EPA/ROD/R02-99/028

1999

EPA Superfund

Record of Decision:

WELSBACH & GENERAL GAS MANTLE (CAMDENRADIATION)EPA ID: NJD986620995OU 01CAMDEN AND GLOUCESTER CIT, NJ07/23/1999

RECORD OF DECISION

DECISION SUMMARY

Welsbach/General Gas Mantle Contamination Site

Glouster City & Camden, Camden County, New Jersey

United States Environmental Protection Agency

Region 2

New York, New York

July 1999

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Welsbach/General Gas Mantle Contamination Superfund Site

Gloucester City & Camden, Camden County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's selection

of a remedial action to address soil and building material contamination at the Welsbach/General

Gas Mantle Contamination Site (the “Site”), in accordance with the requirements of the

Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended

(CERCLA), 42 U.S.C. §9601-9675, and to the extent practicable, the National Oil and Hazardous

Substances Pollution Contingency Plan (NCP), as amended, 40 CFR Part 300. This decision

document explains the factual and legal basis for selecting the remedy for the first operable unit of

this Site.

The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the

planned remedial action in accordance with Section 121 of CERCLA. The NJDEP concurs with

the selected remedy (see Appendix IV). The information supporting this remedial action is

contained in the Administrative Record for the Site, the index of which can be found in Appendix

III of this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Welsbach/General Gas Mantle

Contamination Site, if not addressed by implementing the response action selected in this ROD,

may present an imminent and substantial endangerment to public health, welfare, or the

environment.

DESCRIPTION OF THE SELECTED REMEDY

The remedy described in this document represents the first of three planned remedial actions or

operable units for the Welsbach/General Gas Mantle Contamination Site. It will address

radiologically-contaminated soil and building materials at the former Welsbach and General Gas

Mantle facilities and properties in the vicinity of these facilities. For the second operable unit at

the site, the current owner of the former Welsbach facility is performing a remedial investigation

and feasibility study on the last remaining Welsbach era building. A third operable unit is planned

to investigate potential site impacts to groundwater, surface water, sediments, and wetlands. The

major components of the selected remedy include:

! Excavation/removal of soil and waste materials with radiological contamination above

remedial action objectives from the former Welsbach and General Gas Mantle Facilities:

! Excavation/removal of soil and waste materials with radiological contamination above

remedial action objectives from the residential and commercial properties in the vicinity of

two former gas mantle facilities;

! Off-site disposal of the radiologically-contaminated soil and waste materials;

! Decontamination and demolition of the General Gas Mantle Building; and

! Appropriate environmental monitoring to ensure the effectiveness of the remedy.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy meets the requirements for remedial actions set forth in Section 121 of

CERCLA, in that it: (1) is protective of human health and the environment; (2) complies with

Federal and State requirements that are legally applicable or relevant and appropriate to the extent

practicable; (3) is cost-effective, and (4) utilizes permanent solutions and alternative treatment (or

resource recovery) technologies to the maximum extent practicable. However, because treatment

of the principal threats of the Site was not found to be practicable, this remedy does not satisfy

the statutory preference for treatment as a principal element.

Because this remedy will not result in hazardous substances remaining on the remediated

properties above levels that allow for unlimited use and unrestricted exposure, a five-year review

of this action will not be required.

I certify that the remedy selected for this Site is protective of human health and the environment.

TABLE OF CONTENTSpage

SITE NAME, LOCATION AND DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . 2

HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . 4

SCOPE AND ROLE OF RESPONSE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

THE NATURE OF RADIONUCLIDES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

DESCRIPTION OF REMEDIAL ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . 16

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . 21

SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

DOCUMENTATION OF SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . . . . 29

APPENDICES

APPENDIX I FIGURESAPPENDIX II TABLESAPPENDIX III ADMINISTRATIVE RECORD INDEXAPPENDIX IV STATE LETTERAPPENDIX V RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

Site Background

The Welsbach/General Gas Mantle Contamination site (Welsbach/GGM or Site) is a multi-

property site located in Gloucester City and Camden, Camden County, New Jersey. EPA initially

identified the Site in 1980 during an archive search conducted as part of the investigation of the

U.S. Radium Corporation Superfund site located in Orange, New Jersey. Historical U.S. Radium

Corporation files indicated that radiological materials were purchased by U.S. Radium from the

Welsbach Corporation during the 1920s.

Between the 1890s and 1940s, the Welsbach Company (Welsbach) manufactured gas mantles at

its facility in Gloucester City, New Jersey. Welsbach was a major manufacturer and distributer of

gas mantles until gas lighting was replaced by the electric light. Welsbach extracted the

radioactive element thorium from monazite ore and used it in the gas mantle manufacturing

process. Thorium causes the mantles to glow more brightly when heated. A second gas mantle

manufacturing facility, known as the General Gas Mantle Company (GGM), was located in

Camden, New Jersey. GGM operated from 1915 to approximately 1940.

In May 1981, EPA conducted an aerial radiological survey of the Camden and Gloucester City

area to investigate for radioactive contaminants. The survey encompassed a 20 square kilometer

area surrounding the former locations of the Welsbach and GGM facilities. Five areas with

elevated gamma radiation were identified from the aerial survey; they included the locations of the

two former gas mantle manufacturing facilities and three mainly residential areas in both Camden

and Gloucester City. In 1993, EPA reanalyzed the data from the aerial survey. Based on this

revised information, EPA identified a sixth potential radiologically-contaminated area which

includes two vacant lots in Gloucester City.

In the early 1990s, NJDEP conducted detailed radiological investigations at more than 1,000

properties located throughout the original five study areas. Radiological contamination was

identified at the two former gas mantle facilities and at approximately 100 properties located near

the two facilities. In 1996, the Welsbach/GGM site was placed on National Priorities List (NPL)

because of the presence of radioactive contaminants.

EPA divided the Welsbach/GGM site into six study areas in Camden and Gloucester City, New

Jersey (Figure 1). A brief description of each study area and its current land use is presented

below:

• Study Area One: includes the former GGM Facility and residential and commercial

properties which surround the facility (Figure 2.) The former GGM Facility is located in a

mixed industrial, commercial, and residential zoned section of Camden.

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• Study Area Two: includes the location of the former Welsbach Facility and nearby

residential/commercial properties. The former Welsbach Company is situated in industrial

zoned section of Gloucester City with residential properties to the immediate east (Figure

3.)

• Study Area Three: includes residential and recreational properties in Gloucester City,

including the Gloucester City Swim Club and the Johnson Boulevard Land Preserve.

• Study Area Four: includes residential properties in the Fairview section of Camden.

• Study Area Five: includes residential properties, vacant land properties, and two

municipal parks near Temple Avenue and the South Branch of Newton Creek in

Gloucester City.

• Study Area Six: includes two vacant lots in a residential zoned area of Gloucester City.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Welsbach and the GGM Facilities have complex histories of changes in name, ownership, and

operation. Specific details are discussed in the paragraphs below.

The United Gas Improvement Company, which formed Welsbach, purchased the patent rights to

manufacture thorium-containing gas mantles in the 1880s from Dr. Carl Auer von Welsbach. The

process for manufacturing the Welsbach gas mantle used a highly purified solution of 99 percent

thorium nitrate and 1 percent cerium nitrate as a "lighting fluid" in distilled water. A fabric sock

was then dipped into the thorium solution to create the gas mantle. Thorium caused the gas

mantle, when lit, to give off a very bright white light.

The commercial source of thorium and cerium is a mineral known as monazite sand. Monazite

sand contains approximately 5-6 percent thorium oxide and 20-30 percent cerium oxide. Thorium

was typically extracted from the monazite ore by heating the ore in a sulfuric acid solution. The

thorium and other rare earth elements would go into solution, while the radium-228 remained in

the tailings of insoluble sulfates. Around 1915, Welsbach started using and selling the radium-228

for use in luminescent paint. For a number of years, Welsbach was the largest manufacturer of gas

mantles in the world, making up to 250,000 mantles per day at its peak.

Welsbach also made gas room heaters, gas storage water heaters, gas and electrical fixtures,

electrical refrigerators, plumbing supplies and lacquers. Manufacturing operations at the Welsbach

facility began as early as 1882 and lasted until the 1940s. The facility property covered an area of

about 21 acres, and consisted of about 20 buildings.

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In 1942, the U.S. Government acquired the Welsbach Facility and sold it to the Randall

Corporation in 1948. Randall leased the property to the Radio Corporation of America. Victor

Division. A series of intervening owners followed. In May,1976, the property was purchased by

Holt Hauling and Warehousing, Inc. (Holt), the current owner of the property. Holt operates a

cargo and overseas shipping business. None of the owners of the property after Welsbach dealt

with radioactive materials.

Only one Welsbach era-building, the Armstrong Building, is still present on the property. There is

no information available on when the other Welsbach-era buildings were demolished. The remedy

for the Armstrong Building is not part of this decision.

The former gas mantle manufacturing facility in Camden was owned and operated by the GGM

Company from 1912 to 1941. There is little information available regarding activities at GGM,

other than it used and resold radium and thorium.

Between 1941 and 1978, there was a total of seven different private owners of the property.

Based on current information, none of these operations involved radioactive materials. In January

1978, the southern portion of the property was purchased by the Dynamic Blending Company. In

October 1988, the northern portion of the property was purchased by Ste-Lar Textiles. In 1992,

NJDEP removed radiologically-contaminated fabrics, relocated Ste-Lar, and sealed up the GGM

building on the northern property to restrict access.

During the years that Welsbach and GGM operated, ore tailings were used for fill at properties in

the vicinity of the facilities. It is also reported that building debris from the former Welsbach

Facility may have been disposed of as fill in the area. In addition, workers from the former

Welsbach and GGM Facilities may have brought contamination home with them. These properties

associated with radiological waste from the Welsbach and GGM Facilities are collectively termed

Vicinity Properties.

In 1991, NJDEP initiated a radiological investigation at more than 1,000 properties located

throughout Study Areas 1 through 5. At properties where NJDEP determined that exposure levels

were unacceptable (or posed an immediate health risk), it performed interim remedial measures.

These measures included the installation of radon/thoron ventilation systems and placement of

concrete or lead sheeting to shield gamma radiation. In addition, NJDEP restricted access to

outdoor areas which exceeded its action levels.

In 1998, EPA identified a 100 square foot area in a Gloucester City Park, located in Study Area 5,

that had elevated levels of gamma radiation at the surface. In December 1998, EPA performed a

removal action to reduce exposure to these elevated levels. EPA excavated the top three feet of

radiologically-contaminated soil, disposed of this soil off-site at a permitted facility, and replaced

the waste material with clean fill.

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Both the Welsbach Company and the GGM Company went out of business in the early 1940s, andEPA has been unable to identify any successor companies. In September 1997. EPA entered intoan Administrative Order on Consent (AOC) with Holt, the current owner of the former WelsbachFacility. Under the terms of the AOC, Holt agreed to perform a Remedial Investigation andFeasibility Study (RI/FS) on the Armstrong Building. Holt has also submitted information tosupport its position that it is not liable for response costs at the former Welsbach facility. EPA iscurrently evaluating this information.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS report, the Proposed Plan and supporting documentation were made available to thepublic in the administrative record file at the Superfund Document Center at EPA Region II, 290Broadway, 18th Floor, New York, New York 10007 and at the following repositories: City ofCamden Main Library, 418 Federal Street, Camden, New Jersey 08103; the Hynes Center, 1855South 4th Street, Camden, New Jersey 80104; and the Gloucester City Public Library, Monmouthand Hudson Streets, Gloucester City, New Jersey 08030. Notices of availability for thedocuments in the administrative record were published in the Philadelphia Inquirer on February 1,1999, the Courier-Post on February 2, 1999, and the Gloucester City News on February 4, 1999.The public comment period which related to these documents was held from February 1, 1999 toMarch 3, 1999.

EPA conducted public meetings in both Gloucester City and Camden to inform local officials andinterested citizens about the Superfund process, to review proposed remedial activities at the Siteand receive comments on the Proposed Plan, and to respond to questions from area residents andother interested parties. Meetings were held on February 23, 1999, at the Pine Grove Fire Station#2 in Gloucester City, and on February 24, 1999, at the Camden County Municipal UtilitiesAuthorities Auditorium in Camden. Responses to the comments received at the public meeting areincluded in the Responsiveness Summary (see Appendix V). The City of Gloucester Citysubmitted a resolution supporting the proposed remedy. No other written comments werereceived during the public comment period.

This Record of Decision (ROD) document presents the selected remedial action for theWelsbach/GGM site, chosen in accordance with the Comprehensive Environmental Response,Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act, and, to the extent practicable, the National Oil and Hazardous SubstancesPollution Contingency Plan (NCP). The selection of the remedy for this site is based on theadministrative record.

SCOPE AND ROLE OF RESPONSE ACTION

This action is the first operable unit or phase taken to address the radiological contamination atthe Site. This action will address the radiologically-contaminated soil and building materials at theVicinity Properties and the former Welsbach and GGM Facilities. For the second operable

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unit at the site, Holt is performing an RI/FS for the Armstrong Building. A remedy for this second

operable unit will be selected in a future ROD. A third operable unit is planned to investigate

potential site impacts to groundwater, surface water, sediments, and wetlands.

THE NATURE OF RADIONUCLIDES

A radionuclide is an element that spontaneously changes or “decays” into another element

through natural processes. Radionuclides are present in trace amounts in all rocks and soils, and

consist primarily of elements of the uranium-238 and thorium-232 decay series. There are

approximately 1,700 different unstable atomic species or radionuclides. These include both

naturally occurring and man-made radionuclides.

The radionuclides of concern in the wastes which originated at the former Welsbach and GGM

Facilities are members of the uranium and thoriurn decay series. There are 14 unique

radionuclides in the uranium decay series and 11 unique radionuclides in the thoriurn decay series

which precede the formation of stable lead (Pb-206 or Pb-208). Alpha, beta, and gamma radiation

are emitted from the various members of the two decay series. The primary nuclides of concern

are Thorium-232,-Radium-226, and radon gas (Radon-222 and Radon-220.)

Each radionuclide has its own unique characteristic “fingerprint,” consisting of three parameters:

! The radioactive half-life describes the amount of time in which half of any given number

of atoms of a radionuclide will decay.

! The mode of decay refers to the type(s) of particles or electromagnetic rays emitted from

the radionuclide as it decays. These types include alpha and beta particles, and gamma

rays.

! The amount of energy carried away from the atom by the particles or rays is radionuclide

specific. It is the transfer of this energy to living tissue which may cause biological

effects.

When radionuclides decay, they emit energy in the form of radiation. The decaying radionuclide is

often called the “parent”, and the radionuclide produced is called the “decay product”. A quantity

of radioactive material is measured by its rate of decay, expressed by the unit Curie (Ci), which is

equal to 2.22 x 1012 (2.22 trillion) disintegrating atoms per minute. A more convenient unit for

expressing environmental radioactivity is the picoCurie (pCi), which is equal to 1 x 10-12 “ (one

trillionth) Ci. Table 1 summarizes the common units of measure for radionuclides that are

discussed below.

Radium-226 is a naturally occurring, radioactive, metallic element formed from the decay of

uranium. In its decay, Radium-226 forms Radon-222 or radon gas. Radon gas is colorless,

odorless, radioactive and inert; therefore, it can move easily through soil to the ground surface or

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into houses, Within a matter of days, the radon gas itself decays into a series of radioactive decay

products. While radon gas in the outdoor air dissipates quickly, the concentration of radon decay

products in the indoor air can build up over time. Exposure to the energy released by these

various decaying atoms can result in adverse health effects. For radon decay products, a special

unit called Working Level (WL) has been developed. Working Level is defined as any

combination of short-lived radon decay products in 1 liter of air that will result in the ultimate

emission of 1.3 x 105 Mega-electron Volts of potential alpha energy. This value is approximately

equal to the alpha energy released from the decay of progeny in equilibrium with 100 pCi of

Radon-222.

Thorium-232 is also a naturally occurring radionuclide and is the initial radionuclide of the

thorium decay series. Its decay products include Radium-228 and Radon-220. Radon-220 is also

known as thoron. Thoron and its decay products have extremely short half-lives that usually

prevent them from concentrating to any appreciable extent in indoor air. However, if a significant

source of thoron exists within, beneath, or adjacent to a structure (such as the thorium and

Radium-228 found in Welsbach/GGM site wastes), thoron decay products can reach

concentrations which create health risks.

SUMMARY OF SITE CHARACTERISTICS

In September 1997, EPA started an RI to characterize the nature and extent of contamination at

the Welsbach Facility, GGM Facility, and 20 of the radiologically-contaminated properties

identified by NJDEP in the vicinity of Welsbach and GGM. The work was conducted by Malcolm

Pirnie, Inc., under contract to EPA. In order to develop a cleanup strategy for the Site, the RI

field investigations were divided into three property categories, as follows:

! Former Welsbach Company Facility;

! Former General Gas Mantle Company Facility;

! Vicinity Properties

Property Investigations

EPA conducted both chemical and radiological characterizations of the former Welsbach and

GGM Facilities to define the went of contamination. EPA also performed a radiological

investigation on 20 of the potentially contaminated Vicinity Properties identified by NJDEP. Only

20 Vicinity Properties were investigated during the RI so that EPA could confirm the NJDEP data

and expedite the development of cleanup alternatives. Based on evaluation of the NJDEP data,

EPA segregated the properties investigated by NJDEP into the following three categories. Table 2

summarizes the results of the property classification.

1) Properties where there is no evidence of contamination related to the Welsbach/GGM site.

These are properties which have surface exposure rates less than 13 µR/h, radon progeny

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measurements less than 0.02 WL, and radon gas levels less than 4.0 pCi/l. The exposure raterepresents the upper level of the range of natural background.

2) “Suspect Properties” - are properties for which either elevated levels (i.e., above background)of radioactivity were detected by NJDEP or properties situated adjacent to known contaminatedproperties; and

3) “Contaminated Properties” - are properties with levels of radioactivity which potentiallywarrant remedial action (i.e. properties with either exposure rates greater than 30 µR/h., radonprogeny greater than 0.02 WL, radon gas levels greater than 4.0 pCi/l, or thorium or radiumconcentration in the soil greater than 5 pCi/g.)

EPA will investigate the remaining Contaminated Properties which were not studied in the RI andthe Suspect Properties during the remedial design phase of this cleanup. EPA estimates that it willstudy about 600 properties during the design phase to determine exactly which properties requirecleanup. This additional work may include sampling for chemical analysis, where deemedappropriate when considering past ownership and historic information. Table 3 summarizes thevolume of contaminated soil and debris at the Contaminated Properties. Field activities conductedas part of the RI included the following:

! Radon measurements! Radon decay product Working Level measurements! Gamma radiation surface and one-meter height exposure rate surveys! Surface and subsurface soil sampling! Downhole gamma radiation logging! Total surface beta surveys and removable surface alpha and beta sampling! Structural materials sampling for radionuclides (in some buildings)! Chemical sampling for metals, volatile organic compounds, and semi-volatile organic

compounds at the two former gas mantle facilities

The results of the RI can be summarized as follows.

Former Welsbach Facility Investigation

Most of the radiological contamination is located in the area of what is believed to be the locationof a former Welsbach building that was demolished in the 1970s. This area is currently used forstorage. However, there are smaller areas of contamination scattered throughout the property.The soil in these areas is contaminated with elevated concentrations of the thoriurn and uraniumdecay series radionuclides. These radionuclides are principal threat wastes. Subsurfacecontamination on the Welsbach facility averages about 11 feet in depth. An estimated 27,200cubic yards of soil/buried debris have thoriurn and/or radium concentrations exceeding 5 pCi/g.Radium and thorium, concentrations in soil ranged from background (about 1 pCi/g for each) toas high as 455 pCi/g and 1,190 pCi/g, respectively. Surface gamma exposure

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rates associated with the contaminated soils ranged from background (less than 10 micro

Roentgen per hour [µ/R/h]) to 780 µR/h. The highest readings were associated with a large fill

area identified in the middle of the storage area.

Low levels of chemical contaminants were also identified at the former Welsbach Facility.

Contaminants of potential concern include semi-volatile organic compounds and arsenic. These

contaminants may be indicative of “Historic Fill”. If this is confirmed during the remedial design

and these contaminants are not comingled with the radiological contaminants of concern, then

there may be a need to remediate such historic contaminants.

Former General Gas Mantle Facility Investigation

Elevated concentrations of thorium and uranium decay series radionuclides were identified in soils

on the former GGM property. Contamination was generally limited to the top six to eight feet,

although contamination in some areas of South Fourth Street and the GGM Courtyard ranged

from 12 to 16 feet in depth. An estimated 900 cubic yards of soil have thorium and/or radium

concentrations which exceeded 5 pCi/g. Radium and thorium concentrations in soil ranged from

background to as high as 172 pCi/g and 149 pCi/g, respectively.

Surface gamma exposure rates associated with the contaminated soils ranged from background

(less than 10 µR/h) to 380 µR/h. Only localized areas of surface contamination were identified

outdoors. Most of the outdoor contamination is located in the area of South Fourth Street.

However, EPA identified some smaller areas of contamination in the alleyway behind the

property. The contamination also extended onto some backyards of neighboring residential

properties.

Elevated levels of surface contamination were observed in many areas inside the former GGM

building. Levels as high as 2.33 microCi per square meter(µCi/m2 ) were observed. Indoor gamma

exposure rates ranged from background to 900 µR/h. An estimated 1,460 cubic yards of

contaminated structural materials in the building itself were identified, with thorium

concentrations as high as 750 pCi/g. In the basement of the former GGM building, radon decay

product concentrations measured 1.7 WL, compared to an average background level of 0.005

WL.

Certain semi-volatile organic compounds and metals were identified in the outdoor portions of the

former GGM Facility. These were, however, at such low levels that they are not of concern.

These contaminants may be indicative of “Historic Fill”. If this is confirmed during the remedial

design and these contaminants are not comingled with the radiological contaminants of concern,

then there may be a need to remediate such historic contaminants.

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Vicinity Property Investigation

EPA investigated 20 properties in Camden and Gloucester City for radiological contamination as

part of the RI. EPA compared the data from these properties to information collected from earlier

NJDEP investigations on over 1000 properties and determined that the data were comparable.

Contaminated soil averaged about two to three feet in depth on most residential properties. On a

few properties, contamination extended to 10 feet in depth. Some site properties have indoor

radon gas concentrations or soil radionuclide concentrations which pose a long-term risk to

human health.

Based on the comparison of EPA and NJDEP data, EPA identified a total of 54 properties as

having contamination above the cleanup levels. During the remedial design phase, EPA will

delineate the extent of contamination on each of these properties in order to design a cleanup plan

for each property.

During the remedial design, EPA will also investigate approximately 600 additional properties that

are either adjacent to the known contaminated properties or have gamma exposure rates slightly

above background levels. If contamination above the cleanup objectives is found on any of these

Suspect Properties, EPA will delineate the extent of this contamination and design a cleanup plan

for those properties.

Based on its review of the NJDEP data, EPA determined that 449 out of the approximately 1,000

properties NJDEP investigated showed no evidence of contamination. These properties had

surface gamma exposure rates less than the upper range of natural background, radon progeny

less than 0.02 WL, and radon gas levels below 4.0 pCi/l.

Current and Future Land Use

The site properties and the surrounding areas consist of industrial, commercial, and residential

zoning districts. Study Area 1 is located in an industrial-zoned section of Camden with residential

properties east of the former GGM Facility. In Study Area 2, the former Welsbach Facility is

situated in an industrial-zoned section of Gloucester City with residential properties to the

immediate east. Study Area 3 consists of residential properties, a private swim club, and a land

preserve. Study Area 4 consists entirely of residential properties. Residential properties and two

municipal parks comprise Study Area 5. Study Area 6 consists of vacant land in a residential area.

No significant changes in land use are anticipated, except in the area of GGM where there is a

possibility that some residential areas may be rezoned for commercial uses. The former GGM

facility is bordered by residential homes located on Arlington Street in Camden. Most of the

homes on Arlington Street are abandoned and there is debate within the community, given the

industrial nature of the area, whether to rezone this area to allow for commercial development or

leave it residential. Whether zoning changes will actually be made is uncertain at this time.

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SUMMARY OF SITE RISKS

A baseline risk assessment was conducted for the former Welsbach Facility, the former GGMFacility, and the Vicinity Properties using analytical data obtained during the RI. The baseline riskassessment estimates the human health risk which could result from the contamination at a site ifno remedial action were taken.

Ecological risks, that is, the risks to aquatic and terrestrial wildlife, were not evaluated for thisoperable unit. However, EPA compared the levels of radioactive exposure to various species withthe cleanup criteria. Based on this comparison, EPA determined that the cleanup criteria will beprotective of ecological receptors for this operable unit. An Ecological Risk Assessment will beconducted in a future RI to evaluate the potential for adverse effects to aquatic and terrestrialwildlife in accordance with Ecological Risk Assessment Guidance for Superfund, Process forDesigning and Conducting Ecological Risk Assessments (EPA 540-R-97-006).

To evaluate human health risks, a four-step process was used for assessing site-related risks for areasonable maximum exposure scenario. These steps are: Hazard Identification - identified thecontaminants of concern at the site based on several factors such as toxicity, frequency ofoccurrence. and concentration; Exposure Assessment - estimated the magnitude of actual and/orpotential human exposures, the frequency and duration of these exposures, and the pathways(e.g., ingesting contaminated soil) by which humans are potentially exposed; Toxicity Assessment- determined the types of adverse health effects associated with exposures to site contaminants,and the relationship between magnitude of exposure dose) and severity of adverse effects(response); and Risk Characterization - summarized and combined outputs of the exposure andtoxicity assessments to provide a quantitative (e.g., one-in-a-million excess cancer risk)assessment of site-related risks.

For risk assessment purposes, individual contaminants are typically separated into two categoriesof health hazard depending on whether they exhibit carcinogenic effects (causing cancer) ornoncarcinogenic effects (causing health effects other than cancer.) Radionuclides from theuranium and thoriurn decay series (e.g., radium, thorium, radon, and radon decay products) areknown human carcinogens. Nonradiological chemical contaminants (e.g., PAHs and arsenic) mayexhibit both carcinogenic and noncarcinogenic health effects.

EPA's acceptable cancer risk range is 10-4 to 10-6, which can be interpreted to mean that anindividual may have a one in 10,000 to one in 1,000,000 increased chance of developing cancerbecause of site-related exposure to a carcinogen. EPA usually initiates remedial action at a sitewhen the risk estimate exceeds this range.

Human health risks were estimated for both radionuclides and chemicals of concern at the formerWelsbach and GGM Facilities, and for radionuclides concern at the Vicinity Properties. Buildingmaterials and/or soil were the environmental media of concern. Following EPA guidance, riskswere estimated based, on a “reasonable maximum exposure” scenario. Risks were

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estimated as a result of exposure to site-related carcinogens based on a number of assumptionsthat result in an overall exposure estimate that is conservative but within a realistic range ofexposure.

In assessing potential human health risks from exposure to the radionuclides, several scenarioswere evaluated which involve exposure to external gamma radiation, ingestion of radioactivematerials, and inhalation of radioactive materials. For the former Welsbach Facility, risk estimateswere evaluated for current and future workers, other site workers (part-time workers), andconstruction workers. For the former GGM Facility, risk estimates were evaluated for current andfuture trespassers, and future construction workers, adult residents, child residents, and workers.At the Vicinity Properties, risk estimates were evaluated for adult and child residents of the 14residential properties investigated, and appropriate populations at the remaining six VicinityProperties (Jogging Track, Swim Club, Martins Lake, Public Park, Land Preserve, and thePopcorn Factory.) These risks were then compared to the risk from natural background sourcesof radiation.

The following exposure pathways were evaluated in detail for current and future land-useconditions:

! Inhalation of radon decay products by residents, or occupants at commercialproperties;

! Exposure to external gamma radiation emanating from thorium- and radium-contaminated material, resulting in elevated exposures to residents/occupants;

! Ingestion of radionuclides in soil by residents/occupants;

! Ingestion of radionuclides in locally grown produce by residents; and

! Inhalation of radioactive particulates by residents/occupants.

The Vicinity Properties and the former Welsbach and GGM Facilities have radiogenic risk(radiation induced) cancer risk estimates, that is, the risks due solely to the presence ofradioactive materials above background levels, which exceed EPA’s risk range. The maximumexcess lifetime radiogenic cancer risk estimates based on reasonable maximum exposures are 5.7 x10-2 at the former Welsbach Facility (to the current and future site worker), 1.8 x 10-1 at theformer GGM Facility (to a hypothetical future site worker), and 1.8 x 10-1 to a hypotheticalresident of a Vicinity Property (See Tables 4 and 5.) The uranium and thorium decay seriesradionuclides are principal threat wastes because of these increased cancer risks.

The cancer risk from chemical exposures at the former Welsbach and GGM facilities was alsoevaluated for the same populations as the radionuclides. Construction workers at both Welsbachand GGM would be subject to the maximum risk from the chemicals of concern (See Table 6

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and 7.) However, these cancer risks do not exceed EPA’s risk range and. therefore, no additionalremedial action is necessary to address chemical contaminants at these facilities.

To assess the potential for cumulative noncarcinogenic effects posed by multiple contaminants.EPA has developed a hazard index (HI). The HI is derived by adding the noncancer risks for sitechemicals with the same target organ or mechanism of toxicity. When the HI exceeds 1.0, theremay be concern for adverse health effects due to exposure to multiple chemicals.

For the Welsbach/GGM site, non-cancer health effects were evaluated only at the formerWelsbach and GGM Facilities. The total HI for construction worker exposure to the chemicals ofconcern in soil at the former Welsbach Facility from ingestion, dermal contact, and inhalation isequal to EPA’s acceptable level of 1.0 (See Table 6.) Ingestion of arsenic is the predominantcontributor to the risk estimate. The total HI for construction worker exposure to the chemicalsof concern in soil at the GGM Facility from ingestion, dermal contact, and inhalation is 0.03; thishazard index is below EPA’s acceptable level of 1.0, indicating that adverse, noncarcinogenichealth effects from such exposure are unlikely (See Table 7.)

The following are the dominant radiological exposure pathway risks for the various exposurescenarios evaluated for the Welsbach/GGM site. At residential properties and the formerWelsbach Facility, the majority of risk is from exposure to external gamma radiation, or directradiation. Occupants of the former GGM Facility (current and future trespassers and future siteworkers) are at risk primarily from inhalation of radon decay products. Future constructionworker risk is primarily due to direct radiation, although inhalation of particulates containingradioactive material also contributes a significant portion of the risk.

This RI focused primarily on residential and commercial properties, and sensitive species of plantsand animals are not likely to inhabit these portions of the Site. However, sensitive species may bepresent in Study Areas 3 and 5 around Newton Creek and associated areas of the Delaware River.An ecological risk characterization will be conducted in conjunction with the third operable unitRI to assess potential impacts to ground water, surface water, and sediment from the Site.

Uncertainties

The procedures and estimates used to assess risks, as in all such assessments, are subject to a widevariety of uncertainties. In general, the main sources of uncertainty include:

! environmental chemistry sampling and analysis! environmental parameter measurement! fate and transport modeling! exposure parameter estimation! toxicological data

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Uncertainty in environmental sampling arises in part from the potentially uneven distribution of

chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual

levels present. Environmental chemistry analysis error can stem from several sources including the

errors inherent in the analytical methods and characteristics of the matrix being sampled. In

addition, there is uncertainty inherent in the measurement of radioactivity.

Uncertainties in the exposure assessment are related to estimates of how often an individual

would actually come in contact with the radionuclides of concern, the period of time over which

such exposure would occur, and the models used to estimate the concentrations of the

contaminants of concern at the point of exposure.

Uncertainties in toxicological data occur in extrapolating both from animals to humans and from

high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture

of contaminants. These uncertainties are addressed by making conservative assumptions

concerning risk and exposure parameters throughout the assessment. As a result, the Risk

Assessment provides upper-bound estimates of the risks to populations that may be exposed to

radionuclides, and is highly unlikely to underestimate actual risks related exposure.

More specific information concerning public health risks, including a quantitative evaluation of the

degree of risk associated with various exposure pathways, is presented in the Risk Assessment

Report.

Actual or threatened releases of hazardous substances from this Site, if not addressed by

implementing the response action selected in this ROD, may present an imminent and substantial

endangerment to public health, welfare, or the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These

objectives are based on available information and standards such as applicable or relevant and

appropriate requirements (ARARs) and risk-based levels established in the risk assessment. EPA’s

remedial action objectives for the Welsbach/GGM. Contamination site are to take measures that

will prevent or mitigate further release of radioactive contaminated materials to the surrounding

environment and to eliminate or minimize the risk to human health and the environment. The

sources of radiation include both contaminated soil and structural materials. Direct radiation,

inhalation, ingestion of plants and soil are potential pathways. The following objectives were

established for the Welsbach/GGM site:

! Eliminate or minimize the potential for humans to ingest, come into dermal contact with,

or inhale particulates of radioactive constituents or to be exposed to external gamma

radiation in order to achieve the level of protection required by the NCP (10-4 to 10-6 risk

range).

1Exposure to 4 pCi/1 of air for radon corresponds to an approximate annual average exposure of 0.02 WL for radon

decay products, when assuming residential land use.

2References for ALARA principles -“Radiation Protection (Guidance to Federal, Agencies for Occupational

Exposure”. 1987, Federal Register 52. No. 17, 2822, and “Federal Guidance Report No. 11",

September 1988, EPA-520\1-88-020.

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! Prevent long-term exposure to thorium- and radium-contaminated material (e.g., soil),with concentrations greater than 5 pCi/g.

! Prevent exposure to indoor concentrations of radon gas and radon decay product greater than 4 pCi/1 and 0.02 WL1, respectively.

! Prevent direct contact with building surfaces exhibiting total surface thoriumcontamination exceeding 0.026 µCi/m2 above background.

