EPA/ROD/R02-99/028
1999
EPA Superfund
Record of Decision:
WELSBACH & GENERAL GAS MANTLE (CAMDENRADIATION)EPA ID: NJD986620995OU 01CAMDEN AND GLOUCESTER CIT, NJ07/23/1999
RECORD OF DECISION
DECISION SUMMARY
Welsbach/General Gas Mantle Contamination Site
Glouster City & Camden, Camden County, New Jersey
United States Environmental Protection Agency
Region 2
New York, New York
July 1999
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Welsbach/General Gas Mantle Contamination Superfund Site
Gloucester City & Camden, Camden County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's selection
of a remedial action to address soil and building material contamination at the Welsbach/General
Gas Mantle Contamination Site (the “Site”), in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended
(CERCLA), 42 U.S.C. §9601-9675, and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), as amended, 40 CFR Part 300. This decision
document explains the factual and legal basis for selecting the remedy for the first operable unit of
this Site.
The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the
planned remedial action in accordance with Section 121 of CERCLA. The NJDEP concurs with
the selected remedy (see Appendix IV). The information supporting this remedial action is
contained in the Administrative Record for the Site, the index of which can be found in Appendix
III of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Welsbach/General Gas Mantle
Contamination Site, if not addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedy described in this document represents the first of three planned remedial actions or
operable units for the Welsbach/General Gas Mantle Contamination Site. It will address
radiologically-contaminated soil and building materials at the former Welsbach and General Gas
Mantle facilities and properties in the vicinity of these facilities. For the second operable unit at
the site, the current owner of the former Welsbach facility is performing a remedial investigation
and feasibility study on the last remaining Welsbach era building. A third operable unit is planned
to investigate potential site impacts to groundwater, surface water, sediments, and wetlands. The
major components of the selected remedy include:
! Excavation/removal of soil and waste materials with radiological contamination above
remedial action objectives from the former Welsbach and General Gas Mantle Facilities:
! Excavation/removal of soil and waste materials with radiological contamination above
remedial action objectives from the residential and commercial properties in the vicinity of
two former gas mantle facilities;
! Off-site disposal of the radiologically-contaminated soil and waste materials;
! Decontamination and demolition of the General Gas Mantle Building; and
! Appropriate environmental monitoring to ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in Section 121 of
CERCLA, in that it: (1) is protective of human health and the environment; (2) complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the extent
practicable; (3) is cost-effective, and (4) utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable. However, because treatment
of the principal threats of the Site was not found to be practicable, this remedy does not satisfy
the statutory preference for treatment as a principal element.
Because this remedy will not result in hazardous substances remaining on the remediated
properties above levels that allow for unlimited use and unrestricted exposure, a five-year review
of this action will not be required.
I certify that the remedy selected for this Site is protective of human health and the environment.
TABLE OF CONTENTSpage
SITE NAME, LOCATION AND DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . 4
SCOPE AND ROLE OF RESPONSE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
THE NATURE OF RADIONUCLIDES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
DESCRIPTION OF REMEDIAL ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . 16
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . 21
SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
DOCUMENTATION OF SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . . . . 29
APPENDICES
APPENDIX I FIGURESAPPENDIX II TABLESAPPENDIX III ADMINISTRATIVE RECORD INDEXAPPENDIX IV STATE LETTERAPPENDIX V RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
Site Background
The Welsbach/General Gas Mantle Contamination site (Welsbach/GGM or Site) is a multi-
property site located in Gloucester City and Camden, Camden County, New Jersey. EPA initially
identified the Site in 1980 during an archive search conducted as part of the investigation of the
U.S. Radium Corporation Superfund site located in Orange, New Jersey. Historical U.S. Radium
Corporation files indicated that radiological materials were purchased by U.S. Radium from the
Welsbach Corporation during the 1920s.
Between the 1890s and 1940s, the Welsbach Company (Welsbach) manufactured gas mantles at
its facility in Gloucester City, New Jersey. Welsbach was a major manufacturer and distributer of
gas mantles until gas lighting was replaced by the electric light. Welsbach extracted the
radioactive element thorium from monazite ore and used it in the gas mantle manufacturing
process. Thorium causes the mantles to glow more brightly when heated. A second gas mantle
manufacturing facility, known as the General Gas Mantle Company (GGM), was located in
Camden, New Jersey. GGM operated from 1915 to approximately 1940.
In May 1981, EPA conducted an aerial radiological survey of the Camden and Gloucester City
area to investigate for radioactive contaminants. The survey encompassed a 20 square kilometer
area surrounding the former locations of the Welsbach and GGM facilities. Five areas with
elevated gamma radiation were identified from the aerial survey; they included the locations of the
two former gas mantle manufacturing facilities and three mainly residential areas in both Camden
and Gloucester City. In 1993, EPA reanalyzed the data from the aerial survey. Based on this
revised information, EPA identified a sixth potential radiologically-contaminated area which
includes two vacant lots in Gloucester City.
In the early 1990s, NJDEP conducted detailed radiological investigations at more than 1,000
properties located throughout the original five study areas. Radiological contamination was
identified at the two former gas mantle facilities and at approximately 100 properties located near
the two facilities. In 1996, the Welsbach/GGM site was placed on National Priorities List (NPL)
because of the presence of radioactive contaminants.
EPA divided the Welsbach/GGM site into six study areas in Camden and Gloucester City, New
Jersey (Figure 1). A brief description of each study area and its current land use is presented
below:
• Study Area One: includes the former GGM Facility and residential and commercial
properties which surround the facility (Figure 2.) The former GGM Facility is located in a
mixed industrial, commercial, and residential zoned section of Camden.
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• Study Area Two: includes the location of the former Welsbach Facility and nearby
residential/commercial properties. The former Welsbach Company is situated in industrial
zoned section of Gloucester City with residential properties to the immediate east (Figure
3.)
• Study Area Three: includes residential and recreational properties in Gloucester City,
including the Gloucester City Swim Club and the Johnson Boulevard Land Preserve.
• Study Area Four: includes residential properties in the Fairview section of Camden.
• Study Area Five: includes residential properties, vacant land properties, and two
municipal parks near Temple Avenue and the South Branch of Newton Creek in
Gloucester City.
• Study Area Six: includes two vacant lots in a residential zoned area of Gloucester City.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Welsbach and the GGM Facilities have complex histories of changes in name, ownership, and
operation. Specific details are discussed in the paragraphs below.
The United Gas Improvement Company, which formed Welsbach, purchased the patent rights to
manufacture thorium-containing gas mantles in the 1880s from Dr. Carl Auer von Welsbach. The
process for manufacturing the Welsbach gas mantle used a highly purified solution of 99 percent
thorium nitrate and 1 percent cerium nitrate as a "lighting fluid" in distilled water. A fabric sock
was then dipped into the thorium solution to create the gas mantle. Thorium caused the gas
mantle, when lit, to give off a very bright white light.
The commercial source of thorium and cerium is a mineral known as monazite sand. Monazite
sand contains approximately 5-6 percent thorium oxide and 20-30 percent cerium oxide. Thorium
was typically extracted from the monazite ore by heating the ore in a sulfuric acid solution. The
thorium and other rare earth elements would go into solution, while the radium-228 remained in
the tailings of insoluble sulfates. Around 1915, Welsbach started using and selling the radium-228
for use in luminescent paint. For a number of years, Welsbach was the largest manufacturer of gas
mantles in the world, making up to 250,000 mantles per day at its peak.
Welsbach also made gas room heaters, gas storage water heaters, gas and electrical fixtures,
electrical refrigerators, plumbing supplies and lacquers. Manufacturing operations at the Welsbach
facility began as early as 1882 and lasted until the 1940s. The facility property covered an area of
about 21 acres, and consisted of about 20 buildings.
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In 1942, the U.S. Government acquired the Welsbach Facility and sold it to the Randall
Corporation in 1948. Randall leased the property to the Radio Corporation of America. Victor
Division. A series of intervening owners followed. In May,1976, the property was purchased by
Holt Hauling and Warehousing, Inc. (Holt), the current owner of the property. Holt operates a
cargo and overseas shipping business. None of the owners of the property after Welsbach dealt
with radioactive materials.
Only one Welsbach era-building, the Armstrong Building, is still present on the property. There is
no information available on when the other Welsbach-era buildings were demolished. The remedy
for the Armstrong Building is not part of this decision.
The former gas mantle manufacturing facility in Camden was owned and operated by the GGM
Company from 1912 to 1941. There is little information available regarding activities at GGM,
other than it used and resold radium and thorium.
Between 1941 and 1978, there was a total of seven different private owners of the property.
Based on current information, none of these operations involved radioactive materials. In January
1978, the southern portion of the property was purchased by the Dynamic Blending Company. In
October 1988, the northern portion of the property was purchased by Ste-Lar Textiles. In 1992,
NJDEP removed radiologically-contaminated fabrics, relocated Ste-Lar, and sealed up the GGM
building on the northern property to restrict access.
During the years that Welsbach and GGM operated, ore tailings were used for fill at properties in
the vicinity of the facilities. It is also reported that building debris from the former Welsbach
Facility may have been disposed of as fill in the area. In addition, workers from the former
Welsbach and GGM Facilities may have brought contamination home with them. These properties
associated with radiological waste from the Welsbach and GGM Facilities are collectively termed
Vicinity Properties.
In 1991, NJDEP initiated a radiological investigation at more than 1,000 properties located
throughout Study Areas 1 through 5. At properties where NJDEP determined that exposure levels
were unacceptable (or posed an immediate health risk), it performed interim remedial measures.
These measures included the installation of radon/thoron ventilation systems and placement of
concrete or lead sheeting to shield gamma radiation. In addition, NJDEP restricted access to
outdoor areas which exceeded its action levels.
In 1998, EPA identified a 100 square foot area in a Gloucester City Park, located in Study Area 5,
that had elevated levels of gamma radiation at the surface. In December 1998, EPA performed a
removal action to reduce exposure to these elevated levels. EPA excavated the top three feet of
radiologically-contaminated soil, disposed of this soil off-site at a permitted facility, and replaced
the waste material with clean fill.
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Both the Welsbach Company and the GGM Company went out of business in the early 1940s, andEPA has been unable to identify any successor companies. In September 1997. EPA entered intoan Administrative Order on Consent (AOC) with Holt, the current owner of the former WelsbachFacility. Under the terms of the AOC, Holt agreed to perform a Remedial Investigation andFeasibility Study (RI/FS) on the Armstrong Building. Holt has also submitted information tosupport its position that it is not liable for response costs at the former Welsbach facility. EPA iscurrently evaluating this information.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS report, the Proposed Plan and supporting documentation were made available to thepublic in the administrative record file at the Superfund Document Center at EPA Region II, 290Broadway, 18th Floor, New York, New York 10007 and at the following repositories: City ofCamden Main Library, 418 Federal Street, Camden, New Jersey 08103; the Hynes Center, 1855South 4th Street, Camden, New Jersey 80104; and the Gloucester City Public Library, Monmouthand Hudson Streets, Gloucester City, New Jersey 08030. Notices of availability for thedocuments in the administrative record were published in the Philadelphia Inquirer on February 1,1999, the Courier-Post on February 2, 1999, and the Gloucester City News on February 4, 1999.The public comment period which related to these documents was held from February 1, 1999 toMarch 3, 1999.
EPA conducted public meetings in both Gloucester City and Camden to inform local officials andinterested citizens about the Superfund process, to review proposed remedial activities at the Siteand receive comments on the Proposed Plan, and to respond to questions from area residents andother interested parties. Meetings were held on February 23, 1999, at the Pine Grove Fire Station#2 in Gloucester City, and on February 24, 1999, at the Camden County Municipal UtilitiesAuthorities Auditorium in Camden. Responses to the comments received at the public meeting areincluded in the Responsiveness Summary (see Appendix V). The City of Gloucester Citysubmitted a resolution supporting the proposed remedy. No other written comments werereceived during the public comment period.
This Record of Decision (ROD) document presents the selected remedial action for theWelsbach/GGM site, chosen in accordance with the Comprehensive Environmental Response,Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act, and, to the extent practicable, the National Oil and Hazardous SubstancesPollution Contingency Plan (NCP). The selection of the remedy for this site is based on theadministrative record.
SCOPE AND ROLE OF RESPONSE ACTION
This action is the first operable unit or phase taken to address the radiological contamination atthe Site. This action will address the radiologically-contaminated soil and building materials at theVicinity Properties and the former Welsbach and GGM Facilities. For the second operable
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unit at the site, Holt is performing an RI/FS for the Armstrong Building. A remedy for this second
operable unit will be selected in a future ROD. A third operable unit is planned to investigate
potential site impacts to groundwater, surface water, sediments, and wetlands.
THE NATURE OF RADIONUCLIDES
A radionuclide is an element that spontaneously changes or “decays” into another element
through natural processes. Radionuclides are present in trace amounts in all rocks and soils, and
consist primarily of elements of the uranium-238 and thorium-232 decay series. There are
approximately 1,700 different unstable atomic species or radionuclides. These include both
naturally occurring and man-made radionuclides.
The radionuclides of concern in the wastes which originated at the former Welsbach and GGM
Facilities are members of the uranium and thoriurn decay series. There are 14 unique
radionuclides in the uranium decay series and 11 unique radionuclides in the thoriurn decay series
which precede the formation of stable lead (Pb-206 or Pb-208). Alpha, beta, and gamma radiation
are emitted from the various members of the two decay series. The primary nuclides of concern
are Thorium-232,-Radium-226, and radon gas (Radon-222 and Radon-220.)
Each radionuclide has its own unique characteristic “fingerprint,” consisting of three parameters:
! The radioactive half-life describes the amount of time in which half of any given number
of atoms of a radionuclide will decay.
! The mode of decay refers to the type(s) of particles or electromagnetic rays emitted from
the radionuclide as it decays. These types include alpha and beta particles, and gamma
rays.
! The amount of energy carried away from the atom by the particles or rays is radionuclide
specific. It is the transfer of this energy to living tissue which may cause biological
effects.
When radionuclides decay, they emit energy in the form of radiation. The decaying radionuclide is
often called the “parent”, and the radionuclide produced is called the “decay product”. A quantity
of radioactive material is measured by its rate of decay, expressed by the unit Curie (Ci), which is
equal to 2.22 x 1012 (2.22 trillion) disintegrating atoms per minute. A more convenient unit for
expressing environmental radioactivity is the picoCurie (pCi), which is equal to 1 x 10-12 “ (one
trillionth) Ci. Table 1 summarizes the common units of measure for radionuclides that are
discussed below.
Radium-226 is a naturally occurring, radioactive, metallic element formed from the decay of
uranium. In its decay, Radium-226 forms Radon-222 or radon gas. Radon gas is colorless,
odorless, radioactive and inert; therefore, it can move easily through soil to the ground surface or
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into houses, Within a matter of days, the radon gas itself decays into a series of radioactive decay
products. While radon gas in the outdoor air dissipates quickly, the concentration of radon decay
products in the indoor air can build up over time. Exposure to the energy released by these
various decaying atoms can result in adverse health effects. For radon decay products, a special
unit called Working Level (WL) has been developed. Working Level is defined as any
combination of short-lived radon decay products in 1 liter of air that will result in the ultimate
emission of 1.3 x 105 Mega-electron Volts of potential alpha energy. This value is approximately
equal to the alpha energy released from the decay of progeny in equilibrium with 100 pCi of
Radon-222.
Thorium-232 is also a naturally occurring radionuclide and is the initial radionuclide of the
thorium decay series. Its decay products include Radium-228 and Radon-220. Radon-220 is also
known as thoron. Thoron and its decay products have extremely short half-lives that usually
prevent them from concentrating to any appreciable extent in indoor air. However, if a significant
source of thoron exists within, beneath, or adjacent to a structure (such as the thorium and
Radium-228 found in Welsbach/GGM site wastes), thoron decay products can reach
concentrations which create health risks.
SUMMARY OF SITE CHARACTERISTICS
In September 1997, EPA started an RI to characterize the nature and extent of contamination at
the Welsbach Facility, GGM Facility, and 20 of the radiologically-contaminated properties
identified by NJDEP in the vicinity of Welsbach and GGM. The work was conducted by Malcolm
Pirnie, Inc., under contract to EPA. In order to develop a cleanup strategy for the Site, the RI
field investigations were divided into three property categories, as follows:
! Former Welsbach Company Facility;
! Former General Gas Mantle Company Facility;
! Vicinity Properties
Property Investigations
EPA conducted both chemical and radiological characterizations of the former Welsbach and
GGM Facilities to define the went of contamination. EPA also performed a radiological
investigation on 20 of the potentially contaminated Vicinity Properties identified by NJDEP. Only
20 Vicinity Properties were investigated during the RI so that EPA could confirm the NJDEP data
and expedite the development of cleanup alternatives. Based on evaluation of the NJDEP data,
EPA segregated the properties investigated by NJDEP into the following three categories. Table 2
summarizes the results of the property classification.
1) Properties where there is no evidence of contamination related to the Welsbach/GGM site.
These are properties which have surface exposure rates less than 13 µR/h, radon progeny
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measurements less than 0.02 WL, and radon gas levels less than 4.0 pCi/l. The exposure raterepresents the upper level of the range of natural background.
2) “Suspect Properties” - are properties for which either elevated levels (i.e., above background)of radioactivity were detected by NJDEP or properties situated adjacent to known contaminatedproperties; and
3) “Contaminated Properties” - are properties with levels of radioactivity which potentiallywarrant remedial action (i.e. properties with either exposure rates greater than 30 µR/h., radonprogeny greater than 0.02 WL, radon gas levels greater than 4.0 pCi/l, or thorium or radiumconcentration in the soil greater than 5 pCi/g.)
EPA will investigate the remaining Contaminated Properties which were not studied in the RI andthe Suspect Properties during the remedial design phase of this cleanup. EPA estimates that it willstudy about 600 properties during the design phase to determine exactly which properties requirecleanup. This additional work may include sampling for chemical analysis, where deemedappropriate when considering past ownership and historic information. Table 3 summarizes thevolume of contaminated soil and debris at the Contaminated Properties. Field activities conductedas part of the RI included the following:
! Radon measurements! Radon decay product Working Level measurements! Gamma radiation surface and one-meter height exposure rate surveys! Surface and subsurface soil sampling! Downhole gamma radiation logging! Total surface beta surveys and removable surface alpha and beta sampling! Structural materials sampling for radionuclides (in some buildings)! Chemical sampling for metals, volatile organic compounds, and semi-volatile organic
compounds at the two former gas mantle facilities
The results of the RI can be summarized as follows.
Former Welsbach Facility Investigation
Most of the radiological contamination is located in the area of what is believed to be the locationof a former Welsbach building that was demolished in the 1970s. This area is currently used forstorage. However, there are smaller areas of contamination scattered throughout the property.The soil in these areas is contaminated with elevated concentrations of the thoriurn and uraniumdecay series radionuclides. These radionuclides are principal threat wastes. Subsurfacecontamination on the Welsbach facility averages about 11 feet in depth. An estimated 27,200cubic yards of soil/buried debris have thoriurn and/or radium concentrations exceeding 5 pCi/g.Radium and thorium, concentrations in soil ranged from background (about 1 pCi/g for each) toas high as 455 pCi/g and 1,190 pCi/g, respectively. Surface gamma exposure
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rates associated with the contaminated soils ranged from background (less than 10 micro
Roentgen per hour [µ/R/h]) to 780 µR/h. The highest readings were associated with a large fill
area identified in the middle of the storage area.
Low levels of chemical contaminants were also identified at the former Welsbach Facility.
Contaminants of potential concern include semi-volatile organic compounds and arsenic. These
contaminants may be indicative of “Historic Fill”. If this is confirmed during the remedial design
and these contaminants are not comingled with the radiological contaminants of concern, then
there may be a need to remediate such historic contaminants.
Former General Gas Mantle Facility Investigation
Elevated concentrations of thorium and uranium decay series radionuclides were identified in soils
on the former GGM property. Contamination was generally limited to the top six to eight feet,
although contamination in some areas of South Fourth Street and the GGM Courtyard ranged
from 12 to 16 feet in depth. An estimated 900 cubic yards of soil have thorium and/or radium
concentrations which exceeded 5 pCi/g. Radium and thorium concentrations in soil ranged from
background to as high as 172 pCi/g and 149 pCi/g, respectively.
Surface gamma exposure rates associated with the contaminated soils ranged from background
(less than 10 µR/h) to 380 µR/h. Only localized areas of surface contamination were identified
outdoors. Most of the outdoor contamination is located in the area of South Fourth Street.
However, EPA identified some smaller areas of contamination in the alleyway behind the
property. The contamination also extended onto some backyards of neighboring residential
properties.
Elevated levels of surface contamination were observed in many areas inside the former GGM
building. Levels as high as 2.33 microCi per square meter(µCi/m2 ) were observed. Indoor gamma
exposure rates ranged from background to 900 µR/h. An estimated 1,460 cubic yards of
contaminated structural materials in the building itself were identified, with thorium
concentrations as high as 750 pCi/g. In the basement of the former GGM building, radon decay
product concentrations measured 1.7 WL, compared to an average background level of 0.005
WL.
Certain semi-volatile organic compounds and metals were identified in the outdoor portions of the
former GGM Facility. These were, however, at such low levels that they are not of concern.
These contaminants may be indicative of “Historic Fill”. If this is confirmed during the remedial
design and these contaminants are not comingled with the radiological contaminants of concern,
then there may be a need to remediate such historic contaminants.
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Vicinity Property Investigation
EPA investigated 20 properties in Camden and Gloucester City for radiological contamination as
part of the RI. EPA compared the data from these properties to information collected from earlier
NJDEP investigations on over 1000 properties and determined that the data were comparable.
Contaminated soil averaged about two to three feet in depth on most residential properties. On a
few properties, contamination extended to 10 feet in depth. Some site properties have indoor
radon gas concentrations or soil radionuclide concentrations which pose a long-term risk to
human health.
Based on the comparison of EPA and NJDEP data, EPA identified a total of 54 properties as
having contamination above the cleanup levels. During the remedial design phase, EPA will
delineate the extent of contamination on each of these properties in order to design a cleanup plan
for each property.
During the remedial design, EPA will also investigate approximately 600 additional properties that
are either adjacent to the known contaminated properties or have gamma exposure rates slightly
above background levels. If contamination above the cleanup objectives is found on any of these
Suspect Properties, EPA will delineate the extent of this contamination and design a cleanup plan
for those properties.
Based on its review of the NJDEP data, EPA determined that 449 out of the approximately 1,000
properties NJDEP investigated showed no evidence of contamination. These properties had
surface gamma exposure rates less than the upper range of natural background, radon progeny
less than 0.02 WL, and radon gas levels below 4.0 pCi/l.
Current and Future Land Use
The site properties and the surrounding areas consist of industrial, commercial, and residential
zoning districts. Study Area 1 is located in an industrial-zoned section of Camden with residential
properties east of the former GGM Facility. In Study Area 2, the former Welsbach Facility is
situated in an industrial-zoned section of Gloucester City with residential properties to the
immediate east. Study Area 3 consists of residential properties, a private swim club, and a land
preserve. Study Area 4 consists entirely of residential properties. Residential properties and two
municipal parks comprise Study Area 5. Study Area 6 consists of vacant land in a residential area.
No significant changes in land use are anticipated, except in the area of GGM where there is a
possibility that some residential areas may be rezoned for commercial uses. The former GGM
facility is bordered by residential homes located on Arlington Street in Camden. Most of the
homes on Arlington Street are abandoned and there is debate within the community, given the
industrial nature of the area, whether to rezone this area to allow for commercial development or
leave it residential. Whether zoning changes will actually be made is uncertain at this time.
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SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for the former Welsbach Facility, the former GGMFacility, and the Vicinity Properties using analytical data obtained during the RI. The baseline riskassessment estimates the human health risk which could result from the contamination at a site ifno remedial action were taken.
Ecological risks, that is, the risks to aquatic and terrestrial wildlife, were not evaluated for thisoperable unit. However, EPA compared the levels of radioactive exposure to various species withthe cleanup criteria. Based on this comparison, EPA determined that the cleanup criteria will beprotective of ecological receptors for this operable unit. An Ecological Risk Assessment will beconducted in a future RI to evaluate the potential for adverse effects to aquatic and terrestrialwildlife in accordance with Ecological Risk Assessment Guidance for Superfund, Process forDesigning and Conducting Ecological Risk Assessments (EPA 540-R-97-006).
To evaluate human health risks, a four-step process was used for assessing site-related risks for areasonable maximum exposure scenario. These steps are: Hazard Identification - identified thecontaminants of concern at the site based on several factors such as toxicity, frequency ofoccurrence. and concentration; Exposure Assessment - estimated the magnitude of actual and/orpotential human exposures, the frequency and duration of these exposures, and the pathways(e.g., ingesting contaminated soil) by which humans are potentially exposed; Toxicity Assessment- determined the types of adverse health effects associated with exposures to site contaminants,and the relationship between magnitude of exposure dose) and severity of adverse effects(response); and Risk Characterization - summarized and combined outputs of the exposure andtoxicity assessments to provide a quantitative (e.g., one-in-a-million excess cancer risk)assessment of site-related risks.
For risk assessment purposes, individual contaminants are typically separated into two categoriesof health hazard depending on whether they exhibit carcinogenic effects (causing cancer) ornoncarcinogenic effects (causing health effects other than cancer.) Radionuclides from theuranium and thoriurn decay series (e.g., radium, thorium, radon, and radon decay products) areknown human carcinogens. Nonradiological chemical contaminants (e.g., PAHs and arsenic) mayexhibit both carcinogenic and noncarcinogenic health effects.
EPA's acceptable cancer risk range is 10-4 to 10-6, which can be interpreted to mean that anindividual may have a one in 10,000 to one in 1,000,000 increased chance of developing cancerbecause of site-related exposure to a carcinogen. EPA usually initiates remedial action at a sitewhen the risk estimate exceeds this range.
Human health risks were estimated for both radionuclides and chemicals of concern at the formerWelsbach and GGM Facilities, and for radionuclides concern at the Vicinity Properties. Buildingmaterials and/or soil were the environmental media of concern. Following EPA guidance, riskswere estimated based, on a “reasonable maximum exposure” scenario. Risks were
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estimated as a result of exposure to site-related carcinogens based on a number of assumptionsthat result in an overall exposure estimate that is conservative but within a realistic range ofexposure.
In assessing potential human health risks from exposure to the radionuclides, several scenarioswere evaluated which involve exposure to external gamma radiation, ingestion of radioactivematerials, and inhalation of radioactive materials. For the former Welsbach Facility, risk estimateswere evaluated for current and future workers, other site workers (part-time workers), andconstruction workers. For the former GGM Facility, risk estimates were evaluated for current andfuture trespassers, and future construction workers, adult residents, child residents, and workers.At the Vicinity Properties, risk estimates were evaluated for adult and child residents of the 14residential properties investigated, and appropriate populations at the remaining six VicinityProperties (Jogging Track, Swim Club, Martins Lake, Public Park, Land Preserve, and thePopcorn Factory.) These risks were then compared to the risk from natural background sourcesof radiation.
The following exposure pathways were evaluated in detail for current and future land-useconditions:
! Inhalation of radon decay products by residents, or occupants at commercialproperties;
! Exposure to external gamma radiation emanating from thorium- and radium-contaminated material, resulting in elevated exposures to residents/occupants;
! Ingestion of radionuclides in soil by residents/occupants;
! Ingestion of radionuclides in locally grown produce by residents; and
! Inhalation of radioactive particulates by residents/occupants.
The Vicinity Properties and the former Welsbach and GGM Facilities have radiogenic risk(radiation induced) cancer risk estimates, that is, the risks due solely to the presence ofradioactive materials above background levels, which exceed EPA’s risk range. The maximumexcess lifetime radiogenic cancer risk estimates based on reasonable maximum exposures are 5.7 x10-2 at the former Welsbach Facility (to the current and future site worker), 1.8 x 10-1 at theformer GGM Facility (to a hypothetical future site worker), and 1.8 x 10-1 to a hypotheticalresident of a Vicinity Property (See Tables 4 and 5.) The uranium and thorium decay seriesradionuclides are principal threat wastes because of these increased cancer risks.
The cancer risk from chemical exposures at the former Welsbach and GGM facilities was alsoevaluated for the same populations as the radionuclides. Construction workers at both Welsbachand GGM would be subject to the maximum risk from the chemicals of concern (See Table 6
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and 7.) However, these cancer risks do not exceed EPA’s risk range and. therefore, no additionalremedial action is necessary to address chemical contaminants at these facilities.
To assess the potential for cumulative noncarcinogenic effects posed by multiple contaminants.EPA has developed a hazard index (HI). The HI is derived by adding the noncancer risks for sitechemicals with the same target organ or mechanism of toxicity. When the HI exceeds 1.0, theremay be concern for adverse health effects due to exposure to multiple chemicals.
For the Welsbach/GGM site, non-cancer health effects were evaluated only at the formerWelsbach and GGM Facilities. The total HI for construction worker exposure to the chemicals ofconcern in soil at the former Welsbach Facility from ingestion, dermal contact, and inhalation isequal to EPA’s acceptable level of 1.0 (See Table 6.) Ingestion of arsenic is the predominantcontributor to the risk estimate. The total HI for construction worker exposure to the chemicalsof concern in soil at the GGM Facility from ingestion, dermal contact, and inhalation is 0.03; thishazard index is below EPA’s acceptable level of 1.0, indicating that adverse, noncarcinogenichealth effects from such exposure are unlikely (See Table 7.)
The following are the dominant radiological exposure pathway risks for the various exposurescenarios evaluated for the Welsbach/GGM site. At residential properties and the formerWelsbach Facility, the majority of risk is from exposure to external gamma radiation, or directradiation. Occupants of the former GGM Facility (current and future trespassers and future siteworkers) are at risk primarily from inhalation of radon decay products. Future constructionworker risk is primarily due to direct radiation, although inhalation of particulates containingradioactive material also contributes a significant portion of the risk.
This RI focused primarily on residential and commercial properties, and sensitive species of plantsand animals are not likely to inhabit these portions of the Site. However, sensitive species may bepresent in Study Areas 3 and 5 around Newton Creek and associated areas of the Delaware River.An ecological risk characterization will be conducted in conjunction with the third operable unitRI to assess potential impacts to ground water, surface water, and sediment from the Site.
Uncertainties
The procedures and estimates used to assess risks, as in all such assessments, are subject to a widevariety of uncertainties. In general, the main sources of uncertainty include:
! environmental chemistry sampling and analysis! environmental parameter measurement! fate and transport modeling! exposure parameter estimation! toxicological data
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Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry analysis error can stem from several sources including the
errors inherent in the analytical methods and characteristics of the matrix being sampled. In
addition, there is uncertainty inherent in the measurement of radioactivity.
Uncertainties in the exposure assessment are related to estimates of how often an individual
would actually come in contact with the radionuclides of concern, the period of time over which
such exposure would occur, and the models used to estimate the concentrations of the
contaminants of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from
high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture
of contaminants. These uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the assessment. As a result, the Risk
Assessment provides upper-bound estimates of the risks to populations that may be exposed to
radionuclides, and is highly unlikely to underestimate actual risks related exposure.
More specific information concerning public health risks, including a quantitative evaluation of the
degree of risk associated with various exposure pathways, is presented in the Risk Assessment
Report.
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and
appropriate requirements (ARARs) and risk-based levels established in the risk assessment. EPA’s
remedial action objectives for the Welsbach/GGM. Contamination site are to take measures that
will prevent or mitigate further release of radioactive contaminated materials to the surrounding
environment and to eliminate or minimize the risk to human health and the environment. The
sources of radiation include both contaminated soil and structural materials. Direct radiation,
inhalation, ingestion of plants and soil are potential pathways. The following objectives were
established for the Welsbach/GGM site:
! Eliminate or minimize the potential for humans to ingest, come into dermal contact with,
or inhale particulates of radioactive constituents or to be exposed to external gamma
radiation in order to achieve the level of protection required by the NCP (10-4 to 10-6 risk
range).
1Exposure to 4 pCi/1 of air for radon corresponds to an approximate annual average exposure of 0.02 WL for radon
decay products, when assuming residential land use.
2References for ALARA principles -“Radiation Protection (Guidance to Federal, Agencies for Occupational
Exposure”. 1987, Federal Register 52. No. 17, 2822, and “Federal Guidance Report No. 11",
September 1988, EPA-520\1-88-020.
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! Prevent long-term exposure to thorium- and radium-contaminated material (e.g., soil),with concentrations greater than 5 pCi/g.
! Prevent exposure to indoor concentrations of radon gas and radon decay product greater than 4 pCi/1 and 0.02 WL1, respectively.
! Prevent direct contact with building surfaces exhibiting total surface thoriumcontamination exceeding 0.026 µCi/m2 above background.
! Prevent migration of thorium-contaminated material that could result in the exposuresdescribed above.
! Comply with chemical-, location-, and action-specific ARARs.
EPA, in the Office of Solid Waste and Emergency Response (OSWER) Directives No. 9200.4-18and No. 9200.4-25, developed health guidelines for limiting exposure to ionizing radiation fromradium and other sources. To further ensure protectiveness, those health guidelines can besupplemented by selecting response actions which reduce exposures resulting from ionizingradiation to levels that are As Low As Reasonably Achievable (ALARA2) taking intoconsideration technical, economic and social factors.
