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RECORD OF DECISION

Welsbach/General Gas Mantle Contamination Superfimd Site

Gloucester City & Camden, Camden County, New Jersey

United States Environmental Protection Agency Region II New York, New York July 1999

500001 DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Welsbach/General Gas Mantle Contamination Superfiind 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 HI 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:

500002 • 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.

Date Regiojtfal A

500003 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:

Selected remedy:

Alternative (V-3) - Excavation and off-site disposal of contaminated soil. Alternative (W-3) - Excavation and off-site disposal of contaminated soil. Alternative (G-3) - Decontamination and Demolition of the General Gas Mantle Building

Capital cost: $33,892,120

Anticipated Construction Completion: September 2004

O & M cost: $0

Present-worth cost: $33,892,120

Lead:

Site is currently fund lead - EPA is the lead agency

Primary Contact: Rick Robinson, Remedial Project Manager, (212) 637-4371

Secondary Contact: Pat Evangelista, Chief, New Jersey Projects/State Coordination Team, (212)637-4403

Waste:

Waste type: thorium, radium, uranium Waste origin: gas mantle manufacturing, extracting thorium from ore Contaminated medium: Soil and building materials

500004 RECORD OF DECISION

DECISION SUMMARY

Welsbach/General Gas Mantle Contamination Site

Gloucester City & Camden, Camden County, New Jersey

United States Environmental Protection Agency Region 2 New York, New York July 1999

500005 TABLE OF CONTENTS

SITE NAME, LOCATION AND DESCRIPTION

SITE HISTORY AND ENFORCEMENT ACTIVITIES

HIGHLIGHTS OF COMMUNITY PARTICIPATION ...... 4

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

THE NATURE OF RADIONUCLIDES

SUMMARY OF SITE CHARACTERISTICS ...... 6

SUMMARY OF SITE RISKS ...... 10

REMEDIAL ACTION OBJECTIVES ...... 13

DESCRIPTION OF REMEDIAL ALTERNATIVES ...... 16

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

SELECTED REMEDY ...... 26

STATUTORY DETERMINATIONS ...... 27

DOCUMENTATION OF SIGNIFICANT CHANGES ...... 29

APPENDICES

APPENDIX I FIGURES APPENDIX II TABLES APPENDIX III ADMINISTRATIVE RECORD INDEX APPENDIX IV STATE LETTER APPENDIX V RESPONSIVENESS SUMMARY

500006 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.

500007 • 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 (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 discus -ed 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 manue. 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.

500008 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, ri 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.

500009 Both the Welsbach Company and the GGM Company went out of business in the early 1940s, and EPA has been unable to identify any successor companies. In September 1997, EPA entered into an Administrative Order on Consent (AOC) with Holt, the current owner of the former Welsbach Facility. Under the terms of the AOC, Holt agreed to perform a Remedial Investigation and Feasibility Study (RI/FS) on the Armstrong Building. Holt has also submitted information to support its position that it is not liable for response costs at the former Welsbach facility. EPA is currently evaluating this information.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS report, the Proposed Plan and supporting documentation were made available to the public in the administrative record file at the Superfund Document Center at EPA Region II, 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 Hynes Center, 1855 South 4th Street, Camden, New Jersey 80104; and the Gloucester City Public Library, Monmouth and Hudson Streets, Gloucester City, New Jersey 08030. Notices of availability for the documents 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 to March 3,1999.

EPA conducted public meetings in both Gloucester City and Camden to inform local officials and interested citizens about the Superfund process, to review proposed remedial activities at the Site and receive comments on the Proposed Plan, and to respond to questions from area residents and other 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 Utilities Authorities Auditorium in Camden. Responses to the comments received at the public meeting are included in the Responsiveness Summary (see Appendix V). The City of Gloucester City submitted a resolution supporting the proposed remedy. No other written comments were received during the public comment period.

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

SCOPE AND ROLE OF RESPONSE ACTION

This action is the first operable unit or phase taken to address the radiological contamination at the Site. This action will address the radiologically-cr ntaminated soil and building materials at the Vicinity Properties and the former Welsbach anc JGM Facilities. For the second operable

500010 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 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, 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 "parent11, 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

500011 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 tnt 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 l.SxlO5 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 radionuciide 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 shm 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 Pimie, Inc., under contract to EPA. In order to develop a cleanup strategy for the Site, the RI field investigations were divided into three property categories, as follows:

• Former Welsbach Company Facility; • Former General Gas Mantle Company Facility; • Vicinity Properties

Property Investigations

EPA conducted both chemical and radiological characterizations of the former Welsbach 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. 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 uR/h, radon progeny

500012 measurements less than 0.02 WL, and radon gas levels less than 4.0 pCi/1. The exposure rate represents 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 contaminated properties; and

3) "Contaminated Properties" - are properties with levels of radioactivity which potentially warrant remedial action (i.e. properties with either exposure rates greater than 30 uR/h, radon progeny greater than 0.02 WL, radon gas levels greater than 4.0 pCi/1, or thorium or radium concentration in the soil greater than 5 pCi/g.)

EPA will investigate the remaining Contaminated Properties which were not studied in the RI and the Suspect Properties during the remedial design phase of this cleanup. EPA estimates that it will study about 600 properties during 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. Table 3 summarizes the volume of contaminated soil and debris at the Contaminated Properties. 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 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 hi the area of what is believed to be the location 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. These radionuclides are principal threat wastes. 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

500013 rates associated with the contaminated soils ranged from background (less than 10 micro- Roentgen per hour [uR/h]) to 780 uR/h. The highest readings were associated with a ,arge 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 or concern, then there may be a need to remediate such historic contaminants.

Former General Gas Mantle Facility Investigation

Elevated concentrations of thorium and uranium decay series radionuclides were identified 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 Cc urrvard 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 uR/h) to 380 uR/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(uCi/m2) were observed. Indoor gamma exposure rates ranged from background to 900 uR/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.

500014 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 1000 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/1.

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.

500015 SUMMARY OF SITE RISKS

A baseline risk assessment was conducted for the former Welsbach Facility, the former GGM Facility, and the Vicinity Properties using analytical data 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 risks to aquatic and terrestrial wildlife, were not evaluated for this operable unit. However, EPA compared the levels of radioactive exposure to various species with the cleanup criteria. Based on this comparison, EPA determined that the cleanup criteria will be protective of ecological receptors for this operable unit. An Ecological Risk Assessment will be conducted in a future RI to evaluate the potential for adverse effects to aquatic and terrestrial wildlife in accordance with Ecological Risk Assessment Guidance for Superfund, Process for Designing and Conducting Ecological Risk Assessments (EPA 540-R-97-006).

To evaluate human health risks, a: ur-step process was used for assessing site-related risks for 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 from the uranium and thorium decay series (e.g., radium, thorium, radon, and radon decay products) are known human carcinogens. Nonradiological chemical contaminants (e.g., PAHs and arsenic) may exhibit both carcinogenic and noncarcinogenic health effects.

EPA's acceptable cancer risk range is 10"4 to 10"6, which can be interpreted to mean that 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. EPA usually initiates remedial action at a site when the risk estimate exceeds this range.

Human health risks were estimated for both radionuclides and chemicals of concern at the former Welsbach and GGM Facilities, and :: r radionuclides o oncera at the Vicinity Properties. Building materials and/or soil were me environmental nj?dia of concern. Following EPA guidance, risks were estimated based on a "reasonable maximum exposure" scenario. Risks were

500016 estimated as a result of exposure to site-related carcinogens based on a number of 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 scenarios were evaluated which involve exposure to external gamma radiation, ingestion of radioactive materials, and inhalation of radioactive materials. For the former Welsbach Facility, risk estimates were evaluated for current and future workers, other site workers (part-time workers), and construction workers. For the former GGM Facility, risk estimates were evaluated for current and future 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 14 residential properties investigated, and appropriate populations at the remaining six Vicinity Properties (Jogging Track, Swim Club, Martins Lake, Public Park, Land Preserve, and the Popcorn Factory.) These risks were then compared to the risk from natural background sources of radiation.

