drinking water standards. False positives and negatives will be
minimized and data will not have excessive qualifiers attached if the
values are above minimum detection limits. Duplicate sampling will be
submitted (when possible) at a rate of 10 percent of the sample
collection, in order to check and verify lab quality.

Step 7: Optimize the Design

In order to document recovery of fish populations and size classes in
the on-site portion of the Peconic River, an annual survey will be
conducted. The survey will utilize electro-shocking and other
appropriate sampling techniques to collect the highest number of fish
possible, with reasonable effort. All fish collected will be identified
to species and, at a minimum, will have total body length measured.
Total numbers sampled will be recorded. Areas of coverage will be, at a
minimum, from 150 feet east of the east firebreak up to the outfall of
the STP.

Fish sampling will include at least five samples of each species of
fish, as is practical or available, including brown bullhead, chain
pickerel or largemouth bass, or yellow perch. Fish from different
feeding guilds (bottom feeders, predatory fish, etc.) are sampled to
document potential pathways of contaminants through the food chain and
up to the level of potential human consumption (game fish). Samples will
be taken from the following locations, including but not limited to:
BNL, when population sizes permit; Swan Pond; Donahue's Pond; Forge Pond
on the Peconic River; and Lower Lake on the Carmans River (control
location). Additional locations along the Peconic River may be sampled
as part of monitoring for the post-cleanup of the Peconic River (i.e.
Manor Road area and Shultz Road area). Fillets of larger species of fish
will be utilized as being representative of edible portions.
Radionuclide (gamma) analysis may require composite sampling of two or
more fish to ensure sufficient sample volume for analysis. In order to
maximize the analytical process, sample analysis will be conducted in
priority order of: mercury, metals, PCBs/pesticides (on site and
Donahue's pond samples only), and gamma emitting radionuclides. It may
be necessary to take separate samples or composite samples to gather
radionuclide data. Smaller species will be composited and analyzed as
whole body and will be indicative of prey- or bait-type fish.

Fish sampled under the Peconic River Post-Cleanup DQO on site and at
Donahue's Pond will also be tested for pesticides and metals other than
mercury.

In addition to fish sampling from these ponds, a sediment sample and a
single vegetation sample of any abundant emergent aquatic plant will be
taken (three samples on site). Sufficient material will be taken in
order to complete the analysis for gamma-emitting radionuclides,
PCBs/pesticides (BNL and Donahue's Pond only), and metals.

**Table 8.1.1 2009 Aquatic Surveillance Monitoring Program**

  --------------------------------------------------------------------------------
  Matrix       Location     Number of     Analysis           Frequency   Sample
                            Samples                                      Type
  ------------ ------------ ------------- ------------------ ----------- ---------
  Fish         BNL          10 + 1QA\*    PCBs/Pesticides,   Annual      Grab
                                          Metals                         

               Swan Pond    10 + 1QA      Gamma, Metals      Annual      Grab

               Donahue's    10 + 1QA\*    Metals             Annual      Grab
               Pond                                                      

               Forge Pond   10 + 1QA      Gamma, Metals      Annual      Grab

               Lower Lake,  10 + 1QA      Gamma, Metals      Annual      Grab
               Carmans                                                   
               River                                                     

  Vegetation   BNL and      8 + 1QA       Gamma,             Annual      Grab
               Swan,                      PCBs/Pesticides                
               Donahue's,                 (BNL), Metals                  
               and Forge                                                 
               Ponds,                                                    
               Carmans                                                   
               River                                                     

  Sediment     Swan,        4             Gamma, Metals      Annual      Grab
               Donahue's,                                                
               and Forge                                                 
               Ponds,                                                    
               Carmans                                                   
               River                                                     

  Water        Swan,        4             Gamma, Metals      Annual      Grab
               Donahue's,                                                
               and Forge                                                 
               Ponds,                                                    
               Carmans                                                   
               River                                                     

  Water        Meadow Marsh 1             Metals, Nutrients, Annual      Grab
                                          Water Quality                  
                                          Parameters                     

  Fish         BNL (as      Population    Length and Weight  Annual      Grab
               needed)      Survey        (if possible)                  
  --------------------------------------------------------------------------------

#  {#section-4 .KRob-heading-1}

Total Sampling and Analysis Cost for Monitoring Program

The proposed sampling program will result in no decrease in sampling and
analysis cost.

FY2007 Costs \$36,500

FY2008 Costs \$36,500

Difference 0

See Appendix B for the monitoring program for this DQO.

**Peconic River Post-Cleanup Monitoring**

**[DQO Start Date]{.smallcaps}** January 1, 2007

**[Revision Number/Date]{.smallcaps}** Rev. 2, December 1, 2008

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section-5 .KRob-heading-1}

Summary of Proposed Changes

On an annual basis and after five years of annual monitoring (through
2010), BNL and DOE will evaluate all environmental data collected since
completion of the cleanup for each of the Record of Decision
(ROD)-required monitoring activities (sediment, surface water, fish).
Recommendations for future monitoring activities and/or response
actions, as appropriate, will then be submitted to the Environmental
Protection Agency (EPA), New York State Department of Environmental
Conservation (NYSDEC), and Suffolk County Department of Health Services
(SCDHS) as part of the Annual Peconic River Monitoring Report and the
BNL Five-Year Review in 2011.

In 2008, BNL began collecting and ageing scales from Peconic River fish
(other than brown bullheads, which do not have scales), as well as
collecting and aging otoliths (ear bones) from Peconic River brown
bullheads. Fish age will be used to help evaluate trends in mercury
concentration in fish tissue since the completion of the Peconic River
cleanup in 2005. Fish ageing will continue in 2009 and 2010. As part of
the BNL Five-Year Review, BNL and DOE will evaluate and make a
recommendation to EPA, NYSDEC, and SCDHS concerning fish ageing beyond
2010.

Also in 2008, BNL initiated the collection of surface water samples 15
feet upstream and 15 feet downstream of two sediment sample locations
with elevated mercury concentrations. The sample data will be used to
evaluate the potential downstream transport of mercury from these
locations. Collection of surface water samples in these locations will
continue in 2009. These data will be evaluated with EPA, NYSDEC, and
SCDHS as part of the Annual Peconic River Monitoring Report and as part
of the BNL Five-Year Review in 2011.

Description and Technical Basis

BNL completed the cleanup and restoration of the Peconic River in May
2005. The cleanup operation removed sediment containing mercury and
other co-located contaminants including polychlorinated biphenyls
(PCBs), pesticides, heavy metals, and cesium-137 (Cs-137) from
approximately 19 acres of the river starting at the Sewage Treatment
Plant (STP) outfall and extending to the area of Manor Road.
approximately 4.5 miles downstream of the BNL STP. Cleanup resulted in
an average level of mercury in the remaining sediments of approximately
0.2 ppm and removal of approximately 90 percent of the co-located
contaminants.

This DQO describes the post-remediation environmental monitoring that
will be performed to demonstrate compliance with the Operable Unit (OU)
V Peconic River Record of Decision (ROD). To promote sampling
efficiency, some environmental samples will also be analyzed to meet the
requirements of the surveillance monitoring program. The mission of the
surveillance monitoring program is to provide early detection of
potential releases of contaminants through environmental monitoring not
otherwise required by remediation-required or permit-required compliance
monitoring.

Because potentially remaining contaminated sediment presents the
greatest source of potential mercury bioaccumulation in fish, both
sediment and fish will be sampled once annually to monitor the long-term
effectiveness of the cleanup. Sediment will be monitored for mercury,
PCBs, and Cs-137. Silver and copper also pose a potential threat to the
aquatic community. Additional analyses will be performed for these
analytes on one sediment sample within each of the five fish collection
areas. Each sediment sample will also be analyzed for pesticides, as
part of the surveillance monitoring program. Fish will be analyzed for
mercury and radionuclides in fish tissue. As required by the ROD, fish
collected on site will also be monitored for PCBs. Fish will be sampled
when collections can be obtained without impacting the wellbeing of the
fish population. Surface water samples will be collected twice annually
(June and August) and analyzed for mercury, methyl mercury, and Total
Suspended Solids (TSS).

The continued effectiveness of the cleanup during the first five years
will be evaluated through an annual review of the sampling data with
EPA, NYSDEC, and SCDHS. On an annual basis, sampling modifications will
be made for subsequent sampling, if necessary, as well as the need for
potential additional response actions.

For each of the ROD-required monitoring activities (sediment, surface
water, fish), after five years of annual monitoring, BNL/DOE will
evaluate all environmental data collected since completion of the
cleanup. BNL/DOE will then recommend future monitoring activities and/or
response actions, as appropriate, and submit them to EPA, NYSDEC, and
SCDHS as part of the BNL Five-Year Review in 2011.

Drivers for Monitoring Being Conducted Under This Program

#  {#section-6 .KRob-heading-1}

  ------- ---------------------------------------------------------------
          Compliance

  x       Support compliance

  x       Surveillance

  x       Restoration
  ------- ---------------------------------------------------------------

-   OU V ROD for Area of Concern 30 (Peconic River).

-   Final Closeout Report, Peconic River Remediation Phases 1 and 2.

-   OU I Soils and OU V Long-Term Monitoring and Maintenance Plan.

-   Peconic River post-cleanup monitoring data can be used to determine
    impacts from discharges from the STP. Collection of this monitoring
    data can also be considered a "best management practice" to ensure
    the early detection of potential contamination in order to better
    protect the public and environment.

-   Surveillance monitoring to document continued effectiveness of
    environmental cleanup operations and trends of changing levels of
    contaminants in sediments and water column is also considered a
    "best management practice."