! Prevent migration of thorium-contaminated material that could result in the exposuresdescribed above.

! Comply with chemical-, location-, and action-specific ARARs.

EPA, in the Office of Solid Waste and Emergency Response (OSWER) Directives No. 9200.4-18and No. 9200.4-25, developed health guidelines for limiting exposure to ionizing radiation fromradium and other sources. To further ensure protectiveness, those health guidelines can besupplemented by selecting response actions which reduce exposures resulting from ionizingradiation to levels that are As Low As Reasonably Achievable (ALARA2) taking intoconsideration technical, economic and social factors.

EPA recommends that indoor radon concentrations in homes should not exceed 4 pCi per liter ofair (pCi/1). In 40 CFR 192, “Standards for Cleanup of Land and Buildings Contaminated withResidual Radioactive Materials From Inactive Uranium Processing Sites,” EPA enacted standardsfor limiting exposure to radon decay products and gamma radiation. While this regulation is notdirectly applicable to this site because the Welsbach and GGM Facilities are not inactive uraniumprocessing sites. EPA considers the cleanup standards in 40 CFR 192 to be relevant andappropriate for the Site. The relevant portions of 40 CFR 192 include limiting exposure to: radondecay products to levels less than 0.02 WL and radium concentrations (implemented as the sum ofRa-226 and Ra-228) to 5 pCi/g. EPA, in Directive No.9200.4-25, states that whenever the 5pCi/g radium soil cleanup standard is determined to be relevant and appropriate at a CERCLA sitewhich contains both radium and thorium in-the waste, the pCi/g cleanup standard also applies tothorium, (implemented as the sum of Th-230 and Th-232).

In achieving the remedial action objectives for the Site, EPA would rely on the ALARA principlesused at other radiologically-contaminated sites in New Jersey. Applying ALARA

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principles means taking additional measures during implementation of the remedial action,beyond those required to meet a specified cleanup goal, to assure protectiveness. An ALARAapproach is being used because of the long-lived nature of radionuclides, the difficulty ineliminating routes of exposure, and limitations of the analytical equipment to detectradionuclides.

EPA’s experience at the other radiologically-contaminated sites in New Jersey has shown thatthe remedial action objectives noted above can be achieved by incorporating ALARAprinciples. Applying the 5 pCi/g cleanup standard with ALARA principles at these other NewJersey sites has resulted in exposure levels that are lower than the levels that would resultfrom using the 5 pCi/g standard alone. Therefore, by using similar remedial action objectives,the Welsbach/GGM site would pose no unacceptable risk for residential uses after cleanup.and would result in a cleanup that is protective under CERCLA.

The NJDEP has developed a draft proposed regulation concerning the remediation ofradiologically-contaminated soil. In reviewing this case, the NJDEP believes that the remedyselected in this ROD will achieve the goals in the draft proposal through the incorporation ofthe ALARA principles in removing the radiologically-contaminated soils and covering theexcavated areas with clean fill.

The selected remedy will meet the remedial action objectives through the excavation andoff-site disposal of the radiologically-contaminated soils and waste materials. Excavation ofsoils will eliminate the threat of physical migration of contaminants, as well as potentialexposure through various pathways (ingestion, inhalation, dermal contact, external gammaradiation, etc.). Contaminated soils will be shipped off-site to a licensed commercial facilityfor permanent long-term management. For buildings, specifically at GGM, the selectedremedy, decontamination. demolition, and off-site disposal of contaminated materials, willreduce exposures to acceptable levels for future use of the property.

Any potential ecological risks and adverse impacts from existing radiological contaminationon the properties addressed under this action will be minimized because the contaminatedsoils will be removed and backfilled with clean soil. There are also limited habitats forecological receptors at the properties addressed under this action. Furthermore, by removingthe radiologically-contaminated waste, the surface water and sheet flow pathways will beeliminated as routes of exposure.

Wetlands are not present at either the former Welsbach or GGM facilities. However, wetlandsare present in Areas 3 and 5, along the South Branch of Newton Creek. During the remedialdesign, EPA will delineate wetland areas which are actually or potentially impacted bycontamination or remedial activities.

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DESCRIPTION OF REMEDIAL ALTERNATIVES

Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1), mandates that a remedial action mustbe protective of human health and the environment. cost-effective, and utilize permanentsolutions and alternative treatment technologies or resource recovery technologies to themaximum extent practicable. Section 121(b)(1) also establishes a preference for remedialactions which employ, as a principal element, treatment which permanently and significantlyreduces the volume, toxicity, or mobility of the hazardous substances, pollutants andcontaminants at a site. Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), further specifies thata remedial action must attain a level or standard of control of the hazardous substances,pollutants, and contaminants, which at least attains ARARs under federal and state laws,unless a waiver can be justified pursuant to Section 121(d)(4) of CERCLA, 42U.S.C. §9621(d)(4). CERCLA also requires that if a remedial action is selected that results inhazardous substances, pollutants, or contaminants remaining at a site above levels that allowfor unlimited use and unrestricted exposure, EPA must review the action no less than everyfive years after the start of the action.

In the RI/FS Report, EPA evaluated Remedial Alternatives for addressing the radiologicalcontamination associated with the Site. Cleanup alternatives were evacuated for the VicinityProperties, the former Welsbach Facility and the General Gas Mantle Facility. Thealternatives include: No Action, Engineering Controls, and Excavation and Off-SiteDisposal. Table 8 summarizes the costs of each alternative.

Vicinity Properties

The Vicinity Properties include residential, commercial, and public properties whereradiological contamination was identified in soils located outdoors and/or beneath buildings,and properties with indoor air contamination.

Vicinity Properties Alternative 1 (V-1) - No Action

Estimated Capital Cost: $0Estimated Annual Operation and Maintenance (O&M) Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none

A “No Action” alternative is evaluated for every Superfund site to establish a baseline forcomparison with remedial alternatives. Under this alternative, no remedial action would beperformed at the Site. Previous interim remedial actions implemented by NJDEP would notbe maintained. Current institutional controls including fencing would not be maintained.Because hazardous substances would remain at the Vicinity Properties above acceptablelevels, five-year reviews would be required.

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Vicinity Properties Alternative 2 (V-2) - Engineering Controls

Estimated Capital Cost: $900,000Estimated Annual O&M Cost: $99,000Estimated Present Worth: $1,810,000Estimated Implementation Period: 3-5 years

Under this alternative, outdoor gamma shielding would be placed at each property which hascontaminated soil. The gamma shield would consist of a geotextile liner, fill material, 6 inchesof topsoil, and vegetation (seeding or sod). The thickness of the fill material will vary from 6inches to 42 inches, based on the shielding requirements of each property. A total ofapproximately 75,000 square feet of coverage would be installed.

In addition, indoor gamma shielding would be placed inside buildings exhibitingunacceptable exposure levels. The shielding would consist of concrete or steel as needed. Theconcrete would range from 4 inches to 7 inches thick, and about 1.5 inches of steel sheetingwould be placed on wall surfaces. A total of approximately 2,000 square feet of concrete and60 square feet of steel coverage would be installed. Finally, if any property buildings exhibitelevated radon/thoron levels, a sub-slab ventilation radon mitigation system would beinstalled.

Institutional controls, such as deed restrictions, would be required to ensure the protectivenessof the remedy. Because hazardous substances would remain at the Vicinity Properties aboveacceptable levels, five-year reviews would be required. The estimated time to design andconstruct the remedy is from three to five years.

Vicinity Properties Alternative 3 (V-3) - Excavation and Off-Site Disposal

Estimated Capital Cost: $13,408,560Estimated Annual O&M Cost: $0Estimated Present Worth: $13,408,560Estimated Implementation Period: 3-5 years

Under this alternative, soil on the Vicinity Properties contaminated above 5 pCi/g greater thanbackground would be excavated and disposed of at a licensed off-site facility. Radiologically-contaminated building demolition debris would also be excavated and disposed of off-site.EPA will replace these areas with clean fill. The total volume of soils requiring disposal at theVicinity Properties is estimated to be 11,000 cubic yards. The total volume of burieddemolition debris at the Vicinity Properties is estimated to be 2,250 cubic yards.

Where contamination is suspected underneath buildings, this alternative includes removingconcrete flooring and underpinning the buildings. After the removal of contaminated soil, anew concrete floor would be constructed. Approximately 21 properties would requireconcrete floor removal and replacement. Underpinning may be required at one property.

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The estimated time to design and construct the remedy is three to five years. Provisions wouldneed to be made for the temporary relocation of residents and businesses during constructionof this alternative. During excavation. short-term provisions to prevent dust generation andprotect workers would be required. EPA will develop a wetland mitigation plan if it disturbswetland areas by remedial activities.

Welsbach Facility

The former Welsbach Facility is presently owned and operated by Holt as a cargo storage andoversea shipping operation. Radiological contamination on the property is present in theoutdoor portion of the storage area. Most of the contamination is located in a singlecontiguous area. with smaller contaminated areas scattered across the property. TheArmstrong Building is not included in the remediation alternatives. Holt is preparing an RI/FSthat will address the remedial alternatives for that building.

Welsbach Alternative I (W-1) - No Action

Estimated Capital Cost: $0Estimated Annual O&M Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none

Under this alternative, no remedial action would be performed at the Site. Current institutionalcontrols, including fencing, would not be maintained. Because hazardous substances wouldremain on the property above acceptable levels. five-year reviews would be required.

Welsbach Alternative 2 (W-2) - Engineering Controls

Estimated Capital Cost: $5,686,000Estimated Annual O&M Cost: $44,000Estimated Present Worth: $6,182,000Estimated Implementation Period: 3-5 years

Under this alternative, outdoor gamma shielding would be placed in the areas of the formerWelsbach property that have soil contamination. The gamma shield would consist of steelcovered by asphalt. The steel would range in thickness from 1 to 5 inches, with a 4-incnasphalt cover. Approximately 53,000 square feet of area would be, covered by the steelshielding.

Institutional controls, such as deed restrictions, would be required to ensure the protectivenessof the remedy. Because hazardous substances would remain on the property above acceptablelevels, five-year reviews would be required. The estimated time to design and construct theremedy is three to five years.

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Welsbach Alternative 3 (W-3) - Excavation and Off-Site Disposal

Estimated Capital Cost: $18,503,560Estimated Annual O&M Cost: $0Estimated Present Worth: $18.503.560Estimated Implementation Period: 3-5 years

Under this alternative, all soil contamination at the Welsbach site above 5 pCi/g greater thanbackground would be excavated and disposed of at a licensed off-site facility. EPA will alsoexcavate contaminated building debris from past demolition activities, which is currentlyburied on-site, and dispose of this material at an appropriate off-site facility. EPA will backfillthese areas with clean fill. The volume of soils above the cleanup standard is estimated to be19,400 cubic yards. The volume of buried demolition debris requiring disposal is estimated tobe 4.400 cubic yards. During excavation, short-term provisions to prevent dust generation andprotect workers would be required.

Subsurface contamination on the Welsbach Facility averages about 11 feet in depth. In thearea of the deepest contamination, underground tunnels dating from around the turn of thecentury are present. These tunnels extend down to about 10 to 12 feet in depth. These tunnelscan act as conduits to carry radon gas to nearby residential properties. As a result, the remedyincludes excavation of the contamination to the tunnel depths to prevent any future radonmigration problems and to protect future workers from elevated gamma radiation levels. Theestimated time to design and construct the remedy is three to five years.

General Gas Mantle Facility

The GGM building is presently inactive and in a dilapidated state. The building has beenboarded shut and fenced in by NJDEP. Radiological contamination on the property exists bothinside and outside the building. Inside the building, contamination is present in buildingmaterials and in ambient air. Outside the GGM Facility, soil contamination is primarilylocated to the inunediate southwest of the GGM building extending into South Fourth Street.Two smaller areas of contaminated soils are situated to the northeast of the building and in thealleyway adjacent to the eastern side of the building.

General Gas Mantle Alternative 1 (G-1) - No Action

Estimated Capital Cost: $0Estimated Annual O&M Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none

Under this alternative, no remedial action would be performed at the Site. PTevious interimremedial actions would not be maintained. Current institutional controls including fencingwould

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not be maintained. Because hazardous substances would remain on the property aboveacceptable levels, five-year reviews would be required.

General Gas Mantle Alternative 2 (G - 2) - Engineering Controls

Estimated Capital Cost: $122.000Estimated Annual O&M Cost: $23.000Estimated Present Worth: $381.000Estimated Implementation Period: 2-3 years

Under this alternative, outdoor gamma shielding would be placed at the former General GasMantle property. The gamma shield would consist of either a soil shield or a concrete shield.The soil shield would include a geotextile liner, fill material, 6 inches of tonsoil, andvegetation (seeding or sod). The thickness of the fill material will range, from 6 to 24 inches.The thickness of the concrete will range from 6 to 8 inches. Approyimately 5,000 square feetof coverage would be required. Areas of contamination extending into Forth Fourth Streetwould be covered with an additional 4 inches of asphalt.

Also under this alternative, significant institutional controls, including permanently boardingshut the building and restricting access to the building forever, would be required. Becausehazardous substances would remain on the property above acceptable levels, five-year reviewswould berequired. The estimated time to design and construct the remedy is two to three years.

General Gas Mantle Alternative 3 - Excavation and Off-Site Disposal of Soil andBuilding/Demolition Debris

Option A: Demolition and Disposal

Estimated Capital Cost: $2,309,560Estimated Annual O&M Cost: $0Estimated Present Worth: $2,309,560Estimated Implementation Period: 1-2 years

Under this alternative for the GGM property, EPA will excavate contaminated soil above 5pCi/g greater than background and dispose of this waste in a licensed off-site facility.Contaminated building demolition debris which is currently buried on-site because of formerdemolition activities would also be excavated and disposed of off-site. EPA will backfill theseareas with clean fill. The volume of soil and buried dem6lition debris at GGM is estimated tobe 650 cubic yards and 60 cubic yards, respectively.

Under this alternative, the former General Gas Mantle building would be demolished, and thedemolition debris would be disposed of with the contaminated soil. The volume of buildingmaterials to be demolished is estimated to be 1,400 cubic yards. During excavation and

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demolition, short-term provisions to prevent dust generation and protect workers would berequired. The estimated time to design and construct the remedy is one to two years.

Option B: Decontamination, Demolition and Disposal

Estimated Capital Cost: $1.979.560Estimated Annual O&M Cost: $0Estimated Present Worth: $1.979.560Estimated Implementation Period: 1-2 years

This alternative essentially would be the same as 3A above, except that the demolition of thebuilding would proceed in steps. First, the wood structural materials and roofing would beremoved. This debris (approximately 450 cubic yards) would be disposed of with thecontaminated soil. The remainder of the building (approximately 950 cubic yards of primarilymasonry and concrete) would then be decontaminated using pressure washing beforedemolition. The contaminated waste water would be disposed of at an approved off-sitefacility. The building would then be demolished and the debris would be crushed and sentoff-site for disposal. The estimated time to design and construct the remedy is one to twoyears.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in Section 121 of CERCLA, 42U.S.C. §9621, by conducting a detailed analysis of the viable remedial alternatives pursuant tothe NCP, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysisconsisted of an assessment of the individual alternatives against each of nine evaluationcriteria and a comparative analysis focusing upon the relative performance of each alternativeagainst those criteria.

The following “threshold” criteria are the most important and must be satisfied by anyalternative in order to be eligible for selection:

1. Overall protection of human health and the environment considers whether or not aremedial alternative provides adequate protection and describes how risks posedthrough each exposure pathway are eliminated, reduced, or controlled throughtreatment, engineering controls, or institutional controls.

2. Compliance with ARARs addresses whether or not a remedial alternative meets all ofthe applicable or relevant and appropriate requirements of federal and stateenvironmental statutes and requirements, or provides grounds for invoking a waiver.

The following “primary balancing” criteria are used to make comparisons and to identify themajor trade-offs between alternatives:

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3. Long-term effectiveness and permanence, refers to the ability of a remedial alternativeto maintain reliable protection of human health and the environment over time, oncecleanup goals have been met. It also addresses that magnitude and effectiveness of themeasures that may be required to manage the risk based by treatment residuals and/oruntreated wastes.

4. Reduction of toxicity, mobility, or volume through treatment addresses the statutorypreference for selecting remedial actions that employ treatment technologies thatpermanently and significantly reduce toxicity, mobility, or volume of hazardoussubstances as a principal element.

5. Short-term effectiveness considers the period of time needed to achieve protection andany adverse impacts on human health and the environment that may be posed duringthe construction and implementation period until cleanup goals are achieved.

6. Implementability refers to the technical and administrative feasibility of a remedialalternative, including the availability of materials and services needed to implement thealternative.

7. Cost includes the estimated capital and operation and maintenance costs, and thepresent- worth costs.

The following “modifying” criteria are considerea ;ully after the formal public cornmentperiod on the Proposed Plan is complete:

8. State acceptance indicates whether, based on its review of the RI/FS reports and theProposed Plan, the State supports, opposes, and/or has identified any reservations withthe preferred alternative.

9. Community acceptance refers to the public’s general response to the alternativesdescribed in the Proposed Plan and tne RI/FS report. Responses to public commentsare addressed in the Responsiveness Summary section of this Record of Decision.

A comparative analysis of the remedial alternatives based upon the evaluation criteria notedabove follows:

Overall Protection to Human Health and the Environment

The No Action Alternatives (W-1, V-1, G-1) would not be protective of human health and theenvironment because the Site would remain in its current contaminated condition. Therefore,the No Action Alternatives have been eliminated from consideration and will not be discussedfurther.

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Under the Engineering Controls Alternatives (W-2, V-2. G-2), potential exposure routes of

gamma radiation would be shielded by soil, concrete and/or steel sheeting. The shielding would

have to be maintained, and institutional controls, such as deed restrictions, would be required to

ensure that these alternatives are protective.

For the Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3). all radiological

contamination above cleanup standards would be excavated and disposed of off-site in a licensed

disposal facility. Institutional controls would not be necessary. All unacceptable risks to human

health and the environment would be eliminated by the excavation and off-site disposal of the

radiologically-contaminated waste.

Compliance with Applicable or Relevant. and Appropriate Requirements

Actions taken at any Superfund site must meet all ARARs of federal and state law, or provide

grounds for invoking a waiver of these requirements. There are three types of ARARs: action-

specific, chemical-specific, and location-specific. Action-specific ARARs are technology or

activity-specific requirements or limitations related to various activities. Chemical-specific ARARs

are usually numerical values which establish the amount or concentration of a chemical that may

be found in, or discharged to, the ambient environment. Location-specific requirements are

restrictions placed on the concentrations of hazardous substances or the conduct of activities

solely because they occur in a special location.

For the Welsbach/GGM site, no requirements are applicable for the cleanup of the radiological

contamination. However, as discussed earlier, portions of the federal regulations governing the

cleanup of uranium mill tailings from inactive uranium processing sites, at 40 CFR 192, have been

determined to be relevant and appropriate. These provide the radon decay products standard of

0.02 WL and soil cleanup criteria of 5 pCi/g above background.

The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) would comply with all

ARARs. All contamination above the 40 CFR 192 cleanup standards would be excavated and sent

off-site for disposal. The Engineering Controls Alternatives (W-2, V-2, G-2) would comply with

all ARARs that limit exposure to gamma radiation and radon. However, the Engineering Controls

Alternatives would not comply with 40 CFR 192, because the contaminated material would

remain at the Site.

Long-Term Effectiveness and Permanence

The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) are all effective and

permanent. They are considered a final remedial action. The contaminated material would be

removed from the Site and stored in a controlled, licensed off-site facility.

The long-term effectiveness of the Engineering Controls Alternatives W-2 and V-2 would be

uncertain. Contaminated material would remain in place, and the engineering controls would

24

require deed restrictions and long-term monitoring. In addition. the engineering controls would

have to be maintained forever because the half-life of thorium. is 14 billion years.

Alternative G-2 (Engineering Controls for General Gas Mantle) would not be effective in the

long-term because of the dilapidated nature of the building, even if the building were completely

sealed.

Reduction of Toxicity, Mobility, or Volume Through Treatment

No treatment technology is known today that can substantially reduce the toxicity, mobility, or

volume of radioactive materials found at the Site, and meet the 40 CFR 192 cleanup standards.

The total amount of radioactivity cannot be altered or destroyed, as is often possible with

chemical contaminants. Therefore, none of the remedial alternatives fully satisfy this evaluation

criteria.

However, Alternative G-3 with Option B (the General Gas Mantle Decontamination and

Demolition Alternative) would reduce the volume of contaminated building debris to be disposed

of off-site by pressure washing the radioactive contamination off the floors and walls before

demolition. The contaminants would be concentrated in the filtrate after pressure washing. Only

this filtrate would have to be disposed of in a licensed off-site facility.

Short-Term-Effectiveness

Both the Engineering Control Alternatives (W-2, V-2, G-2) and the Excavation and Off-Site

Disposal Alternatives (W-3, V-3, G-3) provide effective short-term protection, and become

effective as they are implemented at individual properties. The estimated time to design and

construct the remedial alternatives for the former Welsbach Facility (Alternatives W-2 and W-3)

and the Vicinity Properties (Alternatives V-2 and V-3) is from three to five years. For the former

GGM Facility, the estimated time to design and construct the Engineering Control Alternative

G-2 is from two to three years, and for the Excavation and Off-Site Disposal Alternative G-3

from one to two years.

The Engineering Control Alternatives involve less intrusive activities, and pose less of a threat to

workers and the surrounding community than the Excavation and Off-Site Disposal Alternatives.

However, both the Engineering Control Alternatives and the Excavation and Off-Site Disposal

Alternatives involve intrusive activities, including, in some cases, temporary relocation of

residents.

The Excavation and Off-Site Disposal Alternatives have a greater potential adverse impact in the

short term because of the excavation of radiologically-contaminated soil. For future workers, this

could lead to increased short-term exposure to radon, gamma radiation, and soil radionuclides.

Dust suppression techniques and/or other measures would be required to minimize the impacts of

this alternative. However, under Alternative V-2 (Engineering Controls for the Vicinity

25

Properties), there would be some increased short-term risk to workers during the installation of

the radon mitigation systems. This is due to the need to excavate under the foundation of homes

that require radon mitigation.

Implementability

The Excavation and Off-Site Disposal Alternatives (W-3, V-3 and G-3) are readily

implementable. Similar activities have been utilized at other radiologically-contaminated sites

around the country. There is an available off-site disposal facility. which is accessible by both

truck and rail. However, the continued availability of this off-site disposal facility is required for

implementation of these alternatives.

Implementation of the Engineering Controls Alternatives V-2 and G-2 may pose some difficulties.

Under Alternative V-2 (for the Vicinity Properties), there may be some difficulty in getting the

consent of all of the property owners to restrict future work on their properties. EPA would have

to reach agreement with individual property owners to file Declarations of Environmental

Restrictions (i.e., deed restrictions) on their properties. For Alternative G-2 (for General Gas

Mantle), it would be difficult to keep the building permanently sealed from trespassers.

Cost

Alternative V-2 includes construction costs of $900,000 to implement engineering control

measures at the Vicinity Properties. Annual O&M costs are estimated to be $99,000. The present

worth cost of Alternative V-2 is $1,810,000, with O&M costs assumed for 30 years. Alternative

W-2 includes construction costs of $5,686,000 to implement engineering control measures at the

former Welsbach Facility. Annual O&M costs are estimated to be $44,000. The present worth

cost of Alternative W-2 is $6,182,000, with O&M costs assumed for 30 years. Alternative G-2

includes construction costs of $122,000 to implement engineering controls at the General Gas

Mantle Facility. Annual O&M costs are estimated to be $23,000. The present worth cost of

Alternative G-2 is $381,000, with O&M costs assumed for 30 years. The radionuclides in

question have half-lives far greater than 30 years, so any of the Engineering Controls remedies

must be maintained effectively forever.

Alternative V-3 includes construction costs of $13,408,560 to excavate the radiologically

contaminated soil at the Vicinity Properties and dispose of the waste at an off-site disposal

facility. Alternative W-3 includes construction costs of $18,503,560 to excavate the

radiologically-contaminated soil at the former Welsbach Facility and dispose of the waste at an

off-site disposal facility. Alternative G-3 - Option A involves construction costs of $2,309,560,

and includes demolishing the General Gas Mantle building and disposal of all the building debris at

an off-site disposal facility Alternative G-3 - Option B involves construction costs of $1,979,560,

and includes decontaminating the General Gas Mantle building before its demolition.

26

There are no O&M costs associated with the Excavation and Off-Site Disposal Altematives W-3,

V-3 and G-3 Options A and B).

State Acceptance

The State concurs with the selected remedial action.

Community Acceptance

EPA solicited input from the community on the remedial alternatives proposed for the

Welsbach/General Gas Mantle Contamination Site. The community was supportive of EPA’s

preferred remedy which called for the excavation and off-site disposal of the radiologically

contaminated soils at the Site. The No Action and Engineering Controls Alternatives received no

community support. The attached Responsiveness Summary addresses the comments received

during the public comment period.

SELECTED REMEDY

Based upon consideration of the results of the RI/FS, the requirements of CERCLA, the detailed

analysis of the alternatives, and public comments, EPA and NJDEP have determined that the

Excavation and Off-Site Disposal Alternatives (V-3, W-3, and G-3 with Option B) are the

appropriate remedies for the Site.

The selected remedial action will provide a final remedy and achieve the remedial action

objectives at the Vicinity Properties and the Welsbach and General Gas Mantle Facilities by:

! eliminating or minimizing the potential for humans to ingest, come in dermal contact with,

or inhale particulates of radioactive constituents, or be exposed to external gamma

radiation, thereby achieving the level of protection required by the NCP;

! preventing exposure to radon gas and radon decay products in excess of 4 pCi/L and 0.02

WL, respectively;

! preventing direct contact with building surfaces exhibiting total surface thorium

contamination exceeding 0.026Ci/m2 above background;

! preventing long-term exposure to thorium- and radium-contaminated materials with

concentrations greater than 5 pCi/g above background; and

! preventing migration of radiologically-contaminated materials that could result in

exposures described above.

27

Radiologically-contaminated soil found on the Vicinity Properties and the former Welsbach and

GGM Facilities in excess of 5 pCi/g above background will be excavated consistent with 40 CFR

192, Subparts B and E. The remedy will attain a risk level similar to risk levels associated with

exposure to natural background radiation. This will be confirmed via post-excavation property

surveys. The Multi-Agency Radiation Survey and Site Investigation Manual (MARISSM) may be

used where appropriate to conduct such property surveys. MARISSM provides a methodology to

confirm that a particular soil concentration level has been achieved after the remedial action is

completed. An appropriate survey methodology to be used will be determined during remedial

design.

EPA estimates that the following volumes of contaminated soil and debris will be removed from

the Site: Vicinity Properties - 13,000 cubic yards, General Gas Mantle - 2.500 cubic yards.

Welsbach Facility - 27,000 cubic yards. EPA will dispose of the radiologically-contaminated

material at a licensed, off-site facility. Areas that have been excavated will be restored with clean

fill. No significant changes in land use are anticipated. Because all contamination above the

cleanup criteria will be excavated and sent off-site for disposal, all remediated properties will be

available for unrestricted future use.

EPA will make every effort to minimize any long-term disruption to individual residents or the

community. During excavation, EPA may need to temporarily relocate some residents at

government expense.

As previously stated, EPA will investigate approximately 600 Suspect Properties during the

remedial design phase. When these properties are tested, it is likely that some will be found to

contain radiologically-contaminated material and will require remediation. The selected remedy

also includes such remediation. EPA believes that cleanup of additional contaminated properties

will not affect the overall scope of the remedial action.

STATUTORY DETERMINATIONS

Superfund remedy selection is based on CERCLA and the regulations contained in the NCP.

Under its legal authorities, EPA’s primary responsibility in selecting remedies at Superfund sites

is to undertake actions that are protective of human health and the environment. In addition,

Section 121 of CERCLA establishes several other statutory requirements and preferences. These

specify that, when complete, the selected remedial action for this site must comply with

applicable or relevant and appropriate environmental standards established under federal and state

environmental laws unless a statutory waiver is justified. The selected remedy also must be cost

effective and utilize permanent solutions and alternative treatment technologies or resource

recovery technologies to the maximum extent practicable. Finally, the statute includes a

preference for remedies that employ treatment that permanently and significantly reduce the

volume, toxicity, or mobility of the hazardous wastes, as their principal element. The following

sections discuss how the selected remedy meets these statutory requirements for the first operable

unit of the Welsbach/GGM site.

28

Protection of Human Health and the Environment

This remedy is fully protective of human health and the environment for all properties, with

radiological contamination above the cleanup standards. It is estimated that no radiologically-

contaminated soil above the cleanup standards will remain on the affected properties. The remedy

will attain a risk level similar to risk levels associated with exposure to natural background

radiation. Implementation of this remedy will eliminate additional risks attributable to exposures

to indoor or outdoor gamma radiation, indoor radon gas or radon decay products, inhalation

and/or ingestion of contaminated soil, and ingestion of contaminated vegetables grown in

contaminated soil. This remedy will comply with the ARARs for exposure to indoor gamma

radiation and the inhalation of radon gas or radon decay products, and attainment of soil cleanup

standards.

There are few short-term risks associated with the implementation of this remedy. Where

excavation occurs, dust suppression measures can reduce the risk of inhalation of radiologically-

contaminated dust. In addition, no adverse cross-media impacts are expected from the remedy.

Compliance with ARARs

As presented earlier, the primary ARARs for this site are contained in 40 CFR 192, Subpart B.

This regulation deals with the cleanup of inactive uranium processing facilities. EPA has

determined that while these standards are not applicable, they are relevant and appropriate to the

situation at the Welsbach/GGM site. Table 9 lists and summarizes these and other standards that

may be pertinent during the implementation of this remedial action.

When implemented, the cleanup of the affected properties within the study areas will comply with

all public health and soil cleanup ARARs, and will allow for unrestricted use of these properties.

Cost Effectiveness

The selected remedy is cost-effective because it provides the highest degree of overall

effectiveness relative to its cost. The remedy provides for complete protection of public health and

the environment at the affected properties.

The radioactive half-life of thorium-232, the primary contaminant of concern, is 14 billion years.

Remedies that would isolate wastes containing thorium and the uranium series radionuclides

permanently from the public and the environment are preferable.

Utilization of Permanent Solutions and Alternative Treatment Technologies to thq Maximum

Extent Practicable

EPA and the State of New Jersey have determined that the selected remedy represents the

maximum extent to which permanent solutions and currently available treatment technologies can

29

be utilized in a cost-effective manner for this phase of the remedial action at the Welsbach/General

Gas Mantle Contamination site. Of those alternatives that are protective of human health and the

environment and comply with ARARs, EPA and the State of New Jersey have determined that the

selected remedy provides the best balance of trade-offs in terms of long-term effectiveness and

permanence, short-term effectiveness, implementability, cost, the statutory preference for

treatment as a principal element and State and community acceptance.

Alternatives V-3, W-3, and G-3 result in a permanent solution to the radioactive contamination.

The longevity of these contaminants of concern (thousands to billions of years) favors excavation

which permanently removes them from their current uncontrolled locations. Commercial disposal

at a licensed facility with an appropriate closure plan will ensure that these radiological wastes are

permanently isolated from human and ecological receptors. The Excavation and Off-Site Disposal

Alternatives are considered implementable and will result in a remedy that is highly effective in the

long-term. These remedies are also consistent with the remedial approach taken at all other

radiologically-contaminated sites in New Jersey.

Preference for Treatment as a Principal Element

The principal threat at the Site is from exposure to excess levels of indoor and/or outdoor gamma

radiation, and ingestion and/or inhalation of radiologically-contaminated soil. In addition, there

are threats from the generation of excess concentrations of radon gas and radon decay products

indoors which migrate from the underlying soils, and are subsequently inhaled by the residents of

those houses. Because there is no treatment available that destroys the radioactive source of these

threats, the selected remedy does not satisfy the statutory preference for treatment as the principal

element. The remedy does reduce the exposure to all excess levels of indoor and/or outdoor

gamma radiation. It also provides for complete remediation at the affected properties, thereby

reducing the exposure risk from all pathways.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative presented in the Proposed Plan.

30

APPENDIX I

FIGURES

31

32

34

APPENDIX II

TABLES

35

TABLE -1

RADIATION UNITS

ParameterHistorical International

Unit Abbrev. Unit Abbrev.

Quantity Curie Ci Becquerel Bq

RadionuclideConcentration inSoil or OtherSolid Material

picoCurie pergram of Solid

pCi/g Becquerel perkilogram

Bq/kg

RadionuclideConcentration in Water

picoCurie perliter of Water

pCi/L --- —

Radon Gas Conc. picoCurie perliter of Air

pCi/L Becquerel percu. meter

Bq/m3

Radon ProgenyConc.

Working Level WL --- ---

Exposure Rate micro-Roentgenper hour

µR/h — —

Dose RadiationAbsorbed Dose

rad Gray Gy

Dose Equivalent RadiationEquivalent Man

rem Sievert Sv

36

TABLE-2

PROPERTY CHARACTERIZATION

WELSBACII/GGM SITE

STUDY AREA AREA 1 AREA 2 AREA 3 AREA 4 AREA 5 AREA 6 TOTAL

PROPERTIES SURVERYED BY THE

NJDEP

359 174 48 474 32 NA1 1088

PROPERTIES WITH NO EVIDENCE OF

CONTAMINATION

<13 µN/HR

<0.02 WL RADON DECAY PRODUCTS

<4.0 pCi/L RADON

103 40 18 272 16 0 449

SUSPECT PROPERTIES

13 - 30 µR/h OR

ADJACENT TO CONTAMINATED

PROPERTIES

239 113 23 199 11 0 585

POTENTIALLY CONTAMINATED

PROPERTIES

>30 µR/HR

>0.02 WL RADON DECAY PRODUCTS

> 4.0 pCi/L RADON

17 21 7 3 5 1 54

Note:

1 - Study Area 6 was not part of the NJDEP investigation.