EPA recommends that indoor radon concentrations in homes should not exceed 4 pCi per liter ofair (pCi/1). In 40 CFR 192, “Standards for Cleanup of Land and Buildings Contaminated withResidual Radioactive Materials From Inactive Uranium Processing Sites,” EPA enacted standardsfor limiting exposure to radon decay products and gamma radiation. While this regulation is notdirectly applicable to this site because the Welsbach and GGM Facilities are not inactive uraniumprocessing sites. EPA considers the cleanup standards in 40 CFR 192 to be relevant andappropriate for the Site. The relevant portions of 40 CFR 192 include limiting exposure to: radondecay products to levels less than 0.02 WL and radium concentrations (implemented as the sum ofRa-226 and Ra-228) to 5 pCi/g. EPA, in Directive No.9200.4-25, states that whenever the 5pCi/g radium soil cleanup standard is determined to be relevant and appropriate at a CERCLA sitewhich contains both radium and thorium in-the waste, the pCi/g cleanup standard also applies tothorium, (implemented as the sum of Th-230 and Th-232).
In achieving the remedial action objectives for the Site, EPA would rely on the ALARA principlesused at other radiologically-contaminated sites in New Jersey. Applying ALARA
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principles means taking additional measures during implementation of the remedial action,beyond those required to meet a specified cleanup goal, to assure protectiveness. An ALARAapproach is being used because of the long-lived nature of radionuclides, the difficulty ineliminating routes of exposure, and limitations of the analytical equipment to detectradionuclides.
EPA’s experience at the other radiologically-contaminated sites in New Jersey has shown thatthe remedial action objectives noted above can be achieved by incorporating ALARAprinciples. Applying the 5 pCi/g cleanup standard with ALARA principles at these other NewJersey sites has resulted in exposure levels that are lower than the levels that would resultfrom using the 5 pCi/g standard alone. Therefore, by using similar remedial action objectives,the Welsbach/GGM site would pose no unacceptable risk for residential uses after cleanup.and would result in a cleanup that is protective under CERCLA.
The NJDEP has developed a draft proposed regulation concerning the remediation ofradiologically-contaminated soil. In reviewing this case, the NJDEP believes that the remedyselected in this ROD will achieve the goals in the draft proposal through the incorporation ofthe ALARA principles in removing the radiologically-contaminated soils and covering theexcavated areas with clean fill.
The selected remedy will meet the remedial action objectives through the excavation andoff-site disposal of the radiologically-contaminated soils and waste materials. Excavation ofsoils will eliminate the threat of physical migration of contaminants, as well as potentialexposure through various pathways (ingestion, inhalation, dermal contact, external gammaradiation, etc.). Contaminated soils will be shipped off-site to a licensed commercial facilityfor permanent long-term management. For buildings, specifically at GGM, the selectedremedy, decontamination. demolition, and off-site disposal of contaminated materials, willreduce exposures to acceptable levels for future use of the property.
Any potential ecological risks and adverse impacts from existing radiological contaminationon the properties addressed under this action will be minimized because the contaminatedsoils will be removed and backfilled with clean soil. There are also limited habitats forecological receptors at the properties addressed under this action. Furthermore, by removingthe radiologically-contaminated waste, the surface water and sheet flow pathways will beeliminated as routes of exposure.
Wetlands are not present at either the former Welsbach or GGM facilities. However, wetlandsare present in Areas 3 and 5, along the South Branch of Newton Creek. During the remedialdesign, EPA will delineate wetland areas which are actually or potentially impacted bycontamination or remedial activities.
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DESCRIPTION OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1), mandates that a remedial action mustbe protective of human health and the environment. cost-effective, and utilize permanentsolutions and alternative treatment technologies or resource recovery technologies to themaximum extent practicable. Section 121(b)(1) also establishes a preference for remedialactions which employ, as a principal element, treatment which permanently and significantlyreduces the volume, toxicity, or mobility of the hazardous substances, pollutants andcontaminants at a site. Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), further specifies thata remedial action must attain a level or standard of control of the hazardous substances,pollutants, and contaminants, which at least attains ARARs under federal and state laws,unless a waiver can be justified pursuant to Section 121(d)(4) of CERCLA, 42U.S.C. §9621(d)(4). CERCLA also requires that if a remedial action is selected that results inhazardous substances, pollutants, or contaminants remaining at a site above levels that allowfor unlimited use and unrestricted exposure, EPA must review the action no less than everyfive years after the start of the action.
In the RI/FS Report, EPA evaluated Remedial Alternatives for addressing the radiologicalcontamination associated with the Site. Cleanup alternatives were evacuated for the VicinityProperties, the former Welsbach Facility and the General Gas Mantle Facility. Thealternatives include: No Action, Engineering Controls, and Excavation and Off-SiteDisposal. Table 8 summarizes the costs of each alternative.
Vicinity Properties
The Vicinity Properties include residential, commercial, and public properties whereradiological contamination was identified in soils located outdoors and/or beneath buildings,and properties with indoor air contamination.
Vicinity Properties Alternative 1 (V-1) - No Action
Estimated Capital Cost: $0Estimated Annual Operation and Maintenance (O&M) Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none
A “No Action” alternative is evaluated for every Superfund site to establish a baseline forcomparison with remedial alternatives. Under this alternative, no remedial action would beperformed at the Site. Previous interim remedial actions implemented by NJDEP would notbe maintained. Current institutional controls including fencing would not be maintained.Because hazardous substances would remain at the Vicinity Properties above acceptablelevels, five-year reviews would be required.
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Vicinity Properties Alternative 2 (V-2) - Engineering Controls
Estimated Capital Cost: $900,000Estimated Annual O&M Cost: $99,000Estimated Present Worth: $1,810,000Estimated Implementation Period: 3-5 years
Under this alternative, outdoor gamma shielding would be placed at each property which hascontaminated soil. The gamma shield would consist of a geotextile liner, fill material, 6 inchesof topsoil, and vegetation (seeding or sod). The thickness of the fill material will vary from 6inches to 42 inches, based on the shielding requirements of each property. A total ofapproximately 75,000 square feet of coverage would be installed.
In addition, indoor gamma shielding would be placed inside buildings exhibitingunacceptable exposure levels. The shielding would consist of concrete or steel as needed. Theconcrete would range from 4 inches to 7 inches thick, and about 1.5 inches of steel sheetingwould be placed on wall surfaces. A total of approximately 2,000 square feet of concrete and60 square feet of steel coverage would be installed. Finally, if any property buildings exhibitelevated radon/thoron levels, a sub-slab ventilation radon mitigation system would beinstalled.
Institutional controls, such as deed restrictions, would be required to ensure the protectivenessof the remedy. Because hazardous substances would remain at the Vicinity Properties aboveacceptable levels, five-year reviews would be required. The estimated time to design andconstruct the remedy is from three to five years.
Vicinity Properties Alternative 3 (V-3) - Excavation and Off-Site Disposal
Estimated Capital Cost: $13,408,560Estimated Annual O&M Cost: $0Estimated Present Worth: $13,408,560Estimated Implementation Period: 3-5 years
Under this alternative, soil on the Vicinity Properties contaminated above 5 pCi/g greater thanbackground would be excavated and disposed of at a licensed off-site facility. Radiologically-contaminated building demolition debris would also be excavated and disposed of off-site.EPA will replace these areas with clean fill. The total volume of soils requiring disposal at theVicinity Properties is estimated to be 11,000 cubic yards. The total volume of burieddemolition debris at the Vicinity Properties is estimated to be 2,250 cubic yards.
Where contamination is suspected underneath buildings, this alternative includes removingconcrete flooring and underpinning the buildings. After the removal of contaminated soil, anew concrete floor would be constructed. Approximately 21 properties would requireconcrete floor removal and replacement. Underpinning may be required at one property.
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The estimated time to design and construct the remedy is three to five years. Provisions wouldneed to be made for the temporary relocation of residents and businesses during constructionof this alternative. During excavation. short-term provisions to prevent dust generation andprotect workers would be required. EPA will develop a wetland mitigation plan if it disturbswetland areas by remedial activities.
Welsbach Facility
The former Welsbach Facility is presently owned and operated by Holt as a cargo storage andoversea shipping operation. Radiological contamination on the property is present in theoutdoor portion of the storage area. Most of the contamination is located in a singlecontiguous area. with smaller contaminated areas scattered across the property. TheArmstrong Building is not included in the remediation alternatives. Holt is preparing an RI/FSthat will address the remedial alternatives for that building.
Welsbach Alternative I (W-1) - No Action
Estimated Capital Cost: $0Estimated Annual O&M Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none
Under this alternative, no remedial action would be performed at the Site. Current institutionalcontrols, including fencing, would not be maintained. Because hazardous substances wouldremain on the property above acceptable levels. five-year reviews would be required.
Welsbach Alternative 2 (W-2) - Engineering Controls
Estimated Capital Cost: $5,686,000Estimated Annual O&M Cost: $44,000Estimated Present Worth: $6,182,000Estimated Implementation Period: 3-5 years
Under this alternative, outdoor gamma shielding would be placed in the areas of the formerWelsbach property that have soil contamination. The gamma shield would consist of steelcovered by asphalt. The steel would range in thickness from 1 to 5 inches, with a 4-incnasphalt cover. Approximately 53,000 square feet of area would be, covered by the steelshielding.
Institutional controls, such as deed restrictions, would be required to ensure the protectivenessof the remedy. Because hazardous substances would remain on the property above acceptablelevels, five-year reviews would be required. The estimated time to design and construct theremedy is three to five years.
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Welsbach Alternative 3 (W-3) - Excavation and Off-Site Disposal
Estimated Capital Cost: $18,503,560Estimated Annual O&M Cost: $0Estimated Present Worth: $18.503.560Estimated Implementation Period: 3-5 years
Under this alternative, all soil contamination at the Welsbach site above 5 pCi/g greater thanbackground would be excavated and disposed of at a licensed off-site facility. EPA will alsoexcavate contaminated building debris from past demolition activities, which is currentlyburied on-site, and dispose of this material at an appropriate off-site facility. EPA will backfillthese areas with clean fill. The volume of soils above the cleanup standard is estimated to be19,400 cubic yards. The volume of buried demolition debris requiring disposal is estimated tobe 4.400 cubic yards. During excavation, short-term provisions to prevent dust generation andprotect workers would be required.
Subsurface contamination on the Welsbach Facility averages about 11 feet in depth. In thearea of the deepest contamination, underground tunnels dating from around the turn of thecentury are present. These tunnels extend down to about 10 to 12 feet in depth. These tunnelscan act as conduits to carry radon gas to nearby residential properties. As a result, the remedyincludes excavation of the contamination to the tunnel depths to prevent any future radonmigration problems and to protect future workers from elevated gamma radiation levels. Theestimated time to design and construct the remedy is three to five years.
General Gas Mantle Facility
The GGM building is presently inactive and in a dilapidated state. The building has beenboarded shut and fenced in by NJDEP. Radiological contamination on the property exists bothinside and outside the building. Inside the building, contamination is present in buildingmaterials and in ambient air. Outside the GGM Facility, soil contamination is primarilylocated to the inunediate southwest of the GGM building extending into South Fourth Street.Two smaller areas of contaminated soils are situated to the northeast of the building and in thealleyway adjacent to the eastern side of the building.
General Gas Mantle Alternative 1 (G-1) - No Action
Estimated Capital Cost: $0Estimated Annual O&M Cost: $0Estimated Present Worth: $0Estimated Implementation Period: none
Under this alternative, no remedial action would be performed at the Site. PTevious interimremedial actions would not be maintained. Current institutional controls including fencingwould
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not be maintained. Because hazardous substances would remain on the property aboveacceptable levels, five-year reviews would be required.
General Gas Mantle Alternative 2 (G - 2) - Engineering Controls
Estimated Capital Cost: $122.000Estimated Annual O&M Cost: $23.000Estimated Present Worth: $381.000Estimated Implementation Period: 2-3 years
Under this alternative, outdoor gamma shielding would be placed at the former General GasMantle property. The gamma shield would consist of either a soil shield or a concrete shield.The soil shield would include a geotextile liner, fill material, 6 inches of tonsoil, andvegetation (seeding or sod). The thickness of the fill material will range, from 6 to 24 inches.The thickness of the concrete will range from 6 to 8 inches. Approyimately 5,000 square feetof coverage would be required. Areas of contamination extending into Forth Fourth Streetwould be covered with an additional 4 inches of asphalt.
Also under this alternative, significant institutional controls, including permanently boardingshut the building and restricting access to the building forever, would be required. Becausehazardous substances would remain on the property above acceptable levels, five-year reviewswould berequired. The estimated time to design and construct the remedy is two to three years.
General Gas Mantle Alternative 3 - Excavation and Off-Site Disposal of Soil andBuilding/Demolition Debris
Option A: Demolition and Disposal
Estimated Capital Cost: $2,309,560Estimated Annual O&M Cost: $0Estimated Present Worth: $2,309,560Estimated Implementation Period: 1-2 years
Under this alternative for the GGM property, EPA will excavate contaminated soil above 5pCi/g greater than background and dispose of this waste in a licensed off-site facility.Contaminated building demolition debris which is currently buried on-site because of formerdemolition activities would also be excavated and disposed of off-site. EPA will backfill theseareas with clean fill. The volume of soil and buried dem6lition debris at GGM is estimated tobe 650 cubic yards and 60 cubic yards, respectively.
Under this alternative, the former General Gas Mantle building would be demolished, and thedemolition debris would be disposed of with the contaminated soil. The volume of buildingmaterials to be demolished is estimated to be 1,400 cubic yards. During excavation and
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demolition, short-term provisions to prevent dust generation and protect workers would berequired. The estimated time to design and construct the remedy is one to two years.
Option B: Decontamination, Demolition and Disposal
Estimated Capital Cost: $1.979.560Estimated Annual O&M Cost: $0Estimated Present Worth: $1.979.560Estimated Implementation Period: 1-2 years
This alternative essentially would be the same as 3A above, except that the demolition of thebuilding would proceed in steps. First, the wood structural materials and roofing would beremoved. This debris (approximately 450 cubic yards) would be disposed of with thecontaminated soil. The remainder of the building (approximately 950 cubic yards of primarilymasonry and concrete) would then be decontaminated using pressure washing beforedemolition. The contaminated waste water would be disposed of at an approved off-sitefacility. The building would then be demolished and the debris would be crushed and sentoff-site for disposal. The estimated time to design and construct the remedy is one to twoyears.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in Section 121 of CERCLA, 42U.S.C. §9621, by conducting a detailed analysis of the viable remedial alternatives pursuant tothe NCP, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysisconsisted of an assessment of the individual alternatives against each of nine evaluationcriteria and a comparative analysis focusing upon the relative performance of each alternativeagainst those criteria.
The following “threshold” criteria are the most important and must be satisfied by anyalternative in order to be eligible for selection:
1. Overall protection of human health and the environment considers whether or not aremedial alternative provides adequate protection and describes how risks posedthrough each exposure pathway are eliminated, reduced, or controlled throughtreatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedial alternative meets all ofthe applicable or relevant and appropriate requirements of federal and stateenvironmental statutes and requirements, or provides grounds for invoking a waiver.
The following “primary balancing” criteria are used to make comparisons and to identify themajor trade-offs between alternatives:
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3. Long-term effectiveness and permanence, refers to the ability of a remedial alternativeto maintain reliable protection of human health and the environment over time, oncecleanup goals have been met. It also addresses that magnitude and effectiveness of themeasures that may be required to manage the risk based by treatment residuals and/oruntreated wastes.
4. Reduction of toxicity, mobility, or volume through treatment addresses the statutorypreference for selecting remedial actions that employ treatment technologies thatpermanently and significantly reduce toxicity, mobility, or volume of hazardoussubstances as a principal element.
5. Short-term effectiveness considers the period of time needed to achieve protection andany adverse impacts on human health and the environment that may be posed duringthe construction and implementation period until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedialalternative, including the availability of materials and services needed to implement thealternative.
7. Cost includes the estimated capital and operation and maintenance costs, and thepresent- worth costs.
The following “modifying” criteria are considerea ;ully after the formal public cornmentperiod on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS reports and theProposed Plan, the State supports, opposes, and/or has identified any reservations withthe preferred alternative.
9. Community acceptance refers to the public’s general response to the alternativesdescribed in the Proposed Plan and tne RI/FS report. Responses to public commentsare addressed in the Responsiveness Summary section of this Record of Decision.
A comparative analysis of the remedial alternatives based upon the evaluation criteria notedabove follows:
Overall Protection to Human Health and the Environment
The No Action Alternatives (W-1, V-1, G-1) would not be protective of human health and theenvironment because the Site would remain in its current contaminated condition. Therefore,the No Action Alternatives have been eliminated from consideration and will not be discussedfurther.
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Under the Engineering Controls Alternatives (W-2, V-2. G-2), potential exposure routes of
gamma radiation would be shielded by soil, concrete and/or steel sheeting. The shielding would
have to be maintained, and institutional controls, such as deed restrictions, would be required to
ensure that these alternatives are protective.
For the Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3). all radiological
contamination above cleanup standards would be excavated and disposed of off-site in a licensed
disposal facility. Institutional controls would not be necessary. All unacceptable risks to human
health and the environment would be eliminated by the excavation and off-site disposal of the
radiologically-contaminated waste.
Compliance with Applicable or Relevant. and Appropriate Requirements
Actions taken at any Superfund site must meet all ARARs of federal and state law, or provide
grounds for invoking a waiver of these requirements. There are three types of ARARs: action-
specific, chemical-specific, and location-specific. Action-specific ARARs are technology or
activity-specific requirements or limitations related to various activities. Chemical-specific ARARs
are usually numerical values which establish the amount or concentration of a chemical that may
be found in, or discharged to, the ambient environment. Location-specific requirements are
restrictions placed on the concentrations of hazardous substances or the conduct of activities
solely because they occur in a special location.
For the Welsbach/GGM site, no requirements are applicable for the cleanup of the radiological
contamination. However, as discussed earlier, portions of the federal regulations governing the
cleanup of uranium mill tailings from inactive uranium processing sites, at 40 CFR 192, have been
determined to be relevant and appropriate. These provide the radon decay products standard of
0.02 WL and soil cleanup criteria of 5 pCi/g above background.
The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) would comply with all
ARARs. All contamination above the 40 CFR 192 cleanup standards would be excavated and sent
off-site for disposal. The Engineering Controls Alternatives (W-2, V-2, G-2) would comply with
all ARARs that limit exposure to gamma radiation and radon. However, the Engineering Controls
Alternatives would not comply with 40 CFR 192, because the contaminated material would
remain at the Site.
Long-Term Effectiveness and Permanence
The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) are all effective and
permanent. They are considered a final remedial action. The contaminated material would be
removed from the Site and stored in a controlled, licensed off-site facility.
The long-term effectiveness of the Engineering Controls Alternatives W-2 and V-2 would be
uncertain. Contaminated material would remain in place, and the engineering controls would
24
require deed restrictions and long-term monitoring. In addition. the engineering controls would
have to be maintained forever because the half-life of thorium. is 14 billion years.
Alternative G-2 (Engineering Controls for General Gas Mantle) would not be effective in the
long-term because of the dilapidated nature of the building, even if the building were completely
sealed.
Reduction of Toxicity, Mobility, or Volume Through Treatment
No treatment technology is known today that can substantially reduce the toxicity, mobility, or
volume of radioactive materials found at the Site, and meet the 40 CFR 192 cleanup standards.
The total amount of radioactivity cannot be altered or destroyed, as is often possible with
chemical contaminants. Therefore, none of the remedial alternatives fully satisfy this evaluation
criteria.
However, Alternative G-3 with Option B (the General Gas Mantle Decontamination and
Demolition Alternative) would reduce the volume of contaminated building debris to be disposed
of off-site by pressure washing the radioactive contamination off the floors and walls before
demolition. The contaminants would be concentrated in the filtrate after pressure washing. Only
this filtrate would have to be disposed of in a licensed off-site facility.
Short-Term-Effectiveness
Both the Engineering Control Alternatives (W-2, V-2, G-2) and the Excavation and Off-Site
Disposal Alternatives (W-3, V-3, G-3) provide effective short-term protection, and become
effective as they are implemented at individual properties. The estimated time to design and
construct the remedial alternatives for the former Welsbach Facility (Alternatives W-2 and W-3)
and the Vicinity Properties (Alternatives V-2 and V-3) is from three to five years. For the former
GGM Facility, the estimated time to design and construct the Engineering Control Alternative
G-2 is from two to three years, and for the Excavation and Off-Site Disposal Alternative G-3
from one to two years.
The Engineering Control Alternatives involve less intrusive activities, and pose less of a threat to
workers and the surrounding community than the Excavation and Off-Site Disposal Alternatives.
However, both the Engineering Control Alternatives and the Excavation and Off-Site Disposal
Alternatives involve intrusive activities, including, in some cases, temporary relocation of
residents.
The Excavation and Off-Site Disposal Alternatives have a greater potential adverse impact in the
short term because of the excavation of radiologically-contaminated soil. For future workers, this
could lead to increased short-term exposure to radon, gamma radiation, and soil radionuclides.
Dust suppression techniques and/or other measures would be required to minimize the impacts of
this alternative. However, under Alternative V-2 (Engineering Controls for the Vicinity
25
Properties), there would be some increased short-term risk to workers during the installation of
the radon mitigation systems. This is due to the need to excavate under the foundation of homes
that require radon mitigation.
Implementability
The Excavation and Off-Site Disposal Alternatives (W-3, V-3 and G-3) are readily
implementable. Similar activities have been utilized at other radiologically-contaminated sites
around the country. There is an available off-site disposal facility. which is accessible by both
truck and rail. However, the continued availability of this off-site disposal facility is required for
implementation of these alternatives.
Implementation of the Engineering Controls Alternatives V-2 and G-2 may pose some difficulties.
Under Alternative V-2 (for the Vicinity Properties), there may be some difficulty in getting the
consent of all of the property owners to restrict future work on their properties. EPA would have
to reach agreement with individual property owners to file Declarations of Environmental
Restrictions (i.e., deed restrictions) on their properties. For Alternative G-2 (for General Gas
Mantle), it would be difficult to keep the building permanently sealed from trespassers.
Cost
Alternative V-2 includes construction costs of $900,000 to implement engineering control
measures at the Vicinity Properties. Annual O&M costs are estimated to be $99,000. The present
worth cost of Alternative V-2 is $1,810,000, with O&M costs assumed for 30 years. Alternative
W-2 includes construction costs of $5,686,000 to implement engineering control measures at the
former Welsbach Facility. Annual O&M costs are estimated to be $44,000. The present worth
cost of Alternative W-2 is $6,182,000, with O&M costs assumed for 30 years. Alternative G-2
includes construction costs of $122,000 to implement engineering controls at the General Gas
Mantle Facility. Annual O&M costs are estimated to be $23,000. The present worth cost of
Alternative G-2 is $381,000, with O&M costs assumed for 30 years. The radionuclides in
question have half-lives far greater than 30 years, so any of the Engineering Controls remedies
must be maintained effectively forever.
Alternative V-3 includes construction costs of $13,408,560 to excavate the radiologically
contaminated soil at the Vicinity Properties and dispose of the waste at an off-site disposal
facility. Alternative W-3 includes construction costs of $18,503,560 to excavate the
radiologically-contaminated soil at the former Welsbach Facility and dispose of the waste at an
off-site disposal facility. Alternative G-3 - Option A involves construction costs of $2,309,560,
and includes demolishing the General Gas Mantle building and disposal of all the building debris at
an off-site disposal facility Alternative G-3 - Option B involves construction costs of $1,979,560,
and includes decontaminating the General Gas Mantle building before its demolition.
26
There are no O&M costs associated with the Excavation and Off-Site Disposal Altematives W-3,
V-3 and G-3 Options A and B).
State Acceptance
The State concurs with the selected remedial action.
Community Acceptance
EPA solicited input from the community on the remedial alternatives proposed for the
Welsbach/General Gas Mantle Contamination Site. The community was supportive of EPA’s
preferred remedy which called for the excavation and off-site disposal of the radiologically
contaminated soils at the Site. The No Action and Engineering Controls Alternatives received no
community support. The attached Responsiveness Summary addresses the comments received
during the public comment period.
SELECTED REMEDY
Based upon consideration of the results of the RI/FS, the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, EPA and NJDEP have determined that the
Excavation and Off-Site Disposal Alternatives (V-3, W-3, and G-3 with Option B) are the
appropriate remedies for the Site.
The selected remedial action will provide a final remedy and achieve the remedial action
objectives at the Vicinity Properties and the Welsbach and General Gas Mantle Facilities by:
! eliminating or minimizing the potential for humans to ingest, come in dermal contact with,
or inhale particulates of radioactive constituents, or be exposed to external gamma
radiation, thereby achieving the level of protection required by the NCP;
! preventing exposure to radon gas and radon decay products in excess of 4 pCi/L and 0.02
WL, respectively;
! preventing direct contact with building surfaces exhibiting total surface thorium
contamination exceeding 0.026Ci/m2 above background;
! preventing long-term exposure to thorium- and radium-contaminated materials with
concentrations greater than 5 pCi/g above background; and
! preventing migration of radiologically-contaminated materials that could result in
exposures described above.
27
Radiologically-contaminated soil found on the Vicinity Properties and the former Welsbach and
GGM Facilities in excess of 5 pCi/g above background will be excavated consistent with 40 CFR
192, Subparts B and E. The remedy will attain a risk level similar to risk levels associated with
exposure to natural background radiation. This will be confirmed via post-excavation property
surveys. The Multi-Agency Radiation Survey and Site Investigation Manual (MARISSM) may be
used where appropriate to conduct such property surveys. MARISSM provides a methodology to
confirm that a particular soil concentration level has been achieved after the remedial action is
completed. An appropriate survey methodology to be used will be determined during remedial
design.
EPA estimates that the following volumes of contaminated soil and debris will be removed from
the Site: Vicinity Properties - 13,000 cubic yards, General Gas Mantle - 2.500 cubic yards.
Welsbach Facility - 27,000 cubic yards. EPA will dispose of the radiologically-contaminated
material at a licensed, off-site facility. Areas that have been excavated will be restored with clean
fill. No significant changes in land use are anticipated. Because all contamination above the
cleanup criteria will be excavated and sent off-site for disposal, all remediated properties will be
available for unrestricted future use.
EPA will make every effort to minimize any long-term disruption to individual residents or the
community. During excavation, EPA may need to temporarily relocate some residents at
government expense.
As previously stated, EPA will investigate approximately 600 Suspect Properties during the
remedial design phase. When these properties are tested, it is likely that some will be found to
contain radiologically-contaminated material and will require remediation. The selected remedy
also includes such remediation. EPA believes that cleanup of additional contaminated properties
will not affect the overall scope of the remedial action.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on CERCLA and the regulations contained in the NCP.
Under its legal authorities, EPA’s primary responsibility in selecting remedies at Superfund sites
is to undertake actions that are protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory requirements and preferences. These
specify that, when complete, the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards established under federal and state
environmental laws unless a statutory waiver is justified. The selected remedy also must be cost
effective and utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently and significantly reduce the
volume, toxicity, or mobility of the hazardous wastes, as their principal element. The following
sections discuss how the selected remedy meets these statutory requirements for the first operable
unit of the Welsbach/GGM site.
28
Protection of Human Health and the Environment
This remedy is fully protective of human health and the environment for all properties, with
radiological contamination above the cleanup standards. It is estimated that no radiologically-
contaminated soil above the cleanup standards will remain on the affected properties. The remedy
will attain a risk level similar to risk levels associated with exposure to natural background
radiation. Implementation of this remedy will eliminate additional risks attributable to exposures
to indoor or outdoor gamma radiation, indoor radon gas or radon decay products, inhalation
and/or ingestion of contaminated soil, and ingestion of contaminated vegetables grown in
contaminated soil. This remedy will comply with the ARARs for exposure to indoor gamma
radiation and the inhalation of radon gas or radon decay products, and attainment of soil cleanup
standards.
There are few short-term risks associated with the implementation of this remedy. Where
excavation occurs, dust suppression measures can reduce the risk of inhalation of radiologically-
contaminated dust. In addition, no adverse cross-media impacts are expected from the remedy.
Compliance with ARARs
As presented earlier, the primary ARARs for this site are contained in 40 CFR 192, Subpart B.
This regulation deals with the cleanup of inactive uranium processing facilities. EPA has
determined that while these standards are not applicable, they are relevant and appropriate to the
situation at the Welsbach/GGM site. Table 9 lists and summarizes these and other standards that
may be pertinent during the implementation of this remedial action.
When implemented, the cleanup of the affected properties within the study areas will comply with
all public health and soil cleanup ARARs, and will allow for unrestricted use of these properties.
Cost Effectiveness
The selected remedy is cost-effective because it provides the highest degree of overall
effectiveness relative to its cost. The remedy provides for complete protection of public health and
the environment at the affected properties.
The radioactive half-life of thorium-232, the primary contaminant of concern, is 14 billion years.
Remedies that would isolate wastes containing thorium and the uranium series radionuclides
permanently from the public and the environment are preferable.
Utilization of Permanent Solutions and Alternative Treatment Technologies to thq Maximum
Extent Practicable
EPA and the State of New Jersey have determined that the selected remedy represents the
maximum extent to which permanent solutions and currently available treatment technologies can
29
be utilized in a cost-effective manner for this phase of the remedial action at the Welsbach/General
Gas Mantle Contamination site. Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA and the State of New Jersey have determined that the
selected remedy provides the best balance of trade-offs in terms of long-term effectiveness and
permanence, short-term effectiveness, implementability, cost, the statutory preference for
treatment as a principal element and State and community acceptance.
Alternatives V-3, W-3, and G-3 result in a permanent solution to the radioactive contamination.
The longevity of these contaminants of concern (thousands to billions of years) favors excavation
which permanently removes them from their current uncontrolled locations. Commercial disposal
at a licensed facility with an appropriate closure plan will ensure that these radiological wastes are
permanently isolated from human and ecological receptors. The Excavation and Off-Site Disposal
Alternatives are considered implementable and will result in a remedy that is highly effective in the
long-term. These remedies are also consistent with the remedial approach taken at all other
radiologically-contaminated sites in New Jersey.
Preference for Treatment as a Principal Element
The principal threat at the Site is from exposure to excess levels of indoor and/or outdoor gamma
radiation, and ingestion and/or inhalation of radiologically-contaminated soil. In addition, there
are threats from the generation of excess concentrations of radon gas and radon decay products
indoors which migrate from the underlying soils, and are subsequently inhaled by the residents of
those houses. Because there is no treatment available that destroys the radioactive source of these
threats, the selected remedy does not satisfy the statutory preference for treatment as the principal
element. The remedy does reduce the exposure to all excess levels of indoor and/or outdoor
gamma radiation. It also provides for complete remediation at the affected properties, thereby
reducing the exposure risk from all pathways.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative presented in the Proposed Plan.
30
APPENDIX I
FIGURES
31
32
34
APPENDIX II
TABLES
35
TABLE -1
RADIATION UNITS
ParameterHistorical International
Unit Abbrev. Unit Abbrev.
Quantity Curie Ci Becquerel Bq
RadionuclideConcentration inSoil or OtherSolid Material
picoCurie pergram of Solid
pCi/g Becquerel perkilogram
Bq/kg
RadionuclideConcentration in Water
picoCurie perliter of Water
pCi/L --- —
Radon Gas Conc. picoCurie perliter of Air
pCi/L Becquerel percu. meter
Bq/m3
Radon ProgenyConc.
Working Level WL --- ---
Exposure Rate micro-Roentgenper hour
µR/h — —
Dose RadiationAbsorbed Dose
rad Gray Gy
Dose Equivalent RadiationEquivalent Man
rem Sievert Sv
36
TABLE-2
PROPERTY CHARACTERIZATION
WELSBACII/GGM SITE
STUDY AREA AREA 1 AREA 2 AREA 3 AREA 4 AREA 5 AREA 6 TOTAL
PROPERTIES SURVERYED BY THE
NJDEP
359 174 48 474 32 NA1 1088
PROPERTIES WITH NO EVIDENCE OF
CONTAMINATION
<13 µN/HR
<0.02 WL RADON DECAY PRODUCTS
<4.0 pCi/L RADON
103 40 18 272 16 0 449
SUSPECT PROPERTIES
13 - 30 µR/h OR
ADJACENT TO CONTAMINATED
PROPERTIES
239 113 23 199 11 0 585
POTENTIALLY CONTAMINATED
PROPERTIES
>30 µR/HR
>0.02 WL RADON DECAY PRODUCTS
> 4.0 pCi/L RADON
17 21 7 3 5 1 54
Note:
1 - Study Area 6 was not part of the NJDEP investigation.