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

• Inhalation of radon decay products by residents, or occupants at commercial properties;

• 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 of radioactive materials above background levels, which exceed EPA's risk range. The maximum excess lifetime radiogenic cancer risk estimates based on reasonable maximum exposures are 5.7 x 10'2 at the former Welsbach Facility (to the current and future site worker), 1.8 x 10'' at the former GGM Facility (to a hypothetical future site worker), and 1.8 x 10'2 to a hypothetical resident of a Vicinity Property (See Tables 4 and 5.) The uranium and thorium decay series radionuclides are principal threat wastes because of these increased cancer risks.

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

500017 and 7.) However, these cancer risks do not exceed EPA's risk range and, therefore, no additional remedial 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 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 only 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 (5 ce Table 6.) 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 0.03; this hazard index is below EPA's acceptable level of 1.0, indicating that adverse, noncarcinogenic health effects from such exposure are unlikely (See Table 7.)

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 radon 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 5 around Newton Creek and associated areas of the Delaware River. An ecological risk characterization will be conducted in conjunction with the third operable unit RI 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 wide variety of uncertainties. In general, the main sources of uncertainty include:

• environmental chemistry sampling and analysis • environmental parameter measurement • fate and transport modeling • exposure parameter estimation • lexicological data

500018 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~* to 10* risk range).

500019 • 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 produc: _ ~*ater than 4 pCi/1 and 0.02 WL1, respectively.

• Prevent direct contact with building surfaces exhibiting total surface thorium contamination exceeding 0.026 uCi/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 (ALARA2) 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/1). 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 40 CFR 192 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/g. EPA, in Directive No. 9200.4-25, states that whenever :he 5 pCi/g radium soil cleanup standard is determined to be relevant and appropriate at a CZRCLA site which contains both radium and thorium in the waste, the 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 radiologically-contaminated sites in New Jersey. Applying ALARA

1 Exposure to 4 pCi/1 of air for radon corresponds to an approximate annual average exposure of 0.02 WL for radon decay products, when assuming residential land use. 2 References for ALARA principles -"Radiation Protection G_ dance to Federal Agencies for Occupational Exposure", 1987, Federal Register 5~. No.17, 26... and "Federal Guidance Report No. 11", September 1988, EPA-520U-88-020.

500020 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, and limitations of the analytical equipment to detect radionuclides.

EPA's experience at the other radiologically-contaminated sites in New Jersey has shown that the remedial action objectives noted above can be achieved by incorporating ALARA principles. Applying the 5 pCi/g cleanup standard with ALARA principles at these other New Jersey sites has resulted in exposure levels that are lower than the levels that would result from 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 of radiologically-contaminated soil. In reviewing this case, the NJDEP believes that the remedy selected in this ROD will achieve the goals in the draft proposal through the incorporation of the ALARA principles in removing the radiologically-contaminated soils and covering the excavated areas with clean fill.

The selected remedy will meet the remedial action objectives through the excavation and off-site disposal of the radiologically-contaminated soils and waste materials. 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 shipped off-site to a licensed commercial facility for permanent long- term management. For buildings, specifically at GGM, the selected remedy, decontamination, demolition, and off-site disposal of contaminated materials, will reduce exposures to 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 either the former Welsbach or 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.

500021 DESCRIPTION OF REMEDIAL ALTERNATIVES

Section 121(b)(l) of CERCLA, 42 U.S.C. §9621(bXl), mandates that a remedial action must ne protective of human health and the environment, cost-effective, and utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Section 121(b)(l) also establishes a preference for remedial actions which employ, as a principal element, treatment which permanently and significantly reduces the volume, toxicity, or mobility of the hazardous substances, pollutants and contaminants at a site. Section 121(d) of CERCLA, 42 U.S.C. §962 l(d), further specifies that a 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, 42 U.S.C. §9621(d)(4). 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.

In the RI/FS Report, EPA evaluated Remedial Alternatives for addressing the radiological contamination associated with the Site. Cleanup alternatives were evu.uated 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. Table 8 summarizes the costs of each alternative.

Vicinity Properties

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

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

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

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.

500022 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 of 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. A total of 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: $ 13,408,560 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 background 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 may be required at one property.

500023 The estimated time to design and construct the remedy is 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 p^vent dust generation and protect workers would be required. EPA will develop a wetland mitii. . on plan if it disturbs wetland areas by remedial activities.

Welsbach Facility

The former Welsbach Facility is presently owned and operated by Holt as a cargo storage and oversea shipping operation. Radiological contamination on tfe property is present in the outdoor portion of the storage area. Most of the contamination is located in a single contiguous area, with smaller contaminated 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-l) - 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: $5,686,000 Estimated Annual O&M Cost: $44,000 Estimated Present Worth: $6,182,000 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 three to five years.

500024 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. EPA will also excavate contaminated building debris from past demolition activities, which is currently buried on-site, and dispose of this material at an appropriate off-site facility. EPA will backfill 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 turn 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 the tunnel 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 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 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-l) - No Action

Estimated Capital Cost: $0 Estimated Annual O&M Cost: SO 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

500025 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 ((• 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, 6 inches of tonsoil, and vegetation (seeding or sod). The thickness of the fill material will range from 6 • 24 inches. The thickness of the concrete will range from 6 to 8 inches. Approximately 5,000 square feet of coverage would be required. Areas of contamination extending into ^outh 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 two to three years.

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

Option A: 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, EPA will excavate contaminated soil above 5 pCi/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 former demolition activities would also be excavated and disposed of off-site. EPA will backfill these areas 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 Mantle 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

500026 demolition, short-term provisions to prevent dust generation and protect workers would be required. The estimated time to design and construct the remedy is one to two years.

Option B: Decontamination, Demolition and Disposal

Estimated Capital Cost: $ 1,979,560 Estimated Annual O&M Cost: $0 Estimated Present Worth: $ 1.979,560 Estimated Implementation Period: 1 -2 years

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

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

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

The following "threshold" criteria are the most important and must be satisfied by any alternative in order to be eligible for selection:

1. Overall protection of human health and the environment considers whether or not a remedial alternative provides adequate protection and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

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

The following "primary balancing" criteria are used to make comparisons and to identify the major trade-offs between alternatives:

500027 3. Long-term effectiveness and permanence refers to the ability of a remedial alternative to maintain reliable protection of human health and the environment over time, once cleanup goals have been met. It also addresses the magnitude and effectiveness of the measures that may be required to manage the risk posed by treatment residuals and/or untreated wastes.

4. Reduction oftoxicity, mobility, or volume through treatment addresses the statutory preference for selecting remedial actions that employ treatment technologies that permanently and significantly reduce toxicity, mobility, or volume of hazardous substances as a principal element.

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

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

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

The following "modifying" criteria are considered fully after the formal public comment period on the Proposed Plan is complete:

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

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

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

Overall Protection to Human Health and the Environment

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

500028 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.

Lone-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

500029 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 Toxicitv. 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 full; 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

500030 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.

Implementabilitv

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.

500031 There are no O&M costs associated with the Excavation and Off-Site Disposal Alternatives (W-3, V-3 and G-3 Options A and B).

State Acceptance

The State concurs with the selected remedial action.

Community Acceptance

EPA solicited input from the community on the remedial alternatives proposed for the Welsbach/General Gas Mantle Contamination S;ie. 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 0.026uCi/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.

500032 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.

500033 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 radioiogically- 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 the 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

500034 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.

500035 APPENDIX I

FIGURES

500036 WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE STUDY AREAS FIGURE 1

500037 SOUTH FOURTH STREET

71 Q m

^» isf to i5 *Si E°| 5 m; n P

ARLINGTON STREET Ul O o o OJ O 00 c m3) K) Figure 3 - Former Welsbach Facility

WALT WHITMAN BRIDGE en o o ELLJS STREET o to vo APPENDIX II

TABLES

500040 TABLE -1

RADIATION UNITS

Historical International Parameter Unit Abbrev. Unit Abbrev.

