Welsbach/General Gas Mantle Contamination Superfimd … · Welsbach/General Gas Mantle...

RECORD OF DECISION

Welsbach/General Gas Mantle Contamination Superfimd Site

Gloucester City & Camden, Camden County, New Jersey

United States Environmental Protection AgencyRegion II

New York, New YorkJuly 1999

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Welsbach/General Gas Mantle Contamination Superfiind SiteGloucester City & Camden, Camden County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) documents the U.S. Environmental Protection Agency'sselection of a remedial action to address soil and building material contamination at theWelsbach/General Gas Mantle Contamination Site (the "Site"), in accordance with therequirements of the Comprehensive Environmental Response, Compensation and Liability Act of1980, as amended (CERCLA), 42 U.S.C. §9601-9675, and to the extent practicable, the NationalOil 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 firstoperable unit of this Site.

The New Jersey Department of Environmental Protection (NJDEP) has been consulted on theplanned remedial action in accordance with Section 121 of CERCLA. The NJDEP concurs withthe selected remedy (see Appendix IV). The information supporting this remedial action iscontained in the Administrative Record for the Site, the index of which can be found inAppendix HI of this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Welsbach/General Gas MantleContamination 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 theenvironment.

DESCRIPTION OF THE SELECTED REMEDY

The remedy described in this document represents the first of three planned remedial actions oroperable units for the Welsbach/General Gas Mantle Contamination Site. It will addressradiologically-contaminated soil and building materials at the former Welsbach and General GasMantle facilities and properties in the vicinity of these facilities. For the second operable unit atthe site, the current owner of the former Welsbach facility is performing a remedial investigationand feasibility study on the last remaining Welsbach era building. A third operable unit isplanned to investigate potential site impacts to groundwater, surface water, sediments, andwetlands. The major components of the selected remedy include:

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• Excavation/removal of soil and waste materials with radiological contamination aboveremedial action objectives from the former Welsbach and General Gas Mantle Facilities;

• Excavation/removal of soil and waste materials with radiological contamination aboveremedial action objectives from the residential and commercial properties in the vicinityof 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 ofCERCLA, in that it: (1) is protective of human health and the environment; (2) complies withFederal and State requirements that are legally applicable or relevant and appropriate to theextent practicable; (3) is cost-effective, and (4) utilizes permanent solutions and alternativetreatment (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 remedydoes not satisfy the statutory preference for treatment as a principal element.

Because this remedy will not result in hazardous substances remaining on the remediatedproperties above levels that allow for unlimited use and unrestricted exposure, a five-year reviewof this action will not be required.

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

DateRegiojtfal A

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RECORD OF DECISION FACT SHEETEPA 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:

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

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, uraniumWaste origin: gas mantle manufacturing, extracting thorium from oreContaminated medium: Soil and building materials

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RECORD OF DECISION

DECISION SUMMARY

Welsbach/General Gas Mantle Contamination Site

Gloucester City & Camden, Camden County, New Jersey

United States Environmental Protection AgencyRegion 2

New York, New YorkJuly 1999

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TABLE OF CONTENTS

SITE NAME, LOCATION AND DESCRIPTION

SITE HISTORY AND ENFORCEMENT ACTIVITIES

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

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

THE NATURE OF RADIONUCLIDES

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 IAPPENDIX IIAPPENDIX IIIAPPENDIX IVAPPENDIX V

FIGURESTABLESADMINISTRATIVE RECORD INDEXSTATE LETTERRESPONSIVENESS 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. EPAinitially identified the Site in 1980 during an archive search conducted as part of the investigationof 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. Radiumfrom the Welsbach Corporation during the 1920s.

Between the 1890s and 1940s, the Welsbach Company (Welsbach) manufactured gas mantles atits facility in Gloucester City, New Jersey. Welsbach was a major manufacturer and distributerof gas mantles until gas lighting was replaced by the electric light. Welsbach extracted theradioactive element thorium from monazite ore and used it in the gas mantle manufacturingprocess. Thorium causes the mantles to glow more brightly when heated. A second gas mantlemanufacturing facility, known as the General Gas Mantle Company (GGM), was located inCamden, New Jersey. GGM operated from 1915 to approximately 1940.

In May 1981, EPA conducted an aerial radiological survey of the Camden and Gloucester Cityarea to investigate for radioactive contaminants. The survey encompassed a 20 square kilometerarea surrounding the former locations of the Welsbach and GGM facilities. Five areas withelevated gamma radiation were identified from the aerial survey; they included the locations ofthe two former gas mantle manufacturing facilities and three mainly residential areas in bothCamden and Gloucester City. In 1993, EPA reanalyzed the data from the aerial survey. Basedon this revised information, EPA identified a sixth potential radiologically-contaminated areawhich includes two vacant lots in Gloucester City.

In the early 1990s, NJDEP conducted detailed radiological investigations at more than 1,000properties located throughout the original five study areas. Radiological contamination wasidentified at the two former gas mantle facilities and at approximately 100 properties located nearthe 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, NewJersey (Figure 1). A brief description of each study area and its current land use is presentedbelow:

• Study Area One: includes the former GGM Facility and residential and commercialproperties which surround the facility (Figure 2.) The former GGM Facility is located ina 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 nearbyresidential/commercial properties. The former Welsbach Company is situated in anindustrial zoned section of Gloucester City with residential properties to the immediateeast (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 twomunicipal parks near Temple Avenue and the South Branch of Newton Creek inGloucester 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 discus -ed in the paragraphs below.

The United Gas Improvement Company, which formed Welsbach, purchased the patent rights tomanufacture 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 99percent thorium nitrate and 1 percent cerium nitrate as a "lighting fluid" in distilled water. Afabric sock was then dipped into the thorium solution to create the gas manue. Thorium causedthe 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. Monazitesand 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 acidsolution. 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 andselling the radium-228 for use in luminescent paint. For a number of years, Welsbach was thelargest manufacturer of gas mantles in the world, making up to 250,000 mantles per day at itspeak.

Welsbach also made gas room heaters, gas storage water heaters, gas and electrical fixtures,electrical refrigerators, plumbing supplies and lacquers. Manufacturing operations at theWelsbach facility began as early as 1882 and lasted until the 1940s. The facility propertycovered 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 RandallCorporation in 1948. Randall leased the property to the Radio Corporation of America, VictorDivision. A series of intervening owners followed. In May .1976, the property was purchased byHolt Hauling and Warehousing, Inc. (Holt), the current owner of the property. Holt operates acargo and overseas shipping business. None of the owners of the property after Welsbach dealtwith radioactive materials.

Only one Welsbach era-building, the Armstrong Building, is still present on the property. Thereis no information available on when the other Welsbach-era buildings were demolished. Theremedy for the Armstrong Building is not part of this decision.

The former gas mantle manufacturing facility in Camden was owned and operated by the GGMCompany 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. InJanuary 1978, the southern portion of the property was purchased by the Dynamic BlendingCompany. In October 1988, the northern portion of the property was purchased by Ste-LarTextiles. In 1992, NJDEP removed radiologically-contaminated fabrics, relocated Ste-Lar, andsealed 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 inthe vicinity of the facilities. It is also reported that building debris from the former WelsbachFacility may have been disposed of as fill in the area, ri addition, workers from the formerWelsbach and GGM Facilities may have brought contamination home with them. Theseproperties associated with radiological waste from the Welsbach and GGM Facilities arecollectively termed Vicinity Properties.

In 1991, NJDEP initiated a radiological investigation at more than 1,000 properties locatedthroughout Study Areas 1 through 5. At properties where NJDEP determined that exposurelevels were unacceptable (or posed an immediate health risk), it performed interim remedialmeasures. These measures included the installation of radon/thoron ventilation systems andplacement of concrete or lead sheeting to shield gamma radiation. In addition, NJDEP restrictedaccess to outdoor areas which exceeded its action levels.

In 1998, EPA identified a 100 square foot area in a Gloucester City Park, located in StudyArea 5, that had elevated levels of gamma radiation at the surface. In December 1998, EPAperformed a removal action to reduce exposure to these elevated levels. EPA excavated the topthree 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,and EPA has been unable to identify any successor companies. In September 1997, EPA enteredinto an Administrative Order on Consent (AOC) with Holt, the current owner of the formerWelsbach Facility. Under the terms of the AOC, Holt agreed to perform a RemedialInvestigation and Feasibility Study (RI/FS) on the Armstrong Building. Holt has also submittedinformation to support its position that it is not liable for response costs at the former Welsbachfacility. EPA is currently 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 onFebruary 1, 1999, the Courier-Post on February 2,1999, and the Gloucester City News onFebruary 4, 1999. The public comment period which related to these documents was held fromFebruary 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 activities at theSite and receive comments on the Proposed Plan, and to respond to questions from area residentsand other interested parties. Meetings were held on February 23,1999, at the Pine Grove FireStation #2 in Gloucester City, and on February 24,1999, at the Camden County MunicipalUtilities Authorities Auditorium in Camden. Responses to the comments received at the publicmeeting are included in the Responsiveness Summary (see Appendix V). The City of GloucesterCity submitted 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-cr ntaminated soil and building materials atthe Vicinity Properties and the former Welsbach anc JGM 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 thissecond operable unit will be selected in a future ROD. A third operable unit is planned toinvestigate 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 elementthrough natural processes. Radionuclides are present in trace amounts in all rocks and soils, andconsist primarily of elements of the uranium-238 and thorium-232 decay series. There areapproximately 1,700 different unstable atomic species or radionuclides. These include bothnaturally occurring and man-made radionuclides.

The radionuclides of concern in the wastes which originated at the former Welsbach and GGMFacilities are members of the uranium and thorium decay series. There are 14 uniqueradionuclides in the uranium decay series and 11 unique radionuclides in the thorium decayseries which precede the formation of stable lead (Pb-206 or Pb-208). Alpha, beta, and gammaradiation are emitted from the various members of the two decay series. The primary nuclides ofconcern 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 numberof atoms of a radionuclide will decay.

• The mode of decay refers to the type(s) of particles or electromagnetic rays emitted fromthe radionuclide as it decays. These types include alpha and beta particles, and gammarays.

• The amount of energy carried away from the atom by the particles or rays is radionuclidespecific. It is the transfer of this energy to living tissue which may cause biologicaleffects.

When radionuclides decay, they emit energy in the form of radiation. The decaying radionuclideis often called the "parent11, and the radionuclide produced is called the "decay product". Aquantity 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 convenientunit 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 arediscussed below.

Radium-226 is a naturally occurring, radioactive, metallic element formed from the decay ofuranium. 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 radioactivedecay products, While radon gas in the outdoor air dissipates quickly, the concentration of radondecay products in tnt indoor air can build up over time. Exposure to the energy released by thesevarious decaying atoms can result in adverse health effects. For radon decay products, a specialunit called Working Level (WL) has been developed. Working Level is defined as anycombination of short-lived radon decay products in 1 liter of air that will result in the ultimateemission of l.SxlO5 Mega-electron Volts of potential alpha energy. This value is approximatelyequal to the alpha energy released from the decay of progeny in equilibrium with 100 pCi ofRadon-222.

Thorium-232 is also a naturally occurring radionuclide and is the initial radionuciide of thethorium decay series. Its decay products include Radium-228 and Radon-220. Radon-220 isalso known as thoron. Thoron and its decay products have extremely shm half-lives that usuallyprevent them from concentrating to any appreciable extent in indoor air. However, if asignificant source of thoron exists within, beneath, or adjacent to a structure (such as the thoriumand Radium-228 found in Welsbach/GGM site wastes;, thoron decay products can reachconcentrations which create health risks.

SUMMARY OF SITE CHARACTERISTICS

In September 1997, EPA started an RI to characterize the nature and extent of contamination atthe Welsbach Facility, GGM Facility, and 20 of the radiologically-contaminated propertiesidentified by NJDEP in the vicinity of Welsbach and GGM. The work was conducted byMalcolm Pimie, 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 andGGM Facilities to define the extent of contamination. EPA also performed a radiologicalinvestigation 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 theNJDEP data and expedite the development of cleanup alternatives. Based on evaluation of theNJDEP data, EPA segregated the properties investigated by NJDEP into the following threecategories. 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 uR/h, radon progeny

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measurements less than 0.02 WL, and radon gas levels less than 4.0 pCi/1. 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 uR/h, radonprogeny greater than 0.02 WL, radon gas levels greater than 4.0 pCi/1, 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 RIand the Suspect Properties during the remedial design phase of this cleanup. EPA estimates thatit will study about 600 properties during the design phase to determine exactly which propertiesrequire cleanup. This additional work may include sampling for chemical analysis, wheredeemed appropriate when considering past ownership and historic information. Table 3summarizes the volume of contaminated soil and debris at the Contaminated Properties. Fieldactivities conducted as part of the RI included the following:

Radon measurementsRadon decay product Working Level measurementsGamma radiation surface and one-meter height exposure rate surveysSurface and subsurface soil samplingDownhole gamma radiation loggingTotal surface beta surveys and removable surface alpha and beta samplingStructural materials sampling for radionuclides (in some buildings)Chemical sampling for metals, volatile organic compounds, and semi-volatile organiccompounds 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 hi the area of what is believed to be thelocation of a former Welsbach building that was demolished in the 1970s. This area is currentlyused for storage. However, there are smaller areas of contamination scattered throughout theproperty. The soil in these areas is contaminated with elevated concentrations of the thoriumand uranium decay series radionuclides. These radionuclides are principal threat wastes.Subsurface contamination on the Welsbach facility averages about 11 feet in depth. Anestimated 27,200 cubic yards of soil/buried debris have thorium and/or radium concentrationsexceeding 5 pCi/g. Radium and thorium concentrations in soil ranged from background (about 1pCi/g for each) to as 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 [uR/h]) to 780 uR/h. The highest readings were associated with a ,arge fillarea 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. Thesecontaminants may be indicative of "Historic Fill". If this is confirmed during the remedialdesign and these contaminants are not comingled with the radiological contaminants or 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 insoils on the former GGM property. Contamination was generally limited to the top six to eightfeet, although contamination in some areas of South Fourth Street and the GGM Cc urrvardranged from 12 to 16 feet in depth. An estimated 900 cubic yards of soil have thorium and/orradium concentrations which exceeded 5 pCi/g. Radium and thorium concentrations in soilranged 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 uR/h) to 380 uR/h. Only localized areas of surface contamination were identifiedoutdoors. 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 theproperty. The contamination also extended onto some backyards of neighboring residentialproperties.

Elevated levels of surface contamination were observed in many areas inside the former GGMbuilding. Levels as high as 2.33 microCi per square meter(uCi/m2) were observed. Indoorgamma exposure rates ranged from background to 900 uR/h. An estimated 1,460 cubic yards ofcontaminated structural materials in the building itself were identified, with thoriumconcentrations as high as 750 pCi/g. In the basement of the former GGM building, radon decayproduct concentrations measured 1.7 WL, compared to an average background level of0.005 WL.

Certain semi-volatile organic compounds and metals were identified in the outdoor portions ofthe 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 remedialdesign 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 aspart of the RI. EPA compared the data from these properties to information collected fromearlier NJDEP investigations on over 1000 properties and determined that the data werecomparable. Contaminated soil averaged about two to three feet in depth on most residentialproperties. On a few properties, contamination extended to 10 feet in depth. Some siteproperties have indoor radon gas concentrations or soil radionuclide concentrations which pose along-term risk to human health.

Based on the comparison of EPA and NJDEP data, EPA identified a total of 54 properties ashaving contamination above the cleanup levels. During the remedial design phase, EPA willdelineate the extent of contamination on each of these properties in order to design a cleanupplan for each property.

During the remedial design, EPA will also investigate approximately 600 additional propertiesthat are either adjacent to the known contaminated properties or have gamma exposure ratesslightly above background levels. If contamination above the cleanup objectives is found on anyof these Suspect Properties, EPA will delineate the extent of this contamination and design acleanup plan for those properties.

Based on its review of the NJDEP data, EPA determined that 449 out of the approximately 1000properties NJDEP investigated showed no evidence of contamination. These properties hadsurface gamma exposure rates less than the upper range of natural background, radon progenyless than 0.02 WL, and radon gas levels below 4.0 pCi/1.

Current and Future Land Use

The site properties and the surrounding areas consist of industrial, commercial, and residentialzoning districts. Study Area 1 is located in an industrial-zoned section of Camden withresidential properties east of the former GGM Facility. In Study Area 2, the former WelsbachFacility is situated in an industrial-zoned section of Gloucester City with residential properties tothe immediate east. Study Area 3 consists of residential properties, a private swim club, and aland preserve. Study Area 4 consists entirely of residential properties. Residential properties andtwo municipal parks comprise Study Area 5. Study Area 6 consists of vacant land in a residentialarea.

No significant changes in land use are anticipated, except in the area of GGM where there is apossibility that some residential areas may be rezoned for commercial uses. The former GGMfacility is bordered by residential homes located on Arlington Street in Camden. Most of thehomes on Arlington Street are abandoned and there is debate within the community, given theindustrial nature of the area, whether to rezone this area to allow for commercial development orleave 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 baselinerisk assessment estimates the human health risk which could result from the contamination at asite if no 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 specieswith the cleanup criteria. Based on this comparison, EPA determined that the cleanup criteriawill be protective of ecological receptors for this operable unit. An Ecological Risk Assessmentwill be conducted in a future RI to evaluate the potential for adverse effects to aquatic andterrestrial wildlife 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: ur-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 thorium decay series (e.g., radium, thorium, radon, and radon decay products) areknown human 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 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 :: r radionuclides o oncera at the Vicinity Properties.Building materials and/or soil were me environmental nj?dia of concern. Following EPAguidance, risks were estimated based on a "reasonable maximum exposure" scenario. Risks were

10

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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, riskestimates were evaluated for current and future workers, other site workers (part-time workers),and construction workers. For the former GGM Facility, risk estimates were evaluated forcurrent and future trespassers, and future construction workers, adult residents, child residents,and workers. At the Vicinity Properties, risk estimates were evaluated for adult and childresidents of the 14 residential properties investigated, and appropriate populations at theremaining six Vicinity Properties (Jogging Track, Swim Club, Martins Lake, Public Park, LandPreserve, and the Popcorn Factory.) These risks were then compared to the risk from naturalbackground sources of 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 5.7x 10'2 at the former Welsbach Facility (to the current and future site worker), 1.8 x 10'' at theformer GGM Facility (to a hypothetical future site worker), and 1.8 x 10'2 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 chemicalsof concern in soil at the former Welsbach Facility from ingestion, dermal contact, and inhalationis equal to EPA's acceptable level of 1.0 (5 ce 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 ofplants and animals are not likely to inhabit these portions of the Site. However, sensitive speciesmay be present in Study Areas 3 and 5 around Newton Creek and associated areas of theDelaware River. An ecological risk characterization will be conducted in conjunction with thethird operable unit RI to assess potential impacts to ground water, surface water, and sedimentfrom the Site.

Uncertainties

The procedures and estimates used to assess risks, as in all such assessments, are subject to awide variety 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• lexicological data

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Uncertainty in environmental sampling arises in part from the potentially uneven distribution ofchemicals in the media sampled. Consequently, there is significant uncertainty as to the actuallevels present. Environmental chemistry analysis error can stem from several sources includingthe errors inherent in the analytical methods and characteristics of the matrix being sampled. Inaddition, there is uncertainty inherent in the measurement of radioactivity.

Uncertainties in the exposure assessment are related to estimates of how often an individualwould actually come in contact with the radionuclides of concern, the period of time over whichsuch exposure would occur, and the models used to estimate the concentrations of thecontaminants of concern at the point of exposure.

Uncertainties in toxicological data occur in extrapolating both from animals to humans and fromhigh to low doses of exposure, as well as from the difficulties in assessing the toxicity of amixture of contaminants. These uncertainties are addressed by making conservative assumptionsconcerning risk and exposure parameters throughout the assessment. As a result, the RiskAssessment provides upper-bound estimates of the risks to populations that may be exposed toradionuclides, and is highly unlikely to underestimate actual risks related exposure.

More specific information concerning public health risks, including a quantitative evaluation ofthe degree of risk associated with various exposure pathways, is presented in the Risk AssessmentReport.

Actual or threatened releases of hazardous substances from this Site, if not addressed byimplementing the response action selected in this ROD, may present an imminent and substantialendangerment to public health, welfare, or the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. Theseobjectives are based on available information and standards such as applicable or relevant andappropriate 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 measuresthat will prevent or mitigate further release of radioactive contaminated materials to thesurrounding environment and to eliminate or minimize the risk to human health and theenvironment. The sources of radiation include both contaminated soil and structural materials.Direct radiation, inhalation, ingestion of plants and soil are potential pathways. The followingobjectives 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 gammaradiation in order to achieve the level of protection required by the NCP (10~* to 10* riskrange).

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

• Prevent exposure to indoor concentrations of radon gas and radon decay produc: _ ~*aterthan 4 pCi/1 and 0.02 WL1, respectively.

• Prevent direct contact with building surfaces exhibiting total surface thoriumcontamination exceeding 0.026 uCi/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 :he5 pCi/g radium soil cleanup standard is determined to be relevant and appropriate at a CZRCLAsite which contains both radium and thorium in the waste, the pCi/g cleanup standard alsoapplies 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 ALARAprinciples used at other radiologically-contaminated sites in New Jersey. Applying ALARA

1 Exposure to 4 pCi/1 of air for radon corresponds to an approximate annual average exposure of0.02 WL for radon decay products, when assuming residential land use.2 References for ALARA principles -"Radiation Protection G_ dance to Federal Agencies forOccupational Exposure", 1987, Federal Register 5~. No.17, 26... and "Federal Guidance ReportNo. 11", September 1988, EPA-520U-88-020.

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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 detect radionuclides.

EPA's experience at the other radiologically-contaminated sites in New Jersey has shown that theremedial action objectives noted above can be achieved by incorporating ALARA principles.Applying the 5 pCi/g cleanup standard with ALARA principles at these other New Jersey siteshas resulted in exposure levels that are lower than the levels that would result from using the5 pCi/g standard alone. Therefore, by using similar remedial action objectives, theWelsbach/GGM site would pose no unacceptable risk for residential uses after cleanup, and wouldresult 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 of theALARA principles in removing the radiologically-contaminated soils and covering the excavatedareas with clean fill.

The selected remedy will meet the remedial action objectives through the excavation and off-sitedisposal of the radiologically-contaminated soils and waste materials. Excavation of soils willeliminate the threat of physical migration of contaminants, as well as potential exposure throughvarious pathways (ingestion, inhalation, dermal contact, external gamma radiation, etc.).Contaminated soils will be shipped off-site to a licensed commercial facility for permanent long-term management. For buildings, specifically at GGM, the selected remedy, decontamination,demolition, and off-site disposal of contaminated materials, will reduce exposures to acceptablelevels for future use of the property.

Any potential ecological risks and adverse impacts from existing radiological contamination onthe properties addressed under this action will be minimized because the contaminated soils willbe removed and backfilled with clean soil. There are also limited habitats for ecological receptorsat 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 ofexposure.

Wetlands are not present at either the former Welsbach or GGM facilities. However, wetlands arepresent 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 orremedial activities.

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DESCRIPTION OF REMEDIAL ALTERNATIVES

Section 121(b)(l) of CERCLA, 42 U.S.C. §9621(bXl), mandates that a remedial action must neprotective of human health and the environment, cost-effective, and utilize permanent solutionsand alternative treatment technologies or resource recovery technologies to the maximum extentpracticable. Section 121(b)(l) also establishes a preference for remedial actions which employ, asa principal element, treatment which permanently and significantly reduces the volume, toxicity,or mobility of the hazardous substances, pollutants and contaminants at a site. Section 121(d) ofCERCLA, 42 U.S.C. §962 l(d), further specifies that a remedial action must attain a level orstandard of control of the hazardous substances, pollutants, and contaminants, which at leastattains ARARs under federal and state laws, unless a waiver can be justified pursuant to Section121(d)(4) of CERCLA, 42 U.S.C. §9621(d)(4). CERCLA also requires that if a remedial actionis selected that results in hazardous substances, pollutants, or contaminants remaining at a siteabove levels that allow for unlimited use and unrestricted exposure, EPA must review the actionno less than every five 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 evu.uated for the VicinityProperties, the former Welsbach Facility and the General Gas Mantle Facility. The alternativesinclude: No Action, Engineering Controls, and Excavation and Off-Site Disposal. Table 8summarizes the costs of each alternative.

Vicinity Properties

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

Vicinity Properties Alternative 1 (V-l) - 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 not bemaintained. Current institutional controls including fencing would not be maintained. Becausehazardous substances would remain at the Vicinity Properties above acceptable levels, five-yearreviews 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 inches oftopsoil, and vegetation (seeding or sod). The thickness of the fill material will vary from 6 inchesto 42 inches, based on the shielding requirements of each property. A total of approximately75,000 square feet of coverage would be installed.

In addition, indoor gamma shielding would be placed inside buildings exhibiting unacceptableexposure levels. The shielding would consist of concrete or steel as needed. The concrete wouldrange from 4 inches to 7 inches thick, and about 1.5 inches of steel sheeting would be placed onwall surfaces. A total of approximately 2,000 square feet of concrete and 60 square feet of steelcoverage would be installed. Finally, if any property buildings exhibit elevated radon/thoronlevels, a sub-slab ventilation radon mitigation system would be installed.

Institutional controls, such as deed restrictions, would be required to ensure the protectiveness ofthe 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. EPAwill replace these areas with clean fill. The total volume of soils requiring disposal at the VicinityProperties is estimated to be 11,000 cubic yards. The total volume of buried demolition debris atthe 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, a newconcrete floor would be constructed. Approximately 21 properties would require concrete floorremoval 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 construction ofthis alternative. During excavation, short-term provisions to p^vent dust generation and protectworkers would be required. EPA will develop a wetland mitii. . on plan if it disturbs wetlandareas 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 tfe property is present in the outdoorportion of the storage area. Most of the contamination is located in a single contiguous area, withsmaller contaminated areas scattered across the property. The Armstrong Building is not includedin the remediation alternatives. Holt is preparing an RI/FS that will address the remedialalternatives for that building.

Welsbach Alternative 1 (W-l) - 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-inch asphaltcover. 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 ofthe 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 isthree 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 currently buriedon-site, and dispose of this material at an appropriate off-site facility. EPA will backfill theseareas with clean fill. The volume of soils above the cleanup standard is estimated to be 19,400cubic yards. The volume of buried demolition debris requiring disposal is estimated to be 4,400cubic yards. During excavation, short-term provisions to prevent dust generation and protectworkers would be required.

Subsurface contamination on the Welsbach Facility averages about 11 feet in depth. In the area ofthe deepest contamination, underground tunnels dating from around the turn of the century arepresent. These tunnels extend down to about 10 to 12 feet in depth. These tunnels can act asconduits to carry radon gas to nearby residential properties. As a result, the remedy includesexcavation of the contamination to the tunnel depths to prevent any future radon migrationproblems and to protect future workers from elevated gamma radiation levels. The estimated timeto 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 been boardedshut and fenced in by NJDEP. Radiological contamination on the property exists both inside andoutside the building. Inside the building, contamination is present in building materials and inambient air. Outside the GGM Facility, soil contamination is primarily located to the immediatesouthwest of the GGM building extending into South Fourth Street. Two smaller areas ofcontaminated soils are situated to the northeast of the building and in the alleyway adjacent to theeastern side of the building.

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

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

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

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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 ((• 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. Thesoil shield would include a geotextile liner, fill material, 6 inches of tonsoil, and vegetation(seeding or sod). The thickness of the fill material will range from 6 • 24 inches. The thicknessof the concrete will range from 6 to 8 inches. Approximately 5,000 square feet of coverage wouldbe required. Areas of contamination extending into ôuth Fourth Street would be covered with anadditional 4 inches of asphalt.

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

General Gas Mantle Alternative 3 - Excavation and Off-Site Disposalof Soil and Building/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 5 pCi/ggreater than background and dispose of this waste in a licensed off-site facility. Contaminatedbuilding demolition debris which is currently buried on-site because of former demolitionactivities would also be excavated and disposed of off-site. EPA will backfill these areas withclean fill. The volume of soil and buried demolition debris at GGM is estimated to be 650 cubicyards 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 3 A 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 before demolition.The contaminated waste water would be disposed of at an approved off-site facility. The buildingwould then be demolished and the debris would be crushed and sent off-site for disposal. Theestimated time to design and construct the remedy is one to two years.

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 to theNCP, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consistedof an assessment of the individual alternatives against each of nine evaluation criteria and acomparative analysis focusing upon the relative performance of each alternative against thosecriteria.

The following "threshold" criteria are the most important and must be satisfied by any alternativein 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 posed througheach exposure pathway are eliminated, reduced, or controlled through treatment,engineering controls, or institutional controls.

2. Compliance with ARARs addresses whether or not a remedial alternative meets all of theapplicable or relevant and appropriate requirements of federal and state environmentalstatutes 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 alternative tomaintain reliable protection of human health and the environment over time, once cleanupgoals have been met. It also addresses the magnitude and effectiveness of the measuresthat may be required to manage the risk posed by treatment residuals and/or untreatedwastes.

4. Reduction oftoxicity, 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 and anyadverse impacts on human health and the environment that may be posed during theconstruction 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 the present-worth costs.

The following "modifying" criteria are considered fully after the formal public comment periodon 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 with thepreferred alternative.

9. Community acceptance refers to the public's general response to the alternatives describedin the Proposed Plan and the RI/FS report. Responses to public comments are addressedin the Responsiveness Summary section of this Record of Decision.

A comparative analysis of the remedial alternatives based upon the evaluation criteria noted abovefollows:

Overall Protection to Human Health and the Environment

The No Action Alternatives (W-l, V-l, G-l) would not be protective of human health and theenvironment because the Site would remain in its current contaminated condition. Therefore, theNo 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 ofgamma radiation would be shielded by soil, concrete and/or steel sheeting. The shielding wouldhave to be maintained, and institutional controls, such as deed restrictions, would be required toensure that these alternatives are protective.

For the Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3), all radiologicalcontamination above cleanup standards would be excavated and disposed of off-site in a licenseddisposal facility. Institutional controls would not be necessary. All unacceptable risks to humanhealth and the environment would be eliminated by the excavation and off-site disposal of theradiologically-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 providegrounds 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 oractivity-specific requirements or limitations related to various activities. Chemical-specificARARs are usually numerical values which establish the amount or concentration of a chemicalthat may be found in, or discharged to, the ambient environment. Location-specific requirementsare restrictions placed on the concentrations of hazardous substances or the conduct of activitiessolely because they occur in a special location.

For the Welsbach/GGM site, no requirements are applicable for the cleanup of the radiologicalcontamination. However, as discussed earlier, portions of the federal regulations governing thecleanup of uranium mill tailings from inactive uranium processing sites, at 40 CFR 192, havebeen determined to be relevant and appropriate. These provide the radon decay products standardof 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 allARARs. All contamination above the 40 CFR 192 cleanup standards would be excavated andsent off-site for disposal. The Engineering Controls Alternatives (W-2, V-2, G-2) would complywith all ARARs that limit exposure to gamma radiation and radon. However, the EngineeringControls Alternatives would not comply with 40 CFR 192, because the contaminated materialwould remain at the Site.

Lone-Term Effectiveness and Permanence

The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) are all effective andpermanent. They are considered a final remedial action. The contaminated material would beremoved 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 beuncertain. Contaminated material would remain in place, and the engineering controls would

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require deed restrictions and long-term monitoring. In addition, the engineering controls wouldhave 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 thelong-term because of the dilapidated nature of the building, even if the building were completelysealed.

Reduction of Toxicitv. Mobility, or Volume Through Treatment

No treatment technology is known today that can substantially reduce the toxicity, mobility, orvolume 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 withchemical contaminants. Therefore, none of the remedial alternatives full; satisfy this evaluationcriteria.

However, Alternative G-3 with Option B (the General Gas Mantle Decontamination andDemolition Alternative) would reduce the volume of contaminated building debris to be disposedof off-site by pressure washing the radioactive contamination off the floors and walls beforedemolition. The contaminants would be concentrated in the filtrate after pressure washing. Onlythis 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-SiteDisposal Alternatives (W-3, V-3, G-3) provide effective short-term protection, and becomeeffective as they are implemented at individual properties. The estimated time to design andconstruct 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 formerGGM Facility, the estimated time to design and construct the Engineering Control AlternativeG-2 is from two to three years, and for the Excavation and Off-Site Disposal Alternative G-3 fromone to two years.

The Engineering Control Alternatives involve less intrusive activities, and pose less of a threat toworkers and the surrounding community than the Excavation and Off-Site Disposal Alternatives.However, both the Engineering Control Alternatives and the Excavation and Off-Site DisposalAlternatives involve intrusive activities, including, in some cases, temporary relocation ofresidents.

The Excavation and Off-Site Disposal Alternatives have a greater potential adverse impact in theshort term because of the excavation of radiologically-contaminated soil. For future workers, thiscould 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 ofthis alternative. However, under Alternative V-2 (Engineering Controls for the Vicinity

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Properties), there would be some increased short-term risk to workers during the installation ofthe radon mitigation systems. This is due to the need to excavate under the foundation of homesthat require radon mitigation.

Implementabilitv

The Excavation and Off-Site Disposal Alternatives (W-3, V-3 and G-3) are readilyimplementable. Similar activities have been utilized at other radiologically-contaminated sitesaround the country. There is an available off-site disposal facility, which is accessible by bothtruck and rail. However, the continued availability of this off-site disposal facility is required forimplementation of these alternatives.

Implementation of the Engineering Controls Alternatives V-2 and G-2 may pose somedifficulties. Under Alternative V-2 (for the Vicinity Properties), there may be some difficulty ingetting the consent of all of the property owners to restrict future work on their properties. EPAwould have to reach agreement with individual property owners to file Declarations ofEnvironmental Restrictions (i.e., deed restrictions) on their properties. For Alternative G-2 (forGeneral Gas Mantle), it would be difficult to keep the building permanently sealed fromtrespassers.