NA - Not Applicable
37
TABLE 3
ESTIMATED VOLUME OF CONTAMINATED MATERIALSWELSBACH/GGM SITE
SOIL(CUBIC YARDS)
STRUCTURAL/DEBRISMATERIALS
(CUBIC YARDS)
FORMER WELSBACHFACILITY
22,200 5,000
FORMER GGM FACILITY 885 1,460
VICINITY PROPERTIES 11,010 2,255
TOTAL 34,100 8,720
38
TABLE 4
RADIOLOGICAL RISK ESTIMATES BASED ON REASONABLE MAXIMUM EXPOSURES
AT
FORMER GAS MANTLE MANUFACTURING FACILITIES
POPULATION PATHWAY EXPOSURE
MEDIUM
GROSS
RISK
BACKGROUND
RISK
NET
RISK
TOTAL
RISK
FORMER WELSBACH FACILITY
WORKER EXTERNAL SOIL 5.70e-02 7.30e-05 5.70e-02 5.70e-02
OTHER WORKER EXTERNAL SOIL 1.40e-02 1.80e-05 1.40e-02 1.40e-02
CONSTRUCTION WORKER EXTERNALINGESTIONINHALATION
SOILSOIL
PARTICULATES
7.50e-043.10e-051.10e-03
8.70e-075.60e-088.40e-07
7.50e-043.10e-051.10e-03 1.90e-03
FORMER GENERAL GAS MANTLE FACILITY
TRESPASSER EXTERNAL*
INGESTIONINHALATION
*
SOILBUILDING MATERIALS
SOILPARTICULATES
RADON DECAY PRODUCTS
3.10e-052.00e-051.90e-060.00e+002.50e-03
1.30e-063.40e-061.40e-070.00e+007.40e-06
3.00e-061.70e-051.80e-060.00e+002.50e-03 2.50e-03
CONSTRUCTION WORKER EXTERNALINGESTIONINHALATION
SOILSOIL
PARTICULATES
2.10e-05
7.50e-07
2.80e-05
8.70e-07
5.60e-08
8.40e-07
2.00e-05
6.90e-07
2.70e-05 4.80e-05
ADULT RESIDENT EXTERNALINGESTION
*INHALATION
SOILSOIL
HOME GROWN PRODUCERADON DECAY PRODUCTS
8.90e-03
2.70e-05
2.30e-08
4.90e-03
3.80e-04
2.00e-06
3.20e-06
8.00e-04
8.50e-03
2.50e-05
2.00e-05
4.10e-03 1.30e-02
CHILD RESIDENT EXTERNALINGESTION
*INHALATION
SOILSOIL
HOME GROWN PRODUCERADON DECAY PRODUCTS
1.80e-03
1.10e-05
1.90e-06
5.60e-04
7.80e-05
8.10e-07
2.70e-07
9.20e-05
1.70e-03
1.00e-05
1.60e-06
4.70e-04 2.20e-03
WORKER EXTERNALINHALATION
*
BUILDING MATERIALSPARTICULATES
RADON DECAY PRODUCTS
1.40e-03
0.00e+00
1.80e-01
2.40e-04
0.00e+00
5.10e-04
1.20e-03
0.00e+00
1.80e-01 1.80e-01
39
TABLE 5
VICINITY PROPERTIES
SUMMARY OF RADIOLOGICAL RISK ESTIMATES
BASED ON REASONABLE MAXIMUM EXPOSURES*
VICINITY
PROPERTY POPULATION PATHWAY
RISK
GROSS BACKGROUND NET
PUBLIC PARK
SITE WORKER ExternalInhalation of ParticulatesInhalation of RadonIngestion of Soil
7.3e-012.3e-021.7e-033.0e-03
8.6e-051.8e-065.2e-045.5e-07
7.3e-012.3e-021.2e-033.0e-03
Total: 7.6e-01 6.1e-04 7.6e-01
POPCORNFACTORY
CONSTRUCTIONWORKER
EXTERNALInhalation of ParticulatesIngestion of Soil
3.3e-041.1e-051.1e-06
8.3e-073.1e-083.1e-09
3.3e-041.1e-051.1e-06
Total: 3.4e-04 8.6e-0 3.4e-04
PUBLIC PARK
ADULTRECREATIONALIST
ExternalInhalation of ParticulatesIngestion of Soil
2.2e-016.9e-034.5e-04
2.6e-055.5e-078.3e-08
2.2e-016.9e-034.5e-04
Total: 2.3e-01 2.7e-05 2.3e-01
POPCORNFACTORY
RESIDENT ADULT ExternalInhalation of RadonIngestion of Soil
4.7e-021.2e-011.2e-04
3.5e-047.9e-042.0e-06
4.7e-021.2e-011.2e-04
Total: 1.7e-01 1.1e-03 1.7e-01
PUBLIC PARKCHILDRECREATIONALIST
EternalInhalation of ParticulatesIngestion of Soil
4.4e-021.2e-031.8e-04
5.1e-069.4e-083.3e-08
4.4e-021.2e-031.8e-04
Total: 4.5e-02 5.2e-06 4.5e-02
LANDPRESERVE
RESIDENT CHILD ExternalInhalation of RadonIngestion of Home GrownProduceIngestion of Soil
7.0e-022.5e-02
2.5e-034.6e-04
6.8e-059.0e-05
3.8e-067.8e-07
7.0e-022.5e-02
2.5e-034.6e-04
Total: 9.8e-02 1.6e-04 9.8e-02
LANDPRESERVE
TRESPASSER EternalInhalation of ParticulatesIngestion of Soil
2.4e-031.2e-042.3e-06
2.5e-069.4e-083.8e-09
2.4e-031.2e-042.3e-06
Total: 2.5e-03 2.6e-06 2.5e-03
• The exposure duration varies for each population considered in the risk Assessment. Only the maximum riskestimates for each population evaluated are provided.
TABLE 6
RISK ASSESSMENT SUMMARY
FORMER WELSBACH FACILITY
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium Exposure Chemical
Carcinogenic Risk
Chemical
Non-Carcinogenic Hazard Quotient
Ingestion Inhalation Dermal Exposure
Routes Total
Primary
Target
Organ
Ingestion Inhalation Dermal Exposure
Routes Total
Soil Soil Benzo(a)Anthracene 6e-08 -- No Tox
Data
6e-08 Arsenic Skin 1e+00 -- 2e-01 1e+00
Benzo(b)Fluoranthene 1e-07 -- No Tox
Data
1e-07
Benzo(a)Pyrene 6e-07 -- No Tox
Data
6e-07
Aroclor-1248 1e-08 -- 7e-09 2e-08
Aroclor-1254 1e-08 -- 8e-09 2e-08
Antimony No tox data -- No Tox
Data
--
Arsenic 7e-06 -- 1e-06 8e-06
Selenium -- -- -- --
(Total) 7e-06 -- 1e-06 8e-06 (Total) 1e+00 -- 2e-01 1e+00
Particulates Benzo(a)Anthracene -- No Tox
Data
-- -- -- -- -- --
Benzo(b)Fluoranthene -- No Tox
Data
-- -- - - - -
Benzo(a)Pyrene -- No Tox
Data
-- -- -- -- -- --
Aroclor-1248 -- 2e-09 -- 2e-09 -- -- -- --
Aroclor-1254 -- 2e-09 -- 2e-09 - - - -
Antimony -- No Tox
Data
-- -- - - - --
Arsenic -- 1e-05 -- 1e-05 - - - --
Selenium -- -- -- -- -- -- -- --
(Total) -- 1e-05 -- 1e-05 (Total) -- -- -- --
Total Risk Across Soil 2e-05 Total Hazard Index Across All Media and All Exposure
Routes1e+00
Total Risk Across All Medial and All Exposure Routes 2e-05 Total Skin III 1e+00
TABLE 7
RISK ASSESSMENT SUMMARY
GENERAL GAS MANTLE
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium Exposure Chemical
Carcinogenic Risk
Chemical
Non-Carcinogenic Hazard Quotient
Ingestion Inhalation Dermal Exposure
Routes Total
Primar
y
Target
Organ
Ingestion Inhalation Dermal Exposure
Routes Total
Soil Soil Benzo(a)Anthracene 2e-09 -- No Tox Data 2e-09 Aroclor-1248 N/A 2e-03 -- 1e-03 3e-03
Benzo(a)Pyrene 2e-08 -- No Tox Data 2e-08 Selenium Liver 2e-04 -- No Tox Data 2e-04
Aroclor-1248 9e-10 -- 7e-10 2e-09
Selenium -- --
Thallium -- --
(Total) 2e-08 -- 7e-10 2e-08 (Total) 2e-03 -- 1e-03 3e-03
Particulates Benzo(a)Anthracene -- No Tox
data
-- -- -- -- -- --
Benzo(a)Pyrene -- No Tox
data
-- -- -- -- -- --
Aroclor-1248 -- 2e-10 -- 2e-10 -- -- -- --
Selenium -- -- -- -- -- -- --
Thallium -- -- -- -- -- -- --
(Total) -- 2e-10 -- 2e-10 (Total) -- -- -- --
Total Risk Across Soil 2e-08 Total Hazard Index Across All Media and All Exposure Routes 3e-03
Total Risk Across All Medial and All Exposure Routes 2e-08 Total Skin III = 2e-04
TABLE 8
SUMMARY OF ALTERNATIVE COSTS
WELSBACH/GENERAL GAS MANTLE SITE
ALTERNATIVE PROPERTY CAPITAL O & M*
(30 Years)
TOTAL
NO ACTION
WELSBACH (W-1) $0 $0 $0
VICINITY PROPERTIES (V-1) $0 $0 $0
GENERAL GAS MANTLE (G-1) $0 $0 $0
ENGINEERING
CONTROLSWELSBACH (W-2) $5,686,000 $496,000 $6,182,000
VICINITY PROPERTIES (V-2) $900,000 $910,000 $1,810,000
GENERAL GAS MANTLE (G-2) $122,000 $259,000 $381,000
EXCAVATION AND
OFF-SITE DISPOSALWELSBACH (W-3) $18,503,560 $0 $18,503,560
VICINITY PROPERTIES (V-3) $13,408,560 $0 $2,309,560
GENERAL GAS MANTLE
OPTION B (G-3)1
$2,309,560 $0 $2,309,560
GENERAL GAS MANTLE
OPTION B (G-3)2
$1,979,560 $0 $1,979,560
* O&M costs calculated using an 8 percent discount rate
1. Option A: Demolition and Disposal of GGM building2. Option B: Decontamination and Demolition of GGM building
43
TABLE 9
SITE SPECIFIC CLEANUP STANDARDS
TYPE PERTINENT
STANDARD OR
GUIDELINE
SOURCES
Radon and ThoronIndoor Concentration
4 pCi/L Citizen Guide toRadon (EPA 1992)
Radon and ThoronDecay Progeny:
AverageMaximum
0.02 WL0.03 WL
40 CFR 19240 CFR 192
Soil:Radium andOther Radionuclides
5 pCi/g - Sum of 226Ra and 228Ra5 pCi/g - Sum of 230Th and 232Th
40 CFR 192
Subsurface Soil:Radium andOther Radionuclides
5 pCi/g - Sum of 226Ra and 228Ra5 pCi/g - Sum of 230Th and 232Th
OSWER Directive9200.4-25
Wetlands Protection of Wetlands Clean Water act40 CFR 230.1 et seq.
Executive Order 11990
Endangered Species Protection of Endangered andThreatened Species
Endangered Species Act16 U.S.C. 1536 (a)(2)
Historic Buildings Protection of ArchaeologicalSignificant Items
National HistoricPreservation Act16 U.S.C. 470(f)
APPENDIX III
ADMINISTRATIVE RECORD INDEX
WELSBACH & GENERAL GAS MANTLE CONTAMINATIONADMINISTRATIVE RECORDINDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.2 Notification/Site Inspection Reports
P. 100001-100308
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites. Camden and GloucesterCity, New Jersey, Volume I of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.
P. 100309-100551
Report: Final Hazard Ranking SystemDocumentation Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume II of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.
P. 100552-101016
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume III of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.
P. 101017-101428
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume IV of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared
1
by Mr. Steven T. McNulty, Project manager, Mr.Todd G. Teryek, Task Leader, Mr. John L.Splendore, P.E., Work Assignment Manager, U.S.EPA, Region 11, March 27, 1995.
P. 101429-101707
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites. Camden and GloucesterCity, New Jersey, Volume V of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.
P. 101708-102024
Report: Final Hazard Ranking SystemDocumentation Welsbach and General GAS MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VI of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995.
P. 102025-102600
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VII of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John L. Splendore, P.E., WorkAssignment Manager, U.S. EPA, Region II, March27, 1995. (Note: The Gloucester City/CamdenSurvey of Affected Properties for SeniorCitizens and Children, pages 102298-102305, isconfidential due to the Privacy Act. It islocated at the U.S. EPA Superfund RecordsCenter, 290 Broadway, 18th Fl., N.Y., N.Y.10007-1866.)
P. 102601-102920
Report: Final Hazard Ranking SystemDocumentation, Welsbach and General Gas MantleContamination Sites, Camden and GloucesterCity, New Jersey, Volume VIII of VIII, preparedfor the Environmental Services Division, U.S.EPA, Region II, prepared by Mr. Steven T.McNulty, Project Manager, Mr. Todd G. Teryek,Task Leader, Mr. John
2
L. Splendore, P.Z., Work Assignment Manager,U.S. EPA, Region II, March 27, 1995. (Note: TheQuality Control Internal Controls and AuditsManual, pages 102763-102822, and The QualityAssurance Manual pages 102823-102876, areconfidential business information. They arelocated at the U.S. EPA Superfund RecordsCenter, 290 Broadway, 18th Fl., N.Y., N.Y.10007-1866.)
1.4 Site Investigation Reports
P. 102921-102947
Report: An Aerial Survey of Gloucester, NewJersey and Surrounding Area, prepared for theU.S. EPA, Region II, prepared by Mr. Joel E.Jobst, Mr. Harvey W. Clark, Project Scientists,May 1981.
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P. 300001-300192
Plan: Welsbach/General Gas MantleContamination Sites, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft Final Work Plan,Remedial Investigation/ Feasibility Study,Volume I, prepared for the U.S. EPA, Region II,prepared by Malcolm Pirnie, Inc., June 1997.
3.4 Remedial Investigation Reports
P. 300193-300347
Report: Welsbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No, 050-28UC, Stage 1aArchaeological Investigation, prepared for theU.S. EPA, Region II, prepared by MalcolmPirnie, Inc., June 1998.
P. 300348-300694
Report: Welsbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No, 050-28UC, Draft Final RemedialInvestigation/Feasibility Study Report, VolumeI, prepared for the U.S. EPA, Region II,prepared by Malcolm Pirnie, Inc., June 1998.
P. 300695-301035
Report: Welsbach and General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft Final RemedialInvestigation/Feasibility Study Report, VolumeII,
3
prepared for the U.S. EPA, Region II, preparedby Malcolm Pirnie, Inc., June 1998.
3.5 Correspondence
P. 301036-301134
Report: Weslbach/ General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC Response to Comments,prepared for the U.S. EPA, Region II, preparedby Malcolm Pirnie, Inc. November 1997.
P. 301135-301145
Memorandum to Addressees, from Stephen D.Luftig, Director, of Office of Emergency andRemedial Response, and Mr. Larry Weinstock,Acting Director, Office of Radiation and Indoorair, re: Establishment of Cleanup Levels forCERCLA Sites with Radioactive Contamination,August 22, 1997.
P. 301146-301151
Memorandum to Addressees, from Mr. Stephen D.Luftig, Director, of Office of Emergency andRemedial Response, and Mr. Larry Weinstock,Acting Director, Office of Radiation and Indoorair, re: Use of Soil Cleanup Criteria in 40 CFRPart 192 as Remediation Goal for CERCLA sites,February 12, 1998.
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700001-700059
Administrative Orders on Consent for RemedialInvestigation/Feasibility Study ArmstrongBuilding, In the Matter of Welsbach Gas MantleContamination Site (8U), Holt Hauling andWarehouse System, Inc., Respondent, undated.
8.0 HEALTH ASSESSMENTS
8.1 ATSDR Health Assessments
P. 800001-800037
Memorandum to Mr. John Prince, ERRD/NJSB1-N,from Mr. Arthur Block, Senior. RegionalRepresentative, re: Final Health Consultationfor Welsbach and General Gas MantleContamination Sites (WGGMCS), March 12, 1997.
4
10.0 PUBLIC PARTICIPATION
10.2 Community Relations Plans
P. 10.00001-10.00038
Plan: Weslbach/General Gas MantleContamination Site, Camden, New Jersey, WorkAssignment No. 050-28UC, Draft FinalCommunity Relations Plan, RemedialInvestigation/Feasibility Study, prepared forthe U.S. EPA, Region II, prepared by MalcolmPirnie, June 1997.
10.9 Proposed Plan
P. 10.00039-10.00059
Plan: Superfund Proposed Plan, Weslbach/General GasMantle Contamination, Superfund Site, Camden andGloucester City, Camden County, New Jersey, preparedby U.S. EPA Region II, February 1999.
5
APPENDIX IV
STATE LETTER
July 21, 1999
Ms. Jeanne M. Fox
Regional Administrator
U.S. EPA - Region II
290 Broadway
New York, NY 10007-1866
Subject: Welsbach/General Gas Mande Contamination Superfund Site
Record of Decision (ROD)
Dear Mr. Fox:
The New Jersey Department of Environmental Protection (NJDEP) has evaluated and concurs with the
component of the selected remedy as described below for the Welsback/General Gas Mantle Superfund Site.
The selected remedy corresponds to the first of three planed operable units for the Site which includes
properties located in Gloucester City and Camden, Camden County, New Jersey.
The major components of the selected remedy include:
• Excavation/removal of soil and waste materials with radiological contamination above remedial action
objectives from the former Welsback and General Gas Mantle Facilities;
• Excavation/removal of soil and waste materials with radiological contamination above remedial action
objectives from the residential and commercial properties in the vicinity of two former gas mantle facilities;
• Off-site disposal of the radiologically-contaminated soil and waste materials;
• Decontamination and demolition of the General Gas Mantle Building; and
• Appropriate environmental monitoring to ensure the effectiveness of the remedy.
NJDEP concurs that the selected remedy is protective of human health and the environment, complies with
requirements that are legally applicable or relevant and appropriate for the remedial action, and is cost
effective.
2
The State of New Jersey appreciates the opportunity afforded to participate in the Superfund process.
APPENDIX V
RESPONSIVENESS SUMMARY
RESPONSIVENESS SUMMARY
FOR THE
WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE
GLOUCESTER CITY & CAMDEN, CAMDEN COUNTY, NEW JERSEY
I. INTRODUCTION
This Responsiveness Summary provides a summary of public comments and concernsregarding the remedial investigation and feasibility study (RI/FS) report and the ProposedPlan for the Welsbach/General Gas Mantle Contamination site. It also provides the U.S.Environmental Protection Agency's (EPA's) responses to those comments. After reviewingand considering all public comments received during the public comment period, EPA hasselected a remedy for the former Welsbach Facilitv, the former General Gas Mantle (GGM)Facility, and the Vicinity Properties at the Welsbach/General Gas Mantle Contamination site.
The RI/FS report, the Proposed Plan and supporting documentation were made available tothe public in the administrative record file at the Superfund Document Center in EPA RegionII. 290 Broadway, 18th Floor, New York, New York 10007 and at the following repositories:City of Camden Main Library, 418 Federal Street, Camden, New Jersey 08103; the HynesCenter, 1855 South 4th Street, Camden, New Jersey 80104; and the Gloucester City PublicLibrary, Monmouth and Hudson Streets, Gloucester City, New Jersey 08030. The notice ofavailabil ity for the above-referenced documents was published in the Philadelphia Inquireron February 1, 1999, the Courier-Post on February 2, 1999, and the Gloucester City Newson February 4, 1999. The public comment period which related to these documents was heldfrom February 1, 1999 to March 3, 1999.
EPA conducted public meetings in both Gloucester City and Camden to inform local officialsand interested citizens about the Superfund process, to review proposed remedial activitiesat the Site and receive comments on the Proposed Plan, and to respond to questions fromarea residents and other interested parties. Meetings were held on February 23, 1999, at thePine Grove Fire Station #2 in Gloucester City, and on February 24, 1999, at the CamdenCounty Municipal Utilities Authorities Auditorium in Camden. Responses to the commentsreceived at the public meeting are included in this Responsiveness Summary. The City ofGloucester City submitted a resolution supporting the proposed remedy. No other writtencomments were received during the public comment period.
In general, the community responded positively to EPA's Proposed Plan. A majority of theresidents recognized the importance of remediating the contamination at theWelsbach/General Gas Mantle Contamination site.
The next section of this Responsiveness Summary provides a comprehensive summary ofmajor questions, comments, concerns, and responses, by summarizing oral comments madeat the public meetings and EPA's responses.
2
The last section of this Responsiveness Summary includes appendices which documentpublic participation in the remedy selection process for this site. There are four appendicesattached to this Responsiveness Summary. They are as follows:
Appendix A contains the Proposed Plan that was distributed to the public for reviewand comment, and a Proposed Plan Summary that was provided to interested partieswith the Proposed Plan:
Appendix B contains the public notices which appeared in the Philadelphia Inquire,the Courier-Post, and the Gloucester City News;
Appendix C contains the transcripts of the public meetings; and
Appendix D contains the written comments received by EPA during the publiccomment period.
II COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS, AND RESPONSES
Oral Comments Received During the Public Meetings
This section summarizes oral comments raised at the public meetings and EPA's responses.The comments and corresponding responses are presented in the following categories:
1.0 Remedial Investigation and Feasibility Study2.0 EPA's Proposed Plan3.0 Health and Safety4.0 Cleanup Schedule5.0 Public Participation Process6.0 Real Estate Issues7.0 Other
1.0 Remedial Investigation and Feasibility Study
1.1 Comment: An interested resident noted that the maps prepared for the project showedthat properties north of the General Gas Mantle Building were not investigated. EPA wasasked whether these properties would be included in future investigations.
Response: During the remedial design, EPA will investigate these properties and otherproperties that are adjacent to known contaminated properties.
3
2.0 EPA's Proposed Plan
2.1 Comment: An interested citizen asked what will happen to the residents while the remedial
work is going on.
Response: EPA will work with the property owner(s) so that there is as little inconvenience to
residents as possible. If there is a need for temporary relocation, the property owner will not be
responsible for any costs. All costs associated with the temporary relocation will be paid by EPA.
2.2 Comment: An interested citizen asked if the decision on whether to proceed with the
demolition of the GGM building and excavation of the contaminated material from the site has
been made.
Response: EPA will not make a final decision until all public comments have been received;
however, the preferred remedy calls for the demolition of the GGM building and the excavation
and off-site disposal of the radiologically-contaminated soils and waste materials. At that time,
EPA will issue the Record of Decision (ROD) which formally selects a remedy for the cleanup
of the site.
2.3 Comment: An interested resident inquired as to how the contaminated material would be
shipped from the site.
Response: The material will be shipped off-site via rail transport. The material will be excavated
from any given contaminated property and loaded onto a truck for transport to a rail loading site
in or near Gloucester City or Camden. Measures will be taken to secure the containers holding
the contaminated material to ensure the public's safety.
2.4 Comment: An interested resident asked how deep the excavations are going to be in the
backyards of the homes on Arlington Street in Camden.
Response: At this time, EPA does not know the exact depths and volumes of soil that would
need to be removed from the Arlington Street properties. The exact volumes will be determined
during the remedial design phase. For the purpose of the RI/FS, volume estimates were based on
the investigation of other properties with similar conditions. Based on this information, EPA
estimates that contamination is generally limited to the top one to two feet of soil.
2.5 Comment: An interested citizen asked if there is a work plan for the demolition of the GGM
building and excavation and off-site disposal of the radiologically-contaminated materials.
Response: A work plan for the construction activities will be prepared after the Remedial
Design is completed. Prior to beginning construction activities, EPA will hold public meetings
4
describing the construction activities that would take place. At that time, a work plan would be
available for review at the public repositories.
2.6 Comment: An interested citizen complimented EPA on selecting the most thorough remedy
and asked whether the cleanup will allow for future unrestricted use of the properties.
Response: The cleanup criteria are protective of both human health and the environment.
Consequently, once the material has been removed, there would be no restriction on future uses
of these properties.
2.7 Comment: An interested resident asked if residents would be relocated during the cleanup
and for how long.
Response: Based on EPA's current findings, only a limited number of individuals may need to
be temporarily relocated during remediation. EPA would assure that relocated residents would
be provided with comparable accommodations. EPA would pay for temporary relocation
expenses. On similar sites that required relocation, EPA has found that the length of time a
resident would be relocated ranges from three to six months.
2.8 Comment: An interested party asked if EPA is going to check for radon in the basements.
Response: Part of EPA's investigation protocol is to perform a radon test on any potential
radiologically-contaminated property.
2.9 Comment: A interested party asked whether EPA would reconsider the cleanup plan if it
discovered much more contamination that expected.
Response: EPA does not anticipate finding such a substantial additional amount of
contamination that it would require changing the proposed remedy. The communities of both
Camden and Gloucester City support the remedy. Where EPA finds radiological contamination,
it will take it away. Once the ROD has been issued, EPA would be required to hold additional
public meetings and receive public comment before it modified the selected remedy.
3.0 Public Health Concerns
3.1 Comment: An interested resident questioned whether there were any long-term health effects
associated with the site. In particular, the resident mentioned the recent cancer study prepared by
the New Jersey Department of Health which indicated a higher than normal occurrence of lung
cancer throughout the area surrounding the site.
Response: The only long-term health effect from radiation is an increase in the risk of
developing cancer. Although the study indicated that there was an increase in the incidence of
5
lung cancer in the area, the results of the cancer study indicate that the Superfund sites were not
the probable cause for this increase.
3.2 Comment: An interested citizen inquired about whether a health study would be performed
on the residents of contaminated properties both prior to and following any remedial actions.
Response: EPA does not plan to perform focused health studies on residential property owners in
the future.
3.3 Comment: An interested resident asked what would be done for the residents while the soil
was being removed and will this pose any problems for people. How is EPA going to protect
them?
Response: The problems are more logistical than health based. The work will be performed in a
controlled manner to reduce dust and to ensure there is no spread of contamination. If there is a
potential health risk or significant inconvenience to the property owner, the homeowner may be
temporarily relocated until the work is complete.
3.4 Comment: A resident found some material from Welsbach in his home and was concerned
about possible health affects.
Response: At the public meeting, EPA informed the resident that it would scan his property to
see if there was any radiological contamination. A few days after the public meeting, EPA
investigated the property and found no radiological contamination.
4.0 Cleanup Schedule
4.1 Comment: An interested resident asked how soon the former GGM building would be
demolished.
Response: EPA anticipates that the GGM building will be demolished within one to two years.
5.0 Public Participation Process
5.1 Comment: An interested resident asked whether EPA was in contact with Camden city
officials.
Response: Yes, EPA has discussed the proposed remedial actions with the City of Camden’s
mayor’s office.
5.2 Comment: An interested resident asked what the next steps would be regarding informing the
residents of upcoming activities.
6
Response: Following the public comment period, EPA will prepare a ROD which selects the
cleanup remedy for the site. The ROD will include all of the public comments and EPA’s
responses. After the ROD is signed, EPA will place it in the local public repositories. The new
public meeting will be held prior to the start of any construction activities. EPA will also provide
periodic updates during the cleanup process.
6.0 Real Estate Issues
6.1 Comment: An interested citizen asked what could or should be done if an owner of a
contaminated property wishes to sell the property.
Response: The owner should provide a prospective buyer with all data about contamination on
the property. The participants in the transaction would need to obtain the advice of an Attorney
regarding their obligations under State law. If necessary, EPA can enter into an prospective
purchaser agreement with a potential purchaser of a contaminated property. The agreement would
provide that the purchaser would not be held liable for any cleanup costs associated with the
property. EPA’s policy is not to pursue innocent landowners for cost recovery.
6.2 Comment: An interested resident asked whether the owner of a contaminated property who
became the owner through inheritance from a relative would be responsible for cleanup costs.
Response: Persons who inherit contaminated property will not be held responsible for cleanup
costs if they can demonstrate that they had nothing to do with the contamination and can meet the
other requirements set forth in Sections 107(b) and 101 (35(A)(iii.) of CERCLA. There are
similar provisions in State law and an Attorney should be consulted on these matters.
Furthermore, under EPA’s existing policy, residential owners of contaminated property will not
be asked to demonstrate that they have defenses to liability or asked to reimburse EPA for the
costs of cleaning up that property so long as the owners did not cause or exacerbate the
contamination and they cooperate with EPA’s cleanup efforts.
7.0 Other
7.1 Comment: An interested resident asked if the NJDEP had performed property surveys in the
neighborhood of the Jogging Track, where a removal of contaminated material occurred.
Response: With few exceptions, the properties surveyed by the NJDEP were within the areas
identified in the Aerial Radiological Survey performed by EPA in 1981. Certain areas were
excluded based upon records which indicated that homes were constructed prior to the dates of
dumping/filling activities. Because the area in question was outside the areas identified in the
aerial survey. NJDEP did not survey this area.
7.2 Comment: An interested citizen asked if money has been approved for this project.
7
Response: EPA has allocated money for the design of the project. The design phase of the project
must be completed before EPA can allocate money for construction. When the design phase is
complete, EPA’s regional office will request EPA Headquarters in Washington, D.C. to allocate
funding for this project. At this time, we do not anticipate any problems.
7.3 Comment: A number of residents expressed concern over security issues associated with the
radiological contamination at the Popcorn Factory part of the site in Gloucester City.
Response: The former Popcorn Factory property is surrounded by a fence to keep people away
from the contamination. Gloucester City also placed gravel over the contaminated areas to protect
the residents. There are no signs posted because a majority of the residents in the area informed
city officials that they preferred no signs around the property. The contaminated materials from
EPA’s removal action which are presently being stored in roll-offs on the property are securely
covered. (Since the public meeting, the roll-off containers have been removed and disposed
off-site.)
7.4 Comment: A number of citizens questioned whether contamination was found in the area
designated for a playground near the Jogging Track in Gloucester City.
Response: At the public meeting EPA indicated that it would investigate the area designated for
the playground prior to its construction. In March 1999, EPA investigated this area and found no
radiological contamination.
Written Comments Received During the Public Comment Period
Comment: The City of Gloucester City submitted a resolution endorsing EPA’s plans for
cleaning up the radiologically contaminated properties in Gloucester City.
Response: No response necessary.
Appendix A
Proposed Plan
EPA Region 2 - February 1999 Page 2
EPA will also be available on an informal basis to
answer any questions at the Pine Grove Fire Station
#2 on Tuesday, February 23, 1999, from 1:00 p.m.
to 4:00 p.m. and at the Camden County Municipal
Utilities Authority Auditorium on Wednesday,
February 24, 1999, from 1:00 to 4:00 p.m.
Comments received at the public meeting and all
written comments, will be documented in the
Responsiveness Summary Section of the Record of
Decision (ROD), the document which formalizes the
selection of the remedy. All written comments should
be addressed to:
Richard J. Robinson
Project Manager
U.S. ENVIRONMENTAL PROTECTION AGENCY
290 Broadway, 19th Floor
New York, NY 10007-1866
Copies of the RI/FS report, Proposed Plan, and
supporting documentation are available at EPA’s
office at 290 Broadway, 18th Floor, New York, NY
10007-1866, (212) 637-4308, and at the following
repositories:
City of Camden Main Library
418 Federal Street
Camden, NJ 08103
(609)757-7650
Hynes Center
1855 South 4th Street
Camden, NJ 80103
(609)966-9617
Gloucester City Public Library
Monmouth and Hudson Streets
Gloucester City, NJ 08030
(609)456-4181
EPA, after consultation with NJDEP, will select a
remedy for the Site only after the public comment
period has ended, and the information submitted
during that time has been reviewed and considered.
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 117 (a) of
the Comprehensive Environmental Response,
Compensation and Liability Act: (CERCLA), as
amended, and Section 300.430(f) of the National Oil
and Hazardous Substances Pollution Contingency
Plan (NCP).
SITE BACKGROUND
Between the 1890s and 1940s, the Welsbach
Company (Welsbach) manufactured gas mantles at its
facility in Gloucester City, New Jersey. Welsbach
was a major manufacturer and distributer of gas
mantles until gas lighting was replaced by the electric
light. Welsbach extracted the radioactive element
thorium from ore and used it in the gas mantle
manufacturing process. Thorium causes the mantles to
glow more brightly when heated. A second gas mantle
manufacturing facility, known as the General Gas
Mantle Company (GGM), was located in Camden,
New Jersey. GGM was operated from 1915 to
approximately 1940.
EPA initially identified the Site in 1980, during an
archive search conducted as part of the investigation
of the U.S. Radium Corporation Superfund site
located in Orange, New Jersey. Historical U.S.
Radium Corporation files indicated that radiological
materials were purchased by U.S. Radium from the
Welsbach Corporation during the 1920's.
In May 1981, EPA conducted an aerial radiological
survey of the Camden and Gloucester City area to
investigate for radioactive contaminants. The survey
encompassed a 20 square kilometer area surrounding
the former locations of the Welsbach and General
Gas
Mantle Facilities. Five areas with elevated gamma
radiation were identified from the aerial survey; they
included the locations of the two former gas mantle
manufacturing facilities and three mainly residential
areas in both Camden; and Gloucester City. In 1993,
the data form the aerial survey were reanalyzed.
Based on this revised information, EPA identified a
sixth potential radiologically contaminated area which
includes two vacant lots in Gloucester City.
EPA Region 2 - February 1999 Page 3
In the early 1990s, NJDEP conducted more detailed
radiological investigations at more than 1,000
properties located throughout the original five study
areas. Radiological contamination was found at the
two former gas mantle facilities. NJDEP data also
indicated that approximately 100 properties near the
two former gas mantle facilities might be
contaminated. In 1996, the Welsbach/GGM site was
placed on National Priorities List (NPL) because of
the presence of radioactive contaminants.
Based on their geographic proximity. EPA divided the
Welsbach/GGM site into six study areas in Camden
and Gloucester City, New Jersey (Figure 1). A brief
description of each study area and its current land use
is presented below:
• Study Area One: includes the former
General Gas Mantle Facility and residential
and commercial properties which surround
the facility. The former GGM Facility is
located in a mixed industrial, commercial,
and residential zoned section of Camden.
• Study Area Two: includes the location of the
former Welsbach Facility and nearby
residential commercial properties. The
former Welsbach Company is situated in an
industrial zoned section of Gloucester City
with residential properties to the immediate
east.