Quantity ' Curie Ci Becquerel Bq

Radionuclide picoCurie per pCi/g Becquerel per Bq/kg Concentration in gram of Solid kilogram Soil or Other Solid Material

Radionuclide picoCurie per pCi/L — ... Concentration in liter of Water Water

Radon Gas Cone. picoCurie per pCi/L Becquerel per Bq/m3 liter of Air cu. meter

Radon Progeny Working Level WL ... — Cone.

Exposure Rate micro-Roentgen nR/h ... — per hour

Dose Radiation rad Gray Gy Absorbed Dose

Dose Equivalent Radiation rem Sievert Sv Equivalent Man

500041 TABLE-2 PROPERTY CHARACTERIZATION WELSBACH/GGM SITE

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

PROPERTIES SURVEYED BY THE 359 174 48 474 32 NA1 1088 NJDEP PROPERTIES WITH NO EVIDENCE OF CONTAMINATION 103 40 18 272 16 0 449 30 jiR/HR > 0.02 WL RADON DECAY PRODUCTS > 4.0 pCi/L RADON

Note: (.n 1 • Study Area 6 was not part of the NJDEP investigation. o o o NA-Not Applicable .u K) 36 TABLE 3

ESTIMATED VOLUME OF CONTAMINATED MATERIALS WELSBACH/GGM SITE

SOIL STRUCTURAL/DEBRIS (CUBIC YARDS) MATERIALS (CUBIC YARDS)

FORMER WELSBACH 22,200 5,000 FACILITY

FORMER GGM FACILITY 885 1,460

VICINITY PROPERTIES 11,010 2,255

TOTAL 34,100 8,720

500043 TABLE 4

RADIOLOGICAL RISK ESTIMATES BASED ON REASONABLE MAXIMUM EXPOSURES AT FORMER GAS MANTLE MANUFACTURING FACILITIES

POPULATION PATHWAY EXPOSURE GROSS BACKGROUND NET TOTAL MEDIUM RISK RISK RISK RISK

FORMER WELSBACH FACILITY

WORKER EXTERNAL SOIL 5.70e-02 7.306-05 5.706-02 5.70e-02

OTHER WORKER EXTERNAL SOIL 1.40e-02 1.806-05 1.406-02 l.40e-02

CONSTRUCTION WORKER EXTERNAL SOIL 7.506-04 8.706-07 7.506-04 INGESTION SOIL 3.106-05 5.606-08 3.106-05 INHALATION PARTICULATES 1.108-03 8.406-07 1.106-03 l.90e-03

FORMER GENERAL GAS MANTLE FACILITY

TRESPASSER EXTERNAL SOIL 3.100-05 1.306-06 3.006-05 BUILDING MATERIALS 2.006-05 3.406-06 1.706-05 INGESTION SOIL 1.900-06 1.406-07 1.80e-06 INHALATION PARTICULATES O.OOe+00 0.006+00 O.OOe+00 H RADON DECAY PRODUCTS 2.50e-03 7406-06 2.506-03 2.50t-OJ

CONSTRUCTION WORKER EXTERNAL SOIL 2.106-05 8.706-07 2.006-05 INGESTION SOIL 7.506-07 5.606-08 6.906-07 INHALATION PARTICULATES 2.806-05 8.406-07 2.706-05 4.80*05

ADULT RESIDENT EXTERNAL SOIL 8.906-03 3.806-04 8.506-03 INGESTION SOIL 2.706-05 2.006-06 2.506-05 HOME GROWN PRODUCE 2.306-05 3.206-06 2.006-05 INHALATION RADON DECAY PRODUCTS 4.906-03 8.006-04 4.106-03 IJOe-02

CHILD RESIDENT EXTERNAL SOIL 1.806-03 7.806-05 1.706-03 INGESTION SOIL 1.106-05 8.106-07 1.006-05 • HOME GROWN PRODUCE 1.906-06 2.706-07 1.606-06 INHALATION RADON DECAY PRODUCTS 5.606-04 9.206-05 4.706-04 2JOC-03

WORKER EXTERNAL BUILDING MATERIALS 1.406-03 2.406-04 1.206-03 INHALATION PARTICULATES O.OOe+00 O.OOe+00 O.OOe+00 RADON DECAY PRODUCTS 1.806-01 5.106-04 1.806-01 1.80*41

500044 TABLE 5 VICINITY PROPERTIES

SUMMARY OF RADIOLOGICAL RISK ESTIMATES BASED ON REASONABLE MAXIMUM EXPOSURES* RISK VICINITY PROPERTY POPULATION PATHWAY GROSS BACKGROUND NET

SITE WORKER External 7.36-01 8.66-05 7.3e-01 Inhalation of Participates 2.3e-02 1.86-06 2.3e-02 PUBLIC PARK Inhalation of Radon 1.76-03 5.26-04 1 .2e-03 Ingestion of Soil 3.0e-03 5.56-07 3.0e-03 Total: 7.6e-01 6 16-04 7.6e-01

CONSTRUCTION POPCORN WORKER External 3.36-04 8.36-07 3.36-04 FACTORY Inhalation of Participates 1.16-05 3.16-08 1.16-05 Ingestion of Soil 1.16-06 3.16-09 1.16-06 Total: 3.46-04 8.66-07 346-04

ADULT RECREATIONALIST External 2.26-01 2.66-05 2.26-01 PUBLIC PARK Inhalation of Participates 6.96-03 5.56-07 6.96-03 Ingestion of Soil 4.5e-04 8.36-08 4.56-04 Total: 2.3e-01 2.76-05 2.36-01

RESIDENT ADULT External 4.7e-02 3.56-04 4.76-02 POPCORN Inhalation of Radon 1.26-01 7.96-04 1.26-01 FACTORY Ingestion of Soil 1.26-04 2.0e-06 1.26-04 Total: 1.76-01 1.16-03 1.76-01

CHILD RECREATIONALIST External 4.46-02 5.16-06 4.46-02 PUBLIC PARK Inhalation of Particulates 1.26-03 9.4e-08 1.26-03 Ingestion of Soil 1.86-04 3.36-08 1.86-04 Total: 4.56-02 5.26-06 4.56-02

RESIDENT CHILD External 7.06-02 6.86-05 7.06-02 Inhalation of Radon 2.56-02 9.06-05 2.56-02 LAND PRESERVE Ingestion of Home Grown Produce 2.564)3 3.86-06 2.56-03 Ingestion of Soil 4.60-04 7.86-07 4.66-04 Total: 9.86-02 1.66-04 9.86-02

TRESPASSER External 2.46-03 2.56-06 2.46-03 LAND 1.26-04 9.46-08 1.26-04 PRESERVE Inhalation of Particulates Ingestion of Sol 2.36-06 3.86-09 2.36-06 Total: 2.56-03 2.66-06 2.56-03

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

500045 39 TABLE 6 RISK ASSESSMENT SUMMARY FORMER WELSBACH FACILITY

SccMrie Tncfiww: Fttm Rectpot FofMlatio* Cattractioa Wortn RtctplocAy Adult______

Carcinogenic Risk Non-Carcinogenic Hazard Quotient Ingestion Inhalation Dermal Exposure Primary Ingestion Medium Exposure Chenkal Chemical Inhalation Dermal Exposure Routes Total Target Routes Total Organ Soil Soil Benzo(a)Anthracene 6e-08 — No Tox Data 6e-08 Arsenic Skin le+00 .. 2e-OI le+00 Benzo(b)Fluoranthene le-07 - No Tox Data le-07 Benzo(a)Pyrene 6e-07 - No Tox Data 6e-07 Aroclor-1248 le-08 - 7e-09 2e-08 Aroclor-1254 le-08 - 8e-09 2e-08 Antimony No Tox Data - No Tox Data -- Arsenic 7e-06 -- le-06 8e-06 Selenium — - - - (Total) 7e-06 -- le-06 8e-06 (Total) le+00 - 2c-OI l( MM) Paniculate; Benzo(a)Anthracenr - 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 cn le-05 - le-05 - - -- o Arsenic - - 0 Selenium o i* (Total) - le-05 - le-05 (Total) ------Total Risk Across Soil 2e-OS Total Hazard Index Across All Media and All Rxposure Routes le+00