Cost

Alternative V-2 includes construction costs of $900,000 to implement engineering controlmeasures at the Vicinity Properties. Annual O&M costs are estimated to be $99,000. The presentworth cost of Alternative V-2 is $1,810,000, with O&M costs assumed for 30 years. AlternativeW-2 includes construction costs of $5,686,000 to implement engineering control measures at theformer Welsbach Facility. Annual O&M costs are estimated to be $44,000. The present worthcost of Alternative W-2 is $6,182,000, with O&M costs assumed for 30 years. Alternative G-2includes construction costs of $122,000 to implement engineering controls at the General GasMantle Facility. Annual O&M costs are estimated to be $23,000. The present worth cost ofAlternative G-2 is $381,000, with O&M costs assumed for 30 years. The radionuclides inquestion have half-lives far greater than 30 years, so any of the Engineering Controls remediesmust 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 disposalfacility. Alternative W-3 includes construction costs of $18,503,560 to excavate theradiologically-contaminated soil at the former Welsbach Facility and dispose of the waste at anoff-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 debrisat 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.

25

500031

There are no O&M costs associated with the Excavation and Off-Site Disposal Alternatives (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 theWelsbach/General Gas Mantle Contamination S;ie. The community was supportive of EPA'spreferred 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 nocommunity support. The attached Responsiveness Summary addresses the comments receivedduring the public comment period.

SELECTED REMEDY

Based upon consideration of the results of the RI/FS, the requirements of CERCLA, the detailedanalysis of the alternatives, and public comments, EPA and NJDEP have determined that theExcavation and Off-Site Disposal Alternatives (V-3, W-3, and G-3 with Option B) are theappropriate remedies for the Site.

The selected remedial action will provide a final remedy and achieve the remedial actionobjectives 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 gammaradiation, 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 0.02WL, respectively;

• preventing direct contact with building surfaces exhibiting total surface thoriumcontamination exceeding 0.026uCi/m2 above background;

• preventing long-term exposure to thorium- and radium-contaminated materials withconcentrations greater than 5 pCi/g above background; and

• preventing migration of radiologically-contaminated materials that could result inexposures described above.

26

500032

Radiologically-contaminated soil found on the Vicinity Properties and the former Welsbach andGGM Facilities in excess of 5 pCi/g above background will be excavated consistent with 40 CFR192, Subparts B and E. The remedy will attain a risk level similar to risk levels associated withexposure to natural background radiation. This will be confirmed via post-excavation propertysurveys. The Multi-Agency Radiation Survey and Site Investigation Manual (MARISSM) maybe used where appropriate to conduct such property surveys. MARISSM provides a methodologyto confirm that a particular soil concentration level has been achieved after the remedial action iscompleted. An appropriate survey methodology to be used will be determined during remedialdesign.

EPA estimates that the following volumes of contaminated soil and debris will be removed fromthe 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-contaminatedmaterial at a licensed, off-site facility. Areas that have been excavated will be restored with cleanfill. No significant changes in land use are anticipated. Because all contamination above thecleanup criteria will be excavated and sent off-site for disposal, all remediated properties will beavailable for unrestricted future use.

EPA will make every effort to minimize any long-term disruption to individual residents or thecommunity. During excavation, EPA may need to temporarily relocate some residents atgovernment expense.

As previously stated, EPA will investigate approximately 600 Suspect Properties during theremedial design phase. When these properties are tested, it is likely that some will be found tocontain radiologically-contaminated material and will require remediation. The selected remedyalso includes such remediation. EPA believes that cleanup of additional contaminated propertieswill 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 sitesis 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. Thesespecify that, when complete, the selected remedial action for this site must comply withapplicable or relevant and appropriate environmental standards established under federal and stateenvironmental laws unless a statutory waiver is justified. The selected remedy also must be cost-effective and utilize permanent solutions and alternative treatment technologies or resourcerecovery technologies to the maximum extent practicable. Finally, the statute includes apreference for remedies that employ treatment that permanently and significantly reduce thevolume, toxicity, or mobility of the hazardous wastes, as their principal element. The followingsections discuss how the selected remedy meets these statutory requirements for the first operableunit of the Welsbach/GGM site.

27

500033

Protection of Human Health and the Environment

This remedy is fully protective of human health and the environment for all properties withradiological contamination above the cleanup standards. It is estimated that no radioiogically-contaminated soil above the cleanup standards will remain on the affected properties. The remedywill attain a risk level similar to risk levels associated with exposure to natural backgroundradiation. Implementation of this remedy will eliminate additional risks attributable to exposuresto indoor or outdoor gamma radiation, indoor radon gas or radon decay products, inhalationand/or ingestion of contaminated soil, and ingestion of contaminated vegetables grown incontaminated soil. This remedy will comply with the ARARs for exposure to indoor gammaradiation and the inhalation of radon gas or radon decay products, and attainment of soil cleanupstandards.

There are few short-term risks associated with the implementation of this remedy. Whereexcavation 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 hasdetermined that while these standards are not applicable, they are relevant and appropriate to thesituation at the Welsbach/GGM site. Table 9 lists and summarizes these and other standards thatmay be pertinent during the implementation of this remedial action.

When implemented, the cleanup of the affected properties within the study areas will comply withall 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 overalleffectiveness relative to its cost. The remedy provides for complete protection of public healthand 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 radionuclidespermanently from the public and the environment are preferable.

Utilization of Permanent Solutions and Alternative Treatment Technologies to the MaximumExtent Practicable

EPA and the State of New Jersey have determined that the selected remedy represents themaximum extent to which permanent solutions and currently available treatment technologies can

28

500034

be utilized in a cost-effective manner for this phase of the remedial action at theWelsbach/General Gas Mantle Contamination site. Of those alternatives that are protective ofhuman health and the environment and comply with ARARs, EPA and the State of New Jerseyhave 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 statutorypreference 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 excavationwhich permanently removes them from their current uncontrolled locations. Commercial disposalat a licensed facility with an appropriate closure plan will ensure that these radiological wastes arepermanently isolated from human and ecological receptors. The Excavation and Off-SiteDisposal Alternatives are considered implementable and will result in a remedy that is highlyeffective in the long-term. These remedies are also consistent with the remedial approach taken atall 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 gammaradiation, and ingestion and/or inhalation of radiologically-contaminated soil. In addition, thereare threats from the generation of excess concentrations of radon gas and radon decay productsindoors which migrate from the underlying soils, and are subsequently inhaled by the residents ofthose houses. Because there is no treatment available that destroys the radioactive source of thesethreats, the selected remedy does not satisfy the statutory preference for treatment as the principalelement. The remedy does reduce the exposure to all excess levels of indoor and/or outdoorgamma radiation. It also provides for complete remediation at the affected properties, therebyreducing the exposure risk from all pathways.

DOCUMENTATION OF SIGNIFICANT CHANGES

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

29

500035

APPENDIX I

FIGURES

30

500036

WELSBACH/GENERAL GAS MANTLECONTAMINATION

SITE STUDY AREAS FIGURE 1

31

500037

to

Ul

O o o OJ 00

71 Q m ^» is f i* 5 Si E°|

5 m;

n P O c 3) m K)

SOUT

H FO

UR

TH S

TREE

T

AR

LIN

GTO

N

STRE

ET

Figure 3 - Former Welsbach Facility

enoootovo

ELLJS STREET

WALT WHITMANBRIDGE

APPENDIX II

TABLES

34

500040

TABLE -1

RADIATION UNITS

Parameter

Quantity

RadionuclideConcentration inSoil or OtherSolid Material

RadionuclideConcentration inWater

Radon Gas Cone.

Radon ProgenyCone.

Exposure Rate

Dose

Dose Equivalent

Historical

Unit

' Curie

picoCurie pergram of Solid

picoCurie perliter of Water

picoCurie perliter of Air

Working Level

micro-Roentgenper hour

RadiationAbsorbed Dose

RadiationEquivalent Man

Abbrev.

Ci

pCi/g

pCi/L

pCi/L

WL

nR/h

rad

rem

International

Unit

Becquerel

Becquerel perkilogram

—

Becquerel percu. meter

...

...

Gray

Sievert

Abbrev.

Bq

Bq/kg

...

Bq/m3

—

—

Gy

Sv

35

500041

TABLE-2PROPERTY CHARACTERIZATION

WELSBACH/GGM SITE

STUDY AREA

PROPERTIES SURVEYED BY THENJDEP

PROPERTIES WITH NO EVIDENCE OFCONTAMINATION<I3 fiR/HR< 0.02 WL RADON DECAY PRODUCTS< 4.0 pCi/L RADON

SUSPECT PROPERTIES13-30 nR/hORADJACENT TO CONTAMINATEDPROPERTIES

POTENTIALLY CONTAMINATEDPROPERTIES>30 jiR/HR> 0.02 WL RADON DECAY PRODUCTS

> 4.0 pCi/L RADON

AREA 1

359

103

239

17

AREA 2

174

40

113

21

AREA 3

48

18

23

7

AREA 4

474

272

199

3

AREAS

32

16

11

5

AREA 6

NA1

0

0

1

TOTAL

1088

449

585

54

(.nooo.uK)

Note:1 • Study Area 6 was not part of the NJDEP investigation.

NA-Not Applicable

36

TABLE 3

ESTIMATED VOLUME OF CONTAMINATED MATERIALSWELSBACH/GGM SITE

FORMER WELSBACHFACILITY

FORMER GGM FACILITY

VICINITY PROPERTIES

TOTAL

SOIL(CUBIC YARDS)

22,200

885

11,010

34,100

STRUCTURAL/DEBRISMATERIALS

(CUBIC YARDS)

5,000

1,460

2,255

8,720

37

500043

TABLE 4

RADIOLOGICAL RISK ESTIMATES BASED ON REASONABLE MAXIMUM EXPOSURESAT

FORMER GAS MANTLE MANUFACTURING FACILITIES

POPULATION PATHWAY EXPOSUREMEDIUM

GROSSRISK

BACKGROUNDRISK

NETRISK

TOTALRISK

FORMER WELSBACH FACILITY

WORKER

OTHER WORKER

CONSTRUCTION WORKER

EXTERNAL

EXTERNAL

EXTERNALINGESTIONINHALATION

SOIL

SOIL

SOILSOIL

PARTICULATES

5.70e-02

1.40e-02

7.506-043.106-051.108-03

7.306-05

1.806-05

8.706-075.606-088.406-07

5.706-02

1.406-02

7.506-043.106-051.106-03

5.70e-02

l.40e-02

l.90e-03

FORMER GENERAL GAS MANTLE FACILITY

TRESPASSER

CONSTRUCTION WORKER

ADULT RESIDENT

CHILD RESIDENT

WORKER

EXTERNAL

INGESTIONINHALATION

H

EXTERNALINGESTIONINHALATION

EXTERNALINGESTION

INHALATION

EXTERNALINGESTION

•

INHALATION

EXTERNALINHALATION

SOILBUILDING MATERIALS

SOILPARTICULATES

RADON DECAY PRODUCTS

SOILSOIL

PARTICULATES

SOILSOIL

HOME GROWN PRODUCERADON DECAY PRODUCTS

SOILSOIL

HOME GROWN PRODUCERADON DECAY PRODUCTS

BUILDING MATERIALSPARTICULATES

RADON DECAY PRODUCTS

3.100-052.006-051.900-06O.OOe+002.50e-03

2.106-057.506-072.806-05

8.906-032.706-052.306-054.906-03

1.806-031.106-051.906-065.606-04

1.406-03O.OOe+001.806-01

1.306-063.406-061.406-070.006+007406-06

8.706-075.606-088.406-07

3.806-042.006-063.206-068.006-04

7.806-058.106-072.706-079.206-05

2.406-04O.OOe+005.106-04

3.006-051.706-051.80e-06O.OOe+002.506-03

2.006-056.906-072.706-05

8.506-032.506-052.006-054.106-03

1.706-031.006-051.606-064.706-04

1.206-03O.OOe+001.806-01

2.50t-OJ

4.80*05

IJOe-02

2JOC-03

1.80*41

38

500044

VICINITYPROPERTY

PUBLIC PARK

POPCORNFACTORY

PUBLIC PARK

POPCORNFACTORY

PUBLIC PARK

LANDPRESERVE

LANDPRESERVE

TABLE 5VICINITY PROPERTIES

SUMMARY OF RADIOLOGICAL RISK ESTIMATESBASED ON REASONABLE MAXIMUM EXPOSURES*

POPULATION

SITE WORKER

CONSTRUCTIONWORKER

ADULTRECREATIONALIST

RESIDENT ADULT

CHILDRECREATIONALIST

RESIDENT CHILD

TRESPASSER

PATHWAY

ExternalInhalation of ParticipatesInhalation of RadonIngestion of Soil

Total:

ExternalInhalation of ParticipatesIngestion of Soil

Total:

ExternalInhalation of ParticipatesIngestion of Soil

Total:

ExternalInhalation of RadonIngestion of Soil

Total:

ExternalInhalation of ParticulatesIngestion of Soil

Total:

ExternalInhalation of RadonIngestion of Home GrownProduceIngestion of Soil

Total:

ExternalInhalation of ParticulatesIngestion of Sol

Total:

RISK

GROSS

7.36-012.3e-021.76-033.0e-037.6e-01

3.36-041.16-051.16-063.46-04

2.26-016.96-034.5e-042.3e-01

4.7e-021.26-011.26-041.76-01

4.46-021.26-031.86-044.56-02

7.06-022.56-02

2.564)34.60-049.86-02

2.46-031.26-042.36-062.56-03

BACKGROUND

8.66-051.86-065.26-045.56-076 16-04

8.36-073.16-083.16-098.66-07

2.66-055.56-078.36-082.76-05

3.56-047.96-042.0e-061.16-03

5.16-069.4e-083.36-085.26-06

6.86-059.06-05

3.86-067.86-071.66-04

2.56-069.46-083.86-092.66-06

NET

7.3e-012.3e-021 .2e-033.0e-037.6e-01

3.36-04

1.16-051.16-06346-04

2.26-016.96-034.56-042.36-01

4.76-021.26-011.26-041.76-01

4.46-021.26-031.86-044.56-02

7.06-022.56-02

2.56-034.66-049.86-02

2.46-031.26-042.36-062.56-03

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

39 500045

TABLE 6RISK ASSESSMENT SUMMARYFORMER WELSBACH FACILITY

SccMrie Tncfiww: Fttm

Rectpot FofMlatio* Cattractioa Wortn

RtctplocAy Adult___________

Medium

Soil

cno0oi*

Exposure

Soil

Paniculate;

Chenkal

Benzo(a)AnthraceneBenzo(b)FluorantheneBenzo(a)PyreneAroclor-1248Aroclor-1254AntimonyArsenicSelenium

(Total)Benzo(a)AnthracenrBenzo(b)FluorantheneBenzo(a)PyreneAroclor-1248Aroclor-1254AntimonyArsenicSelenium

(Total)

Carcinogenic RiskIngestion

6e-08le-076e-07le-08le-08

No Tox Data7e-06

—7e-06--

:~--

Inhalation

—----------

No Tox DataNo Tox DataNo Tox Data

2e-092e-09

No Tox Datale-05

le-05

Dermal

No Tox DataNo Tox DataNo Tox Data

7e-098e-09

No Tox Datale-06-

le-06---™"

-

-

-

Total Risk Across Soil

Total Risk Across All Media and All Exposure Routes

ExposureRoutes Total

6e-08le-076e-072e-082e-08

--8e-06-

8e-06-~

2e-092e-09

le-05

le-05

2e-OS

2e-OS

Chemical

Arsenic

(Total)

(Total)

Non-Carcinogenic Hazard QuotientPrimaryTargetOrgan

Skin

•

Ingestion

le+00

le+00--—

-

-

--

Inhalation

..

---•"

-

-

--

Dermal

2e-OI

2c-OI---

;;---

Total Hazard Index Across All Media and All Rxposure Routes

Total Skin 111 =


le+00

l ( M M )

-

-

"

-

--

--

le+00

le+00

TABLE 7RISK ASSESSMENT SUMMARY

GENERAL GAS MANTLE

Sceiurio Tuncfranc: Future

Receptor PopulMm: Construction Worker

Receptor Age: Adult____________

Medium

Soil

Eiposure

Soil

Paniculate;

Chemical

Benzo(a)AnthraccneBcnzo(a)PyreneAroclor-1248SeleniumThallium

(Total)Benzo(a)AnthraceneBenzo(a)PyreneAroclor-1248SeleniumThallium

(Total)

Carcinogenic RiskIngestion

2e-092e-089e-IO

2e-08-----—-

Inhalation

~~-----

No Tox DataNo Tox Data

2e-IO

2e-IO

Dermal

No Tox DataNo Tox Data

7e-IO

7e-IO------—--

Total Risk Across Soil

Total Risk Across All Media and All Exposure Routes


2e-092e-082e-09

---

2e-08---

2e-10---

2e-10

2e-08

2e-08

Chemical

Aroclor-1248Selenium

(Total)

(Total)

Non-Carcinogenic Hazard QuotientPrimaryTargetOrgan

N/ALiver

Ingestion

2e-032e-04

2c-03-----~--

Inhalation

—-

---------

Dermal

le-03No Tox Data

le-03-~---~--

Total Hazard Index Across All Media and All Exposure Routes

Total Liver III =


3e-032e-04

3e-03------

3e-03

2e-04tnooo

TABLE 8 ^

SUMMARY OF ALTERNATIVE COSTSWELSBACH/GENERAL GAS MANTLE SITE

ALTERNATIVE

NO ACTION

ENGINEERING CONTROLS

EXCAVATION ANDOFF-SITE DISPOSAL

1

PROPERTY

WELSBACH(W-l)

VICINITY PROPERTIES (V-l)

GENERAL GAS MANTLE (G-l)

WELSBACH (W-2)

VICINITY PROPERTIES (V-2)

GENERAL GAS MANTLE (G-2)

WELSBACH (W-3)

VICINITY PROPERTIES (V-3)

GENERAL GAS MANTLEOPTION A (G-3)1

GENERAL GAS MANTLEOPTION B (G-3)2

CAPITAL

SO

SO

SO

$5,686,000

$900,000

$122,000

$18,503,560

$13,408,560

$2,309,560

$1,979,560

O&M'(30 Years)

$0

SO

$0

$496,000

S9 10.000

$259,000

$0

$0

$0

$0

TOTAL

SO

$0

SO

$6,182,000

SI, 8 10,000

$381,000

$18,503,560 ̂

$13,408,560

$2,309,560

$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

42500048

TABLE 9

SITE SPECIFIC CLEANUP STANDARDS

TYPE PERTINENTSTANDARD 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 etseq.

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(0

43500049

APPENDIX III

ADMINISTRATIVE RECORD INDEX

500050

WELSBACH fc GENERAL GAS MANTLE CONTAMINATIONADMINISTRATIVE RECORDINDEX OF DOCUMENTS

1.0 SITE IDENTIFICATION

1.2 Notification/Sit* Inspection Reports

100001-100308

100309-100551

100552-101016

101017-101428

Report: Final Hazard Ranking System Documentation.Welsbach and General Gas Mantle ContaminationSites. Camden and Gloucester Citv. New Jersey.Volume I of VIII. prepared for the EnvironmentalServices Division, U.S. EPA, Region II, preparedby 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 II, March 27, 1995.

Report: Final Hazard Ranking System Documentation.Welabaeh and General Gas Mantle ContaminationSites. Camden and Gloucester Citv. New Jersey.Volume II of VIII. prepared for the EnvironmentalServices Division, U.S. EPA, Region II, preparedby 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 II, March 27, 1995.

Report: Final Hazard Ranking System Documentation.Walsbaeh and General Gaa Mantle ContaminationSites. Camden and Gloucester Citv. New Jeraev.Volume III of VIII. prepared for the EnvironmentalServices Division, U.S. EPA, Region II, preparedby 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 II, March 27, 1995.

Report: Final Hazard Ranking System Documentation.Welabaeh and General Qaa Mantle ContaminationSites. Camden *nd Gloueeater Citv. New Jeraev.Volume IV of VIII. prepared for the EnvironmentalService* Division, U.S. EPA, Region II, prepared

1

500051

101429-101707

101708-102024

102025-102600

102601-102920

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 II, March 27, 1995.

Report: Final Hazard Ranking System Document at lerWelsbaeh and General Gas Mantle ContaminationSites. Camden and Gloucester Citv. New Jersey.Volume V of VIII. prepared for the EnvironmentalServices Division, U.S. EPA, Region II, preparedby 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 II, March 27, 1995.

Report: Final Hazard Ranking System Documentation.Welsbaeh and General Gaa Mar.tie ContaminationSites. Camden and Gloucester Citv. New Jersey.Volume VI of VIII. prepared for the EnvironmentalServices Division, U.S. EPA, Region II, preparedby 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 II, March 27, 1995.

Report: Final Hazard Ranking System Documentation.Welsbaeh and General Gas Mantle ContaminationSites. Camden and Gloucester Citv. New Jersey.Volume VII of VIII. prepared for the EnvironmentalServices Division. U.S. EPA, Region II, preparedby 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 II, March 27, 1995. (Note: TheGloucester City/Camden Survey of AffectedProperties for Senior Citizens and Children, pages102298-102305, is confidential due to the PrivacyAct. It is located at the U.S. EPA SuperfundRecords Center, 290 Broadway, 18th Fl., N.Y., N.Y.10007-1866.)

Report: Final Hazard Ranking System Documentation.Welsbaeh and General Gas Mantle ContaminationSites. Camden and Gloucester Citv. New Jersey,volume VIII of vm. prepared for theEnvironmental Services Division, U.S. EPA, RegionII, prepared by Mr. Steven T. McNulty, ProjectManager, Mr. Todd G. Teryek, Task Leader, Mr. John

500052

L. Splendors, P.E1., Work Assignment Manager, U.S.EPA, Region II, March 27, 1995. (Note: The QualityControl Internal Controls and Audits Manual, pages102763-102822, and The Quality Assurance Manual,pages 102823-102876, are confidential businessinformation. They are located at the U.S. EPASuperfund Records Center, 290 Broadway, 18th Fl.,N.Y., N.Y. 10007-1866.)

1.4 Sit* Investigation Reports

P. 102921- Report: An Aerial Survey of Gloucester. New Jersey102947 and Surrounding Area, prepared for the U.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 Plan*

P. 300001- Plan: Welsbach/General Gas Mantle Contamination300192 Site, Camden, New Jersey, Work Assignment No.050-

28UC, Draft Final Work Plan, RemedialInvestigation/ Feasibility Study, Volume I,prepared for the U.S. EPA, Region II, prepared byMalcolm Pirnie, Inc., June 1997.

3.4 Remedial Investigation Report*

P. 300193- Report: Welsbach/General Gas Mantle Contamination300347 Site. Camden. New Jersey. Work Assignment No. 050-

2BUC. Staoe la Archaeological Investigation.prepared for the U.S. EPA, Region II, prepared byMalcolm Pirnie, Inc., June 1998.

P. 300348- Report: Welabach/General Gas Mantle300694 Contamination Site. Camden. New Jersey. Work

Assignment No. 050-2B11C. Draft Final RemedialInvestigation/Feasibility Study Report. Volume I.prepared for the U.S. EPA, Region II, prepared byMalcolm Pirnie, Inc., June 1998.

P. 300695- Report: He1abash/General Gag Mantle301035 Contamination Site. Camden. New Jereev. Work

AflBJanment No. OSO-2BUC. Draft Final RemedialInvegtioation/FeaBibilitv Study Report. Volume II.

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

3.5 Correspondence

P. 301036- Report: Welsbach/ General Gaa Mantle Contamination301134 Site. Camden. New Jeraev. Work Assignment No. 050-

2SUC Response _o Comments, prepared for the U.S.EPA, Region II, prepared by Malcolm Pirnie, Inc.November 1997.

P. 301135- Memorandum to Addressees, from Stephen D. Luftig,301145 Director, of Office of Emergency and Remedial

Response, and Mr. Larry Weinstock, ActingDirector, Office of Radiation and Indoor Air, re:Establishment of Cleanup Levels for CERCIA Siteswith Radioactive Contamination, August 22, 1997.

P. 301146- Memorandum to Addressees, from Mr. Stephen D.301151 Luftig, Director, of Office of Emergency and

Remedial Response, and Mr. Larry Weinstock, ActingDirector, Office of Radiation and Indoor Air, re:Use of Soil Cleanup Criteria in 40 CFR Part 192 asRemediation Goal for CERCLA sites, February 12,1998.

7.0 XNTORCBONT

7.3 Administrative Orders

P. 700001- Administrative Orders on Consent for Remedial700059 Investigation/Feasibility Study Armstrong

Building, In the Matter of Welsbach Gas MantleContamination Site (8U), Holt Hauling andWarehouse System, Inc., Respondent, undated.

8.0 HEALTH ASSESSMENTS

8.1 AMD* Health Assessawnts

P. 800001- Memorandum to Mr. John Prince, ERRD/NJSB1-N, from800037 Mr. Arthur Block, Senior. Regional Representative,

re: Final Health Consultation for Welsbach andGeneral Gas Mantle Contamination Sites (WGGMCS),March 12, 1997.

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10.0 PUBLIC PARTICIPATION

10.2 Coanunity Relation* Plans

P. 10.00001- Plan: Welsbach/General Gas Mantle Contamination10.00038 Site, Camden, New Jersey, Work Assignment No. 050-

28UC, Draft Final Community Relations Plan,Remedial Investigation/Feasibility Study, preparedfor the U.S. EPA, Region II, prepared by MalcolmPirnie, June 1997.

10.9 Proposed Plan

P. 10.00039- Plan: Superfund Proposed Plan, Welsbach/General10.00059 Gas Mantle Contamination, Superfund Site, Camden

and Gloucester City, Camden County, New Jersey,prepared by U.S. EPA Region II, February 1999.

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APPENDIX IV

STATE LETTER

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SENT BY'SITE REMEDIATION : 7-21-99 :12:45PM : FAX * 609 633 2360- 212 637 4429:* 2/ 3

ofledd Whitm»n . Dwpirtmant of UnvironmcnUl Piolccliou Rnburt C. SWnn. Jr.

Governor Oflto»«rtt»C»«tato««r CommittiontrP.O. Bos 402

TmtM. Mm Jtncy ttOS44n

-1914

July 21, 1999

Ms. Jeanne M. FoxRegional AdministratorU.S. EPA - Region H290 BroadwayNew York, NY 10007-1866

Subject: Wdsbach/General Gas Maatle Contamination Supcrfuad SiteRecord of Decision (ROD)

Door Ma. Fox:

The New Jersey Department of Environmental Protection (NJDEP) has evaluated and concurswith the components of the selected remedy as described below for the Weisbsch/Ccncra! C&*Mantle Superfund Site. The selected remedy corresponds to the first of three planned operableunits for the She which includes properties located in Gloucester City and Camden, ComdenCounty, New Jersey.

The major components of the telected remedy include:

• Excavation/removal of soil and waste materials with radiological contamination above remedialaction objectives from the former Wdsbacb and General Gas Mantle Facilities;

• Excavation/removal of soil and waste materials with radiological contamination abuve lanaliaiaction objectives fiom the residential and commercial properties in the vicinity of two formergas mantle facilities;

• OfF-site disposal of tteradic4ogicalty-conta^

• 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 theremedial action, and k cost effective.

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acm 01 01 it * oua ooo o/ o

TJ»c State of New Jersey Appreciate* the opportunity «Hbrdfid «. iM/bv^MO^ i,, d.vprocess.

C. Shinn, Jr.CommissionerNew Jersey Department of EnvironmentalProtection

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APPENDIX V

RESPONSIVENESS SUMMARY

500059

RESPONSIVENESS SUMMARYFOR THE

WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITEGLOUCESTER CITY & CAMDEN, CAMDEN COUNTY, NEW JERSEY

I. INTRODUCTION

This Responsiveness Summary provides a summary of public comments and concerns regardingthe remedial investigation and feasibility study (RI/FS) report and the Proposed Plan for theWelsbach/General Gas Mantle Contamination site. It also provides the U.S. EnvironmentalProtection Agency's (EPA's) responses to those comments. After reviewing and considering allpublic comments received during the public comment period, EPA has selected a remedy for theformer Welsbach Facility, the former General Gas Mantle (GGM) Facility, and the VicinityProperties at the Welsbach/General Gas Mantle Contamination site.

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 in EPA Region II, 290Broadway, 18th Floor, New York, New York 10007and 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. The notice of availability for the above-referenced documents was published in the Philadelphia Inquirer on February 1, 1999, theCourier-Post on February 2, 1999, and the Gloucester Citv News on February 4, 1999. Thepublic 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 officialsand interested citizens about the Superfund process, to review proposed remedial activities at theSite and receive comments on the Proposed Plan, and to respond to questions from area residentsand other interested parties. Meetings were held on February 23, 1999, at the Pine Grove FireStation #2 in Gloucester City, and on February 24,1999, at the Camden County MunicipalUtilities Authorities Auditorium in Camden. Responses to the comments received at the publicmeeting are included in this Responsiveness Summary. The City of Gloucester City submitted aresolution supporting the proposed remedy. No other written comments were received during thepublic 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 the Welsbach/GeneralGas Mantle Contamination site.

The next section of this Responsiveness Summary provides a comprehensive summary of majorquestions, comments, concerns, and responses, by summarizing oral comments made at thepublic meetings and EPA's responses.

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The last section of this Responsiveness Summary includes appendices which document publicparticipation in the remedy selection process for this site. There are four appendices attached tothis Responsiveness Summary. They are as follows:

Appendix A contains the Proposed Plan that was distributed to the public for review andcomment, and a Proposed Plan Summary that was provided to interested panics with theProposed Plan;

Appendix B contains the public notices which appeared in the Philadelphia Inquirer, theCourier-Post, and the Gloucester Citv News:

Appendix C contains the transcripts of the public meetings; and

Appendix D contains the written comments received by EPA during the public commentperiod.

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. Thecomments 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 showed thatproperties north of the General Gas Mantle Building were not investigated. EPA was askedwhether 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.

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2.0 EPA's Proposed Plan

2.1 Comment: An interested citizen asked what will happen to the residents while the remedialwork is going on.

Response: EPA will work with the property owner(s) so that there is as little inconvenience toresidents as possible. If there is a need for temporary relocation, the property owner will not beresponsible for any costs. All costs associated with the temporary relocation will be paid byEPA.

2.2 Comment: An interested citizen asked if the decision on whether to proceed with thedemolition of the GGM building and excavation of the contaminated material from the site hasbeen 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 excavationand 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 ofthe site.

2.3 Comment: An interested resident inquired as to how the contaminated material would beshipped from the site.

Response: The material will be shipped off-site via rail transport. The material will beexcavated from any given contaminated property and loaded onto a truck for transport to a railloading site in or near Gloucester City or Camden. Measures will be taken to secure thecontainers 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 thebackyards of the homes on Arlington Street in Camden.

Response: At this time, EPA does not know the exact depths and volumes of soil that wouldneed to be removed from the Arlington Street properties. The exact volumes will be determinedduring the remedial design phase. For the purpose of the RI/FS, volume estimates were based onthe investigation of other properties with similar conditions. Based on this information, EPAestimates 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 GGMbuilding 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 Designis completed. Prior to beginning construction activities, EPA will hold public meetings

500062

describing the construction activities that would take place. At that time, a work plan would beavailable 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 usesof these properties.

2.7 Comment: An interested resident asked if residents would be relocated during the cleanupand for how long.

Response: Based on EPA's current findings, onlv a limited number of individuals may need tobe temporarily relocated during remediation. EPA would assure that relocated residents wouldbe provided with comparable accommodations. EPA would pay for temporary relocationexpenses. On similar sites that required relocation, EPA has found that the length of time aresident 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 potentialradiologically-contaminated property.

2.9 Comment: A interested party asked whether EPA would reconsider the cleanup plan if itdiscovered much more contamination that expected.

Response: EPA does not anticipate finding such a substantial additional amount ofcontamination that it would require changing the proposed remedy. The communities of bothCamden 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 h ' d additionalpublic meetings and receive public comment before it modified the selected remeoy.

3.0 Public Health Concerns

3.1 Comment: An interested resident questioned whether there were any long-term healtheffects associated with the site. In particular, the resident mentioned the recent cancer studyprepared by the New Jersey Department of Health which indicated a higher than normaloccurrence of lung cancer throughout the area surrounding the site.

Response: The only long-term health effect from radiation is an increase in the risk ofdeveloping cancer. Although the study indicated that there was an increase in the incidence of

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lung cancer in the area, the results of the cancer study indicate that the Superfund sites were notthe probable cause for this increase.

3.2 Comment: An interested citizen inquired about whether a health study would be performedon 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 ownersin the future.

3.3 Comment: An interested resident asked what would be done for the residents while the soilwas being removed and will this pose any problems for people. How is EPA going to protectthem?

Response: The problems are more logistical than health based. The work will be performed in acontrolled manner to reduce dust and to ensure there is no spread of contamination. If there is apotential health risk or significant inconvenience to the property owner, the homeowner may betemporarily relocated until the work is complete.

3.4 Comment: A resident found some material from Welsbach in his home and was concernedabout possible health affects.

Response: At the public meeting, EPA informed the resident that it would scan his property tosee if there was any radiological contamination. A few days after the public meeting, EPAinvestigated 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 bedemolished.

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 cityofficials.

Response: Yes, EPA has discussed the proposed remedial actions with the City of Camden'smayor's office.

5.2 Comment: An interested resident asked what the next steps would be regarding informingthe residents of upcoming activities.

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Response: Following the public comment period, EPA will prepare a ROD which selects thecleanup remedy for the site. The ROD will include all of the public comments and EPA'sresponses. After the ROD is signed, EPA will place it in the local public repositories. The nextpublic meeting will be held prior to the start of any construction activities. EPA will alsoprovide 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 acontaminated property wishes to sell the property.