• Study Area Three: includes residential and
recreational properties in Gloucester City.
including the Gloucester City Swim Club and
the Johnson Boulevard Land Preserve.
• Study Area Four: includes residential
properties in the Fairview section of Camden.
• Study Area Five: includes residential
properties, vacant land properties, and two
municipal parks near Temple Avenue and the
South Branch of Newton Creek in Gloucester
City.
• Study Area Six: includes two vacant lots in
a residential zoned area of Gloucester City.
This area was initially identified when the
aerial survey data were revised in 1993. This
area was identified during site assessments
performed by the City of Gloucester City.
No significant changes in land use are anticipated,
except in the Study Area 1 where there is a
possibilities that some residential areas may be
rezoned for commercial uses. Whether zoning
chances will actually be made is uncertain at this
time.
SITE HISTORY
The Welsbach and the GGM Facilities have complex
histories of name and ownership changes. Specific
details are discussed in the paragraphs below.
The United Gas Improvement Company, which
formed Welsbach, purchased the patent rights to
manufacture thorium-containing gas mantles in the
1880s from Dr. Carl Auer van Welsbach. The process
for manufacturing the Welsbach gas mantle used a
highly purified solution of 99 percent thoriurn nitrate
and 1 percent cerium nitrate as a "lighting fluid" in
distilled water. A fabric sock was then dipped into the
thorium solution to create the gas mantle. Thoriurn
caused the gas mantle to give off a very bright white
light when lit.
The commercial source of thorium and cerium is a
mineral known as monazite sand. Monazite sand
contains approximately 5-6 percent thorium oxide and
20-30 percent cerium oxide. Thorium was typically
extracted from the monazite ore by heating the ore in
a sulfuric acid solution. The thoritizin, and other rare
earth element’s would go into solution. while the
radium-228 remained in the tailings of insoluble
sulfates. Around 1915, Welsbach started using and
selling the radium-228 for its use in luminescent
paint. For a number of years, Welsbach was the
largest manufacturer of gas mantles in the world
making up to 250,000 mantles per day at its peak.
Welsbach also made gas room heaters, gas storage
water heaters, gas and electrical fixtures, electrical
refrigerators, plumbing supplies and lacquers.
Manufacturing operations at the Welsbach facility
Page 4
EPA Region 2 - February 1999 Page 5
began as early as 1882 and lasted until the 1940s. The
facility property covered an area of about 21 acres,
and consisted of about 20 buildings.
In 1948, the former Welsbach Facility in Gloucester
City was sold to the Randall Corporation, and leased
to the Radio Corporation of America, Victor Division.
In May 1976, the property was purchased by Holt
Hauling and Warehousing, Inc. (Holt), the current
owner of the property. Holt operates a cargo and
overseas shipping business.
Only one Welsbach era building, the Armstrong
Building, is still present on the property. There is no
information available on when the other
Welsbach-era buildings were demolished. The
Armstrong Building is not part of this Operable Unit.
Holt is performing an RI/FS of the Armstrong
Building under an Administrative Consent Order with
EPA.
The former gas mantle manufacturing facility in
Camden was owned and operated by the GGM
Company from 1912 to 1941. There is little
information available regarding activities at GGM,
other than it used and resold radium and thorium.
Between 1941 and 1978, there had been a total of
seven different private owners of the property. Based
on current information, none of these operations
involved radioactive materials. In January 1978, the
southern portion of the property was occupied by the
Dynamic Blending Company. In October 1988, the
northern portion of the property was purchased by
Ste-Lar Textiles. In 1992, NJDEP removed
radiologically contaminated fabrics from the facility,
relocated Ste-Lar, and sealed up the GGM building to
restrict access.
During the years that Welsbach and GGM operated,
ore tailings were used for fill at properties in the
vicinity of the facilities. It is also reported that
building debris from the former Welsbach Facility
may have been disposed of as fill in the area. In
addition, workers from the former Welsbach and
GGM Facilities may have brought contamination
home with them. These properties associated with
radiological waste from the Welsbach and GGM
Facilities are collectively termed Vicinity Properties
In 1991, NJDEP initiated a radiological investization
at more than 1,000 properties located throughout
Study Areas 1 through 5. At properties where
NJDEP determined that exposure levels were
unacceptable (or posed an immediate health risk ).
they performed interim remedial measures. These
measures included the installation of radon thoron
ventilation systems and placement of concrete or lead
sheeting to shield gamma radiation. In addition.
NJDEP restricted access to outdoor areas which
exceeded its action levels.
In 1998, EPA identified a 100 square foot area in a
Gloucester City Park, located in Study Area 5, that
had high levels of gamma radiation at the surface. In
December 1998. EPA performed a removal action to
reduce exposure to the high levels of gamma radiation
at the surface. EPA excavated the top three feet of
radiologically contaminated soil and replaced the
waste material with clean fill.
THE NATURE OF RADIONUCLIDES
A radionuclide is an element that spontaneously
changes, or “decays” into another element through
natural processes. Radionuclides are present in trace
amounts in all rocks and soils, and consist primarily
of elements of the uranium-238 and thorium-232
decay series. There are approximately 1,700 different
unstable atomic species, or radionuclides. These
include both naturally occurring and man-made
radionuclides.
The radionuclides of concern in the wastes which
originated at the former Welsbach and GGM
Facilities are members of the uranium and thorium.
decay series. There are 14 unique radionuclides in the
uranium decay series and 11 unique radionuclides in
the thorium decay series which precede the formation
of stable lead (Pb-206 or Pb-208). Alpha, beta, and
gamma radiation are emitted from the various
members of the two decay series. The primary
nuclides of concern are Thorium-232,
EPA Region 2 - February 1999 Page 6
Radium-226, and radon gas (Radon-222 and
Radon-220.)
Each radionuclide has its own unique characteristic
“fingerprint,” consisting of three parameters:
1. The radioactive half-life describes the
amount of time in which half of any given
number of atoms of a radionuclide will
decay.
2. The mode of decay refers to the type(s) of
particles or electromagnetic rays emitted
from the radionuclide as it decays. These
types include alpha and beta particles, and
gamma rays.
3. The amount of energy carried away from the
atom by the particles or rays is radionuclide
specific. It is the transfer of this energy to
living tissue which may cause biological
effects.
When radionuclides decay, they emit energy in the
form of radiation. The decaying radionuclide is often
called the “parent”, and the radionuclide produced is
called the “decay product”. A quantity of radioactive
material is measured by its rate of decay, expressed
by the unit Curie (Ci), which is equal to 2.22 x 1012
(2.22 trillion) disintegrating atoms per minute. A
more convenient unit for expressing environmental
radioactivity is the picoCurie (pCi), which is equal to
1 x 10-12 (one trillionth) Ci.
Radium-226 is a naturally occurring, radioactive,
metallic elernent formed from the decay of uranium.
In its decay, Radium-226 forms Radon-222 or radon
gas. Radon gas is colorless, odorless, radioactive and
inert; therefore, it can move easily through soil to the
ground surface or into houses. Within a matter of
days. the radon gas itself decays into a series of
radioactive decay products. While radon gas in the
outdoor air dissipates quickly, the concentration of
radon decay products in the indoor air can build up
over time. Exposure to the energy released by these
various decaying atoms can result in adverse health
effects. For radon decay products, a special unit,
called Working Level (WL) has been developed.
Working Level is defined as any combination of
short-lived radon decay products in 1 liter of air that
will result in the ultimate emission of 1.3 x 105 Mega-
electron Volts of potential alpha energy. This value is
approximately equal to the alpha energy released
from the decay of progeny in equilibrium with 100
pCi of Radon-222.
Thorium-232 is also a naturally occurring
radionuclide and is the initial radionuclide of the
thorium decay series. Its decay products include
radium-228 and Radon-220. Radon-220 is also
known as thoron. Thoron and its decay products have
extremely short half-lives that usually prevent them
from concentrating to any appreciable extent in indoor
air. However, if a significant source of thoron exists
within, beneath, or adjacent to a structure (such as the
thorium. and radium-228 found in Welsbach/GGM
site wastes), thoron decay products can reach
concentrations which create health risks.
REMEDIAL INVESTIGATION SUMMARY
In September 1997, EPA started an RI to characterize
the nature and extent of contamination at the
Welsbach Facility, General Gas Mantle Facility, and
20 of the radiologicaily contaminated properties
identified by NJDEP in the vicinity of Welsbach and
GGM. In order to develop a cleanup strategy for the
Site, the RI field investigations were divided into
three property categories, as follows:
· Former Welsbach Company Facility;
· Former General Gas Mantle Company
Facility;
· Vicinity Properties
The RI/FS report presents the results of field
investigations conducted to date at both Welsbach and
GGM Facilities and the 20 Vicinity Properties. In
future phases of the remediation, called operable
units, EPA will investigate potentially impacted
groundwater, surface water, and sediments.
EPA Region 2 - February 1999 Page 7
Property Investigations
EPA conducted both chemical and radiological
characterizations of the former Welsbach and GGM
Facilities to define the extent of contamination. EPA
also performed a radiological investigation on 20 of
the potentially contaminated Vicinity Properties
identified by NJDEP. Only 20 Vicinity Properties
were investigated during the RI so that EPA could
confirm the NJDEP data and expedite the
development of cleanup alternatives. EPA will
investigate the remaining potentially contaminated
properties identified by NJDEP. and other properties
suspected of being possibly contaminated during the
remedial design phase of this cleanup. EPA estimates
that about 600 properties will be studied in the design
phase to determine exactly which properties require
cleanup. This additional work may include sampling
for chemical analysis, where deemed appropriate
when considering past ownership and historic
information. Field activities conducted as part of the
RI included the following:
! Radon measurements
! Radon decay product Working Level
measurements
! Gamma radiation surface and one-meter
height exposure rate surveys
! Surface and subsurface soil sampling
! Downhole gamma radiation logging
! Total surface beta surveys and removable
surface alpha and beta sampling
! Structural materials sampling (in some
buildings)
Results of Field Investigations
Areas with elevated levels of radioactivity that
exceeded the radiological standards for human health
were identified during the remedial investigations.
The RI data support the following conclusions:
Former Welsbach Facility
! Most of the radiological contamination is
located in the area of a former Welsbach
building that was demolished in the 1970s.
This area is currently used for storage.
However, there are smaller areas of
contamination scattered throughout the
property. The soil in these areas is
contaminated with elevated concentrations of
the thorium and uranium decay series
radionuclides. Subsurface contamination on
the Welsbach facility averages about 11 feet
in depth. An estimated 27,200 cubic yards of
soil/buried debris have thorium and or
radium concentrations exceeding 5 pCi/g.
Radium and thorium concentrations in soil
ranged from background (about 1 pCi/g for
each) to as high as 455 pCi/g and 1.190
PCi/g, respectively.
! Surface gamma exposure rates associated
with the contaminated soils ranged from
background (less than 10 micro-Roentgen per
hour [µR/h]) to 780 µR/h. The highest
readings were associated with a large fill
area identified in the middle of the storage
area.
! Low levels of chemical contaminants were
identified at the former Welsbach Facility.
Contaminants of potential concern include
semi-volatile organic compounds and arsenic.
These contaminants may be indicative of
“Historic Fill”. If this is confirmed in the
remedial design, then there may be no need
to excavate this soil. Instead, it may be more
appropriate to cap these soils in place.
Former General Gas Mantle Facility
! Elevated concentrations of thorium and
uranium decay series radionuclides were
identified in soils on the former GGM
property. Contamination was generally
limited to the top six to eight feet, although
contamination in some areas of South Fourth
Street and the GGM Courtyard ranged from
12 to 16 feet in depth. An estimated 900
cubic yards of soil had thorium and/or
radium concentrations which exceeded 5
pCi/g.
EPA Region 2 - February 1999 Page 8
Radium and thorium concentrations in soil
ranged from background to as high as 172
pCi/g and 149 pCi/g, respectively.
! Surface gamma exposure rates associated
with the contaminated soils ranged from
background (less than 10 µR/h) to 380 µR/h.
Only localized areas of surface
contamination were identified outdoors.
! Most of the outdoor contamination is located
in the area of South Fourth Street. However,
some smaller areas of contamination were
identified in the alleyway behind the property
that extended onto some backyards of
neighboring residential properties.
! Elevated levels of surface contamination
were observed in many areas inside the
former GGM building. Levels as high as
2.33 microCi per meter square (µCi/m2 ) area
were observed.
! Indoor gamma exposure rates ranged from
background to 900 µR/h.
! An estimated 1,460 cubic yards of
contaminated structural materials in the
building itself were identified, with thorium
concentrations as high as 750 pCi/g.
! In the basement of the former GGM building,
radon decay product concentrations measured
1.7 WL, compared to an average background
level of 0.005 WL.
! Certain semi-volatile organic compounds and
metals were identified. These were; however,
at such low levels that they are not chemicals
of concern. These contaminants may be
indicative of “Historic Fill”. If this is
confirmed in the remedial design, then there
may be no need to excavate this soil. Instead,
it may be more appropriate to cap these soils
in place.
Vicinity Properties
EPA investigated 20 properties in Camden and
Gloucester City for radiological contamination as part
of the RI. EPA compared these data to information
collected from earlier NJDEP investigators and
determined that the data were comparable. These data
support the following conclusions:
! Some site properties have indoor radon gas
concentrations or soil radionuclide
concentrations which pose a long-term risk to
human health.
! Contaminated soil averaged about two to
three feet in depth on most residential
properties. On a few properties,
contamination extended to 10 feet in depth.
! Based on the comparison of EPA and
NJDEP data, approximately 50 properties
were identified as having contamination
above the cleanup levels. During the
remedial design phase. EPA will delineate
the extent of contamination on these
properties in order to design a cleanup plan
for each property.
! EPA identified approximately 600 properties
that are either adjacent to the known
contaminated properties or have gamma
exposure rates above background levels. In
the RI report, these properties are termed
“suspect properties.” During the remedial
design phase, EPA will investigate and
sample these properties to see if there is any
radiological contamination present. If
contamination above the cleanup objectives
is found, EPA will delineate the extent of this
contamination and design a cleanup plan for
these properties.
SUMMARY OF SITE RISK
A baseline risk assessment was conducted for the
former Welsbach Facility, the former GGM Facility,
and the Vicinity Properties utilizing analytical data
EPA Region 2 - February 1999 Page 9
obtained during the RI. The baseline risk assessment
estimates the human health risk which could result
from the contamination at a site if no remedial action
were taken.
Ecological risks, that is, the risk to aquatic and
terrestrial wildlife (plants and animals), were not
evaluated for this operable unit because the study
areas consisted primarily of residential and
commercial properties. An Ecological Risk
Assessment will be conducted in a future RI to
evaluate the potential for adverse effects to aquatic
and terrestrial wildlife (plants and animals) in
accordance with Ecological Risk Assessment
Guidance for Superfund, Process for Designing and
Conducting Ecological Risk Assessments (EPA 540-
R-97-006).
To evaluate human health risks, a four-step process
was used for assessing site-related risks for a
reasonable maximum exposure scenario. These steps
are: Hazard Identification - identified the
contaminants of concern at the site based on several
factors such as toxicity, frequency of occurrence, and
concentration;Exposure Assessment - estimated the
magnitude of actual and/or potential human
exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting
contaminated soil) by which humans are potentially
exposed; Toxicity Assessment - determined the types
of adverse health effects associated with exposures to
site contaminants, and the relationship between
magnitude of exposure (dose) and severity of adverse
effects (response); and Risk Characterization
summarized and combined outputs of the exposure
and toxicity assessments to provide a quantitative
(e.g., one-in-a-million excess cancer risk) assessment
of site-related risks.
For risk assessment purposes, individual contaminants
are typically separated into two categories of health
hazard depending on whether they exhibit
carcinogenic effects (causing cancer) or
noncarcinogenic effects (causing health effects other
than cancer.) Radionuclides (e.g., radium, thorium,
radon, thoron, and radon/thoron decay products) are
known carcinogens. Nonradiological chemical
contaminants (e.g.. PAHs and arsenic) may exhibit
both carcinogenic and noncarcinogenic health effects.
EPA's acceptable cancer risk range is 10-4
to 10-6
which can be interpreted to mean that an individual
may have a one in 10,000 to one in 1,000,000
increased chance of developing cancer because of
site-related exposure to a carcinogen.
Human health risks were estimated for both
radionuclides and chemicals of concern at the former
Welsbach and GGM Facilities, and for radionuclides
of concern at the Vicinity Properties. Building
materials and/or soil were the environmental media of
concern. Risks (that is, the probability of developing a
cancer because of exposure to radioactive materials)
were calculated based on “reasonable maximum
exposure” according to EPA guidance. This means
that risks are estimated as a result of exposure to
site-related carcinogens over a 30-year lifetime under
the specific exposure conditions at a site and other
exposure assumptions that result in an overall
exposure estimate that is conservative but within a
realistic range of exposure.
In assessing potential human health risks from
exposure to the radionuclides, several exposure
scenarios involving exposure to external gamma
radiation, ingestion of radioactive materials, and
inhalation of radioactive materials were evaluated.
Risks were estimated for several current and future
scenarios, and were compared to the risk from natural
background sources of radiation.
The maximum excess lifetime radiogenic (radiation
induced cell damage) cancer risks, that is, the risks
due solely to the presence of radioactive materials
above background levels, are 5.7 x 10-2 at the former
Welsbach Facility (to the current and future site
worker), 1.8 x 10-1 at the former GGM Facility (to a
hypothetical future site worker), and 1.8 x 10-2 to a
resident of a vicinity property. These radiogenic risks
exceed EPA's acceptable risk range. The cancer risk
from chemical exposures to the same populations at
the former Welsbach and GGM Facilities was also
EPA Region 2 - February 1999 Page 10
evaluated. The cancer risk did not exceed EPA's risk
range and; therefore, no additional remedial action is
necessary because of chemical contaminants.
To assess the potential for cumulative
noncarcinogenic efffects posed by multiple
contaminants, EPA has developed a hazard index
(HI). The HI is derived by adding the noncancer risks
for site chemicals with the same target organ or
mechanism of toxicity. When the HI exceeds 1.0.
there may be concern for adverse health effects due to
exposure to multiple chemicals.
For the Welsbach/GGM site, non-cancer health
effects were evaluated on1y at the former Welsbach
and GGM Facilities. The total HI for construction
worker exposure to the chemicals of concern in soil at
the former Welsbach Facility from ingestion, dermal
contact, and inhalation is equal to EPA's acceptable
level of 1.0. Ingestion of arsenic is the predominant
contributor to the risk estimate. The total HI for
construction worker exposure to the chemicals of
concern in soil at the GGM Facility from ingestion,
dermal contact, and inhalation is 3 x 10-2; this hazard
index is below EPA’s acceptable level of 1.0,
indicating that adverse, noncarcinogenic health effects
from such exposure are unlikely.
The following are the dominant radiological exposure
pathway risks for the various exposure scenarios
evaluated for the Welsbach/GGM site. At residential
properties and the former Welsbach Facility, the
majority of risk is from exposure to external gamma
radiation, or direct radiation. Occupants of the former
GGM Facility (current and future trespassers and
future site workers) are at risk primarily from
inhalation of thoron decay products. Future
construction worker risk is primarily due to direct
radiation, although inhalation of particulates
containing radioactive material also contributes a
significant portion of the risk.
This RI focused primarily on residential and
commercial properties, and sensitive species of plants
and animals are not likely to inhabit these portions of
the Site. However, sensitive species may be present
in Study Areas 3 and 4 around Newton Creek. Any
ecological risk characterization for these areas will be
conducted a future operable unit.
Actual or threatened releases of hazardous substances
from the Site, if not addressed by the preferred
alternatives, or one of the other active measures
considered, may present a current or potential threat
to public health, welfare, or the environment
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to
protect human health and the environment. These
objectives are based on available information and
standards such as applicable or relevant, and
appropriate requirements (ARARs) and risk based-
based levels established in the risk assessment. EPA’s
remedial action objectives for the Welsbach General
Gas Mantle Contamination site are to take measures
that will prevent or mitigate further release of
radioactive contaminated materials to the surrounding
environment and to eliminate or minimize the risk to
human health and the environment. The sources of
radiation include both contaminated soil and
structural materials. Direct radiation, inhalation,
ingestion of plants and soil are potential pathways.
EPA proposes the following remedial action
objectives for the Site:
! Eliminate or minimize the potential for
humans to ingest, come into dermal contact
with, or inhale particulates of radioactive
constituents or to be exposed to external
gamma radiation in order to achieve the level
of protection required by the NCP ( 10-4
to
10-6
risk range).
! Prevent long-term exposure to thorium- and
radium-contaminated material (e.g., soil)
with concentrations greater than 5 pCi/g.
EPA Region 2 - February 1999 Page 11
! Prevent exposure to indoor concentrations of
radon gas and radon decay products greater
than 4 pCi/L and 0.02 WL1 respectively.
! Prevent direct contact with building surfaces
exhibiting total surface thoriurn
contamination exceeding 0.026 µC/m2 above
background.
! Prevent migration of thorium-contaminated
material that could result in the exposures
described above.
! Comply with chemical-, location-, and action
specific ARARs.
EPA, in the Office of Solid Waste and Emergency
Response (OSWER) Directives No. 9200.4-18, and
No. 9200.4-25, developed health guidelines for
limiting exposure to ionizing radiation from radium
and other sources. To further ensure protectiveness,
those health guidelines can be supplemented by
selecting response actions which reduce exposures
resulting from ionizing radiation to levels that are As
Low As Reasonably Achievable (ALARA) taking
into consideration technical, economic and social
factors.
EPA recommends that indoor radon concentrations in
homes should not exceed 4 pCi per liter of air
(pCi/L). In 40 CFR 192, “Standards for Cleanup of
Land and Buildings Contaminated with Residual
Radioactive Materials From Inactive Uranium
Processing Sites ,” EPA enacted standards for
limiting exposure to radon decay products and gamma
radiation. While this regulation is not directly
applicable to this site because the Welsbach and
GGM Facilities are not inactive uranium processing
sites. EPA considers the cleanup standards in 40 CFR
192 to be relevant and appropriate for the Site. The
relevant portions of an CFR192 include limiting
exposure to radon decay products to levels less than
0.02 WL and radium concentrations (implemented as
the sum of Ra-226 and Ra-228) to 5 pCi/gram. EPA,
in Directive No 9200.4-25, states that whenever the 5
pCi/g radium soil cleanup standard is determined to
be relevant and appropriate at a CERCLA site which
contains both radium and thorium in the waste, the 5
pCi/g cleanup standard also applies to thorium
(implemented as the sum of Th-230 and Th-232).
In achieving the remedial action objectives for the
Site, EPA would rely on the ALARA principles used
at other radiological contaminated sites in New
Jersey. Applying ALARA principles means taking
additional measures during implementation of the
remedial action, beyond those required to meet a
specified cleanup goal, to assure protectiveness. An
ALARA approach is being used because of the long-
lived nature of radionuclides, the difficulty in
eliminating routes of exposure, limitations of the
analytical equipment to detect radionuclides, and site
specific factors which may make it necessary to
remove material at levels below 5 pCi/g to achieve
adequate public health protection.
EPA's experience at the other radiological
contaminated sites in New Jersey has shown that the
remedial action objectives noted above can be
achieved by incorporating ALARA principles.
Therefore, by using similar remedial action
objectives, the Welsbach/GGM Site would pose no
unacceptable risk for residential uses after cleanup,
and would result in a cleanup that is protective under
CERCLA.
To meet the remedial action objectives outlined
above, EPA plans to excavate radiologically
contaminated soils and waste materials, and dispose
of them off-site. Excavation of soils will eliminate the
threat of physical migration of contaminants, as well
as potential exposure through various pathways
(ingestion, inhalation, dermal contact, external
gamma radiation, etc.). Contaminated soils will be
1Exposure to 4 Pci/l of air for radon
corresponds to an approximate annual average
exposure of 0.02 WL for radon decay product.
2References for ALARA principles -
“Radiation Protection Guidance to Federal Agencies
for Occupational Exposure”, 1987, Federal Register
52, No. 17, 2822; and “Federal Guidance Report No.
11". September 1988, EPA-520\1-88-020.
EPA Region 2 - February 1999 Page 12
shipped off-site to a licensed commercial facility for
permanent long-term management.
The planned response action for buildings,
specifically at GGM, is decontamination, demolition,
and off-site disposal of contaminated materials to
reduce exposures within acceptable levels for future
use of the property.
Any potential ecological risks and adverse impacts
from existing radiological contamination on the
properties addressed under this action will be
minimized because the contaminated soils will be
removed and backfilled with clean soil. There are also
limited habitats for ecological receptors at the
properties addressed under this action. Furthermore,
by removing the radiologically contaminated waste,
the surface water and sheet flow pathways will be
eliminated as routes of exposure.
Wetlands are not present at both the former Welsbach
and GGM facilities. However, wetlands are present in
Areas 3 and 5, along the South Branch of Newton
Creek. During the remedial design. EPA will
delineate wetland areas which are actually or
potentially impacted by contamination or remedial
activities.
SCOPE AND ROLE OF ACTION
The goal of the proposed remedial action is to
minimize or eliminate the potential health hazard
posed by all radiologically contaminated soils and
structural materials at the Site. Because of the large
geographical area associated with this project, not all
potentially contaminated areas were evaluated during
the RI. EPA will investigate additional areas as part
of the remedial design to delineate the full extent of
contamination. The Armstrong Building, ground
water, surface water, and sediments, will be
addressed in future Operable Units.
SUMMARY OF ALTERNATIVES
CERCLA requires that each remedy be protective of
human health and the environment, be cost effective, .
comply with other statutory laws, and utilize
permanent solutions and alternative treatment
technologies and resource recovery alternatives to the
maximum extent practicable. In addition. the statute
includes a preference for the use of treatment as a
principal element for the reduction of toxicity,
mobility, or volume of hazardous substances.
CERCLA also requires that if a remedial action is
selected that results in hazardous substances,
pollutants, or contaminants remaining at a site above
levels that allow for unlimited use and unrestricted
exposure. EPA must review the action no less than
every five years after the start of the action.
This Proposed Plan evaluates the Remedial
Alternatives for addressing the contamination
associated with the Site. Cleanup alternatives were
evaluated for the Vicinity Properties, the former
Welsbach Facility and the General Gas Mantle
Facility. The alternatives include: No Action,
Engineering Controls, and Excavation and Off-Site
Disposal.
Vicinity Properties
The Vicinity Properties include residential,
commercial, and public properties where radiological
contamination was identified in soils situated outdoors
and/or beneath buildings, and properties with indoor
air contamination.
Vicinity Properties Alternative 1 (V-1) -
No Action
Estimated Capital Cost: $0
Estimated Annual Operation and Maintenance
(O&M) Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period none
EPA Region 2 - February 1999 Page 13
A “No Action” alternative is evaluated for every
Superfund site to establish a baseline for comparison
with remedial alternatives. Under this alternative, no
remedial action would be performed at the Site.
Previous interim remedial actions implemented by
NJDEP would not be maintained. Current
institutional controls including fencing would not be
maintained. Because hazardous substances would
remain at the Vicinity Properties above acceptable
levels, five-year reviews would be required.
Vicinity Properties Alternative 2 (V-2) -
Engineering Controls
Estimated Capital Cost: $900,000
Estimated Annual O&M Cost: $99,000
Estimated Present Worth: $1,810,000
Estimated Implementation Period 3-5 years
Under this alternative, outdoor gamma shielding
would be placed at each property which has
contaminated soil. The gamma shield would consist of
a geotextile liner, fill material, 6-inches topsoil, and
vegetation (seeding or sod). The thickness of the fill
material will vary from 6 inches to 42 inches, based
on the shielding requirements of each property . A
total of approximately 75,000 square feet of coverage
would be installed.
In addition, indoor gamma shielding would be placed
inside buildings exhibiting unacceptable exposure
levels. The shielding would consist of concrete or
steel as needed. The concrete would range from 4
inches to 7 inches thick, and about 1.5 inches of steel
sheeting would be placed on wall surfaces.
Approximately 2.000 square feet of concrete and 60
square feet of steel coverage would be installed.
Finally, if any property buildings exhibit elevated
radon/thoron levels, a sub-slab ventilation radon
mitigation system would be installed.
Institutional controls, such as deed restrictions, would
be required to ensure the protectiveness of the
remedy. Because hazardous substances would remain
at the Vicinity Properties above acceptable levels,
five-year reviews would be required. The estimated
time to design and construct the remedy is from three
to five years.
Vicinity Properties Alternative 3 (V-3) -
Excavation and Off-Site Disposal
Estimated Capital Cost: $13,408,561
Estimated Annual O&M Cost: $0
Estimated Present Worth: $13,408,560
Estimated Implementation Period 3-5 years
Under this alternative, soil on the Vicinity Properties
contaminated above 5 pCi/g greater than backgound
would be excavated and disposed of at a licensed
off-site facility. Radiologically contaminated building
demolition debris would also be excavated and
disposed of off-site. EPA will replace these areas with
clean fill. The total volume of soils requiring, disposal
at the Vicinity Properties is estimated to be 11,000
cubic yards. The total volume of buried demolition
debris at the Vicinity Properties is estimated to be
2,250 cubic yards.
Where contamination is suspected underneath
buildings, this alternative includes removing concrete
flooring and underpinning the buildings. After the
removal of contaminated soil, a new concrete floor
would be constructed. Approximately 21 properties
would require concrete floor removal and
replacement. Underpinning is estimated to be required
at one property.
The estimated time to design and constrict the remedy
is from three to five years. Provisions would need to
be made for the temporary relocation of residents and
businesses during construction of this alternative.
During excavation, short-term provisions to prevent
dust generation and protect workers would be
required.
Welsbach Facility
The former Welsbach Facility is presently owned and
operated by Holt, as a cargo storage and oversea
shipping operation. Radiological contamination on the
property is present in the outdoor portion of the
EPA Region 2 - February 1999 Page 14
storage area. Most of the contamination is located in a
single contiguous area, with smaller elevated areas
scattered across the property. The Armstrong Building
is not included in the remediation alternatives. Holt is
preparing an RI/FS that will address the remedial
alternatives for that building.
Welsbach Alternative 1 (W-1) - No Action
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period none
Under this alternative, no remedial action would be
performed at the Site. Current institutional controls
including fencing would not be maintained. Because
hazardous substances would remain on the property
above acceptable levels, five-year reviews would be
required.
Welsbach Alternative 2 (W-2) - Engineering
Controls
Estimated Capital Cost: $5,690,000
Estimated Annual O&M Cost: $44,000
Estimated Present Worth: $6,180,000
Estimated Implementation Period 3-5 years
Under this alternative outdoor gamma shielding would
be placed in the areas of the former Welsbach
property that have soil contamination. The gamma
shield would consist of steel covered by asphalt. The
steel would range in thickness from 1 to 5 inches,
with a 4-inch asphalt cover. Approximately 53,000
square feet of area would be covered by the steel
shielding.
Institutional controls, such as deed restrictions, would
be required to ensure the protectiveness of the
remedy. Because hazardous substances would remain
on the property above acceptable levels, five-year
reviews would be required. The estimated time to
design and construct the remedy is from three to five
years.
Welsbach Alternative 3 (W-3) - Excavation and
Off-Site Disposal
Estimated Capital Cost: $18,503,560
Estimated Annual O&M Cost: $0
Estimated Present Worth: $18,503,560
Estimated Implementation Period 3-5 years
Under this alternative, all soil contamination at the
Welsbach site above 5 pCi/g greater than background
would be excavated and disposed of at a licensed
off-site facility. Contaminated building demolition
debris which is currently buried on-site because of
former demolition activities would also be excavated
and disposed of at an appropriate off-site facility.
EPA will replace these areas with clean fill. The
volume of soils above the cleanup standard is
estimated to be 19,400 cubic yards. The volume of
buried demolition debris requiring disposal is
estimated to be 4,400 cubic yards. During excavation,
short-term provisions to prevent dust generation and
protect workers would be required.
Subsurface contamination on the Welsbach Facility
averages about 11 feet in depth. In the area of the
deepest contamination, underground tunnels dating
from around the of the century are present. These
tunnels extend down to about 10 to 12 feet in depth.
These tunnels can act as conduits to carry radon gas
to nearby residential properties. As a result, the
remedy includes excavation of the contamination to
these depths to prevent any future radon migration
problems and to protect future workers from elevated
gamma radiation levels. The estimated time to design
and construct the remedy is from three to five years.
General Gas Mantle Facility
The GGM building is presently inactive and in a
dilapidated state. The building has been boarded shut
and fenced in by NJDEP. Radiological contamination
on the property exists both inside and outside the
building. Inside the building, contamination is present
in building materials and in ambient air. Outside the
GGM Facility, soil contamination is primarily located
EPA Region 2 - February 1999 Page 15
to the immediate southwest of the GGM building
extending into South Fourth Street. Two smaller
areas of contaminated soils are situated to the
northeast of the building and in the alleyway
adjacent to the eastern side of the building.
General Gas Mantle Alternative 1 (G-1) - No
Action
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period none
Under this alternative, no remedial action would be
performed at the Site. Previous interim remedial
actions would not be maintained. Current
institutional controls including fencing would not
be maintained. Because hazardous substances
would remain on the property above acceptable
levels, five-year reviews would be required.
General Gas Mantle Alternative 2 (G-2)-
Engineering Controls
Estimated Capital Cost: $122,000
Estimated Annual O&M Cost: $23,000
Estimated Present Worth: $381,000
Estimated Implementation Period 2-3 years
Under this alternative, outdoor gamma shielding
would be placed at the former General Gas Mantle
property. The gamma shield would consist of either
a soil shield or a concrete shield. The soil shield
would include a geotextile liner, fill material,
six-inches topsoil, and vegetation (seeding or sod).