Total Risk Across All Media and All Exposure Routes 2e-OS Total Skin 111 = le+00 TABLE 7 RISK ASSESSMENT SUMMARY GENERAL GAS MANTLE

Sceiurio Tuncfranc: Future Receptor PopulMm: Construction Worker

Receptor Age: Adult______

Carcinogenic Risk Non-Carcinogenic Hazard Quotient Ingestion Inhalation Dermal Exposure Primary Inhalation Medium Eiposure Chemical Chemical Ingestion Dermal Exposure Routes Total Target Routes Total Organ

Soil Soil Benzo(a)Anthraccne 2e-09 ~ No Tox Data 2e-09 Aroclor-1248 N/A 2e-03 — le-03 3e-03 Bcnzo(a)Pyrene 2e-08 ~ No Tox Data 2e-08 Selenium Liver 2e-04 - No Tox Data 2e-04 Aroclor-1248 9e-IO - 7e-IO 2e-09 Selenium -- -- Thallium - - (Total) 2e-08 - 7e-IO 2e-08 (Total) 2c-03 - le-03 3e-03 Paniculate; Benzo(a)Anthracene -- No Tox Data ------Benzo(a)Pyrene - No Tox Data - - - - ~ - Aroclor-1248 - 2e-IO -- 2e-10 - - -- - Selenium ------Thallium — — - ~ - ~ - (Total) - 2e-IO -- 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 Media and All Exposure Routes 2e-08 Total Liver III = 2e-04 tn o o o TABLE 8 ^

SUMMARY OF ALTERNATIVE COSTS WELSBACH/GENERAL GAS MANTLE SITE

ALTERNATIVE PROPERTY CAPITAL O&M' TOTAL (30 Years) NO ACTION

WELSBACH(W-l) SO $0 SO VICINITY PROPERTIES (V-l) SO SO $0 GENERAL GAS MANTLE (G-l) SO $0 SO ENGINEERING CONTROLS

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

VICINITY PROPERTIES (V-2) $900,000 S9 10.000 SI, 8 10,000

GENERAL GAS MANTLE (G-2) $122,000 $259,000 $381,000 EXCAVATION AND OFF-SITE DISPOSAL WELSBACH (W-3) $18,503,560 $0 $18,503,560 ^ VICINITY PROPERTIES (V-3) $13,408,560 $0 $13,408,560 GENERAL GAS MANTLE $2,309,560 $0 $2,309,560 OPTION A (G-3)1 GENERAL GAS MANTLE $1,979,560 $0 $1,979,560 1 OPTION B (G-3)2

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

1. Option A: Demolition and Disposal of GGM building 2. Option B: Decontamination and Demolition of GGM building

500048 42 TABLE 9

SITE SPECIFIC CLEANUP STANDARDS

TYPE PERTINENT SOURCES STANDARD OR GUIDELINE

Radon and Thoron 4 pCi/L Citizen Guide to Indoor Concentration Radon (EPA 1992)

Radon and Thoron Decay Progeny: Average 0.02 WL 40 CFR 192 Maximum 0.03 WL 40 CFR 192

Soil: Radium and 5 pCi/g - Sum of 226Ra and 228Ra 40 CFR 192 Other Radionuclides 5 pCi/g - Sum of 230Th and 232Th

Subsurface Soil: Radium and 5 pCi/g - Sum of 226Ra and 228Ra OSWER Directive Other Radionuclides 5 pCi/g - Sum of 230Th and 232Th 9200.4-25

Wetlands Protection of Wetlands Clean Water Act 40 CFR 230.1 etseq.

Executive Order 11990

Endangered Species Protection of Endangered and Endangered Species Act Threatened Species 16 U.S.C. 1536 (a)(2)

Historic Buildings Protection of Archaeological National Historic Significant Items Preservation Act 16 U.S.C. 470(0

500049 43 APPENDIX III

ADMINISTRATIVE RECORD INDEX

500050 WELSBACH fc GENERAL GAS MANTLE CONTAMINATION ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

1.0 SITE IDENTIFICATION 1.2 Notification/Sit* Inspection Reports

100001- Report: Final Hazard Ranking System Documentation. 100308 Welsbach and General Gas Mantle Contamination Sites. Camden and Gloucester Citv. New Jersey. Volume I of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995.

100309- Report: Final Hazard Ranking System Documentation. 100551 Welabaeh and General Gas Mantle Contamination Sites. Camden and Gloucester Citv. New Jersey. Volume II of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995.

100552- Report: Final Hazard Ranking System Documentation. 101016 Walsbaeh and General Gaa Mantle Contamination Sites. Camden and Gloucester Citv. New Jeraev. Volume III of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995. 101017- Report: Final Hazard Ranking System Documentation. 101428 Welabaeh and General Qaa Mantle Contamination Sites. Camden *nd Gloueeater Citv. New Jeraev. Volume IV of VIII. prepared for the Environmental Service* Division, U.S. EPA, Region II, prepared

500051 by Mr. Steven T. McNulty, Project Manager, Mr. Todd G. Teryek, Task Leader, Mr. John L. Splendore, P.E., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995.

101429- Report: Final Hazard Ranking System Document at ler 101707 Welsbaeh and General Gas Mantle Contamination Sites. Camden and Gloucester Citv. New Jersey. Volume V of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995.

101708- Report: Final Hazard Ranking System Documentation. 102024 Welsbaeh and General Gaa Mar.tie Contamination Sites. Camden and Gloucester Citv. New Jersey. Volume VI of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995.

102025- Report: Final Hazard Ranking System Documentation. 102600 Welsbaeh and General Gas Mantle Contamination Sites. Camden and Gloucester Citv. New Jersey. Volume VII of VIII. prepared for 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., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995. (Note: The Gloucester City/Camden Survey of Affected Properties for Senior Citizens and Children, pages 102298-102305, is confidential due to the Privacy Act. It is located at the U.S. EPA Superfund Records Center, 290 Broadway, 18th Fl., N.Y., N.Y. 10007-1866.)

102601- Report: Final Hazard Ranking System Documentation. 102920 Welsbaeh and General Gas Mantle Contamination Sites. Camden and Gloucester Citv. New Jersey, volume VIII of vm. prepared for 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

500052 L. Splendors, P.E1., Work Assignment Manager, U.S. EPA, Region II, March 27, 1995. (Note: The Quality Control Internal Controls and Audits Manual, pages 102763-102822, and The Quality Assurance Manual, pages 102823-102876, are confidential business information. They are located at the U.S. EPA Superfund Records Center, 290 Broadway, 18th Fl., N.Y., N.Y. 10007-1866.) 1.4 Sit* Investigation Reports

P. 102921- Report: An Aerial Survey of Gloucester. New Jersey 102947 and Surrounding Area, prepared for the U.S. EPA, Region II, prepared by Mr. Joel E. Jobst, Mr. Harvey W. Clark, Project Scientists, May 1981.

3.0 REMEDIAL INVESTIGATION 3.3 Work Plan* P. 300001- Plan: Welsbach/General Gas Mantle Contamination 300192 Site, Camden, New Jersey, Work Assignment 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 Report* P. 300193- Report: Welsbach/General Gas Mantle Contamination 300347 Site. Camden. New Jersey. Work Assignment No. 050- 2BUC. Staoe la Archaeological Investigation. prepared for the U.S. EPA, Region II, prepared by Malcolm Pirnie, Inc., June 1998. P. 300348- Report: Welabach/General Gas Mantle 300694 Contamination Site. Camden. New Jersey. Work Assignment No. 050-2B11C. Draft Final Remedial Investigation/Feasibility Study Report. Volume I. prepared for the U.S. EPA, Region II, prepared by Malcolm Pirnie, Inc., June 1998. P. 300695- Report: He1abash/General Gag Mantle 301035 Contamination Site. Camden. New Jereev. Work AflBJanment No. OSO-2BUC. Draft Final Remedial Invegtioation/FeaBibilitv Study Report. Volume II.