Response: The owner should provide a prospective buyer with all data about contamination onthe property. The participants in the transaction would need to obtain the advice of an Attorneyregarding their obligations under State law. If necessary, EPA can enter into an prospectivepurchaser agreement with a potential purchaser of a contaminated property. The agreementwould provide that the purchaser would not be held liable for any cleanup costs associated withthe 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 whobecame 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 cleanupcosts if they can demonstrate that they had nothing to do with the contamination and can meetthe other requirements set forth in Sections 107(b) and 101 (35(A)(iii.) of CERCLA. There aresimilar 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 notbe asked to demonstrate that they have defenses to liability or asked to reimburse EPA for thecosts of cleaning up that property so long as the owners did not cause or exacerbate thecontamination 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 theneighborhood of the Jogging Track, where a removal of contaminated material occurred.

Response: With few exceptions, the properties surveyed by the NJDEP were within the areasidentified in the Aerial Radiological Survey performed by EPA in 1981. Certain areas wereexcluded based upon records which indicated that homes were constructed prior to the dates ofdumping/filling activities. Because the area in question was outside the areas identified in theaerial survey. NJDEP did not survey this area.

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

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Response: EPA has allocated money for the design of the project. The design phase of theproject must be completed before EPA can allocate money for construction. When the designphase is complete, EPA's regional office will request EPA Headquarters in Washington. D.C. toallocate 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 theradiological 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 awayfrom the contamination. Gloucester City also placed gravel over the contaminated areas toprotect the residents. There are no signs posted because a majority of the residents in the areainformed city officials that they preferred no signs around the property. The contaminatedmaterials from EPA's removal action which are presently being stored in roll-offs on theproperty are securely covered. (Since the public meeting, the roll-off containers have beenremoved and disposed off-site.)

7.4 Comment: A number of citizens questioned whether contamination was found in the areadesignated for a playground near the Jogging Track in Gloucester City'.

Response: At the public meeting EPA indicated that it would investigate the area designated forthe playground prior to its construction. In March 1999, EPA investigated this area and found noradiological contamination.

Written Comments Received During the Public Comment Period

Comment: The City of Gloucester City submitted a resolution endorsing EPA's plans forcleaning up the radiologically contaminated properties in Gloucester City.

Response: No response necessary.

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Appendix A

Proposed Plan

500067

Superfund Proposed PlanWelsbach/General Gas Mantle Contamination

Superfund SiteCamden and Gloucester CityCamden County, New Jersey

Region 2February 199S

Mark Your Calendar

Public Comment Period

February 1,1999 to March 3,1999

Public Meetings:

Gloucester CityTuesday, February 23,1999 at

7:00 p.m. at Pine Grove Fire Station #2

CamdenWednesday, February 24,1999 at

7:00 p.m. at Camden County MunicipalUtilities Authority Auditorium

Availability Sessions -informal question and answer sessions:

Gloucester CityTuesday, February 23,1999, from

1:00 p.m. to 4:00 p.m. at Pine GroveFire Station #2

CamdenWednesday, February 24,1999, from

1:00 to 4:00 p.m. at Camden CountyMunicipal Utilities Authority Auditorium

PURPOSE OF THE PROPOSED PLAN

This Proposed Plan describes me remedial alternatives that the U.S. EnvironmentsProtection Agency (EPA) considered in addressing soil and building materiacontamination at the Welsbach/General Gas Mantle Contamination Site (Site). Thiplan also identifies EPA's preferred remedial alternatives and the rationale for thipreference. This document was developed by EPA, in consultation with the New Jerse;Department of Environmental Protection (NJDEP). The alternatives summarized herare described in greater detail in the Remedial Investigation and Feasibility Studywhich is now available at the City of Camden Main Library, Camden, New Jersey; thHynes Center, Camden, New Jersey; the Gloucester City Public Library, Gloucester Cir>New Jersey; and at EPA's offices at 290 Broadway, 18th Floor, New York, New York

EPA's preferred remedial alternatives address soil and building contamination at thSite. The preferred alternatives are the excavation and off-site disposal alternatives fcthe Vicinity Properties, Welsbach Facility and General Gas Mantle Facility (AltemativV-3, W-3, and G-3 with Option B).

EPA encourages the public to review and comment on all of the alternatives considereby EPA in this Proposed Plan. The remedies described in this Proposed Plan are EPApreferred remedy for the Site. Changes to the preferred remedy or a change from thpreferred remedy to another remedy may be made if public comments or additional daiindicate that such a change will result in a more appropriate remedy. EPA, iconsultation with NJDEP, will select the remedy after considering all publcomments.*

COMMUNITY ROLE M SELECTION PROCESS

EPA relies on public input to ensure that the concernsof the community are considered in selecting aneffective remedy for each Superfund site. To thisend, EPA has made the Remedial Investigation andFeasibility Study (RI/FS) report, Proposed Plan, andsupporting documentation available to the public for a

public comment period from February 1,1999, toMarch 3,1999.

During the public comment period, EPA will hold apublic meeting at the Pine Grove Fire Station #2 inGloucester City on Tuesday, February 23,1999 at7:00 p.m., and at the Camden County MunicipalUtilities Authority Auditorium, in Camden onWednesday, February 24,1999 at 7:00 p.m. Atthese meetings, EPA will present the conclusions ofthe RI/FS, discuss the reasons for recommending thepreferred remedial alternatives, and receive publiccomments.

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EPA will also be available on an informal basis toanswer 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 MunicipalUtilities Authority Auditorium on Wednesday,February 24,1999, from 1:00 to 4:00 p.m.

Comments received at the public meeting, and allwritten comments, will be documented in theResponsiveness Summary Section of the Record ofDecision (ROD), the document which formalizes theselection of the remedy. All written commentsshould be addressed to:

Richard J. RobinsonProject Manager

U.S. Environmental Protection Agency2 90 Broadway, J 9th FloorNew York, NY 10007-1866

Copies of the RI/FS report. Proposed Plan, andsupporting documentation are available at EPA'soffice at 290 Broadway, 18th Floor, New York, NY10007-1866. (212) 637-4308, and at the followingrepositories:

City of Camden Main Library418 Federal StreetCamden, NJ 08103

(609) 757-7650

Hynes Center1855 South 4th StreetCamden, NJ 80104

(609)966-9617

Gloucester City Public LibraryMonmouth and Hudson Streets

Gloucester City, NJ 08030(609)456-4181

EPA, after consultation with NJDEP, will select aremedy for the Site only after the public commentperiod has ended, and the information submittedduring that time has been reviewed and considered.EPA is issuing this Proposed Plan as part of its public

participation responsibilities under Section 111 (a) ofthe Comprehensive Environmental Response,Compensation and Liability Act (CERCLA). asamended, and Section 300.430(f) of the National Oiland Hazardous Substances Pollution ContingencyPlan (NCP).

ISrTE BACKGROUND

Between the 1890s and 1940s, the WelsbachCompany (Welsbach) manufactured gas mantles at itsfacility in Gloucester City, New Jersey. Welsbachwas a major manufacturer and distributer of gasmantles until gas lighting was replaced by*the electriclight. Welsbach extracted the radioactive elementthorium from ore .ind used it in the gas mantlemanufacturing process. Thorium causes the mantlesto glow more brightly when heated. A second gasmantle manufacturing facility, known as the GeneralGas Mantle Company (GGM), was located inCamden, New Jersey. GGM was operated from 1915to approximately 1940.

EPA initially identified the Site in 1980, during;archive search conducted as part of the investigationof the U.S. Radium Corporation Superrund sitelocated in Orange, New Jersey. Historical U.S.Radium Corporation files indicated that radiologicalmaterials were purchased by U.S. Radium from theWelsbach Corporation during the 1920s.

In May 1981, EPA conducted an aerial radiologicalsurvey of the Camden and Gloucester City area toinvestigate for radioactive contaminants. The surveyencompassed a 20 square kilometer area surroundingthe former locations of the Welsbach and General GasMantle Facilities. Five areas with elevated gammaradiation were identified from the aerial survey; theyincluded the locations of the two former gas mantlemanufacturing facilities and three mainly residentialareas in both Camden and Gloucester City. In 1993,the data from the aerial survey were reanalyzed.Based or. this revised information, EPA identified asixth potential radiologicalh contaminated area whichincludes two vacant lots in Gloucester City.

EPA Region 2 - February 1999 Page 2500068A

In the early 1990s, NJDEP conducted more detailedradiological investigations at more than 1,000properties located throughout the original five studyareas. Radiological contamination was found at thetwo former gas mantle facilities. NJDEP data alsoindicated that approximately 100 properties near thetwo former gas mantle facilities might becontaminated. In 1996, the Welsbach/GGM site wasplaced on National Priorities List (NPL) because ofthe presence of radioactive contaminants.

Based on their geographic proximity, EPA dividedthe Welsbach/GGM site into six study areas inCamden and Gloucester City, New Jersey (Figure 1).A brief description of each study area and its currentland use is presented below:

• Study Area One: includes the former GeneralGas Mantle Facility and residential andcommercial properties which surround the facility.The former GGM Facility is located in a mixedindustrial, commercial, and residential zonedsection of Camden.

• Study Area Two: includes the location of theformer Welsbach Facility and nearbyresidential/commercial properties. The formerWelsbach Company is situated in an industrialzoned section of Gloucester City with residentialproperties to the immediate east.

• Study Area Three: includes residential andrecreational properties in Gloucester City,including the Gloucester City Swim Club and theJohnson Boulevard Land Preserve.

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

• Study Area Five: includes residential properties,vacant land properties, and two municipal parksnear Temple Avenue and the South Branch ofNewton Creek in Gloucester City.

• Study Area Six: includes two vacant lots in aresidential zoned area of Gloucester City. Thisarea was initially identified when the aerial surveydata were revised in 1993. This area was

identified during site assessments performed b\ theCity of Gloucester City.

No significant changes in land use are anticipated.except in the Study Area 1 where there is a possibilitythat some residential areas may be rezoned forcommercial uses. Whether zoning changes willactually be made is uncertain at this time.

iSITEHISTORY

The Welsbach and the GGM Facilities have complexhistories of name and ownership changes. Specificdetails are discussed in the paragraphs below.

The United Gas Improvement Company, whichformed Welsbach, purchased the patent rights tomanufacture thorium-containing gas mantles in the1880s from Dr. Carl Auer von Welsbach. Theprocess for manufacturing the Welsbach gas mantleused a highly purified solution of 99 percent thoriumnitrate and 1 percent cerium nitrate as a "lightingfluid" in distilled water. A fabric sock was thendipped into the thorium solution to create the gasmantle. Thorium caused the uas mantle to give off avery bright white light when lit.

The commercial source of thorium and cerium is amineral known as monazite sand. Monazite sandcontains approximately 5-6 percent thorium oxideand 20-30 percent cerium oxide. Thorium wastypically extracted from the monazite ore by heatingthe ore in a sulfuric acid solution. The thorium andother rare earth elemen's would go into solution,while the radium-228 remained in the tailings ofinsoluble sulfates. Around 1915, Welsbach startedusing and selling the radium-228 for its use inluminescent paint. For a number of years, Welsbachwas the largest manufacturer of gas mantles in theworld making up to 250,000 mantles per day at itspeak.

Welsbach also made gas room heaters, gas storagewater heaters, gas and electrical fixtures, electricalrefrigerators, plumbing supplies and lacquers.Manufacturing operations at the Welsbach facility

EPA Region 2 - February 1999 Page 3500068B

WELSBACH/GENERAL GAS MANTLECONTAMINATION SITE - STUDY AREAS

Page 4500069

began as early as 1882 and lasted until the 1940s.The facility property covered an area of about 21acres, and consisted of about 20 buildings.

In 1948, the former Welsbach Facility in GloucesterCity was sold to the Randall Corporation, and leasedto the Radio Corporation of America, VictorDivision. In May 1976, the property was purchasedby Holt Hauling and Warehousing, Inc. (Holt), thecurrent owner of the property. Holt operates a cargoand overseas shipping business.

Only one Welsbach era building, the ArmstrongBuilding, is still present on the property. There is noinformation available on when the other Welsbach-erabuildings were demolished. The Armstrong Buildingis not part of this Operable Unit. Holt is performingan Rl/FS of the Armstrong Building under anAdministrative Consent Order with EPA.

The former gas mantle manufacturing facility inCamden was owned and operated by the GGMCompany from 1912 to 1941. There is littleinformation available regarding activities at GGM,other than it used and resold radium and thorium.

Between 1941 and 1978, there had been a total ofseven different private owners of the property. Basedon current information, none of these operationsinvolved radioactive materials. In January 1978, thesouthern portion of the property was occupied by theDynamic Blending Company. In October 1988, thenorthern portion of the property was purchased bySte-Lar Textiles. In 1992, NJDEP removedradiologically contaminated fabrics from the facility,relocated Ste-Lar, and sealed up the GGM building torestrict access.

During the years that Welsbach and GGM operated,ore tailings were used for fill at properties in thevicinity of the facilities. It is also reported thatbuilding debris from the former Welsbach Facilitymay have been disposed of as fill in the area. Inaddition, workers from the former Welsbach andGGM Facilities may have brought contaminationhome with them. These properties associated with

radiological waste from the Welsbach and GGMFacilities are collectively termed Vicinity Properties

In 1991, NJDEP initiated a radiological investigationat more than 1,000 properties located throughoutStudy Areas 1 through 5. At properties whereNJDEP determined that exposure levels wereunacceptable (or posed an immediate health risk).they performed interim remedial measures. Thesemeasures included the installation of radon/moronventilation systems and placement of concrete or leadsheeting to shield gamma radiation. In addition.NJDEP restricted access to outdoor areas whichexceeded its action levels. *

In 1998, EPA identified a 100 square foot area in aGloucester City Park, located in Study Area 5, thathad high levels of gammj radiation at the surface. InDecember 1998, EPA performed a removal action toreduce exposure to the high levels of gammaradiation at the surface. EPA excavated the top threefeet of radiologically contaminated soil and replacedthe waste material with clean fill.

;THE NATURE OF RADIONUCLIDESA radionuclide is an element that spontaneouslychanges, or "decays" into another element throughnatural processes. Radionuclides are present in traceamounts in all rocks and soils, and consist primarilyof elements of the uranium-238 and thorium-232decay series. There are approximately 1,700 differentunstable atomic species, or radionuclides. Theseinclude both naturally occurring and man-maderadionuclides.

The radionuclides of concern in the wastes whichoriginated at the former Welsbach and GGMFacilities are members of the uranium and thoriumdecay series. There are 14 unique radionuclides inthe uranium decay series and 11 unique radionuclidesin the thorium decay series which precede theformation of stable lead (Pb-206 or Pb-208). Alpha,beta, and gamma radiation are emitted from thevarious members of the two decay series. Theprimary nuclides of concern are Thorium-232,

EPA Region 2 - February 1999 PageS500070

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 amountof time in which half of any given number ofatoms of a radionuclide will decay.

2. The mode of decay refers to the type(s) ofparticles or electromagnetic rays emitted fromthe radionuclide as it decays. These typesinclude alpha and beta particles, and gammarays.

3. The amount of energy carried away from theatom by the particles or rays is radionuciidespecific. It is the transfer of this energy toliving tissue which may cause biologicaleffects.

When radionuclides decay, they emit energy in theform of radiation. The decaying radionuclide is oftencalled the "parent", and the radionuclide produced iscalled the "decay product". A quantity of radioactivematerial is measured by its rate of decay, expressedby the unit Curie (Ci), which is equal to 2.22 x 1012

(2.22 trillion) disintegrating atoms per minute. Amore convenient unit for expressing environmentalradioactivity is the picoCurie (pCi), which is equal to1 x 10-' :(onetrillionth)Ci.

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

In its decay. Radium-226 forms Radon-222 or radongas. Radon gas is colorless, odorless, radioactive andinert; therefore, it can move easily through soil to theground surface or into houses. Within a matter ofdays, the radon sas itself decays into a series ofradioactive dec r- products. While radon gas in theoutdoor air aissipates quickly, the concentration ofra : '?n decay products in the indoor air can build upc • time. Exposure to the energy released by thesevarious decaying atoms can result in adverse health

effects. For radon decay products, a special unitcalled Working Level (WL) has been developedWorking Level is defined as any combination o^short-lived radon decay products in 1 liter of air thatwill result in the ultimate emission of 1.3x10- Mega-electron Volts of potential alpha energy. This value isapproximately equal to the alpha energy releasedfrom the decay of progeny in equilibrium with 100pCi of Radon-222.

Thorium-232 is also a naturally occurringradionuclide and is the initial radionuclide of thethorium decay series. Its decay products includeradium-228 and Radon-220. Radon-220 is* alsoknown as thoron. Thoron and its decay productshave extremely short half-lives that usually preventthem from concentra"ng to any appreciable extent inindoor air. However, u a significant source of thoronexists within, beneath, or adjacent to a structure (suchas the thorium and radium-228 found inWelsbach/GGM site wastes), thoron decay productscan reach concentrations which create health risks.

I REMEDIAL INVESTIGATION SUMMARY _

In September 1997, EPA started an RI tocharacterize the nature and extent of contamination atthe Welsbach Facility. General Gas Mantle Facility,and 20 of the radiologically contaminated propertiesidentified by NJDEP in the vicinity of Welsbach andGGM. In order to develop a cleanup strategy for theSite, the RJ field investigations were divided intothree property categories, as follows:

Former Welsbach Company Facility;Former General Gas Mantle CompanyFacility;Vicinity Properties.

The RI/FS report presents the results of fieldinvestigations conducted to date ar both Welsbachand GGM Facilities and the 20 V cmity Properties.In future phases of the remediation, called operableunits, EPA will investigate potentially impactedground water, surface water, and sediments.

EPA Region 2 - February 1999 Page 6500071

Property Investigations

EPA conducted both chemical and radiologicalcharacterizations of the former Welsbach and GGMFacilities to define the extent of contamination. EPAalso performed a radiological investigation on 20 ofthe potentially contaminated Vicinity Propertiesidentified by NJDEP. Only 20 Vicinity Propertieswere investigated during the RI so that EPA couldconfirm the NJDEP data and expedite thedevelopment of cleanup alternatives. EPA willinvestigate the remaining potentially contaminatedproperties identified by NJDEP, and other propertiessuspected of being possibly contaminated during theremedial design phase of this cleanup. EPA estimatesthat about 600 properties will be studied in the designphase to d :termine exactly which properties requirecleanup. This additional work may include samplingfor chemical analysis, where deemed appropriatewhen considering past ownership and historicinformation. Field activities conducted as part of theRI included the following:

•*-, •

•

•••

•

Radon measurementsRadon decay product Working LevelmeasurementsGamma radiation surface and one-meterheight exposure rate surveysSurface and subsurface soil samplingDownhole gamma radiation loggingTotal surface beta surveys and removablesurface alpha and beta samplingStructural materials sampling (in somebuildings)

Results of Field Investigations

Areas with elevated levels of radioactivity thatexceeded the radiological standards for human healthwere identified during the remedial investigations.The RI data support the following conclusions:

Former Welsbach Facility

• Most of the radiological contamination islocated in the area of a former Welsbach

building that was demolished in the 1970s.This area is currently used for storageHowever, there are smaller areas ofcontamination scattered throughout theproperty. The soil in these areas iscontaminated with elevated concentrations ofthe thorium and uranium decay seriesradionuclides. Subsurface contamination onthe Welsbach facility averages about 11 feet indepth. An estimated 27,200 cubic yards ofsoil/buried debris have thorium and or radiumconcentrations exceeding 5 pCi'g Radiumand thorium concentrations in soil rangedfrom background (about 1 pCi/g fcfi each) toas high as 455 pCi/g and 1.190 pCi g.respectively.

• Surface gamma exposure rates associatedwith the contaminated soils ranged frombackground (less than 10 micro-Roentgen perhour [uRTi]) to 780 nR/h. The highestreadings were associated with a large fill areaidentified in the middle of the storage area.

• Low levels of chemical contaminants wereidentified at the former Welsbach Facility.Contaminants of potential concern includesemi-volatile organic compounds and arsenic.These contaminants may be indicative of"Historic Fill". If this is conf.—ned in theremedial design, then there may be no need toexcavate this soil. Instead, it may be moreappropriate to cap these soils in place.

Former General Gas Mantle Facility

• Elevated concentrations of thorium anduranium decay series radionuclides wereidentified in soils on the former GGMproperty. Contamination was generallylimited to the top six to eight feet, althoughcontamination in some areas of South FourthStreet and the GGM Courtyard ranged from12 to 16 feet in depth. An estimated 900cubic yards of soil had thorium and/or radiumconcentrations which exceeded 5 pCi/g.


Radium and thorium concentrations in soilranged from background to as high as 172pCi/g and 149 pCi/g, respectively.

Surface gamma exposure rates associatedwith the contaminated soils ranged frombackground (less than 10 uR/h) to 380 uR/h.Only localized areas of surface contaminationwere identified outdoors.

Most of the outdoor contamination is locatedin the area of South Fourth Street. However,some smaller areas of contamination wereidentified in the alleyway behind the propertythat extended onto some backyards ofneighboring residential properties.

Elevated levels of surface contamination wereobserved in many areas inside the formerGGM building. Levels as high as 2.33microCi per meter square (uCi/m :) area wereobserved.

Indoor gamma exposure rates ranged frombackground to 900 \iRfh.

An estimated 1.460 cubic yards ofcontaminated structural materials in thebuilding itself were identified, with thoriumconcentrations as high as 750 pCi/g.

In the basement of the former GGM building,radon decay product concentrations measured1.7 WL, compared to an average backgroundlevel of 0.005 WL.

Certain semi-volatile organic compounds andmetals were identified. These were; however,at such low levels that they are not chemicalsof concern. These contaminants may beindicative of "Historic Fill". If this isconfirmed in the remedial design, then theremay be no need to excavate this soil. Instead,it may be more appropriate to cap these soilsin place.

Vicinity Properties

EPA investigated 20 properties in Camden and _^Gloucester City for radiological contamination as partof the RI. EPA compared these data to informationcollected from earlier NJDEP investigations anddetermined that the data were comparable. Thesedata support the following conclusions:

• Some site properties have indoor radon gasconcentrations or soil radionuclideconcentrations which pose a long-term risk tohuman health.

4

• Contaminated soil averaged about two tothree feet in depth on most residentialproperties. On a few properties,contamination extended to 10 feet in depth.

• Based on the comparison of EPA and NJDEPdata, approximately 50 properties wereidentified as having contamination above thecleanup levels. During the remedial designphase, EPA will delineate the extent ofcontamination on these properties in order'Zodesign a cleanup plan for each property.

• EPA identified approximately 600 propertiesthat are either adjacent to the knowncontaminated properties or have gammaexposure rates above background levels. Inthe RI report, these properties are termed"suspect properties." During the remedialdesign phase, EPA will investigate and samplethese properties to see if there is anyradiological contamination present. Ifcontamination above the cleanup objectives isfound, EPA will delineate the extent of thiscontamination and design a cleanup plan forthese properties.

jSUMMARY OF SITE RISK

A baseline risk assessment was conducted for theformer Welsbach Facility, the former GGM Faci1

and the Vicinity Properties utilizing analytical daur


obtained during the RI. The baseline risk assessmentestimates the human health risk which could resultfrom the contamination at a site if no remedial actionwere taken.

Ecological risks, that is, the risk to aquatic andterrestrial wildlife (plants and animals), were notevaluated for this operable unit because the studyareas consisted primarily of residential andcommercial properties. An Ecological RiskAssessment will be conducted in a future RI toevaluate the potential for adverse effects to aquaticand terrestrial wildlife (plants and animals) inaccordance with Ecological Risk AssessmentGuidance for Superfund, Process for Designing andConducting Ecological Risk Assessments (EPA 540-R-97-006).

To evaluate human health risks, a four-step processwas used for assessing site-related risks for areasonable maximum exposure scenario. These stepsare: Hazard Identification - identified thecontaminants of concern at the site based on severalfactors such as toxicity, frequency of occurrence, andconcentration; Exposure Assessment - estimated themagnitude of actual and/or potential humanexposures, the frequency and duration of theseexposures, and the pathways (e.g., ingestingcontaminated soil) by which humans are potentiallyexposed; Toxicity A ssessment - determined the typesof adverse health effects associated with exposures tosite contaminants, and the relationship betweenmagnitude of exposure (dose) and severity of adverseeffects (response); and Risk Characterization -summarized and combined outputs of the exposureand toxicity assessments to provide a quantitative(e.g., one-in-a-million excess cancer risk) assessmentof site-related risks.

For risk assessment purposes, individual contaminantsare typically separated into two categories of healthhazard depending on whether they exhibitcarcinogenic effects (causing cancer) ornoncarcinogenic effects (causing health effects otherthan cancer.) Radionuclides (e.g., radium, thorium,radon, thoron, and radon/thoron decay products) are

known carcinogens. Nonradiological chemicalcontaminants (e.g., PAHs and arsenic) may exhibitboth carcinogenic and noncarcinogenic health effects.

EPA's acceptable cancer risk range is 10"* to 10'bwhich can be interpreted to mean that an individualmay have a one in 10.000 to one in 1.000.000increased chance of developing cancer because ofsite-related exposure to a carcinogen.

Human health risks were estimated for bothradionuclides and chemicals of concern at the formerWelsbach and GGM Facilities, and for radionuclidesof concern at the Vicinity Properties. Buddingmaterials and/or soil were the environmental media ofconcern. Risks (that is, the probability of developinga cancer because of exposure to radioactivematerials) were calculated based on "reasonablemaximum exposure" according to EPA guidance.This means that risks are estimated as a result ofexposure to site-related carcinogens over a 30-yearlifetime under the specific exposure conditions at asite and other exposure assumptions that result in anoverall exposure estimate that is conservative butwithin a realistic range of exposure.

In assessing potential human health risks fromexposure to the radionuclides, several exposurescenarios involving exposure to external gammaradiation, ingestion of radioactive materials, andinhalation of radioactive materials were evaluated.Risks were estimated for several current and futurescenarios, and were compared to the risk from naturalbackground sources of radiation.

The maximum excess lifetime radiogenic (radiationinduced cell damage) cancer risks, that is, the risksdue solely to the presence of radioactive materialsabove background levels, are 5.7 x 10"2 at the formerWelsbach Facility (to the current and future siteworker), 1.8 x 10'' at the former GGM Facility (to ahypothetical future site worker), and 1.8 x 10"2 to aresident of a vicinity property. These radiogenic risksexceed EPA's acceptable risk range. The cancer riskfrom chemical exposures to the same populations atthe former Welsbach and GGM Facilities was also


evaluated. The cancer risk did not exceed EPA's riskrange and; therefore, no additional remedial action isnecessary because of chemical contaminants.

To assess the potential for cumulativenoncarcinogenic effects posed by multiplecontaminants, EPA has developed a hazard index(HI). The HI is derived by adding the noncancerrisks for site chemicals with the same target organ ormechanism of toxicity. When the HI exceeds 1.0.there may be concern for adverse health effects due toexposure to multiple chemicals.

For the Welsbach/GGM site, non-cancer healtheffects were evaluated only at the former Welsbachand GGM Facilities. The total HI for constructionworker exposure to the chemicals of concern in soilat the former Welsbach Facility from ingestion,dermal contact, and inhalation is equal to EPA'sacceptable level of 1.0. Ingestion of arsenic is thepredominant contributor to the risk estimate. Thetotal HI for construction worker exposure to thechemicals of concern in soil at the GGM Facility fromingestion. dermal contact, and inhalation is 3 x 10'2;this hazard index is below EPA's acceptable level of

•r>. indicating that adverse, noncarcinogenic healthmeets from such exposure are unlikely.

The following are the dominant radiological exposurepathway risks for the various exposure scenariosevaluated for the Welsbach/GGM site. At residentialproperties and the former Welsbach Facility, themajority of risk is from exposure to external gammaradiation, or direct radiation. Occupants of theformer GGM Facility (current and future trespassersand future site workers) are at risk primarily frominhalation of thoron decay products. Futureconstruction worker risk is primarily due to directradiation, although inhalation of particulatescontaining radioactive material also contributes asignificant portion of the risk.

This RI focused primarily on residential andcommercial properties, and sensitive species of plantsand animals are not likely to inhabit these portions ofthe Site. However, sensitive species may be present

in Study Areas 3 and 5 around Newton Creek. Anecological risk characterization for these areas u;"conducted in a future operable unit. ^

e

Actual or threatened releases of hazardous substancesfrom the Site, if not addressed by the preferredalternatives, or one of the other active measuresconsidered, may present a current or potential threatto public health, welfare, or the environment

I REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals toprotect human health and the environment. Theseobjectives are based on available information andstandards such as applicable or relevant andappropriate requirements (ARARs) and risk based-based levels established in the risk assessment. EPA'sremedia action objectives for the Welsbach/GeneralGas Ma/..ie Contamination site are to take measuresthat will prevent or mitigate further release ofradioactive contaminated materials to the surroundingenvironmen: and to eliminate or minimize the risk Khuman heauh and the environment. The sources _radiation include both contaminated soil andstructural materials. Direct radiation, inhalation.ingestion of plants and soil are potential pathways.EPA proposes the following remedial actionobjectives for the Site:

• Eliminate or minimize the potential forhumans to ingest, come into dermal contactwith, or inhale particulates of radioactiveconstituents or to be exposed to externalgamma radiation in order to achieve the levelof protection required by the NCP (10'^ to10'6 risk range).

• Prevent long-term exposure to thorium- andradium-contaminated material (e.g., soil) withconcentrations greater than 5 pCi/g.


• Prevent exposure to indoor concentrations ofradon gas and radon decay products greaterthan 4 pCi/L and 0.02 WL', respectively.

• Prevent direct contact with building surfacesexhibiting total surface thorium contaminationexceeding 0.026 uCi/m2 above background.

• Prevent migration of thorium-contaminatedmaterial that could result in the exposuresdescribed above.

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

EPA. in the Office of Solid Waste and EmergencyResponse (OSWER) Directives No. 9200.4-18, andNo. 9200.4-25. developed health guidelines forlimiting exposure to ionizing radiation from radiumand other sources. To further ensure protectiveness,those health guidelines can be supplemented byselecting response actions which reduce exposuresresulting from ionizing radiation to levels that are AsLow As Reasonably Achievable (ALARA2) takinginto consideration technical, economic and socialfactors.

EPA recommends that indoor radon concentrations inhomes should not exceed 4 pCi per liter of air (pCi/1).In 40 CFR 192, "Standards for Cleanup of Land andBuildings Contaminated with Residual RadioactiveMaterials From Inactive Uranium Processing Sites,"EPA enacted standards for limiting exposure to radondecay products and gamma radiation. While thisregulation is not directly applicable to this sitebecause the Welsbach and GGM Facilities are not

' Exposure to 4 pCi/l of air for radon corresponds to anapproximate annual average exposure of 0.02 WL forradon decay products.

References for ALARA principles -"RadiationProtection Guidance to Federal Agencies forOccupational Exposure", 1987, Federal Register 52,No. 17, 2822; and "Federal Guidance Report No. 11",September 1988. EPA-520\1-88-020.

inactive uranium processing sites. EPA considers thecleanup standards in 40 CFR 192 to be relevant andappropriate for the Site. The relevant portions of 40CFR 192 include limiting exposure to: radon deca\products to levels less than 0.02 WL and radiumconcentrations (implemented as the sum of Ra-22t>and Ra-228) to 5 pCi/gram. EPA, in Directive No9200.4-25, states that whenever the 5 pCi'g radiumsoil cleanup standard is determined to be relevant andappropriate at a CERCLA site which contains bothradium and thorium in the waste, the 5 pCi g cleanupstandard also applies to thorium (implemented as thesum of Th-230 and Th-232).

4

In achieving the remedial action objectives for theSite, EPA would rely on the ALARA principles usedat other radiological contaminated sites in NewJersey. Applying ALARA principles means takingadditional measures during implementation of theremedial action, beyond those required to meet aspecified cleanup goal, to assure protectiveness. AnALARA approach is being used because of the long-lived nature of radionuclides, the difficulty ineliminating routes of exposure, limitations of theanalytical equipment to detect radionuclides. and site-specific factors which ,;.ay make it necessary toremove material at levels below 5 pCi/g to achieveadequate public health protection.

EPA's experience at the other radiologicalcontaminated sites in New Jersey has shown that theremedial action objectives noted above can beachieved by incorporating ALARA principles.Therefore, by using similar remedial action objective'the Welsbach/GGM Site would pose no unacceptablerisk for residential uses after cleanup, and wouldresult in a cleanup that is protective under CERCLA.

To meet the remedial action objectives outlinedabove, EPA plans to excavate radiologicallycontaminated soils and waste materials, and disposeof them off-site. Excavation of soils will eliminate ththreat of physical migration of contaminants, as wellas potential exposure through various pathways(ingestion, inhalation, dermal contact, externalgamma radiation, etc.)- Contaminated soils will be


shipped off-site to a licensed commercial facility forpermanent long-term management.

The planned response action for buildings, specificallyat GGM, is decontamination, demolition, and off-sitedisposal of contaminated materials to reduceexposures within acceptable levels for future use ofthe property.

Any potential ecological risks and adverse impactsfrom existing radiological contamination on theproperties addressed under this action will beminimized because the contaminated soils will beremoved and backfilled with clean soil. There arealso limited habitats for ecological receptors at theproperties addressed under this action. Furthermore,by removing the radiologically contaminated waste,the surface water and sheet flow pathways will beeliminated as routes of exposure.

Wetlands are not present at both the former Welsbachanu GGM facilities. However, wetlands are presentin Areas 3 and 5, along the South Branch of NewtonCreek. During the remedial design. EPA willdelineate wetland areas whi.h are actually orpotentially impacted by contamination or remedialactivities.

SCOPE AND ROLE OF ACTION

The goal of the proposed remedial action is tominimize or eliminate the potential health hazardposed by all radiologically contaminated soils andstructural materials at the Site. Because of the largegeographical area associated with this project, not allpotentially contaminated areas were evaluated duringthe RI. EPA will investigate additional areas as partof the remedial design to delineate the full extent ofcontamr tion. The Armstrong Building, groundwater, Su. âce water, and sediments, will beaddressed in future Operable Units.