The thickness of the fill material will range from
six to 24 inches. The thickness of the concrete will
range from six to eight inches. Approximately
5,000 square feet of coverage would be required.
Areas of contamination extending into South
Fourth Street would be covered with an additional
4 inches of asphalt.
Also under this alternative, significant institutional
controls, including permanently boarding shut the
building and restricting access to the building
forever would be required. Because hazardous
substances would remain on the property above
acceptable levels, five-year reviews would be
required. The estimated time to design and
construct the remedy is from two to three years.
General Gas Mantle Alternative 3 - Excavation
and Off-Site Disposal of Soil and
Building/Demolition Debris
G-3A: Demolition and Disposal
Estimated Capital Cost: $2,309,560
Estimated Annual O&M Cost: $0
Estimated Present Worth: $2,309,560
Estimated Implementation Period 1-2 years
Under this alternative for the GGM property, soil
contaminated above 5 pCi/g greater than
background would be excavated and disposed of at
a licensed off-site facility. Contaminated building
demolition debris which is currently buried on-site
because of former demolition activities would also
be excavated and disposed of off-site. EPA will
replace these area with clean fill. The volume of
soil and buried demolition debris at GGM is
estimated to be 650 cubic yards and 60 cubic
yards, respectively.
Under this alternative, the former General Gas
Mantl building would be demolished, and the
demolition debris would be disposed of with the
contaminated soil. The volume of building
materials to be demolished is estimated to be 1,400
cubic yards. During excavation and demolition,
short-term provisions to prevent dust generation
and protect workers would be required. The
estimated time to design and construct the remedy
is from one to two years.
G-3B: Decontamination, Demolition and
Disposa
Estimated Capital Cost: $1,736,560
Estimated Annual O&M Cost: $0
Estimated Present Worth: $1,736,560
Estimated Implementation Period 1-2 years
EPA Region 2 - February 1999 Page 16
EPA Region 2 - February 1999 Page 17
would be required to ensure that these alternatives
are protective.
For the Excavation and Off-Site Disposal
Alternatives (W-3, V-3, G-3), all radiological
contamination above cleanup standards would be
removed and disposed of off-site in a licensed
disposal facility. Institutional controls would not be
necessary. All unacceptable risks to human health
and the environment would be eliminated by the
excavation and off-site disposal of the radiologically
contaminated waste.
Compliance with Applicable or Relevant, and
Appropriate Requirements
Actions taken at any Superfund site must meet all
ARARs of federal and state law, or provide grounds
for invoking a waiver of these requirements. There
are three types of ARARs: action-specific,
chemical-specific, and location-specific.
Action-specific ARARs are technology or
activity-specific requirements or limitations related
to various activities. Chemical-specific ARARs are
usually numerical values which establish the amount
or concentration of a chemical that may be found in,
or discharged to, the ambient environment.
Location-specific requirements are restrictions
placed on the concentrations of hazardous
substances or the conduct of activities solely
because they occur in a special location.
For the Welsbach/GGM site, no requirements are
applicable for the cleanup of the radiological
contamination. However, as discussed earlier,
portions of the federal regulations governing the
cleanup of uranium mill tailings from inactive
uranium processing sites, at 40 CFR 192, have been
determined to be relevant and appropriate. These
provide the radon decay products standard of 0.02
WL and soil cleanup criteria of 5 pCi/g. In addition,
waste materials produced at the former Welsbach
Facility would be considered “by-product” material
as defined by Section 11 (e)(2) of the U.S. Atomic
Energy Act (AEA).3 Since Welsbach processed
monazite ores to extract thorium. EPA has
determined Section II(e)(2) of the AEA to be
relevant and appropriate. Because the waste
materials from the Welsbach Facility and its
operations are an AEA Section II(e)(2) waste
material, they must he disposed of at a licensed
facility in accordance with AEA requirements.
The Excavation and Off-Site Disposal Alternatives
(W-3, V-3, G-3) would comply with all ARARs.
All contamination above the 40 CFR 192 cleanup
standards would be excavated and sent off-site for
disposal. The Engineering Controls Alternatives
(W2, V-2, G-2) would comply with all ARARs
that limit exposure to gamma radiation and radon.
However, the Engineering Controls Alternatives
would not comply with 40 CFR 192, because the
contaminated material would remain at the Site.
Long-Term Effectiveness and Permanence
The Excavation and Off-Site Disposal Alternatives
(W-3, V-3, G-3 ) are all effective and permanent.
They are considered a final remedial action. The
contaminated material would be removed from the
Site and stored in a controlled, licensed facility.
The long-term effectiveness of the Engineering
Controls Alternatives W-2 and V-2 would be
uncertain. Contaminated material would remain in
place, and the engineering controls would require
deed restrictions and long-term monitoring. In
addition, the engineering controls would have to be
maintained forever because the half-life of thorium
is 14 billion years.
Alternative G-2 (Engineering Controls for General
Gas Mantle) would not be effective in the
long-term
3 “By-product” material means (1) any radioactive material(except special nuclear material) yielded in or made radioactive byexposure to the radiation incident to the process of producing orutilizing special nuclear material, and (2) the tailings or wastesproduced by the extraction or concentration of uranium or thorium fromany ore processed primarily for its source material content.
EPA Region 2 - February 1999 Page 18
because of the dilapidated nature of the building,
even if the building were completely sealed.
Reduction of Toxicity, Mobility, or Volume Through
Treatment
No treatment technology is known today that can
substantially reduce the toxicity, mobility, or volume
of radioactive materials found at the Site, and meet
the 40 CFR 192 cleanup standards. The total amount
of radioactivity cannot be altered or destroyed, as is
often possible with chemical contaminants.
Therefore. none of the remedial alternatives fully
satisfy this evaluation criteria.
However, the Excavation and Off-Site Disposal
Alternatives (W-3, V-3, G-3) would lead to some
reduction in the mobility of the material because
radioactive contaminated materials would be
contained in a secure landfill cell. Alternative G-3
with Option B (the General Gas Mantle
Decontamination and Demolition Alternative) would
reduce the volume of contaminated building debris to
be disposed of off-site by pressure washing the
radioactive contamination off the floors and walls
before demolition. The contaminants would be
concentrated in the filtrate after pressure washing.
Only this filtrate would have to be disposed of in a
licensed facility.
Short-Term Effectiveness
Both the Engineering Control Alternatives (W-2, V-
2, G-2) and the Excavation and Off-Site Disposal
Alternatives (W-3, V-3, G-3) provide effective short-
term protection and become effective as they are
implemented at individual properties. The estimated
time to design and construct the remedial alternatives
for the former Welsbach Facility (Alternatives W-2
and W-3) and the Vicinity Properties (Alternatives
V-2 and V-3) is from three to five years. For the
former GGM Facility, the estimated time to design
and construct the Engineering Control Alternative
G-2 is from two to three years, and for the Off-Site
Disposal Alternative G-3 from one to two years.
The Engineering Control Alternatives involve less
intrusive activities, and pose less of a threat to
workers and the surrounding community than the
Excavation and Off-Site Disposal Alternatives
However, both the Engineering Control Alternatives
and the Excavation and Off-Site Disposal
Alternatives involve intrusive activities, including,
in some cases temporary relocation of residents.
The Excavation and Off-Site Disposal Alternatives
have a greater potential adverse impact in the short
term because of the excavation of radiologically-
contaminated soil. For future workers, this could
lead to increased short-term exposure to radon,
gamma radiation, and soil radionuclides. Dust
suppression techniques and or other measures
would be required to minimize the impacts of this
alternative. However, under Alternative V-2
(Engineering Controls for the Vicinity Properties),
there would be some increased short-term risk to
workers during the installation of the radon
mitigation systems. This is due to the need to
excavate under the foundation of homes that require
radon mitigation.
Implementability
The Excavation and Disposal Alternatives (W-3,
V-3, G-3) are readily implementable. Similar
activities have been utilized at other radiologically-
contaminated sites around the country. There is an
available off-site disposal facility, which is
accessible by both truck and rail. However, the
continued availability of this off-site disposal
facility is required for implementation of these
alternatives.
Implementation of the Engineering Controls
Alternatives V-2 and G-2 may pose some
difficulties. Under Alternative V-2 (for the Vicinity
Properties), there may be some difficulty in getting
the consent of all of the property owners to restrict
future work on their properties. EPA would have to
reach agreements with individual property owners
to file Declarations of Environmental Restrictions
(i.e., deed restrictions) on their properties. For
Alternative G-2 (for General Gas Mantle), it would
be difficult to
EPA Region 2 - February 1999 Page 19
keep the building permanently sealed from
trespassers.
Cost
Alternative V-2 includes construction costs of
$900,000 to implement engineering control
measures at the Vicinity Properties. Annual O&M
costs are estimated to be $99,000. The present
worth cost of Alternative V-2 is $1,810,000, with
O&M costs assumed for 30 years. Alternative W-2
includes construction costs of $5,690,000 to
implement engineering control measures at the
former Welsbach Facility. Annual O&M costs are
estimated to be $44,000. The present worth cost of
Alternative W-2 is $6,180,000, with O&M costs
assumed for 30 years. Alternative G-2 includes
construction costs of $122,000 to implement
engineering controls at the General Gas Mantle
Facility. Annual O&M costs are estimated to be
$23,000. The present worth cost of Alternative G-2
is $381,000, with O&M costs assumed for 30
years. The radionuclides in question have half-lives
far greater than 30 years, so any of the Engineering
Controls remedies must be maintained effectively
forever.
Alternative V-3 includes construction costs of
$13,408,560 to excavate the radiologically-
contaminated soil at the Vicinity Properties and
dispose of the waste at an off-site disposal facility.
Alternative W-3 includes construction costs of
$18,503,560 to excavate the radiologically-
contaminated soil at the former Welsbach Facility
and dispose of the waste at an off-site disposal
facility. Alternative G-3 - Option A involves
construction costs of $2,309,560, and includes
demolishing the General Gas Mantle building and
disposal of all the building debris at an off-site
disposal facility Alternative G-3 - Option B
involves construction costs of $1,736,560, and
includes decontaminating the General Gas Mantle
building before its demolition. There are no O&M
costs associated with the Excavation and Off-Site
Disposal Alternatives (W-3, V-3, G-3 Options A
and B).
State Acceptance
The State of New Jersey is currently evaluating the
Proposed Plan.
Community Acceptance
Community acceptance of the preferred alternatives
will be evaluated after the public comment period
ends and will be described in the Record of
Decision for the Site.
PREFERRED ALTERNATIVE
Based on the information available to evaluate the
remedial alternatives against the nine criteria. EPA
recommends the Excavation and Off-Site Disposal
Alternatives (V-3, W-3, and G-3 with Option B) as
the preferred alternatives for the cleanup of the
contaminated soil and building materials at the
Site.
Rationale for the Preferred Alternatives
For each of the three property types, EPA’s
preferred alternative is the excavation and off-site
disposal alternative. Alternatives V-3, W-3, and
G-3 with Option B are the most protective
alternatives.
The radioactive half-life of thorium-232, the
primary contaminant of concern, is 14 billion
years. Remedies that would isolate wastes
containing thorium and the uranium series
radionuclides permanently from the public and the
environment are preferable.
Alternatives V-3, W-3, and G-3 result in a
permanent solution to the radioactive
contamination. The longevity of these chemicals of
concern (thousands to billions of years) favors
excavation which permanently removes the
contaminants from their current uncontrolled
locations. Commercial disposal at a licensed
facility with an appropriate closure plan will ensure
that these radiological wastes are permanently
isolated from human and ecological receptors. The
Excavation and Off-Site Disposal Alternatives are
considered implementable and will
EPA Region 2 - February 1999 Page 20
result in a remedy that is highly effective in the
long-term. These remedies are also consistent with
the remedial approach taken at all other
radiologically-contaminated sites in New Jersey.
Alternatives V-3, W-3, and G-3 provide greater
long-term effectiveness because all soils with
radioactivity greater than 5 pCi/g are disposed of in
a licensed radiological waste disposal facility. The
technology and equipment to perform the remedial
action are readily available. Implementation of
Alternatives V3, W-3, and G-3 would allow for
unrestricted future use of all affected properties.
The Engineering Controls Alternatives (V-2, W-2,
and G-2) would require deed restrictions and
long-term monitoring essentially forever because of
the extremely long half-lives of the radiological
contaminants. Thus, EPA believes excavation and
off-site disposal of the radiological contamination
represents the most viable cleanup alternative.
The preferred alternatives will provide the best
balance of tradeoffs among alternatives with
respect to the evaluating criteria. EPA believes that
the preferred alternatives will be protective of
human health and the environment, will be cost
effective, and will utilize permanent solutions and
alternative treatment technologies or resource
recovery technologies to the maximum extent
practicable.
NEXT STEPS
After EPA has presented the preferred alternative
at the public meeting and has received any
comments and questions during the public comment
period. EPA will summarize the comments and
provide its responses in a document called the
“Responsiveness Summary.” The Responsiveness
Summary will be appended to the Record of
Decision, which will describe the final alternative
selected by EPA and provide EPA's rationale for
that selection.
EPA Region 2 - February 1999 Page 21
MAILING LISTMAILING LISTADDITIONSADDITIONS
If you know of someone who is not receiving
information and would like to be placed on the
mailing list for the Welsbach/General Gas Mantle Contamination
Site, call Ms. Natalie Loney at (212) 637-3639, e-mail her at
[email protected], or fill out and mail this
form to:
Ms. Natalie Loney
Community Relations Coordinator
US. Environmental Protection Agency
290 Broadway, 26th Floor
New York NY 10007-1866
Name
Address
Telephone
Affiliation
Superfund Fact Sheet
Welsbach/General Gas Mantle Contamination Site
Gloucester City/Camden, New Jersey February 1999
INTRODUCTION
This summary highlights the U.S. Environmental
Protection Agency’s (EPA’s) Proposed Plan for the
cleanup of contaminated soils and building materials
at the Welsbach/General Gas Mantle
(Welsbach/GGM) Superfund site in Camden County,
New Jersey.
Investigations at the Welsbach/GGM site have shown
that some commercial, residential, and public
properties located in the Camden and Gloucester City
area contain soil contaminated to varying degrees with
thorium, radium, and uranium.
These contaminants are radioactive and associated
with waste materials generated in the manufacturing
activities that took place at the former Welsbach and
General Gas Mantle facilities. Both facilities used
radioactive elements, specifically thonum, in the
production of gas mantles, were used for lighting
purposes in the late 19th and early 20th centuries.
Radium. uranium and thorium are associated with
mantle production process.
Radioactive elements such as thorium, radium or
uranium are unstable and as a result release energy.
Thorium releases energy in the form of alpha particles,
beta particles or gamma radiation. This radioactive
decay also forms radon gas.
Radon gas is odorless, colorless and tasteless and can
be harmful if people are exposed to it over many years.
Gamma radiation also may pose health problems to
people who come in contact with the wastes over long
periods of time.
WELSBACH/GENERAL GAS MANTLE SITE
The Welsbach/GGM site is comprised of properties
within the following six study areas:
Study Area One: a mixed industrial, commercial,
and residential zoned section of Camden which
includes the former GGM facility and residential and
commercial properties which surround the facility.
Study Area Two: an industrial zoned property in
Gloucester City along the Delaware River, formerly
occupied by the Welsbach Corporation and a
residential area to the immediate east.
Study Area Three: residential and recreational
properties in Gloucester City, including the Johnson
Boulevard Lana Preserve.
Study Area Four: residential properties in the
Fairview section of Camden.
Study Area Five: residential properties, vacant and
properties, and two municipal parks near Temple
Avenue and the South Branch of Newton Creek in
Gloucester City.
Study Area Six: vacant lots in a residential zoned
area of Gloucester City.
REMEDIAL INVESTIGATION AND FEASIBILITY
STUDY
in 1997 EPA began a remedial investigation and
feasibility study (RI/FS) to determine the source and
extent of radiological contamination in the Camden and
Gloucester City area and to evaluate cleanup alternatives.
The areas investigated during the RI/FS included the
former Welsbach facility, the former GGM facility, and 20
of the radiologically contaminated properties identified
during earlier investigations conducted by the New Jersey
Department of Environmental Protection (NJDEP). The
findings of the remedial investigation were then used to
prepare a feasibility study, which evaluates cleanup
alternatives.
THE PROPOSED PLAN
In addition to the RI/FS, EPA has prepared a Proposed
Plan for the Welsbach/GGM site which identifies EPA's
preferred cleanup alternatives for the radiologically
contaminated properties. The alternatives which were
evaluated include: No Action; Installation of
Engineering Controls; and Excavation and Off-Site
Disposal of Contaminated Materials.
EPA's preferred alternative is Excavation and Off-site
Disposal of Contaminated Materials. This alternative calls
for the removal and off-site disposal of
radioactively-contaminated soil. The excavated areas will
be backfilled with clean soil. Where necessary,
contaminated building material will be removed and
replaced with clean material. Removal of contaminated of
soils and building materials will eliminate potential
gamma radiation and radon exposure through various
pathways (ingestion, inhalation, dermal contact, etc.).
The planned response action for the former GGM
building, is decontamination, demolition, and off-site
disposal of contaminated materials. All contaminated
material will be taken to an approved off-site disposal
facility.
The estimated volumes of contaminated material from the
site properties are:
! Vicinity Properties:
soil - 11,000 cubic yards;
demolition debris - 2,250 cubic yards;
! Former Welsbach Facility:
soil - 19,400 cubic yards;
demolition debris - 4,400 cubic yards;
! Former GGM Facility:
soil - 650 cubic yards;
demolition debris - 60 cubic yards;
building materials - 450 cubic yards.
The cost of the proposed remedial action is estimated to be
$13,408,560, $18,503,560, and $1,979,560 for the
Vicinity Properties. former Welsbach facility, and former
GGM facility, respectively.
While some of the activities proposed for site cleanup may
be disruptive to individual homeowners or the community.
EPA will work with affected residents and the community
to ensure a safe and quick cleanup of the site.
EPA relies on public input to ensure that the concerns of
the community are considered in selecting an effective
remedy for each Superfund site. To this end, EPA has
made the RI/FS report. Proposed Plan, and supporting
documentation available to the public for a public
comment period from February 1, 1999, to March 3,
1999. EPA considers all public comments before selecting
a final cleanup plan. For more information please contact:
Natalie Loney, Community Relations Coordinator at (212)
637-3639 or Rick Robinson, Project Manager at (212)
637-4371.
The RI/FS report which presents the results of field
investigations conducted to date at these properties has
been completed. Copies of the RI/FS report. Proposed
Plan, and supporting documentation are available at EPA's
offices at:
290 Broadway, 18th Floor
New York, NY
10007-1866
(212) 637-4308
and at the following repositories:
City of Camden Main Library
418 Federal Street
Camden, NJ 08103
(609) 757-7650
Hynes Center
1855 South 4th Street
Camden, NJ 80104
(609) 966-9617
Gloucester City Public Library
Monmouth and Hudson Streets
Gloucester City, NJ 08030
(609) 456-4181
SUMMARY
The Proposed Plan presents EPA's preferred remedy for the
cleanup of contaminated properties which are part of the
Welsbach/GGM site. EPA proposes to excavate
contaminated soil and waste materials; decontaminate (as
appropriate), demolish, and remove contaminated debris
and building material: dispose of the contaminated soils
and waste materials in a licensed off-site disposal facility;
and restore the affected properties with clean fill. The
proposed remedy would provide a permanent cleanup
response and would be protective of human health and the
environment.
Appendix B
Public Notices
Appendix C
Transcripts of Public Meetings
D E G N A N & B A T E M A N, I N C.(609) 547-2565
1
2
U.S. Environmental Protection Agency’s (EPA's)3
Proposed Plan for Cleanup of Superfund Sites4
Public Hearing5
6
7
8
February 23, 19989
10
Public Meeting of the U.S. Environmental11
Protection Agency (EPA) held at the Pine Grove Fire12
Station #2, Gloucester City, New Jersey, before13
Linda A. Burns, Shorthand Reporter and Notary Public14
of the state of New Jersey, on the above date,15
commencing at 7:00 p.m.16
17
18
19
20
21
22
23
24
2
D E G N A N & B A T E M A N, I N C.(609) 547-2565
EPA Public Meeting - 2/23/99 3
D E G A N & B A T E M A N, I N C.
(609) 547-2565
MS. CERVANTES-GROSS: I just wanted1
to start by thanking all of you for coming2
here tonight to talk with us about the3
Welsbach/General Gas Mantle Superfund site4
and post cleanup. We will be talking with5
you about all of the cleanup here and will6
be giving you different information about7
the study that was done and the8
alternatives that we have looked at as far9
as what we are proposing.10
Just to introduce people who are here11
tonight from EPA and who are involved in12
the cleanup, we have Rick Robinson who is13
the project manager for EPA for this site.14
Pat Evangelista is the team leader for us15
at EPA and oversees all of the Superfund16
sites in our region, New Jersey, and all17
the sites that deal with radioactive18
contamination.19
Alan Fellman is with Malcolm Pirnie,20
a contractor that works with EPA to21
actually do the investigation and cleanup,22
as well as Bob Kerbel who is also with23
Malcolm Pirnie.24
EPA Public Meeting - 2/23/99 4
D E G A N & B A T E M A N, I N C.
(609) 547-2565
And obviously, everyone here knows1
Bob Saunders who has been doing so much2
work with us and will be here long after3
we're gone. And Artie Block is also here4
from ATSDR, the Agency for Toxic Substances5
and Disease Registry, part of the Federal6
Department of Health and Human Services.7
And ATSDR works with us on a consultation8
basis and works with us closely to look at9
these Superfund investigations that we do10
and gives us information on potential11
health impacts.12
As well, I also wanted to introduce13
Linda Burns who is the stenographer who14
will be taking down all of the contents15
that you make tonight. And that's why we16
are here tonight, to hear from you, your17
thoughts, your comments, your concerns.18
And to take any questions you have about19
what we will be discussing tonight and what20
our proposed cleanup will be for the21
contamination for the site.22
And just to point out, my name is23
Mary Helen Cervantes, I’m with EPA as24
EPA Public Meeting - 2/23/99 5
D E G A N & B A T E M A N, I N C.
(609) 547-2565
well. And I work in the area of Superfund1
Community Relations. The Superfund program2
stresses, as we do throughout all of the3
programs, community involvement and4
community participation. We feel we can do5
a much better job by having you involved6
and telling us what you hear, see and know7
about the community, your community, in8
which you live. You know what's happening9
here a lot better than we do most of the10
time. So again, that's why we are here11
tonight, to hear your comments and12
concerns.13
In order for us to do that and to14
make sure that we get everything down, if15
you could, after we go through our16
presentations, if you could hold your17
questions until the end. We will try to18
move through it as quickly as possible to19
make time for questions.20
When you have questions or want to21
make a statement, state your name clearly22
so that Linda can get that down and speak23
up so we can get it all down. So at the24
EPA Public Meeting - 2/23/99 6
D E G A N & B A T E M A N, I N C.
(609) 547-2565
end of the comment period, which ends on1
March 3, which is next Wednesday, we'll2
take comments on what we're proposing up3
until next Wednesday. Afterwards we will4
do a responsiveness summary, which we'll go5
through all the comments and all of your6
concerns and we'll write a summary7
responsive to that. But what you say8
tonight and whatever comments you have,9
that will actually go into the official10
record. So you don't have to write it down11
afterwards. We'll take it down right here12
as you say it.13
I also just wanted to point out that14
Natalie Loney, whom you may have met, works15
with EPA and is the assigned Community16
Involvement Coordinator for the site. So17
I'm just sitting in for her today. She18
just had a baby on Valentine's Day, but you19
will see here throughout all of the other20
meetings throughout the year. She is the21
one who is assigned just to work with you22
and to handle your questions and concerns23
and to make sure you're involved as much as24
EPA Public Meeting - 2/23/99 7
D E G A N & B A T E M A N, I N C.
(609) 547-2565
possible and we want you to be involved in1
the process here.2
Just a couple of things very3
quickly. We have various project4
initiatives that will help you understand5
-- you'll see there's a lot of technical6
information, but there are programs that7
are available to help you understand the8
technical information. And if anyone is9
interested in those programs, I will talk10
to you about those afterwards. They are11
numerous. But just talk to me afterwards12
if you'd like.13
I'll now turn it over to Pat and Pat14
is going to go through the Superfund15
program in general.16
MR. EVANGELISTA: Good evening,17
ladies and gentlemen. Thanks for coming18
out tonight and participating in our19
meeting.20
Just to reiterate a little bit of21
what Mary Helen said, we highly encourage22
all of you to come forward and identify any23
comments, concerns or questions that you'd24
EPA Public Meeting - 2/23/99 8
D E G A N & B A T E M A N, I N C.
(609) 547-2565
like to have answered. If not tonight, you1
know, anytime in the near future. we'll2
hand out business cards if you'd like and3
feel free to call us at any time.4
What I'm going to do now for you is5
give you a little briefing on what6
Superfund is about so that you maybe7
understand better why we're here and what8
kind of process we've been following and9
are going to follow until we're done with10
this particular site.11
Back in 1980, Congress gave EPA the12
authority under a law that's known to us as13
the Comprehensive Environmental Response14
and Liability Act. And then five or six15
years later they amended that law to give16
us what we currently have today. Our17
process always beings with somehow an18
identification to the agency that there's a19
problem in a certain area. And that's what20
you see up on the screen as the discovery21
or CERCLIS. The CERCLIS is simply a22
program or process we use to track site23
progress.24
EPA Public Meeting - 2/23/99 9
D E G N A N & B A T E M A N, I N C.