500053 prepared for the U.S. EPA, Region II, prepared by Malcolm Pirnie, Inc., June 1998. 3.5 Correspondence P. 301036- Report: Welsbach/ General Gaa Mantle Contamination 301134 Site. Camden. New Jeraev. Work Assignment No. 050- 2SUC Response _o Comments, prepared for the U.S. EPA, Region II, prepared by Malcolm Pirnie, Inc. November 1997. P. 301135- Memorandum to Addressees, from Stephen D. Luftig, 301145 Director, of Office of Emergency and Remedial Response, and Mr. Larry Weinstock, Acting Director, Office of Radiation and Indoor Air, re: Establishment of Cleanup Levels for CERCIA Sites with Radioactive Contamination, August 22, 1997. P. 301146- Memorandum to Addressees, from Mr. Stephen D. 301151 Luftig, Director, of Office of Emergency and Remedial Response, and Mr. Larry Weinstock, Acting Director, Office of Radiation and Indoor Air, re: Use of Soil Cleanup Criteria in 40 CFR Part 192 as Remediation Goal for CERCLA sites, February 12, 1998.

7.0 XNTORCBONT 7.3 Administrative Orders P. 700001- Administrative Orders on Consent for Remedial 700059 Investigation/Feasibility Study Armstrong Building, In the Matter of Welsbach Gas Mantle Contamination Site (8U), Holt Hauling and Warehouse System, Inc., Respondent, undated.

8.0 HEALTH ASSESSMENTS

8.1 AMD* Health Assessawnts P. 800001- Memorandum to Mr. John Prince, ERRD/NJSB1-N, from 800037 Mr. Arthur Block, Senior. Regional Representative, re: Final Health Consultation for Welsbach and General Gas Mantle Contamination Sites (WGGMCS), March 12, 1997.

500054 10.0 PUBLIC PARTICIPATION

10.2 Coanunity Relation* Plans P. 10.00001- Plan: Welsbach/General Gas Mantle Contamination 10.00038 Site, Camden, New Jersey, Work Assignment No. 050- 28UC, Draft Final Community Relations Plan, Remedial Investigation/Feasibility Study, prepared for the U.S. EPA, Region II, prepared by Malcolm Pirnie, June 1997. 10.9 Proposed Plan P. 10.00039- Plan: Superfund Proposed Plan, Welsbach/General 10.00059 Gas Mantle Contamination, Superfund Site, Camden and Gloucester City, Camden County, New Jersey, prepared by U.S. EPA Region II, February 1999.

500055 APPENDIX IV

STATE LETTER

500056 SENT BY'SITE REMEDIATION : 7-21-99 :12:45PM : FAX * 609 633 2360- 212 637 4429:* 2/ 3

of ledd Whitm»n . Dwpirtmant of UnvironmcnUl Piolccliou Rnburt C. SWnn. Jr. Governor Oflto»«rtt»C»«tato««r Committiontr P.O. Bos 402 TmtM. Mm Jtncy ttOS44n -1914

July 21, 1999

Ms. Jeanne M. Fox Regional Administrator U.S. EPA - Region H 290 Broadway New York, NY 10007-1866 Subject: Wdsbach/General Gas Maatle Contamination Supcrfuad Site Record of Decision (ROD)

Door Ma. Fox:

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

The major components of the telected remedy include:

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

• Excavation/removal of soil and waste materials with radiological contamination abuve lanaliai action objectives fiom the residential and commercial properties in the vicinity of two former gas mantle facilities; • OfF-site disposal of tteradic4ogicalty-conta^

• Decontamination and demolition of the General Gas Mantle Building; and • Appropriate environmental monitoring to ensure the effectiveness of the remedy. NJDEP concurs that the selected remedy is protective of human health and the environment, complies with requirements that are legally applicable or relevant and appropriate for the remedial action, and k cost effective.

500057 acm 01 01 it * oua ooo o/ o

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

C. Shinn, Jr. Commissioner New Jersey Department of Environmental Protection

500058 APPENDIX V

RESPONSIVENESS SUMMARY

500059 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 concerns regarding the remedial investigation and feasibility study (RI/FS) report and the Proposed Plan 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 reviewing and considering all public comments received during the public comment period, EPA has selected a remedy for the former Welsbach Facility, 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 to the public in the administrative record file at the Superfund Document Center in EPA Region II, 290 Broadway, 18th Floor, New York, New York 10007and at the following repositories: City of Camden Main Library, 418 Federal Street, Camden, New Jersey 08103; the Hynes Center, 1855 South 4th Street, Camden, New Jersey 80104; and the Gloucester City Public Library, Monmouth and Hudson Streets, Gloucester City, New Jersey 08030. The notice of availability for the above- referenced documents was published in the Philadelphia Inquirer on February 1, 1999, the Courier-Post on February 2, 1999, and the Gloucester Citv News on February 4, 1999. The public comment period which related to these documents was held from February 1, 1999 to March 3, 1999.

EPA conducted public meetings in both Gloucester City and Camden to inform local officials and interested citizens about the Superfund process, to review proposed remedial activities at the Site and receive comments on the Proposed Plan, and to respond to questions from area residents and other 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 Utilities Authorities Auditorium in Camden. Responses to the comments received at the public meeting are included in this Responsiveness Summary. The City of Gloucester City submitted a resolution supporting the proposed remedy. No other written comments were received during the public comment period.

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

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

500060 The last section of this Responsiveness Summary includes appendices which document public participation in the remedy selection process for this site. There are four appendices attached to this Responsiveness Summary. They are as follows:

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

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

Appendix C contains the transcripts of the public meetings; and

Appendix D contains the written comments received by EPA during the public comment 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 Study 2.0 EPA's Proposed Plan 3.0 Health and Safety 4.0 Cleanup Schedule 5.0 Public Participation Process 6.0 Real Estate Issues 7.0 Other

1.0 Remedial Investigation and Feasibility Study

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

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

500061 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

500062 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, onlv 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 h ' d additional public meetings and receive public comment before it modified the selected remeoy.

3.0 Public Health Concerns

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

500063 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.

500064 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 next 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.

500065 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.

500066 Appendix A

Proposed Plan

500067 Superfund Proposed Plan Welsbach/General Gas Mantle Contamination Superfund Site Camden and Gloucester City Camden County, New Jersey February 199S Region 2

Mark Your Calendar PURPOSE OF THE PROPOSED PLAN

Public Comment Period This Proposed Plan describes me remedial alternatives that the U.S. Environments Protection Agency (EPA) considered in addressing soil and building materia February 1,1999 to March 3,1999 contamination at the Welsbach/General Gas Mantle Contamination Site (Site). Thi plan also identifies EPA's preferred remedial alternatives and the rationale for thi Public Meetings: preference. This document was developed by EPA, in consultation with the New Jerse; Department of Environmental Protection (NJDEP). The alternatives summarized her Gloucester City are described in greater detail in the Remedial Investigation and Feasibility Study Tuesday, February 23,1999 at which is now available at the City of Camden Main Library, Camden, New Jersey; th 7:00 p.m. at Pine Grove Fire Station #2 Hynes Center, Camden, New Jersey; the Gloucester City Public Library, Gloucester Cir> New Jersey; and at EPA's offices at 290 Broadway, 18th Floor, New York, New York Camden Wednesday, February 24,1999 at EPA's preferred remedial alternatives address soil and building contamination at th 7:00 p.m. at Camden County Municipal Site. The preferred alternatives are the excavation and off-site disposal alternatives fc Utilities Authority Auditorium the Vicinity Properties, Welsbach Facility and General Gas Mantle Facility (Altemativ V-3, W-3, and G-3 with Option B). Availability Sessions - informal question and answer sessions: EPA encourages the public to review and comment on all of the alternatives considere by EPA in this Proposed Plan. The remedies described in this Proposed Plan are EPA Gloucester City preferred remedy for the Site. Changes to the preferred remedy or a change from th Tuesday, February 23,1999, from preferred remedy to another remedy may be made if public comments or additional dai 1:00 p.m. to 4:00 p.m. at Pine Grove indicate that such a change will result in a more appropriate remedy. EPA, i Fire Station #2 consultation with NJDEP, will select the remedy after considering all publ comments.* Camden Wednesday, February 24,1999, from 1:00 to 4:00 p.m. at Camden County public comment period from February 1,1999, to Municipal Utilities Authority Auditorium March 3,1999.