#  {#section-7 .KRob-heading-1}

Data Quality Objective Analysis

Step 1: State the Problem

Past practices at BNL have resulted in contaminants being released to
the Peconic River System. These contaminants were released from the STP
and entered the river at the discharge point with eventual migration
downstream. Recent improvements to the STP and pollution prevention
practices include upgrades of the treatment system to the tertiary
level, improved waste minimization and waste handling practices, and
minimized use of specific hazardous materials (e.g. mercury and silver).
Sewer cleaning and remediation of the sand filter beds at the STP and
minimization of mercury sources throughout the Laboratory lessen the
likelihood of mercury being released to the Peconic River System. These
improvements have greatly reduced the potential for future releases of
contaminants (conventional and radiological). However, there is always a
slight potential that contaminants could be released in an "upset"
situation, and very small amounts of mercury are permitted to be
released under BNL's State Pollutant Discharge Elimination System
(SPDES) permit.

This monitoring program addresses the problems in documenting the
achievement and maintenance of the cleanup goals required by the Peconic
River ROD with data of appropriate quality to meet Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) and ROD
mandates.

The Peconic River cleanup was completed in 2005 and annual post-cleanup
monitoring was initiated in 2006. Monitoring will continue until the
remedial action has been demonstrated to be protective of human health
and the environment. The Peconic River monitoring program is designed
such that if the value of a sediment sample is greater than or equal to
2.0 mg/kg, then the nature and extent of mercury contamination will be
characterized in a one hundred square foot area surrounding the original
sample point. Sampling modifications will be made for subsequent
sampling, if necessary. After five years of annual monitoring, BNL/DOE
will evaluate all environmental data that have been collected since the
completion of the cleanup. BNL/DOE will then recommend future monitoring
activities and/or response actions, as appropriate, to EPA, NYS-DEC, and
SCDHS as part of the BNL Five-Year Review in 2011.

Annual monitoring will be guided by the DQO analysis and monitoring
summaries that follow, and are detailed in the OU I Soils and OU V
Long-Term Monitoring and Maintenance Plan. The monitoring data will be
summarized in an annual Peconic River Monitoring Report, which BNL/DOE
will submit to EPA, NYDEC, and SCDHS for review. The DQO process that
follows will be used to guide data interpretation and recommendations to
the regulators made each year in the Annual Peconic River Monitoring
Report. The DQO decisions may be modified in response to potential
changes in data needs.

Step 2: Identify the Decision

The desired decisions for demonstration of the success of the Peconic
River cleanup can be represented through the following question:

Have cleanup actions reduced the amount of mercury, PCBs, and
radionuclides in the sediments and fish and reduced the amount of
mercury and methyl mercury in the water column to levels protective of
human health and the environment in sections of the Peconic River
impacted by BNL operations?

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   Baseline monitoring before cleanup of the Peconic River

-   Post-cleanup sediment confirmation data

-   Control location monitoring data for the Connetquot River reference
    station

-   STP discharge monitoring data

-   Field Sampling Team field logs and records

-   Environmental Monitoring standard operating procedure

-   RODs for the STP and Peconic River remediation in OU V

-   Closeout reports for the STP and Peconic River Cleanup Projects

-   Data summary reports for mercury and methyl mercury for Peconic
    River surface water

Step 4: Define the Study Boundaries

The boundaries of this study include the Peconic River cleanup area from
the BNL STP outfall, downstream to approximately one quarter mile east
of Manor Road. The downstream extent of monitoring is at Connecticut
Avenue, approximately 2.6 miles downstream of Manor Road. A control
location for comparison of the surface water data is located at the
Connetquot River, approximately 20 miles to the southwest of BNL. Data
collection and temporal boundaries include sediment sampling in June,
regardless of water level; surface water sampling in June and August;
and fish sampling between May and August. If necessary, to avoid
potential drought or high water periods, fish and surface water
collections may occur somewhat earlier or later.

Step 5: Develop the Decision Rule

Decision 1

*Are the levels of BNL-attributable contaminants present in annual
Peconic River sediment samples remaining stable relative to mercury
cleanup goals?*

**If** the average annual mercury concentration in sediment remains
below the cleanup limits of 1.0 ppm and 0.75 ppm for samples collected
on and off laboratory property, respectively, and no individual sample
equals or exceeds the goal that all mercury concentrations in the
remediated areas are less than 2.0 ppm following the cleanup, **then**
the current sampling plan will continue to be implemented without
modification from 2006 through 2010.

**If** any individual sediment sample equals or exceeds the goal that
all mercury concentrations in the remediated areas are less than 2.0 ppm
following the cleanup, **then** BNL/DOE will characterize the nature and
extent of contamination in the area surrounding the sample point(s) with
the elevated value(s). The detailed characterization will be implemented
by re-sampling the original data point location, plus four additional
sample points located 5 feet upstream, 5 feet downstream, 5 feet to the
left, and 5 feet to the right of the original sample, thus
characterizing a 100 square foot area.

**If** the average mercury concentration of the five resample points is
greater than or equal to 2.0 ppm, **then** additional nature and extent
sampling of the sediment in the area of the elevated sediment mercury
concentrations will be required. These data will be evaluated to assess
the potential for the elevated sediment mercury concentrations to
require near-term cleanup to prevent impact to human health and the
environment.

**If** after five years of sediment sampling (through 2010) the average
annual mercury concentration in sediment remains below the cleanup goals
of 1.0 ppm and 0.75 ppm for samples collected on and off site,
respectively, and no sample equals or exceeds the goal that all mercury
concentrations in the remediated areas are less than 2.0 ppm following
the cleanup, **then** BNL/DOE will evaluate and recommend to EPA,
NYSDEC, and SCDHS that the ROD-required Peconic River sediment sampling
be replaced with routine long-term surveillance sampling beyond 2010.

**If** after five years of sediment sampling (through 2010) the average
annual mercury concentration in sediment equals or exceeds the cleanup
goals of 1.0 ppm and 0.75 ppm for samples collected on and off site,
respectively, and/or sediment sample(s) equal or exceed the goal that
all mercury concentrations in the remediated areas are less than 2.0 ppm
following the cleanup, **then** BNL/DOE will evaluate all environmental
data collected since completion of the cleanup and recommend future
monitoring activities and/or response actions, as appropriate, to EPA,
NYSDEC, and SCDHS as part of the BNL Five-Year Review in 2011.

**Decision 2**

*Are the average levels of BNL-attributable mercury, PCBs, and
radionuclides in Peconic River fish trending toward levels that are
protective of human health?*

After the concentrations of environmental contaminants in sediment are
removed or reduced, the body burden of contaminants in fish tissue
typically require several years for substantial reduction depending on
the contaminant, the environment, and the feeding guild. For this
reason, the concentrations of contaminants in fish tissue resulting from
each year of monitoring between 2006 and 2010 should be trended relative
to the pre-cleanup levels.

**If** the annual levels of BNL-attributable mercury, PCBs, and
radionuclides in Peconic River fish are trending toward levels that are
more protective of human health, **then** BNL/DOE will continue to
monitor Peconic River fish, as required by the Peconic River ROD.

**If** the annual levels of BNL-attributable mercury, PCBs, and
radionuclides in Peconic River fish are trending toward levels that are
less protective of human health, **then** BNL/DOE will evaluate and
recommend to EPA, NYSDEC, and SCDHS that sampling protocols be modified
to better characterize potential source terms.

**If** after five years of fish sampling the average levels of
BNL-attributable mercury, PCBs, and radionuclides in Peconic River fish
are at levels protective of humans, **then** BNL/DOE will propose to
EPA, NYSDEC, and SCDHS that fish monitoring required by the Peconic
River ROD be replaced by long-term surveillance monitoring beyond 2010.

**If** after five years of fish sampling the average levels of
BNL-attributable mercury, PCBs, and radionuclides in Peconic River fish
are not trending toward levels that are protective of human health,
**then** BNL/DOE will evaluate all environmental data collected since
completion of the cleanup and recommend future monitoring activities
and/or response actions, as appropriate, to EPA, NYSDEC, and SCDHS as
part of the BNL Five-Year Review in 2011.

Decision 3

*Have cleanup actions reduced the amount of mercury and methyl mercury
in the water column in the Peconic River?*

Confirmatory sampling of Peconic River sediments at the time of cleanup
of the Peconic River indicate that, on average, the level of mercury in
sediments is approximately 0.2 ppm and co-located PCBs and Cs-137 were
reduced by approximately 90 percent. Mercury and methyl mercury analysis
of the water column samples is geared toward indicating the section(s)
of the river with the most optimal conditions for contributing total
mercury and methyl mercury from the sediment to the water column and
converting inorganic mercury to methyl mercury.

**If** sampling and trending shows declining levels over five years of
mercury and methyl mercury in the water column, **then** BNL will
re-evaluate the methyl mercury monitoring program when values have been
maintained or have declined over a period of five years, or if the
methyl mercury monitoring program data has not been useful in evaluating
the long-term effectiveness of the remedy. Re-evaluation will consider
whether the methyl mercury sampling program should be maintained at the
current level or modified. After five years of annual monitoring,
BNL/DOE will evaluate all environmental data collected since completion
of the cleanup. BNL/DOE will then recommend future monitoring
activities, as appropriate, to EPA, NYSDEC, and SCDHS for review in
2011.

**If** sampling and trending shows that mercury and methyl mercury in
the water column have been increasing in concentration and have been
increasing over the past five years, **then** BNL/DOE will evaluate all
environmental data collected since completion of the cleanup and then
recommend future monitoring activities and/or response actions, as
appropriate, to EPA, NYSDEC, and SCDHS as part of the BNL Five-Year
Review in 2011.