(609) 547-2565
Then we move into what's known as the1
preliminary assessment or site inspection.2
We go out and we try to ascertain, on a3
preliminary basis, what kind of a problem4
we're dealing with so that we can funnel5
all of that information into a hazard6
ranking system. Based on the hazard7
ranking system we are able to rate that8
problem or that site, if you will, and if9
the score, based on the ranking, exceeds or10
is higher than 28.5, which was somehow11
selected very arbitrarily, the site ends up12
on what's known as the National Priorities13
List. This is a prioritization list that14
the agency uses to deal with the sites that15
are on it.16
From the National Priorities List we17
are then able to authorize federal money to18
proceed into what is known as the Remedial19
Investigation/Feasibility Study. The20
Remedial investigation/Feasibility Study is21
a very detailed study of the problem or the22
site or the properties, if you will.23
Perhaps you've seen us out there taking24
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soil samples. You may have seen our1
contractors. You may be aware of our field2
office.3
So we've been gathering data on this4
site for the past year or so. That data is5
then analyzed to formulate alternatives6
that we can further evaluate to identify7
the preferred cleanup option to address the8
contamination that's out there. Those9
cleanup options are identified in the10
Feasibility study and the Feasibility Study11
is used to generate the proposed plan.12
The proposed plan -- I guess we went13
public with it back on February 1 -- "went14
public with it," meaning we identified it15
in public notice, in the newspapers, for16
your knowledge. It's available for your17
review. We have copies of it here tonight18
if you'd like a copy. And in that proposed19
plan we proposed to you what we'd like to20
do to clean up this site. And Rick will21
get into a lot of that detail.22
After the public comment period ends23
we'll proceed into a Record of Decision,24
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after having considering all of your1
comments and concerns. That Record of2
Decision will formally identify the3
cleanup. The cleanup will then be designed4
under what's known as a remedial design.5
That design will identify all of the6
specifications that the contractor will7
need to follow in order to clean up your8
properties. That, in effect, is the9
cleanup.10
Once the agency has determined that11
the cleanup has occurred pursuant to all of12
the specifications, we give it a clean bill13
of health, if you will, and we remove it14
from the National Priorities List or delist15
it from the NPL.16
That essentially describes our17
process. If you have any questions I'd be18
happy to answer them for you later. At19
this point I'll pass it onto Rick Robinson,20
the Project Manager for the site.21
MR. ROBINSON: Thanks again, Pat.22
Just for background, the site is23
located both in Camden and Gloucester24
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City. It comprises two former Gas Mantle1
manufacturing facilitie some residential2
properties, commercial properties,3
municipal park lands and vacant land.4
As part of the State's investigation5
early on, in the early 1990s they divided6
the site into a number of study areas. And7
as we were going on with our investigation,8
we followed along with their study areas.9
The first one, Study Area 1, is the10
General Gas Mantle Facility in Camden and11
the surrounding properties.12
Study Area 2 is the former Welsbach13
Facility here in Gloucester City and the14
surrounding properties.15
Study Area 3 is the residential area16
in Gloucester City, including the Johnson17
Boulevard Land Preserve.18
Study Area 4 is the residential area19
in the Fairview section of Camden.20
Study Area 5, the residential21
properties and also some municipal parks in22
Gloucester City.23
And Study Area 6, some vacant24
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properties in the residential area in1
Gloucester City.2
Study Area 1, again, the General Gas3
Mantle Facility in Camden. And there is a4
photograph of the area with the General Gas5
Mantle building highlighted (indicating).6
There's a photograph of the General Gas7
Mantle building on the corner of Jefferson8
Street.9
Study Area 2 is the former Welsbach10
facility. It's now owned by Holt with the11
Gloucester terminal. The Armstrong12
building is the last remaining building13
from Welsbach's operation. And the area in14
pink right in here (indicating) is the15
location of the former Welsbach building16
that was demolished around 1975, 1976. And17
that is the main contamination area on that18
property. There's a photograph of the19
Armstrong building as it is today. There's20
the Walt Whitman Bridge in the background.21
Study Area 3 is Gloucester City.22
Gloucester City Swim Club is highlighted23
and the Johnson Boulevard Land Preserve.24
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Study Area 4, again, is the Fairview1
section of Camden. And we only found a few2
properties in this part of the site that3
were identified as having elevated levels4
of gamma radiation.5
Study Area 5 is in Gloucester City6
and includes the former Welsbach dump area7
on Temple Avenue and contamination in the8
park areas along Johnson Boulevard there.9
And Study Area 6 is a newly10
identified area and we call it the Popcorn11
Factory. You can ask Bob Saunders as to12
how that name came about. And there's a13
photograph of the Popcorn Factory and14
vacant lot. And the area in red is the15
small area of contamination that we found16
with radiological components.17
Going to the site history now. In18
about 1885 a Dr. von Welsbach invented a19
process using thorium to manufacture gas20
mantles. For those of you who don't know21
what a gas mantle is, you know in a camping22
lantern, you can see over on the left23
(indicating), and in a street light right24
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here (indicating), that is the gas mantle.1
And what they did is take a sock-like2
material and they dipped it in the thorium3
solution. And when it dried, it was lit.4
And it produced a very brilliant white5
light.6
And in about 1890 Welsbach started7
manufacturing the gas mantles here in8
Gloucester City. And at the turn of the9
century they were the world's largest10
manufacturer of gas mantles. And by the11
1940b they finally went out of business12
when the electric light put the gas light13
industry out of business.14
In Camden, General Gas Mantle15
manufactured gas mantles from about 1912 to16
1941. They were a much smaller company17
than Welsbach. They were a small18
competitor. There is very little19
information that we know about the Gas20
Mantle's activities other than it used and21
resold radium and thorium in the production22
of gas mantles.23
What we’ve termed vicinity properties24
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are all the other properties that we found1
at the site, excluding the General Gas2
Mantle facility and the Welsbach facility.3
And they were contaminated as a result of4
either disposal of the ore tailings from5
the Welsbach operation or building debris6
when buildings were demolished. Like when7
they built the Walt Whitman Bridge, some of8
the buildings were knocked down. Or from9
former workers bringing contamination home10
with them.11
Previously the site was identified in12
1980 during an archive search of the U.S.13
Radium Site in Orange, New Jersey. And in14
May 1981 EPA sponsored an aerial fly-over15
where a helicopter flew over the area with16
gamma detectors and was searching for gamma17
radiation. And as a result of that the18
State then conducted preliminary screening19
surveys in the mid 1980s and in the early20
1990s they investigated over a thousand21
properties in both Camden and Gloucester22
City.23
And as a result of that they24
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identified about 20 properties that needed1
-- that they felt needed some more2
immediate measures taken. And as a result3
they installed some radon/thoron4
ventilation systems in a number of homes.5
They installed concrete or steel sheeting6
on properties, in people's basements. And7
they also purchased one property and8
relocated the residents.9
In 1992 the State also removed10
radioactive material in the General Gas11
Mantle building and relocated the current12
occupant at the time, Ste-Lar Textiles, and13
they sealed up the building to restrict14
access.15
The State's investigation they16
base their surveys on just surface exposure17
rates, indoor radon sampling and they18
performed very limited surface soil19
samples. However, they did not really look20
in the subsurface at all. They made no21
estimates on the amount or extent of22
contamination and were just looking to23
address the more immediate potential health24
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time. EPA's involvement at the site became1
official when it was placed on the National2
Priorities List in June of 1996. And then3
that's when I was given the site and4
started the investigation process.5
Currently the General Gas Mantle6
building is inactive and boarded shut.7
Welsbach is currently owned by Holt and is8
an active facility. And with the vicinity9
properties, the immediate health concerns10
were addressed either by the State's11
remedial actions or by the EPA removal12
action. Like what we did in the park in13
December around the Ponytail(ph) Field.14
And here's a photograph of the excavation15
where we removed the top three feet of16
surface contamination. we're hoping to17
ship that material. It's being temporarily18
staged around the Popcorn Factory and we're19
going to ship that off in about three20
weeks. Today we had somebody out there21
sampling that material in preparation for22
shipment.23
Right now I’d like mo turn this24
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Right now I’d like to turn this1
portion of the talk over to Alan Fellman.2
And Dr. Fellman will talk to you a little3
bit about the radiation issues. Thank4
you.5
MR. FELLMAN: My background is in6
health physics and radiation sciences. So7
I'm going to spend just a few minutes to8
give you a few points about some of the9
terminology and some of the components10
regarding radioactivity that hopefully will11
help you follow along with the materials12
that you have been given to read and some13
of the things that you're hearing tonight.14
And then later on I'll come back and have a15
few words about the risk assessment that we16
did, which is a component of the Superfund17
remedial investigation.18
You've already heard some terms19
related to radioactivity. And I just want20
to hit on some of the key ones. When we21
measure radioactivity, when we want to22
identify a quantity of radioactive23
material, we need different units than What24
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we're more traditionally used to because1
we're not talking about a mass. We can't2
describe the weight of the material. What3
we're concerned about is the rate that4
these atoms are decaying, undergoing5
radioactive decay.6
The term we use, the unit, is called7
pico Curies. When we're talking about how8
much is in dirt or how much is in water, we9
express it as a concentration, pico Curies10
per gram or pico Curies per liter of11
water. Now this term is indicative of how12
much. It does not really address what kind13
of dose one received or what the risk is14
from that material. The point being that,15
ten pico Curies per gram of one type of16
radioactivity might give someone a17
different dose and have a different risk18
associated with it than ten pico Curies per19
gram of a different radioactivity.20
When we talk about dose of radiation,21
and that's really related to the risk, we22
use a unit called millirem. And that's a23
measure of the potential for biological24
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effect as a result of that radiation.1
Basically what we're measuring is energy2
that is coming from the radioactivity that3
is emitted from that radioactive material4
and is absorbed in the biological tissues.5
And that energy that's transferred from the6
radioactivity to the tissues is the subject7
of what could then ultimately lead to a8
biological effect or a health effect.9
Obviously, the greater the dose the10
greater the risk. There are several11
2 different types of radioactivity and you've12
3 heard some of previous speakers say the13
words thorium, radon, radium. All of these14
are different elements that have15
radioactivity associated with them. They16
emit different types of radioactivity.17
Alpha particles and beta particles18
and gamma rays are the three more common19
types of radioactivity and they're really20
the ones that we're concerned about here.21
They have different properties. Alpha22
particles are, relatively heavy. They23
travel slowly and they are not penetrating,24
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which means that they will not travel very1
far. If they're emitted from surface soil2
they will be stopped within one to two3
inches of air. They cannot get through a4
sheet of paper.5
Beta particles on the other hand have6
an intermediate amount of penetrating7
ability. They're smaller than alpha8
particles but they do have some mass9
associated with them. So while they can10
get through a sheet of paper, they will be11
stopped by something like a piece of wood.12
Gamma rays on the other hand are very13
similar to X-rays. They have no mass14
simply. It's simply packets of energy.15
It's sometimes referred to as penetrating16
radiation because it can travel fairly17
significant distances through air, paper,18
wood. And it takes a more dense media to19
absorb that energy and stop the gamma rays20
such as concrete or lead.21
The problem here, by and large what22
we're dealing with are what's known as ore23
residues. The by-product of the thorium24
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extraction processes that were implemented1
by the Welsbach company who left them with2
large piles of dirt which contained these3
ore residues with elevated concentration of4
radioactivity.5
In this schematic here, the area6
that's shaded in blue tends to show7
potential areas with these elevated levels8
of thorium. And if that were the case,9
what you can get, radon gas which is10
mobile, which can emanate from this dirt11
into the indoor atmosphere. Fortunately12
we've seen very little of that at the13
Welsbach General Gas Mantle sites. Much14
more frequently would be the case where15
there would be some of this material in an16
outdoor area where the influx of the gas17
into an indoor environment isn't likely to18
happen. But there the potential exposure19
would be from the gamma radiation that's20
emitted to an occupant who would be21
occupying, that would get a dose of that22
gamma radiation.23
At this point I’m going to let24
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Bob Kerbel speak for a few minutes. He's1
been our Project Manager from Malcolm2
Pernie throughout the investigation and3
he'll take you through some of the key4
points in that investigation.5
MR. KERBEL: I just want to give you6
a little insight of the type of7
investigation we did in the community so8
you can kind of see everything in the9
nutshell and see the type of work we've10
been doing.11
There are three areas we looked12
into. Two of the industrial facilities,13
the former Welsbach facility and the14
is General Gas Mantle facility. And then15
there was the vicinity problem, basically16
everything else. I assume most people here17
are homeowners and your home would come.18
under that vicinity property category.19
If there's anything good about this20
type of work from our standpoint as21
investigators it's that it's easy for us to22
detect this type of contamination. It23
gives off gamma radiation. So we basically24
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walk over the property with meters similar1
to this. And we might have come to your2
property and walked over the property in3
search for elevated level's of radiation. I4
have a little meter here. And we'd take5
those readings and walk over your entire6
property.7
Then if we find something we take8
soil samples and test for radiological and9
chemical contaminants. We only test for10
chemical contaminants at industrial11
properties because there's always a chance12
that there could be some chemical13
contamination just given the industrial14
nature of those areas.15
Once we find an area, we have to come16
up with a volume, how much is there. So we17
put a boring into the ground and these can18
be either shallow or deep. The only reason19
there's not a deep check mark under20
vicinity properties is because we really21
didn't have deep contamination on22
residential properties. That was really at23
the industrial sites that we needed to go a24
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little deeper. And as Alan alluded to, if1
there's soil contamination in the area,2
that gives off radon gas that could get3
into the household, so we test for that as4
well.5
On the industrial properties we also6
do something called alpha/beta measurements7
where we would actually sample structural8
materials. Because sometimes we might run9
into a question, whether it's the soil10
under the building or the building material11
itself that might be contaminated. So we12
might test that.13
This isn't too easy to see, but I14
want you to use your imagination a little15
bit. Let me try to get your eyes to focus16
here. This is the former Welsbach facility17
that was located along the Delaware River.18
The Delaware River is up there on top, you19
can see a smoke stack. And King Street20
would be at the lower end of the picture.21
But if you could imagine, this is the early22
part of the century. There's no DEP;23
there's no environmental protection24
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agency. The hazards associated with1
radiation really aren't known yet. Things2
like nuclear power are decades in the3
future yet to come. And as Rick said they4
made gas mantles here. Things like X-rays5
that the doctor does now were still being6
discovered at that time.7
But at this facility, they brought8
ore in. So basically on this facility9
there was a pile of dirt that they would10
extract the thorium from to use in these11
gas mantles. So at the time it was really12
a prosperous business until the electric13
light bulb came into play and put them out14
of business. But at that time the hazards15
weren't really known.16
In future years, in the last couple17
of decades, we're more aware of the hazards18
associated with radiation. So now someone19
said, you know what, we should go back to20
all these facilities that did this in the21
early part of the century. Because the22
sand that contained thorium, that could23
potentially be radioactive. So we should24
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go back to these facilities to see if,1
indeed, there is radioactive material on2
these sites.3
So years later they come back to the4
site but now there's no building here. The5
circle is basically where the facility6
would have been. So what we do is just7
what I told you earlier, we walk over the8
entire site and it takes a number of weeks9
to do it because it's so large, and we look10
for elevated levels of radiation. Because11
at the beginning the thought is, if the12
building is gone, it's conceivable that13
they had these huge basements and they14
knocked the building down and filled the15
basement and then paved over it.16
So we go over the entire site, we17
look for the elevated levels and then we18
bring them back to our office and we have19
special programs that help us see what the20
radiation levels are. Now this is a bird's21
eye view looking down at this site now.22
And wherever you see a colored area, those23
are elevated radiation levels. That's a24
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clear signal for us that there is1
contamination on the site. And then we go2
back and take soil samples to see that it3
is thorium. And we do borings to see how4
deep it is. Ballpark approximately ten5
feet deep in locations.6
Alan is going to come back and talk7
more about risk, but I just want to give a8
little perspective to it. When we do this9
work it's not like we dress up in suits or10
anything. We just wear our regular work11
cloths and work in these areas and get our12
measurements and so on. For the people13
that work for Malcolm Pernie, I'm14
responsible for their health and safety.15
And for me, the real risk is that they16
don't get killed by a truck going through17
the yards rather than the radiation wells.18
Another thing to keep in mind, this19
is not like an oil spill that’s spreading20
out there. It's been there for 50 years.21
It really doesn't move around unless you22
mechanically move it to another location.23
when I mentioned that soil pile from 50 to24
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100 years ago, what if you had a1
residential property, they removed a tree,2
there's a hole in the ground and they took3
that soil to fill the hole. That’s the4
type of thing we're looking for now.5
The General Gas Mantle building, let6
me just tell you a little bit about what we7
have here. It's all closed up now. Again,8
as Alan was telling you, the radon levels9
coming from the ground underneath the10
building, that is indeed what's happening11
here. Since it's all boarded up, there's12
no ventilation so there is a high radon13
level. There is some soil contamination,14
nowhere near as extensive as at the15
(INAUDIBLE) facility.16
And it is a longer building and it17
does come out into the street at South18
Fourth Street. And there are some building19
materials. The building is vacant.20
There's nothing in there., There's wood21
floors and some of those wood floors are22
contaminated. They would have to be23
decontaminated before the building is24
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demolished. But Rick Robinson will come1
back and talk a little about that.2
I assume most people here are3
property owners. So the last category is4
the vicinity properties. So let me touch5
base a little more on this one. The goal6
here is to get to the cleanup as soon as7
possible. And we were fortunate in this8
case that the State went to a thousand9
properties. So we didn't want to go to a10
thousand properties all over again and11
investigate those properties. But what we12
had to do is see that we could use the13
State's data. So we went to 20 properties14
and we compared our data to the State15
data. And we agreed with their data.16
So then we took their data and17
categorized it. The State went to18
approximately 1,000 properties. Here it's19
1,088. When we looked at the State data,20
we said approximately half, 449 properties21
are clean. We can't find any indication of22
contamination on those properties.23
Then there's another category we put24
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on that we call suspect properties. That's1
585 properties. Now suspect properties are2
our grey area. If a property was adjacent3
to a contaminated property, we4
automatically called it suspect because we5
want to check it out because it's adjacent6
to that contaminated property.7
Throughout the State people test8
their homes for radon and get elevated9
levels of radon in certain locations. That10
might have happened here and it would be11
perfectly normal. But we question is that12
because of the normal radium in the soil,13
or is it a sign that there might be some14
soil contamination from the Welsbach15
facility.16
We use the term natural background17
radiation because there's radiation all18
over but there's an average. And these19
properties might have had levels on the20
high end of that. If you live in a brick21
home, that may be a reason that it's high.22
But we want to go back to those properties23
to really break them either way, if it's24
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the contaminated category or the clean1
property category.2
And then the bottom line is we have3
54 contaminated properties. Properties4
that clearly had some contamination on them5
from our results and the State’s. And we6
came up with a volume for this for our7
estimate in the future.8
Before I let Alan come back and talk9
again about risk, I just want to mention on10
suspect properties, again it's our grey11
area. The contamination on all these12
properties might be a small spot that we13
can take away and put in a pail. We might14
have to bring a backhoe in there to dig it15
out. But the suspect properties, we would16
think that most of those properties can be17
moved to the clean category eventually.18
But we don't know that for sure and we19
won’t know until we actually do the testing20
on that property.21
So I'll let Alan come back and talk a22
little bit about health risks.23
MR. FELLMAN: whenever I talk to24
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people about the risk of radiation, it's1
always a good frame of reference to say a2
few words first about natural background3
radioactivity. it's very helpful when you4
realize that we live on a radioactive5
planet. And as a result of that, we're6
constantly being bombarded by7
radioactivity, no matter where we are,8
having nothing to do with the Superfund9
site.10
There are several different sources11
of natural radioactivity and they're listed12
in this table. Cosmic and cosmogenic refer13
to things coming from the atmosphere, the14
upper atmosphere.15
Terrestrial radioactivity is the16
natural thorium, radium, uranium that's in17
the ground, in the soil, in the rocks. And18
we get most of that 28 millirem per year19
from terrestrial sources which comes from20
gamma radiation.21
Inhaled radiation, we’re talking22
mostly there about radon gas. On average,23
in the average house, anytime you put four24
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walls and a ceiling together you're going1
to get some level of radon gas. And on2
average we get a dose of about 200 millirem3
per year.4
And then the internal emitters,5
referring to the radioactivity that we6
carry around in our bodies from natural7
sources such as potassium 40, which is a8
small but significant component of all the9
potassium on the planet. There's a little10
bit of these in soil, in the plants,11
vegetables and fruit and so forth. And so12
we're constantly ingesting and excreting13
some of this radioactivity. And as a14
result of it being in our bodies we receive15
a dose on average of 40 millirem per year.16
There's also a host of consumer17
products that have one or another type of18
radioactivity associated with it. And you19
can see it's a pretty diverse list. And20
the last one that we show there are gas21
mantles. We know a little bit more about22
them than we'd like to.23
Adding a few more things to those24
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that you see here on this slide, I have a1
little show and tell here. Most everybody2
who works in my field has one of these.3
This is a piece of Fiestaware(ph) which4
you'll find in almost any antique show.5
And this orange color -- I don't know why6
they call it yellow cake -- but the glaze7
that they apply to give it this orange8
color is called yellow cake. And it has a9
fair amount of natural uranium in it.10
This meter here is called a Geiger11
viewer detector, the common name is a12
pancake probe because of the shape. It has13
very low background. When you turn it on,14
from regular background radiation, this is15
what you'll hear, the sporadic beep. Each16
time a photon or a gamma ray is interacting17
inside the detector, it makes a click. And18
then, as you can tell when I get close to19
the Fiestaware, there's quite a20
difference. If I move one to two feet21
away, you can hear how rapidly that level22
of radioactivity decreases. As we remove23
ourselves from the source, the level drops24
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off fairly rapidly. So again, a very high1
level right out of the source, but by the2
time I get within three feet apart, there's3
very little, if any, impact right here.4
Now, another thing that's kind of5
interesting is that for those of us who6
have been told by our doctors that we have7
to reduce our salt intake because of8
hypertension or heart problems, they say,9
go get some salt substitute from the10
grocery store. What you're getting is not11
a salt substitute, it's potassium chloride12
instead of sodium chloride.13
And as I said earlier, of all the14
potassium on the planet, a very small15
traction is radioactive. And there's no16
difference from the potassium that's in17
here than the potassium that's in a banana18
or potato or any other potassium-rich19
food. And the difference is not quite what20
you'd hear with the Fiestaware, but you do21
hear a difference. And again, that's22
natural potassium 40 emitting beta23
particles and gamma rays. And this is what24
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we need to eat to protect us from1
hypertension. Again, it doesn't cause a2
big dose. I just want to illustrate the3
fact that there's radioactivity all around4
us, even in the things that we eat.5
When we talk about dose effect6
relationship, about being exposed to7
radiation, there's one point -- if you get8
nothing else -- there's one point that I9
think is very important for you to10
understand. And that is that what we know11
about radiation is that, yes, it is most12
definitely a human carcinogen. But we know13
that because of studies that have been done14
on populations of people that have been15
exposed to very, very high doses of16
radiation, compared to background, compared17
to the levels that we have at some of the,18
quote, unquote, contaminated properties19
here. These would be groups such as the20
Japanese who survived the atomic weapons21
blast at the end of World War II. Several22
groups of patients, who back in the ‘20s23
and ‘30s, and ‘40S were treated for various24
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ailments with radiation. Whereas now, the1
medical community uses radioactivity to try2
to help destroy cancer cells. Back then it3
used to be a treatment for certain4
diseases. So 20, 30, 40 years later there5
are these populations treated with these6
high doses of radioactivity who were7
followed and were found to suffer from high8
or increased levels of cancer.9
So what do we do as public health10
scientists? We know that when the dose is11
very high we see excess cancer. Now we’ve12
got the lower dose and you can see in this13
curve, what Im talking about earlier with14
the Japanese and some of these other15
groups, theyre up here in the dose16
response curve. We know the dose is very17
high and we see the health effect or the18
risk of cancer is easy to measure. what we19
have down here is what I call an area of20
great uncertainty. There are no data that21
we can point to that will show that at the22
levels that we’re exposed to from23
background radiation and from levels that24
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are slightly greater than background such1
as some of the properties that have these2
thorium residues an them. There are no3
data that show that people exposed at those4
levels are actually suffering from5
increased incidents of any type of cancer.6
But the fact that I can say that7
doesn’t mean that we can then dismiss or8
would want to say there’s no problem, let’s9
forget about it. We make an assumption.10
we assume that there’s a linear risk. We11
assume what’s called no threshold, that as12
soon as you get any dose of radiation, we13
assume there’s some risk. it might be very14
small. We certainly can’t measure it and15
the truth of the matter is, there may be no16
risk at all.17
But we assume that there is a risk.18
And when we end up at a risk level, when we19
do our risk assessment part of this20
investigation, we come up with a number and21
compare that to what EPA has determined to22
be the acceptable risk range. And if our23
models project a risk greater -- that is24
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greater than the risk range that EPA is1
looking to obtain, that becomes the basis2
for a cleanup. The way the Superfund law3
is written, EPA needs to demonstrate a risk4
greater than what they found to be5
acceptable and to use that then as a reason6
to go forward with an action.7
At this point I’ll stop and Rick will8
pick back up and discuss the alternatives9
for the sites.10
MR. ROBINSON: Thanks, Alan. Now11
what we’re going to talk about is, based on12
the results of the remedial investigation13
we evaluated a number of alternatives for14
the cleanup. And we evaluated alternatives15
for the three property types we discussed16
earlier, the vicinity properties, the17
Welsbach facility and for the General Gas18
Mantle facility. And for each of the three19
property types we evaluated, we evaluated a20
No Action Alternative; an Engineering21
Controls Alternative; and an Excavation and22
Off-site Disposal Alternative.23
The No Action Alternative is an24
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alternative that we have to do on each1
Superfund site. And we have to compare the2
other alternatives versus what if we did3
nothing. If we left it alone, what are the4
risks. So the No Action Alternative is5
something that we have to do. In this case6
here, it was determined that there is a7
risk above EPA’s criteria, as Alan just8
told you. And as a result we’re not going9
to talk about the No Action Alternative10
anymore. And we’re not even going to11
consider it right now.12
For the vicinity properties, for the13
Engineering Controls Alternative, it’s14
Alternative V-2. Outdoor gamma shields15
would be required on approximately 5016
properties; indoor gamma shields on17
approximately 20 properties; and radon18
mitigation systems would be needed an19
approximately 4 properties; As a result we20
would need to have deed restrictions on the21
property, limiting future work on that22
property. And we would have to negotiate23
that with each property owner. The State24
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of New Jersey would be responsible for1
enforcing those restrictions. And we would2
have to go back every five years to make3
sure that it was protected and the shields4
were still effective.5
For the Alternative V-3, the6
Excavation and Off-site Disposal7
Alternative, all the soil and debris above8
our cleanup standards would be excavated9
and disposed of off-site. And under this10
alternative, the contaminated materials11
would all be removed. The mobility of the12
contaminants would be eliminated and there13
would be no significant institutional14
controls remaining on the properties. The15
properties would be safe for future reuse16
and the remedy would be protective of human17
health and environment.18
For the Welsbach facility,19
Engineering Controls, again we would need20
outdoor gamma shields. We would need deed21
restrictions limiting future site work.22
And we would have to go back every five23
years to make sure that it was protected24
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and that the shields were Still effective.1
Alternative W-3 for the Welsbach2
facility, all the soil and debris above our3
cleanup standards would be removed and4
excavated and sent off-site for disposal.5
All of the materials, again, would be6
removed from the property, mobility of the7
contaminants would then be eliminated, and8
there would be no controls remaining.9
For General Gas Mantle, again for the10
Engineering Controls Alternative, G-2,11
again outdoor gamma shields. For the Gas12
Mantle building, we would have them13
permanently board the building shut. We14
would have to restrict access against the15
building, and we would have to go back16
every five years to make sure that it was17
still effective controls.18
For the Excavation and Off-site19
Disposal Alternative G-3, we evaluated two20
options for the buildings. For the General21
Gas Mantle facility under Option A, the22
building would just be demolished and the23
building materials would be sent off-site24
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as contaminated materials.1
For Option B, we would first go in2
and try to decontaminate the building and3
then this would reduce the volume of4
material that needed to go to off-site5
disposal. For both options all materials6
would be moved from the site and there7
would be no significant institutional8
controls.9
And now we’ll just go into some10
summaries. The summary of the cost for the11
vicinity properties. The engineering12
controls would cost about $2 million13
dollars to implement. And the Excavation14
and Off-site Disposal would cost15
approximately a little over $13 million16
dollars.17
For the Welsbach facility, the18
engineering controls, almost $6 million19
dollars. And the Excavation and off-site20
Disposal, $18.5 million dollars.21
For the General Gas Mantle facility,22
the Engineering Controls Alternative just23
under $400,000. And the Excavation and24
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Off-site Disposal for Option A which was1
the straight demolition of the building is2
just over $2 million dollars. And for the3
decontamination and demolition of the4
building, just under $2 million dollars.5
As a result, EPA’s preferred6
alternative is the Excavation and Off-site7
Disposal Alternative, V-3, W-3 and G-3.8
And with the General Gas mantle facility it9
would be option B, decontamination prior to10
the demolition.11
In summry, the total cost of the12
selected remedies combined is almost $3413
million dollars. Where do we go to next14
now? The next steps, right now we’re at15
the process soliciting public comment. And16
as Mary Helen told you earlier, we’re here17
to respond to your verbal comments tonight18
and we’re also encouraging you to submit19
written comments, if necessary. And after20
we receive public comments, we select a21
remedy in a document that’s called a Record22
of Decision (ROD). And once we sign the23
Record of Decision, EPA can then start the24
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design process.1
Our focus will be on the residential2
properties first. And then followed by3
that the commercial and industrial property4
cleanups. We plan on starting the field5
investigations on the suspect properties in6
the fall of this year. And we’ll hopefully7
start the design and investigation on the8
potential contaminated properties also in9
the fall. And we’re also going to try to10
start the demolition process of the General11
Gas Mantle building sometime this year and12
hopefully finish in one to two years. The13
General Gas Mantle building is in a very14
sad state of disrepair. vandalized a15
number of times. The wood floor is a fire16
hazard. we’d like to get the building down17
as soon as possible.18
The plan right now is to start the19
cleanup activities on the individual20
properties in about three to five years.21
One of the processes with the design is22
that because it’s an individual nature of23
the property -- because the contamination24
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is on an individual property, we have to do1
a specific design on each individual2
property. And it takes time to generate3
the design activities on all these4
different properties and put it together in5
a package so that we can have a contractor6
go in and do the cleanup all at once.7
We’re also in the process of8
conducting a ground water investigation.9
And that’s underway right now to make sure10
there is no radiological contamination from11
the site in the ground water. We don’t12
believe we’ll find that much, but thorium13
itself does not like water. It doesn’t go14
into water, into solution. But we’re15
testing the ground water anyway just to16
confirm that there is no radiological17
contamination there.18
We’re also going to investigate the19
wetland areas around Newton Creek, around20
the Johnson Boulevard Land Preserve and21
along Temple Avenue where there’s two22
former dumps as well as the Welsbach23
operation.24
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And that’s the end of our1
presentation. We'd like to invite you to2
ask any questions. we're all here to3
answer them.4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
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21
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MR. EVANGELISTA: Before we get1
involved in the questions and answers, I2
just wanted to point out that we have some3
handouts up front. One provides you with4
factual information, sort of a summary fact5
sheet. Hopefully it kind of reiterates6
what I opened up with at the initial part7
of the meeting. If you have any questions8
now is a good time to raise them.9
MS. CERVANTES-GROSS: Or if you just10
have a comment. If you could just state11
your name again before you give us your12
question.13
MR. BECKS: My name is John Becks(ph)14
(INAUDIBLE). I live on the 900 block of15
Somerset Street. I’m about eight houses16
from where you were doing the cleanup17
earlier.18
Did they come around -- did you or19
the State come around to individual homes20
in that area to test our homes? And what21
steps are being taken for that?22
MR. ROBINSON: You might have to show23
us on one of the maps where Somerset Street24
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is.1
MR. SAUNDERS: Johnson Boulevard, the2
ponytail, almost catty-corner, right in3
those blocks.4
MR. ROBINSON: I would have to look5
at the State information on whether or not6
that part of Somerset Street was included7
in the investigation. We could let you8
know if there is any information on your9
property -- if the State did survey it or10
not. If you don't believe they did –11
MR. BECKS: No, I don't.12
MR. SAUNDERS: That area -- actually13
the whole town -- we get a lot of false14
positives, which is what we want. They go15
back through that area to see if it's16
construction of the home material. And in17
that area the only thing they saw was along18
the Johnson Boulevard area of houses in19
Gloucester, (INAUDIBLE), in that immediate20
area.21
MR. BECKS: Why wouldn't they be?22
MR. SAUNDERS: We went out. I can23
show you an one of the colored pictures24
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where it was done.1
MR. BECKS: And was it?2
MR. SAUNDERS: Yes, it was done. Was3
the house done? No. Plus the construction4
date of those homes -- that was called the5
homes, like, that (INAUDIBLE) and a lot of6