During the public comment period, EPA will hold a public meeting at the Pine Grove Fire Station #2 in COMMUNITY ROLE M SELECTION PROCESS Gloucester City on Tuesday, February 23,1999 at 7:00 p.m., and at the Camden County Municipal EPA relies on public input to ensure that the concerns Utilities Authority Auditorium, in Camden on of the community are considered in selecting an Wednesday, February 24,1999 at 7:00 p.m. At effective remedy for each Superfund site. To this these meetings, EPA will present the conclusions of end, EPA has made the Remedial Investigation and the RI/FS, discuss the reasons for recommending the Feasibility Study (RI/FS) report, Proposed Plan, and preferred remedial alternatives, and receive public supporting documentation available to the public for a comments.

500068 EPA will also be available on an informal basis to participation responsibilities under Section 111 (a) of answer any questions at the Pine Grove Fire Station the Comprehensive Environmental Response, #2 on Tuesday, February 23,1999, from 1:00 p.m. Compensation and Liability Act (CERCLA). as to 4:00 p.m., and at the Camden County Municipal amended, and Section 300.430(f) of the National Oil Utilities Authority Auditorium on Wednesday, and Hazardous Substances Pollution Contingency February 24,1999, from 1:00 to 4:00 p.m. Plan (NCP).

Comments received at the public meeting, and all ISrTE BACKGROUND written comments, will be documented in the Responsiveness Summary Section of the Record of Between the 1890s and 1940s, the Welsbach Decision (ROD), the document which formalizes the Company (Welsbach) manufactured gas mantles at its selection of the remedy. All written comments facility in Gloucester City, New Jersey. Welsbach should be addressed to: was a major manufacturer and distributer of gas mantles until gas lighting was replaced by*the electric Richard J. Robinson light. Welsbach extracted the radioactive element Project Manager thorium from ore .ind used it in the gas mantle U.S. Environmental Protection Agency manufacturing process. Thorium causes the mantles 2 90 Broadway, J 9th Floor to glow more brightly when heated. A second gas New York, NY 10007-1866 mantle manufacturing facility, known as the General Gas Mantle Company (GGM), was located in Copies of the RI/FS report. Proposed Plan, and Camden, New Jersey. GGM was operated from 1915 supporting documentation are available at EPA's to approximately 1940. office at 290 Broadway, 18th Floor, New York, NY 10007-1866. (212) 637-4308, and at the following EPA initially identified the Site in 1980, during; repositories: archive search conducted as part of the investigation of the U.S. Radium Corporation Superrund site City of Camden Main Library located in Orange, New Jersey. Historical U.S. 418 Federal Street Radium Corporation files indicated that radiological Camden, NJ 08103 materials were purchased by U.S. Radium from the (609) 757-7650 Welsbach Corporation during the 1920s. Hynes Center th In May 1981, EPA conducted an aerial radiological 1855 South 4 Street survey of the Camden and Gloucester City area to Camden, NJ 80104 investigate for radioactive contaminants. The survey (609)966-9617 encompassed a 20 square kilometer area surrounding the former locations of the Welsbach and General Gas Gloucester City Public Library Mantle Facilities. Five areas with elevated gamma Monmouth and Hudson Streets radiation were identified from the aerial survey; they Gloucester City, NJ 08030 included the locations of the two former gas mantle (609)456-4181 manufacturing facilities and three mainly residential areas in both Camden and Gloucester City. In 1993, EPA, after consultation with NJDEP, will select a the data from the aerial survey were reanalyzed. remedy for the Site only after the public comment Based or. this revised information, EPA identified a period has ended, and the information submitted sixth potential radiologicalh contaminated area which during that time has been reviewed and considered. includes two vacant lots in Gloucester City. EPA is issuing this Proposed Plan as part of its public

EPA Region 2 - February 1999 Page 2 500068A In the early 1990s, NJDEP conducted more detailed identified during site assessments performed b\ the radiological investigations at more than 1,000 City of Gloucester City. properties located throughout the original five study areas. Radiological contamination was found at the No significant changes in land use are anticipated. two former gas mantle facilities. NJDEP data also except in the Study Area 1 where there is a possibility indicated that approximately 100 properties near the that some residential areas may be rezoned for two former gas mantle facilities might be commercial uses. Whether zoning changes will contaminated. In 1996, the Welsbach/GGM site was actually be made is uncertain at this time. placed on National Priorities List (NPL) because of the presence of radioactive contaminants. iSITEHISTORY

Based on their geographic proximity, EPA divided The Welsbach and the GGM Facilities have complex the Welsbach/GGM site into six study areas in histories of name and ownership changes. Specific Camden and Gloucester City, New Jersey (Figure 1). details are discussed in the paragraphs below. A brief description of each study area and its current land use is presented below: The United Gas Improvement Company, which formed Welsbach, purchased the patent rights to • Study Area One: includes the former General manufacture thorium-containing gas mantles in the Gas Mantle Facility and residential and 1880s from Dr. Carl Auer von Welsbach. The commercial properties which surround the facility. process for manufacturing the Welsbach gas mantle The former GGM Facility is located in a mixed used a highly purified solution of 99 percent thorium industrial, commercial, and residential zoned nitrate and 1 percent cerium nitrate as a "lighting section of Camden. fluid" in distilled water. A fabric sock was then dipped into the thorium solution to create the gas • Study Area Two: includes the location of the former Welsbach Facility and nearby mantle. Thorium caused the uas mantle to give off a residential/commercial properties. The former very bright white light when lit. Welsbach Company is situated in an industrial zoned section of Gloucester City with residential The commercial source of thorium and cerium is a properties to the immediate east. mineral known as monazite sand. Monazite sand contains approximately 5-6 percent thorium oxide • Study Area Three: includes residential and and 20-30 percent cerium oxide. Thorium was recreational properties in Gloucester City, typically extracted from the monazite ore by heating including the Gloucester City Swim Club and the the ore in a sulfuric acid solution. The thorium and Johnson Boulevard Land Preserve. other rare earth elemen's would go into solution, while the radium-228 remained in the tailings of • Study Area Four: includes residential properties in insoluble sulfates. Around 1915, Welsbach started the Fairview section of Camden. using and selling the radium-228 for its use in luminescent paint. For a number of years, Welsbach • Study Area Five: includes residential properties, vacant land properties, and two municipal parks was the largest manufacturer of gas mantles in the near Temple Avenue and the South Branch of world making up to 250,000 mantles per day at its Newton Creek in Gloucester City. peak.