Step 6: Specify Acceptable Error Tolerances

Because the monitoring data discussed in this section and detailed in
the OU I Soils and OU V Long-Term Monitoring and Maintenance Plan are
collected to satisfy the sampling requirements specified in the Peconic
River ROD and to facilitate comparison with pre-cleanup characterization
data, the monitoring data must meet the CERCLA specifications by which
the Peconic River pre-remediation and confirmation data were collected.
Data will be reported in Full EPA CLP style. Analytical methods and
Quality Assurance/Quality Control (QA/QC) requirements are specified in
the OU I Soils and OU V Long Term Monitoring and Maintenance Plan,
Appendix C.

Step 7: Optimize the Design

Analytical results from Peconic River sediment, fish, and surface water
sampling will be used to document the condition of the Peconic River
resulting from cleanup operations and will be evaluated on an annual
basis to determine whether modification or additional optimization are
needed.

Sediment samples will be collected annually in June from 30 locations
along the Peconic River from just upstream of the BNL STP outfall and
extending through the Manor Road cleanup area and ending in Donahue's
Pond. Samples will be analyzed for mercury, PCBs, and radionuclides.
Samples will be collected at each of the sample locations regardless of
whether it is covered by water. Within each sample area, fine-grained
depositional sediment will be selected for sampling. Five of the 30
samples (17 percent), indicated with an asterisk in the following table,
will be collected within the areas from which fish will be sampled.
These sediment samples will be analyzed as part of the surveillance
program for mercury, silver, copper, and pesticides to survey for
potential ecological risks, as well as PCBs and gamma emitting
radionuclides. If Peconic River water levels are sufficiently low, the
sediment trap upstream of station HQ will be evaluated in the Annual
Report for removal, as required by the Peconic River ROD. An additional
three sediment samples will be collected from within and beneath the
sediment trap when it is removed. These samples will be analyzed for TAL
metals, pesticides, PCBs, and gamma-emitting radionuclides and will be
used to support the disposal of the sediment.

**Table 8.2.1 2009** Peconic River Sediment Sampling Locations

  ------------------------ ----------------------- -----------------------
  PR-SS-01\*               PR-SS-14                PR-SS-29

  PR-SS-02                 PR-SS-15                PR-SS-30

  PR-SS-03                 PR-SS-16\*              PR-SS-31

  PR-SS-04                 PR-SS-17                PR-SS-33\*

  PR-SS-05                 PR-SS-18                PR-SS-35

  PR-SS-06                 PR-SS-19                PR-SS-37

  PR-SS-07                 PR-SS-21                PR-SS-38

  PR-SS-09                 PR-SS-23                PR-MR-01\*

  PR-SS-10                 PR-SS-24                PR-MR-02

  PR-SS-12                 PR-SS-26                PR-DP-01\*
  ------------------------ ----------------------- -----------------------

Note:

> \* PR-SS-01, PR-SS-16, PR-SS-33, and PR-MR-01 will be collected from
> fish sampling locations within remediation areas P, D, A, and Manor
> Road, respectively. PR-DP-01 is from Donahue's Pond, located
> downstream of the remediated sections of the river.

Fish samples will be collected from five sections of the Peconic River.
To the extent that water level, fish abundance, and size allow, fish
will be collected from the sections of the river detailed in Table
8.2.2.

**Table 8.2.2 2009 Peconic River Fish Collection Locations**

  --------------- ---------------------------------------------------------
  **Remediation   **Location Description**
  Area**          

  Area A          Between stream gauging stations HE and HMn.

  Area D          Along North Street in the ponded sections of the river
                  upstream and downstream of stream gauging station HQ. If
                  water level or fish population size is not sufficient for
                  fish collection, the ponded section of the river in
                  remediation Area C may be substituted or added to
                  supplement on site Area D collections.

  Area P          Upstream of Schultz Road. If water level or fish
                  population size is not sufficient for fish collection,
                  the Ice Pond in remediation Area P may be substituted.

  Manor Road      Within the section of the Peconic River between
                  approximately 100 yards upstream and downstream of Manor
                  Road.

  Donahue's Pond  Donahue's Pond is an impounded section of the Peconic
                  River at the Peconic River Sportsman's Club.
  --------------- ---------------------------------------------------------

To the extent possible, five fish of sufficient size to obtain an edible
fillet will be collected for analysis from each of two feeding guilds.
Brown bullhead and/or white sucker will represent the bottom feeding
guild. Chain pickerel and/or large mouth bass will represent the
carnivore feeding guild. Sunfish may be used if chain pickerel or bass
are not available. If fish sizes are insufficient to obtain fillets,
smaller fish may be composited for a whole body analysis. All analytical
results will be reported as wet weight mass of contaminant per unit mass
of fish tissue.

Surface water samples will be taken from 21 locations in June and August
(provided sufficient water is present) along the Peconic River beginning
just west of the BNL STP outfall and ending at Connecticut Avenue. The
sampling locations also include an additional sample (sample 22) at a
control location at the Connetquot River reference station in western
Suffolk County.

In 2008, four additional water column sampling stations were added to
the list of water column sampling stations that will be sampled for
total mercury, methyl mercury, TSS, and flow. These four new water
column sampling stations (PR-SS-15-U1-WC1, PR-SS-15-U1-WC2,
PR-SS-15-U1-WC3, and PR-SS-15-U1-WC4) were added to evaluate the
potential transport of mercury and methyl mercury downstream from two
Peconic River sediment sampling stations (PR-SS-15-U1-L40 and
PR-SS-15-U1-L65) that had elevated mercury concentrations in 2007 and
2008. PR-SS-15-U1-WC1 and PR-SS-15-U1-WC2 are located 15 feet downstream
of the two sediment stations and PR-SS-15-U1-WC3 and PR-SS-15-U1-WC4 are
located 15 feet upstream of the two sediment stations. These four new
water column sampling stations will be sampled four times a year during
periods of the year when there is flow past the stream gauging station
HQ. Typically, low flow conditions occur between August and October. In
2008, there was no flow in this section of the river after June 25.

The data collected form these four new stations will be reported in the
annual Peconic River Monitoring Report and will be evaluated on an
annual basis with EPA, NYSDEC, and SCDHS and during the Five-Year
Review. These data will be evaluated as part of the decision process of
whether elevated mercury in the PR-SS-15-U1 sediment area merits near
term action or whether an action decision can be made as part of the
Five-Year Review in 2011.

**Table 8.2.3 2009 Locations of Water Column Sampling Stations**

  ----------------- ----------------------------- -----------------------
  **Station**       **Description**               **Distance Downstream
                                                  of STP (miles)**

  PR-WC-14          Upstream of STP               0.1

  PR-WC-13          Upstream of STP               0.1

  PR-WC-12          Upstream of STP               0.1

  PR-WC-11          STP Outfall                   0.0

  PR-WC-10          West of HMn                   0.3

  PR-WC-09          Downstream of HMn             0.6

  PR-WC-08          South of Area B               0.8

  PR-WC-07          South of Area C               1.0

  PR-WC-06          North of Area D               1.1

  PR-WC-05          Downstream of HQ              1.5

  PR-WC-04          2^nd^ Downstream of HQ        1.8

  PR-WC-03          3^rd^ West of Schultz Road    2.2

  PR-WC-02          2^nd^ West of Schultz Road    2.6

  PR-WC-01          1^st^ West of Schultz Road    3.1

  PR-WCS-01         Schultz Road                  3.5

  PR-WCS-02         East of Schultz Road          4.0

  PR-WCS-03         West of Manor Road            4.5

  PR-WCS-04         Manor Road                    4.8

  PR-WCS-05         West of Cranberry Bogs        6.0

  PR-WCS-06         East of Cranberry Bogs        6.6

  PR-WCS-07         Connecticut Avenue            7.1

  Connetquot River  Reference Site in Connetquot  \-
                    River                         

  PR-SS-15-U1-WC1   Up and Downstream of L40 and  1.5
  to WC4            L65                           
  ----------------- ----------------------------- -----------------------

Additional water quality sampling will supplement the mercury and methyl
mercury Peconic River surface water collections. The purpose of this
sampling is to track potential changes in the Peconic River water
quality following the remediation. The samples are to be collected at
each of the 21 Peconic River methyl mercury stations during the two
annual methyl mercury sampling rounds and at eight of the methyl mercury
stations in four additional sampling rounds. The four additional
sampling rounds will be collected two weeks prior to and two 2 weeks
after the June and late August methyl mercury collections. A total of 74
water quality samples will be collected on an annual basis. Table 8.2.4
indicates the sampling frequency, stations, and analytes.

**Table 8.2.4 2009 Water Quality Stations, Schedule, and Analyses**

+------------+------------------+--------------------------------------+
| *          | **Schedule**     | **Analyses**                         |
| *Station** |                  |                                      |
+============+==================+======================================+
| PR-WC-14   | June and August  | [Laboratory Analyses]{.underline}    |
|            |                  |                                      |
|            |                  | Chlorophyll-a, Total Phosphorus,     |
|            |                  | Total Nitrogen, Nitrate/Nitrite      |
|            |                  |                                      |
|            |                  | Total Kjeldahl Nitrogen (TKN), Total |
|            |                  | Organic Carbon (TOC), Total          |
|            |                  | Suspended Solids (TSS)               |
|            |                  |                                      |
|            |                  | [Field Measurements]{.underline}     |
|            |                  |                                      |
|            |                  | Turbidity, Dissolved Oxygen (DO),    |
|            |                  | pH, Temperature, Depth, Flow         |
+------------+------------------+--------------------------------------+
| PR-WC-13   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-12   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-11   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-10\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-09\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-08\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-07   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-06\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-05   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-04\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-03\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-02   | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WC-01\* | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-01  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-02  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-03  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| P          | June and August  |                                      |
| R-WCS-04\* |                  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-05  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-06  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-WCS-07  | June and August  |                                      |
+------------+------------------+--------------------------------------+
| PR-SS      | Four times       | Total mercury, methyl mercury, TSS   |
| -15-U1-WC1 | annually\*\*     |                                      |
| to WC4     |                  |                                      |
+------------+------------------+--------------------------------------+

Note:

\* Samples will be collected two weeks prior to and two weeks after June
and August collection.