the construction predated the site. The7
homes were built -- that whole section on8
Somerset Street predated a lot of the dump9
area. The wetland area that was all10
wetlands in the ‘50s. So that's some of11
the ones where we didn't see anything.12
When I say "we," EPA. There was nothing to13
indicate that there was any concern14
whatsoever in that area (INAUDIBLE) quite a15
few feet to make sure.16
Some of the pictures -- here some17
people made mention of (indicating).18
People want to make sure again and again19
and again, to make sure. So that’s why it20
may be contaminated here. we are going to21
look here and here and here and here again22
(indicating). The last thing anybody wants23
to do is do this wrong.24
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I live around the block. I have --1
was my house tested? No. Because I know2
the age of when they were built, how it was3
built. Where Dr. Kelly lives, that area,4
that predated the dump. So the homes built5
before the dump (INAUDIBLE) they weren't6
(INAUDIBLE). However, as part of this7
randomly (INAUDIBLE). They did go out.8
MR. ROBINSON: If you'd like and you9
are concerned, we can just go over and do a10
quick walkover while one of our contractors11
is out here.12
MR. BECKS: I'm concerned too, in13
talking with various neighbors, it was a14
common practice at the time when they were15
filling the wetlands, that people go home16
and pick up building materials, bring them17
home to your site, wood and such. And18
that's a concern.19
MR. FELLMAN: Part of the answer is20
that this fly-over data kind of laid out21
the boundaries of the different study22
areas, as starting points. And not looking23
at a map, you know, I suspect that your24
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home is probably outside of the boundaries1
that the fly-over gave us to start with.2
MR. BECKS: I was doing some work in3
my basement about a week and a half ago. I4
tore out the closet and there was building5
material from Welsbach.6
MR. ROBINSON: Really. If you could7
please leave your name. I have a8
contractor who's here with me today doing9
some fieldwork and we can make an10
appointment and scan your property. We'll11
need to do that this week.12
MR. BECKS: I have two very small13
children that my wife and I love dearly.14
MR. SAUNDERS: That's the kind of15
information -- some people think they're16
going to get in trouble.17
MR. BECKS: Well, that's why I came18
here. That's not the only reason. I was19
planning on coming when I first read it in20
the Gloucester City News. The only way21
that I knew about this meeting was from22
that article in the Gloucester City News.23
I can see by the amount if people that24
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apparently nobody cares or everyone wasn't1
informed.2
MR. SAUNDERS: This is what we did.3
Gloucester City News was given the same4
data as the Courier and as the Inquirer.5
And all those areas of people who live in a6
house (INAUDIBLE) there was suspect7
condition. So now you're looking at quite8
a few hundred people and this is generally9
the response.10
MR. BECKS: I only really get the11
Gloucester City News. I don't read the12
Courier or the Inquirer.13
MR. SAUNDERS: In fairness to EPA, a14
lot of these residents who had questions, a15
lot of them have called to complain. And16
we'll give them the information -- plus the17
residents we've sat down with. And I'll18
show you what we have here, a demarcation.19
MR. BECKS: There was a lot of people20
filling in tree holes from dirt piles down21
at the end of the street.22
MR. SAUNDERS: But the fly-over would23
have shown that.24
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MR. ROBINSON: We can schedule a time1
tomorrow morning. We,11 still be here in2
town. We can make an appointment with you3
or anytime at your convenience when we're4
down here. If you know of anybody else who5
are not in these areas who have other6
Welsbach materials, we're very, very7
interested in trying to find those homes.8
Like a former worker who used to work there9
may have brought some stuff home with him.10
It's very, very hard to do the entire11
town. And we need help from the public on12
that.13
MR. SAUNDERS: As always, if you get14
the word out, they can call us 24 hours a15
day and we'll take a quick sample. That's16
the beauty. We can meter it and say, yes,17
it's there; no, it's not. We want to do18
that with a whole host of the materials.19
MR. BECKS: Thank you.20
MS. CERVANTES-GROSS: Anyone else21
have a comment or a question?22
MS. MARKS (ph) - my name is Sue23
Marks. I live in Bellmawr. I was a24
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resident of Fairview for many years. I1
have a couple of questions and I spoke to a2
couple of gentlemen earlier.3
I have a cancer study here that I4
sent to the EPA (INAUDIBLE) a couple of5
weeks ago. I received a copy of this and6
in here, one of things that stood out for7
me was, it says higher cancer incidents8
from the Welsbach General Gas mantle site9
appear to be due to significantly higher10
lung cancer incidents in the population,11
especially in males.12
Do you -- and maybe you're not the13
right people to ask -- but to me I'm14
concerned about the health aspect of what15
has seemed to be a long-term problem here.16
As I said, I used to live in Fairview and17
my house -- I just saw on one of the poster18
boards there -- was basically right19
directly behind one of your highly20
contaminated homes. I'm concerned about21
the residents’ health. And I guess what I22
need to know is, the people that are living23
in these homes that are the 54 contaminated24
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homes, what will be done with them, to1
them, for them, while this remedial work is2
going on? In other words, A, will they be3
moved out of their home; B, will they be4
monitored for any sort of health problems5
as the remedial work is going on? To me6
that's one of my greatest concerns.7
I think, Bob, you and I had spoken8
about this earlier. I don't know where9
this came from. I don't know how it's in10
reference to this Welsbach site. But I11
have to know that it must be connected12
somewhere.13
MR. ROBINSON: For the answer to the14
health study, we have Artie Block here from15
ATSDR. And his agency is the one who16
sponsored the State investigation.17
MR. BLOCK: Let me just take a18
moment. Again, my name is Arthur Block.19
I'm a Senior Regional Representative for20
ATSDR.21
As was mentioned by Mary Helen, ATSDR22
is the Agency for Toxic Substances and23
Disease Registry and is part of the24
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Department of Health and Human Services.1
We are primarily, and our main mandate and2
responsibility, is environmental health.3
We work very closely with the Federal EPA,4
the State, the community, whatever it is to5
identify if there are any health needs or6
health concerns associated with7
environmental exposure. And that's8
basically our main role.9
One other thing I'll tell you about10
our agency, my agency, is that it is an11
independent environmental health agency.12
In other words, we look at situations that13
affect you, the community, on an14
independent basis. We look at all the data15
that was put in front of us and we evaluate16
that data independently of other agencies.17
And we give you our health call as to what18
is up or what's going on in your19
community. I'm not going to spend too much20
more time on this. Here's the information21
and certainly if after the meeting you want22
to speak more to me about our agency, you23
can have this information about ATSDR. And24
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there's a lovely young lady over here who1
says she's a computer geek, so I'm going to2
pass this onto you, which is our web page.3
And we also have some more of that if4
you're into computer information. And5
actually you can get a lot of information,6
more than I could ever tell you tonight,7
about contaminants, about how they impact8
on human health. So if you want that9
information I can certainly pass that along10
to you too. And I'll certainly give you my11
card and, as Pat indicated, if you have any12
follow-up questions.13
I'm not a scientist. I'm just like14
you guys. But I work in public health so15
there may be some specific questions, if16
you do come up with any, that refer to a17
specific science or physic radiation. I'll18
refer those to Alan. He is a health19
physicist and the person who can give you20
the scientific readouts. I'll give you the21
readout from the point of view of just22
common people like ourselves.23
If you look at the houses that, as24
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they existed 50, 60 years ago or the area1
around there 50, 60 years ago -- I wish we2
were able to take one of these machines and3
read what people were exposed to back then4
and at what level. We don't know. We5
don't know. That is the bottom line.6
Nobody knows. It takes time for cancer to7
develop. It doesn't happen overnight. And8
it takes a lot of dosage, constantly being9
exposed to these high doses. These are10
things that just come out. And that’s how11
I understand it.12
To get exposed on a normal basis, as13
indicated, we do commonly get exposed to14
radiation in different levels. Most of15
that is not of public health concern.16
People who generally worked in these17
situations and got a constant exposure to18
them, these are the people who developed --19
or in the case, you know, of the Japanese,20
where you have a huge, huge amount of21
dosage coming at you at one time. So these22
things we know about.23
Now, let me also make some other24
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statements about the study. And that1
hopefully will get to your question. Is2
lung cancer -- can it be associated or is3
it biologically causable that radiation can4
cause lung cancer? The answer is yes. But5
looking at the numbers and what was given6
to ATSDR and the New Jersey Department of7
Health who did the evaluation of the8
sampling that was done, these dosages were9
not high enough or should not have been10
high enough to give you lung cancer.11
That's the short and long of it.12
But nonetheless, ATSDR, my agency,13
along with the New Jersey Department of14
Health and the Department of Health and15
Human Services decided to take a look. And16
you won't be surprised to hear that in New17
Jersey there are other sites like this. So18
you have Maywood in Maywood, New Jersey.19
You have the West Orange, Montclair area,20
all similar radon exposures. New Jersey21
and ATSDR decided, well, let's take a look22
because communities generally are concerned23
about cancer and understandably so,24
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radiation issues around these type of1
Superfund sites.2
So we pick these three areas here,3
this whole bottom area (indicating), and4
those other two that I just mentioned. If5
you read the study, you'll find out that6
with an examining of the cancer risks7
around a one- or two-mile area of those8
Superfund sites, there was no elevated9
cancer of any type found associated with10
the exposure to radon or radiation. Didn't11
find it. Didn't find it in Montclair.12
Didn't find it in Maywood.13
What we did find, what you're14
bringing up is, yes, there was elevated15
lung cancer found here in this area.16
What's kind of interesting is, you have the17
same type of contaminant.18
If you look at the history of all of19
these sites, they're very similar. And yet20
you have just one elevation of one type of21
cancer, lung cancer, in this area. What22
you would want -- what you might expect to23
find is that if this is all similar24
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contamination, all similar exposures to1
people, that you'd find lung cancer here2
and find lung cancer in Maywood and you'd3
find lung cancer also in the Montclair,4
West Orange area.5
Is radiation the cause for the6
increased lung cancer? In all honesty, I7
cannot say to you standing in front of you,8
and I wouldn't say that, that it isn't9
possible. It is possible. The probability10
of it is probably much less than that.11
Okay. Beyond that, it would take a very --12
you'd have to study the individual people13
themselves to find out -- to rule out14
other, what are called, confounders.15
What are these confounders? These16
confounders are things like occupational17
exposure that causes lung contamination.18
Smoking, that we know has a direct19
association with lung cancer. These are20
the confounders that, if you pursued this21
further, you may find, yes, there was a lot22
of smokers out there. Or, yeah, they were,23
in fact, occupationally exposed. And that24
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elevated number that was found from that1
study will start to decrease or it should.2
Unless we rule out all other3
confounders and you're stuck with, yeah,4
it's the radiation. That's what that study5
was trying to find out. Is there any6
similarities in the occurrence of cancers7
within those three -- around those three8
given Superfund sites and there wasn't any9
found. Other than the one elevation of10
lung cancer here. And that was the purpose11
of the study. It wasn't necessarily to12
associate Superfund sites and cancer. That13
was not the purpose. The purpose was to14
see if there was any commonality of the15
exposures and things like that from the16
Superfund sites.17
Let me stop there. Having heard what18
Alan said, having heard what I said, are19
there more concerns than that? Did I20
somewhat, kind of, sort of, answer your21
question?22
MS. MARKS: Yes. It's just my23
concern that we live in the area that's24
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very polluted.1
MR. BLOCK: It's a very real2
concern.3
MS. MARKS: Exactly. And the4
Welsbach problems coupled with this study5
just alarmed me more than I thought.6
I do have a couple other questions.7
MR. EVANGELISTA: At this point I'd8
like to address the other part of your9
question regarding how the EPA will deal10
with affected residents whose property will11
require cleanup.12
As Rick and I touched upon a little13
earlier, we talked about the remedial14
design phase of the project. At that point15
EPA will look at each of these individual16
properties that will require cleanup and17
design an approach for cleaning up that18
property. And each property will be19
different. You may have a property that20
has several bricks in the backyard that we21
will essentially pick up and take away. We22
may have another property where we may have23
to excavate a certain volume of soil that's24
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elevated in levels of radioactivity which1
we'll also move away.2
Whatever you may have as far as a3
cleanup that's required, the agency will4
and hopes to work very cooperatively with5
the property owner. Our intent or our6
approach will be as we've applied it in7
other sites like Montclair where we'll work8
as closely as we can with the property9
owner to impose as little inconvenience as10
possible.11
You touched a little bit upon12
relocation. If there's a need for13
relocation, which we hope there won't be,14
but if there is a need then EPA will work15
as closely with the property owner as16
possible to provide as temporary relocation17
as possible. And, of course, that will be18
at our expense or the Superfund's expense.19
But we hope that that will not be the case20
for any of the properties. But I'm not out21
here to tell you tonight that that's not22
ever going to be the case on any of these23
projects. That may very well be the case24
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on some of the projects. So we'll just1
have to wait and see and we'll do our best2
to keep you as informed as possible in as3
timely a fashion as possible.4
MR. SAUNDERS: Say I live in a house5
that there's known contamination there, I6
understand remedial measures have already7
been taken (INAUDIBLE) shields as discussed8
earlier. So right now, if you're in the9
house (INAUDIBLE) we know we're going to10
protect you. There’s a lot of (INAUDIBLE)11
that don't care about the health issues,12
they just care about the trees and birds.13
That's the farthest thing from the truth.14
(INAUDIBLE) and then we go from there. And15
we have been somewhat criticized in16
(INAUDIBLE) and using overkill. And yes,17
we do take overkill and we wear it as a18
badge of honor. (INAUDIBLE) some of the19
people over at the Popcorn Factory, I'd20
much rather be brought before my governing21
body -- there are quite a few Council22
people here -- I'd much rather be brought23
on the carpet for overkill than not doing24
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enough. And the direction is always1
overkill. It's never not enough. So here2
that's what we've taken. EPA, they have3
gone above and beyond in many, many4
situations.5
MS. MARKS: Would there be any sort6
of follow-up, I mean, like a health study7
done on the residents after your remedial8
work takes place? Will you be tracking9
them for a period of time to see if they10
develop any sort of problems or any11
long-term problems due to -- maybe before12
your remedial work started and before these13
temporary structures were put into place?14
MR. SAUNDERS: Would you be able to15
speak for the purpose of contamination?16
MR. BLOCK: Your question is more, as17
I understood it, they're going to begin the18
remedial and then -- did I sense that you19
think you're going to be exposed to20
something during that time period and21
then --22
MS. MARKS: No; no.23
MR. BLOCK: Okay. I did24
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misunderstand then.1
MS. MARKS: I understand the way it's2
going to occur. What I'm saying is, these3
people, evidently, I assume some of them4
have been living in these contaminated5
homes for some time. Will there be some6
sort of a health study done on them before7
the remedial work starts and then would8
there be a follow-up study just to track9
the situation to see if anything -- they10
have incurred any sort of medical problems?11
MR. FELLMAN: In a sense that first12
health study is what ATSDR funded to the13
State. Because the only health effects14
that we associate with exposure to15
radiation is cancer. There aren't other16
illnesses that we look at as indices of17
radiation exposure. So it's either18
elevated cancer or not. And so that first19
look, in effect, is the study that you've20
looked at. Now whether there's going to be21
an additional study done or another study22
done down the road -- I think -–23
MR. BLOCK: The bottom line, is there24
25
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a health plan?1
MR. ROBINSON: It's not planned.2
MR. FELLMAN: It's not part of this3
process.4
MR. BLOCK: It doesn't require it5
from the viewpoint of looking at the site6
and how the impact on health would be. So7
the short answer is no. But I know Bob8
wanted me to just discuss the Cancer9
Registry.10
Are all of you familiar with the11
State Cancer Registry? Is there anyone who12
needs information on that and how it works13
and what it's there for? Are you okay with14
that? Because I'll spend a moment on that15
if you'd like.16
New Jersey, like all 50 states17
throughout the nation, maintains what is18
called a Cancer Registry. Some states do19
it better than others. And, in fact,20
they're funded very well to maintain a good21
Cancer Registry. And within the states22
there are mandated laws that hold -–23
hospitals and physicians who diagnose24
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cancer must report that cancer incident to1
the State. And once it's reported, then it2
comes into the registry system.3
And the reason for that is,4
obviously, all of us are concerned about5
cancer. Not only for research reasons, but6
certainly we want to know how much cancer7
is out there and specifically within our8
own areas. Are there more elevated cancers9
overall? Why? Because that then may10
prompt further investigations. A perfect11
example of that is just north and east of12
here, Toms River. And I'm sure a lot of13
you have heard about that. And our agency,14
ATSDR, along with the New Jersey Department15
of Health is very, very much into that16
childhood cancer investigation at this17
point.18
So this Cancer Registry maintains all19
of the reported incidents. And actually20
this is kind of interesting. Prior to Toms21
River, the New Jersey Cancer Registry was22
probably four to five years behind in terms23
of keeping up with the data that was24
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entering in. After Toms River, all of a1
sudden money came into the Cancer2
Registry. And now it's probably -- and I'm3
not kidding you about this -- New Jersey's4
Registry is a gold mark standard registry.5
But something like that had to happen. And6
there are other states in the union who are7
not very good with keeping their data. But8
New Jersey is exemplary with its program.9
Now what that does is -- and when you10
get into the issue of statisticians and11
numbers and how big populations are in12
terms of how do you measure what's13
happening in one community as opposed to14
another community, what they do is -- I'm15
simplifying it, really -- I have to. I16
really don't understand all of it. I'm not17
a statistician.18
What they do is take comparable19
populations in numbers and size and their20
socioeconomic background. And they compare21
these two populations which are similar and22
look at the cancer rates or incidents23
within those populations, they should be24
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similar. Everything else being equal, they1
should be similar. But if something pops2
out, whether it be bladder cancer or lung3
cancer or brain cancer, that just doesn't4
gel, that pushes the investigative health5
system to go further, what's in this6
neighborhood that may be causing it, to do7
further investigation.8
MR. SAUNDERS: In an indirect way,9
yes, there is a follow-up indirectly.10
MR. GRABOWSKI: Mike Grabowski. I'm11
just wondering if your house is found12
contaminated and you don't want to live13
there, you want to sell, there's a problem14
there. But the State of New Jersey has a15
disclosure on it. You have to tell the16
Realtor. What happens with that?17
MR. ROBINSON: Well, I guess that's18
one of the grey areas of the process with19
an individual property that has20
contamination on it and the property owner21
wants to sell it.22
For EPA, what we can do to a23
potential purchaser -- we can enter into an24
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agreement with the purchaser to give them a1
prospective purchaser agreement to not be2
held liable for any cleanup costs associated.3
That way it may be helpful with the4
transfer. So that he wouldn't be taking on5
liability. However, with respect -–6
MR. EVANGELISTA: And assurance that7
it will be cleaned up.8
MR. ROBINSON: Right.9
MR. GRABOWSKI: Do I have to put down10
the limit of contamination in the area?11
MR. EVANGELISTA: We would be able to12
inform them at an appropriate time when13
we've properly investigated your property14
-- if it's your property that we're15
talking about -- yes, we'll have cut lines16
as we call them, where the contamination17
is, an estimate of the volume, etc., etc.18
If someone's interested in your property,19
we can provide them with a document that20
says EPA is going to clean up this property21
and is not going to hold you accountable22
for it in any way, shape or form.23
MR. GRABOWSKI: It will be pretty24
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tough to sell the property.1
MR. EVANGELISTA: I understand that,2
sir.3
MR. GRABOWSKI: Nobody would want to4
buy it, I don't think.5
MR. EVANGELISTA: I understand. And6
I guess the other part that may give you7
comfort, we've been moving along in this8
project extremely quickly. You may look at9
other Superfund projects where an RI/FS has10
gone on for three, four, five years. We've11
completed this process in what some would12
say is record time. We did it in a year.13
And we hope to continue moving that quickly14
so that we can restore your property and15
others to a form where it may be attractive16
for selling or you may be comfortable with17
it again.18
UNIDENTIFIED SPEAKER: I own a19
property on Temple Avenue that goes right20
into Newton Creek, concreted over. My son21
was told recently by a lawyer from Malcolm22
Pirnie that -- I had wanted to either give23
him the property or sell it, get it out of24
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my hair, so to speak. And the lawyer told1
him that he would be responsible for the2
cost of the cleanup.3
MR. KERBEL: Just to be clear, it4
wasn't a Malcolm Pirnie lawyer. I don't5
know if -–6
UNIDENTIFIED SPEAKER: He had spoken7
to Steve McNally(ph).8
MR. KERBEL: Steve is right here.9
UNIDENTIFIED SPEAKER: And he was10
referred to a lawyer.11
MR. ROBINSON: I think Steve referred12
your son to me.13
UNIDENTIFIED SPEAKER: Oh, was that14
you?15
MR. ROBINSON: Yes, I'm Rick16
Robinson.17
MR. KERBEL: We don't have the18
authority.19
MR. ROBINSON: Your son spoke to me20
and I basically told your son it's in his21
best interest to talk to an attorney to22
find out from an attorney himself, his own23
attorney. I didn't give him any legal24
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advice. I just told him it would be in his1
best interest to talk to an attorney prior2
to any transfer. Because he doesn't want3
to take on any liability knowing that he's4
buying a contaminated property. I'm just5
giving him advice, you know. I would6
contact an attorney. And I was just -–7
UNIDENTIFIED SPEAKER: And if I died8
tomorrow and he inherited the property, he9
would not have to pay for the cleanup?10
MR. ROBINSON: He would not.11
MR. EVANGELISTA: And neither would12
you.13
MR. ROBINSON: It's a different story14
when someone purchased the property not at15
full-market value and they try to buy a16
property for, you know -- they know it's17
contaminated and they're getting it for,18
like, three cents on the dollar or ten19
cents on the dollar. That's where EPA20
would then go back to that person who's21
buying it cheaply and say, hey, you're22
buying it not at the fair-market value and23
we may want to get some of that money24
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back. That’s where the issue is.1
MR. BLOCK: May I say one more thing2
about the Cancer Registry? I just want to3
point out the fact that the local County4
and City here are trying to get information5
from the New Jersey Cancer Registry to do6
some type of follow-up also. So they’re7
attempting to get that information.8
The Cancer Registry information is9
extremely confidential and private. And10
it’s designed under law to be that way. So11
to get that information, sometimes you have12
to jump through hoops to try to get that13
information. But I know your City and14
County are attempting to get that15
information to do some additional follow-up16
work. Is that correct?17
MR. SAUNDERS: Yes.18
MS. CERVANTES-GROSS: Any other19
questions or comments?20
MS. MARKS: Just two more. I wanted21
to address the issue of the alternatives.22
One, obviously, was a No Action Alternative23
which, for obvious reasons, would never24
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work. The second, the Engineering Controls1
Alternative. And the third, the excavation2
and demolition of the various properties.3
Is it my understanding that the EPA4
is suggesting that the demolition and5
excavation go forward? Has a decision been6
made on that?7
MR. ROBINSON: The decision won’t be8
made until EPA hears all the public9
comments. And we’re patiently waiting to10
hear your responses today, your verbal11
comments, and any written comments that are12
submitted. As Mary Helen said earlier, our13
public comment period ends on March 3, next14
is Wednesday. So after next Wednesday, then15
EPA sits back and writes responses to all16
of the questions and will formally select a17
is remedy in a document called the Record of18
Decision. And attached to the Record of19
Decision is another document that we call20
the responsiveness summary, which21
summarizes the verbal responses today that22
we’re given and the written responses23
also.24
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So that’s why we have a court1
reporter here today and she’s taking down2
your questions and my answers. So all that3
will be part of the record.4
MR. SAUNDERS: At the local level,5
our (INAUDIBLE) is March 3. And on that6
document would be a resolution (INAUDIBLE)7
in our City that supports that. I asked8
for a telephone campaign and that would be9
such (INAUDIBLE). That is something they10
need to make (INAUDIBLE) what is the11
interest here. And we support them12
totally. It’s part of what has to occur13
and we do have (INAUDIBLE) in that office14
and our governing body (INAUDIBLE).15
MS. MARKS: And I would hope that the16
City of Camden would do likewise. Although17
would have to say in my years -- you18
think you got 25 people here tonight --19
you’ll probably be lucky if you get ten20
tomorrow night. Unfortunately, a lot of21
City residents aren’t real anxious to go22
into the CCMUA at night. So that may not23
give you a real indication. Has anyone24
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there been in touch with the mayor over the1
situation?2
MR. ROBINSON: I’ve been in contact3
with the City of Camden, the mayor’s4
assistant.5
MS. MARKS: Okay. I would like to6
see the City of Camden put forth the same7
kind of resolution to remove and excavate8
the sites.9
MR. EVANGELISTA: I guess based on10
what we’ve seen and heard thus far, it’s11
our anticipation that the decision will be,12
in fact, to excavate both Camden and13
Gloucester City.14
MR. FELLMAN: In the proposed plan,15
that’s what EPA is indicating is EPA’s16
preference. So they need to have reasons17
why not to go forward with that, as opposed18
to having to be convinced to do it.19
MS. MARKS: Okay. One more20
question. When you excavate these sites21
and remove the contaminated material, it22
will be put onto a truck and trucked out of23
the area to wherever your hazardous waste24
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facility is?1
MR. ROBINSON: Most likely we will2
probably ship it by rail.3
MS. MARKS: Okay. If you ship it by4
rail it’s obviously not going to be put on5
the train right here in Gloucester City --6
MR. ROBINSON: We would hope to find7
a site here in Gloucester City to ship it8
out.9
MS. MARKS: On rail?10
MR. ROBINSON: On rail.11
MS. MARKS: You’re going to have it12
come right from the contaminated site in13
Gloucester City to the rail?14
MR. ROBINSON: Or the nearest rail15
transfer –-16
MR. SAUNDERS: We have two staging17
areas. If you’re getting to or worrying18
about spilling something, if you have an19
opportunity I can take you to the tankers20
they go in. They are totally encapsulated.21
MS. MARKS: You’re not going to bring22
it in from Camden? Incinerator ash has -–23
MR. SAUNDERS: We have sites here in24
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Camden and Gloucester City (INAUDIBLE) put1
on a truck. Just like you had (INAUDIBLE)2
that stuff.3
MS. MARKS: what is your estimate -–4
MR. SAUNDERS; Now you said three5
weeks. That’s beyond anybody’s control6
here.7
MS. MARKS: The problem is low8
(INAUDIBLE).9
UNIDENTIFIED SPEAKER: But your10
earlier statement that the stuff was11
falling out the top and containers were12
open and totally (INAUDIBLE) totally sealed13
at the top. I wasn’t –-14
MR. SAUNDERS: They were just -- if15
your concern is about falling out -–16
MS. MARKS: That is my concern that17
some of it will be falling out as you put18
it in and maybe it isn’t all carried away.19
MR. ROBINSON: We have a lot of20
experience in dealing with contamination,21
removing radiological contamination waste.22
We just completed a very large excavation23
in an Essex County site and a number of24
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homes in orange, New Jersey and Montclair.1
That material is transported by truck and2
sent out to Utah. Trucks moving it every3
day, moving it for four or five years now.4
MS. MARKS: I wasn’t insinuating that5
there was –-6
MR. ROBINSON: The material is not7
hazardous waste; it’s radioactive waste.8
MR. GRABOWSKI: Something should be9
on those trailers. In my neighborhood10
where I have a store, kids are jumping that11
fence and playing in that area. Now why12
shouldn’t that be marked off as hazardous13
waste?14
MR. SAUNDERS: Well, as I said15
before, I hope you’re calling the police16
when children are there. The (INAUDIBLE)17
site you saw with contamination is under18
gravel and dirt. There’s a fence. In19
order to get into those trailers20
(INAUDIBLE) to get into that property.21
MR. GRABOWSKI: Why don’t you have22
signs up?23
MR. SAUNDERS: The other issue is,24
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depending on the type of radiation you1
have, it depends on how you placard it. At2
that level there isn’t an appropriate3
placard. It’s too low.4
MR. FELLMAN: The labeling on the5
container for this type of waste is6
outlined in the Department of7
Transportation regulations. And the levels8
are such, or this type of waste is such,9
that it doesn’t warrant the type of label,10
I guess, that you’re looking for.11
MR. GRABOWSKI: Now high is that12
rating on that site?13
MR. FELLMAN: The rating?14
MR. GRABOWSKI: Reading; reading.15
The reading that you’re getting.16
MR. FELLMAN: I haven’t scanned those17
containers so I couldn’t answer that other18
than to say it’s clearly elevated because19
if it wasn’t, it would not have been20
removed from the park. So there’s21
something there. How high? I don’t know.22
MR. EVANGELISTA: You’re not talking23
about placards that should be on them for24
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shipment, you essentially just want some1
warning signs for kids.2
MR. GRABOWSKI: You know, like Bob3
said, call the police. I work too and my4
wife can’t constantly sit by the window and5
watch.6
MR. ROBINSON: What we’ll do is,7
we’ll arrange for signs to be placed on the8
fence.9
MR. SAUNDERS: This is the problem we10
have. If we speak to X amount of neighbors11
and try to accommodate the wishes of most12
neighbors in this township, that’s the13
problem. we’re never going to make14
everybody happy. Some people want signs.15
The vast majority of people indicate to me,16
if we don’t have to have signs, they really17
appreciate it.18
MR. FELLMAN: They want it to be19
invisible. They don’t want signs right20
next to their homes.21
MR. GRABOWSKI: I think it’s stupid.22
MR. FELLMAN: And you’re entitled to23
that opinion. But this is what people are24
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telling Bob and other folks.1
MR. GRABOWSKI: They’re afraid2
because if they want to sell their house,3
nobody is going to buy it.4
MR. SAUNDERS: It’s going to be5
remediated as soon as possible. It’s also6
going to be certified clean. And nothing7
will be done on there until that’s done.8
We can say confidently for the neighbors of9
the Popcorn Factory, that site is safe for10
you and everyone else. And we say that11
with full confidence. The items that are12
staged there will be removed. Those types13
of things are there to make sure that the14
residents, children and everyone else are15
safe. We’re not going to tell you things16
that we don’t know as exist today.17
UNIDENTIFIED SPEAKER: Mike sees18
these people in the suits, but they’re19
dealing with the removal every day. But if20
you go and you walk, you’re not going to21
get that type of exposure. Is that what22
you’re concerned about, Mike?23
MR. GRABOWSKI: No. The children in24
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the neighborhood. I live catty-corner from1
that. I don’t know if my property is2
contaminated or not.3
MR. SAUNDERS: In order for the kids4
to get into the containers -–5
MR. GRABOWSKI: They’re not getting6
into the containers. They’re covered. But7
they’re getting into the property8
(INAUDIBLE) before the fence (INAUDIBLE).9
MR. SAUNDERS: I think even if you10
patrolled it (INAUDIBLE). It’s an example11
of overkill. The City has done more to12
protect our residents than (INAUDIBLE).13
Required us to put more gravel at the site,14
to be more protective of our residents. So15
even if a child is standing (INAUDIBLE),16
it’s somewhat misleading that the17
contamination is underneath.18
So again, as Alan said, (INAUDIBLE)19
it’s, like, months and months and months of20
not moving it. We used overkill and are21
protective of that site. And I appreciate22
your concerns. And they’re valid. And23
we’ve taken -- if they tell us this is good24
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enough, we go a few more steps.1
UNIDENTIFIED SPEAKER: As far as2
getting from point A to point B, I live in3
the (INAUDIBLE) hundred block of Somerset4
Street. And as a truck would back in, they5
would put a tarp down. The truck would6
back over top of this tarp, seal it, and7
actually broom the truck off and everything8
around those tires was broomed off. I9
thought it was total overkill protection10
for us, the residents of the City, and I11
loved it. Before that truck moved, three12
or four guys would walk around it and sweep13
every tire, every little nook and cranny.14
It was amazing how they did it.15
MR. EVANGELISTA: In addition to16
that, getting back to the containers on the17
Popcorn property, not only are they covered18
with the locked covers, but inside the19
material is covered with clean fill. So20
even if someone opens the cover and gets in21
there, they’re jumping onto -–22
MR. GRABOWSKI: I didn’t know you had23
clean fill on top of that.24
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MR. EVANGELISTA: So there’s that1
additional protective measure that’s been2
taken. Like the gentleman said, everything3
is done with overkill.4
MR. SAUNDERS: They are metal too.5
The tops are sealed shut metal units, not6
open containers. There are several things7
they would have to do to get to the8
problem.9
MS. CERVANTES-GROSS: Any other10
comments or questions? Thank you for11
coming and, again, you have until next12
Wednesday if you have any other questions13
or comments. And you may have seen on the14
board outside here, there is additional15
information on the individual properties in16
the areas. Thank you.17
********18
MS. CERVANTES-GROSS: Can we go back19
on the record for some additional comments,20
please?21
MS. GRAHAM: Theresa Graham and Ed22
Gorman, Chairman of the Community23
Playground, Fort Nassau, that will be24
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placed at Johnson Boulevard right in the1
middle of the jogging track. And our2
concerns are the safety of any contaminants3
on there. we were told that an overall was4
done of the top of it and there doesn’t5
appear to be any right there.6
And our concern is that we’ll put7
$110,000 into the building of this8
playground and then come April 7th or 11th9
we’ll have it finished, and then what10
happens to it if later on you find11
something there. We want to be assured12
that our property, if anything has to be13
done, will be taken care of by DEP, I14
guess.15
MR. GORMAN: By somebody.16
MR. GRAHAM: By Somebody. Because a17
lot of time and effort on the part of this18
community as a whole has gone into this19
project. And we want to safeguard the20
children of the community above all.21
MR. GORMAN: Is there any fast22
tracking or something they could test23
before we actually build it on April 7?24
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MS. GRAHAM: Is there any kind of a1
boring that they could come down and do to2
totally assure us? Because we’re already3
contracted in for the beginning of this4
project on the 7th. Thank you.5
********6
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94
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C E R T I F I C A T E1
STATE OF NEW JERSEY2
I, LINDA A. BURNS, Shorthand Reporter and Notary3
Public of the State of New Jersey, do hereby certify4
that I reported the public hearing in the5
above-captioned matter and that the foregoing is a6
true and correct transcript of the stenographic notes7
of testimony taken by me in the above-captioned8
matter.9
I further certify that I am not an10
attorney or counsel for any of the parties, nor a11
relative or employee of any attorney or counsel12
connected with the action, nor financially interested13
in the action.14
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Dated: March 4, 199924
Appendix D
Written Comments
R E S O L U T I O N
#R- 058 -99
A RESOLUTION ENDORSING THE ENVIRONMENTAL
PROTECTION AGENCY'S PLAN FOR CLEANUP OF RADIOLOGICALLY
CONTAMINATED PROPERTIES
WHEREAS, the United States Environmental Protection Agency has investigated various
sites in Gloucester City and Camden in relationship to the Welsbach/General Mantle Superfund
Contamination Site, including the four areas in Gloucester City listed below:
a) Study Area Two – an industrial zoned property along the Delaware River, formerly
occupied by the Welsbach Corporation and a residential area to the immediate east.
b) Study Area Three – residential and recreational properties, including the Johnson
Boulevard Land Preserve;
c) Study Area Five – residential properties, vacant land properties, and two municipal
parks near Temple Avenue an the South Branch of Newton Creek,
d) Study Area Six – vacant lots in a residential zoned area of Gloucester City; and
WHEREAS, the E.P.A.’s investigations have shown properties in the above stated locations
to contain soil contaminated to varying degrees with thorium, radium and uranium. which are
associated with waste materials generated in the manufacturing activities that took place at former
Welsbach Gas Mantle facilities; and
WHEREAS, the E.P.A. has proposed the following alternatives to address the findings
stated above:
a) No action;
b) Installation of engineering controls;
c) Excavation and off-site disposal of contaminated materials, and
WHEREAS, the locations of this contamination are almost entirely located in residential and
recreational areas, and the cost of excavation did off-site disposal, estimated to be $31,912,120.00,
shall be born entirely by the United States Environmental Protection Agency.
NOW, THEREFORE. BE IT RESOLVED that the Mayor and Common Council of
Gloucester City do hereby endorse the excavation and off-site disposal of contaminated materials from
the Welsbach/General Mantle Superfund Contamination Sites which are located in a Gloucester City.
D E G N A N & B A T E M A N, I N C.