NA - Not Applicable

37

TABLE 3

ESTIMATED VOLUME OF CONTAMINATED MATERIALSWELSBACH/GGM SITE

SOIL(CUBIC YARDS)

STRUCTURAL/DEBRISMATERIALS

(CUBIC YARDS)

FORMER WELSBACHFACILITY

22,200 5,000

FORMER GGM FACILITY 885 1,460

VICINITY PROPERTIES 11,010 2,255

TOTAL 34,100 8,720

38

TABLE 4

RADIOLOGICAL RISK ESTIMATES BASED ON REASONABLE MAXIMUM EXPOSURES

AT

FORMER GAS MANTLE MANUFACTURING FACILITIES

POPULATION PATHWAY EXPOSURE

MEDIUM

GROSS

RISK

BACKGROUND

RISK

NET

RISK

TOTAL

RISK

FORMER WELSBACH FACILITY

WORKER EXTERNAL SOIL 5.70e-02 7.30e-05 5.70e-02 5.70e-02

OTHER WORKER EXTERNAL SOIL 1.40e-02 1.80e-05 1.40e-02 1.40e-02

CONSTRUCTION WORKER EXTERNALINGESTIONINHALATION

SOILSOIL

PARTICULATES

7.50e-043.10e-051.10e-03

8.70e-075.60e-088.40e-07

7.50e-043.10e-051.10e-03 1.90e-03

FORMER GENERAL GAS MANTLE FACILITY

TRESPASSER EXTERNAL*

INGESTIONINHALATION

*

SOILBUILDING MATERIALS

SOILPARTICULATES

RADON DECAY PRODUCTS

3.10e-052.00e-051.90e-060.00e+002.50e-03

1.30e-063.40e-061.40e-070.00e+007.40e-06

3.00e-061.70e-051.80e-060.00e+002.50e-03 2.50e-03

CONSTRUCTION WORKER EXTERNALINGESTIONINHALATION

SOILSOIL

PARTICULATES

2.10e-05

7.50e-07

2.80e-05

8.70e-07

5.60e-08

8.40e-07

2.00e-05

6.90e-07

2.70e-05 4.80e-05

ADULT RESIDENT EXTERNALINGESTION

*INHALATION

SOILSOIL

HOME GROWN PRODUCERADON DECAY PRODUCTS

8.90e-03

2.70e-05

2.30e-08

4.90e-03

3.80e-04

2.00e-06

3.20e-06

8.00e-04

8.50e-03

2.50e-05

2.00e-05

4.10e-03 1.30e-02

CHILD RESIDENT EXTERNALINGESTION

*INHALATION

SOILSOIL

HOME GROWN PRODUCERADON DECAY PRODUCTS

1.80e-03

1.10e-05

1.90e-06

5.60e-04

7.80e-05

8.10e-07

2.70e-07

9.20e-05

1.70e-03

1.00e-05

1.60e-06

4.70e-04 2.20e-03

WORKER EXTERNALINHALATION

*

BUILDING MATERIALSPARTICULATES

RADON DECAY PRODUCTS

1.40e-03

0.00e+00

1.80e-01

2.40e-04

0.00e+00

5.10e-04

1.20e-03

0.00e+00

1.80e-01 1.80e-01

39

TABLE 5

VICINITY PROPERTIES

SUMMARY OF RADIOLOGICAL RISK ESTIMATES

BASED ON REASONABLE MAXIMUM EXPOSURES*

VICINITY

PROPERTY POPULATION PATHWAY

RISK

GROSS BACKGROUND NET

PUBLIC PARK

SITE WORKER ExternalInhalation of ParticulatesInhalation of RadonIngestion of Soil

7.3e-012.3e-021.7e-033.0e-03

8.6e-051.8e-065.2e-045.5e-07

7.3e-012.3e-021.2e-033.0e-03

Total: 7.6e-01 6.1e-04 7.6e-01

POPCORNFACTORY

CONSTRUCTIONWORKER

EXTERNALInhalation of ParticulatesIngestion of Soil

3.3e-041.1e-051.1e-06

8.3e-073.1e-083.1e-09

3.3e-041.1e-051.1e-06

Total: 3.4e-04 8.6e-0 3.4e-04

PUBLIC PARK

ADULTRECREATIONALIST

ExternalInhalation of ParticulatesIngestion of Soil

2.2e-016.9e-034.5e-04

2.6e-055.5e-078.3e-08

2.2e-016.9e-034.5e-04

Total: 2.3e-01 2.7e-05 2.3e-01

POPCORNFACTORY

RESIDENT ADULT ExternalInhalation of RadonIngestion of Soil

4.7e-021.2e-011.2e-04

3.5e-047.9e-042.0e-06

4.7e-021.2e-011.2e-04

Total: 1.7e-01 1.1e-03 1.7e-01

PUBLIC PARKCHILDRECREATIONALIST

EternalInhalation of ParticulatesIngestion of Soil

4.4e-021.2e-031.8e-04

5.1e-069.4e-083.3e-08

4.4e-021.2e-031.8e-04

Total: 4.5e-02 5.2e-06 4.5e-02

LANDPRESERVE

RESIDENT CHILD ExternalInhalation of RadonIngestion of Home GrownProduceIngestion of Soil

7.0e-022.5e-02

2.5e-034.6e-04

6.8e-059.0e-05

3.8e-067.8e-07

7.0e-022.5e-02

2.5e-034.6e-04

Total: 9.8e-02 1.6e-04 9.8e-02

LANDPRESERVE

TRESPASSER EternalInhalation of ParticulatesIngestion of Soil

2.4e-031.2e-042.3e-06

2.5e-069.4e-083.8e-09

2.4e-031.2e-042.3e-06

Total: 2.5e-03 2.6e-06 2.5e-03

• The exposure duration varies for each population considered in the risk Assessment. Only the maximum riskestimates for each population evaluated are provided.

TABLE 6

RISK ASSESSMENT SUMMARY

FORMER WELSBACH FACILITY

Scenario Timeframe: Future

Receptor Population: Construction Worker

Receptor Age: Adult

Medium Exposure Chemical

Carcinogenic Risk

Chemical

Non-Carcinogenic Hazard Quotient

Ingestion Inhalation Dermal Exposure

Routes Total

Primary

Target

Organ

Ingestion Inhalation Dermal Exposure

Routes Total

Soil Soil Benzo(a)Anthracene 6e-08 -- No Tox

Data

6e-08 Arsenic Skin 1e+00 -- 2e-01 1e+00

Benzo(b)Fluoranthene 1e-07 -- No Tox

Data

1e-07

Benzo(a)Pyrene 6e-07 -- No Tox

Data

6e-07

Aroclor-1248 1e-08 -- 7e-09 2e-08

Aroclor-1254 1e-08 -- 8e-09 2e-08

Antimony No tox data -- No Tox

Data

--

Arsenic 7e-06 -- 1e-06 8e-06

Selenium -- -- -- --

(Total) 7e-06 -- 1e-06 8e-06 (Total) 1e+00 -- 2e-01 1e+00

Particulates Benzo(a)Anthracene -- No Tox

Data

-- -- -- -- -- --

Benzo(b)Fluoranthene -- No Tox

Data

-- -- - - - -

Benzo(a)Pyrene -- No Tox

Data

-- -- -- -- -- --

Aroclor-1248 -- 2e-09 -- 2e-09 -- -- -- --

Aroclor-1254 -- 2e-09 -- 2e-09 - - - -

Antimony -- No Tox

Data

-- -- - - - --

Arsenic -- 1e-05 -- 1e-05 - - - --

Selenium -- -- -- -- -- -- -- --

(Total) -- 1e-05 -- 1e-05 (Total) -- -- -- --

Total Risk Across Soil 2e-05 Total Hazard Index Across All Media and All Exposure

Routes1e+00

Total Risk Across All Medial and All Exposure Routes 2e-05 Total Skin III 1e+00

TABLE 7

RISK ASSESSMENT SUMMARY

GENERAL GAS MANTLE

Scenario Timeframe: Future

Receptor Population: Construction Worker

Receptor Age: Adult

Medium Exposure Chemical

Carcinogenic Risk

Chemical

Non-Carcinogenic Hazard Quotient

Ingestion Inhalation Dermal Exposure

Routes Total

Primar

y

Target

Organ

Ingestion Inhalation Dermal Exposure

Routes Total

Soil Soil Benzo(a)Anthracene 2e-09 -- No Tox Data 2e-09 Aroclor-1248 N/A 2e-03 -- 1e-03 3e-03

Benzo(a)Pyrene 2e-08 -- No Tox Data 2e-08 Selenium Liver 2e-04 -- No Tox Data 2e-04

Aroclor-1248 9e-10 -- 7e-10 2e-09

Selenium -- --

Thallium -- --

(Total) 2e-08 -- 7e-10 2e-08 (Total) 2e-03 -- 1e-03 3e-03

Particulates Benzo(a)Anthracene -- No Tox

data

-- -- -- -- -- --

Benzo(a)Pyrene -- No Tox

data

-- -- -- -- -- --

Aroclor-1248 -- 2e-10 -- 2e-10 -- -- -- --

Selenium -- -- -- -- -- -- --

Thallium -- -- -- -- -- -- --

(Total) -- 2e-10 -- 2e-10 (Total) -- -- -- --

Total Risk Across Soil 2e-08 Total Hazard Index Across All Media and All Exposure Routes 3e-03

Total Risk Across All Medial and All Exposure Routes 2e-08 Total Skin III = 2e-04

TABLE 8

SUMMARY OF ALTERNATIVE COSTS

WELSBACH/GENERAL GAS MANTLE SITE

ALTERNATIVE PROPERTY CAPITAL O & M*

(30 Years)

TOTAL

NO ACTION

WELSBACH (W-1) $0 $0 $0

VICINITY PROPERTIES (V-1) $0 $0 $0

GENERAL GAS MANTLE (G-1) $0 $0 $0

ENGINEERING

CONTROLSWELSBACH (W-2) $5,686,000 $496,000 $6,182,000

VICINITY PROPERTIES (V-2) $900,000 $910,000 $1,810,000

GENERAL GAS MANTLE (G-2) $122,000 $259,000 $381,000

EXCAVATION AND

OFF-SITE DISPOSALWELSBACH (W-3) $18,503,560 $0 $18,503,560

VICINITY PROPERTIES (V-3) $13,408,560 $0 $2,309,560

GENERAL GAS MANTLE

OPTION B (G-3)1

$2,309,560 $0 $2,309,560

GENERAL GAS MANTLE

OPTION B (G-3)2

$1,979,560 $0 $1,979,560

* O&M costs calculated using an 8 percent discount rate

1. Option A: Demolition and Disposal of GGM building2. Option B: Decontamination and Demolition of GGM building

43

TABLE 9

SITE SPECIFIC CLEANUP STANDARDS

TYPE PERTINENT

STANDARD OR

GUIDELINE

SOURCES

Radon and ThoronIndoor Concentration

4 pCi/L Citizen Guide toRadon (EPA 1992)

Radon and ThoronDecay Progeny:

AverageMaximum

0.02 WL0.03 WL

40 CFR 19240 CFR 192

Soil:Radium andOther Radionuclides

5 pCi/g - Sum of 226Ra and 228Ra5 pCi/g - Sum of 230Th and 232Th

40 CFR 192

Subsurface Soil:Radium andOther Radionuclides

5 pCi/g - Sum of 226Ra and 228Ra5 pCi/g - Sum of 230Th and 232Th

OSWER Directive9200.4-25

Wetlands Protection of Wetlands Clean Water act40 CFR 230.1 et seq.

Executive Order 11990

Endangered Species Protection of Endangered andThreatened Species

Endangered Species Act16 U.S.C. 1536 (a)(2)

Historic Buildings Protection of ArchaeologicalSignificant Items

National HistoricPreservation Act16 U.S.C. 470(f)

APPENDIX III

ADMINISTRATIVE RECORD INDEX

WELSBACH & GENERAL GAS MANTLE CONTAMINATIONADMINISTRATIVE RECORDINDEX OF DOCUMENTS

1.0 SITE IDENTIFICATION

1.2 Notification/Site Inspection Reports

P. 100001-100308

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites. Camden and GloucesterCity, New Jersey, Volume I of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.

P. 100309-100551

Report: Final Hazard Ranking SystemDocumentation Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume II of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.

P. 100552-101016

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume III of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.

P. 101017-101428

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume IV of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared

1

by Mr. Steven T. McNulty, Project manager, Mr.Todd G. Teryek, Task Leader, Mr. John L.Splendore, P.E., Work Assignment Manager, U.S.EPA, Region 11, March 27, 1995.

P. 101429-101707

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites. Camden and GloucesterCity, New Jersey, Volume V of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.

P. 101708-102024

Report: Final Hazard Ranking SystemDocumentation Welsbach and General GAS MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VI of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.

P. 102025-102600

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VII of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995. (Note: The Gloucester City/CamdenSurvey of Affected Properties for SeniorCitizens and Children, pages 102298-102305, isconfidential due to the Privacy Act. It islocated at the U.S. EPA Superfund RecordsCenter, 290 Broadway, 18th Fl., N.Y., N.Y.10007-1866.)

P. 102601-102920

Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VIII of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John

2

L. Splendore, P.Z., Work Assignment Manager,U.S. EPA, Region II, March 27, 1995. (Note: TheQuality Control Internal Controls and AuditsManual, pages 102763-102822, and The QualityAssurance Manual pages 102823-102876, areconfidential business information. They arelocated at the U.S. EPA Superfund RecordsCenter, 290 Broadway, 18th Fl., N.Y., N.Y.10007-1866.)

1.4 Site Investigation Reports

P. 102921-102947

Report: An Aerial Survey of Gloucester, NewJersey and Surrounding Area, prepared for theU.S. EPA, Region II, prepared by Mr. Joel E.Jobst, Mr. Harvey W. Clark, Project Scientists,May 1981.

3.0 REMEDIAL INVESTIGATION

3.3 Work Plans

P. 300001-300192

Plan: Welsbach/General Gas MantleContamination Sites, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft Final Work Plan,Remedial Investigation/ Feasibility Study,Volume I, prepared for the U.S. EPA, Region II,prepared by Malcolm Pirnie, Inc., June 1997.

3.4 Remedial Investigation Reports

P. 300193-300347

Report: Welsbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No, 050-28UC, Stage 1aArchaeological Investigation, prepared for theU.S. EPA, Region II, prepared by MalcolmPirnie, Inc., June 1998.

P. 300348-300694

Report: Welsbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No, 050-28UC, Draft Final RemedialInvestigation/Feasibility Study Report, VolumeI, prepared for the U.S. EPA, Region II,prepared by Malcolm Pirnie, Inc., June 1998.

P. 300695-301035

Report: Welsbach and General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft Final RemedialInvestigation/Feasibility Study Report, VolumeII,

3

prepared for the U.S. EPA, Region II, preparedby Malcolm Pirnie, Inc., June 1998.

3.5 Correspondence

P. 301036-301134

Report: Weslbach/ General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC Response to Comments,prepared for the U.S. EPA, Region II, preparedby Malcolm Pirnie, Inc. November 1997.

P. 301135-301145

Memorandum to Addressees, from Stephen D.Luftig, Director, of Office of Emergency andRemedial Response, and Mr. Larry Weinstock,Acting Director, Office of Radiation and Indoorair, re: Establishment of Cleanup Levels forCERCLA Sites with Radioactive Contamination,August 22, 1997.

P. 301146-301151

Memorandum to Addressees, from Mr. Stephen D.Luftig, Director, of Office of Emergency andRemedial Response, and Mr. Larry Weinstock,Acting Director, Office of Radiation and Indoorair, re: Use of Soil Cleanup Criteria in 40 CFRPart 192 as Remediation Goal for CERCLA sites,February 12, 1998.

7.0 ENFORCEMENT

7.3 Administrative Orders

P. 700001-700059

Administrative Orders on Consent for RemedialInvestigation/Feasibility Study ArmstrongBuilding, In the Matter of Welsbach Gas MantleContamination Site (8U), Holt Hauling andWarehouse System, Inc., Respondent, undated.

8.0 HEALTH ASSESSMENTS

8.1 ATSDR Health Assessments

P. 800001-800037

Memorandum to Mr. John Prince, ERRD/NJSB1-N,from Mr. Arthur Block, Senior. RegionalRepresentative, re: Final Health Consultationfor Welsbach and General Gas MantleContamination Sites (WGGMCS), March 12, 1997.

4

10.0 PUBLIC PARTICIPATION

10.2 Community Relations Plans

P. 10.00001-10.00038

Plan: Weslbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft FinalCommunity Relations Plan, RemedialInvestigation/Feasibility Study, prepared forthe U.S. EPA, Region II, prepared by MalcolmPirnie, June 1997.

10.9 Proposed Plan

P. 10.00039-10.00059

Plan: Superfund Proposed Plan, Weslbach/General GasMantle Contamination, Superfund Site, Camden andGloucester City, Camden County, New Jersey, preparedby U.S. EPA Region II, February 1999.

5

APPENDIX IV

STATE LETTER

July 21, 1999

Ms. Jeanne M. Fox

Regional Administrator

U.S. EPA - Region II

290 Broadway

New York, NY 10007-1866

Subject: Welsbach/General Gas Mande Contamination Superfund Site

Record of Decision (ROD)

Dear Mr. Fox:

The New Jersey Department of Environmental Protection (NJDEP) has evaluated and concurs with the

component of the selected remedy as described below for the Welsback/General Gas Mantle Superfund Site.

The selected remedy corresponds to the first of three planed operable units for the Site which includes

properties located in Gloucester City and Camden, Camden County, New Jersey.

The major components of the selected remedy include:

• Excavation/removal of soil and waste materials with radiological contamination above remedial action

objectives from the former Welsback and General Gas Mantle Facilities;

• Excavation/removal of soil and waste materials with radiological contamination above remedial action

objectives from the residential and commercial properties in the vicinity of two former gas mantle facilities;

• Off-site disposal of the radiologically-contaminated soil and waste materials;

• Decontamination and demolition of the General Gas Mantle Building; and

• Appropriate environmental monitoring to ensure the effectiveness of the remedy.

NJDEP concurs that the selected remedy is protective of human health and the environment, complies with

requirements that are legally applicable or relevant and appropriate for the remedial action, and is cost

effective.

2

The State of New Jersey appreciates the opportunity afforded to participate in the Superfund process.

APPENDIX V

RESPONSIVENESS SUMMARY

RESPONSIVENESS SUMMARY

FOR THE

WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE

GLOUCESTER CITY & CAMDEN, CAMDEN COUNTY, NEW JERSEY

I. INTRODUCTION

This Responsiveness Summary provides a summary of public comments and concernsregarding the remedial investigation and feasibility study (RI/FS) report and the ProposedPlan for the Welsbach/General Gas Mantle Contamination site. It also provides the U.S.Environmental Protection Agency's (EPA's) responses to those comments. After reviewingand considering all public comments received during the public comment period, EPA hasselected a remedy for the former Welsbach Facilitv, the former General Gas Mantle (GGM)Facility, and the Vicinity Properties at the Welsbach/General Gas Mantle Contamination site.

The RI/FS report, the Proposed Plan and supporting documentation were made available tothe public in the administrative record file at the Superfund Document Center in EPA RegionII. 290 Broadway, 18th Floor, New York, New York 10007 and at the following repositories:City of Camden Main Library, 418 Federal Street, Camden, New Jersey 08103; the HynesCenter, 1855 South 4th Street, Camden, New Jersey 80104; and the Gloucester City PublicLibrary, Monmouth and Hudson Streets, Gloucester City, New Jersey 08030. The notice ofavailabil ity for the above-referenced documents was published in the Philadelphia Inquireron February 1, 1999, the Courier-Post on February 2, 1999, and the Gloucester City Newson February 4, 1999. The public comment period which related to these documents was heldfrom February 1, 1999 to March 3, 1999.

EPA conducted public meetings in both Gloucester City and Camden to inform local officialsand interested citizens about the Superfund process, to review proposed remedial activitiesat the Site and receive comments on the Proposed Plan, and to respond to questions fromarea residents and other interested parties. Meetings were held on February 23, 1999, at thePine Grove Fire Station #2 in Gloucester City, and on February 24, 1999, at the CamdenCounty Municipal Utilities Authorities Auditorium in Camden. Responses to the commentsreceived at the public meeting are included in this Responsiveness Summary. The City ofGloucester City submitted a resolution supporting the proposed remedy. No other writtencomments were received during the public comment period.

In general, the community responded positively to EPA's Proposed Plan. A majority of theresidents recognized the importance of remediating the contamination at theWelsbach/General Gas Mantle Contamination site.

The next section of this Responsiveness Summary provides a comprehensive summary ofmajor questions, comments, concerns, and responses, by summarizing oral comments madeat the public meetings and EPA's responses.

2

The last section of this Responsiveness Summary includes appendices which documentpublic participation in the remedy selection process for this site. There are four appendicesattached to this Responsiveness Summary. They are as follows:

Appendix A contains the Proposed Plan that was distributed to the public for reviewand comment, and a Proposed Plan Summary that was provided to interested partieswith the Proposed Plan:

Appendix B contains the public notices which appeared in the Philadelphia Inquire,the Courier-Post, and the Gloucester City News;

Appendix C contains the transcripts of the public meetings; and

Appendix D contains the written comments received by EPA during the publiccomment period.

II COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS, AND RESPONSES

Oral Comments Received During the Public Meetings

This section summarizes oral comments raised at the public meetings and EPA's responses.The comments and corresponding responses are presented in the following categories:

1.0 Remedial Investigation and Feasibility Study2.0 EPA's Proposed Plan3.0 Health and Safety4.0 Cleanup Schedule5.0 Public Participation Process6.0 Real Estate Issues7.0 Other

1.0 Remedial Investigation and Feasibility Study

1.1 Comment: An interested resident noted that the maps prepared for the project showedthat properties north of the General Gas Mantle Building were not investigated. EPA wasasked whether these properties would be included in future investigations.

Response: During the remedial design, EPA will investigate these properties and otherproperties that are adjacent to known contaminated properties.

3

2.0 EPA's Proposed Plan

2.1 Comment: An interested citizen asked what will happen to the residents while the remedial

work is going on.

Response: EPA will work with the property owner(s) so that there is as little inconvenience to

residents as possible. If there is a need for temporary relocation, the property owner will not be

responsible for any costs. All costs associated with the temporary relocation will be paid by EPA.

2.2 Comment: An interested citizen asked if the decision on whether to proceed with the

demolition of the GGM building and excavation of the contaminated material from the site has

been made.

Response: EPA will not make a final decision until all public comments have been received;

however, the preferred remedy calls for the demolition of the GGM building and the excavation

and off-site disposal of the radiologically-contaminated soils and waste materials. At that time,

EPA will issue the Record of Decision (ROD) which formally selects a remedy for the cleanup

of the site.

2.3 Comment: An interested resident inquired as to how the contaminated material would be

shipped from the site.

Response: The material will be shipped off-site via rail transport. The material will be excavated

from any given contaminated property and loaded onto a truck for transport to a rail loading site

in or near Gloucester City or Camden. Measures will be taken to secure the containers holding

the contaminated material to ensure the public's safety.

2.4 Comment: An interested resident asked how deep the excavations are going to be in the

backyards of the homes on Arlington Street in Camden.

Response: At this time, EPA does not know the exact depths and volumes of soil that would

need to be removed from the Arlington Street properties. The exact volumes will be determined

during the remedial design phase. For the purpose of the RI/FS, volume estimates were based on

the investigation of other properties with similar conditions. Based on this information, EPA

estimates that contamination is generally limited to the top one to two feet of soil.

2.5 Comment: An interested citizen asked if there is a work plan for the demolition of the GGM

building and excavation and off-site disposal of the radiologically-contaminated materials.

Response: A work plan for the construction activities will be prepared after the Remedial

Design is completed. Prior to beginning construction activities, EPA will hold public meetings

4

describing the construction activities that would take place. At that time, a work plan would be

available for review at the public repositories.

2.6 Comment: An interested citizen complimented EPA on selecting the most thorough remedy

and asked whether the cleanup will allow for future unrestricted use of the properties.

Response: The cleanup criteria are protective of both human health and the environment.

Consequently, once the material has been removed, there would be no restriction on future uses

of these properties.

2.7 Comment: An interested resident asked if residents would be relocated during the cleanup

and for how long.

Response: Based on EPA's current findings, only a limited number of individuals may need to

be temporarily relocated during remediation. EPA would assure that relocated residents would

be provided with comparable accommodations. EPA would pay for temporary relocation

expenses. On similar sites that required relocation, EPA has found that the length of time a

resident would be relocated ranges from three to six months.

2.8 Comment: An interested party asked if EPA is going to check for radon in the basements.

Response: Part of EPA's investigation protocol is to perform a radon test on any potential

radiologically-contaminated property.

2.9 Comment: A interested party asked whether EPA would reconsider the cleanup plan if it

discovered much more contamination that expected.

Response: EPA does not anticipate finding such a substantial additional amount of

contamination that it would require changing the proposed remedy. The communities of both

Camden and Gloucester City support the remedy. Where EPA finds radiological contamination,

it will take it away. Once the ROD has been issued, EPA would be required to hold additional

public meetings and receive public comment before it modified the selected remedy.

3.0 Public Health Concerns

3.1 Comment: An interested resident questioned whether there were any long-term health effects

associated with the site. In particular, the resident mentioned the recent cancer study prepared by

the New Jersey Department of Health which indicated a higher than normal occurrence of lung

cancer throughout the area surrounding the site.

Response: The only long-term health effect from radiation is an increase in the risk of

developing cancer. Although the study indicated that there was an increase in the incidence of

5

lung cancer in the area, the results of the cancer study indicate that the Superfund sites were not

the probable cause for this increase.

3.2 Comment: An interested citizen inquired about whether a health study would be performed

on the residents of contaminated properties both prior to and following any remedial actions.

Response: EPA does not plan to perform focused health studies on residential property owners in

the future.

3.3 Comment: An interested resident asked what would be done for the residents while the soil

was being removed and will this pose any problems for people. How is EPA going to protect

them?

Response: The problems are more logistical than health based. The work will be performed in a

controlled manner to reduce dust and to ensure there is no spread of contamination. If there is a

potential health risk or significant inconvenience to the property owner, the homeowner may be

temporarily relocated until the work is complete.

3.4 Comment: A resident found some material from Welsbach in his home and was concerned

about possible health affects.

Response: At the public meeting, EPA informed the resident that it would scan his property to

see if there was any radiological contamination. A few days after the public meeting, EPA

investigated the property and found no radiological contamination.

4.0 Cleanup Schedule

4.1 Comment: An interested resident asked how soon the former GGM building would be

demolished.

Response: EPA anticipates that the GGM building will be demolished within one to two years.

5.0 Public Participation Process

5.1 Comment: An interested resident asked whether EPA was in contact with Camden city

officials.

Response: Yes, EPA has discussed the proposed remedial actions with the City of Camden’s

mayor’s office.

5.2 Comment: An interested resident asked what the next steps would be regarding informing the

residents of upcoming activities.

6

Response: Following the public comment period, EPA will prepare a ROD which selects the

cleanup remedy for the site. The ROD will include all of the public comments and EPA’s

responses. After the ROD is signed, EPA will place it in the local public repositories. The new

public meeting will be held prior to the start of any construction activities. EPA will also provide

periodic updates during the cleanup process.

6.0 Real Estate Issues

6.1 Comment: An interested citizen asked what could or should be done if an owner of a

contaminated property wishes to sell the property.

Response: The owner should provide a prospective buyer with all data about contamination on

the property. The participants in the transaction would need to obtain the advice of an Attorney

regarding their obligations under State law. If necessary, EPA can enter into an prospective

purchaser agreement with a potential purchaser of a contaminated property. The agreement would

provide that the purchaser would not be held liable for any cleanup costs associated with the

property. EPA’s policy is not to pursue innocent landowners for cost recovery.

6.2 Comment: An interested resident asked whether the owner of a contaminated property who

became the owner through inheritance from a relative would be responsible for cleanup costs.

Response: Persons who inherit contaminated property will not be held responsible for cleanup

costs if they can demonstrate that they had nothing to do with the contamination and can meet the

other requirements set forth in Sections 107(b) and 101 (35(A)(iii.) of CERCLA. There are

similar provisions in State law and an Attorney should be consulted on these matters.

Furthermore, under EPA’s existing policy, residential owners of contaminated property will not

be asked to demonstrate that they have defenses to liability or asked to reimburse EPA for the

costs of cleaning up that property so long as the owners did not cause or exacerbate the

contamination and they cooperate with EPA’s cleanup efforts.

7.0 Other

7.1 Comment: An interested resident asked if the NJDEP had performed property surveys in the

neighborhood of the Jogging Track, where a removal of contaminated material occurred.

Response: With few exceptions, the properties surveyed by the NJDEP were within the areas

identified in the Aerial Radiological Survey performed by EPA in 1981. Certain areas were

excluded based upon records which indicated that homes were constructed prior to the dates of

dumping/filling activities. Because the area in question was outside the areas identified in the

aerial survey. NJDEP did not survey this area.

7.2 Comment: An interested citizen asked if money has been approved for this project.

7

Response: EPA has allocated money for the design of the project. The design phase of the project

must be completed before EPA can allocate money for construction. When the design phase is

complete, EPA’s regional office will request EPA Headquarters in Washington, D.C. to allocate

funding for this project. At this time, we do not anticipate any problems.

7.3 Comment: A number of residents expressed concern over security issues associated with the

radiological contamination at the Popcorn Factory part of the site in Gloucester City.

Response: The former Popcorn Factory property is surrounded by a fence to keep people away

from the contamination. Gloucester City also placed gravel over the contaminated areas to protect

the residents. There are no signs posted because a majority of the residents in the area informed

city officials that they preferred no signs around the property. The contaminated materials from

EPA’s removal action which are presently being stored in roll-offs on the property are securely

covered. (Since the public meeting, the roll-off containers have been removed and disposed

off-site.)

7.4 Comment: A number of citizens questioned whether contamination was found in the area

designated for a playground near the Jogging Track in Gloucester City.

Response: At the public meeting EPA indicated that it would investigate the area designated for

the playground prior to its construction. In March 1999, EPA investigated this area and found no

radiological contamination.

Written Comments Received During the Public Comment Period

Comment: The City of Gloucester City submitted a resolution endorsing EPA’s plans for

cleaning up the radiologically contaminated properties in Gloucester City.

Response: No response necessary.

Appendix A

Proposed Plan

EPA Region 2 - February 1999 Page 2

EPA will also be available on an informal basis to

answer any questions at the Pine Grove Fire Station

#2 on Tuesday, February 23, 1999, from 1:00 p.m.

to 4:00 p.m. and at the Camden County Municipal

Utilities Authority Auditorium on Wednesday,

February 24, 1999, from 1:00 to 4:00 p.m.

Comments received at the public meeting and all

written comments, will be documented in the

Responsiveness Summary Section of the Record of

Decision (ROD), the document which formalizes the

selection of the remedy. All written comments should

be addressed to:

Richard J. Robinson

Project Manager

U.S. ENVIRONMENTAL PROTECTION AGENCY

290 Broadway, 19th Floor

New York, NY 10007-1866

Copies of the RI/FS report, Proposed Plan, and

supporting documentation are available at EPA’s

office at 290 Broadway, 18th Floor, New York, NY

10007-1866, (212) 637-4308, and at the following

repositories:

City of Camden Main Library

418 Federal Street

Camden, NJ 08103

(609)757-7650

Hynes Center

1855 South 4th Street

Camden, NJ 80103

(609)966-9617

Gloucester City Public Library

Monmouth and Hudson Streets

Gloucester City, NJ 08030

(609)456-4181

EPA, after consultation with NJDEP, will select a

remedy for the Site only after the public comment

period has ended, and the information submitted

during that time has been reviewed and considered.

EPA is issuing this Proposed Plan as part of its public

participation responsibilities under Section 117 (a) of

the Comprehensive Environmental Response,

Compensation and Liability Act: (CERCLA), as

amended, and Section 300.430(f) of the National Oil

and Hazardous Substances Pollution Contingency

Plan (NCP).

SITE BACKGROUND

Between the 1890s and 1940s, the Welsbach

Company (Welsbach) manufactured gas mantles at its

facility in Gloucester City, New Jersey. Welsbach

was a major manufacturer and distributer of gas

mantles until gas lighting was replaced by the electric

light. Welsbach extracted the radioactive element

thorium from ore and used it in the gas mantle

manufacturing process. Thorium causes the mantles to

glow more brightly when heated. A second gas mantle

manufacturing facility, known as the General Gas

Mantle Company (GGM), was located in Camden,

New Jersey. GGM was operated from 1915 to

approximately 1940.

EPA initially identified the Site in 1980, during an

archive search conducted as part of the investigation

of the U.S. Radium Corporation Superfund site

located in Orange, New Jersey. Historical U.S.

Radium Corporation files indicated that radiological

materials were purchased by U.S. Radium from the

Welsbach Corporation during the 1920's.

In May 1981, EPA conducted an aerial radiological

survey of the Camden and Gloucester City area to

investigate for radioactive contaminants. The survey

encompassed a 20 square kilometer area surrounding

the former locations of the Welsbach and General

Gas

Mantle Facilities. Five areas with elevated gamma

radiation were identified from the aerial survey; they

included the locations of the two former gas mantle

manufacturing facilities and three mainly residential

areas in both Camden; and Gloucester City. In 1993,

the data form the aerial survey were reanalyzed.

Based on this revised information, EPA identified a

sixth potential radiologically contaminated area which

includes two vacant lots in Gloucester City.