\*\* Samples will be collected during periods of flow to evaluate
potential downstream transport. Ideally, these samples will be collected
as part of the June and August collections, as well as November/December
and February/March collections. Schedule adjustments will be made so
that four samples per year can be collected.

Table 8.2.5 summarizes the Peconic River ROD-required and surveillance
monitoring program for all samples collected between the BNL STP outfall
and Connecticut Avenue. The data quality for all samples will support
comparison with the Peconic River Remedial Investigation and
confirmation sampling data. Specific supplemental sampling efforts may
be required, based on the results of routine sampling, and will be
identified, as needed, separate from the Environmental Monitoring Plan.

**Table 8.2.5 2009 Peconic River Post-Cleanup Monitoring Summary**

+---+-----+---------+-----+---------------+------------+-----------+
| * | **  | **M     | **  | *             | **Method** | **Fr      |
| * | Nam | edium** | No. | *Parameters** |            | equency** |
| A | e** |         | of  |               |            |           |
| O |     |         | Sam |               |            |           |
| C |     |         | ple |               |            |           |
| * |     |         | s** |               |            |           |
| * |     |         |     |               |            |           |
+===+=====+=========+=====+===============+============+===========+
| 3 | P   | Surface | 22  | Methyl        | EPA Method | Twice     |
| 0 | eco | w       |     | mercury       | 1630       | annually  |
|   | nic | ater^1^ |     |               |            | (June and |
|   | Ri  |         |     | Mercury       | EPA Method | August)   |
|   | ver |         |     |               | 1631       |           |
|   |     |         |     | TSS           |            |           |
|   |     |         |     |               | EPA Method |           |
|   |     |         |     |               | 160.2      |           |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | Surface | 74  | Chlorophyll-a | SM18 10200 | Two or    |
| 0 | eco | w       | ^3^ |               | H          | four      |
|   | nic | ater^1^ |     | Total         |            | times     |
|   | Ri  |         |     | Phosphorus    | EPA Method | an        |
|   | ver |         |     |               | 365.2      | nually^3^ |
|   |     |         |     | Total         |            |           |
|   |     |         |     | Nitrogen      | EPA Method | (May to   |
|   |     |         |     |               | 300.0      | S         |
|   |     |         |     | Ni            |            | eptember) |
|   |     |         |     | trate/Nitrite | EPA Method |           |
|   |     |         |     |               | 353.1      |           |
|   |     |         |     | Total         |            |           |
|   |     |         |     | Kjeldahl      | EPA Method |           |
|   |     |         |     | Nitrogen      | 351.2      |           |
|   |     |         |     |               |            |           |
|   |     |         |     | TSS           | EPA Method |           |
|   |     |         |     |               | 160.2      |           |
|   |     |         |     | Turbidity     |            |           |
|   |     |         |     |               | Field      |           |
|   |     |         |     | DO            | m          |           |
|   |     |         |     |               | easurement |           |
|   |     |         |     | pH            |            |           |
|   |     |         |     |               | Field      |           |
|   |     |         |     | Temperature   | m          |           |
|   |     |         |     |               | easurement |           |
|   |     |         |     | Depth         |            |           |
|   |     |         |     |               | Field      |           |
|   |     |         |     |               | m          |           |
|   |     |         |     |               | easurement |           |
|   |     |         |     |               |            |           |
|   |     |         |     |               | Field      |           |
|   |     |         |     |               | m          |           |
|   |     |         |     |               | easurement |           |
|   |     |         |     |               |            |           |
|   |     |         |     |               | Field      |           |
|   |     |         |     |               | m          |           |
|   |     |         |     |               | easurement |           |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | Surface | 3   | TSS           | EPA Method | Every 2   |
| 0 | eco | w       |     |               | 160.2      | weeks     |
|   | nic | ater^1^ |     | DO            |            |           |
|   | Ri  | near HQ |     |               | Field      | Every 2   |
|   | ver | s       |     |               | m          | weeks     |
|   |     | ediment |     |               | easurement |           |
|   |     | trap    |     |               |            | (April -- |
|   |     |         |     |               |            | October)  |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | S       | 3   | Mercury       | EPA Method | Prior to  |
| 0 | eco | ediment |     |               | 7471a      | trap      |
|   | nic | within  |     | PCBs          |            | removal   |
|   | Ri  | or      |     |               | EPA Method |           |
|   | ver | beneath |     | Cesium-137    | 8082       |           |
|   |     | HQ      |     |               |            |           |
|   |     | s       |     |               | EPA Method |           |
|   |     | ediment |     |               | 901.1      |           |
|   |     | trap^2^ |     |               |            |           |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | Sedi    | 25  | Mercury       | EPA Method | Annually  |
| 0 | eco | ment^2^ |     |               | 7471a      | (June)    |
|   | nic |         | 5   | PCBs          |            |           |
|   | Ri  |         |     |               | EPA Method |           |
|   | ver |         | 5   | Cesium-137    | 8082       |           |
|   |     |         |     |               |            |           |
|   |     |         |     | Mercury,      | EPA Method |           |
|   |     |         |     | Silver,       | 901.1      |           |
|   |     |         |     | Copper        |            |           |
|   |     |         |     |               | EPA Method |           |
|   |     |         |     | Pesticides    | 7471a      |           |
|   |     |         |     |               |            |           |
|   |     |         |     | PCBs          | EPA Method |           |
|   |     |         |     |               | 8081       |           |
|   |     |         |     | G             |            |           |
|   |     |         |     | amma-emitting | EPA Method |           |
|   |     |         |     | r             | 8082       |           |
|   |     |         |     | adio-nuclides |            |           |
|   |     |         |     |               | EPA Method |           |
|   |     |         |     |               | 901.1      |           |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | Fish on | 20  | Mercury       | EPA Method | Annually  |
| 0 | eco | BNL     |     |               | 7471a      | (between  |
|   | nic | p       |     | PCBs          |            | June and  |
|   | Ri  | roperty |     |               | EPA Method | August)   |
|   | ver |         |     | G             | 8082       |           |
|   |     |         |     | amma-emitting |            |           |
|   |     |         |     | r             | EPA Method |           |
|   |     |         |     | adio-nuclides | 901.1      |           |
+---+-----+---------+-----+---------------+------------+-----------+
| 3 | P   | Fish    | 30  | Mercury       | EPA Method | Annually  |
| 0 | eco | outside |     |               | 7471a      | (between  |
|   | nic | BNL     |     | G             |            | June and  |
|   | Ri  | p       |     | amma-emitting | EPA Method | August)   |
|   | ver | roperty |     | r             | 901.1      |           |
|   |     |         |     | adio-nuclides |            |           |
+---+-----+---------+-----+---------------+------------+-----------+

Notes:

^1^ Sample type is Grab

^2^ Sample type is Core

^3^ 21 stations are sampled in June and August; 8 are also sampled two
weeks prior to and two weeks after the June and August sample events

See Table 8.2.4 for station identification.

Total Sampling and Analysis Costs

The proposed sampling program will result in an annual cost of \$86,400.
Peconic River post-cleanup monitoring is a new program and 2008 is the
second year of inclusion in the EMP. The distribution of the costs is
summarized in Table 8.2.6.

**Table 8.2.6 2009 Sampling and Analysis Costs**

  ---------- ---------- -------------------- ----------------------- -------------
  **AOC**    **Name**   **Medium**           **Emphasis**            **Cost^1^**

  30         Peconic    Surface water        Methyl mercury, Mercury \$29,800
             River                           and TSS                 

  30         Peconic    Surface water        Water Quality           \$24,600
             River                           parameters and HQ TSS   
                                             and dissolved oxygen    

  30         Peconic    Peconic River        Mercury, silver,        \$16,200
             River      sediment on and off  copper, PCBs,           
                        BNL property and HQ  pesticides, Cs-137 and  
                        sediment trap        other Gamma-emitting    
                        sediment             radio-nuclides          

  30         Peconic    Peconic River fish   Mercury, PCBs, and      \$15,800
             River      on and off BNL       Gamma-emitting          
                        property^2^          radio-nuclides          

  Total Cost                                                         
  \$86,400                                                           
  ---------- ---------- -------------------- ----------------------- -------------

Notes:

^1^ Costs include contract analytical laboratory costs and sampling
labor.

FY2007 Costs \$86,400

Difference 0

See Appendix B for the monitoring program for this DQO.

**Farm and Garden Vegetables and Soils**

**[DQO Start Date]{.smallcaps}** January 1, 2003

**[Revision Number/Date]{.smallcaps}** Rev. 2, November 30, 2006

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section-8 .KRob-heading-1}

Summary of Proposed Changes

There are no proposed changes for this DQO in CY2009. Farm vegetables
were sampled in 2008. The next sampling is scheduled for 2013.

Description and Technical Basis

Farm and garden vegetables and associated soils have been sampled in the
past in order to document potential impacts from reactor operations and
to address potential concerns of the public. Sampling locations for farm
vegetables and soil are downwind of BNL (primarily northeast and
southeast). Results from this sampling program have consistently
indicated that no man-made radionuclides attributable to Laboratory
operations have been found in any farm vegetation or soil in the local
area. In 2000, BNL added on-site garden vegetables and soil from a
garden at the apartment complex to the sampling program, with only one
vegetable showing very low detectable levels of Cs-137, a radionuclide
found in some on-site soils.