(609) 547-2565
1
2
U.S. Environmental Protection Agency's (EPA's)3
Proposed Plan for Cleanup of Superfund Sites4
Public Hearing5
6
February 24, 19987
8
Public meeting of the U.S. Environmental9
Protection Agency (EPA) held at the Camden County10
Municipal Utilities Authority Auditorium, Camden,11
New Jersey, before Linda A. Burns, Shorthand Reporter12
and Notary Public of the State of New Jersey, on the13
above date, commencing at 7:00 p.m.14
15
16
17
18
19
20
21
22
23
24
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MS. CERVANTES-GROSS: We're going to1
go ahead and start. I just wanted to thank2
everyone one coming here tonight and we'll3
be giving you several presentations4
tonight. My name is Mary Helen5
Cervantes-Gross. I'm with the EPA and I'm6
here actually, standing in temporarily, for7
Natalie Loney whom most of you know. She8
just had a baby boy on February 14 and she9
will be back out here in the future to work10
with you again.11
But with us here tonight is12
Rick Robinson, Project Manager for the13
Welsbach General Gas Mantle Superfund site;14
Pat Evangelista, who is the team leader15
with the EPA overseeing various types of16
radiation sites and other types of sites17
throughout the region. Here as well is18
Arthur Block with ATSDR. He works with the19
EPA's Agency for Toxic Substances and20
Disease Registry, as well as a consultation21
business on health-related issues. Here22
tonight also is Alan Fellman as well as23
Bob Kerbel, both with Malcolm Pirnie who24
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are contractors for EPA working on both1
investigation of the sites and put together2
much of the information that you will hear3
tonight.4
And I just wanted to remind everyone5
that what you say tonight, whatever6
questions you have, what comments you have7
- - we have Linda Burns here who is a8
stenographer and who is officially taking9
down all of your questions and comments and10
they will go into the official record. And11
at the end of the public comment period,12
which ends next Wednesday, March the 3rd,13
we will review all of the comments what we14
have received both here tonight and at the15
meeting that we had last night in16
Gloucester City. We will also review any17
written comments that we have, and we will18
prepare a responsiveness document answering19
or responding to any comments that you20
have. As well, all of these comments will21
be looked at before we make a final22
decision, because that's what we do with a23
Superfund program. Throughout the program24
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we come out to the community before we make1
final decisions in an attempt to answer any2
questions or concerns you have, so that we3
are sure to address those in its final4
decision.5
So with that I will turn it over to6
Pat who will talk to you a little bit about7
the Superfund program in general.8
MR. EVANGELISTA: Welcome. Before I9
get started in my part of the meeting this10
evening, I'd like to introduce to you, as11
well, Fred Mumford who is here representing12
the New Jersey Department of Environmental13
Protection. What I'd like to do in getting14
the meeting started is to just talk to you15
a little bit about the Superfund process16
and how it works and just to familiarize17
you or remind you of how it works.18
Back in 1980 Congress handed the EPA19
a law known as the Comprehensive20
Environmental Response and Liability Act21
and amended it five or six years later. So22
it's what we're working with at this site23
today.24
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It starts out with what's known as1
discovery. Discovery is the part of the2
process where we are actually made known of3
the site and it warrants us to follow up4
and perform what's known as a preliminary5
assessment or site inspection where we6
gather information that we need to do7
what's known as a hazard ranking. In8
performing the ranking we generate what's9
known as a hazard ranking score. And if10
that score is or exceeds 28.5, the site11
ends up on what's known as the National12
Priorities List.13
This allows us as EPA to perform14
what's next in the process and this is15
known as a remedy investigation feasibility16
study. That's what we would call the more17
detailed investigation of the site to18
gather all of the information that we need19
about that site to generate alternatives20
that we would look into for remediating the21
problem or cleaning up the problem. And22
those alternatives are evaluated in the23
feasibility study part of that remedial24
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investigation.1
The alternatives are then evaluated2
according to certain criteria and, you3
know, at the end of that process we would4
recommend a cleanup alternative that we5
would put before you, the public, and6
concerned citizens. And that part of the7
process is what's known as the proposed8
plan.9
The proposed plan is what we10
presented as of February 1 and is subject11
to your review and comment. And that's12
part of the reason why we're here tonight.13
As a result of the public comment14
period, we generate what's known as a15
transcript, hence our stenographer here.16
And that transcript is added to the record17
of decision which formalizes the agency's18
decision, your comments inclusive, of19
course.20
After that we enter into what's known21
as remedial design. We actually design the22
nuts and bolts of the remedy that the23
agency has selected.24
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From there we enter into the cleanup1
phase and ultimately we certify it as clean2
and acceptable for future use. And we3
delete the site from the National4
Priorities List.5
That's basically the process. If you6
have any questions I'd be happy to answer7
them for you later. Thank you.8
MR. ROBINSON: I'll just go into a9
little bit of background on the site. As10
most of you know the site is located both11
in Camden and in Gloucester City. And it12
comprises the two former gas mantle13
manufacturing facilities. It also includes14
residential properties, commercial15
properties, municipal park lands in16
Gloucester City and vacant land.17
As part of the State's investigation18
early on, they divided the sites into study19
areas. And for the purposes of our20
investigation we followed those study21
areas. And the first study area is where22
we are right now in Camden around the23
General Gas Mantle facility and the24
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surrounding properties. Study Area Two is1
Gloucester City, the former Welsbach2
facility. Study Area Three is also in3
Gloucester City. It comprises residential4
properties and land preserve. Study Area5
Four, some residential properties in the6
Fairview section of Camden. And Study Area7
Five, residential properties including8
municipal parks in Gloucester City. And9
Study Area Six is also some vacant land10
properties in Gloucester City.11
Again, Study Area One is around the12
General Gas Mantle facility here in13
Camden. And this is a photograph of the14
area and the General Gas mantle building is15
highlighted. There’s a photograph of the16
famous General Gas Mantle building.17
Study Area Two is the former Welsbach18
facility, it's now owned by Holt. The19
Gloucester terminal is there on Kings20
Street. And the Armstrong building is the21
last remaining building from Welsbach's22
operation.23
Study Area Three is Gloucester City24
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and it comprises the swim club area and1
Johnson Boulevard Land Preserve.2
Study Area Four is in the Fairview3
section of Camden. And we only had a few4
properties in that area that had some5
elevated gamma radiation levels.6
Study Area Five is Gloucester City7
and comprises a dump area off of Temple8
Avenue and municipal park lands.9
Study Area Six is a newer identified10
area in Gloucester City. We call it the11
Popcorn Factory.12
Site history: In about 1885 a13
Dr. Carl Auer von Welsbach invented the14
process of using thorium, to manufacture gas15
mantles. And just to let you know, gas16
mantles are the material that's used for17
camping lanterns or in the street lights.18
Right there is a gas mantle (indicating).19
And what they did is they took a sock of20
material and dipped it in a solution of21
thorium. And when the sock dried and they22
lit it, it produced a very brilliant white23
light. And as a result the thorium is24
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radioactive. And that's what we’re here to1
clean up.2
In the 1890s Welsbach started3
manufacturing the gas mantle and by the4
turn of the century they were the world's5
largest manufacturer of them. And in the6
early ‘40s they went out of business when7
the electric light put gas lighting out of8
business basically.9
Very little is known about General10
Gas Mantle. We know they operated from11
around 1912 to 1941. We just know that12
they probably used radium and thorium.13
They didn't manufacture -- they didn't14
process any ores. They just bought the15
ores -- bought the refined radium and16
thorium. And they manufactured gas17
mantles.18
What we’ve termed all of the other19
properties that are associated with the20
radiological contamination here, besides21
the Welsbach facility and the General Gas22
Mantle facility, we call them vicinity23
properties. And they were contaminated24
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either from disposal of ore tailings from1
Welsbach, or building debris from when they2
knocked some building down, or when they3
built the bridge back in the early ‘50s, or4
from workers bringing contamination home5
with them.6
Previous investigations: The site7
was initially identified in 1980 as a8
potential radiation site during search of9
the U.S. Radium site in Orange, New10
Jersey. And in 1981 EPA sponsored an area11
fly-over to search for gamma radiation.12
And a helicopter came over the area looking13
for excess gamma radiation levels.14
In the mid-1980s the State went out15
conducting preliminary screenings in the16
area. And in the early 1990s they17
investigated over a thousand properties18
throughout Camden and the Gloucester City19
area. Based on those results they20
identified about 20 properties that they21
felt that needed more immediate action.22
And as a result they installed some23
radon/thoron ventilation systems in some24
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homes. They put concrete or steel sheeting1
down to shield for gamma radiation. And2
they purchased one property in Gloucester3
City and relocated the resident.4
Also, in 1992 they removed5
radioactive materials from the old General6
Gas Mantle building. They relocated the7
occupant at the time, Ste-Lar Textiles.8
And they sealed up the building to restrict9
access.10
The State investigation: They base11
their contamination levels on surface12
exposure rates, indoor radon sampling and13
limited surface soil samples. However,14
they didn't perform any subsurface15
sampling. They made no estimate on the16
amount or extent of contamination. And17
they were just looking to address any of18
the immediate potential health concerns at19
the time.20
EPA's involvement at the site, again,21
when the site was placed or took the lead22
-- we took the lead on the site when the23
site was placed on the Superfund list back24
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in June of 1996. Currently, the General1
Gas Mantle facility is inactive and boarded2
shut. Welsbach is an active facility, now3
owned by Holt. And the vicinity4
properties, any immediate health treats5
were either addressed through interim6
measures performed by the State or by EPA7
removal action last December in the park in8
Gloucester City.9
I'll now turn it over to Alan Fellman10
from Malcolm Pirnie and he will give you a11
real brief overview on radiation.12
MR. FELLMAN: I just want to spend a13
few minutes going over a couple of the14
terms regarding radioactivity that will15
hopefully make it a little easier for you16
to understand.17
Some of the things we're saying about18
the conditions of these properties, when we19
talk about radioactivity we're not talking20
about a typical product that we measure in21
pounds or address in terms of mass. We're22
more concerned with the amount or the rate23
at which the radioactive atoms are24
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decaying. And the unit that we use to1
describe that is called pico Curies, which2
we abbreviate pCi.3
Now when we have radioactivity in4
soil, we express the amount as5
concentration in pico Curies per gram of6
soil. And if we're talking about7
radioactivity in water or liquid, then we8
would express it as pico Curies per liter,9
pCi/l.10
Again, now this is only indicative of11
how much there is. It doesn't really12
address the dose or the risk. To do that13
we need some other terms. The dose of14
radiation is expressed in the unit known as15
millirems. And what we are expressing when16
we quantify millirems, that’s a measure of17
how much energy, which is released from the18
radioactive emissions, is transferred from19
those atoms into an absorbing media such as20
the human body. The amount of energy21
that's deposited is used to determine what22
the dose is and, of course, the higher the23
dose the higher the risk.24
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There are several different types of1
radioactivity that are emitted from2
thorium, uranium, radium, radionuclides3
that are associated with this waste4
material. Alpha particles are the heaviest5
of these. They have mass. They travel6
very slowly. And they can be shielded by7
something as thin as a piece of paper.8
Beta particles are intermediate in9
penetrating ability. They can be10
transferred through a piece of paper but11
are more likely to be stopped by a piece of12
wood.13
On the other hand, gamma radiation,14
also known as photons, have no mass.15
They're simply packets of energy. And they16
are also sometimes referred to as17
penetrating radiation. These are things18
that are more likely to get through paper19
or wood. And it takes something denser or20
thicker to shield them, such as concrete or21
lead.22
The problem that we have here for the23
most part has to do with the radioactive24
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residue being present in dirt. And when1
the dirt gets moved from the Welsbach or2
General Gas Mantle facility onto an3
adjacent or vicinity property, it can be4
put in the ground either adjacent to a5
structure or in some cases beneath a6
structure. When the radioactivity decays7
several of the -- most of the radionuclides8
are solid. They don't travel; they don't9
really go anywhere. They stay where they10
are placed. But at one point in the11
process the resultant atom that's formed is12
a gas, radon. And if the radon gas is13
formed in soil that's either up against the14
side of a building or beneath the building,15
now you've got something that's mobile and16
can emanate from the soil into the building17
resulting in a potential medical threat.18
For people who don't have that19
problem but where there's this type of20
radioactivity associated with the soils21
some distance from a structure, in that22
case the potential exposure to the gamma23
radiation that's emitted from the ground is24
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part of the radiation dose to a person1
occupying that area.2
Also, the next few minutes will be3
spent going over the field investigations4
that Malcolm Pirnie has performed for EPA5
over the last couple of years and6
Bob Kerbel will be talking about that.7
MR. KERBEL: I know some of you were8
here at the meeting we had a year ago, but9
I'll just go over in the nutshell again the10
type of work we've been doing in the two11
communities. We did investigations at the12
former Welsbach facility and the General13
Gas Mantle facility, they are industrial14
facilities. Now anything beyond the border15
of those two facilities we term vicinity16
properties. The term residential property,17
that's categorized into the vicinity18
property category.19
Now, if there's anything good from20
our standpoint as investigators, it's that21
this material is easy to detect. We have22
meters that we walk over the property and23
it's easy to detect if there's an elevated24
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radiation level. So we did that on all of1
the properties. And then if we found an2
elevated radiation level we would go back3
and take a radiological sample and send it4
to the laboratory to confirm that it was5
indeed due to thorium or radium.6
On the industrial sites, given the7
industrial nature of the property, we also8
checked for chemical contaminants. One of9
the focuses of our RI/FS report that we're10
putting together is to come up with a cost11
of how much it would cost to clean this12
up. So we need a volume. So if there was13
contamination, we had to know how deep the14
contamination was. So we put in shallow or15
deep borings, depending where we were. If16
you notice, there’s not a deep check mark17
on the soil borings for the vicinity18
properties. That’s only because, in19
general, the contamination was really on20
the surface of the property. As Alan was21
telling you, radon gas can get in a home so22
we check for radon in any structure that23
might have been on a property. And we also24
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did alpha/beta measurements for structural1
material sampling. Because in some cases,2
especially on the industrial properties,3
the contamination wasn't always associated4
with soil but the building material5
itself.6
Let me work you through this so you7
can kind of understand the process. This8
is an old picture of the Welsbach facility9
which existed about, you know, the early10
part of the century. Just to give you some11
bearings here because I know it's not a12
good picture. The Delaware River is on13
top. You can see the smoke stack of that14
facility. Kings Street is on the bottom.15
This is Gloucester City. But if you can16
imagine, they made these gas mantles at the17
beginning of the century. The hazards18
associated with any materials having19
radioactivity associated with it really20
weren't known at that time. Things like21
X-rays were just being discovered and22
nuclear power -- things like that were23
decades in the future yet to come.24
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But as years went by and in the past1
couple of decades, we became aware of the2
hazards that could be associated with any3
radioactive materials. And someone4
prudently said we should go back to all of5
these facilities that operated in the early6
part of the century and check to see if7
there were, indeed, some radioactive8
materials associated with those9
properties.10
So if you could imagine, you had a11
facility like this (indicating) and you had12
this mound, basically, of sandy-like dirt13
that was there and they processed the14
is thorium out of that sand. So what happened15
is years later we go back to that property16
to see if we can find anything. of course,17
the facility is gone by now. But the18
circle showing where the facility used to19
be, it's actually a large 52-acre sprawl at20
this cargo area.21
But if you could imagine, let's say,22
if you had these large buildings, they23
probably had large basements associated24
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with them. And they knocked down the1
building, you would assume, and maybe put2
them in those large basements and paved3
over it. So the first thing we would do is4
go over this entire property doing the5
surface exposure rate we talked about to6
look for elevated levels of gamma7
a radiation. And we did that over the course8
of several weeks. And then we take that9
information back with us to our office and10
we have computer programs where we can look11
at the data.12
And we go back now, this is a bird's13
eye view looking down at the facility, and14
is all the different colors are where we do15
have elevated levels of radiation. So16
clearly there was something and is17
something on that property. We go back to18
locations like this and take soil samples19
to see that it is thorium causing the20
elevated levels, and it is. And we do the21
borings to see how deep it is to come up22
with a volume. So that’s really what goes23
on at the Welsbach facility.24
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To jump a little closer to home here1
in Camden, to tell you a little bit about2
what we've done. This is the General Gas3
Mantle facility. And as Rick told you,4
it's boarded up now. And as Alan alluded5
to, this material gives off radon gas. But6
there's no ventilation in this building7
because the windows are all boarded up. So8
when we go in there to work in that9
building, there are elevated levels of10
radon levels. There is soil that is11
contaminated under the building and12
adjacent to the building. And it does come13
out somewhat onto South Fourth Street,14
along with the sidewalk and into the street15
somewhat.16
So that will eventually need to be17
removed or remedied as Rick will talk18
about. The building is vacant. There are19
wood floors. Those woods floors as well20
have some contamination associated with21
it. So if this building were to be22
demolished there may be a need to remove23
those floors before any demolition takes24
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place.1
I just wanted to touch on this now2
but Alan will come back and talk a little3
bit more about risk. But when we do work4
on properties like this, it's not like5
we're all dressed up in special equipment.6
We wear our regular work clothes and we7
walk throughout the building with the8
meters. A real hazard that's associated9
with it, from our standpoint, is if we have10
somebody fall through a floor while we're11
in the building rather than the radiation12
problem itself. But Alan will talk a13
little bit more about risk.14
We'll talk about the vicinity15
properties now. One of the problems is16
there is such a large geographical area17
associated with this site where18
contamination could end up. If we were to19
have gone throughout the whole community20
and start from scratch, it would have taken21
us years to do this. But fortunately the22
State and Fred's group, they were here23
previously and they went through over a24
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thousand properties and investigated those1
properties.2
Now, when we started this project we3
didn't want to go out and reinvestigate all4
of these properties. We wanted to use the5
State's data. But we had to be sure we6
could use that data. So we went to 207
properties and we compared our data to the8
State's data. And we agreed that we can9
use the State's data to somewhat categorize10
these properties.11
We went through all of the State's12
data and we categorized the properties13
something like this. Ballpark thousand14
properties that the State went to,15
approximately half, 449, we don’t see any16
evidence that there’s contamination17
associated with those properties. Then we18
have the category we call suspect19
properties. It's a pretty large grey area20
for us. What that category means is that21
we’re not 100 percent sure that they're22
clean. We're not 100 percent sure that23
they may be contaminated either. But we do24
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want to go back and test those properties.1
If a property was simply adjacent to2
contaminated property, we call that a3
suspect property and we put it in this4
category. If it had an elevated radon5
level -- many homes in New Jersey have6
elevated radon. But in this case we tend7
to ask ourselves, is that due to normal8
radiation associated with the soil or is it9
due to the Welsbach facility. We're not10
sure right now so we want to go back and11
check.12
There's radiation all over. It's a13
natural thing and it ranges. There's an14
average. It's high in locations and low in15
others. In some cases you could live in a16
brick home and the levels could be higher17
than you normally expect. But we would put18
it in this category. So there are S8519
properties that we would want to go back to20
now and kind of do additional testing21
eventually and either move them over to the22
clean category or if we needed to move them23
to the contaminated properties category.24
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And then finally there's a category1
where we have potentially contaminated --2
they are properties that, based on the data3
we have available, the evidence suggests4
that there is contamination on those5
properties. And we used our investigation6
from the 20 we went to to come up with a7
volume of materials to estimate a cleanup8
cost associated with the project. And Rick9
will come back and talk a little bit more10
about that in a couple of minutes, right11
after Alan talks a little bit more about12
health risks.13
MR. FELLMAN: Before you can really14
get a handle on the risk from exposure to15
radiation, it's helpful, I think, to16
understand that we live on a radioactive17
planet. And as a result we're constantly18
being exposed to natural sources of19
background radiation. The items that are20
listed on this table break down the21
components of background radiation.22
We are radiated from the atmosphere.23
we receive radiation from natural levels of24
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radionuclide in soil and rock, many of the1
same radionuclide that we have in the waste2
stream at the Welsbach and General Gas3
Mantle facilities; uranium, thorium,4
radium.5
Inhaled radioactivity, that 2006
milligrams per year, is the average dose in7
North America from radon gas. Any time you8
put four walls and a ceiling together,9
you're going to get some level of indoor10
radon that's going to deliver a dose. And11
the average radon level is about one to one12
and a half pico Curies per liter there, and13
that's going to give you your 20014
milligrams.15
Internal emitters is referring to the16
various radionuclide that we store in our17
body tissues. As a reflection of the fact18
that there's radioactivity naturally in19
soil, then when we grow fruit and20
vegetables and all sorts of products, some21
of that radioactivity is taken up and some22
of it is ingested. There's natural23
potassium which is an essential24
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micronutrient. We ingest potassium in lots1
of different products. A small fraction of2
that potassium is radioactive.3
So we carry around these4
radionuclide. We ingest them every day.5
we excrete them every day. And as a result6
of their being in our bodies, we're exposed7
to a dose of about 40 millirem per year.8
There's also a whole lot of9
radioactivity in lots of different types of10
consumer products. And as you read through11
some of these, you can see that there's12
quite a range. And I brought a couple of13
items that add to those.14
This is Morton salt substitute. if15
you need to keep your sodium intake to a16
minimum because of high blood pressure or a17
cardiac problem, your doctor may suggest18
that you use potassium chloride instead of19
sodium chloride. And as I just said, some20
potassium is radioactive. And there's no21
way to separate out the radioactive22
potassium from the nonradioactive23
potassium.24
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This instrument is known as a pancake1
detector. And as you can hear, from2
natural sources it has a very low3
efficiency, you'll get sporadic clicks.4
When I hold the salt substitute up, you get5
a slightly positive response and it's easy6
to hear the difference. Again, that's7
natural potassium in the salt substitute8
that the detector can see.9
Here is a smoke detector. Everybody10
should have these in their home. And one11
of the components of the smoke detector is12
one micro Curies of Americium 241, a13
man-made radionuclide. And when I hold14
this meter up to the source, again you can15
hear the instrument respond.16
This is a piece of Fiestawear (ph).17
It's made in the Southwest, covered with a18
glaze known as yellow cake. And that glaze19
has a lot of natural uranium in it.20
There's a lot of radioactivity here. There21
are people who eat off of these and you'll22
find these in antique shops, at antique23
shows all around the country. So I can24
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either leave that here and radiate my1
colleagues or move it back out of range a2
little bit.3
We’re concerned about radiation dose4
because radiation is a known carcinogen.5
That is the only health affect that we need6
concern ourselves with. There are no acute7
short-term health problems associated with8
exposure to radiation with the exception of9
very, very high doses which are not10
possible from environmental issues such as11
what we have here.12
So we're worried about cancer. We13
know that people who have been exposed to14
very high levels of radioactivity in those15
populations, there is most definitely an16
increase in the incidence of cancer. When17
we set public health policy in this18
country, we assume that there is a risk of19
cancer when we're exposed to any dose of a20
carcinogen, no matter how small. Now, the21
fact of the matter is, when we look at the22
scientific data, we don't really know if23
that's true or not.24
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Because what we have here is, again,1
what's known as a dose response curve or2
dose response line. As the dose increases3
-- so up here in this range (indicating)4
we're looking at high doses such as the5
Japanese who survived the atomic weapons6
blast, groups of patients who were radiated7
for various ailments in the ‘30s or ‘40s8
before medical science realized that that 9
wasn't the way to go. The radium dial10
painters who were basically ingesting11
radium while they painted watch dials12
during the 1920s. Several of them died13
from acute illnesses but most of them14
survived and went on to live 20, 30, 40, 5015
years. And in that group there was16
elevated cancers. So these are groups who17
got very high doses and we know that the18
incidence or cancer or the health effect or19
risk was elevated.20
Now we get down to the lower end of21
the curve where I showed you, just a few22
minutes ago, background radiation, that we23
all get a couple hundred millirems per24
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year. So now we're down in this area of1
the curve (indicating). And now we've got2
this type of a waste stream where there may3
be additional exposure on the magnitude4
similar to what we're getting from5
background. And what do we know about6
that?7
Well, we don't have any scientific8
data that would show that people who are9
exposed to these levels are actually going10
to suffer increased numbers of cancer. We11
don't know that. The scientific studies or12
physical tests are not powerful enough to13
discern that when we're talking about a14
disease or group of disease that is15
afflicting one out of every four Americans16
to begin with. So you just can't measure17
it at these low levels. This is what we18
call an area of great uncertainty.19
However, EPA’s policy is to assume20
that there is some risk at these low21
levels. And when the risk that we22
calculate based on the data that we23
generate during our studies, when that is24
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placed in a risk assessment model and it1
shows us a risk that's unacceptable2
relative to the acceptable risk range that3
EPA has established, EPA can then use that4
information as the basis to go forward with5
the cleanup.6
And now I'll let Rick talk about7
cleanup alternatives.8
MR. ROBINSON: For the Welsbach/9
General Gas Mantle site we evaluated10
cleanup alternatives for the three property11
types we just discussed: The Welsbach12
facility, the General Gas Mantle facility,13
and for the vicinity properties. The three14
alternatives that we looked at were the No15
Action Alternative; an Engineering Controls16
Alternative; and Excavation and Off-site17
Disposal Alternative.18
As part of the Superfund process, EPA19
has to look at a cleanup based on a No20
Action Alternative. What if we did21
nothing, what would be the result? And22
based on the risk assessment that Alan just23
explained a little bit, we found that there24
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was a risk and, therefore, we were going to1
take an action. And as a result, we're not2
going to talk about no action anymore.3
For the vicinity properties, the4
Engineering Controls Alternative, it would5
require outdoor gamma shields on 506
properties; indoor gamma shields on about7
20 properties; and radon mitigation systems8
on about 4 properties. And the excavation9
and off-site disposal alternative, if any10
property was found to have contamination11
above our cleanup levels, we would take the12
material off site for disposal, dig it up13
and take it off site.14
The Welsbach facility, again, the15
Engineering controls Alternative, we would16
put outdoor gamma shields on the property.17
We would have to have deed restrictions18
limiting future site work. And we would19
have to go back every five years to make20
sure that the remedy would still be21
effective.22
For the excavation and off-site23
disposal alternative for the Welsbach24
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facility, again, we find the contamination1
above our cleanup level so we would dig2
that material up and send it off-site for3
disposal.4
For the General Gas mantle facility,5
Engineering Controls Alternative would6
require outdoor gamma shields around the7
outside of the building. We would have to8
permanently board-shut the building. We9
would have to have deed restrictions10
limiting future access to the site. And we11
would have to go back every five years to12
make sure the remedy would still be13
effective.14
Then for the General Gas Mantle, the15
excavation and off-site disposal16
alternative, we have two operations. The17
first option is we would take the building18
down and dispose of the whole building as19
contaminated material. The second option,20
option B is we would first try to21
decontaminate the building, take the22
radioactive material out of the building.23
And that would reduce the volume of24
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materials that would have to be sent1
off-site for disposal.2
The alternatives of the engineering3
controls, again, just to summarize, we4
would have to have deed restrictions on the5
property limiting future site work. The6
State would have to be responsible for7
enforcing those restrictions. And we would8
have to go back every five years to make9
sure it would still be effective.10
For the excavation and off-site11
disposal alternative, all of the12
contamination above our cleanup standards13
would be excavated and sent off-site for14
disposal. And that would result in, again,15
the contaminated materials being removed16
from the site. Mobility of the17
contaminants would be eliminated. And18
there would be no significant institutional19
controls remaining on the properties at20
all. The properties would be safe for21
future reuse and protective of human health22
and environment.23
Just to go over the summary of the24
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costs, for the engineering controls for the1
vicinity properties would be about a little2
over $2 million. And for the excavation3
and off-site disposal on the vicinity4
properties, just over $13 million dollars.5
For the former Welsbach facility, the6
engineering controls just under $6 million7
dollars. And for the excavation and8
off-site disposal alternative, eighteen and9
a half million dollars.10
For the General Gas Mantle facility,11
the engineering controls is just under12
$400,000. And the excavation and just the13
demolition and disposal alternative option,14
just over $2 million dollars. And for the 15
decontamination and demolition, just under16
$2 million dollars.17
EPA's preferred remedy action is the 18
excavation and off-site disposal19
alternative for both the vicinity20
properties, Welsbach and General Gas Mantle21
facility. For the General Gas Mantle we22
have Option B, which is the decontamination23
of the building prior to demolition. The24
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total cost of the remedy is just under $341
million dollars.2
Now we go to what do we next, the3
next steps. The first thing that we’re4
doing right now is respond to public5
comment. We're here today to take your6
verbal comments. And also, again we have a7
public comment period for written comments8
which ends next Wednesday, March 3. And we9
invite the public to send in written10
comments as well as your comments today.11
Once we receive all of the comments,12
we select a remedy in a document called a13
Record of Decision (ROD). And once we sign14
that ROD, EPA can start the design of the15
cleanup.16
Our focus will be first on the17
residential properties and then we'll go to18
the commercial and industrial properties.19
We hope to start the investigations on the20
suspect properties in the fall, later this21
year, and also start the design22
investigations on the potentially23
contaminated properties this year also.24
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And we also plan to demolish the General1
Gas Mantle building as soon as we can,2
hopefully in one to two years.3
This actual cleanup on these4
individual properties we estimate about5
three to five years from today. We're also6
in the process right now of conducting a7
ground water investigation to make sure8
that none of the contamination from the9
site is getting into the ground water. And10
we also have to investigate some wetland11
areas in Gloucester City around Newton12
Creek that are next to some of the known13
contaminated areas.14
15
16
17
18
19
20
21
22
23
24
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MR. ROBINSON: Now we'd like to open1
the meeting up for some comments and2
questions.3
MS. CERVANTES-GROSS: If you have any4
questions about what we discussed tonight.5
MR. ROBINSON: Please state your name6
for the record.7
DONNA MAGGIO(PH) (INAUDIBLE): I have8
a question with the houses on Arlington9
Street. When you say you're going to10
excavate the back yard, how deep is it11
going to go and what's going to be done for12
the people while you're doing this? Will13
this pose any problems for people? What14
is are you going to do to protect them?15
MR. ROBINSON: Right now on Arlington16
Street we have not done any volume samples17
is or estimate of the depth of contamination18
on Arlington Street. That will be done in19
the design phase. We estimate right now,20
by what we've seen on other properties that21
are similar to contamination there, the22
contamination is about one to two feet.23
Generally we try to work around the24
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residents and make sure that they're not1
severely impacted by the work.2
DONNA MAGGIO: This doesn't pose any3
sort of a problem, digging up?4
MR. ROBINSON: We're going to try to5
minimize any potential impacts through6
controls during our construction phase.7
MR. FELLMAN: The impacts are8
(INAUDIBLE). They are not health related.9
DONNA MAGGIO: That's what I'm10
wandering.11
MR. FELLMAN: When these things are12
removed, it's done in a controlled way so13
that dust is minimized. If necessary, soil14
is wet before taking it off. Before things15
are sent out, say, in a truck to travel16
over public roads, the trucks are scanned17
and the wheels. This is all done in a very18
prescribed manner so that contamination is19
not spread.20
DONNA MAGGIO: Is there a work plan,21
a document, yet?22
MR. ROBINSON: When we go to23
construction, after we've completed the24
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remedial design, we'll have another meeting1
prior to the actual demolition or the2
construction activities. We'll present to3
you our plan on how we're going to proceed4
with that phase, the action.5
MR. EVANGELISTA: We'll intend to6
make these plans available in repositories7
for review.8
DONNA MAGGIO: I have a question as9
far as the radon in the basements. Are you10
going to check for radon in the basements?11
MR. FELLMAN: Well, that's part of12
the study protocol when we go to any of the13
suspect properties. The properties that14
we've been to through the remedial15
investigation, we scan for gamma radiation16
indoors and outdoors. We take soil17
samples, put holes in the ground and take18
down hole measures, and put radon detectors19
in the basements and measure for radon.20
That's typically part of the protocol.21
The reason why there have been so few22
properties or structures with elevated23
radon out of the many properties24
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investigated here is because most of the1
contamination, where it exists, is out in2
the yard somewhere as opposed to being3
adjacent to or underneath the house. If4
you have -- like on Arlington Street where5
that kind of strip of contamination is6
toward the rear of the property, closer to7
the alleyway, the radon gas that was formed8
in that material is emanating up into the9
outdoor atmosphere as opposed to if that10
material was underneath the homes emanating11
up and would be intercepted by a house and12
get into the basement. That's when you get13
the higher level or volume of this stuff.14
MS. PULLMAN(ph): My name is Olga Pullman.15
I'd like to first of all say, great, EPA16
has selected the most thorough cleanup17
alternative of the three products. I think18
that's very important for the health and19
safety of the residents and also the future20
of this neighborhood.21
I was just wondering, to make it22
clear in my own mind what you're saying,23
the level of cleanup is going to be to24
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remove anything contaminated and bring in1
fresh fill for any empty areas? And it's2
your position that after that, that land3
could be used for anything, residential,4
playgrounds, parks, vegetable gardens, that5
level of cleanup?6
MR. ROBINSON: Yes.7
MS. PULLMAN: Is that definite? The8
money has been approved for that project?9
MR. ROBINSON: Before we can actually10
get any money for a cleanup we have to go11
through a design. Once we get the design12
altogether, we'll be going out to request13
money from EPA headquarters for the14
project. Until we complete the -- we're15
still three to five years away from that.16
As you see from our presentation, there's a17
lot of things we have to look at to gather18
information together.19
MR. EVANGELISTA: I just wanted to20
add that behind the scenes that's what's21
known as Record Review Board. And what we22
did before we identified our preferred23
alternative and the projected cost estimate24
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is we took the site and all of the1
information before this Board within EPA2
which consists of representation throughout3
the country. And they gave us a nod of4
approval that they're okay with the costs5
associated with it. We don't anticipate6
any problems in funding the project in the7
anticipated time frame.8
MS. PULLMAN: In terms of checking9
property, I happen to notice where the10
Arlington Street property is located, the11
General Gas mantle, you haven't yet checked12
the properties on the other side that's not13
shown on the map, kind of adjacent to it14
heading north. Is that something you're 15
going to include in this investigation?16
MR. KERBEL: That sounds like data17
the State collected, but we didn't in the18
last year go into these properties.19
MR. ROBINSON: Those maps were20
generated or based on information that the21
State provided to EPA. As part of our22
investigation and our next phase in the23
design, we're going to look at the24
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properties adjacent to known contaminated1
or potentially contaminated properties.2
And we'll look at those properties and add3
them on. In future maps they'll include4
other properties that the State has not5
(INAUDIBLE).6
DONNA MAGGIO: I just had a question7
with the time frame. So you think you8
could demolish the General Gas Mantle9
within one to three years?10
MR. ROBINSON: One to two years.11
DONNA MAGGIO: From now?12
MR. ROBINSON: Yes. we're hoping13
sooner. As soon as we get the remedy14
approved the sooner we'll start the process15
of taking the building down.16
MS. PULLMAN: What's going to be your17
next series of steps when you're going to18
inform the community about what's going19
on?20
MR. ROBINSON: Once we select the21
remedy and the Record of Decision -- and in22
the Record of Decision will be all your23
verbal responses today, that's why we have24
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the court reporter here, and any written1
comments submitted -- that will be in the2
responsiveness summary attached to the3
Record of Decision. Once we sign the4
Record of Decision we'll place that5
document in the local repositories: one in6
Camden's main library, one in Gloucester7
City's public library, and in the Hynes8
Center of Camden. The next public meeting9
we'll have is when we're ready to start the10
construction, most likely the General Gas11
Mantle demolition, hopefully later this12
year. If we could move the people along.13
MR. EVANGELISTA: "People" meaning14
EPA management.15
MS. PULLMAN: So, of course, you'd16
let us know if something were to happen.17
If you discover that the scope of work was18
greater than you thought and you had to19
reconsider your plans, at what point would20
you let the community know that, before you21
make the final Record of Decision?22
MR. EVANGELISTA: At this point we23
don't anticipate reconsidering anything as24
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far as what we've proposed in the proposed1
plan or discussed this evening. The only2
way that we would reconsider anything would3
be based on public comment. And based on4
what we've seen and heard thus far, both5
here and in Gloucester City, there's6
nothing indicative of our changing our7
minds.8
MR. ROBINSON: Everyone is in favor9
of us digging the material up and taking it10
off-site.11
MS. PULLMAN: Good.12
MS. CERVANTES-GROSS: In addition, as13
we pointed out, there are still 500-some14
properties that we consider as suspect15
properties. So in the design -- as we go16
through the design phase, there will be17
additional investigation of those18
properties, to include those properties in19
what we’re proposing. once we go out there20
to confirm if they have elevated levels21
above our cleanup levels, those properties22
would be included in -- most of the23
vicinity properties.24
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MR. FELLMAN: Fed into the design1
process that will be ongoing and current.2
MR. KERBEL: There's a lot of3
variability when we say contaminated4
properties. It could range from just a5
small spot where somebody might have to6
almost come in with a shovel and put it in7
a barrel and got it off; to maybe a backhoe8
might have to come in and scrape the top9
off. So there's a lot of variability.10
MS. PULLMAN: I just realized at this11
point you can't say exactly how many12
properties you're going to have to do13
cleanup and what level it will be. I'm14
just being paranoid here. At any point you15
could reconsider the plan if you rediscover16
it’s a greater scope of work or whatever.17
MR. ROBINSON: No. If we find18
contamination it will be taken away.19
MS. PULLMAN: All right.20
Ms. CERVANTES-GROSS: Any other21
questions or comments?22
Okay. I that’s it.23
MR. ROBINSON: Thank You very much24
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for attending and hopefully we’ll see you1
soon with the progress of taking the2
building down.3
MR. EVANGELISTA: There are some4
handouts that are on the table and you’re5
welcomed to take a copy.6
********7
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C E R T I F I C A T E1
STATE OF NEW JERSEY2
I, LINDA A. BURNS, Shorthand Reporter and Notary3
Public of the State of New Jersey, do hereby certify4
that I reported the public hearing in the5
above-captioned matter and that the foregoing is a6
true and correct transcript of the stenographic notes7
of testimony taken by me in the above-captioned8
matter.9
I further certify that I am not an10
attorney or counsel for any of the parties, nor a11
relative or employee of any attorney or counsel12
connected with the action, nor financially interested13
in the action.14
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Dated: March 4, 199824
RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Welsbach/General Gas Mantle Contamination, Inc. Site
Site location: Gloucester City & Camden, Camden County, New Jersey
Listed on the NPL: June 16, 1996
Record of Decision:
Date signed: July 23, 1999
Selected remedy:
Alternative (V-3) - Excavation and off-site disposal of contaminated soil.
Alternative (W-3) - Excavation and off-site disposal of contaminated soil.
Alternative (G-3) - Decontamination and Demolition of the General Gas
Mantle Building
Operable Unit: OU-1
Capital cost: $33,892,120
Anticipated Construction Completion: September 2004
O & M cost: $0
Present-worth cost: $33,892,120
Lead:
Site is currently fund lead - EPA is the lead agency
Primary Contact: Rick Robinson, Remedial Project Manager, (212) 637-4371
Secondary Contact: Pat Evangelista, Chief, New Jersey Projects/State Coordination Team,
(212) 637-4403
Waste:
Waste type: thorium, radium, uranium
Waste origin: gas mantle manufacturing, extracting thorium from ore
Contaminated medium: Soil and building materials