EPA Region 2 - February 1999 Page 3

In the early 1990s, NJDEP conducted more detailed

radiological investigations at more than 1,000

properties located throughout the original five study

areas. Radiological contamination was found at the

two former gas mantle facilities. NJDEP data also

indicated that approximately 100 properties near the

two former gas mantle facilities might be

contaminated. In 1996, the Welsbach/GGM site was

placed on National Priorities List (NPL) because of

the presence of radioactive contaminants.

Based on their geographic proximity. EPA divided the

Welsbach/GGM site into six study areas in Camden

and Gloucester City, New Jersey (Figure 1). A brief

description of each study area and its current land use

is presented below:

• Study Area One: includes the former

General Gas Mantle Facility and residential

and commercial properties which surround

the facility. The former GGM Facility is

located in a mixed industrial, commercial,

and residential zoned section of Camden.

• Study Area Two: includes the location of the

former Welsbach Facility and nearby

residential commercial properties. The

former Welsbach Company is situated in an

industrial zoned section of Gloucester City

with residential properties to the immediate

east.

• Study Area Three: includes residential and

recreational properties in Gloucester City.

including the Gloucester City Swim Club and

the Johnson Boulevard Land Preserve.

• Study Area Four: includes residential

properties in the Fairview section of Camden.

• Study Area Five: includes residential

properties, vacant land properties, and two

municipal parks near Temple Avenue and the

South Branch of Newton Creek in Gloucester

City.

• Study Area Six: includes two vacant lots in

a residential zoned area of Gloucester City.

This area was initially identified when the

aerial survey data were revised in 1993. This

area was identified during site assessments

performed by the City of Gloucester City.

No significant changes in land use are anticipated,

except in the Study Area 1 where there is a

possibilities that some residential areas may be

rezoned for commercial uses. Whether zoning

chances will actually be made is uncertain at this

time.

SITE HISTORY

The Welsbach and the GGM Facilities have complex

histories of name and ownership changes. Specific

details are discussed in the paragraphs below.

The United Gas Improvement Company, which

formed Welsbach, purchased the patent rights to

manufacture thorium-containing gas mantles in the

1880s from Dr. Carl Auer van Welsbach. The process

for manufacturing the Welsbach gas mantle used a

highly purified solution of 99 percent thoriurn nitrate

and 1 percent cerium nitrate as a "lighting fluid" in

distilled water. A fabric sock was then dipped into the

thorium solution to create the gas mantle. Thoriurn

caused the gas mantle to give off a very bright white

light when lit.

The commercial source of thorium and cerium is a

mineral known as monazite sand. Monazite sand

contains approximately 5-6 percent thorium oxide and

20-30 percent cerium oxide. Thorium was typically

extracted from the monazite ore by heating the ore in

a sulfuric acid solution. The thoritizin, and other rare

earth element’s would go into solution. while the

radium-228 remained in the tailings of insoluble

sulfates. Around 1915, Welsbach started using and

selling the radium-228 for its use in luminescent

paint. For a number of years, Welsbach was the

largest manufacturer of gas mantles in the world

making up to 250,000 mantles per day at its peak.

Welsbach also made gas room heaters, gas storage

water heaters, gas and electrical fixtures, electrical

refrigerators, plumbing supplies and lacquers.

Manufacturing operations at the Welsbach facility

Page 4

EPA Region 2 - February 1999 Page 5

began as early as 1882 and lasted until the 1940s. The

facility property covered an area of about 21 acres,

and consisted of about 20 buildings.

In 1948, the former Welsbach Facility in Gloucester

City was sold to the Randall Corporation, and leased

to the Radio Corporation of America, Victor Division.

In May 1976, the property was purchased by Holt

Hauling and Warehousing, Inc. (Holt), the current

owner of the property. Holt operates a cargo and

overseas shipping business.

Only one Welsbach era building, the Armstrong

Building, is still present on the property. There is no

information available on when the other

Welsbach-era buildings were demolished. The

Armstrong Building is not part of this Operable Unit.

Holt is performing an RI/FS of the Armstrong

Building under an Administrative Consent Order with

EPA.

The former gas mantle manufacturing facility in

Camden was owned and operated by the GGM

Company from 1912 to 1941. There is little

information available regarding activities at GGM,

other than it used and resold radium and thorium.

Between 1941 and 1978, there had been a total of

seven different private owners of the property. Based

on current information, none of these operations

involved radioactive materials. In January 1978, the

southern portion of the property was occupied by the

Dynamic Blending Company. In October 1988, the

northern portion of the property was purchased by

Ste-Lar Textiles. In 1992, NJDEP removed

radiologically contaminated fabrics from the facility,

relocated Ste-Lar, and sealed up the GGM building to

restrict access.

During the years that Welsbach and GGM operated,

ore tailings were used for fill at properties in the

vicinity of the facilities. It is also reported that

building debris from the former Welsbach Facility

may have been disposed of as fill in the area. In

addition, workers from the former Welsbach and

GGM Facilities may have brought contamination

home with them. These properties associated with

radiological waste from the Welsbach and GGM

Facilities are collectively termed Vicinity Properties

In 1991, NJDEP initiated a radiological investization

at more than 1,000 properties located throughout

Study Areas 1 through 5. At properties where

NJDEP determined that exposure levels were

unacceptable (or posed an immediate health risk ).

they performed interim remedial measures. These

measures included the installation of radon thoron

ventilation systems and placement of concrete or lead

sheeting to shield gamma radiation. In addition.

NJDEP restricted access to outdoor areas which

exceeded its action levels.

In 1998, EPA identified a 100 square foot area in a

Gloucester City Park, located in Study Area 5, that

had high levels of gamma radiation at the surface. In

December 1998. EPA performed a removal action to

reduce exposure to the high levels of gamma radiation

at the surface. EPA excavated the top three feet of

radiologically contaminated soil and replaced the

waste material with clean fill.

THE NATURE OF RADIONUCLIDES

A radionuclide is an element that spontaneously

changes, or “decays” into another element through

natural processes. Radionuclides are present in trace

amounts in all rocks and soils, and consist primarily

of elements of the uranium-238 and thorium-232

decay series. There are approximately 1,700 different

unstable atomic species, or radionuclides. These

include both naturally occurring and man-made

radionuclides.

The radionuclides of concern in the wastes which

originated at the former Welsbach and GGM

Facilities are members of the uranium and thorium.

decay series. There are 14 unique radionuclides in the

uranium decay series and 11 unique radionuclides in

the thorium decay series which precede the formation

of stable lead (Pb-206 or Pb-208). Alpha, beta, and

gamma radiation are emitted from the various

members of the two decay series. The primary

nuclides of concern are Thorium-232,

EPA Region 2 - February 1999 Page 6

Radium-226, and radon gas (Radon-222 and

Radon-220.)

Each radionuclide has its own unique characteristic

“fingerprint,” consisting of three parameters:

1. The radioactive half-life describes the

amount of time in which half of any given

number of atoms of a radionuclide will

decay.

2. The mode of decay refers to the type(s) of

particles or electromagnetic rays emitted

from the radionuclide as it decays. These

types include alpha and beta particles, and

gamma rays.

3. The amount of energy carried away from the

atom by the particles or rays is radionuclide

specific. It is the transfer of this energy to

living tissue which may cause biological

effects.

When radionuclides decay, they emit energy in the

form of radiation. The decaying radionuclide is often

called the “parent”, and the radionuclide produced is

called the “decay product”. A quantity of radioactive

material is measured by its rate of decay, expressed

by the unit Curie (Ci), which is equal to 2.22 x 1012

(2.22 trillion) disintegrating atoms per minute. A

more convenient unit for expressing environmental

radioactivity is the picoCurie (pCi), which is equal to

1 x 10-12 (one trillionth) Ci.

Radium-226 is a naturally occurring, radioactive,

metallic elernent formed from the decay of uranium.

In its decay, Radium-226 forms Radon-222 or radon

gas. Radon gas is colorless, odorless, radioactive and

inert; therefore, it can move easily through soil to the

ground surface or into houses. Within a matter of

days. the radon gas itself decays into a series of

radioactive decay products. While radon gas in the

outdoor air dissipates quickly, the concentration of

radon decay products in the indoor air can build up

over time. Exposure to the energy released by these

various decaying atoms can result in adverse health

effects. For radon decay products, a special unit,

called Working Level (WL) has been developed.

Working Level is defined as any combination of

short-lived radon decay products in 1 liter of air that

will result in the ultimate emission of 1.3 x 105 Mega-

electron Volts of potential alpha energy. This value is

approximately equal to the alpha energy released

from the decay of progeny in equilibrium with 100

pCi of Radon-222.

Thorium-232 is also a naturally occurring

radionuclide and is the initial radionuclide of the

thorium decay series. Its decay products include

radium-228 and Radon-220. Radon-220 is also

known as thoron. Thoron and its decay products have

extremely short half-lives that usually prevent them

from concentrating to any appreciable extent in indoor

air. However, if a significant source of thoron exists

within, beneath, or adjacent to a structure (such as the

thorium. and radium-228 found in Welsbach/GGM

site wastes), thoron decay products can reach

concentrations which create health risks.

REMEDIAL INVESTIGATION SUMMARY

In September 1997, EPA started an RI to characterize

the nature and extent of contamination at the

Welsbach Facility, General Gas Mantle Facility, and

20 of the radiologicaily contaminated properties

identified by NJDEP in the vicinity of Welsbach and

GGM. In order to develop a cleanup strategy for the

Site, the RI field investigations were divided into

three property categories, as follows:

· Former Welsbach Company Facility;

· Former General Gas Mantle Company

Facility;

· Vicinity Properties

The RI/FS report presents the results of field

investigations conducted to date at both Welsbach and

GGM Facilities and the 20 Vicinity Properties. In

future phases of the remediation, called operable

units, EPA will investigate potentially impacted

groundwater, surface water, and sediments.

EPA Region 2 - February 1999 Page 7

Property Investigations

EPA conducted both chemical and radiological

characterizations of the former Welsbach and GGM

Facilities to define the extent of contamination. EPA

also performed a radiological investigation on 20 of

the potentially contaminated Vicinity Properties

identified by NJDEP. Only 20 Vicinity Properties

were investigated during the RI so that EPA could

confirm the NJDEP data and expedite the

development of cleanup alternatives. EPA will

investigate the remaining potentially contaminated

properties identified by NJDEP. and other properties

suspected of being possibly contaminated during the

remedial design phase of this cleanup. EPA estimates

that about 600 properties will be studied in the design

phase to determine exactly which properties require

cleanup. This additional work may include sampling

for chemical analysis, where deemed appropriate

when considering past ownership and historic

information. Field activities conducted as part of the

RI included the following:

! Radon measurements

! Radon decay product Working Level

measurements

! Gamma radiation surface and one-meter

height exposure rate surveys

! Surface and subsurface soil sampling

! Downhole gamma radiation logging

! Total surface beta surveys and removable

surface alpha and beta sampling

! Structural materials sampling (in some

buildings)

Results of Field Investigations

Areas with elevated levels of radioactivity that

exceeded the radiological standards for human health

were identified during the remedial investigations.

The RI data support the following conclusions:

Former Welsbach Facility

! Most of the radiological contamination is

located in the area of a former Welsbach

building that was demolished in the 1970s.

This area is currently used for storage.

However, there are smaller areas of

contamination scattered throughout the

property. The soil in these areas is

contaminated with elevated concentrations of

the thorium and uranium decay series

radionuclides. Subsurface contamination on

the Welsbach facility averages about 11 feet

in depth. An estimated 27,200 cubic yards of

soil/buried debris have thorium and or

radium concentrations exceeding 5 pCi/g.

Radium and thorium concentrations in soil

ranged from background (about 1 pCi/g for

each) to as high as 455 pCi/g and 1.190

PCi/g, respectively.

! Surface gamma exposure rates associated

with the contaminated soils ranged from

background (less than 10 micro-Roentgen per

hour [µR/h]) to 780 µR/h. The highest

readings were associated with a large fill

area identified in the middle of the storage

area.

! Low levels of chemical contaminants were

identified at the former Welsbach Facility.

Contaminants of potential concern include

semi-volatile organic compounds and arsenic.

These contaminants may be indicative of

“Historic Fill”. If this is confirmed in the

remedial design, then there may be no need

to excavate this soil. Instead, it may be more

appropriate to cap these soils in place.

Former General Gas Mantle Facility

! Elevated concentrations of thorium and

uranium decay series radionuclides were

identified in soils on the former GGM

property. Contamination was generally

limited to the top six to eight feet, although

contamination in some areas of South Fourth

Street and the GGM Courtyard ranged from

12 to 16 feet in depth. An estimated 900

cubic yards of soil had thorium and/or

radium concentrations which exceeded 5

pCi/g.

EPA Region 2 - February 1999 Page 8

Radium and thorium concentrations in soil

ranged from background to as high as 172

pCi/g and 149 pCi/g, respectively.

! Surface gamma exposure rates associated

with the contaminated soils ranged from

background (less than 10 µR/h) to 380 µR/h.

Only localized areas of surface

contamination were identified outdoors.

! Most of the outdoor contamination is located

in the area of South Fourth Street. However,

some smaller areas of contamination were

identified in the alleyway behind the property

that extended onto some backyards of

neighboring residential properties.

! Elevated levels of surface contamination

were observed in many areas inside the

former GGM building. Levels as high as

2.33 microCi per meter square (µCi/m2 ) area

were observed.

! Indoor gamma exposure rates ranged from

background to 900 µR/h.

! An estimated 1,460 cubic yards of

contaminated structural materials in the

building itself were identified, with thorium

concentrations as high as 750 pCi/g.

! In the basement of the former GGM building,

radon decay product concentrations measured

1.7 WL, compared to an average background

level of 0.005 WL.

! Certain semi-volatile organic compounds and

metals were identified. These were; however,

at such low levels that they are not chemicals

of concern. These contaminants may be

indicative of “Historic Fill”. If this is

confirmed in the remedial design, then there

may be no need to excavate this soil. Instead,

it may be more appropriate to cap these soils

in place.

Vicinity Properties

EPA investigated 20 properties in Camden and

Gloucester City for radiological contamination as part

of the RI. EPA compared these data to information

collected from earlier NJDEP investigators and

determined that the data were comparable. These data

support the following conclusions:

! Some site properties have indoor radon gas

concentrations or soil radionuclide

concentrations which pose a long-term risk to

human health.

! Contaminated soil averaged about two to

three feet in depth on most residential

properties. On a few properties,

contamination extended to 10 feet in depth.

! Based on the comparison of EPA and

NJDEP data, approximately 50 properties

were identified as having contamination

above the cleanup levels. During the

remedial design phase. EPA will delineate

the extent of contamination on these

properties in order to design a cleanup plan

for each property.

! EPA identified approximately 600 properties

that are either adjacent to the known

contaminated properties or have gamma

exposure rates above background levels. In

the RI report, these properties are termed

“suspect properties.” During the remedial

design phase, EPA will investigate and

sample these properties to see if there is any

radiological contamination present. If

contamination above the cleanup objectives

is found, EPA will delineate the extent of this

contamination and design a cleanup plan for

these properties.

SUMMARY OF SITE RISK

A baseline risk assessment was conducted for the

former Welsbach Facility, the former GGM Facility,

and the Vicinity Properties utilizing analytical data

EPA Region 2 - February 1999 Page 9

obtained during the RI. The baseline risk assessment

estimates the human health risk which could result

from the contamination at a site if no remedial action

were taken.

Ecological risks, that is, the risk to aquatic and

terrestrial wildlife (plants and animals), were not

evaluated for this operable unit because the study

areas consisted primarily of residential and

commercial properties. An Ecological Risk

Assessment will be conducted in a future RI to

evaluate the potential for adverse effects to aquatic

and terrestrial wildlife (plants and animals) in

accordance with Ecological Risk Assessment

Guidance for Superfund, Process for Designing and

Conducting Ecological Risk Assessments (EPA 540-

R-97-006).

To evaluate human health risks, a four-step process

was used for assessing site-related risks for a

reasonable maximum exposure scenario. These steps

are: Hazard Identification - identified the

contaminants of concern at the site based on several

factors such as toxicity, frequency of occurrence, and

concentration;Exposure Assessment - estimated the

magnitude of actual and/or potential human

exposures, the frequency and duration of these

exposures, and the pathways (e.g., ingesting

contaminated soil) by which humans are potentially

exposed; Toxicity Assessment - determined the types

of adverse health effects associated with exposures to

site contaminants, and the relationship between

magnitude of exposure (dose) and severity of adverse

effects (response); and Risk Characterization

summarized and combined outputs of the exposure

and toxicity assessments to provide a quantitative

(e.g., one-in-a-million excess cancer risk) assessment

of site-related risks.

For risk assessment purposes, individual contaminants

are typically separated into two categories of health

hazard depending on whether they exhibit

carcinogenic effects (causing cancer) or

noncarcinogenic effects (causing health effects other

than cancer.) Radionuclides (e.g., radium, thorium,

radon, thoron, and radon/thoron decay products) are

known carcinogens. Nonradiological chemical

contaminants (e.g.. PAHs and arsenic) may exhibit

both carcinogenic and noncarcinogenic health effects.

EPA's acceptable cancer risk range is 10-4

to 10-6

which can be interpreted to mean that an individual

may have a one in 10,000 to one in 1,000,000

increased chance of developing cancer because of

site-related exposure to a carcinogen.

Human health risks were estimated for both

radionuclides and chemicals of concern at the former

Welsbach and GGM Facilities, and for radionuclides

of concern at the Vicinity Properties. Building

materials and/or soil were the environmental media of

concern. Risks (that is, the probability of developing a

cancer because of exposure to radioactive materials)

were calculated based on “reasonable maximum

exposure” according to EPA guidance. This means

that risks are estimated as a result of exposure to

site-related carcinogens over a 30-year lifetime under

the specific exposure conditions at a site and other

exposure assumptions that result in an overall

exposure estimate that is conservative but within a

realistic range of exposure.

In assessing potential human health risks from

exposure to the radionuclides, several exposure

scenarios involving exposure to external gamma

radiation, ingestion of radioactive materials, and

inhalation of radioactive materials were evaluated.

Risks were estimated for several current and future

scenarios, and were compared to the risk from natural

background sources of radiation.

The maximum excess lifetime radiogenic (radiation

induced cell damage) cancer risks, that is, the risks

due solely to the presence of radioactive materials

above background levels, are 5.7 x 10-2 at the former

Welsbach Facility (to the current and future site

worker), 1.8 x 10-1 at the former GGM Facility (to a

hypothetical future site worker), and 1.8 x 10-2 to a

resident of a vicinity property. These radiogenic risks

exceed EPA's acceptable risk range. The cancer risk

from chemical exposures to the same populations at

the former Welsbach and GGM Facilities was also

EPA Region 2 - February 1999 Page 10

evaluated. The cancer risk did not exceed EPA's risk

range and; therefore, no additional remedial action is

necessary because of chemical contaminants.

To assess the potential for cumulative

noncarcinogenic efffects posed by multiple

contaminants, EPA has developed a hazard index

(HI). The HI is derived by adding the noncancer risks

for site chemicals with the same target organ or

mechanism of toxicity. When the HI exceeds 1.0.

there may be concern for adverse health effects due to

exposure to multiple chemicals.

For the Welsbach/GGM site, non-cancer health

effects were evaluated on1y at the former Welsbach

and GGM Facilities. The total HI for construction

worker exposure to the chemicals of concern in soil at

the former Welsbach Facility from ingestion, dermal

contact, and inhalation is equal to EPA's acceptable

level of 1.0. Ingestion of arsenic is the predominant

contributor to the risk estimate. The total HI for

construction worker exposure to the chemicals of

concern in soil at the GGM Facility from ingestion,

dermal contact, and inhalation is 3 x 10-2; this hazard

index is below EPA’s acceptable level of 1.0,

indicating that adverse, noncarcinogenic health effects

from such exposure are unlikely.

The following are the dominant radiological exposure

pathway risks for the various exposure scenarios

evaluated for the Welsbach/GGM site. At residential

properties and the former Welsbach Facility, the

majority of risk is from exposure to external gamma

radiation, or direct radiation. Occupants of the former

GGM Facility (current and future trespassers and

future site workers) are at risk primarily from

inhalation of thoron decay products. Future

construction worker risk is primarily due to direct

radiation, although inhalation of particulates

containing radioactive material also contributes a

significant portion of the risk.

This RI focused primarily on residential and

commercial properties, and sensitive species of plants

and animals are not likely to inhabit these portions of

the Site. However, sensitive species may be present

in Study Areas 3 and 4 around Newton Creek. Any

ecological risk characterization for these areas will be

conducted a future operable unit.

Actual or threatened releases of hazardous substances

from the Site, if not addressed by the preferred

alternatives, or one of the other active measures

considered, may present a current or potential threat

to public health, welfare, or the environment

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to

protect human health and the environment. These

objectives are based on available information and

standards such as applicable or relevant, and

appropriate requirements (ARARs) and risk based-

based levels established in the risk assessment. EPA’s

remedial action objectives for the Welsbach General

Gas Mantle Contamination site are to take measures

that will prevent or mitigate further release of

radioactive contaminated materials to the surrounding

environment and to eliminate or minimize the risk to

human health and the environment. The sources of

radiation include both contaminated soil and

structural materials. Direct radiation, inhalation,

ingestion of plants and soil are potential pathways.

EPA proposes the following remedial action

objectives for the Site:

! Eliminate or minimize the potential for

humans to ingest, come into dermal contact

with, or inhale particulates of radioactive

constituents or to be exposed to external

gamma radiation in order to achieve the level

of protection required by the NCP ( 10-4

to

10-6

risk range).

! Prevent long-term exposure to thorium- and

radium-contaminated material (e.g., soil)

with concentrations greater than 5 pCi/g.

EPA Region 2 - February 1999 Page 11

! Prevent exposure to indoor concentrations of

radon gas and radon decay products greater

than 4 pCi/L and 0.02 WL1 respectively.

! Prevent direct contact with building surfaces

exhibiting total surface thoriurn

contamination exceeding 0.026 µC/m2 above

background.

! Prevent migration of thorium-contaminated

material that could result in the exposures

described above.

! Comply with chemical-, location-, and action

specific ARARs.

EPA, in the Office of Solid Waste and Emergency

Response (OSWER) Directives No. 9200.4-18, and

No. 9200.4-25, developed health guidelines for

limiting exposure to ionizing radiation from radium

and other sources. To further ensure protectiveness,

those health guidelines can be supplemented by

selecting response actions which reduce exposures

resulting from ionizing radiation to levels that are As

Low As Reasonably Achievable (ALARA) taking

into consideration technical, economic and social

factors.

EPA recommends that indoor radon concentrations in

homes should not exceed 4 pCi per liter of air

(pCi/L). In 40 CFR 192, “Standards for Cleanup of

Land and Buildings Contaminated with Residual

Radioactive Materials From Inactive Uranium

Processing Sites ,” EPA enacted standards for

limiting exposure to radon decay products and gamma

radiation. While this regulation is not directly

applicable to this site because the Welsbach and

GGM Facilities are not inactive uranium processing

sites. EPA considers the cleanup standards in 40 CFR

192 to be relevant and appropriate for the Site. The

relevant portions of an CFR192 include limiting

exposure to radon decay products to levels less than

0.02 WL and radium concentrations (implemented as

the sum of Ra-226 and Ra-228) to 5 pCi/gram. EPA,

in Directive No 9200.4-25, states that whenever the 5

pCi/g radium soil cleanup standard is determined to

be relevant and appropriate at a CERCLA site which

contains both radium and thorium in the waste, the 5

pCi/g cleanup standard also applies to thorium

(implemented as the sum of Th-230 and Th-232).

In achieving the remedial action objectives for the

Site, EPA would rely on the ALARA principles used

at other radiological contaminated sites in New

Jersey. Applying ALARA principles means taking

additional measures during implementation of the

remedial action, beyond those required to meet a

specified cleanup goal, to assure protectiveness. An

ALARA approach is being used because of the long-

lived nature of radionuclides, the difficulty in

eliminating routes of exposure, limitations of the

analytical equipment to detect radionuclides, and site

specific factors which may make it necessary to

remove material at levels below 5 pCi/g to achieve

adequate public health protection.

EPA's experience at the other radiological

contaminated sites in New Jersey has shown that the

remedial action objectives noted above can be

achieved by incorporating ALARA principles.

Therefore, by using similar remedial action

objectives, the Welsbach/GGM Site would pose no

unacceptable risk for residential uses after cleanup,

and would result in a cleanup that is protective under

CERCLA.

To meet the remedial action objectives outlined

above, EPA plans to excavate radiologically

contaminated soils and waste materials, and dispose

of them off-site. Excavation of soils will eliminate the

threat of physical migration of contaminants, as well

as potential exposure through various pathways

(ingestion, inhalation, dermal contact, external

gamma radiation, etc.). Contaminated soils will be

1Exposure to 4 Pci/l of air for radon

corresponds to an approximate annual average

exposure of 0.02 WL for radon decay product.

2References for ALARA principles -

“Radiation Protection Guidance to Federal Agencies

for Occupational Exposure”, 1987, Federal Register

52, No. 17, 2822; and “Federal Guidance Report No.

11". September 1988, EPA-520\1-88-020.

EPA Region 2 - February 1999 Page 12

shipped off-site to a licensed commercial facility for

permanent long-term management.

The planned response action for buildings,

specifically at GGM, is decontamination, demolition,

and off-site disposal of contaminated materials to

reduce exposures within acceptable levels for future

use of the property.

Any potential ecological risks and adverse impacts

from existing radiological contamination on the

properties addressed under this action will be

minimized because the contaminated soils will be

removed and backfilled with clean soil. There are also

limited habitats for ecological receptors at the

properties addressed under this action. Furthermore,

by removing the radiologically contaminated waste,

the surface water and sheet flow pathways will be

eliminated as routes of exposure.

Wetlands are not present at both the former Welsbach

and GGM facilities. However, wetlands are present in

Areas 3 and 5, along the South Branch of Newton

Creek. During the remedial design. EPA will

delineate wetland areas which are actually or

potentially impacted by contamination or remedial

activities.

SCOPE AND ROLE OF ACTION

The goal of the proposed remedial action is to

minimize or eliminate the potential health hazard

posed by all radiologically contaminated soils and

structural materials at the Site. Because of the large

geographical area associated with this project, not all

potentially contaminated areas were evaluated during

the RI. EPA will investigate additional areas as part

of the remedial design to delineate the full extent of

contamination. The Armstrong Building, ground

water, surface water, and sediments, will be

addressed in future Operable Units.

SUMMARY OF ALTERNATIVES

CERCLA requires that each remedy be protective of

human health and the environment, be cost effective, .

comply with other statutory laws, and utilize

permanent solutions and alternative treatment

technologies and resource recovery alternatives to the

maximum extent practicable. In addition. the statute

includes a preference for the use of treatment as a

principal element for the reduction of toxicity,

mobility, or volume of hazardous substances.

CERCLA also requires that if a remedial action is

selected that results in hazardous substances,

pollutants, or contaminants remaining at a site above

levels that allow for unlimited use and unrestricted

exposure. EPA must review the action no less than

every five years after the start of the action.

This Proposed Plan evaluates the Remedial

Alternatives for addressing the contamination

associated with the Site. Cleanup alternatives were

evaluated for the Vicinity Properties, the former

Welsbach Facility and the General Gas Mantle

Facility. The alternatives include: No Action,

Engineering Controls, and Excavation and Off-Site

Disposal.

Vicinity Properties

The Vicinity Properties include residential,

commercial, and public properties where radiological

contamination was identified in soils situated outdoors

and/or beneath buildings, and properties with indoor

air contamination.

Vicinity Properties Alternative 1 (V-1) -

No Action

Estimated Capital Cost: $0

Estimated Annual Operation and Maintenance

(O&M) Cost: $0

Estimated Present Worth: $0

Estimated Implementation Period none

EPA Region 2 - February 1999 Page 13

A “No Action” alternative is evaluated for every

Superfund site to establish a baseline for comparison

with remedial alternatives. Under this alternative, no

remedial action would be performed at the Site.

Previous interim remedial actions implemented by

NJDEP would not be maintained. Current

institutional controls including fencing would not be

maintained. Because hazardous substances would

remain at the Vicinity Properties above acceptable

levels, five-year reviews would be required.

Vicinity Properties Alternative 2 (V-2) -

Engineering Controls

Estimated Capital Cost: $900,000

Estimated Annual O&M Cost: $99,000

Estimated Present Worth: $1,810,000

Estimated Implementation Period 3-5 years

Under this alternative, outdoor gamma shielding

would be placed at each property which has

contaminated soil. The gamma shield would consist of

a geotextile liner, fill material, 6-inches topsoil, and

vegetation (seeding or sod). The thickness of the fill

material will vary from 6 inches to 42 inches, based

on the shielding requirements of each property . A

total of approximately 75,000 square feet of coverage

would be installed.

In addition, indoor gamma shielding would be placed

inside buildings exhibiting unacceptable exposure

levels. The shielding would consist of concrete or

steel as needed. The concrete would range from 4

inches to 7 inches thick, and about 1.5 inches of steel

sheeting would be placed on wall surfaces.

Approximately 2.000 square feet of concrete and 60

square feet of steel coverage would be installed.

Finally, if any property buildings exhibit elevated

radon/thoron levels, a sub-slab ventilation radon

mitigation system would be installed.

Institutional controls, such as deed restrictions, would

be required to ensure the protectiveness of the

remedy. Because hazardous substances would remain

at the Vicinity Properties above acceptable levels,

five-year reviews would be required. The estimated

time to design and construct the remedy is from three

to five years.

Vicinity Properties Alternative 3 (V-3) -

Excavation and Off-Site Disposal

Estimated Capital Cost: $13,408,561

Estimated Annual O&M Cost: $0

Estimated Present Worth: $13,408,560

Estimated Implementation Period 3-5 years

Under this alternative, soil on the Vicinity Properties

contaminated above 5 pCi/g greater than backgound

would be excavated and disposed of at a licensed

off-site facility. Radiologically contaminated building

demolition debris would also be excavated and

disposed of off-site. EPA will replace these areas with

clean fill. The total volume of soils requiring, disposal

at the Vicinity Properties is estimated to be 11,000

cubic yards. The total volume of buried demolition

debris at the Vicinity Properties is estimated to be

2,250 cubic yards.

Where contamination is suspected underneath

buildings, this alternative includes removing concrete

flooring and underpinning the buildings. After the

removal of contaminated soil, a new concrete floor

would be constructed. Approximately 21 properties

would require concrete floor removal and

replacement. Underpinning is estimated to be required

at one property.

The estimated time to design and constrict the remedy

is from three to five years. Provisions would need to

be made for the temporary relocation of residents and

businesses during construction of this alternative.

During excavation, short-term provisions to prevent

dust generation and protect workers would be

required.

Welsbach Facility

The former Welsbach Facility is presently owned and

operated by Holt, as a cargo storage and oversea

shipping operation. Radiological contamination on the

property is present in the outdoor portion of the

EPA Region 2 - February 1999 Page 14

storage area. Most of the contamination is located in a

single contiguous area, with smaller elevated areas

scattered across the property. The Armstrong Building

is not included in the remediation alternatives. Holt is

preparing an RI/FS that will address the remedial

alternatives for that building.

Welsbach Alternative 1 (W-1) - No Action

Estimated Capital Cost: $0

Estimated Annual O&M Cost: $0

Estimated Present Worth: $0

Estimated Implementation Period none

Under this alternative, no remedial action would be

performed at the Site. Current institutional controls

including fencing would not be maintained. Because

hazardous substances would remain on the property

above acceptable levels, five-year reviews would be

required.

Welsbach Alternative 2 (W-2) - Engineering

Controls

Estimated Capital Cost: $5,690,000

Estimated Annual O&M Cost: $44,000

Estimated Present Worth: $6,180,000

Estimated Implementation Period 3-5 years

Under this alternative outdoor gamma shielding would

be placed in the areas of the former Welsbach

property that have soil contamination. The gamma

shield would consist of steel covered by asphalt. The

steel would range in thickness from 1 to 5 inches,

with a 4-inch asphalt cover. Approximately 53,000

square feet of area would be covered by the steel

shielding.

Institutional controls, such as deed restrictions, would

be required to ensure the protectiveness of the

remedy. Because hazardous substances would remain

on the property above acceptable levels, five-year

reviews would be required. The estimated time to

design and construct the remedy is from three to five

years.

Welsbach Alternative 3 (W-3) - Excavation and

Off-Site Disposal

Estimated Capital Cost: $18,503,560

Estimated Annual O&M Cost: $0

Estimated Present Worth: $18,503,560

Estimated Implementation Period 3-5 years

Under this alternative, all soil contamination at the

Welsbach site above 5 pCi/g greater than background

would be excavated and disposed of at a licensed

off-site facility. Contaminated building demolition

debris which is currently buried on-site because of

former demolition activities would also be excavated

and disposed of at an appropriate off-site facility.

EPA will replace these areas with clean fill. The

volume of soils above the cleanup standard is

estimated to be 19,400 cubic yards. The volume of

buried demolition debris requiring disposal is

estimated to be 4,400 cubic yards. During excavation,

short-term provisions to prevent dust generation and

protect workers would be required.

Subsurface contamination on the Welsbach Facility

averages about 11 feet in depth. In the area of the

deepest contamination, underground tunnels dating

from around the of the century are present. These

tunnels extend down to about 10 to 12 feet in depth.

These tunnels can act as conduits to carry radon gas

to nearby residential properties. As a result, the

remedy includes excavation of the contamination to

these depths to prevent any future radon migration

problems and to protect future workers from elevated

gamma radiation levels. The estimated time to design

and construct the remedy is from three to five years.

General Gas Mantle Facility

The GGM building is presently inactive and in a

dilapidated state. The building has been boarded shut

and fenced in by NJDEP. Radiological contamination

on the property exists both inside and outside the

building. Inside the building, contamination is present

in building materials and in ambient air. Outside the

GGM Facility, soil contamination is primarily located

EPA Region 2 - February 1999 Page 15

to the immediate southwest of the GGM building

extending into South Fourth Street. Two smaller

areas of contaminated soils are situated to the

northeast of the building and in the alleyway

adjacent to the eastern side of the building.