'SUMMARY OF REMEDIAL ALTERNATIVES _

CERCLA requires that each remedv be protective othuman health and the environment, oe cost effective.comply with other statutor- laws, and utilizepermanent solutions and alternative treatmenttechnologies and resource recover, alternatives to themaximum extent practicable. In addition, the statuteincludes a preference for the use of treatment as aprincipal element for the reduction of toxicit\.mobility, or volume of hazardous substances.CERCLA also requires that if a remedial action isselected that results in hazardous substance's,pollutants, or contaminants remaining at a site abovelevels that allow for unlimited use and unrestrictedexposure. EPA must review the action no less thanevery five years after the start of the action.

This Proposed Plan evaluates the RemedialAlternatives for addressing the contaminationassociated with the Site. Cleanup alternatives wereevaluated for the Vicinity Properties, the formerWelsbach Facility and the General Gas MantleFacility. The alternatives include: No Action,Engineering Controls, und Excavation and Off-SiteDisposal.

Vicinity Properties

The Vicinity Properties include residential,commercial, and public properties where radiologicalcontamination was identified in soils situatedoutdoors and/or beneath buildings, and propertieswith indoor air contamination.

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

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

EPA ." sgion 2 - February 1999 Page 12500077

A "No Action" alternative is evaluated for everySuperfund site to establish a baseline for comparisonwith remedial alternatives. Under this alternative, noremedial action would be performed at the Site.Previous interim remedial actions implemented byNJDEP would not be maintained. Currentinstitutional controls including fencing would not bemaintained. Because hazardous substances wouldremain at the Vicinity Properties above acceptablelevels, five-year reviews would be required.

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 shieldingwould be placed at each property which has -contaminated soil. The gamma shield would consistof a geotextile liner, fill material, 6-inches topsoil, andvegetation (seeding or sod). The thickness of the fillmaterial will vary from 6 inches to 42 inches, basedon the shielding requirements of each property. Atotal of approximately 75,000 square feet of coveragewould be installed.

In addition, indoor gamma shielding would be placedinside buildings exhibiting unacceptable exposurelevels. The shielding would consist of concrete orsteel as needed. The concrete would range from 4inches to 7 inches thick, and about 1.5 inches of steelsheeting would be placed on wall surfaces.Approximately 2,000 square feet of concrete and 60square feet of steel coverage would be installed.Finally, if any property buildings exhibit elevatedradon/thoron levels, a sub-slab ventilation radonmitigation system would be installed.

Institutional controls, such as deed restrictions, wouldbe required to ensure the protectiveness of theremedy. Because hazardous substances would remainat the Vicinity Properties above acceptable levels,five-year reviews would be required. The estimated

time to design and construct the remedy is from threeto 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: S13.408.560Estimated Implementation Period 3-5 years

Under this alternative, soil on the Vicinity Propertiescontaminated above 5 pCi/g greater than backgroundwould be excavated and disposed of at a licensedoff-site facility. Radiologically contaminated buildingdemolition debris would also be excavated anddisposed of off-site. EPA will replace these areaswith clean fill. The total volume of soils requiringdisposal at the Vicinity' Properties is estimated to be11.000 cubic yards. The total volume of burieddemolition debris at the Vicinity Properties isestimated to be 2.250 cubic yards.

Where contamination is suspected underneathbuildings, this alternative includes removing concreteflooring and underpinning the buildings. After theremoval of contaminated soil, a new concrete floorwould be constructed. Approximately 21 propertieswould require concrete floor removal andreplacement. Underpinning is estimated to berequired at one property.

The estimated time to design and construct theremedy is from three to five years. Provisions wouldneed to be made for the temporary relocation ofresidents and businesses during construction of thisalternative. During excavation, short-term provisionsto prevent dust generation and protect workers wouldbe required.

Welsbach Facility

The former Welsbach Facility is presently owned andoperated by Holt, as a cargo storage and overseashipping operation. Radiological contamination onthe property is present in the outdoor portion of the


storage area. Most of the contamination is located ina single contiguous area, with smaller elevated areasscattered across the property. The ArmstrongBuilding is not included in the remediationalternatives. Holt is preparing an RI/FS that willaddress the remedial alternatives for that building.

Welsbach Alternative 1 (\V-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 beperformed at the Site. Current institutional controlsincluding fencing would not be maintained. Becausehazardous substances would remain on the propertyabove acceptable levels, five-year reviews would berequired.

Welsbach Alternative 2 (W-2) - EngineeringControls

Estimated Capital Cost:Estimated Annual O&M Cost:Estimated Present Worth:Estimated Implementation Period

$5,690,000$44,000

$6.180.0003-5 vears

Under this alternative outdoor gamma shieldingwould be placed in the areas of the former Welsbachproperty that have soil contamination. The gammashield would consist of steel covered by asphalt. Thesteel would range in thickness from 1 to 5 inches,with a 4-inch asphalt cover. Approximately 53,000square feet of area would be covered by the steelshielding.

Institutional controls, such as deed restrictions, wouldbe required to ensure the protectiveness of theremedy. Because hazardous substances would remainon the property above acceptable levels, five-yearreviews would be required. The estimated time todesign and construct the remedy is from three to fivevears.

Welsbach Alternative 3(\V-3) - Excavation andOff-Site Disposal

Estimated Capital Cost: S18.50:oc>0Estimated Annual O&M Cost: SOEstimated Present Worth: $18.503.560Estimated Implementation Period 3-5 years

Under this alternative, all soil contamination at theWelsbach site above 5 pCi/g greater than backgroundwould be excavated and disposed of at a licensedoff-site facility Contaminated building demolitiondebris which is currently buried on-site because offormer demolition activities would also be*excavatedand disposed of at an appropriate off-site facility.EPA will replace these areas with clean fill. Thevolume of soils above the cleanup standard isestimated to be 19,400 cubic yards. The volume ofburied demolition debris requiring disposal isestimated to be 4,400 cubic yards. Duringexcavation, short-term provisions to prevent dustgeneration and protect workers would be required.

Subsurface contamination on the Welsbach Facil;

averages about 11 feet in depth. In the area of the"'deepest contamination, underground tunnels datingfrom around the turn of the century are present.These tunnels extend down to anout 10 to 12 feet indepth. These tunnels can act as conduits to carryradon gas to nearby residential properties. As aresult, the remedy includes excavation of thecontamination to these depths to prevent any futureradon migration problems and to protect futureworkers from elevated gamma radiation levels. Theestimated time to design and construct the remedy isfrom three to five years.

General Gas Mantle Facility

The GGM building is presently inactive and in adilapidated state. The building has been boarded shutand fenced in by NJDEP Radiological contaminationon the property exists both inside and outside thebui.ding. Inside the building, cr- j-ninatio- :s presentin ruilding materials and in am- ;~.t air. Outside theGGM Facility, soil contamination is primarily Ic _id


to the immediate southwest of the GGM buildingextending into South Fourth Street. Two smallerareas of contaminated soils are situated to thenortheast of the building and in the alleyway adjacentto the eastern side of the building.

General Gas Mantle Alternative 1 (G-l) - NoAction


$0$0$0

none

Under this alternative, no remedial action would beperformed at the Site. Previous interim remedialactions would not be maintained. Currentinstitutional controls including fencing would not bemaintained. Because hazardous substances wouldremain on the property above acceptable levels,five-year reviews would be required.

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


$122,000$23,000

$381.0002-3 years

Under this alternative, outdoor gamma shieldingwould be placed at the former General Gas Mantleproperty. The gamma shield would consist of either asoil shield or a concrete shield. The soil shield wouldinclude a geotextile liner, fill material, six-inchestopsoil, and vegetation (seeding or sod). Thethickness of the fill material will range from six to 24inches. The thickness of the concrete will range fromsix to eight inches. Approximately 5,000 square feetof coverage would be required. Areas ofcontamination extending into South Fourth Streetwould be covered with an additional 4 inches ofasphalt.

Also under this alternative, significant institutionalcontrols, including permanently boarding shut the

building and restricting access to the building forever.would be required. Because hazardous substanceswould remain on the property above acceptablelevels, five-year reviews would be required. Theestimated time to design and construct the remedy isfrom two to three years.

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

G-3A: Demolition and Disposal


•S2.309.560$0

$2.309.5601-2 vears

Under this alternative for the GGM property, soilcontaminated above 5 pCi/g greater than backgroundwould be excavated and disposed of at a licensedoff-site facility. Contaminated building demolitiondebris which is currently buried on-site because offormer demolition activities would also be excavatedand disposed of off-site. EPA will replace these areaswith clean fill. The volume of soil and burieddemolition debris at GGM is estimated to be 650cubic yards and 60 cubic yards, respectively.

Under this alternative, the former General Gas Mantlebuilding would be demolished, and the demolitiondebris would be disposed of with the contaminatedsoil. The volume of building materials to bedemolished is estimated to be 1,400 cubic yards.During excavation and demolition, short-termprovisions to prevent dust generation and protectworkers would be required. The estimated time todesign and construct the remedy is from one to twoyears.

G-3B: Decontamination, Demolition and Disposal


$1,736,56C$C

$1,736,5601 -2 yean


This alternative essentially would be the same as 3 Aabove, except that the demolition of the buildingwould proceed in steps. First, the wood structuralmaterials and roofing would be removed. This debriswould be disposed of with the contaminated soil andis estimated to be approximately 450 cubic yards.The remainder of the building (approximately 950cubic yards of primarily masonry and concrete) wouldthen be decontaminated using pressure washingbefore demolition. The building would then bedemolished and the debris would be crushed and sentoff-site for disposal. The estimated time to designand construct the remedy is from one to two years.

EVALUATION OF REMEDIAL ALTERNATIVES"

Each of the above alternatives was evaluated againstspecific criteria on the basis of the statute ryrequirements of CERCLA Section 121. Nine criteriaare used in evaluating the alternatives. The first twocriteria are threshold criteria which must be met byeach alternative. The next five criteria a . theprimary balancing criteria upon which the analysis isbased. The final two criteria are referred to asmodifying criteria and are applied, following thepublic comment period, to evaluate state andcommunity acceptance.

A comparative analysis of these alternatives, basedupon these criteria, is presented below.

Overall Protection to Human Health and theEnvironment

The No Action Alternatives (W-l, V-l, G-l) wouldnot be protective of human health and theenvironment because the Site would remain in itscurrent contaminated condition. Therefore, the NoAction Alternatives have been eliminated fromconsideration and will not be discussed further.

Under the Engineering Controls Alternatives (W-2,V-2, G-2), potential ex-.sure routes of gammaradiation would be sh: -d by concrete and/or steelsheeting. The shieldir... >uld have to be maintained,and institutional controls, such as deed restrictions,

GLOSSARY OF EVALUATION CRITERIA

Threshold Criteria

Overall Protection of Human Health and the Environment: Thiscriterion addresses whether or not a remedy provides adequateprotection and describes how risks are eliminated, reduced orcontrolled through treatment, engineering controls orinstitutional controls.

Compliance with Applicable or Relevant and AppropriateRequirements (ARARsV This criterion addresses whether or nota remedy will meet all of the applicable or relevant andappropriate requirements of other environmental statutes orprovide grounds for invoking a waiver.

4

Primary Balancing Criteria

Long-Term Effectiveness and Permanence: This criterion refersto the ability of the remedy to maintain reliable protection ofhuman health and the environment over time once cleanup goalshave been met.

Reduction of Toxicitv. Mobility and Volmr. -outTreatment: This criterion addresses the anticipated performanceof the treatment technologies that a remedy mz\ employ.

Short-Term Effectiveness: This criterion im..time needed to achieve protection and any achuman health and the environment that ma> n.construction and implementation period unti :achieved

• • s the period r

— ? impacts o_posed during the

:eanup goals are

Implementabilitv: This criterion examines the technical andadministrative feasibility of a remedy, includ..-.<_ availability ofmaterials and services needed to implement a particular option.

Cost: This criterion includes capital, operation and maintenancecosts, and net present worth.

Modifying Criteria

State Acceptance: This criterion indicates whether, based on itsreview of the Rl/FS reports and the Proposed Plan, the Stateconcurs with, opposes, or has no comment on the preferredalternative.

Community Acceptance: This criterion will be addressed in theRecord of Decision following a review of the public commentsreceived on the Rl/FS reports and the Proposed Plan.

EPA Region 2 - Februan -' J9 Page 16500081

would be required to ensure that these alternativesare protective.

For the Excavation and Off-Site Disposal Alternatives(W-3, V-3, G-3), all radiological contamination abovecleanup standards would be removed and disposed ofoff-site in a licensed disposal facility. Institutionalcontrols would not be necessary. All unacceptablerisks to human health and the environment would beeliminated by the excavation and off-site disposal ofthe radiologically contaminated waste.

Compliance with Applicable or Relevant, andAppropriate Requirements

Actions taken at any Superfund site must meet allARARs of federal and state law, or provide groundsfor invoking a waiver of these requirements. Thereare three types of ARARs: action-specific, chemical-specific, and location-specific. Action-specificARARs are technology or activity-specificrequirements or limitations related to variousactivities. Chemical-specific ARARs are usuallynumerical values which establish the amount orconcentration of a chemical that may be found in, ordischarged to, the ambient environment. Location-specific requirements are restrictions placed on theconcentrations of hazardous substances or theconduct of activities solely because they occur in aspecial location.

For the Welsbach/GGM site, no requirements areapplicable for the cleanup of the radiologicalcontamination. However, as discussed earlier,portions of the federal regulations governing thecleanup of uranium mill tailings from inactive uraniumprocessing sites, at 40 CFR 192, have beendetermined to be relevant and appropriate. Theseprovide the radon decay products standard of 0.02WL and soil cleanup criteria of 5 pCi/g. In addition,waste materials produced at the former WelsbachFacility would be considered "by-product" material asdefined by Section 1 l(e)(2) of the U.S. Atomic

Energy Act (AEA).3 Since Welsbach processedmonazite ores to extract thorium. EPA hasdetermined Section 1 l(e)(2) of the AEA to berelevant and appropriate. Because the wastematerials from the Welsbach Facility and itsoperations are an AEA Section 1 l(e)(2) wastematerial, they must be disposed of at a licensedfacility in accordance with AEA requirements.

The Excavation and Off-Site Disposal Alternatives(W-3, V-3, G-3) would comply with all ARARs. Allcontamination above the 40 CFR 192 cleanupstandards would be excavated and sent off-site fordisposal. The Engineering Controls Alternatives (W-2, V-2, G-2) would comply with all ARARs that limitexposure to gamma radiation and radon. However.the Engineering Controls Alternatives would notcomply with 40 CFR 192, because the contaminatedmaterial 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. Thecontaminated material would be removed from theSite and stored in a controlled, licensed facility.

The long-term effectiveness of the EngineeringControls Alternatives W-2 and V-2 would beuncertain. Contaminated material would remain inplace, and the engineering controls would requiredeed restrictions and long-term monitoring. Inaddition, the engineering controls would have to bemaintained forever because the half-life of thorium is14 billion years.

Alternative G-2 (Engineering Controls for GeneralGas 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 radioactiveby exposure to the radiation incident to the process ofproducing or utilizing special nuclear material, and (2) thetailings or wastes produced by the extraction or concentrationof uranium or thorium from any ore processed primarily for itssource material content.


500082

because of the dilapidated nature of the building, evenif the building were completely sealed.

Reduction of Toxicirv. Mobility, or Volume ThroughTreatment

No treatment technology is known today that cansubstantially reduce the toxicity, mobility, or volumeof radioactive materials found at the Site, and meetthe 40 CFR 192 cleanup standards. The total amountof radioactivity cannot be altered or destroyed, as isoften possible with chemical contaminants.Therefore, none of the remedial alternatives fullysatisfy this evaluation criteria.

However, the Excavation and Off-Site DisposalAlternatives (W-3, V-3, G-3) would lead to somereduction in the mobility of the material becauseradioactive contaminated materials would becontained in a secure landfill cell. Alternative G-3with Option B (the General Gas MantleDecontamination and Demolition Alternative) wouldreduce the volume of contaminated building debris tobe disposed of off-site by pressure washing theradioactive contamination off the floors and wallsbefore demolition. The contaminants would beconcentrated in the filtrate after pressure washing.Only this filtrate would have to be disposed of in alicensed facility.

Short-Term Effectiveness

Both the Engineering Control Alternatives (W-2, V-2. G-2) and the Excavation and Off-Site DisposalAlternatives (W-3, V-3, G-3) provide effective short-term protection, and become effective as they areimplemented at individual properties. The estimatedtime to design and construct the remedial alternativesfor the former Welsbach Facility (Alternatives W-2and W-3) and the Vicinity Properties (AlternativesV-2 and V-3) is from three to five years. For theformer GGM Facility, the estimated time to designand construct the Engineering Control AlternativeG-2 is from two to three years, and for the Off-SiteDisposal Alternative G-3 from one to two years.

The Engineering Control Alternatives involve lessintrusive activities, and pose less of a threat toworkers and the surrounding community than theExcavation and Off-Site Disposal Alternatives. ~"However, both the Engineering Control Alternativesand the Excavation and Off-Site Disposal Alternativesinvolve intrusive activities, including, in some cases.temporary relocation of residents.

The Excavation and Off-Site Disposal Alternativeshave a greater potential adverse impact in the shortterm because of the excavation of radiologically-contaminated soil. For future workers, this couldlead to increased short-f.erm exposure to ration,gamma radiation, and soil radionuclides. Dustsuppression techniques and/or other measures wouldbe required to minimize the impacts of thisalternative. However, under Alternative V-2(Engineering Controls for the Vicinity Properties),there would be some increased short-term risk toworkers during the installation of the radon mitigationsystems. This is due to the need to excavate underthe foundation of homes that require radonmitigation.

Implementabilitv

The Excavation and Disposal Alternatives (W-3. V-3,G-3) are readily implementable. Similar activitieshave been utilized at other radiological ly-contaminated sites around the country. There is anavailable off-site disposal facility, which is accessibleby both truck and rail. However, the continuedavailability of this off-site disposal facility is requiredfor implementation of these alternatives.

Implementation of the Engineering ControlsAlternatives 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 ofall of the property owners to restrict future work ontheir properties. EPA would have to reachagreements with individual property owners to fileDeclarations of Environmental Restrictions i.e., deedrestrictions) on their properties. For Alternative G-2(for General Gas Mantle), it would be difficult to


keep the building permanently sealed fromtrespassers.

Cost

Alternative V-2 includes construction costs of$900,000 to implement engineering control measuresat the Vicinity Properties. Annual O&M costs areestimated to be $99,000. The present worth cost ofAlternative V-2 is $1,810,000, with O&M costsassumed for 3'"- years. Alternative W-2 includesconstruction coats of $5,690,000 to implementengineering control measures at the former WelsbachFacility. Annual O&M costs are estimated to be$44,000. The present worth cost of Alternative W-_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 theGeneral Gas Mantle Facility. Annual O&M costs areestimated to be $23,000. The present worth cost ofAlternative G-2 is $381,000, with O&M costsassumed for 30 years. The radionuclides in questionhave half-lives far greater than 30 years, so any of theEngineering Controls remedies must be maintainedeffectively forever.

Alternative V-3 includes construction costs of$13,408,560 to excavate the radiologically-contaminated soil at the Vicinity Properties anddispose 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 anddispose of the waste at an off-site disposal facility.Alternative G-3 - Option A involves constructioncosts of $2,309,560, and includes demolishing theGeneral Gas Mantle building and disposal of all thebuilding debris at an off-site disposal facilityAlternative G-3 - Option B involves constructioncosts of $1,736,560, and includes decontaminatingthe General Gas Mantle building before itsdemolition. There are no O&M costs associated withthe 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 theProposed Plan.

Community Acceptance

Community acceptance of the preferred alternativeswill be evaluated after the public comment periodends and will be described in the Record of Decisionfor the Site.

PREFERRED ALTERNATIVE__________Based on the information available to evaluate theremedial alternatives against the nine criteria, EPArecommends the Excavation and Off-Site DisposalAlternatives (V-3, W-3, and G-3 with Option B) asthe preferred alternatives for the cleanup of thecontaminated soil and building materials at the Site.

Rationale for the Preferred Alternatives

For each of the three property types, EPA's preferredalternative is the excavation and off-site disposalalternative. Alternatives V-3, W-3, and G-3 withOption B are the most protective alternatives.

The radioactive half-life of thorium-232, the primarycontaminant of concern, is 14 billion years. Remediesthat would isolate wastes containing thorium and theuranium series radionuclides permanently from thepublic and the environment are preferable.

Alternatives V-3, W-3, and G-3 result in a permanentsolution to the radioactive contamination. Thelongevity of these chemicals of concern (thousands tobillions of years) favors excavation whichpermanently removes the contaminants from theircurrent uncontrolled locations. Commercial disposalat a licensed facility with an appropriate closure planwill ensure that these radiological wastes arepermanently isolated from human and ecologicalreceptors. The Excavation and Off-Site DisposalAlternatives are considered implementable and will


result in a remedy that is highly effective in the long-term. These remedies are also consistent with theremedial 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 radioactivitygreater than 5 pCi/g are disposed of in a licensedradiological waste disposal facility. The technologyand equipment to perform the remedial action arereadily available. Implementation of Alternatives V-3, W-3, and G-3 would allow for unrestricted futureuse of all affected properties. The EngineeringControls Alternatives (V-2, W-2, and G-2) wouldrequire deed restrictions and long-term monitoringessentially forever because of the extremely long half-lives of the radiological contaminants. Thus, EPAbelieves excavation and off-site disposal of theradiological contamination represents the most viablecleanup alternative.

The preferred alternatives will provide the bestbalance of tradeoffs among alternatives with respectto the evaluating criteria. EPA believes that thepreferred alternatives will be protective of humanhealth and the environment, will be cost effective, andwill utilize permanent solutions and alternativetreatment technologies or resource recoverytechnologies to the maximum extent practicable.

NEXT STEPS_____________________

After EPA has presented the preferred alternative atthe public meeting and has received any commentsand questions during the public comment period,EPA will summarize the comments and provide itsresponses in a document called the "ResponsivenessSummary." The Responsiveness Summary will beappended to the Record of Decision, which willdescribe the final alternative selected by EPA andprovide EPA's rationale for that selection.

EPA Region 2 - February 1^99 Page 20500085

MAILING LISTADDITIONS

If you know of someone who is not receivinginformation and would like to be placed on the

mailing list for the Welsbach/General Gas Mantle ContaminationSite, call Ms. Natalie Loney at (212) 637-3639, e-mail her at

[email protected], or fill out and mail thisform to:

Ms. Natalie LoneyCommunity Relations Coordinator

U.S. Environmental Protection Agency290 Broadway, 26th FloorNew York, NY 10007-1866

Name _________________Address

TelephoneAffiliation^


500086

Superfund Fact Sheet

Welsbach/General Gas Mantle Contamination SiteGloucester City/Camden, New Jersey

xv ERAFebruary

INTRODUCTION

This summary highlights the U.S. EnvironmentalProtection Agency's (EPA's) Proposed Plan for thecleanup of contaminated soils and building materials atthe Welsbach/ General Gas Mantle (Welsbach/GGM)Superfund site in Camden County, New Jersey.

Investigations at the Welsbach/GGM site have shownthat some commercial, residential, and publicproperties located in the Camder and Gloucester Cityarea contain soil contaminated to varying degrees withthorium, radium, and uranium.

These contaminants are radioactive and associatedwith waste materials generated in the manufacturingactivities that took place at the former Welsbach andGeneral Gas Mantle facilities. Both facilities usedradioactive elements, specifically thorium, in theproduction of gas mantles, were used for lightingpurposes in the late 19th and early 20th centuries.Radium, uranium and thorium are associated withmantle production process.

Radioactive elements such as thorium, radium oruranium are unstable and as a result release energy.Thorium releases energy in the form of alpha particles,beta particles or gamma radiation. This radioactivedecay also forms radon gas.

Radon gas is odorless, colorless and tasteless and canbe harmful if people are exposed to it over many years.Gamma radiation also may pose health problems topeople who come in contact with the wastes over longperiods of time.

WELSBACH/ GENERAL GAS MANTLE SITE

The Welsbach/GGM site is comprised of propertieswithin the following six study areas:

Study Area One: a mixed industrial, commercial, andresioential zoned section of Camden which includesthe former GGM facility and residential and commercialproperties which surround the facility.

Study Area Two: an industrial zoned property inGloucester City along the Delaware River, formerlyoccupied by the Welsbach Corporation and aresidential area to the immediate east.

Study Area Three: residential and recreationalproperties in Gloucester City, including the JohnsonBoulevard Land Preserve.

Study Area Four: residential properties in the Fairviewsection of Camden.

Study Area Five: residential properties, vacant landproperties, and two municipal parks near Temple Avenueand the South Branch of Newton Creek in GloucesterCity.

Study Area Six: vacant lots in a residential zoned areaof Gloucester City.

Mark Your Calendar

Public Meetings:

Gloucester CityPine Grove Fire Station #2

onTuesday, February 23,1999 at 7:00 p.m.

CamdenCamden County Municipal Utilities Authority

Auditoriumon

Wednesday , February 24,1999 at 7:00 p.m.

Availability Sessions • informal question andanswer sessions:

Gloucester CityPine Grove Fire Station #2 onTuesday, February 23,1999

1:00 - 4:00 p.m.;

CamdenCamden County Municipal Utilities Authority

Auditorium onWednesday February 24,1999

1:00 -4cQOp.m.

The public comment

nron thee proposed

llacch3,i

500087

REMEDIAL INVESTIGATION AND FEASIBILITYSTUDY

In 1997 ERA began a remedial investigation andfeasibility study (RI/FS) to determine the source andextent of radiological contamination in the Camden andGloucester City area and to evaluate cleanupalternatives. The areas investigated during the RI/FSincluded the former Welsbach facility, the former GGMfacility, and 20 of the radiologically contaminatedproperties identified during earlier investigationsconducted by the New Jersey Department ofEnvironmental Protection (NJDEP). The findings ofthe remedial investigation were then used to prepare afeasibility study, which evaluates cleanup alternatives.

THE PROPOSED PLAN

In addition to the RI/FS, ERA has prepared a ProposedPlan for the Welsbach/GGM site which identifies EPA'spreferred cleanup alternatives for the radiologicallycontaminated properties. The alternatives which wereevaluated include: No Action; Installation ofEngineering Controls; and Excavation and Off-SiteDisposal of Contaminated Materials.

EPA's preferred alternative is Excavation and Off-siteDisposal of Contaminated Materials. This alternativecalls for the removal and off-site disposal ofradioactively-contaminated soil. The excavated areaswill be backfilled with clean soil. Where necessary,contaminated building material will be removed andreplaced with clean material. Removal of contaminatedof soils and building materials will eliminate potentialgamma radiation and radon exposure through variouspathways (ingestion, inhalation, dermal contact, etc.).

The planned response action for the former GGMbuilding, is decontamination, demolition, and off-sitedisposal of contaminated materials. All contaminatedmaterial will be taken to an approved off-site disposalfacility.

The estimated volumes of contaminated material fromthe 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 estimatedto be $13,408,560, $18,503,560, and $1,979,560 forthe Vicinity Properties, former Welsbach facility, andformer GGM facility, respectively.

While some of the activities proposed for site cleanupmay be disruptive to individual homeowneis or thecommunity, EPA will work with affected residents and thecommunity to ensure a safe and quick cleanup of thesite.

EPA relies on public input to ensure that the concerns ofthe community are considered in selecting an effectiveremedy for each Superfund site. To this end. EPA hasmade the RI/FS report, Proposed Plan, and supportingdocumentation available to the public for a publiccomment period from February 1, 1999, to March 3.1999. EPA considers all public comments beforeselecting a final cleanup plan. For more informationplease contact: Natalie Loney. Community RelationsCoordinator at (212) 637-3639 or Rick Robinson, ProjectManager at (212) 637-4371.

The RI/FS report which presents the results of fieldinvestigations conducted to date at these properties hasbeen completed. Copies of the RI/FS report. ProposedPlan, and supporting documentation are available atEPA's offices at:

290 Broadway, 18th FloorNew York, NY10007-1866

(212) 637-4308

and at the following repositories:

City of Camden Main Library418 Federal StreetCamden, NJ 08103

(609) 757-7650

Hynes Center1855 South 4m StreetCamden, NJ 80104

(609) 966-9617

Gloucester City Public LibraryMonmouth and Hudson Streets

Gloucester City, NJ 08030(609)456-4181

SUMMARY

The Proposed Plan presents EPA's preferred remedy forthe cleanup of contaminated properties which are part ofthe Welsbach/GGM site. EPA proposes to excavatecontaminated soil and waste materials; decontaminate(as appropriate), demolish, and remove contaminateddebris and building material; dispose of thecontaminated soils and waste materials in a licensed off-site disposal facility; and restore the affected propertieswith clean fill. The proposed remedy would provide apermanent cleanup response and would be protective ofhuman health and the environment.

500088

Appendix B

Public Notices

500089

.Torn, 19.

Proof of Publication of Notice h The Pliaddphia hqunrUna** Act No. 1*0, fJL. 977, My 9, 1976

Commonwealth o/ PennsylvaniaCounty of Philadelphia ss.:

..............£.-... C iP.f.-J.an.o.................... being duly sworn, depots and say* that THE PHILADELPHIAINQUIRER is a daily newspaper published at Broad and CaJlowhill Streets. Philadelphia County. Pennsylva-nia, which was established in the year 1829. since which date said daily newspaper has been regularly publishedand distributed in said County, and that a copy of the printed notice of publication is attached hereto exactly ••the same was printed and published in the regular editions and issues of said daily newspaper on the followingdates, viz.:

and the...........................day of.February ..A.D.

9919..........

Affiant further deposes that he is duly authorizedby Philadelphia Newspapers, Inc., a corporation,publ isher of THE PHILADELPHIA IN-QUIRER, a daily newspaper, to verify the forego-ing statement under oath, and also declares thataffiant is not interested in the subject matter ofthe aforesaid notice or publication, and that allallegations in the foregoing statement as to time,place and character of publication are true.

U

Sworn to and subscribed before me this........f.5.

day of ......Feb.?.1}.*.*.?.

'ary Public.

My Commission Expires: NOTARIAL SEALMargaret C. Ruchalski. Notary Put*c

City of Phttsdetphia. Ph«a. CountyMy Commission Expires Mty 27. 200°

Copy or itofico or

f •- 'Z *>, t^fUBUC MEETING .-'.".. -. ~-r •'*» •-.Propoaao- Plan to be Olecusssd for WeWMck/Oofteral' . Oao Mantle Contamination Superfund SHe . '

-. Cemdsn/Olouoeeier City. New JerseyThe United Statae Environmental Protection'Agency(EPA) will hold Two Informational public meetings to die*cuss the f Indlnga of a recently completed remedial Inves-tigation and teealblllty study (RI/FS). and announce theproposed remedy for the cleanup of residential and otherproperties which comprise the Wetabacn/Generai Oa»Mantle Contamination Supertund site. The RI/FS waaconducted to determine the source and extent of radia-tion contamination In the area and to evaluate cleanupalternatives. The first public meeting to discuss the flncl-

. .,•- -Mth* Pine QroveFtre Station «>.

f̂ toeated at Ninth end Jereey Avenue

"heaecond meeting will be held on:. .

at the Camdan County trinity Aulnomy* emlttui IMHI. loealed at 1B46 Ferry Avenue In Camden, New Jaraey .• - • t*-r.-fc-f.w\ ,v..r.* . - • >-- .. - -,The RI/FS evaluated three altematrvea for addreealno ra-dlologlcaUy contaminated eoll and atructural material*.

.1 2) Englnaertng and Inatttutlonal Convota '̂ -̂'r*- • .: I' 8) Excavation and Off-Site Olipoaal < - • • > • - . " . ; • -EPA'a propoaad cleanup remedy la Alternative 13. theExcavation and Off-She Olepoaal Alternative. Under tMaalternative.' the radiological contaminated materialwould be removed and tranaported off the alte for dt»-poaal. All of tha aoove aiterativea are outltnad and die-

on' public Input to anaure that the concern* of- ihe community are conaidered In aaiactlog an effectiverr»rneo> for each Superfund eite. To thla and. EPA naa

made1 the RI/FS rapon, Propoaad Plan, and aupportlngydocumantailon available to the public for a public com-'ment. parted from Feoruary 1. IM* to IMoren 3. IBM.Com men ta muat bo received on or before March 3. ia«a.The final declalon document will Include a summary ofpublic commenta and EPA reaponaaa. Coploa of theRI/FS report. Propoaad Plan, and aupponing documen-tation are available at EPA-a office at 20O Broadway. 1 ethFloor. New YorK. NY lOOO7-18Be. (212)837-4308. and atjjhalonowtnalnK — . . . . . .

City of Camderi>«18FederaJ Street

_.__ _. . _ _ _ _ .Written commenta on tna Propoaad Plan should be aont

RlchardJ. Roblnaon-oreall Natalia Loney -U.S. Environmental , U.S. Environmental u .",Protection Agency -•• -. Protection Agency ~: 20O Broadway. 1 atn Floor - - 2BO Broadway. 28th Floor 'NMVOTK. NYirmn7.iaee NewYorK.NY 1OO07-1888

____(212)837-383?________

500090

i.

' PUBLIC MBBTINO •' i transported off the site tor,•Proposed Plan I* be Dls-> disposal. All of the above ol-i—1 fussed for Welsboch/a*n>t ternallves ore outlined and! iui «ro1 <•«» Mantle * • • / •» discussed In the Proposed t

Contamination Juperteftd*. Plan. EPA relies on public,," • Cite •'- • •' .«") Input to ensure that the con-! iGarnde n/Oloucester, Clrv<>. corns ol the community are,)! ••*". . . New Jersey. ,<WuLu considered In selecting on nf <• • '• '•'•*^v$ effective remodr tor each> The United State* Environ-: Supertund site. To this end,.)