Historically, reactor operations had the potential to release fission
products; therefore, downwind sampling was necessary to detect the
presence of these materials in air, soil, water, and biota. The three
reactors on site are no longer operating. The Brookhaven Graphite
Reactor (BGRR) and the High Flux Beam Reactor (HFBR) shared a 300-foot
stack for air emissions, and the BMRR had its own 100-foott stack for
air emissions. Due to the nature of the emissions from these reactors,
both stacks required continuous emissions monitoring.

Drivers for Monitoring Being Conducted Under This Program

  ------- ---------------------------------------------------------------
          Compliance

  x       Support compliance

  x       Surveillance

          Restoration
  ------- ---------------------------------------------------------------

-   DOE Order 450.1A, Environmental Protection Program (2008), requires
    DOE sites to maintain surveillance monitoring to determine possible
    effects of DOE activities on on- and off-site environment and
    natural resources. DOE Order 5400.5, Radiation Protection of the
    Public and Environment (1990), requires DOE sites to maintain
    surveillance monitoring for determining radiological impacts to the
    public and environment.

-   Surveillance monitoring to determine impacts from reactor operations
    can also be considered a "best management practice" to ensure the
    early detection of potential contamination in order to better
    protect the public and environment.

# Data Quality Objective Analysis {#data-quality-objective-analysis .KRob-heading-1}

#  {#section-9 .KRob-heading-1}

Step 1: State the Problem

The problem for study under this DQO is the conversion of the sampling
program for farm vegetables and associated soil from an annual program
to one in which sampling occurs once every five years, or as necessary
as determined by other sampling procedures or the Environmental
Protection Division (EPD) Environmental Event Response Procedure, while
maintaining the annual sampling program for garden vegetables grown on
site, as well as soils taken from the on-site garden.

Step 2: Identify the Decision

The desired decisions under this DQO can be stated as questions.

-   Are radionuclides attributable to BNL operations present in off-site
    soil used to grow vegetables, and in the vegetables themselves?

-   Does the cessation of reactor operations justify the suspension or
    reduction in frequency of farm and garden vegetable sampling?

-   Will a graded approach to farm vegetable and soil sampling that
    allows for tiered sampling as needed or required based on results
    from monitoring other media (i.e., air, water, soil) be sufficiently
    protective of the public and environment?

-   Does soil used to grow garden vegetables on site, and do the
    vegetables themselves, contain radionuclides attributable to BNL
    operations?

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   Date of reactor closures

-   Historic farm and garden vegetation results, as reported in annual
    Site Environmental Reports

-   Identification of other points of air discharge that could
    potentially release long-lived radionuclides that could reach and be
    incorporated in farm and garden vegetables

-   Prevailing wind direction

-   Results from other monitoring data (e.g., air)

-   Field Sampling Team field logs and records

-   Environmental Monitoring Standard Operating Procedures (SOPs)

-   Documentation of the sampling and analysis program

-   Historic soil analysis data from area farms, the BNL apartment area
    garden, and control locations

Step 4: Define the Study Boundaries

The areas for inclusion in this study are area farms downwind of BNL.
Based on prevailing winds, this includes farms to the northeast and
southeast. Also included in the boundary is the on-site vegetable garden
located at the apartment area, and control locations upwind of the
Laboratory. Sampling will be conducted once every 5 years to confirm the
presence or absence of anthropogenic radionuclides originating from BNL
in farm vegetation, and annually for garden vegetables and soil taken on
site.

Step 5: Develop the Decision Rule

Decision 1

*Are radionuclides attributable to BNL operations present in off-site
soil used to grow farm vegetables, and in the farm vegetables
themselves?*

**If** historical data on farm vegetables and soil indicate that no
anthropogenic radionuclides attributable to BNL are present, **then**
consider reduction or elimination of off-site farm vegetables and soil
sampling.

Decision 2

*Does the cessation of reactor operations justify the suspension or
reduction in frequency of farm and garden vegetable sampling?*

**If** all BNL research reactors are permanently shut down, **then**
annual surveillance monitoring in support of reactor operations of local
farm vegetables and soils can be discontinued.

**If** BNL guests and apartment dwellers continue to utilize the on-site
vegetable garden, **then** annual sampling of garden vegetables and the
soil they grow in should continue, due to the continued presence of
historic radionuclide contamination in some BNL soils.

Decision 3

*Will a graded approach to farm and garden vegetable and soil sampling
that allows for tiered sampling as needed or required, based on results
from monitoring other media (i.e. air, water, soil), be sufficiently
protective of the public and environment?*

**If** surveillance monitoring under the air and soil programs indicate
the presence of anthropogenic radionuclides at the BNL boundary air
monitoring stations, or confirmatory sampling indicates the presence of
radionuclides originating from BNL, **then** the BNL Environmental Event
Response Procedure will be followed to determine the need for resuming
annual farm vegetable surveillance monitoring.

Decision 4

*Does soil used to grow garden vegetables on site, and do the vegetables
themselves, contain radionuclides attributable to BNL operations?*

**If** garden vegetables and soils taken on site contain significant
levels of radionuclides attributable to BNL operations, **then** the BNL
Environmental Event Response Procedure will be followed to determine the
need to close or move the garden to a more appropriate location and
inform gardeners of the identified contamination.

Step 6: Specify Acceptable Error Tolerances

Surveillance monitoring is used to identify areas that may be
potentially affected by operations of BNL facilities. The Laboratory has
historically sampled local farm vegetation for the presence of
anthropogenic radionuclides potentially released from BNL operations.
Historic data indicates that no Laboratory-related anthropogenic
radionuclides have been detected in nearby farm vegetation or soils.
Since all BNL reactors are no longer operational, there should be no
potential for the release of long-lived anthropogenic radionuclides from
Laboratory operations. Other environmental surveillance (including
on-site soil, vegetation, and air monitoring) allow for early detection
of operational constituents that could potentially affect human health
and the environment. Confirmatory sampling every five years is designed
to verify the continued absence of anthropogenic radionuclides
originating from BNL. The EPD Environmental Event Response Procedure
provides a mechanism for the reestablishment of annual surveillance
sampling of farm vegetables and associated soils, if necessary, after a
documented event and can be used should evidence of BNL-attributable
radionuclides be discovered in confirmatory sampling.

Errors for radiological data associated with on-site garden vegetables
and soil should be no larger than 20 percent at a 2-sigma significance
level. Data with higher errors should be reviewed for accuracy and
re-analysis or may be considered not to be valid data.

Step 7: Optimize the Design

Monitoring requirements for farm vegetation and associated soils are
shown in Table 8.3.1. These sampling and analysis requirements will be
implemented every five years to confirm the continued absence of
anthropogenic radionuclides attributable to BNL. The next scheduled
sampling of farm vegetables will occur in 2013. Garden vegetables and
associated soil will be sampled annually.

**Table 8.3.1 2009 Farm Vegetables and Associated Soil Monitoring
Program**

+--------------------+----------------------+-------------------------+
| ### Analysis       | #                    | ### Frequ               |
|                    | ## Sampling Location | ency (times per summer) |
+--------------------+----------------------+-------------------------+
| Radiological       | > Lewin's Farm       | > 5 to 7 vegetables\    |
| (gamma)            |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
|                    | > Bruno Farm         | > 4 to 5 vegetables\    |
|                    |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
|                    | > Mays Farm          | > 5 to 7 vegetables\    |
|                    |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
|                    | > Route 25 Farm      | > 1 to 2 vegetables\    |
|                    |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
|                    | > River Road Farm    | > 1 to 2 vegetables\    |
|                    |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
|                    | > Cornell Farm       | > 1 to 3 vegetables\    |
|                    | > (control)          | > 1 soil sample         |
+--------------------+----------------------+-------------------------+
| Radiological       | > BNL Garden         | > 5 to 7 vegetables\    |
| (gamma)            |                      | > 1 soil sample         |
+--------------------+----------------------+-------------------------+

#  {#section-10 .KRob-heading-1}

Total Sampling and Analysis Cost for Monitoring Program

Sampling costs for farm and garden vegetable sampling will decrease by
\$15,000, as sampling of farm vegetables and soils will not occur
between 2009 and 2012.

FY2008 Costs \$19,500

FY2008 Costs \$4,500

Difference -\$15,000

See Appendix B for the monitoring program for this DQO.

Precipitation Monitoring

**[DQO Start Date]{.smallcaps}** January 1, 2003

**[Revision Number/Date]{.smallcaps}** Rev. 1, November 30, 2005

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section-11 .KRob-heading-1}

Summary of Proposed Changes

There are no changes proposed for this DQO for CY2009.

Description and Technical Basis

#  {#section-12 .KRob-heading-1}

BNL currently samples precipitation on a quarterly basis at two
locations on site (Station P4 at the apartment area and S5 at the Sewage
Treatment Plant) in support of reactor operations. BNL's three reactors
have all been permanently shut down. The Brookhaven Graphite Reactor
(BGRR) ceased operation in 1968 and is currently undergoing
decontamination and decommissioning. The High Flux Beam Reactor (HFBR)
was permanently shut down in 1999 and has been placed in a safe and
secure configuration. The BMRR was permanently shut down in December
2000 and is also in a secure configuration. Historical precipitation
data has been reported as providing little, if any, indication of
BNL-related radionuclides in precipitation. However, historical data
within the past decade does indicate several high values of gross
alpha/beta, tritium, and strontium-90 (Sr-90) that had been considered
erroneous, but never investigated. Although reactor operations have
terminated, questions from historical precipitation data persist.
Therefore, continued monitoring is warranted until sufficient
documentation exists to discontinue monitoring.

Additionally, the cleanup of the Peconic River, which was primarily
driven by mercury in sediments, has raised questions about the
importance of atmospheric deposition of mercury. To answer this
question, mercury analysis is being added to the precipitation
monitoring program.