General Gas Mantle Alternative 1 (G-1) - No

Action

Estimated Capital Cost: $0

Estimated Annual O&M Cost: $0

Estimated Present Worth: $0

Estimated Implementation Period none

Under this alternative, no remedial action would be

performed at the Site. Previous interim remedial

actions would not be maintained. Current

institutional controls including fencing would not

be maintained. Because hazardous substances

would remain on the property above acceptable

levels, five-year reviews would be required.

General Gas Mantle Alternative 2 (G-2)-

Engineering Controls

Estimated Capital Cost: $122,000

Estimated Annual O&M Cost: $23,000

Estimated Present Worth: $381,000

Estimated Implementation Period 2-3 years

Under this alternative, outdoor gamma shielding

would be placed at the former General Gas Mantle

property. The gamma shield would consist of either

a soil shield or a concrete shield. The soil shield

would include a geotextile liner, fill material,

six-inches topsoil, and vegetation (seeding or sod).

The thickness of the fill material will range from

six to 24 inches. The thickness of the concrete will

range from six to eight inches. Approximately

5,000 square feet of coverage would be required.

Areas of contamination extending into South

Fourth Street would be covered with an additional

4 inches of asphalt.

Also under this alternative, significant institutional

controls, including permanently boarding shut the

building and restricting access to the building

forever would be required. Because hazardous

substances would remain on the property above

acceptable levels, five-year reviews would be

required. The estimated time to design and

construct the remedy is from two to three years.

General Gas Mantle Alternative 3 - Excavation

and Off-Site Disposal of Soil and

Building/Demolition Debris

G-3A: Demolition and Disposal

Estimated Capital Cost: $2,309,560

Estimated Annual O&M Cost: $0

Estimated Present Worth: $2,309,560

Estimated Implementation Period 1-2 years

Under this alternative for the GGM property, soil

contaminated above 5 pCi/g greater than

background would be excavated and disposed of at

a licensed off-site facility. Contaminated building

demolition debris which is currently buried on-site

because of former demolition activities would also

be excavated and disposed of off-site. EPA will

replace these area with clean fill. The volume of

soil and buried demolition debris at GGM is

estimated to be 650 cubic yards and 60 cubic

yards, respectively.

Under this alternative, the former General Gas

Mantl building would be demolished, and the

demolition debris would be disposed of with the

contaminated soil. The volume of building

materials to be demolished is estimated to be 1,400

cubic yards. During excavation and demolition,

short-term provisions to prevent dust generation

and protect workers would be required. The

estimated time to design and construct the remedy

is from one to two years.

G-3B: Decontamination, Demolition and

Disposa

Estimated Capital Cost: $1,736,560

Estimated Annual O&M Cost: $0

Estimated Present Worth: $1,736,560

Estimated Implementation Period 1-2 years

EPA Region 2 - February 1999 Page 16

EPA Region 2 - February 1999 Page 17

would be required to ensure that these alternatives

are protective.

For the Excavation and Off-Site Disposal

Alternatives (W-3, V-3, G-3), all radiological

contamination above cleanup standards would be

removed and disposed of off-site in a licensed

disposal facility. Institutional controls would not be

necessary. All unacceptable risks to human health

and the environment would be eliminated by the

excavation and off-site disposal of the radiologically

contaminated waste.

Compliance with Applicable or Relevant, and

Appropriate Requirements

Actions taken at any Superfund site must meet all

ARARs of federal and state law, or provide grounds

for invoking a waiver of these requirements. There

are three types of ARARs: action-specific,

chemical-specific, and location-specific.

Action-specific ARARs are technology or

activity-specific requirements or limitations related

to various activities. Chemical-specific ARARs are

usually numerical values which establish the amount

or concentration of a chemical that may be found in,

or discharged to, the ambient environment.

Location-specific requirements are restrictions

placed on the concentrations of hazardous

substances or the conduct of activities solely

because they occur in a special location.

For the Welsbach/GGM site, no requirements are

applicable for the cleanup of the radiological

contamination. However, as discussed earlier,

portions of the federal regulations governing the

cleanup of uranium mill tailings from inactive

uranium processing sites, at 40 CFR 192, have been

determined to be relevant and appropriate. These

provide the radon decay products standard of 0.02

WL and soil cleanup criteria of 5 pCi/g. In addition,

waste materials produced at the former Welsbach

Facility would be considered “by-product” material

as defined by Section 11 (e)(2) of the U.S. Atomic

Energy Act (AEA).3 Since Welsbach processed

monazite ores to extract thorium. EPA has

determined Section II(e)(2) of the AEA to be

relevant and appropriate. Because the waste

materials from the Welsbach Facility and its

operations are an AEA Section II(e)(2) waste

material, they must he disposed of at a licensed

facility in accordance with AEA requirements.

The Excavation and Off-Site Disposal Alternatives

(W-3, V-3, G-3) would comply with all ARARs.

All contamination above the 40 CFR 192 cleanup

standards would be excavated and sent off-site for

disposal. The Engineering Controls Alternatives

(W2, V-2, G-2) would comply with all ARARs

that limit exposure to gamma radiation and radon.

However, the Engineering Controls Alternatives

would not comply with 40 CFR 192, because the

contaminated material would remain at the Site.

Long-Term Effectiveness and Permanence

The Excavation and Off-Site Disposal Alternatives

(W-3, V-3, G-3 ) are all effective and permanent.

They are considered a final remedial action. The

contaminated material would be removed from the

Site and stored in a controlled, licensed facility.

The long-term effectiveness of the Engineering

Controls Alternatives W-2 and V-2 would be

uncertain. Contaminated material would remain in

place, and the engineering controls would require

deed restrictions and long-term monitoring. In

addition, the engineering controls would have to be

maintained forever because the half-life of thorium

is 14 billion years.

Alternative G-2 (Engineering Controls for General

Gas Mantle) would not be effective in the

long-term

3 “By-product” material means (1) any radioactive material(except special nuclear material) yielded in or made radioactive byexposure to the radiation incident to the process of producing orutilizing special nuclear material, and (2) the tailings or wastesproduced by the extraction or concentration of uranium or thorium fromany ore processed primarily for its source material content.

EPA Region 2 - February 1999 Page 18

because of the dilapidated nature of the building,

even if the building were completely sealed.

Reduction of Toxicity, Mobility, or Volume Through

Treatment

No treatment technology is known today that can

substantially reduce the toxicity, mobility, or volume

of radioactive materials found at the Site, and meet

the 40 CFR 192 cleanup standards. The total amount

of radioactivity cannot be altered or destroyed, as is

often possible with chemical contaminants.

Therefore. none of the remedial alternatives fully

satisfy this evaluation criteria.

However, the Excavation and Off-Site Disposal

Alternatives (W-3, V-3, G-3) would lead to some

reduction in the mobility of the material because

radioactive contaminated materials would be

contained in a secure landfill cell. Alternative G-3

with Option B (the General Gas Mantle

Decontamination and Demolition Alternative) would

reduce the volume of contaminated building debris to

be disposed of off-site by pressure washing the

radioactive contamination off the floors and walls

before demolition. The contaminants would be

concentrated in the filtrate after pressure washing.

Only this filtrate would have to be disposed of in a

licensed facility.

Short-Term Effectiveness

Both the Engineering Control Alternatives (W-2, V-

2, G-2) and the Excavation and Off-Site Disposal

Alternatives (W-3, V-3, G-3) provide effective short-

term protection and become effective as they are

implemented at individual properties. The estimated

time to design and construct the remedial alternatives

for the former Welsbach Facility (Alternatives W-2

and W-3) and the Vicinity Properties (Alternatives

V-2 and V-3) is from three to five years. For the

former GGM Facility, the estimated time to design

and construct the Engineering Control Alternative

G-2 is from two to three years, and for the Off-Site

Disposal Alternative G-3 from one to two years.

The Engineering Control Alternatives involve less

intrusive activities, and pose less of a threat to

workers and the surrounding community than the

Excavation and Off-Site Disposal Alternatives

However, both the Engineering Control Alternatives

and the Excavation and Off-Site Disposal

Alternatives involve intrusive activities, including,

in some cases temporary relocation of residents.

The Excavation and Off-Site Disposal Alternatives

have a greater potential adverse impact in the short

term because of the excavation of radiologically-

contaminated soil. For future workers, this could

lead to increased short-term exposure to radon,

gamma radiation, and soil radionuclides. Dust

suppression techniques and or other measures

would be required to minimize the impacts of this

alternative. However, under Alternative V-2

(Engineering Controls for the Vicinity Properties),

there would be some increased short-term risk to

workers during the installation of the radon

mitigation systems. This is due to the need to

excavate under the foundation of homes that require

radon mitigation.

Implementability

The Excavation and Disposal Alternatives (W-3,

V-3, G-3) are readily implementable. Similar

activities have been utilized at other radiologically-

contaminated sites around the country. There is an

available off-site disposal facility, which is

accessible by both truck and rail. However, the

continued availability of this off-site disposal

facility is required for implementation of these

alternatives.

Implementation of the Engineering Controls

Alternatives V-2 and G-2 may pose some

difficulties. Under Alternative V-2 (for the Vicinity

Properties), there may be some difficulty in getting

the consent of all of the property owners to restrict

future work on their properties. EPA would have to

reach agreements with individual property owners

to file Declarations of Environmental Restrictions

(i.e., deed restrictions) on their properties. For

Alternative G-2 (for General Gas Mantle), it would

be difficult to

EPA Region 2 - February 1999 Page 19

keep the building permanently sealed from

trespassers.

Cost

Alternative V-2 includes construction costs of

$900,000 to implement engineering control

measures at the Vicinity Properties. Annual O&M

costs are estimated to be $99,000. The present

worth cost of Alternative V-2 is $1,810,000, with

O&M costs assumed for 30 years. Alternative W-2

includes construction costs of $5,690,000 to

implement engineering control measures at the

former Welsbach Facility. Annual O&M costs are

estimated to be $44,000. The present worth cost of

Alternative W-2 is $6,180,000, with O&M costs

assumed for 30 years. Alternative G-2 includes

construction costs of $122,000 to implement

engineering controls at the General Gas Mantle

Facility. Annual O&M costs are estimated to be

$23,000. The present worth cost of Alternative G-2

is $381,000, with O&M costs assumed for 30

years. The radionuclides in question have half-lives

far greater than 30 years, so any of the Engineering

Controls remedies must be maintained effectively

forever.

Alternative V-3 includes construction costs of

$13,408,560 to excavate the radiologically-

contaminated soil at the Vicinity Properties and

dispose of the waste at an off-site disposal facility.

Alternative W-3 includes construction costs of

$18,503,560 to excavate the radiologically-

contaminated soil at the former Welsbach Facility

and dispose of the waste at an off-site disposal

facility. Alternative G-3 - Option A involves

construction costs of $2,309,560, and includes

demolishing the General Gas Mantle building and

disposal of all the building debris at an off-site

disposal facility Alternative G-3 - Option B

involves construction costs of $1,736,560, and

includes decontaminating the General Gas Mantle

building before its demolition. There are no O&M

costs associated with the Excavation and Off-Site

Disposal Alternatives (W-3, V-3, G-3 Options A

and B).

State Acceptance

The State of New Jersey is currently evaluating the

Proposed Plan.

Community Acceptance

Community acceptance of the preferred alternatives

will be evaluated after the public comment period

ends and will be described in the Record of

Decision for the Site.

PREFERRED ALTERNATIVE

Based on the information available to evaluate the

remedial alternatives against the nine criteria. EPA

recommends the Excavation and Off-Site Disposal

Alternatives (V-3, W-3, and G-3 with Option B) as

the preferred alternatives for the cleanup of the

contaminated soil and building materials at the

Site.

Rationale for the Preferred Alternatives

For each of the three property types, EPA’s

preferred alternative is the excavation and off-site

disposal alternative. Alternatives V-3, W-3, and

G-3 with Option B are the most protective

alternatives.

The radioactive half-life of thorium-232, the

primary contaminant of concern, is 14 billion

years. Remedies that would isolate wastes

containing thorium and the uranium series

radionuclides permanently from the public and the

environment are preferable.

Alternatives V-3, W-3, and G-3 result in a

permanent solution to the radioactive

contamination. The longevity of these chemicals of

concern (thousands to billions of years) favors

excavation which permanently removes the

contaminants from their current uncontrolled

locations. Commercial disposal at a licensed

facility with an appropriate closure plan will ensure

that these radiological wastes are permanently

isolated from human and ecological receptors. The

Excavation and Off-Site Disposal Alternatives are

considered implementable and will

EPA Region 2 - February 1999 Page 20

result in a remedy that is highly effective in the

long-term. These remedies are also consistent with

the remedial approach taken at all other

radiologically-contaminated sites in New Jersey.

Alternatives V-3, W-3, and G-3 provide greater

long-term effectiveness because all soils with

radioactivity greater than 5 pCi/g are disposed of in

a licensed radiological waste disposal facility. The

technology and equipment to perform the remedial

action are readily available. Implementation of

Alternatives V3, W-3, and G-3 would allow for

unrestricted future use of all affected properties.

The Engineering Controls Alternatives (V-2, W-2,

and G-2) would require deed restrictions and

long-term monitoring essentially forever because of

the extremely long half-lives of the radiological

contaminants. Thus, EPA believes excavation and

off-site disposal of the radiological contamination

represents the most viable cleanup alternative.

The preferred alternatives will provide the best

balance of tradeoffs among alternatives with

respect to the evaluating criteria. EPA believes that

the preferred alternatives will be protective of

human health and the environment, will be cost

effective, and will utilize permanent solutions and

alternative treatment technologies or resource

recovery technologies to the maximum extent

practicable.

NEXT STEPS

After EPA has presented the preferred alternative

at the public meeting and has received any

comments and questions during the public comment

period. EPA will summarize the comments and

provide its responses in a document called the

“Responsiveness Summary.” The Responsiveness

Summary will be appended to the Record of

Decision, which will describe the final alternative

selected by EPA and provide EPA's rationale for

that selection.

EPA Region 2 - February 1999 Page 21

MAILING LISTMAILING LISTADDITIONSADDITIONS

If you know of someone who is not receiving

information and would like to be placed on the

mailing list for the Welsbach/General Gas Mantle Contamination

Site, call Ms. Natalie Loney at (212) 637-3639, e-mail her at

loney.natalie@epamail.epa.gov, or fill out and mail this

form to:

Ms. Natalie Loney

Community Relations Coordinator

US. Environmental Protection Agency

290 Broadway, 26th Floor

New York NY 10007-1866

Name

Address

Telephone

Affiliation

Superfund Fact Sheet

Welsbach/General Gas Mantle Contamination Site

Gloucester City/Camden, New Jersey February 1999

INTRODUCTION

This summary highlights the U.S. Environmental

Protection Agency’s (EPA’s) Proposed Plan for the

cleanup of contaminated soils and building materials

at the Welsbach/General Gas Mantle

(Welsbach/GGM) Superfund site in Camden County,

New Jersey.

Investigations at the Welsbach/GGM site have shown

that some commercial, residential, and public

properties located in the Camden and Gloucester City

area contain soil contaminated to varying degrees with

thorium, radium, and uranium.

These contaminants are radioactive and associated

with waste materials generated in the manufacturing

activities that took place at the former Welsbach and

General Gas Mantle facilities. Both facilities used

radioactive elements, specifically thonum, in the

production of gas mantles, were used for lighting

purposes in the late 19th and early 20th centuries.

Radium. uranium and thorium are associated with

mantle production process.

Radioactive elements such as thorium, radium or

uranium are unstable and as a result release energy.

Thorium releases energy in the form of alpha particles,

beta particles or gamma radiation. This radioactive

decay also forms radon gas.

Radon gas is odorless, colorless and tasteless and can

be harmful if people are exposed to it over many years.

Gamma radiation also may pose health problems to

people who come in contact with the wastes over long

periods of time.

WELSBACH/GENERAL GAS MANTLE SITE

The Welsbach/GGM site is comprised of properties

within the following six study areas:

Study Area One: a mixed industrial, commercial,

and residential zoned section of Camden which

includes the former GGM facility and residential and

commercial properties which surround the facility.

Study Area Two: an industrial zoned property in

Gloucester City along the Delaware River, formerly

occupied by the Welsbach Corporation and a

residential area to the immediate east.

Study Area Three: residential and recreational

properties in Gloucester City, including the Johnson

Boulevard Lana Preserve.

Study Area Four: residential properties in the

Fairview section of Camden.

Study Area Five: residential properties, vacant and

properties, and two municipal parks near Temple

Avenue and the South Branch of Newton Creek in

Gloucester City.

Study Area Six: vacant lots in a residential zoned

area of Gloucester City.

REMEDIAL INVESTIGATION AND FEASIBILITY

STUDY

in 1997 EPA began a remedial investigation and

feasibility study (RI/FS) to determine the source and

extent of radiological contamination in the Camden and

Gloucester City area and to evaluate cleanup alternatives.

The areas investigated during the RI/FS included the

former Welsbach facility, the former GGM facility, and 20

of the radiologically contaminated properties identified

during earlier investigations conducted by the New Jersey

Department of Environmental Protection (NJDEP). The

findings of the remedial investigation were then used to

prepare a feasibility study, which evaluates cleanup

alternatives.

THE PROPOSED PLAN

In addition to the RI/FS, EPA has prepared a Proposed

Plan for the Welsbach/GGM site which identifies EPA's

preferred cleanup alternatives for the radiologically

contaminated properties. The alternatives which were

evaluated include: No Action; Installation of

Engineering Controls; and Excavation and Off-Site

Disposal of Contaminated Materials.

EPA's preferred alternative is Excavation and Off-site

Disposal of Contaminated Materials. This alternative calls

for the removal and off-site disposal of

radioactively-contaminated soil. The excavated areas will

be backfilled with clean soil. Where necessary,

contaminated building material will be removed and

replaced with clean material. Removal of contaminated of

soils and building materials will eliminate potential

gamma radiation and radon exposure through various

pathways (ingestion, inhalation, dermal contact, etc.).

The planned response action for the former GGM

building, is decontamination, demolition, and off-site

disposal of contaminated materials. All contaminated

material will be taken to an approved off-site disposal

facility.

The estimated volumes of contaminated material from the

site properties are:

! Vicinity Properties:

soil - 11,000 cubic yards;

demolition debris - 2,250 cubic yards;

! Former Welsbach Facility:

soil - 19,400 cubic yards;

demolition debris - 4,400 cubic yards;

! Former GGM Facility:

soil - 650 cubic yards;

demolition debris - 60 cubic yards;

building materials - 450 cubic yards.

The cost of the proposed remedial action is estimated to be

$13,408,560, $18,503,560, and $1,979,560 for the

Vicinity Properties. former Welsbach facility, and former

GGM facility, respectively.

While some of the activities proposed for site cleanup may

be disruptive to individual homeowners or the community.

EPA will work with affected residents and the community

to ensure a safe and quick cleanup of the site.

EPA relies on public input to ensure that the concerns of

the community are considered in selecting an effective

remedy for each Superfund site. To this end, EPA has

made the RI/FS report. Proposed Plan, and supporting

documentation available to the public for a public

comment period from February 1, 1999, to March 3,

1999. EPA considers all public comments before selecting

a final cleanup plan. For more information please contact:

Natalie Loney, Community Relations Coordinator at (212)

637-3639 or Rick Robinson, Project Manager at (212)

637-4371.

The RI/FS report which presents the results of field

investigations conducted to date at these properties has

been completed. Copies of the RI/FS report. Proposed

Plan, and supporting documentation are available at EPA's

offices at:

290 Broadway, 18th Floor

New York, NY

10007-1866

(212) 637-4308

and at the following repositories:

City of Camden Main Library

418 Federal Street

Camden, NJ 08103

(609) 757-7650

Hynes Center

1855 South 4th Street

Camden, NJ 80104

(609) 966-9617

Gloucester City Public Library

Monmouth and Hudson Streets

Gloucester City, NJ 08030

(609) 456-4181

SUMMARY

The Proposed Plan presents EPA's preferred remedy for the

cleanup of contaminated properties which are part of the

Welsbach/GGM site. EPA proposes to excavate

contaminated soil and waste materials; decontaminate (as

appropriate), demolish, and remove contaminated debris

and building material: dispose of the contaminated soils

and waste materials in a licensed off-site disposal facility;

and restore the affected properties with clean fill. The

proposed remedy would provide a permanent cleanup

response and would be protective of human health and the

environment.

Appendix B

Public Notices

Appendix C

Transcripts of Public Meetings

D E G N A N & B A T E M A N, I N C.(609) 547-2565

1

2

U.S. Environmental Protection Agency’s (EPA's)3

Proposed Plan for Cleanup of Superfund Sites4

Public Hearing5

6

7

8

February 23, 19989

10

Public Meeting of the U.S. Environmental11

Protection Agency (EPA) held at the Pine Grove Fire12

Station #2, Gloucester City, New Jersey, before13

Linda A. Burns, Shorthand Reporter and Notary Public14

of the state of New Jersey, on the above date,15

commencing at 7:00 p.m.16

17

18

19

20

21

22

23

24

2

D E G N A N & B A T E M A N, I N C.(609) 547-2565

EPA Public Meeting - 2/23/99 3

D E G A N & B A T E M A N, I N C.

(609) 547-2565

MS. CERVANTES-GROSS: I just wanted1

to start by thanking all of you for coming2

here tonight to talk with us about the3

Welsbach/General Gas Mantle Superfund site4

and post cleanup. We will be talking with5

you about all of the cleanup here and will6

be giving you different information about7

the study that was done and the8

alternatives that we have looked at as far9

as what we are proposing.10

Just to introduce people who are here11

tonight from EPA and who are involved in12

the cleanup, we have Rick Robinson who is13

the project manager for EPA for this site.14

Pat Evangelista is the team leader for us15

at EPA and oversees all of the Superfund16

sites in our region, New Jersey, and all17

the sites that deal with radioactive18

contamination.19

Alan Fellman is with Malcolm Pirnie,20

a contractor that works with EPA to21

actually do the investigation and cleanup,22

as well as Bob Kerbel who is also with23

Malcolm Pirnie.24

EPA Public Meeting - 2/23/99 4

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(609) 547-2565

And obviously, everyone here knows1

Bob Saunders who has been doing so much2

work with us and will be here long after3

we're gone. And Artie Block is also here4

from ATSDR, the Agency for Toxic Substances5

and Disease Registry, part of the Federal6

Department of Health and Human Services.7

And ATSDR works with us on a consultation8

basis and works with us closely to look at9

these Superfund investigations that we do10

and gives us information on potential11

health impacts.12

As well, I also wanted to introduce13

Linda Burns who is the stenographer who14

will be taking down all of the contents15

that you make tonight. And that's why we16

are here tonight, to hear from you, your17

thoughts, your comments, your concerns.18

And to take any questions you have about19

what we will be discussing tonight and what20

our proposed cleanup will be for the21

contamination for the site.22

And just to point out, my name is23

Mary Helen Cervantes, I’m with EPA as24

EPA Public Meeting - 2/23/99 5

D E G A N & B A T E M A N, I N C.

(609) 547-2565

well. And I work in the area of Superfund1

Community Relations. The Superfund program2

stresses, as we do throughout all of the3

programs, community involvement and4

community participation. We feel we can do5

a much better job by having you involved6

and telling us what you hear, see and know7

about the community, your community, in8

which you live. You know what's happening9

here a lot better than we do most of the10

time. So again, that's why we are here11

tonight, to hear your comments and12

concerns.13

In order for us to do that and to14

make sure that we get everything down, if15

you could, after we go through our16

presentations, if you could hold your17

questions until the end. We will try to18

move through it as quickly as possible to19

make time for questions.20

When you have questions or want to21

make a statement, state your name clearly22

so that Linda can get that down and speak23

up so we can get it all down. So at the24

EPA Public Meeting - 2/23/99 6

D E G A N & B A T E M A N, I N C.

(609) 547-2565

end of the comment period, which ends on1

March 3, which is next Wednesday, we'll2

take comments on what we're proposing up3

until next Wednesday. Afterwards we will4

do a responsiveness summary, which we'll go5

through all the comments and all of your6

concerns and we'll write a summary7

responsive to that. But what you say8

tonight and whatever comments you have,9

that will actually go into the official10

record. So you don't have to write it down11

afterwards. We'll take it down right here12

as you say it.13

I also just wanted to point out that14

Natalie Loney, whom you may have met, works15

with EPA and is the assigned Community16

Involvement Coordinator for the site. So17

I'm just sitting in for her today. She18

just had a baby on Valentine's Day, but you19

will see here throughout all of the other20

meetings throughout the year. She is the21

one who is assigned just to work with you22

and to handle your questions and concerns23

and to make sure you're involved as much as24

EPA Public Meeting - 2/23/99 7

D E G A N & B A T E M A N, I N C.

(609) 547-2565

possible and we want you to be involved in1

the process here.2

Just a couple of things very3

quickly. We have various project4

initiatives that will help you understand5

-- you'll see there's a lot of technical6

information, but there are programs that7

are available to help you understand the8

technical information. And if anyone is9

interested in those programs, I will talk10

to you about those afterwards. They are11

numerous. But just talk to me afterwards12

if you'd like.13

I'll now turn it over to Pat and Pat14

is going to go through the Superfund15

program in general.16

MR. EVANGELISTA: Good evening,17

ladies and gentlemen. Thanks for coming18

out tonight and participating in our19

meeting.20

Just to reiterate a little bit of21

what Mary Helen said, we highly encourage22

all of you to come forward and identify any23

comments, concerns or questions that you'd24

EPA Public Meeting - 2/23/99 8

D E G A N & B A T E M A N, I N C.

(609) 547-2565

like to have answered. If not tonight, you1

know, anytime in the near future. we'll2

hand out business cards if you'd like and3

feel free to call us at any time.4

What I'm going to do now for you is5

give you a little briefing on what6

Superfund is about so that you maybe7

understand better why we're here and what8

kind of process we've been following and9

are going to follow until we're done with10

this particular site.11

Back in 1980, Congress gave EPA the12

authority under a law that's known to us as13

the Comprehensive Environmental Response14

and Liability Act. And then five or six15

years later they amended that law to give16

us what we currently have today. Our17

process always beings with somehow an18

identification to the agency that there's a19

problem in a certain area. And that's what20

you see up on the screen as the discovery21

or CERCLIS. The CERCLIS is simply a22

program or process we use to track site23

progress.24

EPA Public Meeting - 2/23/99 9

D E G N A N & B A T E M A N, I N C.

(609) 547-2565

Then we move into what's known as the1

preliminary assessment or site inspection.2

We go out and we try to ascertain, on a3

preliminary basis, what kind of a problem4

we're dealing with so that we can funnel5

all of that information into a hazard6

ranking system. Based on the hazard7

ranking system we are able to rate that8

problem or that site, if you will, and if9

the score, based on the ranking, exceeds or10

is higher than 28.5, which was somehow11

selected very arbitrarily, the site ends up12

on what's known as the National Priorities13

List. This is a prioritization list that14

the agency uses to deal with the sites that15

are on it.16

From the National Priorities List we17

are then able to authorize federal money to18

proceed into what is known as the Remedial19

Investigation/Feasibility Study. The20

Remedial investigation/Feasibility Study is21

a very detailed study of the problem or the22

site or the properties, if you will.23

Perhaps you've seen us out there taking24

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soil samples. You may have seen our1

contractors. You may be aware of our field2

office.3

So we've been gathering data on this4

site for the past year or so. That data is5

then analyzed to formulate alternatives6

that we can further evaluate to identify7

the preferred cleanup option to address the8

contamination that's out there. Those9

cleanup options are identified in the10

Feasibility study and the Feasibility Study11

is used to generate the proposed plan.12

The proposed plan -- I guess we went13

public with it back on February 1 -- "went14

public with it," meaning we identified it15

in public notice, in the newspapers, for16

your knowledge. It's available for your17

review. We have copies of it here tonight18

if you'd like a copy. And in that proposed19

plan we proposed to you what we'd like to20

do to clean up this site. And Rick will21

get into a lot of that detail.22

After the public comment period ends23

we'll proceed into a Record of Decision,24

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after having considering all of your1

comments and concerns. That Record of2

Decision will formally identify the3

cleanup. The cleanup will then be designed4

under what's known as a remedial design.5

That design will identify all of the6

specifications that the contractor will7

need to follow in order to clean up your8

properties. That, in effect, is the9

cleanup.10

Once the agency has determined that11

the cleanup has occurred pursuant to all of12

the specifications, we give it a clean bill13

of health, if you will, and we remove it14

from the National Priorities List or delist15

it from the NPL.16

That essentially describes our17

process. If you have any questions I'd be18

happy to answer them for you later. At19

this point I'll pass it onto Rick Robinson,20

the Project Manager for the site.21

MR. ROBINSON: Thanks again, Pat.22

Just for background, the site is23

located both in Camden and Gloucester24

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City. It comprises two former Gas Mantle1

manufacturing facilitie some residential2

properties, commercial properties,3

municipal park lands and vacant land.4

As part of the State's investigation5

early on, in the early 1990s they divided6

the site into a number of study areas. And7

as we were going on with our investigation,8

we followed along with their study areas.9

The first one, Study Area 1, is the10

General Gas Mantle Facility in Camden and11

the surrounding properties.12

Study Area 2 is the former Welsbach13

Facility here in Gloucester City and the14

surrounding properties.15

Study Area 3 is the residential area16

in Gloucester City, including the Johnson17

Boulevard Land Preserve.18

Study Area 4 is the residential area19

in the Fairview section of Camden.20

Study Area 5, the residential21

properties and also some municipal parks in22

Gloucester City.23

And Study Area 6, some vacant24

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properties in the residential area in1

Gloucester City.2

Study Area 1, again, the General Gas3

Mantle Facility in Camden. And there is a4

photograph of the area with the General Gas5

Mantle building highlighted (indicating).6

There's a photograph of the General Gas7

Mantle building on the corner of Jefferson8

Street.9

Study Area 2 is the former Welsbach10

facility. It's now owned by Holt with the11

Gloucester terminal. The Armstrong12

building is the last remaining building13

from Welsbach's operation. And the area in14

pink right in here (indicating) is the15

location of the former Welsbach building16

that was demolished around 1975, 1976. And17

that is the main contamination area on that18

property. There's a photograph of the19

Armstrong building as it is today. There's20

the Walt Whitman Bridge in the background.21

Study Area 3 is Gloucester City.22

Gloucester City Swim Club is highlighted23

and the Johnson Boulevard Land Preserve.24

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Study Area 4, again, is the Fairview1

section of Camden. And we only found a few2

properties in this part of the site that3

were identified as having elevated levels4

of gamma radiation.5

Study Area 5 is in Gloucester City6

and includes the former Welsbach dump area7

on Temple Avenue and contamination in the8

park areas along Johnson Boulevard there.9

And Study Area 6 is a newly10

identified area and we call it the Popcorn11

Factory. You can ask Bob Saunders as to12

how that name came about. And there's a13

photograph of the Popcorn Factory and14

vacant lot. And the area in red is the15

small area of contamination that we found16

with radiological components.17

Going to the site history now. In18

about 1885 a Dr. von Welsbach invented a19

process using thorium to manufacture gas20

mantles. For those of you who don't know21

what a gas mantle is, you know in a camping22

lantern, you can see over on the left23

(indicating), and in a street light right24

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here (indicating), that is the gas mantle.1

And what they did is take a sock-like2

material and they dipped it in the thorium3

solution. And when it dried, it was lit.4

And it produced a very brilliant white5

light.6

And in about 1890 Welsbach started7

manufacturing the gas mantles here in8

Gloucester City. And at the turn of the9

century they were the world's largest10

manufacturer of gas mantles. And by the11

1940b they finally went out of business12

when the electric light put the gas light13

industry out of business.14

In Camden, General Gas Mantle15

manufactured gas mantles from about 1912 to16

1941. They were a much smaller company17

than Welsbach. They were a small18

competitor. There is very little19

information that we know about the Gas20

Mantle's activities other than it used and21

resold radium and thorium in the production22

of gas mantles.23

What we’ve termed vicinity properties24

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are all the other properties that we found1

at the site, excluding the General Gas2

Mantle facility and the Welsbach facility.3

And they were contaminated as a result of4

either disposal of the ore tailings from5

the Welsbach operation or building debris6

when buildings were demolished. Like when7

they built the Walt Whitman Bridge, some of8

the buildings were knocked down. Or from9

former workers bringing contamination home10

with them.11

Previously the site was identified in12

1980 during an archive search of the U.S.13

Radium Site in Orange, New Jersey. And in14

May 1981 EPA sponsored an aerial fly-over15

where a helicopter flew over the area with16

gamma detectors and was searching for gamma17

radiation. And as a result of that the18

State then conducted preliminary screening19

surveys in the mid 1980s and in the early20

1990s they investigated over a thousand21

properties in both Camden and Gloucester22

City.23

And as a result of that they24

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identified about 20 properties that needed1