.mental Protection Agency EPAhasmodemeRI/FSre-iI . (EPA) will hold two Infer- port. Proposed Plan, and)i * motional public meetings 1*1 supporting documentation[ .dfacusl the findings of a re- • available to the Public for a ti lAtntly completed remedial public comment period!

investigation and feasibility* from PEBRUAHY1, IWIo ,.'iA<udy (RI/PS). and an- '.MARCH 3. im. Comments'

, «jt*vnce the proposed rente-; must be received on or be-, j«*fi for the cleanup of resIA tore MARCH 1 l»t». The fl-f•«*entlal and ether properties; not decision document will I

which comprise the Wels-i Includeaeummoryetpubllcj' bach/Oeneral Oos Mantle' comments and BPA re-f

[ Contamination fuperfund (ponset-CoplesoftheRI/FS!-»lle. The RUPt was eon,-; report. Proposed Plan, and)

ducted to determine the supporting documentation I'Jourc* and extent of radio-' are available at ERA'S of- J

' Tlon contamination In the or- flee at JtO Broadway., llth ':'. .ea and to evaluate cleanup•. Floor. New York. NY*

blternatlves. The tlrst pub-. 10007-ltit. (212) 437-430M.lie meeting to discuss the and at the following Infer

I will be held oni^* motion repositories: <lcitv»i

•- I'Jrt the Comde'n County Utlll-,.;;fy Authority's auditorium.',!• r , - • • • • < *'Jbcoted at IMS Perry Ave^ written commends on the*

; riii* In Camden, New Jersey;, f Proposed Plan should bajlJheRf/FS evaluated three' sent to: . - . » , ! . y,,/3

• alternatives for addrasslnd (Richard J. Robinson • *' '

s. They are:•*!.' No action ' ...i. Engineering and ' •;l«""Olhslltutlonol Centrals ' J **':5. Excavation and '.' ',' ".£'Off-SiteDisposal ' ' •"i^PA's proposed cleanupremedy Is Alternative »3.4t>e Excavation and Off-SiteDisposal Alternative. Under

iithls alternative, the radio-logically contaminated ma-1 ferial would be removed and

99

'logically contomlnot'',U.S. Environmental Protect ,•d soil and structural mate-. lion Agy. , , ... .„ rid*tal. Th.v or.-'•-T .-..,- 2M Broadway, Itth Ft. ..,.«•••

New York, NY 10007-tMe ,,OR CALL: NATALIE LO- „NEY .,9U.S. Environmental Protec-tion Agy. , . •no Broadway, 26th Fl. ''/New York, NY 1»M7-IMe , , „ =-,(212) A37-3*3e : \Puthe

un»Qt

STATE OF NEW JERSEY

CAMDEN COUNTYss

OOOIT)

S. Butlerof full age. being duly sworn, according to law. says that he/she Isbookkeeper of the

COURIER-POSTand that a Notice, of which the annexed Is a true copy, waspublished dally in the COURIER-POST, a newspaper printedand published daily In the county of Camden. State of NewJersey.

once on the .............2nd. ................ EEb...9.9........

281239 084021 #34827 1

MALCOLM PIRNIE I NCINTERNATIONAL BATTNJ BOB KEMAHMAH NJ 074

(ERE

•ERSEV tOM/SM

GLOUCESTER OTY NEWS. THURSDAY FEBRUARY •» :99Q

A1| rode from Momgomerv to case on behalf ot a female P ""• ' !c tn>l "liege o u r a t h l e K - - . i i s t o n i . r u . .All Sclma „,, fln,nv ,0 Mcn> Jlnjele Sbf w q(UK scouu wiiti those scholar, and ncn »ilh lema.c star<GirlS... phis with Or Mamn Lu- blunt and to the point snips in tneir rockets car. The iampsrn s is te rs

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Vema Williams works Women's Final Four in and. by all means. rfrmW (Hanging world of the sir! Please ceieprate theirfor the National Women* March. She. too. is a win- that vou plav some of your athlete in Amenca nch and proud Rision rnLaw Center As a teen she ner. having never lost a games in prime nme 1 8:00 "Flrst parents and supporting sins m >rvns

coaches must a i w a v s real ihe iov.ii i e \ e . > JL

j«t Oito HAMBLETON-STEWART REALTORSm HJMMIM 28 S Broadway. 64oucerter City»*T »«T" 456-3144*"l"y Girwini Serving fh« area since 1898NicMk DiMMMwir you'll sec »>ons of us cvervwhereNI

member that the courts Jon l need uie L oncresiStsfny Uivp have alreadv answered or the Supreme Court sHid**!* rartwf almost any obstacle a help. 11151 cet oul ot vou:Wifiw Santfi school or administrator easvchair and go 10 3Mil (xwor may throw at an individual game

athlete or team. Alwavs be Yes' Without question.

CLOl'CESTZH CITY 3 bedrooms, beautiful move-in condition home w-remodeled »,„, ̂ Knool or schoo, lcmaic spons iei!en0ibath w- fiberglass shower wsliding doors, plenty of natural wood cabinets. L-counter » board first listed above Wh\ notlazy susans. ss sink, newer w,w in living room, stairs & hall. 1" floor laundry', master ..Q,, ,' cornm,n« 0, , plcasc ^c u,t Iune tobedroom »-dual closets $59.900 pennon together and be »we the V»< i note andGLOUCESTER CITY 3 bedrooms, 1 ", bath, beautiful hardwood floors & chestnut respectful vet firm celebrate a local femalemm. 3 ceiling fans, modem kitchen w,dbl stainless steel. L-counter & rut wood cabi- Frankly, there's no need athlete that we ve over-nets, new dishwasher, garbage disposaL security system, central atr. microwave, pano. for mgcr tra,^ vour looked and not listed to-fenced yard, storage bam. move-in condinon. Only J74.900 Sldc a holding four aces dav Tell us their storvGLOUCESTER CITY 3 bedrooms, great opportunity! Huge detached home only m "Slav calm and be pa- ^" êws addmi u POneed of cosmetic TLC. 2 possible bedrooms on 3 floor. New heater, remodeled batfa w.' veni, giving parents the Box lit Gloucesttr Cm. \Jplumbing fora 1" floor bath, pvc sewer line. 3yrs main roof & lyr kitchen roof entrance „„, around has been the 01010foyer, possible 203k Only $57.900 normal routine. However. Talljlhan'sDEPTFORD NEW LISTING 1 bedroom, new windows, newer carpets, ss sink, new wncn school adnuni- *-<"'«»»«an 5>range, immaculate condition, newer central air compressor, one piece fiberglass rub. stranons inevitablv find pTCC ThfOWSshower storage room with unit. Only $45.900 „„, ;),,, you've educatedGLOUCESTER CITY NEW LISTING 3 bedrooms, 1 '/, bath, new carpets on 1" vourselves about Title LX WlD In O.T.floor, siairs 4 hall way, 1 piece fiberglass rub/shower, windows seat in kitchen, privacy and the Office of Civil M E B A acnon for thefenced rear yard, storage sheds, floored attic ceramic nle foyer. 20x14 concrete pal 10. R.ghts. meetings begin to week of Jan ^th In theexce l len t condition, whole bouse fan $79.900 ^WKV and progress is Jun,or division in whatCLOl TESTER CITY 2 bedrooms, modern kitchen w/oak cabinets and newer range. achieved." was the game of the vearbeautiful condition. .' ceiling fans, newer heater and GHW heater, tenant pays all unli- ^ ]Ooo me female so far. U Conn, down bv 'lies including sewer Addmonal appliances negonable. $575 permontb. call for more athlete has arrived in points late in the 4th

Amenca and she's not go- quarter, tied the game on a

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3) Excavation and Off-she Dispoaal

<— »«.~i metacBl vnatdae mmnredaod Bananonod off the toe for dProposed Plan.

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PUBLIC MEETINGrnf,,,t ru> M kt Diicuxd hr WAtoct/G<Mnl Gu M«MK

nnanonal public meennp to diacucs the findings of s recently conpleted remedialfor the cleanup of residential and other properties which uiiianist the Welsoach/

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ST. MARY'S SCHCXREGISTRATION

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/•'.*'&& -•.•dev*^ 500092 a

Appendix C

Transcripts of Public Meetings

500093

1

2

3

4

7

8

9

U.S. Environmental Protection Agency's (EPA's)

Proposed Plan for Cleanup of Superfund Sites5

Public Hearing6

February 23, 199810 _ _ _ _ - - _ - - - - _ _ - - - - -

11 Public Meeting of the U.S. Environmental

12 Protection Agency (EPA) held at the Pine Grove Fire

1) station #2, Gloucester City, New Jersey, before

1* Linda A. Burns, Shorthand Reporter and Notary Public

10 of the State of New Jersey, on the above date,

16 cornmencing at 7:00 p.m.

17

18

19

20

21

23

24

D E G N A N & B A T E M A N , I N C(609) 547-2565 500094

1 EPA MEMBERS IN ATTENDANCE:

2 Richard J. Robinson, Project ManagerPat Evangelista, Team Leader

3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch

4 MALCOLM PIRNIE REPRESENTATIVES IN ATTENDANCE:

5 Robert Kerbel, AssociateAlan Fellman

6ATSDR REPRESENTATIVES IN ATTENDANCE:

7Arthur Block, Sr. Regional Representative

8ALSO PRESENT:

9Bob Saunders, Emergency Management Coordinator

10I N D E X

11 Witness PageJohn Becks(ph) 50

12 Sue Marks(ph) 56,79Mike Grabowski 74,85

13 Unidentified Speaker 76Unidentified Speaker 88

14 Theresa Graham 91Ed German 92

15E X H I B I T S

16(There were no exhibits marked at this time.)

17

18

19

20

21

22

23

24

D E G N A N & B A T E M A N , I N C .(609) 547-2565

500095

EPA Public Meeting - 2/23/99

1 MS. CERVANTES-GROSS: I just wanted

2 to start by thanking all of you for coming

3 here tonight to talk with us about the

4 Welsbach/General Gas Mantle Superfund site

5 and post cleanup. We will be talking with

6 you about all of the cleanup here and will

7 be giving you different information about

6 the study that was done and the

9 alternatives that we have looked at as far

10 as what we are proposing.

11 Just to introduce people who are here

12 tonight from EPA and who are involved in

13 the cleanup, we have Rick Robinson who is

14 the project manager for EPA for this site.

15 Pat Evangelista is the team leader for us

16 at EPA and oversees all of the Superfund

17 sites in our region, New Jersey, and all

18 the sites that deal with radioactive

19 contamination.

20 Alan Fellman is with Malcolm Pirnie,

21 a contractor that works with EPA to

22 actually do the investigation and cleanup,

23 as well as Bob Kerbel who is also with

24 Malcolm Pirnie.

D E G N A N & B A T E M A N , I N C .(609) 547-2565 500096


1 And obviously, everyone here knows

2 Bob Saunders who has been doing so much

3 work with us and will be here long after

4 we're gone. And Artie Block is also here

5 from ATSDR, the Agency for Toxic Substances

6 and Disease Registry, part of the Federal

7 Department of Health and Human Services.

8 And ATSDR works with us on a consultation

9 basis and works with us closely to look at

10 these Superfund investigations that we do

11 and gives us information on potential

12 health impacts.

13 As well, I also wanted to introduce

14 Linda Burns who is the stenographer who

15 will be taking down all of the comments

16 that you make tonight. And that's why we

17 are here tonight, to hear from you, your

18 thoughts, your comments, your concerns.

19 And to take any questions you have about

20 what we will be discussir.g tonight and what

21 our proposed cleanup will be for the

22 contamination for the site.

23 And just to point out, my name is

24 Mary Helen Cervantes, I'm with EPA as



1 well. And I work in the area of Superfund

2 Community Relations. The Superfund program

3 stresses, as we do throughout all of the

4 programs, community involvement and

5 community participation. We feel we can do

6 a much better job by having you involved

7 and telling us what you hear, see and know

8 about the community, your community, in

9 which you live. You know what's happening

10 here a lot better than we do most of the

11 time. So again, that's why we are here

12 tonight, to hear your comments and

13 concerns.

14 In order for us to do that and to

15 make sure that we get everything down, if

16 you could, after we go through our

17 presentations, if you could hold your

18 questions until the end. We will try to

19 move through it as quickly as possible to

20 make time for questions.

21 When you have questions or want to

22 make a statement, state your name clearly

23 so that Linda can get that down and speak

24 up so we can get it all down. So at the

D E 6 N A N & B A T E M A N , INC.(609) 547-2565

500098

BPA Public Meeting - 2/23/99

1 end of the comment period, which ends on

2 March 3, which is next Wednesday, we'll

3 take comments on what we're proposing up

4 until next Wednesday. Afterwards we will

5 do a responsiveness summary, which we'll go

6 through all the comments and all cf your

7 concerns and we'11 write a summary

8 responsive to that. But what you say

9 tonight and whatever comments you have,

10 that will actually go into the official

11 record. So you don't have to write it down

12 afterwards. We'll take it down right here

13 as you say it.

14 I also just wanted to point out that

15 Natalie Loney, whom you may have met, works

16 with EPA and is the assigned Community

17 Involvement Coordinator for the site. So

18 I'm just sitting in for her today. She

19 just had a baby on Valentine's Day, but you

20 will see here throughout all of the other

21 meetings throughout the year. She is the

22 one who is assigned just to work with you

23 and to handle your questions and concerns

24 and to make sure you're involved as much as

D B G N A N & B A T E M A N , I N C(609) 547-2565 500099

BPA Public Meeting - 2/23/99

1 possible and we want you to be involved in

2 the process here.

3 Just a couple of things very

4 quickly. We have various project

5 initiatives that will help you understand

6 -- you'll see there's a lot of technical

7 information, but there are programs that

8 are available to help you understand the

9 technical information. And if anyone is

10 interested in those programs, I will talk

11 to you about those afterwards. They are

12 numerous. But just talk to me afterwards

13 if you'd like.

14 I'll now turn it over to Pat and Pat

15 is going to go through the Superfund

16 program in general.

17 MR. EVANGELISTA: Good evening,

18 ladies and gentlemen. Thanks for coming

19 out tonight and participating in our

20 meeting.

21 Just to reiterate a little bit of

22 what Mary Helen said, we highly encourage

23 all of you to come forward and identify any

24 comments, concerns or questions that you'd

D B G N A N & B A T B M A N , INC.(609) 547-2565

500100


1 like to nave answered. If not tonight, you

2 know, anytime in the near future. We'll

3 hand out business cards if you'd like and

4 feel free to call us at any time.

5 What I'm going to do now for you is

6 give you a little briefing on what

7 Superfund is about so that you maybe

8 understand better why we're here and what

9 kind of process we've been following and

10 are going to follow until we're done with

11 this particular site.

12 Back in 1980, Congress gave EPA the

13 authority under a law that's known to us as

14 the Comprehensive Environmental Response

15 and Liability Act. And then five or six

16 years later they amended that law to give

17 us what we currently have today. Our

18 process always beings with somehow an

19 identification to the agency that there's a

20 problem in a certain area. And that's what

21 you see up on the screen as the discovery

22 or CBRCLIS. The CERCLIS is simply a

23 program or process we use to track site

24 progress.

D B G N A N & B A T E M A N , I N C .(609) 547-2565

500101


1 Then we move into what's known as the

2 preliminary assessment or site inspection.

3 We go out and we try to ascertain, on a

4 preliminary basis, what kind of a problem

5 we're dealing with so that we can funnel

6 all of that information into a hazard

7 ranking system. Based on the hazard

8 ranking system we are able to rate that

9 problem or that site, if you will, and if

10 the score, based on the ranking, exceeds or

11 is higher than 28.5, which was somehow

12 selected very arbitrarily, the site ends up

13 on what's known as the National Priorities

14 List. This is a prioritization list that

15 the agency uses to deal with the sites that

16 are on it.

17 From the National Priorities List we

18 are then able to authorize federal money to

19 proceed into what is known as the Remedial

20 Investigation/Feasibility Study. The

21 Remedial Investigation/Feasibility Study is

22 a very detailed study of the problem or the

23 site or the properties, if you will.

24 Perhaps you've seen us out there taking


500102

10EPA Public Meeting - 2/23/99

1 soil samples. You may have seen our

2 contractors. You may be aware of our field

3 office.

4 So we've been gathering data on this

5 site for the past year or so. That data is

6 then analyzed to formulate alternatives

7 that we can further evaluate to identify

8 the preferred cleanup option to address the

9 contamination that's out there. Those

10 cleanup options are identified in the

11 Feasibility Study and the Feasibility Study

12 is used to generate the proposed plan.

13 The proposed plan -- I guess we went

14 public with it back on February 1 -- "went

15 public with it," meaning we identified it

16 in public notice, in the newspapers, for

17 your knowledge. It's available for your

18 review. We have copies of it here tonight

19 if you'd like a copy. And in that proposed

20 plan we proposed to you what we'd like to

21 do to clean up this site. And Rick will

22 get into a lot of that detail.

23 After the public comment period ends

24 we'll proceed into a Record of Decision,

D E G N A N & B A T E M A N , I N C(609) 547-2565

500103


1 after having considering all of your

2 comments and concerns. That Record of

3 Decision will formally identify the

4 cleanup. The cleanup will then be designed

5 under what's known as a remedial design.

6 That design will identify all of the

7 specifications that the contractor will

8 need to follow in order to clean up your

9 properties. That, in effect, is the

10 cleanup.

11 Once the agency has determined that

12 the cleanup has occurred pursuant to all of

13 the specifications, we give it a clean bill

14 of health, if you will, and we remove it

15 from the National Priorities List or delist

16 it from the NPL.

17 That essentially describes our

18 process. If you have any questions I'd be

19 happy to answer them for you later. At

20 this point I'll pass it onto Rick Robinson,

21 the Project Manager for the site.

22 MR. ROBINSON: Thanks again, Pat.

23 Just for background, the site is

24 located both in Catnden and Gloucester


500104


1 City. It comprises two former Gas Mantle

2 manufacturing facilitie some residential

3 properties, commercial properties,

4 municipal park lands and vacant land.

5 As part of the State's investigation

6 early on, in the early 1990s they divided

7 the site into a number of study areas. And

8 as we were going on with our investigation,

9 we followed along with their study areas.

10 The first one, Study Area 1, is the

11 General Gas Mantle Facility in Camden and

12 the surrounding properties.

13 Study Area 2 is the former Welsbach

14 Facility here in Gloucester City and the

15 surrounding properties.

16 Study Area 3 is the residential area

17 in Gloucester City, including the Johnson

18 Boulevard Land Preserve.

19 Study Area 4 is the residential area

20 in the Fairview section of Camden.

21 Study Area 5, the residential

22 properties and also some municipal parks in

23 Gloucester City.

24 And Study Area 6, some vacant

D E G N A N & B A T B M A N , INC.(609) 547-2565

500105


1 properties in the residential area in

2 Gloucester City.

3 Study Area l, again, the General Gas

4 Mantle facility in Camden. And there is a

5 photograph of the area with the General Gas

6 Mantle building highlighted (indicating).

7 There's a photograph of the General Gas

8 Mantle building on the corner of Jefferson

9 Street.

10 Study Area 2 is the former Welsbach

11 facility. It's now owned by Holt with the

12 Gloucester terminal. The Armstrong

13 building is the last remaining building

14 from Welsbach's operation. And the area in

15 pink right in here (indicating) is the

16 location of the former Welsbach building

17 that was demolished around 1975, 1976. And

18 that is the main contamination area on that

19 property. There's a photograph of the

20 Armstrong building as it is today. There's

21 the Walt Whitman Bridge in the background.

22 Study Area 3 is Gloucester City.

23 Gloucester City Swim Club is highlighted

24 and the Johnson Boulevard Land Preserve.


500106


1 Study Area 4, again, is the Fairview

2 section of Camden. And we only found a few

3 properties in this part of the site that

4 were identified as having elevated levels

5 of gamma radiation.

6 Study Area 5 is in Gloucester City

7 and includes the former Helsbach dump area

8 on Temple Avenue and contamination in the

9 park areas along Johnson Boulevard there.

10 And Study Area 6 is a newly

11 identified area and we call it the Popcorn

12 Factory. You can ask Bob Saunders as to

13 how that name came about. And there's a

14 photograph of the Popcorn Factory and

15 vacant lot. And the area in red is the

16 small area of contamination that we found

17 with radiological components.

18 Going to the site history now. In

19 about 1885 a Dr. von welsbach invented a

20 process using thorium to manufacture gas

21 mantles. For those of you who don't know

22 what a gas mantle is, you know in a camping

23 lantern, you can see over on the left

24 (indicating), and in a street light right


500107


1 here (indicating), that is the gas mantle.

2 And what they did is take a sock-like

3 material and they dipped it in the thorium

4 solution. And when it dried, it was lit.

5 And it produced a very brilliant white

6 light.

7 And in about 1890 Welsbach started

8 manufacturing the gas mantles here in

9 Gloucester City. And at the turn of the

10 century they were the world's largest

11 manufacturer of gas mantles. And by the

12 1940s they finally went out of business

13 when the electric light put the gas light

14 industry out of business.

15 In Camden, General Gas Mantle

16 manufactured gas mantles from about 1912 to

17 1941. They were a much smaller company

18 than Welsbach. They were a small

19 competitor. There is very little

20 information that we know about the Gas

21 Mantle's activities other than it used and

22 resold radium and thorium in the production

23 of gas mantles.

24 What we've termed vicinity properties

D E G N A N & B A T E M A N , INC.(609) 547-2565

500108


1 are all the other properties that we found

2 at the site, excluding the General Gas

3 Mantle facility and the Welsbach facility.

4 And they were contaminated as a result of

5 either disposal of the ore tailings from

6 the Welsbach operation or building debris

7 when buildings were demolished. Like when

8 they built the Walt Whitman Bridge, some of

9 the buildings were knocked down. Or from

10 former workers bringing contamination home

11 with them.

12 Previously the site was identified in

13 1980 during an archive search of the U.S.

14 Radium Site in Orange, New Jersey. And in

15 May 1981 EPA sponsored an aerial fly-over

16 where a helicopter flew over the area with

17 gamma detectors and was searching for gamma

18 radiation. And as a result of that the

19 State then conducted preliminary screening

20 surveys in the mid 1980s and in the early

21 1990s they investigated over a thousand

22 properties in both Camden and Gloucester

23 City.

24 And as a result of that they

D E G N A N & B A T B M A N , I N C .(609) 547-2565

500109


1 identified about 20 properties that needed

2 -- that they felt needed some more

3 immediate measures taken. And as a result

4 they installed some radon/thoron

5 ventilation systems in a number of homes.

6 They installed concrete or steel sheeting

7 on properties, in people's basements. And

8 they also purchased one property and

9 relocated the residents.

10 In 1992 the State also removed

11 radioactive material in the General Gas

12 Mantle building and relocated the current

13 occupant at the time, Ste-Lar Textiles, and

14 they sealed up the building to restrict

15 access.

16 The State's investigation -- they

17 base their surveys on just surface exposure

18 rates, indoor radon sampling and they

19 performed very limited surface soil

20 samples. However, they did not really look

21 in the subsurface at all. They made no

22 estimates on the amount or extent of

23 contamination and were just looking to

24 address the more immediate potential health


500110

IBEPA Public Meeting - 2/23/99

1 time. BPA's involvement at the site became

2 official when it was placed on the National

3 Priorities List in June of 1996. And then

4 that's when I was given the site and

5 started the investigation process.

6 Currently the General Gas Mantle

7 building is inactive and boarded shut.

8 Welsbach is currently owned by Holt and is

9 an active facility. And with the vicinity

10 properties, the immediate health concerns

11 were addressed either by the State's

12 remedial actions or by the BPA removal

13 action. Like what we did in the park in

14 December around the Ponytail(ph) Field.

15 And here's a photograph of the excavation

16 where we removed the top three feet of

17 surface contamination. We're hoping to

18 ship that material. It's being temporarily

19 staged around the Popcorn Factory and we're

20 going to ship that off in about three

21 weeks. Today we had somebody out there

22 sampling that material in preparation for

23 shipment.

24 Right now I'd like ~o turn this


500111


1 Right now I'd like to turn this

2 portion of the talk over to Alan Fellman.

3 And Dr. Fellman will talk to you a little

4 bit about the radiation issues. Thank

5 you.

6 MR. FELLMAN: My background is in

7 health physics and radiation sciences. So

8 I'm going to spend just a few minutes to

9 give you a few points about some of the

10 terminology and some of the components

11 regarding radioactivity that hopefully will

12 help you follow along with the materials

13 that you have been given to read and some

14 of the things that you're hearing tonight.

15 And then later on I'11 come back and have a

16 few words about the risk assessment that we

17 did, which is a component of the Superfund

18 remedial investigation.

19 You've already heard some terms

20 related to radioactivity. And I just want

21 to hit on some of the key ones. When we

22 measure radioactivity, when we want to

23 identify a quantity of radioactive

24 material, we need different units than what


500112

20BPA Public Meeting - 2/23/99

1 we're more traditionally used to because

2 we're not talking about a mass. He can't

3 describe the weight of the material, what

4 we're concerned about is the rate that

5 these atoms are decaying, undergoing

6 radioactive decay.

7 The term we use, the unit, is called

8 pico Curies. When we're talking about how

9 much is in dirt or how much is in water, we

10 express it as a concentration, pico Curies

11 per gram or pico Curies per liter of

12 water. Now this term is indicative of how

13 much. It does not really address what kind

14 of dose one received or what the risk is

15 from that material. The point being that,

16 ten pico Curies per gram of one type of

17 radioactivity might give someone a

18 different dose and have a different risk

19 associated with it than ten pico Curies per

20 gram of a different radioactivity.

21 When we talk about dose of radiation,

22 and that's really related to the risk, we

23 use a unit called millirem. And that's a

24 measure of the potential for biological

D B Q N A N & B A T B M A N , INC.(609) 547-2565

500113


1 effect as a result of that radiation.

2 Basically what we're measuring is energy

3 that is coming from the radioactivity that

4 is emitted from that radioactive material

5 and is absorbed in the biological tissues.

6 And that energy that's transferred from the

7 radioactivity to the tissues is the subject

8 of what could then ultimately lead to a

9 biological effect or a health effect.

10 Obviously, the greater the dose the

11 greater the risk. There are several

12 different types of radioactivity and you've

13 heard some of previous speakers say the

14 words thorium, radon, radium. All of these

15 are different elements that have

16 radioactivity associated with them. They

17 emit different types of radioactivity.

18 Alpha particles and beta particles

19 and gamma rays are the three more common

20 types of radioactivity and they're really

21 the ones that we're concerned about here.

22 They have different properties. Alpha

23 particles are relatively heavy. They

24 travel slowly and they are not penetrating,


500114


1 which means that they will not travel very

2 far. If they're emitted from surface soil

3 they will be stopped within one to two

4 inches of air. They cannot get through a

5 sheet of paper.

6 Beta particles on the other hand have

7 an intermediate amount of penetrating

8 ability. They're smaller than alpha

9 particles but they do have some mass

10 associated with them. So while they can

11 get through a sheet of paper, they will be

12 stopped by something like a piece of wood.

13 Gamma rays on the other hand are very

14 similar to X-rays. They have no mass

15 simply. It's simply packets of energy.

16 It's sometimes referred to as penetrating

17 radiation because it can travel fairly

18 significant distances through air, paper,

19 wood. And it takes a more dense media to

20 absorb that energy and stop the gamma rays

21 such as concrete or lead.

22 The problem here, by and large what

23 we're dealing with are what's known as ore

24 residues. The by-product of the thorium

D E 6 N A N & B A T E M A N , I N C .(609) 547-2565

500115


1 extraction processes that were implemented

2 by the Welsbach company who left them with

3 large piles of dirt which contained these

4 ore residues with elevated concentration of

5 radioactivity.

6 In this schematic here, the area

7 that's shaded in blue tends to show

8 potential areas with these elevated levels

9 of thorium. And if that were the case,

10 what you can get, radon gas which is

11 mobile, which can emanate from this dirt

12 into the indoor atmosphere. Fortunately

13 we've seen very little of that at the

14 Welsbach General Gas Mantle sites. Much

15 more frequently would be the case where

16 there would be some of this material in an

17 outdoor area where the influx of the gas

18 into an indoor environment isn't likely to

19 happen. But there the potential exposure

20 would be from the gamma radiation that's

21 emitted to an occupant who would be

22 occupying, that would get a dose of that

23 gamma radiation.

24 At this point I'm going to let


500116


1 Bob Kerbel speak for a few minutes. He's

2 been our Project Manager from Malcolm

3 Pirnie throughout the investigation and

4 he'll take you through some of the key

5 points in that investigation.

6 MR. KERBEL: I just want to give you

7 a little insight of the type of

8 investigation we did in the community so

9 you can kind of see everything in the

10 nutshell and see the type of work we've

11 been doing.

12 There are three areas we looked

13 into. Two of the industrial facilities,

14 the former Welsbach facility and the

15 General Gas Mantle facility. And then

16 there was the vicinity problem, basically

17 everything else. I assume most people here

18 are homeowners and your home would come

19 under that vicinity property category.

20 If there's anything good about this

21 type of work from our standpoint as

22 investigators it's that it's easy for us to

23 detect this type of contamination. It

24 gives off gamma radiation. So we basically


500117


1 walk over the property with meters similar

2 to this. And we might have come to your

3 property and walked over the property in

4 search for elevated levels of radiation. I

5 have a little meter here. And we'd take

6 those readings and walk over your entire

7 property.

8 Then if we find something we take

9 soil samples and test for radiological and

10 chemical contaminants. We only test for

11 chemical contaminants at industrial

12 properties because there's always a chance

13 that there could be some chemical

14 contamination just given the industrial

15 nature of those areas.

16 Once we find an area, we have to come

17 up with a volume, how much is there. So we

18 put a boring into the ground and these can

19 be either shallow or deep. The only reason

20 there's not a deep check mark under

21 vicinity properties is because we really

22 didn't have deep contamination on

23 residential properties. That was really at

24 the industrial sites that we needed to go a

D E G N A N & B A T E M A N, I N C .(609) 547-2565

500118


1 little deeper. And as Alan alluded to, if

2 there's soil contamination in the area,

3 that gives off radon gas that could get

4 into the household, so we test for that as

5 well.

6 On the industrial properties we also

7 do something called alpha/beta measurements

8 where we would actually sample structural

9 materials. Because sometimes we might run

10 into a question, whether it's the soil

11 under the building or the building material

12 itself that might be contaminated. So we

13 might test that.

14 This isn't too easy to see, but I

15 want you to use your imagination a little

16 bit. Let me try to get your eyes to focus

17 here. This is the former Welsbach facility

18 that was located along the Delaware River.

19 The Delaware River is up there on top, you

20 can see a smoke stack. And King street

21 would be at the lower end of the picture.

22 But if you could imagine, this is the early

23 part of the century. There's no DEP;

24 there's no environmental protection


500119


1 agency. The hazards associated with

2 radiation really aren't known yet. Things

3 like nuclear power are decades in the

4 future yet to come. And as Rick said they

5 made gas mantles here. Things like X-rays

6 that the doctor does now were still being

7 discovered at that time.

8 But at this facility, they brought

9 ore in. So basically on this facility

10 there was a pile of dirt that they would

11 extract the thorium from to use in these

12 gas mantles. So at the time it was really

13 a prosperous business until the electric

14 light bulb came into play and put them out

15 of business. But at that time the hazards

16 weren't really known.

17 In future years, in the last couple

18 of decades, we're more aware of the hazards

19 associated with radiation. So now someone

20 said, you know what, we should go back to

21 all these facilities that did this in the

22 early part of the century. Because the

23 sand that contained thorium, that could

24 potentially be radioactive. So we should

D E G N A N & B A T E M A N , I N C.(609) 547-2565

500120


1 go back to these facilities to see if,

2 indeed, there is radioactive material on

3 these sites.

4 So years later they come back to the

5 site but now there's no building here. The

6 circle is basically where the facility

7 would have been. So what we do is just

8 what I told you earlier, we walk over the

9 entire site and it takes a number of weeks

10 to do it because it's so large, and we look

11 for elevated levels of radiation. Because

12 at the beginning the thought is, if the

13 building is gone, it's conceivable that

14 they had these huge basements and they

15 knocked the building down and filled the

16 basement and then paved over it.

17 So we go over the entire site, we

18 look for the elevated levels and then we

19 bring them back to our office and we have

20 special programs that help us see what the

21 radiation levels are. Now this is a bird's

22 eye view looking down at this site now.

23 And wherever you see a colored area, those

24 are elevated radiation levels. That's a

D E 6 N A N & B A T B M A N , I N C .(609) 547-2565

500121


1 clear signal for us that there is

2 contamination on the site. And then we go

3 back and take soil samples to see that it

4 is thorium. And we do borings to see how

5 deep it is. Ballpark approximately ten

6 feet deep in locations.

7 Alan is going to come back and talk

8 more about risk, but I just.want to give a

9 little perspective to it. When we do this

10 work it's not like we dress up in suits or

11 anything. We just wear our regular work

12 cloths and work in these areas and get our

13 measurements and so on. For the people

14 that work for Malcolm Pirnie, I'm

15 responsible for their health and safety.

16 And for me, the real risk is that they

17 don't get killed by a truck going through

16 the yards rather than the radiation wells.

19 Another thing to keep in mind, this

20 is not like an oil spill that's spreading

21 out there. It's been there for 50 years.

22 It really doesn't move around unless you

23 mechanically move it to another location.

24 When I mentioned that soil pile from 50 to


500122


1 100 years ago, what if you had a

2 residential property, they removed a tree,

3 there's a hole in the ground and they took

4 that soil to fill the hole. That's the

5 type of thing we're looking for now.