• Study Area Six: includes two vacant lots in a Welsbach also made gas room heaters, gas storage residential zoned area of Gloucester City. This water heaters, gas and electrical fixtures, electrical area was initially identified when the aerial survey refrigerators, plumbing supplies and lacquers. data were revised in 1993. This area was Manufacturing operations at the Welsbach facility

EPA Region 2 - February 1999 Page 3 500068B WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE - STUDY AREAS

Page 4 500069 began as early as 1882 and lasted until the 1940s. radiological waste from the Welsbach and GGM The facility property covered an area of about 21 Facilities are collectively termed Vicinity Properties acres, and consisted of about 20 buildings. In 1991, NJDEP initiated a radiological investigation In 1948, the former Welsbach Facility in Gloucester at more than 1,000 properties located throughout City was sold to the Randall Corporation, and leased Study Areas 1 through 5. At properties where to the Radio Corporation of America, Victor NJDEP determined that exposure levels were Division. In May 1976, the property was purchased unacceptable (or posed an immediate health risk). by Holt Hauling and Warehousing, Inc. (Holt), the they performed interim remedial measures. These current owner of the property. Holt operates a cargo measures included the installation of radon/moron and overseas shipping business. ventilation systems and placement of concrete or lead sheeting to shield gamma radiation. In addition. Only one Welsbach era building, the Armstrong NJDEP restricted access to outdoor areas which Building, is still present on the property. There is no exceeded its action levels. * information available on when the other Welsbach-era buildings were demolished. The Armstrong Building In 1998, EPA identified a 100 square foot area in a is not part of this Operable Unit. Holt is performing Gloucester City Park, located in Study Area 5, that an Rl/FS of the Armstrong Building under an had high levels of gammj radiation at the surface. In Administrative Consent Order with EPA. December 1998, EPA performed a removal action to reduce exposure to the high levels of gamma The former gas mantle manufacturing facility in radiation at the surface. EPA excavated the top three Camden was owned and operated by the GGM feet of radiologically contaminated soil and replaced Company from 1912 to 1941. There is little the waste material with clean fill. information available regarding activities at GGM, other than it used and resold radium and thorium. ;THE NATURE OF RADIONUCLIDES

Between 1941 and 1978, there had been a total of A radionuclide is an element that spontaneously seven different private owners of the property. Based changes, or "decays" into another element through on current information, none of these operations natural processes. Radionuclides are present in trace involved radioactive materials. In January 1978, the amounts in all rocks and soils, and consist primarily southern portion of the property was occupied by the of elements of the uranium-238 and thorium-232 Dynamic Blending Company. In October 1988, the decay series. There are approximately 1,700 different northern portion of the property was purchased by unstable atomic species, or radionuclides. These Ste-Lar Textiles. In 1992, NJDEP removed include both naturally occurring and man-made radiologically contaminated fabrics from the facility, radionuclides. relocated Ste-Lar, and sealed up the GGM building to restrict access. The radionuclides of concern in the wastes which originated at the former Welsbach and GGM During the years that Welsbach and GGM operated, Facilities are members of the uranium and thorium ore tailings were used for fill at properties in the decay series. There are 14 unique radionuclides in vicinity of the facilities. It is also reported that the uranium decay series and 11 unique radionuclides building debris from the former Welsbach Facility in the thorium decay series which precede the may have been disposed of as fill in the area. In formation of stable lead (Pb-206 or Pb-208). Alpha, addition, workers from the former Welsbach and beta, and gamma radiation are emitted from the GGM Facilities may have brought contamination various members of the two decay series. The home with them. These properties associated with primary nuclides of concern are Thorium-232,

EPA Region 2 - February 1999 PageS 500070 Radium-226, and radon gas (Radon-222 and Radon- effects. For radon decay products, a special unit 220.) called Working Level (WL) has been developed Working Level is defined as any combination o^ Each radionuclide has its own unique characteristic short-lived radon decay products in 1 liter of air that "fingerprint," consisting of three parameters: will result in the ultimate emission of 1.3x10- Mega- electron Volts of potential alpha energy. This value is 1. The radioactive half-life describes the amount approximately equal to the alpha energy released of time in which half of any given number of from the decay of progeny in equilibrium with 100 atoms of a radionuclide will decay. pCi of Radon-222.

2. The mode of decay refers to the type(s) of Thorium-232 is also a naturally occurring particles or electromagnetic rays emitted from radionuclide and is the initial radionuclide of the the radionuclide as it decays. These types thorium decay series. Its decay products include include alpha and beta particles, and gamma radium-228 and Radon-220. Radon-220 is* also rays. known as thoron. Thoron and its decay products have extremely short half-lives that usually prevent 3. The amount of energy carried away from the them from concentra"ng to any appreciable extent in atom by the particles or rays is radionuciide indoor air. However, u a significant source of thoron specific. It is the transfer of this energy to exists within, beneath, or adjacent to a structure (such living tissue which may cause biological as the thorium and radium-228 found in effects. Welsbach/GGM site wastes), thoron decay products can reach concentrations which create health risks. When radionuclides decay, they emit energy in the form of radiation. The decaying radionuclide is often I REMEDIAL INVESTIGATION SUMMARY _ called the "parent", and the radionuclide produced is called the "decay product". A quantity of radioactive In September 1997, EPA started an RI to material is measured by its rate of decay, expressed 12 characterize the nature and extent of contamination at by the unit Curie (Ci), which is equal to 2.22 x 10 the Welsbach Facility. General Gas Mantle Facility, (2.22 trillion) disintegrating atoms per minute. A and 20 of the radiologically contaminated properties more convenient unit for expressing environmental identified by NJDEP in the vicinity of Welsbach and radioactivity is the picoCurie (pCi), which is equal to : GGM. In order to develop a cleanup strategy for the 1 x 10-' (onetrillionth)Ci. Site, the RJ field investigations were divided into three property categories, as follows: Radium-226 is a naturally occurring, radioactive, metallic element formed from the decay of uranium. Former Welsbach Company Facility; Former General Gas Mantle Company In its decay. Radium-226 forms Radon-222 or radon Facility; gas. Radon gas is colorless, odorless, radioactive and Vicinity Properties. inert; therefore, it can move easily through soil to the ground surface or into houses. Within a matter of The RI/FS report presents the results of field days, the radon sas itself decays into a series of investigations conducted to date ar both Welsbach radioactive dec r- products. While radon gas in the and GGM Facilities and the 20 V cmity Properties. outdoor air aissipates quickly, the concentration of : In future phases of the remediation, called operable ra '?n decay products in the indoor air can build up units, EPA will investigate potentially impacted c • time. Exposure to the energy released by these ground water, surface water, and sediments. various decaying atoms can result in adverse health

EPA Region 2 - February 1999 Page 6 500071 Property Investigations building that was demolished in the 1970s. This area is currently used for storage EPA conducted both chemical and radiological However, there are smaller areas of characterizations of the former Welsbach and GGM contamination scattered throughout the Facilities to define the extent of contamination. EPA property. The soil in these areas is also performed a radiological investigation on 20 of contaminated with elevated concentrations of the potentially contaminated Vicinity Properties the thorium and uranium decay series identified by NJDEP. Only 20 Vicinity Properties radionuclides. Subsurface contamination on were investigated during the RI so that EPA could the Welsbach facility averages about 11 feet in confirm the NJDEP data and expedite the depth. An estimated 27,200 cubic yards of development of cleanup alternatives. EPA will soil/buried debris have thorium and or radium investigate the remaining potentially contaminated concentrations exceeding 5 pCi'g Radium properties identified by NJDEP, and other properties and thorium concentrations in soil ranged suspected of being possibly contaminated during the from background (about 1 pCi/g fcfi each) to remedial design phase of this cleanup. EPA estimates as high as 455 pCi/g and 1.190 pCi g. that about 600 properties will be studied in the design respectively. phase to d :termine exactly which properties require cleanup. This additional work may include sampling • Surface gamma exposure rates associated for chemical analysis, where deemed appropriate with the contaminated soils ranged from when considering past ownership and historic background (less than 10 micro-Roentgen per information. Field activities conducted as part of the hour [uRTi]) to 780 nR/h. The highest RI included the following: readings were associated with a large fill area identified in the middle of the storage area. Radon measurements •*-, • Radon decay product Working Level • Low levels of chemical contaminants were measurements identified at the former Welsbach Facility. • Gamma radiation surface and one-meter Contaminants of potential concern include height exposure rate surveys semi-volatile organic compounds and arsenic. • Surface and subsurface soil sampling These contaminants may be indicative of • Downhole gamma radiation logging "Historic Fill". If this is conf.—ned in the • Total surface beta surveys and removable remedial design, then there may be no need to surface alpha and beta sampling excavate this soil. Instead, it may be more • Structural materials sampling (in some appropriate to cap these soils in place. buildings) Former General Gas Mantle Facility Results of Field Investigations • Elevated concentrations of thorium and Areas with elevated levels of radioactivity that uranium decay series radionuclides were exceeded the radiological standards for human health identified in soils on the former GGM were identified during the remedial investigations. property. Contamination was generally The RI data support the following conclusions: limited to the top six to eight feet, although contamination in some areas of South Fourth Former Welsbach Facility Street and the GGM Courtyard ranged from 12 to 16 feet in depth. An estimated 900 • Most of the radiological contamination is cubic yards of soil had thorium and/or radium located in the area of a former Welsbach concentrations which exceeded 5 pCi/g.