-- that they felt needed some more2

immediate measures taken. And as a result3

they installed some radon/thoron4

ventilation systems in a number of homes.5

They installed concrete or steel sheeting6

on properties, in people's basements. And7

they also purchased one property and8

relocated the residents.9

In 1992 the State also removed10

radioactive material in the General Gas11

Mantle building and relocated the current12

occupant at the time, Ste-Lar Textiles, and13

they sealed up the building to restrict14

access.15

The State's investigation they16

base their surveys on just surface exposure17

rates, indoor radon sampling and they18

performed very limited surface soil19

samples. However, they did not really look20

in the subsurface at all. They made no21

estimates on the amount or extent of22

contamination and were just looking to23

address the more immediate potential health24

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time. EPA's involvement at the site became1

official when it was placed on the National2

Priorities List in June of 1996. And then3

that's when I was given the site and4

started the investigation process.5

Currently the General Gas Mantle6

building is inactive and boarded shut.7

Welsbach is currently owned by Holt and is8

an active facility. And with the vicinity9

properties, the immediate health concerns10

were addressed either by the State's11

remedial actions or by the EPA removal12

action. Like what we did in the park in13

December around the Ponytail(ph) Field.14

And here's a photograph of the excavation15

where we removed the top three feet of16

surface contamination. we're hoping to17

ship that material. It's being temporarily18

staged around the Popcorn Factory and we're19

going to ship that off in about three20

weeks. Today we had somebody out there21

sampling that material in preparation for22

shipment.23

Right now I’d like mo turn this24

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Right now I’d like to turn this1

portion of the talk over to Alan Fellman.2

And Dr. Fellman will talk to you a little3

bit about the radiation issues. Thank4

you.5

MR. FELLMAN: My background is in6

health physics and radiation sciences. So7

I'm going to spend just a few minutes to8

give you a few points about some of the9

terminology and some of the components10

regarding radioactivity that hopefully will11

help you follow along with the materials12

that you have been given to read and some13

of the things that you're hearing tonight.14

And then later on I'll come back and have a15

few words about the risk assessment that we16

did, which is a component of the Superfund17

remedial investigation.18

You've already heard some terms19

related to radioactivity. And I just want20

to hit on some of the key ones. When we21

measure radioactivity, when we want to22

identify a quantity of radioactive23

material, we need different units than What24

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we're more traditionally used to because1

we're not talking about a mass. We can't2

describe the weight of the material. What3

we're concerned about is the rate that4

these atoms are decaying, undergoing5

radioactive decay.6

The term we use, the unit, is called7

pico Curies. When we're talking about how8

much is in dirt or how much is in water, we9

express it as a concentration, pico Curies10

per gram or pico Curies per liter of11

water. Now this term is indicative of how12

much. It does not really address what kind13

of dose one received or what the risk is14

from that material. The point being that,15

ten pico Curies per gram of one type of16

radioactivity might give someone a17

different dose and have a different risk18

associated with it than ten pico Curies per19

gram of a different radioactivity.20

When we talk about dose of radiation,21

and that's really related to the risk, we22

use a unit called millirem. And that's a23

measure of the potential for biological24

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effect as a result of that radiation.1

Basically what we're measuring is energy2

that is coming from the radioactivity that3

is emitted from that radioactive material4

and is absorbed in the biological tissues.5

And that energy that's transferred from the6

radioactivity to the tissues is the subject7

of what could then ultimately lead to a8

biological effect or a health effect.9

Obviously, the greater the dose the10

greater the risk. There are several11

2 different types of radioactivity and you've12

3 heard some of previous speakers say the13

words thorium, radon, radium. All of these14

are different elements that have15

radioactivity associated with them. They16

emit different types of radioactivity.17

Alpha particles and beta particles18

and gamma rays are the three more common19

types of radioactivity and they're really20

the ones that we're concerned about here.21

They have different properties. Alpha22

particles are, relatively heavy. They23

travel slowly and they are not penetrating,24

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which means that they will not travel very1

far. If they're emitted from surface soil2

they will be stopped within one to two3

inches of air. They cannot get through a4

sheet of paper.5

Beta particles on the other hand have6

an intermediate amount of penetrating7

ability. They're smaller than alpha8

particles but they do have some mass9

associated with them. So while they can10

get through a sheet of paper, they will be11

stopped by something like a piece of wood.12

Gamma rays on the other hand are very13

similar to X-rays. They have no mass14

simply. It's simply packets of energy.15

It's sometimes referred to as penetrating16

radiation because it can travel fairly17

significant distances through air, paper,18

wood. And it takes a more dense media to19

absorb that energy and stop the gamma rays20

such as concrete or lead.21

The problem here, by and large what22

we're dealing with are what's known as ore23

residues. The by-product of the thorium24

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extraction processes that were implemented1

by the Welsbach company who left them with2

large piles of dirt which contained these3

ore residues with elevated concentration of4

radioactivity.5

In this schematic here, the area6

that's shaded in blue tends to show7

potential areas with these elevated levels8

of thorium. And if that were the case,9

what you can get, radon gas which is10

mobile, which can emanate from this dirt11

into the indoor atmosphere. Fortunately12

we've seen very little of that at the13

Welsbach General Gas Mantle sites. Much14

more frequently would be the case where15

there would be some of this material in an16

outdoor area where the influx of the gas17

into an indoor environment isn't likely to18

happen. But there the potential exposure19

would be from the gamma radiation that's20

emitted to an occupant who would be21

occupying, that would get a dose of that22

gamma radiation.23

At this point I’m going to let24

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Bob Kerbel speak for a few minutes. He's1

been our Project Manager from Malcolm2

Pernie throughout the investigation and3

he'll take you through some of the key4

points in that investigation.5

MR. KERBEL: I just want to give you6

a little insight of the type of7

investigation we did in the community so8

you can kind of see everything in the9

nutshell and see the type of work we've10

been doing.11

There are three areas we looked12

into. Two of the industrial facilities,13

the former Welsbach facility and the14

is General Gas Mantle facility. And then15

there was the vicinity problem, basically16

everything else. I assume most people here17

are homeowners and your home would come.18

under that vicinity property category.19

If there's anything good about this20

type of work from our standpoint as21

investigators it's that it's easy for us to22

detect this type of contamination. It23

gives off gamma radiation. So we basically24

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walk over the property with meters similar1

to this. And we might have come to your2

property and walked over the property in3

search for elevated level's of radiation. I4

have a little meter here. And we'd take5

those readings and walk over your entire6

property.7

Then if we find something we take8

soil samples and test for radiological and9

chemical contaminants. We only test for10

chemical contaminants at industrial11

properties because there's always a chance12

that there could be some chemical13

contamination just given the industrial14

nature of those areas.15

Once we find an area, we have to come16

up with a volume, how much is there. So we17

put a boring into the ground and these can18

be either shallow or deep. The only reason19

there's not a deep check mark under20

vicinity properties is because we really21

didn't have deep contamination on22

residential properties. That was really at23

the industrial sites that we needed to go a24

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little deeper. And as Alan alluded to, if1

there's soil contamination in the area,2

that gives off radon gas that could get3

into the household, so we test for that as4

well.5

On the industrial properties we also6

do something called alpha/beta measurements7

where we would actually sample structural8

materials. Because sometimes we might run9

into a question, whether it's the soil10

under the building or the building material11

itself that might be contaminated. So we12

might test that.13

This isn't too easy to see, but I14

want you to use your imagination a little15

bit. Let me try to get your eyes to focus16

here. This is the former Welsbach facility17

that was located along the Delaware River.18

The Delaware River is up there on top, you19

can see a smoke stack. And King Street20

would be at the lower end of the picture.21

But if you could imagine, this is the early22

part of the century. There's no DEP;23

there's no environmental protection24

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agency. The hazards associated with1

radiation really aren't known yet. Things2

like nuclear power are decades in the3

future yet to come. And as Rick said they4

made gas mantles here. Things like X-rays5

that the doctor does now were still being6

discovered at that time.7

But at this facility, they brought8

ore in. So basically on this facility9

there was a pile of dirt that they would10

extract the thorium from to use in these11

gas mantles. So at the time it was really12

a prosperous business until the electric13

light bulb came into play and put them out14

of business. But at that time the hazards15

weren't really known.16

In future years, in the last couple17

of decades, we're more aware of the hazards18

associated with radiation. So now someone19

said, you know what, we should go back to20

all these facilities that did this in the21

early part of the century. Because the22

sand that contained thorium, that could23

potentially be radioactive. So we should24

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go back to these facilities to see if,1

indeed, there is radioactive material on2

these sites.3

So years later they come back to the4

site but now there's no building here. The5

circle is basically where the facility6

would have been. So what we do is just7

what I told you earlier, we walk over the8

entire site and it takes a number of weeks9

to do it because it's so large, and we look10

for elevated levels of radiation. Because11

at the beginning the thought is, if the12

building is gone, it's conceivable that13

they had these huge basements and they14

knocked the building down and filled the15

basement and then paved over it.16

So we go over the entire site, we17

look for the elevated levels and then we18

bring them back to our office and we have19

special programs that help us see what the20

radiation levels are. Now this is a bird's21

eye view looking down at this site now.22

And wherever you see a colored area, those23

are elevated radiation levels. That's a24

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clear signal for us that there is1

contamination on the site. And then we go2

back and take soil samples to see that it3

is thorium. And we do borings to see how4

deep it is. Ballpark approximately ten5

feet deep in locations.6

Alan is going to come back and talk7

more about risk, but I just want to give a8

little perspective to it. When we do this9

work it's not like we dress up in suits or10

anything. We just wear our regular work11

cloths and work in these areas and get our12

measurements and so on. For the people13

that work for Malcolm Pernie, I'm14

responsible for their health and safety.15

And for me, the real risk is that they16

don't get killed by a truck going through17

the yards rather than the radiation wells.18

Another thing to keep in mind, this19

is not like an oil spill that’s spreading20

out there. It's been there for 50 years.21

It really doesn't move around unless you22

mechanically move it to another location.23

when I mentioned that soil pile from 50 to24

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100 years ago, what if you had a1

residential property, they removed a tree,2

there's a hole in the ground and they took3

that soil to fill the hole. That’s the4

type of thing we're looking for now.5

The General Gas Mantle building, let6

me just tell you a little bit about what we7

have here. It's all closed up now. Again,8

as Alan was telling you, the radon levels9

coming from the ground underneath the10

building, that is indeed what's happening11

here. Since it's all boarded up, there's12

no ventilation so there is a high radon13

level. There is some soil contamination,14

nowhere near as extensive as at the15

(INAUDIBLE) facility.16

And it is a longer building and it17

does come out into the street at South18

Fourth Street. And there are some building19

materials. The building is vacant.20

There's nothing in there., There's wood21

floors and some of those wood floors are22

contaminated. They would have to be23

decontaminated before the building is24

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demolished. But Rick Robinson will come1

back and talk a little about that.2

I assume most people here are3

property owners. So the last category is4

the vicinity properties. So let me touch5

base a little more on this one. The goal6

here is to get to the cleanup as soon as7

possible. And we were fortunate in this8

case that the State went to a thousand9

properties. So we didn't want to go to a10

thousand properties all over again and11

investigate those properties. But what we12

had to do is see that we could use the13

State's data. So we went to 20 properties14

and we compared our data to the State15

data. And we agreed with their data.16

So then we took their data and17

categorized it. The State went to18

approximately 1,000 properties. Here it's19

1,088. When we looked at the State data,20

we said approximately half, 449 properties21

are clean. We can't find any indication of22

contamination on those properties.23

Then there's another category we put24

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on that we call suspect properties. That's1

585 properties. Now suspect properties are2

our grey area. If a property was adjacent3

to a contaminated property, we4

automatically called it suspect because we5

want to check it out because it's adjacent6

to that contaminated property.7

Throughout the State people test8

their homes for radon and get elevated9

levels of radon in certain locations. That10

might have happened here and it would be11

perfectly normal. But we question is that12

because of the normal radium in the soil,13

or is it a sign that there might be some14

soil contamination from the Welsbach15

facility.16

We use the term natural background17

radiation because there's radiation all18

over but there's an average. And these19

properties might have had levels on the20

high end of that. If you live in a brick21

home, that may be a reason that it's high.22

But we want to go back to those properties23

to really break them either way, if it's24

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the contaminated category or the clean1

property category.2

And then the bottom line is we have3

54 contaminated properties. Properties4

that clearly had some contamination on them5

from our results and the State’s. And we6

came up with a volume for this for our7

estimate in the future.8

Before I let Alan come back and talk9

again about risk, I just want to mention on10

suspect properties, again it's our grey11

area. The contamination on all these12

properties might be a small spot that we13

can take away and put in a pail. We might14

have to bring a backhoe in there to dig it15

out. But the suspect properties, we would16

think that most of those properties can be17

moved to the clean category eventually.18

But we don't know that for sure and we19

won’t know until we actually do the testing20

on that property.21

So I'll let Alan come back and talk a22

little bit about health risks.23

MR. FELLMAN: whenever I talk to24

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people about the risk of radiation, it's1

always a good frame of reference to say a2

few words first about natural background3

radioactivity. it's very helpful when you4

realize that we live on a radioactive5

planet. And as a result of that, we're6

constantly being bombarded by7

radioactivity, no matter where we are,8

having nothing to do with the Superfund9

site.10

There are several different sources11

of natural radioactivity and they're listed12

in this table. Cosmic and cosmogenic refer13

to things coming from the atmosphere, the14

upper atmosphere.15

Terrestrial radioactivity is the16

natural thorium, radium, uranium that's in17

the ground, in the soil, in the rocks. And18

we get most of that 28 millirem per year19

from terrestrial sources which comes from20

gamma radiation.21

Inhaled radiation, we’re talking22

mostly there about radon gas. On average,23

in the average house, anytime you put four24

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walls and a ceiling together you're going1

to get some level of radon gas. And on2

average we get a dose of about 200 millirem3

per year.4

And then the internal emitters,5

referring to the radioactivity that we6

carry around in our bodies from natural7

sources such as potassium 40, which is a8

small but significant component of all the9

potassium on the planet. There's a little10

bit of these in soil, in the plants,11

vegetables and fruit and so forth. And so12

we're constantly ingesting and excreting13

some of this radioactivity. And as a14

result of it being in our bodies we receive15

a dose on average of 40 millirem per year.16

There's also a host of consumer17

products that have one or another type of18

radioactivity associated with it. And you19

can see it's a pretty diverse list. And20

the last one that we show there are gas21

mantles. We know a little bit more about22

them than we'd like to.23

Adding a few more things to those24

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that you see here on this slide, I have a1

little show and tell here. Most everybody2

who works in my field has one of these.3

This is a piece of Fiestaware(ph) which4

you'll find in almost any antique show.5

And this orange color -- I don't know why6

they call it yellow cake -- but the glaze7

that they apply to give it this orange8

color is called yellow cake. And it has a9

fair amount of natural uranium in it.10

This meter here is called a Geiger11

viewer detector, the common name is a12

pancake probe because of the shape. It has13

very low background. When you turn it on,14

from regular background radiation, this is15

what you'll hear, the sporadic beep. Each16

time a photon or a gamma ray is interacting17

inside the detector, it makes a click. And18

then, as you can tell when I get close to19

the Fiestaware, there's quite a20

difference. If I move one to two feet21

away, you can hear how rapidly that level22

of radioactivity decreases. As we remove23

ourselves from the source, the level drops24

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off fairly rapidly. So again, a very high1

level right out of the source, but by the2

time I get within three feet apart, there's3

very little, if any, impact right here.4

Now, another thing that's kind of5

interesting is that for those of us who6

have been told by our doctors that we have7

to reduce our salt intake because of8

hypertension or heart problems, they say,9

go get some salt substitute from the10

grocery store. What you're getting is not11

a salt substitute, it's potassium chloride12

instead of sodium chloride.13

And as I said earlier, of all the14

potassium on the planet, a very small15

traction is radioactive. And there's no16

difference from the potassium that's in17

here than the potassium that's in a banana18

or potato or any other potassium-rich19

food. And the difference is not quite what20

you'd hear with the Fiestaware, but you do21

hear a difference. And again, that's22

natural potassium 40 emitting beta23

particles and gamma rays. And this is what24

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we need to eat to protect us from1

hypertension. Again, it doesn't cause a2

big dose. I just want to illustrate the3

fact that there's radioactivity all around4

us, even in the things that we eat.5

When we talk about dose effect6

relationship, about being exposed to7

radiation, there's one point -- if you get8

nothing else -- there's one point that I9

think is very important for you to10

understand. And that is that what we know11

about radiation is that, yes, it is most12

definitely a human carcinogen. But we know13

that because of studies that have been done14

on populations of people that have been15

exposed to very, very high doses of16

radiation, compared to background, compared17

to the levels that we have at some of the,18

quote, unquote, contaminated properties19

here. These would be groups such as the20

Japanese who survived the atomic weapons21

blast at the end of World War II. Several22

groups of patients, who back in the ‘20s23

and ‘30s, and ‘40S were treated for various24

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ailments with radiation. Whereas now, the1

medical community uses radioactivity to try2

to help destroy cancer cells. Back then it3

used to be a treatment for certain4

diseases. So 20, 30, 40 years later there5

are these populations treated with these6

high doses of radioactivity who were7

followed and were found to suffer from high8

or increased levels of cancer.9

So what do we do as public health10

scientists? We know that when the dose is11

very high we see excess cancer. Now we’ve12

got the lower dose and you can see in this13

curve, what Im talking about earlier with14

the Japanese and some of these other15

groups, theyre up here in the dose16

response curve. We know the dose is very17

high and we see the health effect or the18

risk of cancer is easy to measure. what we19

have down here is what I call an area of20

great uncertainty. There are no data that21

we can point to that will show that at the22

levels that we’re exposed to from23

background radiation and from levels that24

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are slightly greater than background such1

as some of the properties that have these2

thorium residues an them. There are no3

data that show that people exposed at those4

levels are actually suffering from5

increased incidents of any type of cancer.6

But the fact that I can say that7

doesn’t mean that we can then dismiss or8

would want to say there’s no problem, let’s9

forget about it. We make an assumption.10

we assume that there’s a linear risk. We11

assume what’s called no threshold, that as12

soon as you get any dose of radiation, we13

assume there’s some risk. it might be very14

small. We certainly can’t measure it and15

the truth of the matter is, there may be no16

risk at all.17

But we assume that there is a risk.18

And when we end up at a risk level, when we19

do our risk assessment part of this20

investigation, we come up with a number and21

compare that to what EPA has determined to22

be the acceptable risk range. And if our23

models project a risk greater -- that is24

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greater than the risk range that EPA is1

looking to obtain, that becomes the basis2

for a cleanup. The way the Superfund law3

is written, EPA needs to demonstrate a risk4

greater than what they found to be5

acceptable and to use that then as a reason6

to go forward with an action.7

At this point I’ll stop and Rick will8

pick back up and discuss the alternatives9

for the sites.10

MR. ROBINSON: Thanks, Alan. Now11

what we’re going to talk about is, based on12

the results of the remedial investigation13

we evaluated a number of alternatives for14

the cleanup. And we evaluated alternatives15

for the three property types we discussed16

earlier, the vicinity properties, the17

Welsbach facility and for the General Gas18

Mantle facility. And for each of the three19

property types we evaluated, we evaluated a20

No Action Alternative; an Engineering21

Controls Alternative; and an Excavation and22

Off-site Disposal Alternative.23

The No Action Alternative is an24

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alternative that we have to do on each1

Superfund site. And we have to compare the2

other alternatives versus what if we did3

nothing. If we left it alone, what are the4

risks. So the No Action Alternative is5

something that we have to do. In this case6

here, it was determined that there is a7

risk above EPA’s criteria, as Alan just8

told you. And as a result we’re not going9

to talk about the No Action Alternative10

anymore. And we’re not even going to11

consider it right now.12

For the vicinity properties, for the13

Engineering Controls Alternative, it’s14

Alternative V-2. Outdoor gamma shields15

would be required on approximately 5016

properties; indoor gamma shields on17

approximately 20 properties; and radon18

mitigation systems would be needed an19

approximately 4 properties; As a result we20

would need to have deed restrictions on the21

property, limiting future work on that22

property. And we would have to negotiate23

that with each property owner. The State24

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of New Jersey would be responsible for1

enforcing those restrictions. And we would2

have to go back every five years to make3

sure that it was protected and the shields4

were still effective.5

For the Alternative V-3, the6

Excavation and Off-site Disposal7

Alternative, all the soil and debris above8

our cleanup standards would be excavated9

and disposed of off-site. And under this10

alternative, the contaminated materials11

would all be removed. The mobility of the12

contaminants would be eliminated and there13

would be no significant institutional14

controls remaining on the properties. The15

properties would be safe for future reuse16

and the remedy would be protective of human17

health and environment.18

For the Welsbach facility,19

Engineering Controls, again we would need20

outdoor gamma shields. We would need deed21

restrictions limiting future site work.22

And we would have to go back every five23

years to make sure that it was protected24

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and that the shields were Still effective.1

Alternative W-3 for the Welsbach2

facility, all the soil and debris above our3

cleanup standards would be removed and4

excavated and sent off-site for disposal.5

All of the materials, again, would be6

removed from the property, mobility of the7

contaminants would then be eliminated, and8

there would be no controls remaining.9

For General Gas Mantle, again for the10

Engineering Controls Alternative, G-2,11

again outdoor gamma shields. For the Gas12

Mantle building, we would have them13

permanently board the building shut. We14

would have to restrict access against the15

building, and we would have to go back16

every five years to make sure that it was17

still effective controls.18

For the Excavation and Off-site19

Disposal Alternative G-3, we evaluated two20

options for the buildings. For the General21

Gas Mantle facility under Option A, the22

building would just be demolished and the23

building materials would be sent off-site24

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as contaminated materials.1

For Option B, we would first go in2

and try to decontaminate the building and3

then this would reduce the volume of4

material that needed to go to off-site5

disposal. For both options all materials6

would be moved from the site and there7

would be no significant institutional8

controls.9

And now we’ll just go into some10

summaries. The summary of the cost for the11

vicinity properties. The engineering12

controls would cost about $2 million13

dollars to implement. And the Excavation14

and Off-site Disposal would cost15

approximately a little over $13 million16

dollars.17

For the Welsbach facility, the18

engineering controls, almost $6 million19

dollars. And the Excavation and off-site20

Disposal, $18.5 million dollars.21

For the General Gas Mantle facility,22

the Engineering Controls Alternative just23

under $400,000. And the Excavation and24

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Off-site Disposal for Option A which was1

the straight demolition of the building is2

just over $2 million dollars. And for the3

decontamination and demolition of the4

building, just under $2 million dollars.5

As a result, EPA’s preferred6

alternative is the Excavation and Off-site7

Disposal Alternative, V-3, W-3 and G-3.8

And with the General Gas mantle facility it9

would be option B, decontamination prior to10

the demolition.11

In summry, the total cost of the12

selected remedies combined is almost $3413

million dollars. Where do we go to next14

now? The next steps, right now we’re at15

the process soliciting public comment. And16

as Mary Helen told you earlier, we’re here17

to respond to your verbal comments tonight18

and we’re also encouraging you to submit19

written comments, if necessary. And after20

we receive public comments, we select a21

remedy in a document that’s called a Record22

of Decision (ROD). And once we sign the23

Record of Decision, EPA can then start the24

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design process.1

Our focus will be on the residential2

properties first. And then followed by3

that the commercial and industrial property4

cleanups. We plan on starting the field5

investigations on the suspect properties in6

the fall of this year. And we’ll hopefully7

start the design and investigation on the8

potential contaminated properties also in9

the fall. And we’re also going to try to10

start the demolition process of the General11

Gas Mantle building sometime this year and12

hopefully finish in one to two years. The13

General Gas Mantle building is in a very14

sad state of disrepair. vandalized a15

number of times. The wood floor is a fire16

hazard. we’d like to get the building down17

as soon as possible.18

The plan right now is to start the19

cleanup activities on the individual20

properties in about three to five years.21

One of the processes with the design is22

that because it’s an individual nature of23

the property -- because the contamination24

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is on an individual property, we have to do1

a specific design on each individual2

property. And it takes time to generate3

the design activities on all these4

different properties and put it together in5

a package so that we can have a contractor6

go in and do the cleanup all at once.7

We’re also in the process of8

conducting a ground water investigation.9

And that’s underway right now to make sure10

there is no radiological contamination from11

the site in the ground water. We don’t12

believe we’ll find that much, but thorium13

itself does not like water. It doesn’t go14

into water, into solution. But we’re15

testing the ground water anyway just to16

confirm that there is no radiological17

contamination there.18

We’re also going to investigate the19

wetland areas around Newton Creek, around20

the Johnson Boulevard Land Preserve and21

along Temple Avenue where there’s two22

former dumps as well as the Welsbach23

operation.24

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And that’s the end of our1

presentation. We'd like to invite you to2

ask any questions. we're all here to3

answer them.4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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MR. EVANGELISTA: Before we get1

involved in the questions and answers, I2

just wanted to point out that we have some3

handouts up front. One provides you with4

factual information, sort of a summary fact5

sheet. Hopefully it kind of reiterates6

what I opened up with at the initial part7

of the meeting. If you have any questions8

now is a good time to raise them.9

MS. CERVANTES-GROSS: Or if you just10

have a comment. If you could just state11

your name again before you give us your12

question.13

MR. BECKS: My name is John Becks(ph)14

(INAUDIBLE). I live on the 900 block of15

Somerset Street. I’m about eight houses16

from where you were doing the cleanup17

earlier.18

Did they come around -- did you or19

the State come around to individual homes20

in that area to test our homes? And what21

steps are being taken for that?22

MR. ROBINSON: You might have to show23

us on one of the maps where Somerset Street24

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is.1

MR. SAUNDERS: Johnson Boulevard, the2

ponytail, almost catty-corner, right in3

those blocks.4

MR. ROBINSON: I would have to look5

at the State information on whether or not6

that part of Somerset Street was included7

in the investigation. We could let you8

know if there is any information on your9

property -- if the State did survey it or10

not. If you don't believe they did –11

MR. BECKS: No, I don't.12

MR. SAUNDERS: That area -- actually13

the whole town -- we get a lot of false14

positives, which is what we want. They go15

back through that area to see if it's16

construction of the home material. And in17

that area the only thing they saw was along18

the Johnson Boulevard area of houses in19

Gloucester, (INAUDIBLE), in that immediate20

area.21

MR. BECKS: Why wouldn't they be?22

MR. SAUNDERS: We went out. I can23

show you an one of the colored pictures24

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where it was done.1

MR. BECKS: And was it?2

MR. SAUNDERS: Yes, it was done. Was3

the house done? No. Plus the construction4

date of those homes -- that was called the5

homes, like, that (INAUDIBLE) and a lot of6

the construction predated the site. The7

homes were built -- that whole section on8

Somerset Street predated a lot of the dump9

area. The wetland area that was all10

wetlands in the ‘50s. So that's some of11

the ones where we didn't see anything.12

When I say "we," EPA. There was nothing to13

indicate that there was any concern14

whatsoever in that area (INAUDIBLE) quite a15

few feet to make sure.16

Some of the pictures -- here some17

people made mention of (indicating).18

People want to make sure again and again19

and again, to make sure. So that’s why it20

may be contaminated here. we are going to21

look here and here and here and here again22

(indicating). The last thing anybody wants23

to do is do this wrong.24

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I live around the block. I have --1

was my house tested? No. Because I know2

the age of when they were built, how it was3

built. Where Dr. Kelly lives, that area,4

that predated the dump. So the homes built5

before the dump (INAUDIBLE) they weren't6

(INAUDIBLE). However, as part of this7

randomly (INAUDIBLE). They did go out.8

MR. ROBINSON: If you'd like and you9

are concerned, we can just go over and do a10

quick walkover while one of our contractors11

is out here.12

MR. BECKS: I'm concerned too, in13

talking with various neighbors, it was a14

common practice at the time when they were15

filling the wetlands, that people go home16

and pick up building materials, bring them17

home to your site, wood and such. And18

that's a concern.19

MR. FELLMAN: Part of the answer is20

that this fly-over data kind of laid out21

the boundaries of the different study22

areas, as starting points. And not looking23

at a map, you know, I suspect that your24

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home is probably outside of the boundaries1

that the fly-over gave us to start with.2

MR. BECKS: I was doing some work in3

my basement about a week and a half ago. I4

tore out the closet and there was building5

material from Welsbach.6

MR. ROBINSON: Really. If you could7

please leave your name. I have a8

contractor who's here with me today doing9

some fieldwork and we can make an10

appointment and scan your property. We'll11

need to do that this week.12

MR. BECKS: I have two very small13

children that my wife and I love dearly.14

MR. SAUNDERS: That's the kind of15

information -- some people think they're16

going to get in trouble.17

MR. BECKS: Well, that's why I came18

here. That's not the only reason. I was19

planning on coming when I first read it in20

the Gloucester City News. The only way21

that I knew about this meeting was from22

that article in the Gloucester City News.23

I can see by the amount if people that24

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apparently nobody cares or everyone wasn't1

informed.2

MR. SAUNDERS: This is what we did.3

Gloucester City News was given the same4

data as the Courier and as the Inquirer.5

And all those areas of people who live in a6

house (INAUDIBLE) there was suspect7

condition. So now you're looking at quite8

a few hundred people and this is generally9

the response.10

MR. BECKS: I only really get the11

Gloucester City News. I don't read the12

Courier or the Inquirer.13

MR. SAUNDERS: In fairness to EPA, a14

lot of these residents who had questions, a15

lot of them have called to complain. And16

we'll give them the information -- plus the17

residents we've sat down with. And I'll18

show you what we have here, a demarcation.19

MR. BECKS: There was a lot of people20

filling in tree holes from dirt piles down21

at the end of the street.22

MR. SAUNDERS: But the fly-over would23

have shown that.24

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MR. ROBINSON: We can schedule a time1

tomorrow morning. We,11 still be here in2

town. We can make an appointment with you3

or anytime at your convenience when we're4

down here. If you know of anybody else who5

are not in these areas who have other6

Welsbach materials, we're very, very7

interested in trying to find those homes.8

Like a former worker who used to work there9

may have brought some stuff home with him.10

It's very, very hard to do the entire11

town. And we need help from the public on12

that.13

MR. SAUNDERS: As always, if you get14

the word out, they can call us 24 hours a15

day and we'll take a quick sample. That's16

the beauty. We can meter it and say, yes,17

it's there; no, it's not. We want to do18

that with a whole host of the materials.19

MR. BECKS: Thank you.20

MS. CERVANTES-GROSS: Anyone else21

have a comment or a question?22

MS. MARKS (ph) - my name is Sue23

Marks. I live in Bellmawr. I was a24

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resident of Fairview for many years. I1

have a couple of questions and I spoke to a2

couple of gentlemen earlier.3

I have a cancer study here that I4

sent to the EPA (INAUDIBLE) a couple of5

weeks ago. I received a copy of this and6

in here, one of things that stood out for7

me was, it says higher cancer incidents8

from the Welsbach General Gas mantle site9

appear to be due to significantly higher10

lung cancer incidents in the population,11

especially in males.12

Do you -- and maybe you're not the13

right people to ask -- but to me I'm14

concerned about the health aspect of what15

has seemed to be a long-term problem here.16

As I said, I used to live in Fairview and17

my house -- I just saw on one of the poster18

boards there -- was basically right19

directly behind one of your highly20

contaminated homes. I'm concerned about21

the residents’ health. And I guess what I22

need to know is, the people that are living23

in these homes that are the 54 contaminated24

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homes, what will be done with them, to1

them, for them, while this remedial work is2

going on? In other words, A, will they be3

moved out of their home; B, will they be4

monitored for any sort of health problems5

as the remedial work is going on? To me6

that's one of my greatest concerns.7

I think, Bob, you and I had spoken8

about this earlier. I don't know where9

this came from. I don't know how it's in10

reference to this Welsbach site. But I11

have to know that it must be connected12

somewhere.13

MR. ROBINSON: For the answer to the14

health study, we have Artie Block here from15

ATSDR. And his agency is the one who16

sponsored the State investigation.17

MR. BLOCK: Let me just take a18

moment. Again, my name is Arthur Block.19

I'm a Senior Regional Representative for20

ATSDR.21

As was mentioned by Mary Helen, ATSDR22

is the Agency for Toxic Substances and23

Disease Registry and is part of the24

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Department of Health and Human Services.1

We are primarily, and our main mandate and2

responsibility, is environmental health.3

We work very closely with the Federal EPA,4

the State, the community, whatever it is to5

identify if there are any health needs or6

health concerns associated with7

environmental exposure. And that's8

basically our main role.9

One other thing I'll tell you about10

our agency, my agency, is that it is an11

independent environmental health agency.12

In other words, we look at situations that13

affect you, the community, on an14

independent basis. We look at all the data15

that was put in front of us and we evaluate16

that data independently of other agencies.17

And we give you our health call as to what18

is up or what's going on in your19

community. I'm not going to spend too much20

more time on this. Here's the information21

and certainly if after the meeting you want22

to speak more to me about our agency, you23

can have this information about ATSDR. And24

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there's a lovely young lady over here who1

says she's a computer geek, so I'm going to2

pass this onto you, which is our web page.3

And we also have some more of that if4

you're into computer information. And5

actually you can get a lot of information,6

more than I could ever tell you tonight,7

about contaminants, about how they impact8

on human health. So if you want that9

information I can certainly pass that along10

to you too. And I'll certainly give you my11

card and, as Pat indicated, if you have any12

follow-up questions.13

I'm not a scientist. I'm just like14

you guys. But I work in public health so15

there may be some specific questions, if16

you do come up with any, that refer to a17

specific science or physic radiation. I'll18

refer those to Alan. He is a health19

physicist and the person who can give you20

the scientific readouts. I'll give you the21

readout from the point of view of just22

common people like ourselves.23

If you look at the houses that, as24

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they existed 50, 60 years ago or the area1

around there 50, 60 years ago -- I wish we2

were able to take one of these machines and3

read what people were exposed to back then4

and at what level. We don't know. We5

don't know. That is the bottom line.6

Nobody knows. It takes time for cancer to7

develop. It doesn't happen overnight. And8

it takes a lot of dosage, constantly being9

exposed to these high doses. These are10

things that just come out. And that’s how11

I understand it.12

To get exposed on a normal basis, as13

indicated, we do commonly get exposed to14

radiation in different levels. Most of15

that is not of public health concern.16

People who generally worked in these17

situations and got a constant exposure to18

them, these are the people who developed --19

or in the case, you know, of the Japanese,20

where you have a huge, huge amount of21

dosage coming at you at one time. So these22

things we know about.23

Now, let me also make some other24

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statements about the study. And that1

hopefully will get to your question. Is2

lung cancer -- can it be associated or is3

it biologically causable that radiation can4

cause lung cancer? The answer is yes. But5

looking at the numbers and what was given6

to ATSDR and the New Jersey Department of7

Health who did the evaluation of the8

sampling that was done, these dosages were9

not high enough or should not have been10

high enough to give you lung cancer.11

That's the short and long of it.12

But nonetheless, ATSDR, my agency,13

along with the New Jersey Department of14

Health and the Department of Health and15

Human Services decided to take a look. And16

you won't be surprised to hear that in New17

Jersey there are other sites like this. So18

you have Maywood in Maywood, New Jersey.19

You have the West Orange, Montclair area,20

all similar radon exposures. New Jersey21

and ATSDR decided, well, let's take a look22

because communities generally are concerned23

about cancer and understandably so,24

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radiation issues around these type of1