6 The General Gas Mantle building, let

7 me just tell you a little bit about what we

8 have here. It's all closed up now. Again,

9 as Alan was telling you, the radon levels

10 coming from the ground underneath the

11 building, that is indeed what's happening

12 here. Since it's all boarded up, there's

13 no ventilation so there is a high radon

14 level. There is some soil contamination,

15 nowhere near as extensive as at the

16 (INAUDIBLE) facility.

17 And it is a longer building and it

IB does come out into the street at South

19 Fourth Street. And there are some building

20 materials. The building is vacant.

21 There's nothing in there. There's wood

22 floors and some of those wood floors are

23 contaminated. They would have to be

24 decontaminated before the building is

D B G N A N & B A T E M A N , I N C(609) 547-2565

500123


1 demolished. But Rick Robinson will come

2 back and talk a little about that.

3 I assume most people here are

4 property owners. So the last category is

5 the vicinity properties. So let me touch

6 base a little more on this one. The goal

7 here is to get to the cleanup as soon as

8 possible. And we were fortunate in this

9 case that the State went to a thousand

10 properties. So we didn't want to go to a

11 thousand properties all over again and

12 investigate those properties. But what we

13 had to do is see that we could use the

14 State's data. So we went to 20 properties

15 and we compared our data to the State

16 data. And we agreed with their data.

17 So then we took their data and

18 categorized it. The State went to

19 approximately 1,000 properties. Here it's

20 1,088. When we looked at the State data,

21 we said approximately half, 449 properties

22 are clean. We can't find any indication of

23 contamination on those properties.

24 Then there's another category we put


500124


1 on that we call suspect properties. That's

2 585 properties. Now suspect properties are

3 our grey area. If a property was adjacent

4 to a contaminated property, we

5 automatically called it suspect because we

6 want to check it out because it's adjacent

7 to that contaminated property.

8 Throughout the State people test

9 their homes for radon and get elevated

10 levels of radon in certain locations. That

11 might have happened here and it would be

12 perfectly normal. But we question is that

13 because of the normal radium in the soil,

14 or is it a sign that there might be some

15 soil contamination from the Welsbach

16 facility.

17 We use the term natural background

18 radiation because there's radiation all

19 over but there's an average. And these

20 properties might have had levels on the

21 high end of that. If you live in a brick

22 home, that may be a reason that it's high.

23 But we want to go back to those properties

24 to really break them either way, if it's

D E G N A N & B A T S M A N , INC.(609) 547-2565

500125


1 the contaminated category or the clean

2 property category.

3 And then the bottom line is we have

4 54 contaminated properties. Properties

5 that clearly had some contamination on them

6 from our results and the State's. And we

7 came up with a volume for this for our

8 estimate in the future.

9 Before I let Alan come back and talk

10 again about risk, I just want to mention on

11 suspect properties, again it's our grey

12 area. The contamination on all these

13 properties might be a small spot that we

14 can take away and put in a pail. We might

15 have to bring a backhoe in there to dig it

16 out. But the suspect properties, we would

17 think that most of those properties can be

18 moved to the clean category eventually.

19 But we don't know that for sure and we

20 won't know until we actually do the testing

21 on that property.

22 So I'll let Alan come back and talk a

23 little bit about health risks.

24 MR. FELLMAN: Whenever I talk to


500126


1 people about the risk of radiation, it's

2 always a good frame of reference to say a

3 few words first about natural background

4 radioactivity. It's very helpful when you

5 realize that we live on a radioactive

6 planet. And as a result of that, we're

7 constantly being bombarded by

8 radioactivity, no matter where we are,

9 having nothing to do with the Superfund

10 site.

11 There are several different sources

12 of natural radioactivity and they're listed

13 in this table. Cosmic and cosmogenic refer

14 to things coming from the atmosphere, the

15 upper atmosphere.

16 Terrestrial radioactivity is the

17 natural thorium, radium, uranium that's in

18 the ground, in the soil, in the rocks. And

19 we get most of that 28 millirem per year

20 from terrestrial sources which comes from

21 gamma radiation.

22 Inhaled radiation, we're talking

23 mostly there about radon gas. On average,

24 in the average house, anytime you put four


500127


1 walls and a ceiling together you're going

2 to get some level of radon gas. And on

3 average we get a dose of about 200 millirem

4 per year.

5 And then the internal emitters,

6 referring to the radioactivity that we

7 carry around in our bodies from natural

8 sources such as potassium 40, which is a

9 small but significant component of all the

10 potassium on the planet. There's a little

11 bit of these in soil, in the plants,

12 vegetables and fruit and so forth. And so

13 we're constantly ingesting and excreting

14 some of this radioactivity. And as a

15 result of it being in our bodies we receive

16 a dose on average of 40 millirem per year.

17 There's also a host of consumer

18 products that have one or another type of

19 radioactivity associated with it. And you

20 can see it's a pretty diverse list. And

21 the last one that we show there are gas

22 mantles. We know a little bit more about

23 them than we'd like to.

24 Adding a few more things to those


500128


1 that you see here on this slide, I have a

2 little show and tell here. Most everybody

3 who works in ray field has one of these.

4 This is a piece of Fiestaware(ph) which

5 you'll find in almost any antique show.

6 And this orange color -- I don't know why

7 they call it yellow cake -- but the glaze

8 that they apply to give it this orange

9 color is called yellow cake. And it has a

10 fair amount of natural uranium in it.

11 This meter here is called a Geiger

12 viewer detector, the common name is a

13 pancake probe because of the shape. It has

14 very low background. When you turn it on,

15 from regular background radiation, this is

16 what you'll hear, the sporadic beep. Each

17 time a photon or a gamma ray is interacting

18 inside the detector, it makes a click. And

19 then, as you can tell when I get close to

20 the Fiestaware, there's quite a

21 difference. If I move one to two feet

22 away, you can hear how rapidly that level

23 of radioactivity decreases. As we remove

24 ourselves from the source, the level drops


500129


1 off fairly rapidly. So again, a very high

2 level right out of the source, but by the

3 time I get within three feet apart, there's

4 very little, if any, impact right here.

5 Now, another thing that's kind of

6 interesting is that for those of us who

7 have been told by our doctors that we have

8 to reduce our salt intake because of

9 hypertension or heart problems, they say,

10 go get some salt substitute from the

11 grocery store. What you're getting is not

12 a salt substitute, it's potassium chloride

13 instead of sodium chloride.

14 And as I said earlier, of all the

15 potassium on the planet, a very small

16 rraction is radioactive. And there's no

17 difference from the potassium that's in

18 here than the potassium that's in a banana

19 or potato or any other potassium-rich

20 food. And the difference is not quite what

21 you'd hear with the Fiestaware, but you do

22 hear a difference. And again, that's

23 natural potassium 40 emitting beta

24 particles and gamma rays. And this is what

O E G N A N & B A T B M A N , I N C .(609) 547-2565

500130


1 we need to eat to protect us from

2 hypertension. Again, it doesn't cause a

3 big dose. I just want to illustrate the

4 fact that there's radioactivity all around

5 us, even in the things that we eat.

6 When we talk about dose effect

7 relationship, about being exposed to

8 radiation, there's one point --if you get

9 nothing else -- there's one point that I

10 think is very important for you to

11 understand. And that is that what we know

12 about radiation is that, yes, it is most

13 definitely a human carcinogen. But we know

14 that because of studies that have been done

15 on populations of people that have been

16 exposed to very, very high doses of

17 radiation, compared to background, compared

18 to the levels that we have at some of the,

19 quote, unquote, contaminated properties

20 here. These would be groups such as the

21 Japanese who survived the atomic weapons

22 blast at the end of World War II. Several

23 groups of patients, who back in the '20s

24 and '30s and '40s were treated for various

D E G N A N & B A T E M A N , INC. _(609) 547-2565

500131


1 ailments with radiation. Whereas now, the

2 medical community uses radioactivity to try

3 to help destroy cancer cells. Back then it

4 used to be a treatment for certain

5 diseases. So 20, 30, 40 years later there

6 are these populations treated with these

7 high doses of radioactivity who were

8 followed and were found to suffer from high

9 or increased levels of cancer.

10 So what do we do as public health

11 scientists? We know that when the dose is

12 very high we see excess cancer. Now we've

13 got the lower dose and you can see in this

14 curve, what I'm talking about earlier with

15 the Japanese and some of these other

16 groups, they're up here in the dose

17 response curve. We know the dose is very

18 high and we see the health effect or the

19 risk of cancer is easy to measure. What we

20 have down here is what I call an area of

21 great uncertainty. There are no data that

22 we can point to that will show that at the

23 levels that we1re exposed to from

24 background radiation and from levels that


500132


1 are slightly greater than background such

2 as some of the properties that have these

3 thorium residues on them. There are no

4 data that show that people exposed at those

5 levels are actually suffering from

6 increased incidents of any type of cancer.

7 But the fact that I can say that

8 doesn't mean that we can then dismiss or

9 would want to say there's no problem, let's

10 forget about it. He make an assumption.

11 He assume that there's a linear risk. He

12 assume what's called no threshold, that as

13 soon as you get any dose of radiation, we

14 assume there's some risk. It might be very

15 small. He certainly can't measure it and

16 the truth of the matter is, there may be no

17 risk at all.

18 But we assume that there is a risk.

19 And when we end up at a risk level, when we

20 do our risk assessment part of this

21 investigation, we come up with a number and

22 compare that to what EPA has determined to

23 be the acceptable risk range. And if our

24 models project a risk greater — that is

D E 6 N A N & B A T B M A N , INC.(609) 547-2565 5(J0133


1 greater than the risk range that EPA is

2 looking to obtain, that becomes the basis

3 for a cleanup. The way the Superfund law

4 is written, EPA needs to demonstrate a risk

5 greater than what they found to be

6 acceptable and to use that then as a reason

7 to go forward with an action.

8 At this point I'll stop and Rick will

9 pick back up and discuss the alternatives

10 for the sites.

11 MR. ROBINSON: Thanks, Alan. Now

12 what we're going to talk about is, based on

13 the results of the remedial investigation

14 we evaluated a number of alternatives for

15 the cleanup. And we evaluated alternatives

16 for the three property types we discussed

17 earlier, the vicinity properties, the

18 Welsbach facility and for the General Gas

19 Mantle facility. And for each of the three

20 property types we evaluated, we evaluated a

21 No Action Alternative; an Engineering

22 Controls Alternative; and an Excavation and

23 Off-site Disposal Alternative.

24 The No Action Alternative is an


500134


1 alternative that we have to do on each

2 Superfund site. And we have to compare the

3 other alternatives versus what if we did

4 nothing. If we left it alone, what are the

5 risks. So the No Action Alternative is

6 something that we have to do. In this case

7 here, it was determined that there is a

8 risk above EPA's criteria, as Alan just

9 told you. And as a result we're not going

10 to talk about the No Action Alternative

11 anymore. And we're not even going to

12 consider it right now.

13 For the vicinity properties, for the

14 Engineering Controls Alternative, it's

15 Alternative V-2. Outdoor gamma shields

16 would be required on approximately 50

17 properties; indoor gamma shields on

18 approximately 20 properties ,• and radon

19 mitigation systems would be needed on

20 approximately 4 properties. As a result we

21 would need to have deed restrictions on the

22 property, limiting future work on that

23 property. And we would have to negotiate

24 that with each property owner. The State


500135


1 of New Jersey would be responsible for

2 enforcing those restrictions. And we would

3 have to go back every five years to make

4 sure that it was protected and the shields

5 were still effective.

6 For the Alternative V-3, the

7 Excavation and Off-site Disposal

8 Alternative, all the soil and debris above

9 our cleanup standards would be excavated

10 and disposed of off-site. And under this

11 alternative, the contaminated materials

12 would all be removed. The mobility of the

13 contaminants would be eliminated and there

14 would be no significant institutional

15 controls remaining on the properties. The

16 properties would be safe for future reuse

17 and the remedy would be protective of human

18 health and environment.

19 For the Welsbach facility,

20 Engineering Controls, again we would need

21 outdoor gamma shields. He would need deed

22 restrictions limiting future site work.

23 And we would have to go back every five

24 years to make sure that it was protected


500136


1 and that the shields were still effective.

2 Alternative w-3 for the Welsbach

3 facility, all the soil and debris above our

4 cleanup standards would be removed and

5 excavated and sent off-site for disposal.

6 All of the materials, again, would be

7 removed from the property, mobility of the

8 contaminants would then be eliminated, and

9 there would be no controls remaining.

10 For General Gas Mantle, again for the

11 Engineering Controls Alternative, G-2,

12 again outdoor gamma shields. For the Gas

13 Mantle building, we would have them

14 permanently board the building shut. We

15 would have to restrict access against the

16 building, and we would have to go back

17 every five years to make sure that it was

18 still effective controls.

19 For the Excavation and Off-site

20 Disposal Alternative G-3, we evaluated two

21 options for the buildings. For the General

22 Gas Mantle facility under Option A, the

23 building would just be demolished and the

24 building materials would be sent off-site

D B G N A N & B A T E M A N , INC.(609) 547-2565 500137


1 as contaminated materials.

2 For Option B, we would first go in

3 and try to decontaminate the building and

4 then this would reduce the volume of

5 material that needed to go to off-site

6 disposal. For both options all materials

7 would be moved from the site and there

8 would be no significant institutional

9 controls.

10 And now we'll just go into some

11 summaries. The summary of the cost for the

12 vicinity properties. The engineering

13 controls would cost about $2 million

14 dollars to implement. And the Excavation

15 and Off-site Disposal would cost

16 approximately a little over $13 million

17 dollars.

18 For the Welsbach facility, the

19 engineering controls, almost $6 million

20 dollars. And the Excavation and Off-site

21 Disposal, $18.5 million dollars.

22 For the General Gas Mantle facility,

23 the Engineering Controls Alternative just

24 under $400,000. And the Excavation and


500138


1 Off-site Disposal for Option A which was

2 the straight demolition of the building is

3 just over $2 million dollars. And for the

4 decontamination and demolition of the

5 building, just under $2 million dollars.

6 As a result, EPA's preferred

7 alternative is the Excavation and Off-site

8 Disposal Alternative, V-3, W-3 and G-3.

9 And with the General Gas Mantle facility it

10 would be Option B, decontamination prior to

11 the demolition.

12 In summary, the total cost of the

13 selected remedies combined is almost $34

14 million dollars. Where do we go to next

15 now? The next steps, right now we're at

16 the process soliciting public comment. And

17 as Mary Helen told you earlier, we're here

18 to respond to your verbal comments tonight

19 and we're also encouraging you to submit

20 written comments, if necessary. And after

21 we receive public comments, we select a

22 remedy in a document that's called a Record

23 of Decision (ROD). And once we sign the

24 Record of Decision, EPA can then start the

D E G N A N & B A T E M A N , I N C.(609) 547-2565 500139


1 design process.

2 Our focus will be on the residential

3 properties first. And then followed by

4 that the commercial and industrial property

5 cleanups, we plan on starting the field

6 investigations on the suspect properties in

7 the fall of this year. And we'll hopefully

8 start the design and investigation on the

9 potential contaminated properties also in

10 the fall. And we're also going to try to

11 start the demolition process of the General

12 Gas Mantle building sometime this year and

13 hopefully finish in one to two years. The

14 General Gas Mantle building is in a very

15 sad state of disrepair. Vandalized a

16 number of times. The wood floor is a fire

17 hazard. We'd like to get the building down

18 as soon as possible.

19 The plan right now is to start the

20 cleanup activities on the individual

21 properties in about three to five years.

22 One of the processes with the design is

23 that because it's an individual nature of

24 the property -- because the contamination

D B G N A N & B A T B M A N , I N C .(609) 547-2565

500140


1 is on an individual property, we have to do

2 a specific design on each individual

3 property. And it takes time to generate

4 the design activities on all these

5 different properties and put it together in

6 a package so that we can have a contractor

7 go in and do the cleanup all at once.

8 We're also in the process of

9 conducting a ground water investigation.

10 And that's underway right now to make sure

11 there is no radiological contamination from

12 the site in the ground water. We don't

13 believe we'll find that much, but thorium

14 itself does not like water. It doesn't go

15 into water, into solution. But we're

16 testing the ground water anyway just to

17 confirm that there is no radiological

18 contamination there.

19 We're also going to investigate the

20 wetland areas around Newton Creek, around

21 the Johnson Boulevard Land Preserve and

22 along Temple Avenue where there's two

23 former dumps as well as the Welsbach

24 operation.


500141


1 And that's the end of our

2 presentation. We'd like to invite you to

3 ask any questions. We're all here to

4 answer them.

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24


500142


1 MR. EVANGELISTA: Before we get

2 involved in the questions and answers, I

3 just wanted to point out that we have some

4 handouts up front. One provides you with

5 factual information, sort of a summary fact

6 sheet. Hopefully it kind of reiterates

7 what I opened up with at the initial part

8 of the meeting. If you have any questions

9 now is a good time to raise them.

10 MS. CERVANTES-GROSS: Or if you just

11 have a comment. If you could just state

12 your name again before you give us your

13 question.

14 MR. BECKS: My name is John Becks(ph)

15 (INAUDIBLE). I live on the 900 block of

16 Somerset Street. I'm about eight houses

17 from where you were doing the cleanup

18 earlier.

19 Did they come around -- did you or

20 the State come around to individual homes

21 in that area to test our homes? And what

22 steps are being taken for that?

23 MR. ROBINSON: You might have to show

24 us on one of the maps where Somerset Street


500143


1 is.

2 MR. SAUNDERS: Johnson Boulevard, the

3 ponytail, almost catty-corner, right in

4 those blocks.

5 MR. ROBINSON: I would have to look

6 at the State information on whether or not

7 that part of Somerset Street was included

8 in the investigation. We could let you

9 know if there is any information on your

10 property --if the State did survey it or

11 not. If you don't believe they did --

12 MR. BECKS: No, I don't.

13 MR. SAUNDERS: That area -- actually

14 the whole town --we get a lot of false

15 positives, which is what we want. They go

16 back through that area to see if it's

17 construction of the home material. And in

18 that area the only thing they saw was along

19 the Johnson Boulevard area of houses in

20 Gloucester, (INAUDIBLE), in that immediate

21 area.

22 MR. BECKS: Why wouldn't they be?

23 MR. SAUNDERS: We went out. I can

24 show you on one of the colored pictures


500144


1 where it was done.

2 MR. BECKS: And was it?

3 MR. SAUNDERS: Yes, it was done. Was

4 the house done? No. Plus the construction

5 date of those homes -- that was called the

6 homes, like, that (INAUDIBLE) and a lot of

7 the construction predated the site. The

8 homes were built -- that whole section on

9 Somerset Street predated a lot of the dump

10 area. The wetland area that was all

11 wet.ands in the '50s. So that's some of

12 the ones where we didn't see anything.

13 When I say "we," EPA. There was nothing to

14 indicate that there was any concern

15 whatsoever in that area (INAUDIBLE) quite a

16 few feet to make sure.

17 Some of the pictures -- here some

18 people made mention of (indicating).

19 People want to make sure again and again

20 and again, to make sure. So that's why it

21 may be contaminated here. We are going to

22 look here and here and here and here again

23 (indicating). The last thing anybody wants

24 to do is do this wrong.

D E Q N A N & B A T B M A N , I N C .(609) 547-2565

500145


1 I live around the block. I have --

2 was my house tested? No. Because I know

3 the age of when they were built, how it was

4 built. Where Dr. Kelly lives, that area,

5 that predated the dump. So the homes built

6 before the dump (INAUDIBLE) they weren't

7 (INAUDIBLE). However, as part of this

8 randomly (INAUDIBLE). They did go out.

9 MR. ROBINSON: If you'd like and you

10 are concerned, we can just go over and do a

11 quick walkover while one of our contractors

12 is out here.

13 MR. BECKS: I'm concerned too, in

14 talking with various neighbors, it was a

15 common practice at the time when they were

16 filling the wetlands, that people go home

17 and pick up building materials, bring them

18 home to your site, wood and such. And

19 that's a concern.

20 MR. FELLMAN: Part of the answer is

21 that this fly-over data kind of laid out

22 the boundaries of the different study

23 areas, as starting points. And not looking

24 at a map, you know, I suspect that your


500146


1 home is probably outside of the boundaries

2 that the fly-over gave us to start with.

3 MR. BECKS: I was doing some work in

4 my basement about a week and a half ago. I

5 tore out the closet and there was building

6 material from Welsbach.

7 MR. ROBINSON: Really. If you could

8 please leave your name. I have a

9 contractor who's here with me today doing

10 some fieldwork and we can make an

11 appointment and scan your property. We'll

12 need to do that this week.

13 MR. BECKS: I have two very small

14 children that my wife and I love dearly.

15 MR. SAUNDERS: That's the kind of

16 information -- some people think they're

17 going to get in trouble.

18 MR. BECKS: Well, that's why I came

19 here. That's not the only reason. I was

20 planning on coming when I first read it in

21 the Gloucester City News. The only way

22 that I knew about this meeting was from

23 that article in the Gloucester City News.

24 I can see by the amount of people that


500146A


1 apparently nobody cares or everyone wasn't

2 informed.

3 MR. SAUNDERS: This is what we did.

4 Gloucester City News was given the same

5 data as the Courier and as the Inquirer.

6 And all those areas of people who live in a

7 house (INAUDIBLE) there was suspect

8 condition. So now you're looking at quite

9 a few hundred people and this is generally

10 the response.

11 MR. BECKS: I only really get the

12 Gloucester City News. I don't read the

13 Courier or the Inquirer.

14 MR. SAUNDERS: In fairness to EPA, a

15 lot of these residents who had questions, a

16 lot of them have called to complain. And

17 we'll give them the information -- plus the

18 residents we've sat down with. And I'll•19 show you what we have here, a demarcation.

20 MR. BECKS: There was a lot of people

21 filling in tree holes from dirt piles down

22 at the end of the street.

23 MR. SAUNDERS: But the fly-over would

24 have shown that.


500146B


1 MR. ROBINSON: He can schedule a time

2 tomorrow morning. We'll still be here in

3 town. We can make an appointment with you

4 or anytime at your convenience when we're

5 down here. If you know of anybody else who

6 are not in these areas who have other

7 Welsbach materials, we're very, very

8 interested in trying to find those homes.

9 Like a former worker who used to work there

10 may have brought some stuff home with him.

11 It's very, very hard to do the entire

12 town. And we need help from the public on

13 that.

14 MR. 3AUNDERS: As always, if you get

15 the word out, they can call us 24 hours a

16 day and we'll take a quick sample. That's

17 the beauty. We can meter it and say, yes,

18 it's there; no, it's not. We want to do

19 that with a whole host of the materials.

20 MR. BECKS: Thank you.

21 MS. CERVANTES-GROSS: Anyone else

22 have a comment or a question?

23 MS. MARKS (ph) : My name is Sue

24 Marks. I live in Bellraawr. I was a


500147


1 resident of Fair-view for many years. I

2 have a couple of questions and I spoke to a

3 couple of gentlemen earlier.

4 I have a cancer study here that I

5 sent to the EPA (INAUDIBLE) a couple of

6 weeks ago. I received a copy of this and

7 in here, one of things that stood out for

8 me was, it says higher cancer incidents

9 from the Welsbach General Gas Mantle site

10 appear to be due to significantly higher

11 lung cancer incidents in the population,

12 especially in males.

13 Do you -- and maybe you're not the

14 right people to ask -- but to me I'm

15 concerned about the health aspect of what

16 has seemed to be a long-term problem here.

17 As I said, I used to live in Fair-view and

18 my house -- I just saw on one of the poster

19 boards there -- was basically right

20 directly behind one of your highly

21 contaminated homes. I'm concerned about

22 the residents' health. And I guess what I

23 need to know is, the people that are living

24 in these homes that are the 54 contaminated


500148


1 homes, what will be done with them, to

2 them, for them, while this remedial work is

3 going on? In other words, A, will they be

4 moved out of their home; B, will they be

5 monitored for any sort of health problems

6 as the remedial work is going on? To me

7 that's one of my greatest concerns.

8 I think, Bob, you and I had spoken

9 about this earlier. I don't know where

10 this came from. I don't know how it's in

11 reference to this Welsbach site. But I

12 have to know that it must be connected

13 somewhere.

14 MR. ROBINSON: For the answer to the

15 health study, we have Artie Block here from

16 ATSDR. And his agency is the one who

17 sponsored the State investigation.

18 MR. BLOCK: Let me just take a

19 moment. Again, my name is Arthur Block.

20 I'm a Senior Regional Representative for

21 ATSDR.

22 As was mentioned by Mary Helen, ATSDR

23 is the Agency for Toxic Substances and

24 Disease Registry and is part of the



1 Department of Health and Human Services.

2 We are primarily, and our main mandate and

3 responsibility, is environmental health.

4 We work very closely with the Federal EPA,

5 the State, the community, whatever it is to

6 identify if there are any health needs or

7 health concerns associated with

8 environmental exposure. And that's

9 basically our main role.

10 One other thing I'll tell you about

11 our agency, my agency, is that it is an

12 independent environmental health agency.

13 In other words, we look at situations that

14 affect you, the community, on an

15 independent basis. We look at all the data

16 that was put in front of us and we evaluate

17 that data independently of other agencies.

18 And we give you our health call as to what

19 is up or what's going on in your

20 community. I'm not going to spend too much

21 more time on this. Here's the information

22 and certainly if after the meeting you want

23 to speak more to me about our agency, you

24 can have this information about ATSDR. And


500150


1 there's a lovely young lady over here who

2 says she's a computer geek, so I'm going to

3 pass this onto you, which is our web page.

4 And we also have some more of that if

5 you're into computer information. And

6 actually you can get a lot of information,

7 more than I could ever tell you tonight,

8 about contaminants, about how they impact

9 on human health. So if you want that

10 information I can certainly pass that along

11 to you too. And I'll certainly give you my

12 card and, as Pat indicated, if you have any

13 follow-up questions.

14 I'm not a scientist. I'm just like

15 you guys. But I work in public health so

16 there may be some specific questions, if

17 you do come up with any, that refer to a

18 specific science or physic radiation. I'll

19 refer those to Alan. He is a health

20 physicist and the person who can give you

21 the scientific readouts. I'll give you the

22 readout from the point of view of just

23 common people like ourselves.

24 If you look at the houses that, as


500151


1 they existed 50, 60 years ago or the area

2 around there 50, 60 years ago -- I wish we

3 were able to take one of these machines and

4 read what people were exposed to back then

5 and at what level. We don't know. We

6 don't know. That is the bottom line.

7 Nobody knows. It takes time for cancer to

8 develop. It doesn't happen overnight. And

9 it takes a lot of dosage, constantly being

10 exposed to these high doses. These are

11 things that just come out. And that's how

12 I understand it.

13 To get exposed on a normal basis, as

14 indicated, we do commonly get exposed to

15 radiation in different levels. Most of

16 that is not of public health concern.

17 People who generally worked in these

18 situations and got a constant exposure to

19 them, these are the people who developed --

20 or in the case, you know, of the Japanese,

21 where you have a huge, huge amount of

22 dosage coming at you at one time. So these

23 things we know about.

24 Now, let me also make some other


500152


1 statements about the study. And that

2 hopefully will get to your question. Is

3 lung cancer -- can it be associated or is

4 it biologically causable that radiation can

5 cause lung cancer? The answer is yes. But

6 looking at the numbers and what was given

7 to ATSDR and the New Jersey Department of

8 Health who did the evaluation of the

9 sampling that was done, these dosages were

10 not high enough or should not have been

11 high enough to give you lung cancer.

12 That's the short and long of it.

13 But nonetheless, ATSDR, my agency,

14 along with the New Jersey Department of

15 Health and the Department of Health and

16 Human Services decided to take a look. And

17 you won't be surprised to hear that in New

18 Jersey there are other sites like this. So

19 you have Maywood in Maywood, New Jersey.

20 You have the West Orange, Montclair area,

21 all similar radon exposures. New Jersey

22 and ATSDR decided, well, let's take a look

23 because communities generally are concerned

24 about cancer and understandably so,


500153


1 radiation issues around these type of

2 Superfund sites.

3 So we pick these three areas here,

4 this whole bottom area (indicating), and

5 those other two that I just mentioned. If

6 you read the study, you'll find out that

7 with an examining of the cancer risks

8 around a one- or two-mile area of those

9 Superfund sites, there was no elevated

10 cancer of any type found associated with

11 the exposure to radon or radiation. Didn't

12 find it. Didn't find it in Montclair.

13 Didn't find it in Maywood.

14 What we did find, what you're

15 bringing up is, yes, there was elevated

16 lung cancer found here in this area.

17 What's kind of interesting is, you have the

18 same type of contaminant.

19 If you look at the history of all of

20 these sites, they're very similar. And yet

21 you have just one elevation of one type of

22 cancer, lung cancer, in this area. What

23 you would want -- what you might expect to

24 find is that if this is all similar


500154


1 contamination, all similar exposures to

2 people, that you'd find lung cancer here

3 and find lung cancer in Maywood and you'd

4 find lung cancer also in the Montclair,

5 west Orange area.

6 Is radiation the cause for the

7 increased lung cancer? In all honesty, I

8 cannot say to you standing in front of you,

9 and I wouldn't say that, that it isn't

10 possible. It is possible. The probability

11 of it is probably much less than that.

12 Okay. Beyond that, it would take a very --

13 you'd have to study the individual people

14 themselves to find out --to rule out

15 other, what are called, confounders.

16 What are these confounders? These

17 confounders are things like occupational

18 exposure that causes lung contamination.

19 Smoking, that we know has a direct

20 association with lung cancer. These are

21 the confounders that, if you pursued this

22 further, you may find, yes, there was a lot

23 of smokers out there. Or, yeah, they were,

24 in fact, occupationally exposed. And that


500155


1 elevated number that was found from that

2 study will start to decrease or it should.

3 Unless we rule out all other

4 confounders and you're stuck with, yeah,

5 it's the radiation. That's what that study

6 was trying to find out. Is there any

7 similarities in the occurrence of cancers

8 within those three -- around those three

9 given Superfund sites and there wasn't any

10 found. Other than the one elevation of

11 lung cancer here. And that was the purpose

12 of the study. It wasn't necessarily to

13 associate Superfund sites and cancer. That

14 was not the purpose. The purpose was to

15 see if there was any commonality of the

16 exposures and things like that from the

17 Superfund sites.

18 Let me stop there. Having heard what

19 Alan said, having heard what I said, are

20 there more concerns than that? Did I

21 somewhat, kind of, sort of, answer your

22 question?

23 MS. MARKS: Yes. It's just my

24 concern that we live in the area that's


500156


1 very polluted.

2 MR. BLOCK: It's a very real

3 concern.

4 MS. MARKS: Exactly. And the

5 Welsbach problems coupled with this study

6 just alarmed me more than I thought.

7 I do have a couple other questions.

8 MR. EVANGELISTA: At this point I'd

9 like to address the other part of your

10 question regarding how the EPA will deal

11 with affected residents whose property will

12 require cleanup.

13 As Rick and I touched upon a little

14 earlier, we talked about the remedial

15 design phase of the project. At that point

16 EPA will look at each of these individual

17 properties that will require cleanup and

18 design an approach for cleaning up that

19 property. And each property will be

20 different. You may have a property that

21 has several bricks in the backyard that we

22 will essentially pick up and take away. We

23 may have another property where we may have

24 to excavate a certain volume of soil that's


500157

67KPA Public Meeting - 2/23/99

1 elevated in levels of radioactivity which

2 we'll also move away.

3 Whatever you may have as far as a

4 cleanup that's required, the agency will

5 and hopes to work very cooperatively with

6 the property owner. Our intent or our

7 approach will be as we've applied it in

8 other sites like Montclair where we'll work

9 as closely as we can with the property

10 owner to impose as little inconvenience as

11 possible.

12 You touched a little bit upon

13 relocation. If there's a need for

14 relocation, which we hope there won't be,

15 but if there is a need then EPA will work

16 as closely with the property owner as

17 possible to provide as temporary relocation

18 as possible. And, of course, that will be

19 at our expense or the Superfund's expense.

20 But we hope that that will not be the case

21 for any of the properties. But I'm not out

22 here to tell you tonight that that's not

23 ever going to be the case on any of these

24 projects. That may very well be the case


500158


1 on some of the projects. So we'll just

2 have to wait and see and we'll do our best

3 to keep you as informed as possible in as

4 timely a fashion as possible.

5 MR. SAUNDERS: Say I live in a house

6 that there's known contamination there, I

7 understand remedial measures have already

8 been taken (INAUDIBLE) shields as discussed

9 earlier. So right now, if you're in the

10 house (INAUDIBLE) we know we're going to

11 protect you. There's a lot of (INAUDIBLE)

12 that don't care about the health issues,

13 they just care about the trees and birds.

14 That's the farthest thing from the truth.

15 (INAUDIBLE) and then we go from there. And

16 we have been somewhat criticized in

17 (INAUDIBLE) and using overkill. And yes,

18 we do take overkill and we wear it as a

19 badge of honor. (INAUDIBLE) some of the

20 people over at the Popcorn Factory, I'd

21 much rather be brought before my governing

22 body -- there are quite a few Council

23 people here -- I'd much rather be brought

24 on the carpet for overkill than not doing



1 enough. And the direction is always

2 overkill. It's never not enough. So here

3 that's what we've taken. EPA, they have

4 gone above and beyond in many, many

5 situations.

6 MS. MARKS: Would there be any sort

7 of follow-up, I mean, like a health study

8 done on the residents after your remedial

9 work takes place? Will you be tracking

10 them for a period of time to see if they

11 develop any sort of problems or any

12 long-term problems due to -- maybe before

13 your remedial work started and before these

14 temporary structures were put into place?

15 MR. SAUNDERS: Would you be able to

16 speak for the purpose of contamination?

17 MR. BLOCK: Your question is more, as

18 I understood it, they're going to begin the

19 remedial and then -- did I sense that you

20 think you're going to be exposed to

21 something during that time period and

22 then --

23 MS. MARKS: NO; no.

24 MR. BLOCK: Okay. I did


500160


1 misunderstand then.