#  {#section-13 .KRob-heading-1}

Drivers for Monitoring Being Conducted Under This Program

#  {#section-14 .KRob-heading-1}

  ------- ---------------------------------------------------------------
          Compliance

  x       Support compliance

  x       Surveillance

  x       Restoration
  ------- ---------------------------------------------------------------

-   DOE Order 450.1A, Environmental Protection Program (2008), requires
    that DOE sites maintain surveillance to monitor the effects, if any,
    of DOE activities on the on- and off-site environment and natural
    resources. DOE Order 5400.5, Radiation Protection of the Public and
    Environment (1990), requires DOE sites to maintain surveillance
    monitoring to determine radiological impacts to the public and
    environment.

-   Surveillance monitoring to determine impacts from BNL operations can
    also be considered a "best management practice" to ensure the early
    detection, as well as long-term accumulation of potential
    contamination in order to better protect the public and environment.

-   Peconic River cleanup and subsequent monitoring for mercury and
    methyl mercury in order to document that the river remains in a
    clean state warrants investigating, whether atmospheric deposition
    of mercury is significant or not.

Data Quality Objective Analysis

Step 1: State the Problem

Historical precipitation data suggests the occasional detection of
radionuclides related to Laboratory operations. Therefore, the problem
is documenting whether or not BNL-related radionuclides are deposited in
the environment through precipitation. Additionally, precipitation
monitoring may be able to determine whether or not mercury is being
deposited from the atmosphere in precipitation.

Step 2: Identify the Decision

The desired decision for precipitation monitoring is:

*Does precipitation contain radionuclides attributable to BNL operations
and is mercury being deposited from the atmosphere?*

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   Historical precipitation data

-   Closure of all nuclear reactors at BNL (source term)

-   Field Sampling Team field logs and records

Step 4: Define the Study Boundaries

This DQO only affects the current precipitation sampling at BNL stations
P4 and S5. Sampling occurs on a quarterly basis at both locations. P4 is
located near the apartment complex and S5 is located at the Sewage
Treatment Plant (STP). No off-site precipitation is collected for
analysis at these locations.

Step 5: Develop the Decision Rule

Decision 1

*Does precipitation contain radionuclides attributable to BNL operations
and is mercury being deposited from the atmosphere?*

**If** quarterly precipitation data show no evidence of BNL-related
radionuclides, **then** report data in the annual Site Environmental
Report and continue quarterly monitoring.

**If** quarterly precipitation data show evidence of mercury from
atmospheric deposition, **then** report data in the annual Site
Environmental Report and continue monitoring quarterly.

**If** quarterly data indicate the potential presence of BNL-related
radionuclides, **then** initiate the Environmental Event Response
Procedure to investigate the data validity and source, and report the
data in the annual Site Environmental Report.

**If** data covering a period of five years post-reactor operations
indicate that no BNL-attributable radionuclides are present and data
covering a period of five years since initiation of mercury testing
indicate no measurable levels of mercury from atmospheric deposition,
**then** precipitation monitoring may be discontinued.

Step 6: Specify Acceptable Error Tolerances

Radiological data should have reported values with associated two-sigma
errors no greater than 20 percent. All gross alpha values above 15 pCi/L
should be analyzed to identify the nuclide-specific composition. For
gross beta, the prompt for identification of the nuclide-specific
composition is values above 50 pCi/L. Mercury analysis should be
conducted under Environmental Protection Agency (EPA) method 1631 and
meet the quality assurance guidelines of this method.

Step 7: Optimize the Design

Quarterly precipitation data should be acquired from on-site
precipitation-monitoring locations and analyzed for gross alpha/beta,
tritium, and gamma emitting radionuclides. Results should be reported to
the subject matter expert and reviewed quarterly, and any abnormalities
in the data investigated accordingly.

**Table 8.4.1 2009 Precipitation Surveillance Monitoring**

+----------+------------+--------------+--------------+--------------+
| # Matrix | # No.      | # Analysis   | # Frequency  | # Type       |
|          | of Samples |              |              |              |
+----------+------------+--------------+--------------+--------------+
| Preci    | 8          | Alpha/Beta   | Annual       | Grab         |
| pitation |            |              |              |              |
+----------+------------+--------------+--------------+--------------+
|          | 8          | Gamma        | Annual       | Grab         |
+----------+------------+--------------+--------------+--------------+
|          | 8          | Tritium      | Annual       | Grab         |
+----------+------------+--------------+--------------+--------------+
|          | 8          | Sr-90        | Annual       | Grab         |
+----------+------------+--------------+--------------+--------------+
|          | 8          | Hg           | Annual       | Grab         |
+----------+------------+--------------+--------------+--------------+

#  {#section-15 .KRob-heading-1}

Total Sampling and Analysis Cost for Monitoring Program

There is no change in cost to the program in 2009.

FY2008 Costs \$3,922

FY2009 Costs \$3,922

Difference 0

See Appendix B for the monitoring program for this DQO.

*Intentionally Left Blank*

Terrestrial Vegetation and Soil Monitoring

**[DQO Start Date]{.smallcaps}** January 1, 2003

**[Revision Number/Date]{.smallcaps}** Rev. 3, November 30, 2007

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section-16 .KRob-heading-1}

Summary of Proposed Changes

# There are no proposed changes for this DQO in CY2009. {#there-are-no-proposed-changes-for-this-dqo-in-cy2009. .KRob-heading-1}

#  {#section-17 .KRob-heading-1}

Description and Technical Basis

Historical operations of BNL have resulted in the distribution of
Cesium-137 (Cs-137) in landscape soils. The majority of this
contamination has been remediated. However, low levels of Cs-137 remain
in specific landscape areas at or below cleanup goals. In addition,
soils at or below cleanup goals in these areas have been covered with
clean fill material, 6 to 12 inches in depth. Other areas containing
higher levels of Cs-137 contamination (650 Sump Outfall and the former
Hazardous Waste Management Facility \[HWMF\]) have recently been cleaned
up. Cs-137 at detectable levels are still present at the former HWMF,
but have been covered with clean fill material, to allow natural
attenuation. The continued presence of soil contamination and the
potential for uptake by plants, which can then be passed along to
animals, must be monitored. This can be done through surveillance
monitoring of deer. Soil and vegetation monitoring within the former
HWMF is necessary to document whether or not uptake is occurring.
Additionally, the periodic assessment of soil and vegetation within
remediated landscaped soils should be conducted in order to determine
uptake and/or redistribution of contaminants. The remainder of the soil
and vegetation monitoring at BNL will follow a graded approach, as
outlined below.

The terrestrial vegetation and soil-monitoring program at BNL is
designed to supplement and support other monitoring efforts in a graded
approach. Historically, soil and vegetation monitoring have been
somewhat limited to farm and garden vegetation and soils associated with
the locations where the produce was sampled. This sampling had been
conducted in support of reactor operations to document impacts or lack
thereof from these operations. Since the farm and garden vegetable
sampling is linked to reactor operations and the reactors have been
placed into a permanent shutdown mode, and sampling is no longer
necessary. In addition, since all other current operations only produce
short-lived radionuclides that are not transported at significant
distances, the need for continuous or routine soil and vegetation
monitoring is no longer necessary.

In addition, vegetation and soil sampling occurred along with sampling
of goose fecal material in an attempt to document uptake of Cs-137 by
the geese. The goose fecal material study was conducted for two years,
with only slight indications that geese are obtaining Cs-137 through
ingestion. The program was dropped because it did not provide a clear
indication of uptake. Therefore, the terrestrial vegetation and soil
monitoring should continue in a graded approach in order to document any
effects that BNL operations may have on the local environment. As stated
above, this approach will be graded based on results from surveillance
of air monitoring and, to a limited extent, surveillance monitoring of
deer.

Drivers for Monitoring Being Conducted Under This Program

#   {#section-18 .KRob-heading-1}

  -------- --------------------------------------------------------------
           Compliance

  x        Support compliance

  x        Surveillance

  x        Restoration
  -------- --------------------------------------------------------------

-   DOE Order 450.1A, Environmental Protection Program (2008), requires
    that DOE sites maintain surveillance to monitor the effects, if any,
    of DOE activities on on- and off-site environment and natural
    resources. DOE Order 5400.5, Radiation Protection of the Public and
    Environment (1990), requires DOE sites to maintain surveillance
    monitoring for determining radiological impacts to the public and
    environment.

-   DOE-STD-1153-2002, A Graded Approach for Evaluation of Radiation
    Doses to Aquatic and Terrestrial Biota, recommends sampling design
    to assess radiological impacts to the biotic community.

-   Surveillance monitoring to determine impacts from BNL operations can
    also be considered a "best management practice" to ensure the early
    detection of long-term accumulation of potential contamination to
    better protect the public and environment.

-   Periodic monitoring to determine effectiveness of cleanup operations
    is necessary to document compliance with requirements of the Record
    of Decision (ROD) for Operable Unit (OU) I former HWMF.

-   Periodic monitoring is necessary to determine effectiveness of
    cleanup operations of landscape soils in order to calculate a dose
    to biota.

Data Quality Objective Analysis

#  {#section-19 .KRob-heading-1}

Step 1: State the Problem

BNL has been in operation since 1947. This long history of operation has
included various large-scale experiments, as well as large user
facilities such as reactors and accelerators. The primary source of
potential contamination was the operation of reactors. Since all
reactors have been permanently shut down, the need for continued soil
and vegetation monitoring is less necessary and can be carried out under
a graded approach. Since air monitoring is conducted at six fixed
positions, it is reasonable to expect that any deposition of airborne
materials would occur at the same location. Therefore, in order to
support the air monitoring program, both soil and vegetation samples
should be obtained from the vicinity of the air monitoring locations
when radionuclides attributable to BNL or particulate contamination are
detected that may affect biota. The cleanup of the former HWMF has been
completed. Under the requirements of the Long Term Maintenance and
Monitoring Plan for OU I and V, vegetation and soil sampling should
occur in the first year and every five years after completion of cleanup
to document the success of the cleanup operation.