Superfund sites.2

So we pick these three areas here,3

this whole bottom area (indicating), and4

those other two that I just mentioned. If5

you read the study, you'll find out that6

with an examining of the cancer risks7

around a one- or two-mile area of those8

Superfund sites, there was no elevated9

cancer of any type found associated with10

the exposure to radon or radiation. Didn't11

find it. Didn't find it in Montclair.12

Didn't find it in Maywood.13

What we did find, what you're14

bringing up is, yes, there was elevated15

lung cancer found here in this area.16

What's kind of interesting is, you have the17

same type of contaminant.18

If you look at the history of all of19

these sites, they're very similar. And yet20

you have just one elevation of one type of21

cancer, lung cancer, in this area. What22

you would want -- what you might expect to23

find is that if this is all similar24

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contamination, all similar exposures to1

people, that you'd find lung cancer here2

and find lung cancer in Maywood and you'd3

find lung cancer also in the Montclair,4

West Orange area.5

Is radiation the cause for the6

increased lung cancer? In all honesty, I7

cannot say to you standing in front of you,8

and I wouldn't say that, that it isn't9

possible. It is possible. The probability10

of it is probably much less than that.11

Okay. Beyond that, it would take a very --12

you'd have to study the individual people13

themselves to find out -- to rule out14

other, what are called, confounders.15

What are these confounders? These16

confounders are things like occupational17

exposure that causes lung contamination.18

Smoking, that we know has a direct19

association with lung cancer. These are20

the confounders that, if you pursued this21

further, you may find, yes, there was a lot22

of smokers out there. Or, yeah, they were,23

in fact, occupationally exposed. And that24

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elevated number that was found from that1

study will start to decrease or it should.2

Unless we rule out all other3

confounders and you're stuck with, yeah,4

it's the radiation. That's what that study5

was trying to find out. Is there any6

similarities in the occurrence of cancers7

within those three -- around those three8

given Superfund sites and there wasn't any9

found. Other than the one elevation of10

lung cancer here. And that was the purpose11

of the study. It wasn't necessarily to12

associate Superfund sites and cancer. That13

was not the purpose. The purpose was to14

see if there was any commonality of the15

exposures and things like that from the16

Superfund sites.17

Let me stop there. Having heard what18

Alan said, having heard what I said, are19

there more concerns than that? Did I20

somewhat, kind of, sort of, answer your21

question?22

MS. MARKS: Yes. It's just my23

concern that we live in the area that's24

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very polluted.1

MR. BLOCK: It's a very real2

concern.3

MS. MARKS: Exactly. And the4

Welsbach problems coupled with this study5

just alarmed me more than I thought.6

I do have a couple other questions.7

MR. EVANGELISTA: At this point I'd8

like to address the other part of your9

question regarding how the EPA will deal10

with affected residents whose property will11

require cleanup.12

As Rick and I touched upon a little13

earlier, we talked about the remedial14

design phase of the project. At that point15

EPA will look at each of these individual16

properties that will require cleanup and17

design an approach for cleaning up that18

property. And each property will be19

different. You may have a property that20

has several bricks in the backyard that we21

will essentially pick up and take away. We22

may have another property where we may have23

to excavate a certain volume of soil that's24

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elevated in levels of radioactivity which1

we'll also move away.2

Whatever you may have as far as a3

cleanup that's required, the agency will4

and hopes to work very cooperatively with5

the property owner. Our intent or our6

approach will be as we've applied it in7

other sites like Montclair where we'll work8

as closely as we can with the property9

owner to impose as little inconvenience as10

possible.11

You touched a little bit upon12

relocation. If there's a need for13

relocation, which we hope there won't be,14

but if there is a need then EPA will work15

as closely with the property owner as16

possible to provide as temporary relocation17

as possible. And, of course, that will be18

at our expense or the Superfund's expense.19

But we hope that that will not be the case20

for any of the properties. But I'm not out21

here to tell you tonight that that's not22

ever going to be the case on any of these23

projects. That may very well be the case24

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on some of the projects. So we'll just1

have to wait and see and we'll do our best2

to keep you as informed as possible in as3

timely a fashion as possible.4

MR. SAUNDERS: Say I live in a house5

that there's known contamination there, I6

understand remedial measures have already7

been taken (INAUDIBLE) shields as discussed8

earlier. So right now, if you're in the9

house (INAUDIBLE) we know we're going to10

protect you. There’s a lot of (INAUDIBLE)11

that don't care about the health issues,12

they just care about the trees and birds.13

That's the farthest thing from the truth.14

(INAUDIBLE) and then we go from there. And15

we have been somewhat criticized in16

(INAUDIBLE) and using overkill. And yes,17

we do take overkill and we wear it as a18

badge of honor. (INAUDIBLE) some of the19

people over at the Popcorn Factory, I'd20

much rather be brought before my governing21

body -- there are quite a few Council22

people here -- I'd much rather be brought23

on the carpet for overkill than not doing24

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enough. And the direction is always1

overkill. It's never not enough. So here2

that's what we've taken. EPA, they have3

gone above and beyond in many, many4

situations.5

MS. MARKS: Would there be any sort6

of follow-up, I mean, like a health study7

done on the residents after your remedial8

work takes place? Will you be tracking9

them for a period of time to see if they10

develop any sort of problems or any11

long-term problems due to -- maybe before12

your remedial work started and before these13

temporary structures were put into place?14

MR. SAUNDERS: Would you be able to15

speak for the purpose of contamination?16

MR. BLOCK: Your question is more, as17

I understood it, they're going to begin the18

remedial and then -- did I sense that you19

think you're going to be exposed to20

something during that time period and21

then --22

MS. MARKS: No; no.23

MR. BLOCK: Okay. I did24

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misunderstand then.1

MS. MARKS: I understand the way it's2

going to occur. What I'm saying is, these3

people, evidently, I assume some of them4

have been living in these contaminated5

homes for some time. Will there be some6

sort of a health study done on them before7

the remedial work starts and then would8

there be a follow-up study just to track9

the situation to see if anything -- they10

have incurred any sort of medical problems?11

MR. FELLMAN: In a sense that first12

health study is what ATSDR funded to the13

State. Because the only health effects14

that we associate with exposure to15

radiation is cancer. There aren't other16

illnesses that we look at as indices of17

radiation exposure. So it's either18

elevated cancer or not. And so that first19

look, in effect, is the study that you've20

looked at. Now whether there's going to be21

an additional study done or another study22

done down the road -- I think -–23

MR. BLOCK: The bottom line, is there24

25

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a health plan?1

MR. ROBINSON: It's not planned.2

MR. FELLMAN: It's not part of this3

process.4

MR. BLOCK: It doesn't require it5

from the viewpoint of looking at the site6

and how the impact on health would be. So7

the short answer is no. But I know Bob8

wanted me to just discuss the Cancer9

Registry.10

Are all of you familiar with the11

State Cancer Registry? Is there anyone who12

needs information on that and how it works13

and what it's there for? Are you okay with14

that? Because I'll spend a moment on that15

if you'd like.16

New Jersey, like all 50 states17

throughout the nation, maintains what is18

called a Cancer Registry. Some states do19

it better than others. And, in fact,20

they're funded very well to maintain a good21

Cancer Registry. And within the states22

there are mandated laws that hold -–23

hospitals and physicians who diagnose24

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cancer must report that cancer incident to1

the State. And once it's reported, then it2

comes into the registry system.3

And the reason for that is,4

obviously, all of us are concerned about5

cancer. Not only for research reasons, but6

certainly we want to know how much cancer7

is out there and specifically within our8

own areas. Are there more elevated cancers9

overall? Why? Because that then may10

prompt further investigations. A perfect11

example of that is just north and east of12

here, Toms River. And I'm sure a lot of13

you have heard about that. And our agency,14

ATSDR, along with the New Jersey Department15

of Health is very, very much into that16

childhood cancer investigation at this17

point.18

So this Cancer Registry maintains all19

of the reported incidents. And actually20

this is kind of interesting. Prior to Toms21

River, the New Jersey Cancer Registry was22

probably four to five years behind in terms23

of keeping up with the data that was24

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entering in. After Toms River, all of a1

sudden money came into the Cancer2

Registry. And now it's probably -- and I'm3

not kidding you about this -- New Jersey's4

Registry is a gold mark standard registry.5

But something like that had to happen. And6

there are other states in the union who are7

not very good with keeping their data. But8

New Jersey is exemplary with its program.9

Now what that does is -- and when you10

get into the issue of statisticians and11

numbers and how big populations are in12

terms of how do you measure what's13

happening in one community as opposed to14

another community, what they do is -- I'm15

simplifying it, really -- I have to. I16

really don't understand all of it. I'm not17

a statistician.18

What they do is take comparable19

populations in numbers and size and their20

socioeconomic background. And they compare21

these two populations which are similar and22

look at the cancer rates or incidents23

within those populations, they should be24

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similar. Everything else being equal, they1

should be similar. But if something pops2

out, whether it be bladder cancer or lung3

cancer or brain cancer, that just doesn't4

gel, that pushes the investigative health5

system to go further, what's in this6

neighborhood that may be causing it, to do7

further investigation.8

MR. SAUNDERS: In an indirect way,9

yes, there is a follow-up indirectly.10

MR. GRABOWSKI: Mike Grabowski. I'm11

just wondering if your house is found12

contaminated and you don't want to live13

there, you want to sell, there's a problem14

there. But the State of New Jersey has a15

disclosure on it. You have to tell the16

Realtor. What happens with that?17

MR. ROBINSON: Well, I guess that's18

one of the grey areas of the process with19

an individual property that has20

contamination on it and the property owner21

wants to sell it.22

For EPA, what we can do to a23

potential purchaser -- we can enter into an24

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agreement with the purchaser to give them a1

prospective purchaser agreement to not be2

held liable for any cleanup costs associated.3

That way it may be helpful with the4

transfer. So that he wouldn't be taking on5

liability. However, with respect -–6

MR. EVANGELISTA: And assurance that7

it will be cleaned up.8

MR. ROBINSON: Right.9

MR. GRABOWSKI: Do I have to put down10

the limit of contamination in the area?11

MR. EVANGELISTA: We would be able to12

inform them at an appropriate time when13

we've properly investigated your property14

-- if it's your property that we're15

talking about -- yes, we'll have cut lines16

as we call them, where the contamination17

is, an estimate of the volume, etc., etc.18

If someone's interested in your property,19

we can provide them with a document that20

says EPA is going to clean up this property21

and is not going to hold you accountable22

for it in any way, shape or form.23

MR. GRABOWSKI: It will be pretty24

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tough to sell the property.1

MR. EVANGELISTA: I understand that,2

sir.3

MR. GRABOWSKI: Nobody would want to4

buy it, I don't think.5

MR. EVANGELISTA: I understand. And6

I guess the other part that may give you7

comfort, we've been moving along in this8

project extremely quickly. You may look at9

other Superfund projects where an RI/FS has10

gone on for three, four, five years. We've11

completed this process in what some would12

say is record time. We did it in a year.13

And we hope to continue moving that quickly14

so that we can restore your property and15

others to a form where it may be attractive16

for selling or you may be comfortable with17

it again.18

UNIDENTIFIED SPEAKER: I own a19

property on Temple Avenue that goes right20

into Newton Creek, concreted over. My son21

was told recently by a lawyer from Malcolm22

Pirnie that -- I had wanted to either give23

him the property or sell it, get it out of24

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my hair, so to speak. And the lawyer told1

him that he would be responsible for the2

cost of the cleanup.3

MR. KERBEL: Just to be clear, it4

wasn't a Malcolm Pirnie lawyer. I don't5

know if -–6

UNIDENTIFIED SPEAKER: He had spoken7

to Steve McNally(ph).8

MR. KERBEL: Steve is right here.9

UNIDENTIFIED SPEAKER: And he was10

referred to a lawyer.11

MR. ROBINSON: I think Steve referred12

your son to me.13

UNIDENTIFIED SPEAKER: Oh, was that14

you?15

MR. ROBINSON: Yes, I'm Rick16

Robinson.17

MR. KERBEL: We don't have the18

authority.19

MR. ROBINSON: Your son spoke to me20

and I basically told your son it's in his21

best interest to talk to an attorney to22

find out from an attorney himself, his own23

attorney. I didn't give him any legal24

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advice. I just told him it would be in his1

best interest to talk to an attorney prior2

to any transfer. Because he doesn't want3

to take on any liability knowing that he's4

buying a contaminated property. I'm just5

giving him advice, you know. I would6

contact an attorney. And I was just -–7

UNIDENTIFIED SPEAKER: And if I died8

tomorrow and he inherited the property, he9

would not have to pay for the cleanup?10

MR. ROBINSON: He would not.11

MR. EVANGELISTA: And neither would12

you.13

MR. ROBINSON: It's a different story14

when someone purchased the property not at15

full-market value and they try to buy a16

property for, you know -- they know it's17

contaminated and they're getting it for,18

like, three cents on the dollar or ten19

cents on the dollar. That's where EPA20

would then go back to that person who's21

buying it cheaply and say, hey, you're22

buying it not at the fair-market value and23

we may want to get some of that money24

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back. That’s where the issue is.1

MR. BLOCK: May I say one more thing2

about the Cancer Registry? I just want to3

point out the fact that the local County4

and City here are trying to get information5

from the New Jersey Cancer Registry to do6

some type of follow-up also. So they’re7

attempting to get that information.8

The Cancer Registry information is9

extremely confidential and private. And10

it’s designed under law to be that way. So11

to get that information, sometimes you have12

to jump through hoops to try to get that13

information. But I know your City and14

County are attempting to get that15

information to do some additional follow-up16

work. Is that correct?17

MR. SAUNDERS: Yes.18

MS. CERVANTES-GROSS: Any other19

questions or comments?20

MS. MARKS: Just two more. I wanted21

to address the issue of the alternatives.22

One, obviously, was a No Action Alternative23

which, for obvious reasons, would never24

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work. The second, the Engineering Controls1

Alternative. And the third, the excavation2

and demolition of the various properties.3

Is it my understanding that the EPA4

is suggesting that the demolition and5

excavation go forward? Has a decision been6

made on that?7

MR. ROBINSON: The decision won’t be8

made until EPA hears all the public9

comments. And we’re patiently waiting to10

hear your responses today, your verbal11

comments, and any written comments that are12

submitted. As Mary Helen said earlier, our13

public comment period ends on March 3, next14

is Wednesday. So after next Wednesday, then15

EPA sits back and writes responses to all16

of the questions and will formally select a17

is remedy in a document called the Record of18

Decision. And attached to the Record of19

Decision is another document that we call20

the responsiveness summary, which21

summarizes the verbal responses today that22

we’re given and the written responses23

also.24

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So that’s why we have a court1

reporter here today and she’s taking down2

your questions and my answers. So all that3

will be part of the record.4

MR. SAUNDERS: At the local level,5

our (INAUDIBLE) is March 3. And on that6

document would be a resolution (INAUDIBLE)7

in our City that supports that. I asked8

for a telephone campaign and that would be9

such (INAUDIBLE). That is something they10

need to make (INAUDIBLE) what is the11

interest here. And we support them12

totally. It’s part of what has to occur13

and we do have (INAUDIBLE) in that office14

and our governing body (INAUDIBLE).15

MS. MARKS: And I would hope that the16

City of Camden would do likewise. Although17

would have to say in my years -- you18

think you got 25 people here tonight --19

you’ll probably be lucky if you get ten20

tomorrow night. Unfortunately, a lot of21

City residents aren’t real anxious to go22

into the CCMUA at night. So that may not23

give you a real indication. Has anyone24

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there been in touch with the mayor over the1

situation?2

MR. ROBINSON: I’ve been in contact3

with the City of Camden, the mayor’s4

assistant.5

MS. MARKS: Okay. I would like to6

see the City of Camden put forth the same7

kind of resolution to remove and excavate8

the sites.9

MR. EVANGELISTA: I guess based on10

what we’ve seen and heard thus far, it’s11

our anticipation that the decision will be,12

in fact, to excavate both Camden and13

Gloucester City.14

MR. FELLMAN: In the proposed plan,15

that’s what EPA is indicating is EPA’s16

preference. So they need to have reasons17

why not to go forward with that, as opposed18

to having to be convinced to do it.19

MS. MARKS: Okay. One more20

question. When you excavate these sites21

and remove the contaminated material, it22

will be put onto a truck and trucked out of23

the area to wherever your hazardous waste24

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facility is?1

MR. ROBINSON: Most likely we will2

probably ship it by rail.3

MS. MARKS: Okay. If you ship it by4

rail it’s obviously not going to be put on5

the train right here in Gloucester City --6

MR. ROBINSON: We would hope to find7

a site here in Gloucester City to ship it8

out.9

MS. MARKS: On rail?10

MR. ROBINSON: On rail.11

MS. MARKS: You’re going to have it12

come right from the contaminated site in13

Gloucester City to the rail?14

MR. ROBINSON: Or the nearest rail15

transfer –-16

MR. SAUNDERS: We have two staging17

areas. If you’re getting to or worrying18

about spilling something, if you have an19

opportunity I can take you to the tankers20

they go in. They are totally encapsulated.21

MS. MARKS: You’re not going to bring22

it in from Camden? Incinerator ash has -–23

MR. SAUNDERS: We have sites here in24

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Camden and Gloucester City (INAUDIBLE) put1

on a truck. Just like you had (INAUDIBLE)2

that stuff.3

MS. MARKS: what is your estimate -–4

MR. SAUNDERS; Now you said three5

weeks. That’s beyond anybody’s control6

here.7

MS. MARKS: The problem is low8

(INAUDIBLE).9

UNIDENTIFIED SPEAKER: But your10

earlier statement that the stuff was11

falling out the top and containers were12

open and totally (INAUDIBLE) totally sealed13

at the top. I wasn’t –-14

MR. SAUNDERS: They were just -- if15

your concern is about falling out -–16

MS. MARKS: That is my concern that17

some of it will be falling out as you put18

it in and maybe it isn’t all carried away.19

MR. ROBINSON: We have a lot of20

experience in dealing with contamination,21

removing radiological contamination waste.22

We just completed a very large excavation23

in an Essex County site and a number of24

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homes in orange, New Jersey and Montclair.1

That material is transported by truck and2

sent out to Utah. Trucks moving it every3

day, moving it for four or five years now.4

MS. MARKS: I wasn’t insinuating that5

there was –-6

MR. ROBINSON: The material is not7

hazardous waste; it’s radioactive waste.8

MR. GRABOWSKI: Something should be9

on those trailers. In my neighborhood10

where I have a store, kids are jumping that11

fence and playing in that area. Now why12

shouldn’t that be marked off as hazardous13

waste?14

MR. SAUNDERS: Well, as I said15

before, I hope you’re calling the police16

when children are there. The (INAUDIBLE)17

site you saw with contamination is under18

gravel and dirt. There’s a fence. In19

order to get into those trailers20

(INAUDIBLE) to get into that property.21

MR. GRABOWSKI: Why don’t you have22

signs up?23

MR. SAUNDERS: The other issue is,24

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depending on the type of radiation you1

have, it depends on how you placard it. At2

that level there isn’t an appropriate3

placard. It’s too low.4

MR. FELLMAN: The labeling on the5

container for this type of waste is6

outlined in the Department of7

Transportation regulations. And the levels8

are such, or this type of waste is such,9

that it doesn’t warrant the type of label,10

I guess, that you’re looking for.11

MR. GRABOWSKI: Now high is that12

rating on that site?13

MR. FELLMAN: The rating?14

MR. GRABOWSKI: Reading; reading.15

The reading that you’re getting.16

MR. FELLMAN: I haven’t scanned those17

containers so I couldn’t answer that other18

than to say it’s clearly elevated because19

if it wasn’t, it would not have been20

removed from the park. So there’s21

something there. How high? I don’t know.22

MR. EVANGELISTA: You’re not talking23

about placards that should be on them for24

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shipment, you essentially just want some1

warning signs for kids.2

MR. GRABOWSKI: You know, like Bob3

said, call the police. I work too and my4

wife can’t constantly sit by the window and5

watch.6

MR. ROBINSON: What we’ll do is,7

we’ll arrange for signs to be placed on the8

fence.9

MR. SAUNDERS: This is the problem we10

have. If we speak to X amount of neighbors11

and try to accommodate the wishes of most12

neighbors in this township, that’s the13

problem. we’re never going to make14

everybody happy. Some people want signs.15

The vast majority of people indicate to me,16

if we don’t have to have signs, they really17

appreciate it.18

MR. FELLMAN: They want it to be19

invisible. They don’t want signs right20

next to their homes.21

MR. GRABOWSKI: I think it’s stupid.22

MR. FELLMAN: And you’re entitled to23

that opinion. But this is what people are24

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telling Bob and other folks.1

MR. GRABOWSKI: They’re afraid2

because if they want to sell their house,3

nobody is going to buy it.4

MR. SAUNDERS: It’s going to be5

remediated as soon as possible. It’s also6

going to be certified clean. And nothing7

will be done on there until that’s done.8

We can say confidently for the neighbors of9

the Popcorn Factory, that site is safe for10

you and everyone else. And we say that11

with full confidence. The items that are12

staged there will be removed. Those types13

of things are there to make sure that the14

residents, children and everyone else are15

safe. We’re not going to tell you things16

that we don’t know as exist today.17

UNIDENTIFIED SPEAKER: Mike sees18

these people in the suits, but they’re19

dealing with the removal every day. But if20

you go and you walk, you’re not going to21

get that type of exposure. Is that what22

you’re concerned about, Mike?23

MR. GRABOWSKI: No. The children in24

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the neighborhood. I live catty-corner from1

that. I don’t know if my property is2

contaminated or not.3

MR. SAUNDERS: In order for the kids4

to get into the containers -–5

MR. GRABOWSKI: They’re not getting6

into the containers. They’re covered. But7

they’re getting into the property8

(INAUDIBLE) before the fence (INAUDIBLE).9

MR. SAUNDERS: I think even if you10

patrolled it (INAUDIBLE). It’s an example11

of overkill. The City has done more to12

protect our residents than (INAUDIBLE).13

Required us to put more gravel at the site,14

to be more protective of our residents. So15

even if a child is standing (INAUDIBLE),16

it’s somewhat misleading that the17

contamination is underneath.18

So again, as Alan said, (INAUDIBLE)19

it’s, like, months and months and months of20

not moving it. We used overkill and are21

protective of that site. And I appreciate22

your concerns. And they’re valid. And23

we’ve taken -- if they tell us this is good24

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enough, we go a few more steps.1

UNIDENTIFIED SPEAKER: As far as2

getting from point A to point B, I live in3

the (INAUDIBLE) hundred block of Somerset4

Street. And as a truck would back in, they5

would put a tarp down. The truck would6

back over top of this tarp, seal it, and7

actually broom the truck off and everything8

around those tires was broomed off. I9

thought it was total overkill protection10

for us, the residents of the City, and I11

loved it. Before that truck moved, three12

or four guys would walk around it and sweep13

every tire, every little nook and cranny.14

It was amazing how they did it.15

MR. EVANGELISTA: In addition to16

that, getting back to the containers on the17

Popcorn property, not only are they covered18

with the locked covers, but inside the19

material is covered with clean fill. So20

even if someone opens the cover and gets in21

there, they’re jumping onto -–22

MR. GRABOWSKI: I didn’t know you had23

clean fill on top of that.24

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MR. EVANGELISTA: So there’s that1

additional protective measure that’s been2

taken. Like the gentleman said, everything3

is done with overkill.4

MR. SAUNDERS: They are metal too.5

The tops are sealed shut metal units, not6

open containers. There are several things7

they would have to do to get to the8

problem.9

MS. CERVANTES-GROSS: Any other10

comments or questions? Thank you for11

coming and, again, you have until next12

Wednesday if you have any other questions13

or comments. And you may have seen on the14

board outside here, there is additional15

information on the individual properties in16

the areas. Thank you.17

********18

MS. CERVANTES-GROSS: Can we go back19

on the record for some additional comments,20

please?21

MS. GRAHAM: Theresa Graham and Ed22

Gorman, Chairman of the Community23

Playground, Fort Nassau, that will be24

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placed at Johnson Boulevard right in the1

middle of the jogging track. And our2

concerns are the safety of any contaminants3

on there. we were told that an overall was4

done of the top of it and there doesn’t5

appear to be any right there.6

And our concern is that we’ll put7

$110,000 into the building of this8

playground and then come April 7th or 11th9

we’ll have it finished, and then what10

happens to it if later on you find11

something there. We want to be assured12

that our property, if anything has to be13

done, will be taken care of by DEP, I14

guess.15

MR. GORMAN: By somebody.16

MR. GRAHAM: By Somebody. Because a17

lot of time and effort on the part of this18

community as a whole has gone into this19

project. And we want to safeguard the20

children of the community above all.21

MR. GORMAN: Is there any fast22

tracking or something they could test23

before we actually build it on April 7?24

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MS. GRAHAM: Is there any kind of a1

boring that they could come down and do to2

totally assure us? Because we’re already3

contracted in for the beginning of this4

project on the 7th. Thank you.5

********6

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C E R T I F I C A T E1

STATE OF NEW JERSEY2

I, LINDA A. BURNS, Shorthand Reporter and Notary3

Public of the State of New Jersey, do hereby certify4

that I reported the public hearing in the5

above-captioned matter and that the foregoing is a6

true and correct transcript of the stenographic notes7

of testimony taken by me in the above-captioned8

matter.9

I further certify that I am not an10

attorney or counsel for any of the parties, nor a11

relative or employee of any attorney or counsel12

connected with the action, nor financially interested13

in the action.14

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Dated: March 4, 199924

Appendix D

Written Comments

R E S O L U T I O N

#R- 058 -99

A RESOLUTION ENDORSING THE ENVIRONMENTAL

PROTECTION AGENCY'S PLAN FOR CLEANUP OF RADIOLOGICALLY

CONTAMINATED PROPERTIES

WHEREAS, the United States Environmental Protection Agency has investigated various

sites in Gloucester City and Camden in relationship to the Welsbach/General Mantle Superfund

Contamination Site, including the four areas in Gloucester City listed below:

a) Study Area Two – an industrial zoned property along the Delaware River, formerly

occupied by the Welsbach Corporation and a residential area to the immediate east.

b) Study Area Three – residential and recreational properties, including the Johnson

Boulevard Land Preserve;

c) Study Area Five – residential properties, vacant land properties, and two municipal

parks near Temple Avenue an the South Branch of Newton Creek,

d) Study Area Six – vacant lots in a residential zoned area of Gloucester City; and

WHEREAS, the E.P.A.’s investigations have shown properties in the above stated locations

to contain soil contaminated to varying degrees with thorium, radium and uranium. which are

associated with waste materials generated in the manufacturing activities that took place at former

Welsbach Gas Mantle facilities; and

WHEREAS, the E.P.A. has proposed the following alternatives to address the findings

stated above:

a) No action;

b) Installation of engineering controls;

c) Excavation and off-site disposal of contaminated materials, and

WHEREAS, the locations of this contamination are almost entirely located in residential and

recreational areas, and the cost of excavation did off-site disposal, estimated to be $31,912,120.00,

shall be born entirely by the United States Environmental Protection Agency.

NOW, THEREFORE. BE IT RESOLVED that the Mayor and Common Council of

Gloucester City do hereby endorse the excavation and off-site disposal of contaminated materials from

the Welsbach/General Mantle Superfund Contamination Sites which are located in a Gloucester City.

D E G N A N & B A T E M A N, I N C.

(609) 547-2565

1

2

U.S. Environmental Protection Agency's (EPA's)3

Proposed Plan for Cleanup of Superfund Sites4

Public Hearing5

6

February 24, 19987

8

Public meeting of the U.S. Environmental9

Protection Agency (EPA) held at the Camden County10

Municipal Utilities Authority Auditorium, Camden,11

New Jersey, before Linda A. Burns, Shorthand Reporter12

and Notary Public of the State of New Jersey, on the13

above date, commencing at 7:00 p.m.14

15

16

17

18

19

20

21

22

23

24

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MS. CERVANTES-GROSS: We're going to1

go ahead and start. I just wanted to thank2

everyone one coming here tonight and we'll3

be giving you several presentations4

tonight. My name is Mary Helen5

Cervantes-Gross. I'm with the EPA and I'm6

here actually, standing in temporarily, for7

Natalie Loney whom most of you know. She8

just had a baby boy on February 14 and she9

will be back out here in the future to work10

with you again.11

But with us here tonight is12

Rick Robinson, Project Manager for the13

Welsbach General Gas Mantle Superfund site;14

Pat Evangelista, who is the team leader15

with the EPA overseeing various types of16

radiation sites and other types of sites17

throughout the region. Here as well is18

Arthur Block with ATSDR. He works with the19

EPA's Agency for Toxic Substances and20

Disease Registry, as well as a consultation21

business on health-related issues. Here22

tonight also is Alan Fellman as well as23

Bob Kerbel, both with Malcolm Pirnie who24

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are contractors for EPA working on both1

investigation of the sites and put together2

much of the information that you will hear3

tonight.4

And I just wanted to remind everyone5

that what you say tonight, whatever6

questions you have, what comments you have7

- - we have Linda Burns here who is a8

stenographer and who is officially taking9

down all of your questions and comments and10

they will go into the official record. And11

at the end of the public comment period,12

which ends next Wednesday, March the 3rd,13

we will review all of the comments what we14

have received both here tonight and at the15

meeting that we had last night in16

Gloucester City. We will also review any17

written comments that we have, and we will18

prepare a responsiveness document answering19

or responding to any comments that you20

have. As well, all of these comments will21

be looked at before we make a final22

decision, because that's what we do with a23

Superfund program. Throughout the program24

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we come out to the community before we make1

final decisions in an attempt to answer any2

questions or concerns you have, so that we3

are sure to address those in its final4

decision.5

So with that I will turn it over to6

Pat who will talk to you a little bit about7

the Superfund program in general.8

MR. EVANGELISTA: Welcome. Before I9

get started in my part of the meeting this10

evening, I'd like to introduce to you, as11

well, Fred Mumford who is here representing12

the New Jersey Department of Environmental13

Protection. What I'd like to do in getting14

the meeting started is to just talk to you15

a little bit about the Superfund process16

and how it works and just to familiarize17

you or remind you of how it works.18

Back in 1980 Congress handed the EPA19

a law known as the Comprehensive20

Environmental Response and Liability Act21

and amended it five or six years later. So22

it's what we're working with at this site23

today.24

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It starts out with what's known as1

discovery. Discovery is the part of the2

process where we are actually made known of3

the site and it warrants us to follow up4

and perform what's known as a preliminary5

assessment or site inspection where we6

gather information that we need to do7

what's known as a hazard ranking. In8

performing the ranking we generate what's9

known as a hazard ranking score. And if10

that score is or exceeds 28.5, the site11

ends up on what's known as the National12

Priorities List.13

This allows us as EPA to perform14

what's next in the process and this is15

known as a remedy investigation feasibility16

study. That's what we would call the more17

detailed investigation of the site to18

gather all of the information that we need19

about that site to generate alternatives20

that we would look into for remediating the21

problem or cleaning up the problem. And22

those alternatives are evaluated in the23

feasibility study part of that remedial24

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investigation.1

The alternatives are then evaluated2

according to certain criteria and, you3

know, at the end of that process we would4

recommend a cleanup alternative that we5

would put before you, the public, and6

concerned citizens. And that part of the7

process is what's known as the proposed8

plan.9

The proposed plan is what we10

presented as of February 1 and is subject11

to your review and comment. And that's12

part of the reason why we're here tonight.13

As a result of the public comment14

period, we generate what's known as a15

transcript, hence our stenographer here.16

And that transcript is added to the record17

of decision which formalizes the agency's18

decision, your comments inclusive, of19

course.20

After that we enter into what's known21

as remedial design. We actually design the22

nuts and bolts of the remedy that the23

agency has selected.24

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From there we enter into the cleanup1

phase and ultimately we certify it as clean2

and acceptable for future use. And we3

delete the site from the National4

Priorities List.5

That's basically the process. If you6

have any questions I'd be happy to answer7

them for you later. Thank you.8

MR. ROBINSON: I'll just go into a9

little bit of background on the site. As10

most of you know the site is located both11

in Camden and in Gloucester City. And it12

comprises the two former gas mantle13

manufacturing facilities. It also includes14

residential properties, commercial15

properties, municipal park lands in16

Gloucester City and vacant land.17

As part of the State's investigation18

early on, they divided the sites into study19

areas. And for the purposes of our20

investigation we followed those study21

areas. And the first study area is where22

we are right now in Camden around the23

General Gas Mantle facility and the24

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surrounding properties. Study Area Two is1