2 MS. MARKS: I understand the way it's

3 going to occur, what I'm saying is, these

4 people, evidently, I assume some of them

5 have been living in these contaminated

6 homes for some time. Will there be some

7 sort of a health study done on them before

8 the remedial work starts and then would

9 there be a follow-up study just to track

10 the situation to see if anything — they

11 have incurred any sort of medical problems?

12 MR. FELLMAN: in a sense that first

13 health study is what ATSDR funded to the

14 State. Because the only health effects

15 that we associate with exposure to

16 radiation is cancer. There aren't other

17 illnesses that we look at as indices of

18 radiation exposure. So it's either

19 elevated cancer or not. And so that first

20 look, in effect, is the study that you've

21 looked at. Now whether there's going to be

22 an additional study done or another study

23 done down the road -- I think --

24 MR. BLOCK: The bottom line, is there

O E 6 N A N & B A T B M A N , I N C .(609) 547-2565

500161


1 a health plan?

2 MR. ROBINSON: It's not planned.

3 MR. FELLMAN: It's not part of this

4 process.

5 MR. BLOCK: It doesn't require it

6 from the viewpoint of looking at the site

7 and how the impact on health would be. So

8 the short answer is no. But I know Bob

9 wanted me to just discuss the Cancer

10 Registry.

11 Are all of you familiar with the

12 State Cancer Registry? Is there anyone who

13 needs information on that and how it works

14 and what it's there for? Are you okay with

15 that? Because I'll spend a moment on that

16 if you'd like.

17 New Jersey, like all 50 states

18 throughout the nation, maintains what is

19 called a Cancer Registry. Some states do

20 it better than others. And, in fact,

21 they're funded very well to maintain a good

22 Cancer Registry. And within the states

23 there are mandated laws that hold --

24 hospitals and physicians who diagnose


500162


1 cancer must report that cancer incident to

2 the State. And once it's reported, then it

3 comes into the registry system.

4 And the reason for that is,

5 obviously, all of us are concerned about

6 cancer. Not only for research reasons, but

7 certainly we want to know how much cancer

8 is out there and specifically within our

9 own areas. Are there more elevated cancers

10 overall? Why? Because that then may

11 prompt further investigations. A perfect

12 example of that is just north and east of

13 here, Toms River. And I'm sure a lot of

14 you have heard about that. And our agency,

15 ATSDR, along with the New Jersey Department

16 of Health is very, very much into that

17 childhood cancer investigation at this

18 point.

19 So this Cancer Registry maintains all

20 of the reported incidents. And actually

21 this is kind of interesting. Prior to Toms

22 River, the New Jersey Cancer Registry was

23 probably four to five years behind in terms

24 of keeping up with the data that was

D E G N A N & B A T B M A N , INC.(609) 547-2565 500163


1 entering in. After Toms River, all of a

2 sudden money came into the Cancer

3 Registry. And now it's probably -- and I'm

4 not kidding you about this -- New Jersey's

5 Registry is a gold mark standard registry.

6 But something like that had to happen. And

7 there are other states in the union who are

8 not very good with keeping their data. But

9 New Jersey is exemplary with its program.

10 Now what that does is -- and when you

11 get into the issue of statisticians and

12 numbers and how big populations are in

13 terms of how do you measure what's

14 happening in one community as opposed to

15 another community, what they do is -- I'm

16 simplifying it, really -- I have to. I

17 really don't understand all of it. I'm not

18 a statistician.

19 What they do is take comparable

20 populations in numbers and size and their

21 socioeconomic background. And they compare

22 these two populations which are similar and

23 look at the cancer rates or incidents

24 within those populations, they should be


500164


1 similar. Everything else being equal, they

2 should be similar. But if something pops

3 out, whether it be bladder cancer or lung

4 cancer or brain cancer, that just doesn't

5 gel, that pushes the investigative health

6 system to go further, what's in this

7 neighborhood that may be causing it, to do

8 further investigation.

9 MR. SAUNDERS: In an indirect way,

10 yes, there is a follow-up indirectly.

11 MR. GRABOWSKI: Mike Grabowski. I'm

12 just wondering if your house is found

13 contaminated and you don't want to live

14 there, you want to sell, there's a problem

15 there. But the State of New Jersey has a

16 disclosure on it. You have to tell the

17 Realtor. What happens with that?

18 MR. ROBINSON: Well, I guess that's

19 one of the grey areas of the process with

20 an individual property that has

21 contamination on it and the property owner

22 wants to sell it.

23 For EPA, what we can do to a

24 potential purchaser --we can enter into an

D E G N A N & B A T B M A N , I N C .(609) 547-2565 500165


1 agreement with the purchaser to give them a

2 prospective purchaser agreement to not be

3 held liable for any cleanup costs associated.

4 That way it may be helpful with the

5 transfer. So that he wouldn't be taking on

6 liability. However, with respect --

7 MR. EVANGELISTA: And assurance that

8 it will be cleaned up.

9 MR. ROBINSON: Right.

10 MR. GRABOWSKI: Do I have to put down

11 the limit of contamination in the area?

12 MR. EVANGELISTA: We would be able to

13 inform them at an appropriate time when

14 we've properly investigated your property

15 -- if it's your property that we're

16 talking about -- yes, we'll have cut lines

17 as we call them, where the contamination

IB is, an estimate of the volume, etc., etc.

19 If someone's interested in your property,

20 we can provide them with a document that

21 says EPA is going to clean up this property

22 and is not going to hold you accountable

23 for it in any way, shape or form.

24 MR. GRABOWSKI: It will be pretty


500166


1 tough to sell the property.

2 MR. EVANGELISTA: I understand that,

3 sir.

4 MR. GRABOWSKI: Nobody would want to

5 buy it, I don't think.

6 MR. EVANGELISTA: I understand. And

7 I guess the other part that may give you

8 comfort, we've been moving along in this

9 project extremely quickly. You may look at

10 other Superfund projects where an RI/FS has

11 gone on for three, four, five years. We've

12 completed this process in what some would

13 say is record time, we did it in a year.

14 And we hope to continue moving that quickly

15 so that we can restore your property and

16 others to a form where it may be attractive

17 for selling or you may be comfortable with

18 it again.

19 UNIDENTIFIED SPEAKER: I Own a

20 property on Temple Avenue that goes right

21 into Newton Creek, concreted over. My son

22 was told recently by a lawyer from Malcolm

23 Pirnie that -- I had wanted to either give

24 him the property or sell it, get it out of

D E G N A N & B A T E M A N , I N C(609) 547-25«


1 my hair, so to speak. And the lawyer told

2 him that he would be responsible for the

3 cost of the cleanup.

4 MR. KERBEL: Just to be clear, it

5 wasn't a Malcolm Pirnie lawyer. I don't

6 know if --

7 UNIDENTIFIED SPEAKER: He had spoken

8 to Steve McNally(ph).

9 MR. KERBEL: Steve is right here.

10 UNIDENTIFIED SPEAKER: And he was

11 referred to a lawyer.

12 MR. ROBINSON: I think Steve referred

13 your son to me.

14 UNIDENTIFIED SPEAKER: Oh, was that

15 you?

16 MR. ROBINSON: Yes, I'm Rick

17 Robinson.

18 MR. KERBEL: We don't have the

19 authority.

20 MR. ROBINSON: Your son spoke to me

21 and I basically told your son it's in his

22 best interest to talk to an attorney to

23 find out from an attorney himself, his own

24 attorney. I didn't give him any legal


500168


1 advice. I just told him it would be in his

2 best interest to talk to an attorney prior

3 to any transfer. Because he doesn't want

4 to take on any liability knowing that he's

5 buying a contaminated property. I'm just

6 giving him advice, you know. I would

7 contact an attorney. And I was just --

8 UNIDENTIFIED SPEAKER: And if I died

9 tomorrow and he inherited the property, he

10 would not have to pay for the cleanup?

11 MR. ROBINSON: He would not.

12 MR. EVANGELISTA: And neither would

13 you.

14 MR. ROBINSON: It's a different story

15 when someone purchased the property not at

16 full-market value and they try to buy a

17 property for, you know -- they know it's

18 contaminated and they're getting it for,

19 like, three cents on the dollar or ten

20 cents on the dollar. That's where EPA

21 would then go back to that person who's

22 buying it cheaply and say, hey, you're

23 buying it not at the fair-market value and

24 we may want to get some of that money


500169


1 back. That's where the issue is.

2 MR. BLOCK: May I say one more thing

3 about the Cancer Registry? I just want to

4 point out the fact that the local County

5 and City here are trying to get information

6 from the New Jersey Cancer Registry to do

7 some type of follow-up also. So they're

8 attempting to get that information.

9 The Cancer Registry information is

10 extremely confidential and private. And

11 it's designed under law to be that way. So

12 to get that information, sometimes you have

13 to jump through hoops to try to get that

14 information. But I know your City and

15 County are attempting to get that

16 information to do some additional follow-up

17 work. Is that correct?

18 MR. SAUNDERS: Yes.

19 MS. CERVANTES-GROSS: Any other

20 questions or comments?

21 MS. MARKS: Just two more. I wanted

22 to address the issue of the alternatives.

23 One, obviously, was a No Action Alternative

24 which, for obvious reasons, would never


500170


1 work. The second, the Engineering Controls

2 Alternative. And the third, the excavation

3 and demolition of the various properties.

4 Is it my understanding that the EPA

5 is suggesting that the demolition and

6 excavation go forward? Has a decision been

7 made on that?

8 MR. ROBINSON: The decision won't be

9 made until EPA hears all the public

10 comments. And we're patiently waiting to

11 hear your responses today, your verbal

12 comments, and any written comments that are

13 submitted. As Mary Helen said earlier, our

14 public comment period ends on March 3, next

15 Wednesday. So after next Wednesday, then

16 EPA sits back and writes responses to all

17 of the questions and will formally select a

18 remedy in a document called the Record of

19 Decision. And attached to the Record of

20 Decision is another document that we call

21 the responsiveness summary, which

22 summarizes the verbal responses today that

23 we're given and the written responses

24 also.



1 So that's why we have a court

2 reporter here today and she's taking down

3 your questions and my answers. So all that

4 will be part of the record.

5 MR. SAUNDERS: At the local level,

6 our (INAUDIBLE) is March 3. And on that

7 document would be a resolution (INAUDIBLE)

8 in our City that supports that. I asked

9 for a telephone campaign and that would be

10 such (INAUDIBLE). That is something they

11 need to make (INAUDIBLE) what is the

12 interest here. And we support them

13 totally. It's part of what has to occur

14 and we do have (INAUDIBLE) in that office

15 and our governing body (INAUDIBLE).

16 MS. MARKS: And I would hope that the

17 City of Camden would do likewise. Although

18 I would have to say in my years -- you

19 think you got 25 people here tonight --

20 you'll probably be lucky if you get ten

21 tomorrow night. Unfortunately, a lot of

22 City residents aren't real anxious to go

23 into the CCMUA at night. So that may not

24 give you a real indication. Has anyone


500172


1 there been in touch with the mayor over the

2 situation?

3 MR. ROBINSON: I've been in contact

4 with the City of Camden, the mayor's

5 assistant.

6 MS. MARKS: Okay. I would like to

7 see the City of Camden put forth the same

8 kind of resolution to remove and excavate

9 the sites.

10 MR. EVANGELISTA: I guess based on

11 what we've seen and heard thus far, it's

12 our anticipation that the decision will be,

13 in fact, to excavate both Camden and

14 Gloucester City.

15 MR. FELLMAN: In the proposed plan,

16 that's what EPA is indicating is EPA's

17 preference. So they need to have reasons

18 why not to go forward with that, as opposed

19 to having to be convinced to do it.

20 MS. MARKS: Okay. One more

21 question. When you excavate these sites

22 and remove the contaminated material, it

23 will be put onto a truck and trucked out of

24 the area to wherever your hazardous waste

D E G N A N & B A T E M A N , INC.C«9) S47-2565


1 facility is?

2 MR. ROBINSON: Most likely we will

3 probably ship it by rail.

4 MS. MARKS: Okay. If you ship it by

5 rail it's obviously not going to be put on

6 the train right here in Gloucester City --

7 MR. ROBINSON: We would hope to find

8 a site here in Gloucester City to ship it

9 out.

10 MS. MARKS: On rail?

11 MR. ROBINSON: On rail.

12 MS. MARKS: You're going to have it

13 come right from the contaminated site in

14 Gloucester City to the rail?

15 MR. ROBINSON: Or the nearest rail

16 transfer --

17 MR. SAUNDERS: We have two staging

18 areas. If you're getting to or worrying

19 about spilling something, if you have an

20 opportunity I can take you to the tankers

21 they go in. They are totally encapsulated.

22 MS. MARKS: You're not going to bring

23 it in from Camden? Incinerator ash has --

24 MR. SAUNDERS: We have sites here in


500174


1 Camden and Gloucester City (INAUDIBLE) put

2 on a truck. Just like you had (INAUDIBLE)

3 that stuff.

4 MS. MARKS: what is your estimate --

5 MR. SAUNDERS: Now you said three

6 weeks. That's beyond anybody's control

7 here.

8 MS. MARKS: The problem is low

9 (INAUDIBLE).

10 UNIDENTIFIED SPEAKER: But your

11 earlier statement that the stuff was

12 falling out the top and containers were

13 open and totally (INAUDIBLE) totally sealed

14 at the top. I wasn't --

15 MR. SAUNDERS: They were just --if

16 your concern is about falling out --

17 MS. MARKS: That is my concern that

18 some of it will be falling out as you put

19 it in and maybe it isn't all carried away.

20 MR. ROBINSON: We have a lot of

21 experience in dealing with contamination,

22 removing radiological contamination waste.

23 We just completed a very large excavation

24 in an Essex County site and a number of


500175


1 homes in Orange, New Jersey and Montclair.

2 That material is transported by truck and

3 sent out to Utah. Trucks moving it every

4 day, moving it for four or five years now.

5 MS. MARKS: I wasn't insinuating that

6 there was --

7 MR. ROBINSON: The material is not

8 hazardous waste; it's radioactive waste.

9 MR. GRABOWSKI: Something should be

10 on those trailers. In my neighborhood

11 where I have a store, kids are jumping that

12 fence and playing in that area. Now why

13 shouldn't that be marked off as hazardous

14 waste?

15 MR. SAUNDERS: Well, as I said

16 before, I hope you're calling the police

17 when children are there. The (INAUDIBLE)

18 site you saw with contamination is under

19 gravel and dirt. There's a fence. In

20 order to get into those trailers

21 (INAUDIBLE) to get into that property.

22 MR. GRABOWSKI: Why don't you have

23 signs up?

24 MR. SAUNDERS: The other issue is,


500176


1 depending on the type of radiation you

2 have, it depends on how you placard it. At

3 that level there isn't an appropriate

4 placard. It's too low.

5 MR. FELLMAN: The labeling on the

6 container for this type of waste is

7 outlined in the Department of

8 Transportation regulations. And the levels

9 are such, or this type of waste is such,

10 that it doesn't warrant the type of label,

11 I guess, that you're looking for.

12 MR. GRABOWSKI: How high is that

13 rating on that site?

14 MR. FELLMAN: The rating?

15 MR. GRABOWSKI: Reading; reading.

16 The reading that you're getting.

17 MR. FELLMAN: I haven't scanned those

18 containers so I couldn't answer that other

19 than to say it's clearly elevated because

20 if it wasn't, it would not have been

21 removed from the park. So there's

22 something there. How high? I don't know.

23 MR. EVANGELISTA: You're not talking

24 about placards that should be on them for


500177


1 shipment, you essentially just want some

2 warning signs for kids.

3 MR. GRABOWSKI: You know, like Bob

4 said, call the police. I work too and my

5 wife can't constantly sit by the window and

6 watch.

7 MR. ROBINSON: What we'll do is,

8 we'11 arrange for signs to be placed on the

9 fence.

10 MR. SAUNDERS: This is the problem we

11 have. If we speak to X amount of neighbors

12 and try to accommodate the wishes of most

13 neighbors in this township, that's the

14 problem. We're never going to make

15 everybody happy. Some people want signs.

16 The vast majority of people indicate to me,

17 if we don't have to have signs, they really

18 appreciate it.

19 MR. FELLMAN: They want it to be

20 invisible. They don't want signs right

21 next to their homes.

22 MR. GRABOWSKI: I think it's stupid.

23 MR. FELLMAN: And you're entitled to

24 that opinion. But this is what people are


500178


1 telling Bob and other folks.

2 MR. GRABOWSKI: They're afraid

3 because if they want to sell their house,

4 nobody is going to buy it.

5 MR. SAUNDERS: It's going to be

6 remediated as soon as possible. It's also

7 going to be certified clean. And nothing

8 will be done on there until that's done.

9 We can say confidently for the neighbors of

10 the Popcorn Factory, that site is safe for

11 you and everyone else. And we say that

12 with full confidence. The items that are

13 staged there will be removed. Those types

14 of things are there to make sure that the

15 residents, children and everyone else are

16 safe, we're not going to tell you things

17 that we don't know as exist today.

18 UNIDENTIFIED SPEAKER: Mike sees

19 these people in the suits, but they're

20 dealing with the removal every day. But if

21 you go and you walk, you're not going to

22 get that type of exposure. Is that what

23 you're concerned about, Mike?

24 MR. GRABOWSKI: No. The children in


500179


1 the neighborhood. I live catty-corner from

2 that. I don't know if my property is

3 contaminated or not.

4 MR. SAUNDERS: In order for the kids

5 to get into the containers --

6 MR. GRABOWSKI: They're not getting

7 into the containers. They're covered. But

8 they're getting into the property

9 (INAUDIBLE) before the fence (INAUDIBLE).

10 MR. SAUNDERS: I think even if you

11 patrolled it (INAUDIBLE). It's an example

12 of overkill. The City has done more to

13 protect our residents than (INAUDIBLE).

14 Required us to put more gravel at the site,

15 to be more protective of our residents. So

16 even if a child is standing (INAUDIBLE),

17 it's somewhat misleading that the

18 contamination is underneath.

19 So again, as Alan said, (INAUDIBLE)

20 it's, like, months and months and months of

21 not moving it. We used overkill and are

22 protective of that site. And I appreciate

23 your concerns. And they're valid. And

24 we've taken --if they tell us this is good


500180


1 enough, we go a few more steps.

2 UNIDENTIFIED SPEAKER: As far as

3 getting from point A to point B, I live in

4 the (INAUDIBLE) hundred block of Somerset

5 Street. And as a truck would back in, they

6 would put a tarp down. The truck would

7 back over top of this tarp, seal it, and

8 actually broom the truck off and everything

9 around those tires was broomed off. I

10 thought it was total overkill protection

11 for us, the residents of the City, and I

12 loved it. Before that truck moved, three

13 or four guys would walk around it and sweep

14 every tire, every little nook and cranny.

15 It was amazing how they did it.

16 MR. EVANGELISTA: In addition to

17 that, getting back to the containers on the

18 Popcorn property, not only are they covered

19 with the locked covers, but inside the

20 material is covered with clean fill. So

21 even if someone opens the cover and gets in

22 there, they're jumping onto --

23 MR. GRABOWSKI: I didn't know you had

24 clean fill on top of that.


500181


1 MR. EVANGELISTA: So there's that

2 additional protective measure that's been

3 taken. Like the gentleman said, everything

4 is done with overkill.

5 MR. SAUNDERS: They are metal too.

6 The tops are sealed shut metal units, not

7 open containers. There are several things

8 they would have to do to get to the

9 problem.

10 MS. CERVANTES-GROSS: Any other

11 comments or questions? Thank you for

12 coming and, again, you have until next

13 Wednesday if you have any other questions

14 or comments. And you may have seen on the

15 board outside here, there is additional

16 information on the individual properties in

17 the areas. Thank you.

]_g ********

19 MS. CERVANTES-GROSS: Can we go back

20 on the record for some additional comments,

21 please?

22 MS. GRAHAM: Theresa Graham and Ed

23 Gorman, Chairman of the Community

24 Playground, Fort Nassau, that will be


500182


1 placed at Johnson Boulevard right in the

2 middle of the jogging track. And our

3 concerns are the safety of any contaminants

4 on there. We were told that an overall was

5 done of the top of it and there doesn't

6 appear to be any right there.

7 And our concern is that we'11 put

8 $110,000 into the building of this

9 playground and then come April 7th or nth

10 we'll have it finished, and then what

11 happens to it if later on you find

12 something there. We want to be assured

13 that our property, if anything has to be

14 done, will be taken care of by DEP, I

15 guess.

16 MR. GORMAN: By somebody.

17 MR. GRAHAM: By somebody. Because a

18 lot of time and effort on the part of this

19 community as a whole has gone into this

20 project. And we want to safeguard the

21 children of the community above all.

22 MR. GORMAN: Is there any fast

23 tracking or something they could test

24 before we actually build it on April 7?


500183


1 MS. GRAHAM: Is there any kind of a

2 boring that they could come down and do to

3 totally assure us? Because we're already

4 contracted in for the beginning of this

5 project on the 7th. Thank you.

g ********

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500184

94

1 C E R T I F I C A T E

2 STATE OF NEW JERSEY

3 I, LINDA A. BURNS, Shorthand Reporter and Notary

4 Public of the State of New Jersey, do hereby certify

5 that I reported the public hearing in the

6 above-captioned matter and that the foregoing is a

7 true and correct transcript of the stenographic notes

8 of testimony taken by me in the above-captioned

9 matter.

10 I further certify that I am not an

11 attorney or counsel for any of the parties, nor a

12 relative or employee of any attorney or counsel

13 connected with the action, nor financially interested

14 in the action.

15

16

17

18

19

20

21

22 Linda A. Burns

23

24 Dated: March 4, 1999


a A. Burns500185 ary Public

Appendix D

Written Comments

500186

UUUUUfciitK3-03-1999 3 = 43PM i T r me.

R E S O L U T I O N

#R-05t -99

A RESOLUTION ENDORSING THE|ENVIRONMENTALPROTECTION AGENCY'S PLAN FOR CLEANUP OF RADIOLOG1CALLY

CONTAMINATED PROPERTIESiWHEREAS, the United States Environment!) Protection Agency has investigated

vahous sites in Gloucester City and Camdon in rclatiqiship to the Welsoach/Genenl MantleSupcrfund Contamination She, including the four areas in Gloucester Chy listed below:

a) Study Area Two - an industrial zonal property along the Delaware River,formerly occupied by the Wclsbach Cc -poration and a residential area to theimmediate east:

b) Study Area Three - residential and recrer lional properties, including the JohnsonBoulevard Land Preserve;

c) Study Area Five - residential proper ies, vacant land properties, and twomunicipal parks near Temple Avenue anc the South Branch of Newton Creek,

d) Study Area Six - vacant lots in a resident al zoned area of Gloucester City: andi

WHEREAS, the E.P.A.'$ investigations have shown properties in the above statedlocations to contain soil contaminated to van-ing degre :s with thorium, radium and uranium.which are associated with waste materials generated inplace at former Welsbach Gas Mantle facilities: and

WHEREAS, the E.P.A. has proposed the follov

the manufacturing activities that took

ing alternatives to address the findingsstated above:

a) No action;b) Installation of engineering controls;c) Excavation and off-site disposal of contai linated materials; and

WHEREAS, the locations of this contaminationand recreational areas, and the cost of excavation i$31,9 t2T 120.00, shall be born entirely by the United State

re almost entirely located in residentialid off-site disposal, estimated to beEnvironmental Protection Agency.

NOW, THEREFORE, BE IT RESOLVED thit the Mayor and Common Council ofGloucester City do hereby endorse the excavation and oftpsite disposal of contaminated materialsfrom the Welsbach/General Mantle Superfund Contamination Sites which are located inGloucester City.

Robert T. German. Mayor

Passed by the Mayor and Common Council of Gloucester C: lyofMajph, 1999

500187

2

3U.S. Environmental Protection Agency's (EPA's)

4Proposed Plan for Cleanup of Superfund Sites

5Public Hearing

6

7 _ . _ _ - _ _ - _ _ - - . _ _ _ _ _February 24, 1998

8 __._——.._-.__._..

9 Public Meeting of the U.S. Environmental

10 Protection Agency (EPA) held at the Camden County

11 Municipal Utilities Authority Auditorium, Camden,

12 New Jersey, before Linda A. Burns, Shorthand Reporter

13 and Notary Public of the State of New Jersey, on the

14 above date, commencing at 7:00 p.m.

15

16

17

18

19

20

21

22

23

24

D E 6 N A N & B A T E M A N , INC.(609) 547-2565 500188

1 EPA MEMBERS IN ATTENDANCE:

2 Richard J. Robinson, Project ManagerPat Evangelista, Team Leader

3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch

4 MALCOLM PIRNIE REPRESENTATIVES IN ATTENDANCE:

5 Robert Kerbel, AssociateAlan Fellman

6ATSDR REPRESENTATIVES IN ATTENDANCE:

7Arthur Block, Sr. Regional Representative

8ALSO PRESENT:

9Fred Mumford, NJDEP

10

1 1 I N D E XWitness Page

12Donna Maggio(ph) (INAUDIBLE) 41,47

13 Olga Pullman(ph) 44

14E X H I B I T S

15(There were no exhibits marked at this time.)

16

17

18

19

20

21

22

23

24

D E 6 N A N & B A T E M A N , I N C .(609) 547-2565 500189

EPA Public Hearing - 2/24/99

1 MS. CERVANTES-GROSS: We're going to

2 go ahead and start. I just wanted to thank

3 everyone one coming here tonight and we'll

4 be giving you several presentations

5 tonight. My name is Mary Helen

6 Cervantes-Gross. I'm with the EPA and I'm

7 here actually, standing in temporarily, for

8 Natalie Loney whom most of you know. She

9 just had a baby boy on February 14 and she

10 will be back out here in the future to work

11 with you again.

12 But with us here tonight is

13 Rick Robinson, Project Manager for the

14 Welsbach General Gas Mantle Superfund site;

15 Pat Evangelista, who is the team leader

16 with the EPA overseeing various types of

17 radiation sites and other types of sites

18 throughout the region. Here as well is

19 Arthur Block with ATSDR. He works with the

20 EPA's Agency for Toxic Substances and

21 Disease Registry, as well as a consultation

22 business on health-related issues. Here

23 tonight also is Alan Fellman as well as

24 Bob Kerbel, both with Malcolm Pirnie who

D E G N A N & B A T E M A N , I NC.(609) 547-2565

500190


1 are contractors for EPA working on both

2 investigation of the sites and put together

3 much of the information that you will hear

4 tonight.

5 And I just wanted to remind everyone

6 that what you say tonight, whatever

7 questions you have, what comments you have•

8 --we have Linda Burns here who is a

9 stenographer and who is officially taking

10 down all of your questions and comments and

11 they will go into the official record. And

12 at the end of the public comment period,

13 which ends next Wednesday, March the 3rd,

14 we will review all of the comments chat we

15 have received both here tonight and at the

16 meeting that we had last night in

17 Gloucester City. We will also review any

18 written comments that we have, and we will

19 prepare a responsiveness document answering

20 or responding to any comments that you

21 have. As well, all of these comments will

22 be looked at before we make a final

23 decision, because that's what we do with a

24 Superfund program. Throughout the program

D E 6 N A N & B A T S M A N , INC.(609) 547-2565 500191


1 we come out to the community before we make

2 final decisions in an attempt to answer any

3 questions or concerns you have, so that we

4 are sure to address those in its final

5 decision.

6 So with that I will turn it over to

7 Pat who will talk to you a little bit about

8 the Superfund program in general.

9 MR. EVANGELISTA: Welcome. Before I

10 get started in my part of the meeting this

11 evening, I'd like to introduce to you, as

12 well, Fred Mumford who is here representing

13 the New Jersey Department of Environmental

14 Protection. What I'd like to do in getting

15 the meeting started is to just talk to you

16 a little bit about the Superfund process

17 and how it works and just to familiarize

18 you or remind you of how it works.

19 Back in 1980 Congress handed the EPA

20 a law known as the Comprehensive

21 Environmental Response and Liability Act

22 and amended it five or six years later. So

23 it's what we're working with at this site

24 today.


500192


1 It starts out with what's known as

2 discovery. Discovery is the part of the

3 process where we are actually made known of

4 the site and it warrants us to follow up

5 and perform what's known as a preliminary

6 assessment or site inspection where we

7 gather information that we need to do

8 what's known as a hazard ranking. In

9 performing the ranking we generate what's

10 known as a hazard ranking score. And if

11 that score is or exceeds 28.5, the site

12 ends up on what's known as the National

13 Priorities List.

14 This allows us as EPA to perform

15 what's next in the process and this is

16 known as a remedy investigation feasibility

17 study. That's what we would call the more

18 detailed investigation of the site to

19 gather all of the information that we need

20 about that site to generate alternatives

21 that we would look into for remediating the

22 problem or cleaning up the problem. And

23 those alternatives are evaluated in the

24 feasibility study part of that remedial

D E G N A N & B A T E M A N , I N C(609) 547-2565


1 investigation.

2 The alternatives are then evaluated

3 according to certain criteria and, you

4 know, at the end of that process we would

5 recommend a cleanup alternative that we

6 would put before you, the public, and

7 concerned citizens. And that part of the

8 process is what's known as the proposed

9 plan.

10 The proposed plan is what we

11 presented as of February l and is subject

12 to your review and comment. And that's

13 part of the reason why we're here tonight.

14 As a result of the public comment

15 period, we generate what's known as a

16 transcript, hence our stenographer here.

17 And that transcript is added to the record

18 of decision which formalizes the agency's

19 decision, your comments inclusive, of

20 course.

21 After that we enter into what's known

22 as remedial design. We actually design the

23 nuts and bolts of the remedy that the

24 agency has selected.

D B G N A N & B A T B M A N , I NC.(609) 547-2565

500194


1 From there we enter into the cleanup

2 phase and ultimately we certify it as clean

3 and acceptable for future use. And we

4 delete the site from the National

5 Priorities List.

6 That's basically the process. If you

7 have any questions I'd be happy to answer

8 them for you later. Thank you.

9 MR. ROBINSON: I'll just go into a

10 little bit of background on the site. As

11 most of you know the site is located both

12 in Camden and in Gloucester City. And it

13 comprises the two former gas mantle

14 manufacturing facilities. It also includes

15 residential properties, commercial

16 properties, municipal park lands in

17 Gloucester City and vacant land.

18 As part of the State's investigation

19 early on, they divided the sites into study

20 areas. And for the purposes of our

21 investigation we followed those study

22 areas. And the first study area is where

23 we are right now in Camden around the

24 General Gas Mantle facility and the

D E G N A N & B A T E M A N , INC.(609) 547-2565 500195


1 surrounding properties. Study Area Two is

2 Gloucester City, the former Welsbach

3 facility. Study Area Three is also in

4 Gloucester City. It comprises residential

5 properties and land preserve. Study Area

6 Four, some residential properties in the

7 Fairview section of Camden. And Study Area

8 Five, residential properties including

9 municipal parks in Gloucester City. And

10 Study Area Six is also some vacant land

11 properties in Gloucester City.

12 Again, Study Area One is around the

13 General Gas Mantle facility here in

14 Camden. And this is a photograph of the

15 area and the General Gas Mantle building is

16 highlighted. There's a photograph of the

17 famous General Gas Mantle building.

18 Study Area Two is the former Welsbach

19 facility, it's now owned by Holt. The

20 Gloucester terminal is there on Kings

21 Street. And the Armstrong building is the

22 last remaining building from Welsbach's

23 operation.

24 Study Area Three is Gloucester City

D E G N A N & B A T E M A N , INC.,609, S47-2S6S

10EPA Public Hearing - 2/24/99

1 and it comprises the swim club area and

2 Johnson Boulevard Land Preserve.

3 Study Area Four is in the Fairview

4 section of Camden. And we only had a few

5 properties in that area that had some

6 elevated gamma radiation levels.

7 Study Area Five is Gloucester City

8 and comprises a dump area off of Temple

9 Avenue and municipal park lands.

10 Study Area Six is a newer identified

11 area in Gloucester City. We call it the

12 Popcorn Factory.

13 Site history: In about 1885 a

14 Dr. Carl Auer von Welsbach invented the

15 process of using thorium to manufacture gas

16 mantles. And just to let you know, gas

17 mantles are the material that's used for

18 camping lanterns or in the street lights.

19 Right there is a gas mantle (indicating).

20 And what they did is they took a sock of

21 material and dipped it in a solution of

22 thorium. And when the sock dried and they

23 lit it, it produced a very brilliant white

24 light. And as a result the thorium is


500197


1 radioactive. And that's what we're here to

2 clean up.

3 In the 1890s welsbach started

4 manufacturing the gas mantle and by the

5 turn of the century they were the world's

6 largest manufacturer of them. And in the

7 early '40s they went out of business when

8 the electric light put gas lighting out of

9 business basically.

10 Very little is known about General

11 Gas Mantle. We know they operated from

12 around 1912 to 1941. We just know that

13 they probably used radium and thorium.

14 They didn't manufacture -- they didn't

15 process any ores. They just bought the

16 ores -- bought the refined radium and

17 thorium. And they manufactured gas

18 mantles.

19 What we've termed all of the other

20 properties that are associated with the

21 radiological contamination here, besides

22 the Welsbach facility and the General Gas

23 Mantle facility, we call them vicinity

24 properties. And they were contaminated



1 either from disposal of ore tailings from

2 Welsbach, or building debris from when they

3 knocked some building down, or when they

4 built the bridge back in the early '50s, or

5 from workers bringing contamination home

6 with them.

7 Previous investigations: The site

8 was initially identified in 1980 as a

9 potential radiation site during search of

10 the U.S. Radium site in Orange, New

11 Jersey. And in 1981 EPA sponsored an area

12 fly-over to search for gamma radiation.

13 And a helicopter came over the area looking

14 for excess gamma radiation levels.