Step 2: Identify the Decision

The desired decisions for this monitoring program can be stated as
follows.

-   Will a graded approach to soil and vegetation monitoring using the
    results of air sampling be protective of the environment?

-   Are radionuclides being taken up by vegetation at the former HWMF,
    and are they also found in surface soils within this facility?

-   Are radionuclides being taken up by vegetation in the cleaned up
    landscape soils and 650 sump areas?

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   DOE-established dose to biota guidelines of 1 mrad/day for flora and
    fauna

-   Field Sampling Team field logs and records

-   Environmental Monitoring Standard Operating Procedures (SOPs)

-   Closure reports for Landscape Soils Remediation

-   Project work plans for Operable Units I, IV, and VI

-   Historic soil and vegetation data

-   Historic and current air monitoring data

-   Close-out report for the former HWMF

Step 4: Define the Study Boundaries

The boundaries of this study include the BNL site, as well as control
locations west and northwest of the Laboratory. Deposition of airborne
particulates is likely to occur at any location on site, but detection
is most likely in the downwind sectors. For this reason, soil and
vegetation samples will be taken primarily in the vicinity of air
monitoring stations when air monitoring indicates that sampling is
needed, or every 3-5 years. Air monitoring occurs on a routine basis and
allows for early detection of potential environmental releases. If
airborne contaminants that may affect biota are detected at levels above
historic background, soil and vegetation sampling can be carried out.
The close-out report for the former HWMF specifically identified the
former HWMF and its associated wetlands as a defined study area.

Step 5: Develop the Decision Rule

Decision 1

*Will a graded approach to soil and vegetation monitoring using results
of air sampling be protective of the environment?*

**If** air monitoring identifies particulates containing levels of
gamma-emitting radionuclides higher than historic background levels,
**then** soil and vegetation samples will be taken near the air station
with the higher than background detection levels.

**If** soil and vegetation sampling is triggered, and results indicate
an area of previously unknown contamination or levels higher than
established cleanup criteria, **then** an evaluation will be completed
under the EPD Environmental Event Response Procedure to determine a path
forward.

Decision 2

*Are radionuclides being taken up by vegetation at the former HWMF and
are they also found in surface soils within this facility.*

**If** soil and vegetation sampling results in the first year after
cleanup do not indicate radionuclides being taken up by plant and in the
surface soils at the former HWMF, **then** sampling will take place in
year five after cleanup, to reconfirm presence/absence of radionuclides
in vegetation and surface soils.

**If** soil and vegetation sampling results indicate radionuclides being
taken up by plants and in surface soils, **then** an evaluation will be
completed under the Environmental Event Response Procedure to determine
a path forward.

**Decision 3**

*Are radionuclides being taken up by vegetation in the cleaned up
landscape soils and 650 sump areas?*

**If** soil and vegetation sampling results from within historically
cleaned up landscape soils do not indicate radionuclides being taken up
by plants or in the surface soils, **then** sampling will take place
every five years to reconfirm the presence/absence of radionuclides in
vegetation and surface soils.

**If** soil and vegetation sampling results indicate radionuclides being
taken up by plants and in surface soils, **then** an evaluation will be
completed under the Environmental Event Response Procedure to determine
a path forward.

Step 6: Specify Acceptable Error Tolerances

Terrestrial vegetation and soil sampling will be conducted based on a
graded approach that relies on the detection of contaminants in small
mammals and air samples. Therefore, it is acceptable to act on
reasonable data. If air samples confirm the presence of contaminants
potentially affecting soil and vegetation (i.e., above historic
background levels), then it is prudent to obtain soil and vegetation
samples to verify effect or lack thereof in these media.

For vegetation and soil sampling within the former HWMF, 650 Sump area,
and from landscaped soils cleanup areas, analytical data showing
radionuclides above background should be reported with errors less than
20 percent. Values with errors greater than 20 percent will be reviewed
and may warrant additional sampling for verification.

Step 7: Optimize the Design

If air sampling indicates the presence of a contaminant in the
particulate filters above historic background levels, soil and
vegetation sampling will occur within 100 ft of the air monitoring
station. Four soil samples and four vegetation samples will be taken
following established procedures. One sample of each media will be taken
in each of the four major compass directions to document whether the
airborne contaminant is detectible in either the soil or vegetation.
When a small mammal is sampled and a positive result above 10 pCi/g wet
weight is obtained, the subject matter expert will investigate the
location and determine the sampling requirements and area to be covered.
Sampling triggered by small mammal data will initially not exceed 10
soil and 10 vegetation samples within the designated sampling area. When
soil and vegetation sampling occurs, at least one off-site soil and
vegetation sample must be obtained from established background
locations.

Soil and vegetation sampling will necessitate obtaining at least five
samples of each media in the upland area and two samples of sediment and
emergent vegetation from the eastern portions of the former HWMF
wetlands. Additionally, 10 samples of each media should be obtained from
the cleaned up landscape soils area and two samples of each media from
the 650 Sump area. The first year of sampling at the former HWMF was in
2006; the second round of sampling should occur in 2010.

**Table 8.5.1 2009 Terrestrial Soil and Vegetation Surveillance
Monitoring**

+------------+------------------+---------+-------------+------------+
| # Matrix   | # N              | # A     | # Frequency | # Type     |
|            | umber of Samples | nalysis |             |            |
+------------+------------------+---------+-------------+------------+
| Vegetation | 12 + 2QA         | Gamma   | Annual      | Grab       |
+------------+------------------+---------+-------------+------------+
| Soil       | 12 + 2QA         | Gamma   | Annual      | Grab       |
+------------+------------------+---------+-------------+------------+

#  {#section-20 .KRob-heading-1}

Total Sampling and Analysis Cost for Monitoring Program

The sampling program described in Step 7 will result in no net change in
cost.

FY2008 Costs \$14,637

FY2009 Costs \$14,637

Difference 0

See Appendix B for the monitoring program for this DQO.

*Intentionally Left Blank*

Deer and Small Mammal Sampling

**[DQO Start Date]{.smallcaps}** January 1, 2003

**[Revision Number/Date]{.smallcaps}** Rev. 2, November 30, 2007

**[Implementation Date]{.smallcaps}** January 1, 2009

**[Point of Contact]{.smallcaps}** Tim Green (631) 344-3091

#  {#section-21 .KRob-heading-1}

Summary of Proposed Changes

There are no proposed changes to this DQO in CY2009.

#  {#section-22 .KRob-heading-1}

Description and Technical Basis

BNL has documented the presence of the radionuclide cesium-137 (Cs-137)
within landscape soils and other operational areas on site. Faunal
monitoring of various wildlife species in 1992 identified the presence
of Cs-137 in the tissue of deer and other small mammals. Of all the
mammals inhabiting the Laboratory, deer are the only species that are in
the direct consumption pathway of humans. Deer are known to acquire
Cs-137 through the ingestion of vegetation that has Cs-137 uptake, as
well as by direct ingestion of contaminated soils. In 1996, BNL began a
program of sampling deer on and off site for gamma analysis of meat and
liver. Srontium-90 (Sr-90) analysis in bone was added to the program in
2000, in order to investigate levels present in this matrix. Statistical
analysis on the sampling requirements of deer taken through 1998
suggested that 25 samples on site and 40 samples off site were necessary
to have sufficient confidence in detecting the average presence of
Cs-137 within the deer population. Fewer samples were required on site
due to the fact that Cs-137 is known to be higher in on-site deer. The
higher number of off-site samples was needed to verify the lower
concentrations seen off site. It should be noted that in most years the
required number of samples has not been acquired due to the method of
acquisition (road-killed deer or hunter donations).

Landscape soils containing Cs-137 were remediated in 2000, with the
remaining contamination at or below assigned cleanup standards. Other
areas known to contain Cs-137, including the 650 Sump Outfall, Sewage
Treatment Plant (STP) sand filter beds, and the former Hazardous Waste
Management Facility (HWMF) were all completed in September 2005.

In 2000, BNL began sampling squirrels in order to build a baseline of
information on small mammals. Squirrels were chosen because of the ease
of obtaining samples, the similarity of their diet to that of deer
(except that deer also ingest soil), and their smaller home range. The
smaller home range enables Laboratory ecologists to determine where an
animal may have obtained contamination, should any be found. Sampling
squirrels also allows for a much broader understanding of where
radiological contamination on site exists, because samples can be
gathered across the site instead of relying on road kill, as in the
current deer-sampling program.

BNL now proposes to eliminate small mammal sampling for several reasons.
Sampling on a quarterly basis was more difficult than initially thought.
Additionally, the Laboratory has sufficient data that indicates that for
known contaminant monitoring, squirrels are suitable surrogates in
highly localized areas. Since BNL has conducted significant clean up of
contaminated soils, the need for any localized faunal sampling is
greatly reduced. The Laboratory recommends continuation of deer sampling
as the primary mechanism to document environmental effects on
terrestrial fauna.

Drivers for Monitoring Being Conducted Under This Program

#   {#section-23 .KRob-heading-1}

  ------- ---------------------------------------------------------------
          Compliance

          Support compliance

  x       Surveillance

          Restoration
  ------- ---------------------------------------------------------------

-   DOE Order 450.1A, Environmental Protection Program (2008), requires
    that DOE sites maintain surveillance to monitor the effects, if any,
    of DOE activities on on- and off-site environment and natural
    resources. DOE Order 5400.5, Radiation Protection of the Public and
    Environment (1990), requires DOE sites to determine radiological
    impacts to the public and environment.

-   Surveillance monitoring to determine impacts from past practices can
    be considered a "best management practice" to ensure the early
    detection of potential radiological contamination in order to better
    protect the public and environment.