Gloucester City, the former Welsbach2

facility. Study Area Three is also in3

Gloucester City. It comprises residential4

properties and land preserve. Study Area5

Four, some residential properties in the6

Fairview section of Camden. And Study Area7

Five, residential properties including8

municipal parks in Gloucester City. And9

Study Area Six is also some vacant land10

properties in Gloucester City.11

Again, Study Area One is around the12

General Gas Mantle facility here in13

Camden. And this is a photograph of the14

area and the General Gas mantle building is15

highlighted. There’s a photograph of the16

famous General Gas Mantle building.17

Study Area Two is the former Welsbach18

facility, it's now owned by Holt. The19

Gloucester terminal is there on Kings20

Street. And the Armstrong building is the21

last remaining building from Welsbach's22

operation.23

Study Area Three is Gloucester City24

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and it comprises the swim club area and1

Johnson Boulevard Land Preserve.2

Study Area Four is in the Fairview3

section of Camden. And we only had a few4

properties in that area that had some5

elevated gamma radiation levels.6

Study Area Five is Gloucester City7

and comprises a dump area off of Temple8

Avenue and municipal park lands.9

Study Area Six is a newer identified10

area in Gloucester City. We call it the11

Popcorn Factory.12

Site history: In about 1885 a13

Dr. Carl Auer von Welsbach invented the14

process of using thorium, to manufacture gas15

mantles. And just to let you know, gas16

mantles are the material that's used for17

camping lanterns or in the street lights.18

Right there is a gas mantle (indicating).19

And what they did is they took a sock of20

material and dipped it in a solution of21

thorium. And when the sock dried and they22

lit it, it produced a very brilliant white23

light. And as a result the thorium is24

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radioactive. And that's what we’re here to1

clean up.2

In the 1890s Welsbach started3

manufacturing the gas mantle and by the4

turn of the century they were the world's5

largest manufacturer of them. And in the6

early ‘40s they went out of business when7

the electric light put gas lighting out of8

business basically.9

Very little is known about General10

Gas Mantle. We know they operated from11

around 1912 to 1941. We just know that12

they probably used radium and thorium.13

They didn't manufacture -- they didn't14

process any ores. They just bought the15

ores -- bought the refined radium and16

thorium. And they manufactured gas17

mantles.18

What we’ve termed all of the other19

properties that are associated with the20

radiological contamination here, besides21

the Welsbach facility and the General Gas22

Mantle facility, we call them vicinity23

properties. And they were contaminated24

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either from disposal of ore tailings from1

Welsbach, or building debris from when they2

knocked some building down, or when they3

built the bridge back in the early ‘50s, or4

from workers bringing contamination home5

with them.6

Previous investigations: The site7

was initially identified in 1980 as a8

potential radiation site during search of9

the U.S. Radium site in Orange, New10

Jersey. And in 1981 EPA sponsored an area11

fly-over to search for gamma radiation.12

And a helicopter came over the area looking13

for excess gamma radiation levels.14

In the mid-1980s the State went out15

conducting preliminary screenings in the16

area. And in the early 1990s they17

investigated over a thousand properties18

throughout Camden and the Gloucester City19

area. Based on those results they20

identified about 20 properties that they21

felt that needed more immediate action.22

And as a result they installed some23

radon/thoron ventilation systems in some24

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homes. They put concrete or steel sheeting1

down to shield for gamma radiation. And2

they purchased one property in Gloucester3

City and relocated the resident.4

Also, in 1992 they removed5

radioactive materials from the old General6

Gas Mantle building. They relocated the7

occupant at the time, Ste-Lar Textiles.8

And they sealed up the building to restrict9

access.10

The State investigation: They base11

their contamination levels on surface12

exposure rates, indoor radon sampling and13

limited surface soil samples. However,14

they didn't perform any subsurface15

sampling. They made no estimate on the16

amount or extent of contamination. And17

they were just looking to address any of18

the immediate potential health concerns at19

the time.20

EPA's involvement at the site, again,21

when the site was placed or took the lead22

-- we took the lead on the site when the23

site was placed on the Superfund list back24

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in June of 1996. Currently, the General1

Gas Mantle facility is inactive and boarded2

shut. Welsbach is an active facility, now3

owned by Holt. And the vicinity4

properties, any immediate health treats5

were either addressed through interim6

measures performed by the State or by EPA7

removal action last December in the park in8

Gloucester City.9

I'll now turn it over to Alan Fellman10

from Malcolm Pirnie and he will give you a11

real brief overview on radiation.12

MR. FELLMAN: I just want to spend a13

few minutes going over a couple of the14

terms regarding radioactivity that will15

hopefully make it a little easier for you16

to understand.17

Some of the things we're saying about18

the conditions of these properties, when we19

talk about radioactivity we're not talking20

about a typical product that we measure in21

pounds or address in terms of mass. We're22

more concerned with the amount or the rate23

at which the radioactive atoms are24

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decaying. And the unit that we use to1

describe that is called pico Curies, which2

we abbreviate pCi.3

Now when we have radioactivity in4

soil, we express the amount as5

concentration in pico Curies per gram of6

soil. And if we're talking about7

radioactivity in water or liquid, then we8

would express it as pico Curies per liter,9

pCi/l.10

Again, now this is only indicative of11

how much there is. It doesn't really12

address the dose or the risk. To do that13

we need some other terms. The dose of14

radiation is expressed in the unit known as15

millirems. And what we are expressing when16

we quantify millirems, that’s a measure of17

how much energy, which is released from the18

radioactive emissions, is transferred from19

those atoms into an absorbing media such as20

the human body. The amount of energy21

that's deposited is used to determine what22

the dose is and, of course, the higher the23

dose the higher the risk.24

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There are several different types of1

radioactivity that are emitted from2

thorium, uranium, radium, radionuclides3

that are associated with this waste4

material. Alpha particles are the heaviest5

of these. They have mass. They travel6

very slowly. And they can be shielded by7

something as thin as a piece of paper.8

Beta particles are intermediate in9

penetrating ability. They can be10

transferred through a piece of paper but11

are more likely to be stopped by a piece of12

wood.13

On the other hand, gamma radiation,14

also known as photons, have no mass.15

They're simply packets of energy. And they16

are also sometimes referred to as17

penetrating radiation. These are things18

that are more likely to get through paper19

or wood. And it takes something denser or20

thicker to shield them, such as concrete or21

lead.22

The problem that we have here for the23

most part has to do with the radioactive24

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residue being present in dirt. And when1

the dirt gets moved from the Welsbach or2

General Gas Mantle facility onto an3

adjacent or vicinity property, it can be4

put in the ground either adjacent to a5

structure or in some cases beneath a6

structure. When the radioactivity decays7

several of the -- most of the radionuclides8

are solid. They don't travel; they don't9

really go anywhere. They stay where they10

are placed. But at one point in the11

process the resultant atom that's formed is12

a gas, radon. And if the radon gas is13

formed in soil that's either up against the14

side of a building or beneath the building,15

now you've got something that's mobile and16

can emanate from the soil into the building17

resulting in a potential medical threat.18

For people who don't have that19

problem but where there's this type of20

radioactivity associated with the soils21

some distance from a structure, in that22

case the potential exposure to the gamma23

radiation that's emitted from the ground is24

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part of the radiation dose to a person1

occupying that area.2

Also, the next few minutes will be3

spent going over the field investigations4

that Malcolm Pirnie has performed for EPA5

over the last couple of years and6

Bob Kerbel will be talking about that.7

MR. KERBEL: I know some of you were8

here at the meeting we had a year ago, but9

I'll just go over in the nutshell again the10

type of work we've been doing in the two11

communities. We did investigations at the12

former Welsbach facility and the General13

Gas Mantle facility, they are industrial14

facilities. Now anything beyond the border15

of those two facilities we term vicinity16

properties. The term residential property,17

that's categorized into the vicinity18

property category.19

Now, if there's anything good from20

our standpoint as investigators, it's that21

this material is easy to detect. We have22

meters that we walk over the property and23

it's easy to detect if there's an elevated24

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radiation level. So we did that on all of1

the properties. And then if we found an2

elevated radiation level we would go back3

and take a radiological sample and send it4

to the laboratory to confirm that it was5

indeed due to thorium or radium.6

On the industrial sites, given the7

industrial nature of the property, we also8

checked for chemical contaminants. One of9

the focuses of our RI/FS report that we're10

putting together is to come up with a cost11

of how much it would cost to clean this12

up. So we need a volume. So if there was13

contamination, we had to know how deep the14

contamination was. So we put in shallow or15

deep borings, depending where we were. If16

you notice, there’s not a deep check mark17

on the soil borings for the vicinity18

properties. That’s only because, in19

general, the contamination was really on20

the surface of the property. As Alan was21

telling you, radon gas can get in a home so22

we check for radon in any structure that23

might have been on a property. And we also24

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did alpha/beta measurements for structural1

material sampling. Because in some cases,2

especially on the industrial properties,3

the contamination wasn't always associated4

with soil but the building material5

itself.6

Let me work you through this so you7

can kind of understand the process. This8

is an old picture of the Welsbach facility9

which existed about, you know, the early10

part of the century. Just to give you some11

bearings here because I know it's not a12

good picture. The Delaware River is on13

top. You can see the smoke stack of that14

facility. Kings Street is on the bottom.15

This is Gloucester City. But if you can16

imagine, they made these gas mantles at the17

beginning of the century. The hazards18

associated with any materials having19

radioactivity associated with it really20

weren't known at that time. Things like21

X-rays were just being discovered and22

nuclear power -- things like that were23

decades in the future yet to come.24

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But as years went by and in the past1

couple of decades, we became aware of the2

hazards that could be associated with any3

radioactive materials. And someone4

prudently said we should go back to all of5

these facilities that operated in the early6

part of the century and check to see if7

there were, indeed, some radioactive8

materials associated with those9

properties.10

So if you could imagine, you had a11

facility like this (indicating) and you had12

this mound, basically, of sandy-like dirt13

that was there and they processed the14

is thorium out of that sand. So what happened15

is years later we go back to that property16

to see if we can find anything. of course,17

the facility is gone by now. But the18

circle showing where the facility used to19

be, it's actually a large 52-acre sprawl at20

this cargo area.21

But if you could imagine, let's say,22

if you had these large buildings, they23

probably had large basements associated24

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with them. And they knocked down the1

building, you would assume, and maybe put2

them in those large basements and paved3

over it. So the first thing we would do is4

go over this entire property doing the5

surface exposure rate we talked about to6

look for elevated levels of gamma7

a radiation. And we did that over the course8

of several weeks. And then we take that9

information back with us to our office and10

we have computer programs where we can look11

at the data.12

And we go back now, this is a bird's13

eye view looking down at the facility, and14

is all the different colors are where we do15

have elevated levels of radiation. So16

clearly there was something and is17

something on that property. We go back to18

locations like this and take soil samples19

to see that it is thorium causing the20

elevated levels, and it is. And we do the21

borings to see how deep it is to come up22

with a volume. So that’s really what goes23

on at the Welsbach facility.24

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To jump a little closer to home here1

in Camden, to tell you a little bit about2

what we've done. This is the General Gas3

Mantle facility. And as Rick told you,4

it's boarded up now. And as Alan alluded5

to, this material gives off radon gas. But6

there's no ventilation in this building7

because the windows are all boarded up. So8

when we go in there to work in that9

building, there are elevated levels of10

radon levels. There is soil that is11

contaminated under the building and12

adjacent to the building. And it does come13

out somewhat onto South Fourth Street,14

along with the sidewalk and into the street15

somewhat.16

So that will eventually need to be17

removed or remedied as Rick will talk18

about. The building is vacant. There are19

wood floors. Those woods floors as well20

have some contamination associated with21

it. So if this building were to be22

demolished there may be a need to remove23

those floors before any demolition takes24

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place.1

I just wanted to touch on this now2

but Alan will come back and talk a little3

bit more about risk. But when we do work4

on properties like this, it's not like5

we're all dressed up in special equipment.6

We wear our regular work clothes and we7

walk throughout the building with the8

meters. A real hazard that's associated9

with it, from our standpoint, is if we have10

somebody fall through a floor while we're11

in the building rather than the radiation12

problem itself. But Alan will talk a13

little bit more about risk.14

We'll talk about the vicinity15

properties now. One of the problems is16

there is such a large geographical area17

associated with this site where18

contamination could end up. If we were to19

have gone throughout the whole community20

and start from scratch, it would have taken21

us years to do this. But fortunately the22

State and Fred's group, they were here23

previously and they went through over a24

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thousand properties and investigated those1

properties.2

Now, when we started this project we3

didn't want to go out and reinvestigate all4

of these properties. We wanted to use the5

State's data. But we had to be sure we6

could use that data. So we went to 207

properties and we compared our data to the8

State's data. And we agreed that we can9

use the State's data to somewhat categorize10

these properties.11

We went through all of the State's12

data and we categorized the properties13

something like this. Ballpark thousand14

properties that the State went to,15

approximately half, 449, we don’t see any16

evidence that there’s contamination17

associated with those properties. Then we18

have the category we call suspect19

properties. It's a pretty large grey area20

for us. What that category means is that21

we’re not 100 percent sure that they're22

clean. We're not 100 percent sure that23

they may be contaminated either. But we do24

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want to go back and test those properties.1

If a property was simply adjacent to2

contaminated property, we call that a3

suspect property and we put it in this4

category. If it had an elevated radon5

level -- many homes in New Jersey have6

elevated radon. But in this case we tend7

to ask ourselves, is that due to normal8

radiation associated with the soil or is it9

due to the Welsbach facility. We're not10

sure right now so we want to go back and11

check.12

There's radiation all over. It's a13

natural thing and it ranges. There's an14

average. It's high in locations and low in15

others. In some cases you could live in a16

brick home and the levels could be higher17

than you normally expect. But we would put18

it in this category. So there are S8519

properties that we would want to go back to20

now and kind of do additional testing21

eventually and either move them over to the22

clean category or if we needed to move them23

to the contaminated properties category.24

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And then finally there's a category1

where we have potentially contaminated --2

they are properties that, based on the data3

we have available, the evidence suggests4

that there is contamination on those5

properties. And we used our investigation6

from the 20 we went to to come up with a7

volume of materials to estimate a cleanup8

cost associated with the project. And Rick9

will come back and talk a little bit more10

about that in a couple of minutes, right11

after Alan talks a little bit more about12

health risks.13

MR. FELLMAN: Before you can really14

get a handle on the risk from exposure to15

radiation, it's helpful, I think, to16

understand that we live on a radioactive17

planet. And as a result we're constantly18

being exposed to natural sources of19

background radiation. The items that are20

listed on this table break down the21

components of background radiation.22

We are radiated from the atmosphere.23

we receive radiation from natural levels of24

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radionuclide in soil and rock, many of the1

same radionuclide that we have in the waste2

stream at the Welsbach and General Gas3

Mantle facilities; uranium, thorium,4

radium.5

Inhaled radioactivity, that 2006

milligrams per year, is the average dose in7

North America from radon gas. Any time you8

put four walls and a ceiling together,9

you're going to get some level of indoor10

radon that's going to deliver a dose. And11

the average radon level is about one to one12

and a half pico Curies per liter there, and13

that's going to give you your 20014

milligrams.15

Internal emitters is referring to the16

various radionuclide that we store in our17

body tissues. As a reflection of the fact18

that there's radioactivity naturally in19

soil, then when we grow fruit and20

vegetables and all sorts of products, some21

of that radioactivity is taken up and some22

of it is ingested. There's natural23

potassium which is an essential24

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micronutrient. We ingest potassium in lots1

of different products. A small fraction of2

that potassium is radioactive.3

So we carry around these4

radionuclide. We ingest them every day.5

we excrete them every day. And as a result6

of their being in our bodies, we're exposed7

to a dose of about 40 millirem per year.8

There's also a whole lot of9

radioactivity in lots of different types of10

consumer products. And as you read through11

some of these, you can see that there's12

quite a range. And I brought a couple of13

items that add to those.14

This is Morton salt substitute. if15

you need to keep your sodium intake to a16

minimum because of high blood pressure or a17

cardiac problem, your doctor may suggest18

that you use potassium chloride instead of19

sodium chloride. And as I just said, some20

potassium is radioactive. And there's no21

way to separate out the radioactive22

potassium from the nonradioactive23

potassium.24

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This instrument is known as a pancake1

detector. And as you can hear, from2

natural sources it has a very low3

efficiency, you'll get sporadic clicks.4

When I hold the salt substitute up, you get5

a slightly positive response and it's easy6

to hear the difference. Again, that's7

natural potassium in the salt substitute8

that the detector can see.9

Here is a smoke detector. Everybody10

should have these in their home. And one11

of the components of the smoke detector is12

one micro Curies of Americium 241, a13

man-made radionuclide. And when I hold14

this meter up to the source, again you can15

hear the instrument respond.16

This is a piece of Fiestawear (ph).17

It's made in the Southwest, covered with a18

glaze known as yellow cake. And that glaze19

has a lot of natural uranium in it.20

There's a lot of radioactivity here. There21

are people who eat off of these and you'll22

find these in antique shops, at antique23

shows all around the country. So I can24

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either leave that here and radiate my1

colleagues or move it back out of range a2

little bit.3

We’re concerned about radiation dose4

because radiation is a known carcinogen.5

That is the only health affect that we need6

concern ourselves with. There are no acute7

short-term health problems associated with8

exposure to radiation with the exception of9

very, very high doses which are not10

possible from environmental issues such as11

what we have here.12

So we're worried about cancer. We13

know that people who have been exposed to14

very high levels of radioactivity in those15

populations, there is most definitely an16

increase in the incidence of cancer. When17

we set public health policy in this18

country, we assume that there is a risk of19

cancer when we're exposed to any dose of a20

carcinogen, no matter how small. Now, the21

fact of the matter is, when we look at the22

scientific data, we don't really know if23

that's true or not.24

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Because what we have here is, again,1

what's known as a dose response curve or2

dose response line. As the dose increases3

-- so up here in this range (indicating)4

we're looking at high doses such as the5

Japanese who survived the atomic weapons6

blast, groups of patients who were radiated7

for various ailments in the ‘30s or ‘40s8

before medical science realized that that 9

wasn't the way to go. The radium dial10

painters who were basically ingesting11

radium while they painted watch dials12

during the 1920s. Several of them died13

from acute illnesses but most of them14

survived and went on to live 20, 30, 40, 5015

years. And in that group there was16

elevated cancers. So these are groups who17

got very high doses and we know that the18

incidence or cancer or the health effect or19

risk was elevated.20

Now we get down to the lower end of21

the curve where I showed you, just a few22

minutes ago, background radiation, that we23

all get a couple hundred millirems per24

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year. So now we're down in this area of1

the curve (indicating). And now we've got2

this type of a waste stream where there may3

be additional exposure on the magnitude4

similar to what we're getting from5

background. And what do we know about6

that?7

Well, we don't have any scientific8

data that would show that people who are9

exposed to these levels are actually going10

to suffer increased numbers of cancer. We11

don't know that. The scientific studies or12

physical tests are not powerful enough to13

discern that when we're talking about a14

disease or group of disease that is15

afflicting one out of every four Americans16

to begin with. So you just can't measure17

it at these low levels. This is what we18

call an area of great uncertainty.19

However, EPA’s policy is to assume20

that there is some risk at these low21

levels. And when the risk that we22

calculate based on the data that we23

generate during our studies, when that is24

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placed in a risk assessment model and it1

shows us a risk that's unacceptable2

relative to the acceptable risk range that3

EPA has established, EPA can then use that4

information as the basis to go forward with5

the cleanup.6

And now I'll let Rick talk about7

cleanup alternatives.8

MR. ROBINSON: For the Welsbach/9

General Gas Mantle site we evaluated10

cleanup alternatives for the three property11

types we just discussed: The Welsbach12

facility, the General Gas Mantle facility,13

and for the vicinity properties. The three14

alternatives that we looked at were the No15

Action Alternative; an Engineering Controls16

Alternative; and Excavation and Off-site17

Disposal Alternative.18

As part of the Superfund process, EPA19

has to look at a cleanup based on a No20

Action Alternative. What if we did21

nothing, what would be the result? And22

based on the risk assessment that Alan just23

explained a little bit, we found that there24

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was a risk and, therefore, we were going to1

take an action. And as a result, we're not2

going to talk about no action anymore.3

For the vicinity properties, the4

Engineering Controls Alternative, it would5

require outdoor gamma shields on 506

properties; indoor gamma shields on about7

20 properties; and radon mitigation systems8

on about 4 properties. And the excavation9

and off-site disposal alternative, if any10

property was found to have contamination11

above our cleanup levels, we would take the12

material off site for disposal, dig it up13

and take it off site.14

The Welsbach facility, again, the15

Engineering controls Alternative, we would16

put outdoor gamma shields on the property.17

We would have to have deed restrictions18

limiting future site work. And we would19

have to go back every five years to make20

sure that the remedy would still be21

effective.22

For the excavation and off-site23

disposal alternative for the Welsbach24

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facility, again, we find the contamination1

above our cleanup level so we would dig2

that material up and send it off-site for3

disposal.4

For the General Gas mantle facility,5

Engineering Controls Alternative would6

require outdoor gamma shields around the7

outside of the building. We would have to8

permanently board-shut the building. We9

would have to have deed restrictions10

limiting future access to the site. And we11

would have to go back every five years to12

make sure the remedy would still be13

effective.14

Then for the General Gas Mantle, the15

excavation and off-site disposal16

alternative, we have two operations. The17

first option is we would take the building18

down and dispose of the whole building as19

contaminated material. The second option,20

option B is we would first try to21

decontaminate the building, take the22

radioactive material out of the building.23

And that would reduce the volume of24

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materials that would have to be sent1

off-site for disposal.2

The alternatives of the engineering3

controls, again, just to summarize, we4

would have to have deed restrictions on the5

property limiting future site work. The6

State would have to be responsible for7

enforcing those restrictions. And we would8

have to go back every five years to make9

sure it would still be effective.10

For the excavation and off-site11

disposal alternative, all of the12

contamination above our cleanup standards13

would be excavated and sent off-site for14

disposal. And that would result in, again,15

the contaminated materials being removed16

from the site. Mobility of the17

contaminants would be eliminated. And18

there would be no significant institutional19

controls remaining on the properties at20

all. The properties would be safe for21

future reuse and protective of human health22

and environment.23

Just to go over the summary of the24

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costs, for the engineering controls for the1

vicinity properties would be about a little2

over $2 million. And for the excavation3

and off-site disposal on the vicinity4

properties, just over $13 million dollars.5

For the former Welsbach facility, the6

engineering controls just under $6 million7

dollars. And for the excavation and8

off-site disposal alternative, eighteen and9

a half million dollars.10

For the General Gas Mantle facility,11

the engineering controls is just under12

$400,000. And the excavation and just the13

demolition and disposal alternative option,14

just over $2 million dollars. And for the 15

decontamination and demolition, just under16

$2 million dollars.17

EPA's preferred remedy action is the 18

excavation and off-site disposal19

alternative for both the vicinity20

properties, Welsbach and General Gas Mantle21

facility. For the General Gas Mantle we22

have Option B, which is the decontamination23

of the building prior to demolition. The24

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total cost of the remedy is just under $341

million dollars.2

Now we go to what do we next, the3

next steps. The first thing that we’re4

doing right now is respond to public5

comment. We're here today to take your6

verbal comments. And also, again we have a7

public comment period for written comments8

which ends next Wednesday, March 3. And we9

invite the public to send in written10

comments as well as your comments today.11

Once we receive all of the comments,12

we select a remedy in a document called a13

Record of Decision (ROD). And once we sign14

that ROD, EPA can start the design of the15

cleanup.16

Our focus will be first on the17

residential properties and then we'll go to18

the commercial and industrial properties.19

We hope to start the investigations on the20

suspect properties in the fall, later this21

year, and also start the design22

investigations on the potentially23

contaminated properties this year also.24

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And we also plan to demolish the General1

Gas Mantle building as soon as we can,2

hopefully in one to two years.3

This actual cleanup on these4

individual properties we estimate about5

three to five years from today. We're also6

in the process right now of conducting a7

ground water investigation to make sure8

that none of the contamination from the9

site is getting into the ground water. And10

we also have to investigate some wetland11

areas in Gloucester City around Newton12

Creek that are next to some of the known13

contaminated areas.14

15

16

17

18

19

20

21

22

23

24

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MR. ROBINSON: Now we'd like to open1

the meeting up for some comments and2

questions.3

MS. CERVANTES-GROSS: If you have any4

questions about what we discussed tonight.5

MR. ROBINSON: Please state your name6

for the record.7

DONNA MAGGIO(PH) (INAUDIBLE): I have8

a question with the houses on Arlington9

Street. When you say you're going to10

excavate the back yard, how deep is it11

going to go and what's going to be done for12

the people while you're doing this? Will13

this pose any problems for people? What14

is are you going to do to protect them?15

MR. ROBINSON: Right now on Arlington16

Street we have not done any volume samples17

is or estimate of the depth of contamination18

on Arlington Street. That will be done in19

the design phase. We estimate right now,20

by what we've seen on other properties that21

are similar to contamination there, the22

contamination is about one to two feet.23

Generally we try to work around the24

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residents and make sure that they're not1

severely impacted by the work.2

DONNA MAGGIO: This doesn't pose any3

sort of a problem, digging up?4

MR. ROBINSON: We're going to try to5

minimize any potential impacts through6

controls during our construction phase.7

MR. FELLMAN: The impacts are8

(INAUDIBLE). They are not health related.9

DONNA MAGGIO: That's what I'm10

wandering.11

MR. FELLMAN: When these things are12

removed, it's done in a controlled way so13

that dust is minimized. If necessary, soil14

is wet before taking it off. Before things15

are sent out, say, in a truck to travel16

over public roads, the trucks are scanned17

and the wheels. This is all done in a very18

prescribed manner so that contamination is19

not spread.20

DONNA MAGGIO: Is there a work plan,21

a document, yet?22

MR. ROBINSON: When we go to23

construction, after we've completed the24

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remedial design, we'll have another meeting1

prior to the actual demolition or the2

construction activities. We'll present to3

you our plan on how we're going to proceed4

with that phase, the action.5

MR. EVANGELISTA: We'll intend to6

make these plans available in repositories7

for review.8

DONNA MAGGIO: I have a question as9

far as the radon in the basements. Are you10

going to check for radon in the basements?11

MR. FELLMAN: Well, that's part of12

the study protocol when we go to any of the13

suspect properties. The properties that14

we've been to through the remedial15

investigation, we scan for gamma radiation16

indoors and outdoors. We take soil17

samples, put holes in the ground and take18

down hole measures, and put radon detectors19

in the basements and measure for radon.20

That's typically part of the protocol.21

The reason why there have been so few22

properties or structures with elevated23

radon out of the many properties24

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investigated here is because most of the1

contamination, where it exists, is out in2

the yard somewhere as opposed to being3

adjacent to or underneath the house. If4

you have -- like on Arlington Street where5

that kind of strip of contamination is6

toward the rear of the property, closer to7

the alleyway, the radon gas that was formed8

in that material is emanating up into the9

outdoor atmosphere as opposed to if that10

material was underneath the homes emanating11

up and would be intercepted by a house and12

get into the basement. That's when you get13

the higher level or volume of this stuff.14

MS. PULLMAN(ph): My name is Olga Pullman.15

I'd like to first of all say, great, EPA16

has selected the most thorough cleanup17

alternative of the three products. I think18

that's very important for the health and19

safety of the residents and also the future20

of this neighborhood.21

I was just wondering, to make it22

clear in my own mind what you're saying,23

the level of cleanup is going to be to24

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remove anything contaminated and bring in1

fresh fill for any empty areas? And it's2

your position that after that, that land3

could be used for anything, residential,4

playgrounds, parks, vegetable gardens, that5

level of cleanup?6

MR. ROBINSON: Yes.7

MS. PULLMAN: Is that definite? The8

money has been approved for that project?9

MR. ROBINSON: Before we can actually10

get any money for a cleanup we have to go11

through a design. Once we get the design12

altogether, we'll be going out to request13

money from EPA headquarters for the14

project. Until we complete the -- we're15

still three to five years away from that.16

As you see from our presentation, there's a17

lot of things we have to look at to gather18

information together.19

MR. EVANGELISTA: I just wanted to20

add that behind the scenes that's what's21

known as Record Review Board. And what we22

did before we identified our preferred23

alternative and the projected cost estimate24

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is we took the site and all of the1

information before this Board within EPA2

which consists of representation throughout3

the country. And they gave us a nod of4

approval that they're okay with the costs5

associated with it. We don't anticipate6

any problems in funding the project in the7

anticipated time frame.8

MS. PULLMAN: In terms of checking9

property, I happen to notice where the10

Arlington Street property is located, the11

General Gas mantle, you haven't yet checked12

the properties on the other side that's not13

shown on the map, kind of adjacent to it14

heading north. Is that something you're 15

going to include in this investigation?16

MR. KERBEL: That sounds like data17

the State collected, but we didn't in the18

last year go into these properties.19

MR. ROBINSON: Those maps were20

generated or based on information that the21

State provided to EPA. As part of our22

investigation and our next phase in the23

design, we're going to look at the24

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properties adjacent to known contaminated1

or potentially contaminated properties.2

And we'll look at those properties and add3

them on. In future maps they'll include4

other properties that the State has not5

(INAUDIBLE).6

DONNA MAGGIO: I just had a question7

with the time frame. So you think you8

could demolish the General Gas Mantle9

within one to three years?10

MR. ROBINSON: One to two years.11

DONNA MAGGIO: From now?12

MR. ROBINSON: Yes. we're hoping13

sooner. As soon as we get the remedy14

approved the sooner we'll start the process15

of taking the building down.16

MS. PULLMAN: What's going to be your17

next series of steps when you're going to18

inform the community about what's going19

on?20

MR. ROBINSON: Once we select the21

remedy and the Record of Decision -- and in22

the Record of Decision will be all your23

verbal responses today, that's why we have24

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the court reporter here, and any written1

comments submitted -- that will be in the2

responsiveness summary attached to the3

Record of Decision. Once we sign the4

Record of Decision we'll place that5

document in the local repositories: one in6

Camden's main library, one in Gloucester7

City's public library, and in the Hynes8

Center of Camden. The next public meeting9

we'll have is when we're ready to start the10

construction, most likely the General Gas11

Mantle demolition, hopefully later this12

year. If we could move the people along.13

MR. EVANGELISTA: "People" meaning14

EPA management.15

MS. PULLMAN: So, of course, you'd16

let us know if something were to happen.17

If you discover that the scope of work was18

greater than you thought and you had to19

reconsider your plans, at what point would20

you let the community know that, before you21

make the final Record of Decision?22

MR. EVANGELISTA: At this point we23

don't anticipate reconsidering anything as24

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far as what we've proposed in the proposed1

plan or discussed this evening. The only2

way that we would reconsider anything would3

be based on public comment. And based on4

what we've seen and heard thus far, both5

here and in Gloucester City, there's6

nothing indicative of our changing our7

minds.8

MR. ROBINSON: Everyone is in favor9

of us digging the material up and taking it10

off-site.11

MS. PULLMAN: Good.12

MS. CERVANTES-GROSS: In addition, as13

we pointed out, there are still 500-some14

properties that we consider as suspect15

properties. So in the design -- as we go16

through the design phase, there will be17

additional investigation of those18

properties, to include those properties in19

what we’re proposing. once we go out there20

to confirm if they have elevated levels21

above our cleanup levels, those properties22

would be included in -- most of the23

vicinity properties.24

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MR. FELLMAN: Fed into the design1

process that will be ongoing and current.2

MR. KERBEL: There's a lot of3

variability when we say contaminated4

properties. It could range from just a5

small spot where somebody might have to6

almost come in with a shovel and put it in7

a barrel and got it off; to maybe a backhoe8

might have to come in and scrape the top9

off. So there's a lot of variability.10

MS. PULLMAN: I just realized at this11

point you can't say exactly how many12

properties you're going to have to do13

cleanup and what level it will be. I'm14

just being paranoid here. At any point you15

could reconsider the plan if you rediscover16

it’s a greater scope of work or whatever.17

MR. ROBINSON: No. If we find18

contamination it will be taken away.19

MS. PULLMAN: All right.20

Ms. CERVANTES-GROSS: Any other21

questions or comments?22

Okay. I that’s it.23

MR. ROBINSON: Thank You very much24

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for attending and hopefully we’ll see you1

soon with the progress of taking the2

building down.3

MR. EVANGELISTA: There are some4

handouts that are on the table and you’re5

welcomed to take a copy.6

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C E R T I F I C A T E1

STATE OF NEW JERSEY2

I, LINDA A. BURNS, Shorthand Reporter and Notary3

Public of the State of New Jersey, do hereby certify4

that I reported the public hearing in the5

above-captioned matter and that the foregoing is a6

true and correct transcript of the stenographic notes7

of testimony taken by me in the above-captioned8

matter.9

I further certify that I am not an10

attorney or counsel for any of the parties, nor a11

relative or employee of any attorney or counsel12

connected with the action, nor financially interested13

in the action.14

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Dated: March 4, 199824

RECORD OF DECISION FACT SHEET

EPA REGION II

Site:

Site name: Welsbach/General Gas Mantle Contamination, Inc. Site

Site location: Gloucester City & Camden, Camden County, New Jersey

Listed on the NPL: June 16, 1996

Record of Decision:

Date signed: July 23, 1999

Selected remedy:

Alternative (V-3) - Excavation and off-site disposal of contaminated soil.

Alternative (W-3) - Excavation and off-site disposal of contaminated soil.

Alternative (G-3) - Decontamination and Demolition of the General Gas

Mantle Building

Operable Unit: OU-1

Capital cost: $33,892,120

Anticipated Construction Completion: September 2004

O & M cost: $0

Present-worth cost: $33,892,120

Lead:

Site is currently fund lead - EPA is the lead agency

Primary Contact: Rick Robinson, Remedial Project Manager, (212) 637-4371

Secondary Contact: Pat Evangelista, Chief, New Jersey Projects/State Coordination Team,

(212) 637-4403

Waste:

Waste type: thorium, radium, uranium

Waste origin: gas mantle manufacturing, extracting thorium from ore

Contaminated medium: Soil and building materials