15 In the mid-1980s the State went out

16 conducting preliminary screenings in the

17 area. And in the early 1990s they

18 investigated over a thousand properties

19 throughout Camden and the Gloucester City

20 area. Based on those results they

21 identified about 20 properties that they

22 felt that needed more immediate action.

23 And as a result they installed some

24 radon/thoron ventilation systems in some



1 homes. They put concrete or steel sheeting

2 down to shield for gamma radiation. And

3 they purchased one property in Gloucester

4 City and relocated the resident.

5 Also, in 1992 they removed

6 radioactive materials from the old General

7 Gas Mantle building. They relocated the

8 occupant at the time, Ste-Lar Textiles.

9 And they sealed up the building to restrict

10 access.

11 The State investigation: They base

12 their contamination levels on surface

13 exposure rates, indoor radon sampling and

14 limited surface soil samples. However,

15 they didn't perform any subsurface

16 sampling. They made no estimate on the

17 amount or extent of contamination. And

18 they were just looking to address any of

19 the immediate potential health concerns at

20 the time.

21 EPA's involvement at the site, again,

22 when the site was placed or took the lead

23 --we took the lead on the site when the

24 site was placed on the Superfund list back

D E G N A N & B A T E M A N , I N C .(609) 547-2565 OQ


1 in June of 1996. Currently, the General

2 Gas Mantle facility is inactive and boarded

3 shut. Welsbach is an active facility, now

4 owned by Holt. And the vicinity

5 properties, any immediate health treats

6 were either addressed through interim

7 measures performed by the State or by EPA

8 removal action last December in the park in

9 Gloucester City.

10 I'll now turn it over to Alan Fellman

11 from Malcolm Pirnie and he will give you a

12 real brief overview on radiation.

13 MR. FELLMAN: I just want to spend a

14 few minutes going over a couple of the

15 terms regarding radioactivity that will

16 hopefully make it a little easier for you

17 to understand.

18 Some of the things we're saying about

19 the conditions of these properties, when we

20 talk about radioactivity we're not talking

21 about a typical product that we measure in

22 pounds or address in terms of mass. We're

23 more concerned with the amount or the rate

24 at which the radioactive atoms are



1 decaying. And the unit that we use to

2 describe that is called pico Curies, which

3 we abbreviate pCi.

4 Now when we have radioactivity in

5 soil, we express the amount as

6 concentration in pico Curies per gram of

7 soil. And if we're talking about

8 radioactivity in water or liquid, then we

9 would express it as pico Curies per liter,

10 pCi/1.

11 Again, now this is only indicative of

12 how much there is. It doesn't really

13 address the dose or the risk. To do that

14 we need some other terms. The dose of

15 radiation is expressed in the unit known as

16 millirems. And what we are expressing when

17 we quantify millirems, that's a measure of

18 how much energy, which is released from the

19 radioactive emissions, is transferred from

20 those atoms into an absorbing media such as

21 the human body. The amount of energy

22 that's deposited is used to determine what

23 the dose is and, of course, the higher the

24 dose the higher the risk.

D E 6 N A N & B A T E M A N , I NC.(609) 547-2565

500202


1 There are several different types of

2 radioactivity that are emitted from

3 thorium, uranium, radium, radionuclides

4 that are associated with this waste

5 material. Alpha particles are the heaviest

6 of these. They have mass. They travel

7 very slowly. And they can be shielded by

8 something as thin as a piece of paper.

9 Beta particles are intermediate in

10 penetrating ability. They can be

11 transferred through a piece of paper but

12 are more likely to be stopped by a piece of

13 wood.

14 On the other hand, gamma radiation,

15 also known as photons, have no mass.

16 They're simply packets of energy. And they

17 are also sometimes referred to as

IB penetrating radiation. These are things

19 that are more likely to get through paper

20 or wood. And it takes something denser or

21 thicker to shield them, such as concrete or

22 . lead.

23 The problem that we have here for the

24 most part has to do with the radioactive



1 residue being present in dirt. And when

2 the dirt gets moved from the Welsbach or

3 General Gas Mantle facility onto an

4 adjacent or vicinity property, it can be

5 put in the ground either adjacent to a

6 structure or in some cases beneath a

7 structure. When the radioactivity decays

8 several of the -- most of the radionuclides

9 are solid. They don't travel; they don't

10 really go anywhere. They stay where they

11 are placed. But at one point in the

12 process the resultant atom that's formed is

13 a gas, radon. And if the radon gas is

14 formed in soil that's either up against the

15 side of a building or beneath the building,

16 now you've got something that's mobile and

17 can emanate from the soil into the building

18 resulting in a potential medical threat.

19 For people who don't have that

20 problem but where there's this type of

21 radioactivity associated with the soils

22 some distance from a structure, in that

23 case the potential exposure to the gamma

24 radiation that's emitted from the ground is


18BPA Public Hearing - 2/24/99

1 part of the radiation dose to a person

2 occupying that area.

3 Also, the next few minutes will be

4 spent going over the field investigations

5 that Malcolm Pirnie has performed for EPA

6 over the last couple of years and

7 Bob Kerbel will be talking about that.

8 MR. KERBEL: I know some of you were

9 here at the meeting we had a year ago, but

10 I'll just go over in the nutshell again the

11 type of work we've been doing in the two

12 communities. We did investigations at the

13 former Welsbach facility and the General

14 Gas Mantle facility, they are industrial

15 facilities. Now anything beyond the border

16 of those two facilities we term vicinity

17 properties. The term residential property,

18 that's categorized into the vicinity

19 property category.

20 Now, if there's anything good from

21 our standpoint as investigators, it's that

22 this material is easy to detect. We have

23 meters that we walk over the property and

24 it's easy to detect if there's an elevated

D E G N A N & B A T B M A N , I N C(609) 547-2565


1 radiation level. So we did that on all of

2 the properties. And then if we found an

3 elevated radiation level we would go back

4 and take a radiological sample and send it

5 to the laboratory to confirm that it was

6 indeed due to thorium or radium.

7 On the industrial sites, given the

8 industrial nature of the property, we also

9 checked for chemical contaminants. One of

10 the focuses of our RI/FS report that we're

11 putting together is to come up with a cost

12 of how much it would cost to clean this

13 up. So we need a volume. So if there was

14 contamination, we had to know how deep the

15 contamination was. So we put in shallow or

16 deep borings, depending where we were. If

17 you notice, there's not a deep check mark

18 on the soil borings for the vicinity

19 properties. That's only because, in

20 general, the contamination was really on

21 the surface of the property. As Alan was

22 telling you, radon gas can get in a home so

23 we check for radon in any structure that

24 might have been on a property. And we also


500206


1 did alrl-a/beta measurements for structural

2 material sampling. Because in some cases,

3 especially on the industrial properties,

4 the contamination wasn't always associated

5 with soil but the building material

6 itself.

7 Let me work you through this so you

8 can kind of understand the process. This

9 is an old picture of the Welsbach facility

10 which existed about, you know, the early

11 part of the century. Just to give you some

12 bearings here because I know it's not a

13 good picture. The Delaware River is on

14 top. You can see the smoke stack of that

15 facility. Kings Street is on the bottom.

16 This is Gloucester City. But if. you can

17 imagine, they made these gas mantles at the

18 beginning of the century. The hazards

19 associated with any materials having

20 radioactivity associated with it really

21 weren't known at that time. Things like

22 X-rays were just being discovered and

23 nuclear power -- things like that were

24 decades in the future yet to come.

D E G N A N & B A T E M A N, I N C .(609) 547-2565 500207


1 But as years went by and in the past

2 couple of decades, we became aware of the

3 hazards that could be associated with any

4 radioactive materials. And someone

5 prudently said we should go back to all of

6 these facilities that operated in the early

7 part of the century and check to see if

8 there were, indeed, some radioactive

9 materials associated with those

10 properties.

11 So if you could imagine, you had a

12 facility like this (indicating) and you had

13 this mound, basically, of sandy-like dirt

14 that was there and they processed the

15 thorium out of that sand. So what happened

16 is years later we go back to that property

17 to see if we can find anything. Of course,

18 the facility is gone by now. But the

19 circle showing where the facility used to

20 be, it's actually a large 52-acre sprawl at

21 this cargo area.

22 But if you could imagine, let's say,

23 if you had these large buildings, they

24 probably had large basements associated



1 with them. And they knocked down the

2 building, you would assume, and maybe put

3 them in those large basements and paved

4 over it. So the first thing we would do is

5 go over this entire property doing the

6 surface exposure rate we talked about to

7 look for elevated levels of gamma

8 radiation. And we did that over the course

9 of several weeks. And then we take that

10 information back with us to our office and

11 we have computer programs where we can look

12 at the data.

13 And we go back now, this is a bird's

14 eye view looking down at the facility, and

15 all the different colors are where we do

16 have elevated levels of radiation. So

17 clearly there was something and is

18 something on that property. We go back to

19 locations like this and take soil samples

20 to see that it is thorium causing the

21 elevated levels, and it is. And we do the

22 borings to see how deep it is to come up

23 with a volume. So that's really what goes

24 on at the Welsbach facility.

D E 6 N A N & B A T E M A N , INC.(609) 547-2565 5Q0209


1 To -jump a little closer to home here

2 in Camden, to tell you a little bit about

3 what we've done. This is the General Gas

4 Mantle facility. And as Rick told you,

5 it's boarded up now. And as Alan alluded

6 to, this material gives off radon gas. But

7 there's no ventilation in this building

8 because the windows are all boarded up. So

9 when we go in there to work in that

10 building, there are elevated levels of

11 radon levels. There is soil that is

12 contaminated under the building and

13 adjacent to the building. And it does come

14 out somewhat onto South Fourth Street,

15 along with the sidewalk and into the street

16 somewhat.

17 So that will eventually need to be

18 removed or remedied as Rick will talk

19 about. The building is vacant. There are

20 wood floors. Those woods floors as well

21 have some contamination associated with

22 it. So if this building were to be

23 demolished there may be a need to remove

24 those floors before any demolition takes


500210


1 place.

2 I just wanted to touch on this now

3 but Alan will come back and talk a little

4 bit more about risk. But when we do work

5 on properties like this, it's not like

6 we're all dressed up in special equipment.

7 He wear our regular work clothes and we

8 walk throughout the building with the

9 meters. A real hazard that's associated

10 with it, from our standpoint, is if we have

11 somebody fall through a floor while we're

12 in the building rather than the radiation

13 problem itself. But Alan will talk a

14 little bit more about risk.

15 We'll talk about the vicinity

16 properties now. One of the problems is

17 there is such a large geographical area

18 associated with this site where

19 contamination could end up. If we were to

20 have gone throughout the whole community

21 and start from scratch, it would have taken

22 us years to do this. But fortunately the

23 State and Fred's group, they were here

24 previously and they went through over a



1 thousand properties and investigated those

2 properties.

3 Now, when we started this project we

4 didn't want to go out and reinvestigate all

5 of these properties. We wanted to use the

6 State's data. But we had to be sure we

7 could use that data. So we went to 20

8 properties and we compared our data to the

9 State's data. And we agreed that we can

10 use the State's data to somewhat categorize

11 these properties.

12 We went through all of the State's

13 data and we categorized the properties

14 something like this. Ballpark thousand

15 properties that the State went to,

16 approximately half, 449, we don't see any

17 evidence that there's contamination

18 associated with those properties. Then we

19 have the category we call suspect

20 properties. It's a pretty large grey area

21 for us. What that category means is that

22 we're not 100 percent sure that they're

23 clean. We're not 100 percent sure that

24 they may be contaminated either. But we do

O E G N A N & B A T E M A N , I N C .(609) 547-2565

500212


1 want to go back and test those properties.

2 If a property was simply adjacent to

3 contaminated property, we call that a

4 suspect property and we put it in this

5 category. If it had an elevated radon

6 level -- many homes in New Jersey have

7 elevated radon. But in this case we tend

8 to ask ourselves, is that due to normal

9 radiation associated with the soil or is it

10 due to the Welsbach facility. We're not

11 sure right now so we want to go back and

12 check.

13 There's radiation all over. It's a

14 natural thing and it ranges. There's an

15 average. It's high in locations and low in

16 others. In some cases you could live in a

17 brick home and the levels could be higher

18 than you normally expect. But we would put

19 it in this category. So there are 585

20 properties that we would want to go back to

21 now and kind of do additional testing

22 eventually and either move them over to the

23 clean category or if we needed to move them

24 to the contaminated properties category.

D E G N A N & B A T E M A N, I N C .(609, 547-2565


1 And then finally there's a category

2 where we have potentially contaminated --

3 they are properties that, based on the data

4 we have available, the evidence suggests

5 that there is contamination on those

6 properties. And we used our investigation

7 from the 20 we went to to come up with a

8 volume of materials to estimate a cleanup

9 cost associated with the project. And Rick

10 will come back and talk a little bit more

11 about that in a couple of minutes, right

12 after Alan talks a little bit more about

13 health risks.

14 MR. FELLMAN: Before you can really

15 get a handle on the risk from exposure to

16 radiation, it's helpful, I think, to

17 understand that we live on a radioactive

18 planet. And as a result we're constantly

19 being exposed to natural sources of

20 background radiation. The items that are

21 listed on this table break down the

22 components of background radiation.

23 He are radiated from the atmosphere.

24 He receive radiation from natural levels of


500214


1 radionuclide in soil and rock, many of the

2 same radionuclide that we have ^n the waste

3 stream at the Welsbach and General Gas

4 Mantle facilities; uranium, thorium,

5 radium.

6 Inhaled radioactivity, that 200

7 milligrams per year, is the average dose in

8 North America from radon gas. Any time you

9 put four walls and a ceiling together,

10 you're going to get some level of indoor

11 radon that's going to deliver a dose. And

12 the average radon level is about one to one

13 and a half pico Curies per liter there, and

14 that's going to give you your 200

15 milligrams.

16 Internal emitters is referring to the

17 various radionuclide that we store in our

18 body tissues. As a reflection of the fact

19 that there's radioactivity naturally in

20 soil, then when we grow fruit and

21 vegetables and all sorts of products, some

22 of that radioactivity is taken up and some

23 of it is ingested. There's natural

24 potassium which is an essential

D E G N A N & B A T E M A N , I N C.(609) 547-2565 500215


1 micronutrient. We ingest potassium in lots

2 of different products. A small fraction of

3 that potassium is radioactive.

4 So we carry around these

5 radionuclide. We ingest them every day.

6 We excrete them every day. And as a result

7 of their being in our bodies, we're exposed

8 to a dose of about 40 millirem per year.

9 There's also a whole lot of

10 radioactivity in lots of different types of

11 consumer products. And as you read through

12 some of these, you can see that there's

13 quite a range. And I brought a couple of

14 items that add to those.

15 This is Norton salt substitute. If

16 you need to keep your sodium intake to a

17 minimum because of high blood pressure or a

18 cardiac problem, your doctor may suggest

19 that you use potassium chloride instead of

20 sodium chloride. And as I just said, some

21 potassium is radioactive. And there's no

22 way to separate out the radioactive

23 potassium from the nonradioactive

24 potassium.


500216


1 This instrument is known as a pancake

2 detector. And as you can hear, from

3 natural sources it has a very low

4 efficiency, you'll get sporadic clicks.

5 When I hold the salt substitute up, you get

6 a slightly positive response and it's easy

7 to hear the difference. Again, that's

8 natural potassium in the salt substitute

9 that the detector can see.

10 Here is a smoke detector. Everybody

11 should have these in their home. And one

12 of the components of the smoke detector is

13 one micro Curies of Americium 241, a

14 man-made radionuclide. And when I hold

15 this meter up to the source, again you can

16 hear the instrument respond.

17 This is a piece of Piestawear(ph).

18 It's made in the Southwest, covered with a

19 glaze known as yellow cake. And that glaze

20 has a lot of natural uranium in it.

21 There's a lot of radioactivity here. There

22 are people who eat off of these and you'll

23 find these in antique shops, at antique

24 shows all around the country. So I can

D E 6 N A N & B A T E M A N , INC.(609) 547-2565 500217


1 either leave that here and radiate my

2 colleagues or move it back out of range a

3 little bit.

4 We're concerned about radiation dose

5 because radiation is a known carcinogen.

6 That is the only health affect that we need

7 concern ourselves with. There are no acute

8 short-term health problems associated with

9 exposure to radiation with the exception of

10 very, very high doses which are not

11 possible from environmental issues such as

12 what we have here.

13 So we're worried about cancer. We

14 know that people who have been exposed to

15 very high levels of radioactivity in those

16 populations, there is most definitely an

17 increase in the incidence of cancer. When

18 we set public health policy in this

19 country, we assume that there is a risk of

20 cancer when we're exposed to any dose of a

21 carcinogen, no matter how small. Now, the

22 fact of the matter is, when we look at the

23 scientific data, we don't really know if

24 that's true or not.


500218


1 Because what we have here is, again,

2 what's known as a dose response curve or

3 dose response line. As the dose increases

4 -- so up here in this range (indicating)

5 we're looking at high doses such as the

6 Japanese who survived the atomic weapons

7 blast, groups of patients who were radiated

8 for various ailments in the '30s or '40s

9 before medical science realized that that

10 wasn't the way to go. The radium dial

11 painters who were basically ingesting

12 radium while they painted watch dials

13 during the 1920s. Several of them died

14 from acute illnesses but most of them

15 survived and went on to live 20, 30, 40, 50

16 years. And in that group there was

17 elevated cancers. So these are groups who

18 got very high doses and we know that the

19 incidence or cancer or the health effect or

20 risk was elevated.

21 Now we get down to the lower end of

22 the curve where I showed you, just a few

23 minutes ago, background radiation, that we

24 all get a couple hundred millirems per



1 year. So now we're down in this area of

2 the curve (indicating). And now we've got

3 this type of a waste stream where there may

4 be additional exposure on the magnitude

5 similar to what we're getting from

6 background. And what do we know about

7 that?

8 Well, we don't have any scientific

9 data that would show that people who are

10 exposed to these levels are actually going

11 to suffer increased numbers of cancer. We

12 don't know that. The scientific studies or

13 physical tests are not powerful enough to

14 discern that when we're talking about a

15 disease or group of disease that is

16 afflicting one out of every four Americans

17 to begin with. So you just can't measure

18 it at these low levels. This is what we

19 call an area of great uncertainty.

20 However, EPA's policy is to assume

21 that there is some risk at these low

22 levels. And when the risk that we

23 calculate based on the data that we

24 generate during our studies, when that is

O E G N A N & B A T E M A N , I N C .(609) 547-2565

500220


1 placed in a risk assessment model and it

2 shows us a risk that's unacceptable

3 relative to the acceptable risk range that

4 EPA has established, EPA can then use that

5 information as the basis to go forward with

6 the cleanup.

7 And now I'll let Rick talk about

8 cleanup alternatives.

9 MR. ROBINSON: For the Welsbach/

10 General Gas Mantle site we evaluated

11 cleanup alternatives for the three property

12 types we just discussed: The Welsbach

13 facility, the General Gas Mantle facility,

14 and for the vicinity properties. The three

15 alternatives that we looked at were the No

16 Action Alternative; an Engineering Controls

17 Alternative; and Excavation and Off-site

18 Disposal Alternative.

19 As part of the Superfund process, EPA

20 has to look at a cleanup based on a No

21 Action Alternative. What if we did

22 nothing, what would be the result? And

23 based on the risk assessment that Alan just

24 explained a little bit, we found that there



1 was a risk and, therefore, we were going to

2 take an action. And as a result, we're not

3 going to talk about no action anymore.

4 For the vicinity properties, the

5 Engineering Controls Alternative, it would

6 require outdoor gamma shields on 50

7 properties; indoor gamma shields on about

8 20 properties; and radon mitigation systems

9 on about 4 properties. And the excavation

10 and off-site disposal alternative, if any

11 property was found to have contamination

12 above our cleanup levels, we would take the

13 material off site for disposal, dig it up

14 and take it off site.

15 The Welsbach facility, again, the

16 Engineering Controls Alternative, we would

17 put outdoor gamma shields on the property.

18 We would have to have deed restrictions

19 limiting future site work. And we would


21 sure that the remedy would still be

22 effective.

23 For the excavation and off-site

24 disposal alternative for the Welsbach

O E G N A N & B A T E M A N , INC.(609) 547-2565


1 facility, again, we find the contamination

2 above our cleanup level so we would dig

3 that material up and send it off-site for

4 disposal.


6 Engineering Controls Alternative would

7 require outdoor gamma shields around the

8 outside of the building. We would have to

9 permanently board-shut the building. We

10 would have to have deed restrictions

11 limiting future access to the site. And we

12 would have to go back every five years to

13 make sure the remedy would still be

14 effective.

15 Then for the General Gas Mantle, the

16 excavation and off-site disposal

17 alternative, we have two operations. The

18 first option is we would take the building

19 down and dispose of the whole building as

20 contaminated material. The second option,

21 Option B is we would first try to

22 decontaminate the building, take the

23 radioactive material out of the building.

24 And that would reduce the volume of



1 materials that would have to be sent

2 off-site for disposal.

3 The alternatives of the engineering

4 controls, again, just to summarize, we

5 would have to have deed restrictions on the

6 property limiting future site work. The

7 State would have to be responsible for

8 enforcing those restrictions. And we would


10 sure it would still be effective.

11 For the excavation and off-site

12 disposal alternative, all of the

13 contamination above our cleanup standards

14 would be excavated and sent off-site for

15 disposal. And that would result in, again,

16 the contaminated materials being removed

17 from the site. Mobility of the

18 contaminants would be eliminated. And

19 there would be no significant institutional

20 controls remaining on the properties at

21 all. The properties would be safe for

22 future reuse and protective of human health

23 and environment.

24 Just to go over the summary of the

D E G N A N & B A T E M A N , I N C .<609) 547-2SS5


1 costs, for the engineering controls for the

2 vicinity properties would be about a little

3 over $2 million. And for the excavation

4 and off-site disposal on the vicinity

5 properties, just over $13 million dollars.

6 For the former Welsbach facility, the

7 engineering controls just under $6 million

8 dollars. And for the excavation and

9 off-site disposal alternative, eighteen and

10 a half million dollars.


12 the engineering controls is just under

13 $400,000. And the excavation and just the

14 demolition and disposal alternative option,

15 just over $2 million dollars. And for the

16 decontamination and demolition, just under

17 $2 million dollars.

18 EPA1s preferred remedy action is the

19 excavation and off-site disposal

20 alternative for both the vicinity

21 properties, Welsbach and General Gas Mantle

22 facility. For the General Gas Mantle we

23 have Option B, which is the decontamination

24 of the building prior to demolition. The



1 total cost of the remedy is just under $34

2 million dollars.

3 Now we go to what do we next, the

4 next steps. The first thing that we're

5 doing right now is respond to public

6 comment. We're here today to take your

7 verbal comments. And also, again we have a

8 public comment period for written comments

9 which ends next Wednesday, March 3. And we

10 invite the public to send in written

11 comments as well as your comments today.

12 Once we receive all of the comments,

13 we select a remedy in a document called a

14 Record of Decision (ROD). And once we sign

15 that ROD, EPA can start the design of the

16 cleanup.

17 Our focus will be first on the

18 residential properties and then we'll go to

19 the commercial and industrial properties.

20 We hope to start the investigations on the

21 suspect properties in the fall, later this

22 year, and also start the design

23 investigations on the potentially

24 contaminated properties this year also.


500226


1 And we also plan to demolish the General

2 Gas Mantle building as soon as we can,

3 hopefully in one to two years.

4 This actual cleanup on these

5 individual properties we estimate about

6 three to five years from today. We're also

7 in the process right now of conducting a

8 ground water investigation to make sure

9 that none of the contamination from the

10 site is getting into the ground water. And

11 we also have to investigate some wetland

12 areas in Gloucester City around Newton

13 Creek that are next to some of the known

14 contaminated areas.

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1 MR. ROBINSON: Now we'd like to open

2 the meeting up for some comments and

3 questions.

4 MS. CERVANTES-GROSS: If you have any

5 questions about what we discussed tonight.

6 MR. ROBINSON: Please state your name

7 for the record.

8 DONNA MAGGIO(PH) (INAUDIBLE): I have

9 a question with the houses on Arlington

10 Street. When you say you're going to

11 excavate the back yard, how deep is it

12 going to go and what's going to be done for

13 the people while you're doing this? Will

14 this pose any problems for people? What

15 are you going to do to protect them?

16 MR. ROBINSON: Right now on Arlington

17 Street we have not done any volume samples

18 or estimate of the depth of contamination

19 on Arlington Street. That will be done in

20 the design phase. We estimate right now,

21 by what we've seen on other properties that

22 are similar to contamination there, the

23 contamination is about one to two feet.

24 Generally we try to work around the

D B G N A N & B A T E M A N , INC.(609) 547-2565 500228


1 residents and make sure that they're not

2 severely impacted by the work.

3 DONNA MAGGIO: This doesn't pose any

4 sort of a problem, digging up?

5 MR. ROBINSON: We're going to try to

6 minimize any potential impacts through

7 controls during our construction phase.

8 MR. FELLMAN: The impacts are

9 (INAUDIBLE). They are not health related.

10 DONNA MAGGIO: That's what I'm

11 wondering.

12 MR. FELLMAN: when these things are

13 removed, it's done in a controlled way so

14 that dust is minimized. If necessary, soil

15 is wet before taking it off. Before things

16 are sent out., say, in a truck to travel

17 over public roads, the trucks are scanned

18 and the wheels. This is all done in a very

19 prescribed manner so that contamination is

20 not spread.

21 DONNA MAGGIO: Is there a work plan,

22 a document, yet?

23 MR. ROBINSON: When we go to

24 construction, after we've completed the

D E G N A N & B A T E M A N , I NC.(609) 547-2565 500229


1 remedial design, we'll have another meeting

2 prior to the actual demolition or the

3 construction activities. We'll present to

4 you our plan on how we're going to proceed

5 with that phase, the action.

6 MR. EVANGELISTA: We'll intend to

7 make these plans available in repositories

8 for review.

9 DONNA MAGGIO: I have a question as

10 far as the radon in the basements. Are you

11 going to check for radon in the basements?

12 MR. FELLMAN: Well, that's part of

13 the study protocol when we go to any of the

14 suspect properties. The properties that

15 we've been to through the remedial

16 investigation, we scan for gamma radiation

17 indoors and outdoors. We take soil

18 samples, put holes in the ground and take

19 down hole measures, and put radon detectors

20 in the basements and measure for radon.

21 That's typically part of the protocol.

22 The reason why there have been so few

23 properties or structures with elevated

24 radon out of the many properties

D E G N A N & B A T B M A N , INC.(609) 547-2565 500230

44SPA Public Rearing - 2/24/99

1 investigated here is because most of the

2 contamination, where it exists, is out in

3 the yard somewhere as opposed to being

4 adjacent to or underneath the house. If

5 you have — like on Arlington Street where

6 that kind of strip of contamination is

7 toward the rear of the property, closer to

8 the alleyway, the radon gas that was formed

9 in that material is emanating up into the

10 outdoor atmosphere as opposed to if that

11 material was underneath the homes emanating

12 up and would be intercepted by a house and

13 get into the basement. That's when you get

14 the higher level or volume of this stuff.

15 MS. PULLMAN(ph): My name is Olga Pullman.

16 I'd like to first of all say, great, BPA

17 has selected the most thorough cleanup

18 alternative of the three products. I think

19 that's very important for the health and

20 safety of the residents and also the future

21 of this neighborhood.

22 I was just wondering, to make it

23 clear in my own mind what you're saying,

24 the level of cleanup is going to be to


500231


1 remove anything contaminated and bring in

2 fresh fill for any empty areas? And it's

3 your position that after that, that land

4 could be used for anything, residential,

5 playgrounds, parks, vegetable gardens, that

6 level of cleanup?

7 MR. ROBINSON: Yes.

8 MS. PULLMAN: Is that definite? The

9 money has been approved for that project?

10 MR. ROBINSON: Before we can actually

11 get any money for a cleanup we have to go

12 through a design. Once we get the design

13 altogether, we'll be going out to request

14 money from EPA headquarters for the

15 project. Until we complete the -- we're

16 still three to five years away from that.

17 As you see from our presentation, there's a

18 lot of things we have to look at to gather

19 information together.

20 MR. EVANGELISTA: I just wanted to

21 add that behind the scenes that's what's

22 known as Record Review Board. And what we

23 did before we identified our preferred

24 alternative and the projected cost estimate


500232

46KPA Public Hearing - 2/24/99

1 is we took the site and all of the

2 information before this Board within EPA

3 which consists of representation throughout

4 the country. And they gave us a nod of

5 approval that they're okay with the costs

6 associated with it. We don't anticipate

7 any problems in funding the project in the

8 anticipated time frame.

9 MS. PULLMAN: In terms of checking

10 property, I happen to notice where the

11 Arlington Street property is located, the

12 General Gas Mantle, you haven't yet checked

13 the properties on the other side that's not

14 shown on the map, kind of adjacent to it

15 heading north. Is that something you're

16 going to include in this investigation?

17 MR. KBRBBL: That sounds like data

18 the State collected, but we didn't in the

19 last year go into these properties.

20 MR. ROBINSON: Those maps were

21 generated or based on information that the

22 State provided to EPA. As part of our

23 investigation and our next phase in the

24 design, we're going to look at the


500233


1 properties adjacent to known contaminated

2 or potentially contaminated properties.

3 And we'll look at those properties and add

4 them on. In future maps they'll include

5 other properties that the State has not

6 (INAUDIBLE).

7 DONNA MAGGIO: I just had a question

8 with the time frame. So you think you

9 could demolish the General Gas Mantle

10 within one to three years?

11 MR. ROBINSON: One to two years.

12 DONNA MAGGIO: From now?

13 MR. ROBINSON: Yes. We're hoping

14 sooner. As soon as we get the remedy

15 approved the sooner we'll start the process

16 of taking the building down.

17 MS. PULLMAN: What's going to be your

18 next series of steps when you're going to

19 inform the community about what's going

20 on?

21 MR. ROBINSON: Once we select the

22 remedy and the Record of Decision -- and in

23 the Record of Decision will be all your

24 verbal responses today, that's why we have


500234


1 the court reporter here, and any written

2 comments submitted -- that will be in the

3 responsiveness summary attached to the

4 Record of Decision. Once we sign the

5 Record of Decision we'll place that

6 document in the local repositories: One in

7 Camden's main library, one in Gloucester

8 City's public library, and in the Hynes

9 Center of Camden. The next public meeting

10 we'll have is when we're ready to start the

11 construction, most likely the General Gas

12 Mantle demolition, hopefully later this

13 year. If we could move the people along.

14 MR. BVANGELISTA: "People11 meaning

15 BPA management.

16 MS. PULLMAN: So, of course, you'd

17 let us know if something were to happen.

18 If you discover that the scope of work was

19 greater than you thought and you had to

20 reconsider your plans, at what point would

21 you let the community know that, before you

22 make the final Record of Decision?

23 MR. EVANGELISTA: At this point we

24 don't anticipate reconsidering anything as

D B G N A N & B A T S M A N , INC.(609) 547-2565 500235


1 far as what we've proposed in the proposed

2 plan or discussed this evening. The only

3 way that we would reconsider anything would

4 be based on public comment. And based on

5 what we've seen and heard thus far, both

6 here and in Gloucester City, there's

7 nothing indicative of our changing our

8 minds.

9 MR. ROBINSON: Everyone is in favor

10 of us digging the material up and taking it

11 off-site.

12 MS. PULLMAN: Good.

13 MS. CERVANTES-GROSS: In addition, as

14 we pointed out, there are still 500-some

15 properties that we consider as suspect*

16 properties. So in the design -- as we go

17 through the design phase, there will be

18 additional investigation of those

19 properties, to include those properties in

20 what we're proposing. Once we go out there

21 to confirm if they have elevated levels

22 above our cleanup levels, those properties

23 would be included in -- most of the

24 vicinity properties.


500236


1 MR. FELLMAN: Fed into the design

2 process that will be ongoing and current.

3 MR. KBRBEL: There's a lot of

4 variability when we say contaminated

5 properties. It could range from just a

6 small spot where somebody might have to

7 almost come in with a shovel and put it in

8 a barrel and get it off; to maybe a backhoe

9 might have to come in and scrape the top

10 off. So there's a lot of variability.11 MS. PULLMAN: I just realized at this

12 point you can't say exactly how many

13 properties you're going to have to do

14 cleanup and what level it will be. I'm

15 just being paranoid here. At any point you

16 could reconsider the plan if you rediscover

17 it's a greater scope of work or whatever.

18 MR. ROBINSON: NO. If we find

19 contamination it will be taken away.

20 MS. PULLMAN: All right.

21 MS. CERVANTES-GROSS: Any Other

22 questions or comments?

23 Okay. I that's it.

24 MR. ROBINSON: Thank you very much

D B G N A N & B A T B M A N , I N C .(609) 547-2565 500237


1 for attending and hopefully we'll see you

2 soon with the progress of taking the

3 building down.

4 MR. EVANGELISTA: There are some

5 handouts that are on the table and you're

6 welcomed to take a copy.7 ********

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O E 6 N A N & B A T E M A N , INC.(609) 547-2565 500238

52

1 C E R T I F I C A T E

2 STATE OF NEW JERSEY

3 I, LINDA A. BURNS, Shorthand Reporter and Notary

4 Public of the State of New Jersey, do hereby certify

5 that I reported the public hearing in the

6 above-captioned matter and that the foregoing is a

7 true and correct transcript of the stenographic notes

8 of testimony taken by me in the above-captioned

9 matter.

10 I further certify that I am not an

11 attorney or counsel for any of the parties, nor a

12 relative or employee of any attorney or counsel

13 connected with the action, nor financially interested

14 in the action.

15

16

17

18

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20

21 Linda A. Burns

22

23

24 Dated: March 4, 1998

500239D B 6 N A N & B A T E M A N , I N C .

(609) 547-2565 '""" . LindaA-BurnsNotary Pubhc

Mv Commission T>.r,3.

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