Data Quality Objective Analysis

Step 1: State the Problem

Past practices at BNL have resulted in soil contaminated with cesium-137
(Cs-137). Although most areas of radiological soil contamination have
been remediated, two areas with higher contamination (Sewage Treatment
Plant \[STP\] and the former Hazardous Waste Management Facility
\[HWMF\]) are either in the process of cleanup or scheduled for cleanup
in the next few years. Regardless of when cleanup is completed, low
levels of radiological contamination will persist in the environment and
may be available to wildlife through the consumption of plants via
uptake from the soil or through the direct consumption of contaminated
soils. To determine the impact of Cs-137 on wildlife and the potential
for transfer to the human food pathway, the Laboratory should monitor
the deer population to track and trend Cs-137 levels in tissues that are
normally eaten. In addition, since small mammals have smaller home
ranges, a program to monitor small mammals should be maintained to
refine the understanding of Cs-137 contamination on site.

Step 2: Identify the Decision

The desired decisions for the deer and small mammal surveillance
monitoring programs are:

-   Are Cs-137 levels in deer meat above levels considered protective of
    human health?

-   Are the Cs-137 levels in deer continuing to decline after
    remediation of contaminated soils?

```{=html}
<!-- -->
```
-   Are levels of Cs-137 in deer from areas within one mile of BNL
    identical to on-site levels?

-   Do small mammals (squirrels) accurately depict Cs-137 contamination
    across the Laboratory site? (Removed for 2008)

-   Can small mammals be a surrogate sampling medium for deer? (Removed
    for 2008)

Step 3: Identify Inputs to the Decision

Inputs necessary to support the decisions in Step 2 include:

-   DOE-established dose guideline of 10 mrem/year for the general
    public

-   New York State Department of Health (NYSDOH) guideline consumption
    rate, 64 lb/year/person of deer meat \> 6.9 pCi/g of Cs-137 (wet
    weight)

-   Field Sampling Team field logs and records

-   Environmental Monitoring Standard Operating Procedures (SOPs)

-   Documented remediation of radiologically-contaminated soils

-   Records of Decision (RODs) for OU I, IV, and VI

-   Historic vegetation sampling results

-   Historic soil sampling results

-   Special vegetation sampling results

-   Historic deer and small mammal sampling results

Step 4: Define the Study Boundaries

The boundaries of the study include a comparison of deer taken on site
and those taken within 1 mile of BNL's boundary, as well as deer taken
more than 1 mile from BNL (generally considered background or control
deer). Sampling is conducted annually (with trends developed for a
rolling 5-year period) and is conducted as evenly across months as can
be achieved through opportunistic sampling of deer killed in vehicle
accidents.

The study boundary for small mammal sampling is within the BNL property,
with control samples taken at distances greater than 1 mile from the
Laboratory. Sampling is on an annual basis, with sample events spread
across the four calendar quarters.

Step 5: Develop the Decision Rules

Decision 1

*Are Cs-137 levels in deer meat above levels considered protective of
human health?*

**If** the monitoring data show the data to be consistently below 6.9
pCi/g wet weight, **then** the monitoring will be maintained.

**If** deer meat samples suggest an average annual value of Cs-137
higher than 6.9 pCi/g wet weight, or if a single value in a deer sample
is higher than 11.64 pCi/g wet weight (highest value to date), **then**
an evaluation will be conducted under the EPD Environmental Event
Response Procedure to determine the path forward.

Decision 2

*Are the Cs-137 levels in deer continuing to decline after remediation
of contaminated soils?*

**If** Cs-137 levels in on-site deer meat samples indicate a continued
decline after remediation of contaminated soils, **then** monitoring
will be maintained.

**If** Cs-137 levels in on-site deer reach background levels, **then** a
review of the program and data will determine whether the program should
continue.

**If** Cs-137 values in on-site deer meat samples begin to increase
after remediation of contaminated soils, **then** an evaluation will be
conducted under the EPD Environmental Event Response Procedure to
determine the path forward.

Decision 3

*Are levels of Cs-137 in deer from areas within one mile of BNL
identical to on-site levels?*

**If** Cs-137 concentrations in deer meat samples taken within 1 mile of
BNL are statistically the same as values on site, **then** monitoring
will be maintained.

**If** Cs-137 concentrations in deer meat samples taken within 1 mile of
BNL indicate an increasing trend or steady trend compared to on-site
values, **then** an investigation will be conducted under the EPD
Environmental Event Response Procedure to determine the path forward.

Decision 4

*Do small squirrels accurately depict Cs-137 contamination across the
Laboratory site?*

**If** squirrel sampling clearly shows Cs-137 contamination in wildlife
across the Laboratory site, **then** the sampling program will be
reviewed for a possible reduction in deer sampling and increase in
squirrel sampling. Difficulty in obtaining significant sample numbers
prevents implementing this decision rule.

**If** squirrel sampling does not appear to provide a clear indication
of Cs-137 contamination in wildlife across the Laboratory, **then**
small mammal sampling will be reviewed for reduction or elimination. Due
to the difficulty in obtaining significant numbers of squirrels, this
decision should be eliminated, as should sampling squirrels.

Decision 5

*Can small mammals be an alternate sampling medium for deer?*

**If** statistical comparison of on-site small mammal sampling data and
on-site deer data for Cs-137 indicates that small mammal data are
comparable to deer data, **then** the faunal monitoring program will be
evaluated for a possible reduction in deer sampling and increased
sampling of small mammals.

**If** statistical comparison of small mammal and deer data indicates
that they are not similar or comparable, **then** the small mammal
sampling will be considered for elimination.

While it appears that small mammals contain similar amounts of Cs-137,
difficulty in obtaining sufficient numbers prevents them from being a
good alternative to continued deer sampling.

Step 6: Specify Acceptable Error Tolerances

The presence of Cs-137 in some deer samples indicates that Cs-137 in the
environment is available to humans through the ingestion pathway.
Hunters take approximately 2,000 deer each year in Suffolk County, some
of which are obtained within 1 mile of BNL. In the past, high values of
Cs-137 in deer have been examined, considered to be accurate, and
reported to the general public, and then subsequently discovered to be
in error. The values were, in fact, much lower than initially reported.
This "false positive" caused substantial concern to the community at
large. False positives should be minimized. All values greater than
historic high values will be investigated and verified through multiple
retesting. Cs-137 is the single highest contributing factor for
potential exposures to the general public from Laboratory operations.
BNL must have an accurate understanding of Cs-137 distribution in deer.

Small mammal sampling was initiated in 2000 to determine its
appropriateness as a surrogate for deer sampling. Out of 20 on-site
samples over two years, three samples could be considered high for
Cs-137 in comparison to all others. The three samples originated near
known sources of Cs-137 contamination. Because squirrels are available
to other wildlife as a food source, having an understanding of where
squirrels are acquiring Cs-137 is important in order to protect other
wildlife. Accuracy of data is important to verify the presence or
absence of Cs-137 concentrations in the squirrels sampled. Due to
difficulties in obtaining samples over the past three years, this
sampling program should be eliminated.

Step 7: Optimize the Design

To get sufficient data for comparison and in order to be statistically
sound, samples must be taken both on and off site. Past efforts indicate
that 25 on-site and 40 off-site samples should be obtained annually in
order to produce a statistically accurate average concentration for
Cs-137 in deer tissues. The lower number of on-site samples is due to
the higher concentration of Cs-137 in on-site deer, which results in
better detection. The higher number of samples off site is necessary due
to the high incidence of non-detections and very low detectable levels
in off-site deer. All deer sampled will be tested for gamma-emitting
radionuclides in the flesh (meat) and liver (when available), and
strontium-90 (Sr-90) in bone (when available).

BNL has historically relied on opportunistic sampling through hunter
donations and notification of road-killed deer on site. In 2002, the
Laboratory acquired the ability to selectively sample deer on site.
Therefore, BNL should utilize both methods of obtaining deer for
sampling purposes on site (e.g., continue utilizing road-killed deer,
but supplement this by obtaining the number of deer necessary to reach
the required 25). Selective sampling should utilize five designated
sampling locations that have been established on site. Off-site sampling
of up to 40 deer will continue through collection of road-killed deer
and acceptance of hunter donations and deer obtained through donation by
other agencies, such as the New York State Department of Environmental
Conservation (NYSDEC) and U.S. Fish and Wildlife Services (FWS).

**Table 8.6.1 2009 Deer and Small Mammal Sampling Program**

+--------------+---------------+---------+--------------+------------+
| # Deer       | # N           | # A     | *            | **Sample   |
|              | o. of Samples | nalysis | *Frequency** | Type**     |
+--------------+---------------+---------+--------------+------------+
| Flesh (meat) | 25 on site    | Gamma   | Annually     | Grab       |
|              |               |         |              |            |
|              | 40 off site   |         |              |            |
|              |               |         |              |            |
|              | \+ 6 QA       |         |              |            |
+--------------+---------------+---------+--------------+------------+
| Liver (as    | 25 on site    | Gamma   | Annually     | Grab       |
| available)   |               |         |              |            |
|              | 40 off site   |         |              |            |
|              |               |         |              |            |
|              | +6 QA         |         |              |            |
+--------------+---------------+---------+--------------+------------+
| Bone (as     | 25 on site    | Sr-90   | Annually     | Grab       |
| available)   |               |         |              |            |
|              | 40 off site   |         |              |            |
|              |               |         |              |            |
|              | \+ 6 QA       |         |              |            |
+--------------+---------------+---------+--------------+------------+

Total Sampling and Analysis Cost for Monitoring Program

No net change in cost.

CY2008 cost \$42,606

CY2009 Cost \$42,606

Difference \$0

See Appendix B for the monitoring program for this DQO.

*Intentionally Left Blank*