EPA Region 2 - February 1999 Page 7 500072 Radium and thorium concentrations in soil Vicinity Properties ranged from background to as high as 172 pCi/g and 149 pCi/g, respectively. EPA investigated 20 properties in Camden and _^ Gloucester City for radiological contamination as part Surface gamma exposure rates associated of the RI. EPA compared these data to information with the contaminated soils ranged from collected from earlier NJDEP investigations and background (less than 10 uR/h) to 380 uR/h. determined that the data were comparable. These Only localized areas of surface contamination data support the following conclusions: were identified outdoors. • Some site properties have indoor radon gas Most of the outdoor contamination is located concentrations or soil radionuclide in the area of South Fourth Street. However, concentrations which pose a long-term risk to some smaller areas of contamination were human health. identified in the alleyway behind the property 4 that extended onto some backyards of • Contaminated soil averaged about two to neighboring residential properties. three feet in depth on most residential properties. On a few properties, Elevated levels of surface contamination were contamination extended to 10 feet in depth. observed in many areas inside the former GGM building. Levels as high as 2.33 • Based on the comparison of EPA and NJDEP microCi per meter square (uCi/m:) area were data, approximately 50 properties were observed. identified as having contamination above the cleanup levels. During the remedial design Indoor gamma exposure rates ranged from phase, EPA will delineate the extent of background to 900 \iRfh. contamination on these properties in order'Zo design a cleanup plan for each property. An estimated 1.460 cubic yards of contaminated structural materials in the • EPA identified approximately 600 properties building itself were identified, with thorium that are either adjacent to the known concentrations as high as 750 pCi/g. contaminated properties or have gamma exposure rates above background levels. In In the basement of the former GGM building, the RI report, these properties are termed radon decay product concentrations measured "suspect properties." During the remedial 1.7 WL, compared to an average background design phase, EPA will investigate and sample level of 0.005 WL. these properties to see if there is any radiological contamination present. If Certain semi-volatile organic compounds and contamination above the cleanup objectives is metals were identified. These were; however, found, EPA will delineate the extent of this at such low levels that they are not chemicals contamination and design a cleanup plan for of concern. These contaminants may be these properties. indicative of "Historic Fill". If this is confirmed in the remedial design, then there jSUMMARY OF SITE RISK may be no need to excavate this soil. Instead, it may be more appropriate to cap these soils A baseline risk assessment was conducted for the in place. former Welsbach Facility, the former GGM Faci1 and the Vicinity Properties utilizing analytical daur

EPA Region 2 - February 1999 Page 8 500073 obtained during the RI. The baseline risk assessment known carcinogens. Nonradiological chemical estimates the human health risk which could result contaminants (e.g., PAHs and arsenic) may exhibit from the contamination at a site if no remedial action both carcinogenic and noncarcinogenic health effects. were taken. EPA's acceptable cancer risk range is 10"* to 10'b Ecological risks, that is, the risk to aquatic and which can be interpreted to mean that an individual terrestrial wildlife (plants and animals), were not may have a one in 10.000 to one in 1.000.000 evaluated for this operable unit because the study increased chance of developing cancer because of areas consisted primarily of residential and site-related exposure to a carcinogen. commercial properties. An Ecological Risk Assessment will be conducted in a future RI to Human health risks were estimated for both evaluate the potential for adverse effects to aquatic radionuclides and chemicals of concern at the former and terrestrial wildlife (plants and animals) in Welsbach and GGM Facilities, and for radionuclides accordance with Ecological Risk Assessment of concern at the Vicinity Properties. Budding Guidance for Superfund, Process for Designing and materials and/or soil were the environmental media of Conducting Ecological Risk Assessments (EPA 540- concern. Risks (that is, the probability of developing R-97-006). a cancer because of exposure to radioactive materials) were calculated based on "reasonable To evaluate human health risks, a four-step process maximum exposure" according to EPA guidance. was used for assessing site-related risks for a This means that risks are estimated as a result of reasonable maximum exposure scenario. These steps exposure to site-related carcinogens over a 30-year are: Hazard Identification - identified the lifetime under the specific exposure conditions at a contaminants of concern at the site based on several site and other exposure assumptions that result in an factors such as toxicity, frequency of occurrence, and overall exposure estimate that is conservative but concentration; Exposure Assessment - estimated the within a realistic range of exposure. magnitude of actual and/or potential human exposures, the frequency and duration of these In assessing potential human health risks from exposures, and the pathways (e.g., ingesting exposure to the radionuclides, several exposure contaminated soil) by which humans are potentially scenarios involving exposure to external gamma exposed; Toxicity A ssessment - determined the types radiation, ingestion of radioactive materials, and of adverse health effects associated with exposures to inhalation of radioactive materials were evaluated. site contaminants, and the relationship between Risks were estimated for several current and future magnitude of exposure (dose) and severity of adverse scenarios, and were compared to the risk from natural effects (response); and Risk Characterization - background sources of radiation. summarized and combined outputs of the exposure and toxicity assessments to provide a quantitative The maximum excess lifetime radiogenic (radiation (e.g., one-in-a-million excess cancer risk) assessment induced cell damage) cancer risks, that is, the risks of site-related risks. due solely to the presence of radioactive materials above background levels, are 5.7 x 10"2 at the former For risk assessment purposes, individual contaminants Welsbach Facility (to the current and future site are typically separated into two categories of health worker), 1.8 x 10'' at the former GGM Facility (to a hazard depending on whether they exhibit hypothetical future site worker), and 1.8 x 10"2 to a carcinogenic effects (causing cancer) or resident of a vicinity property. These radiogenic risks noncarcinogenic effects (causing health effects other exceed EPA's acceptable risk range. The cancer risk than cancer.) Radionuclides (e.g., radium, thorium, from chemical exposures to the same populations at radon, thoron, and radon/thoron decay products) are the former Welsbach and GGM Facilities was also

EPA Region 2 - February 1999 Page 9 500074 evaluated. The cancer risk did not exceed EPA's risk in Study Areas 3 and 5 around Newton Creek. An range and; therefore, no additional remedial action is ecological risk characterization for these areas u;" e necessary because of chemical contaminants. conducted in a future operable unit. ^

To assess the potential for cumulative Actual or threatened releases of hazardous substances noncarcinogenic effects posed by multiple from the Site, if not addressed by the preferred contaminants, EPA has developed a hazard index alternatives, or one of the other active measures (HI). The HI is derived by adding the noncancer considered, may present a current or potential threat risks for site chemicals with the same target organ or to public health, welfare, or the environment mechanism of toxicity. When the HI exceeds 1.0. there may be concern for adverse health effects due to I REMEDIAL ACTION OBJECTIVES exposure to multiple chemicals. Remedial action objectives are specific goals to For the Welsbach/GGM site, non-cancer health protect human health and the environment. These effects were evaluated only at the former Welsbach objectives are based on available information and and GGM Facilities. The total HI for construction standards such as applicable or relevant and worker exposure to the chemicals of concern in soil appropriate requirements (ARARs) and risk based- at the former Welsbach Facility from ingestion, based levels established in the risk assessment. EPA's dermal contact, and inhalation is equal to EPA's remedia action objectives for the Welsbach/General acceptable level of 1.0. Ingestion of arsenic is the Gas Ma/..ie Contamination site are to take measures predominant contributor to the risk estimate. The that will prevent or mitigate further release of total HI for construction worker exposure to the radioactive contaminated materials to the surrounding chemicals of concern in soil at the GGM Facility from 2 environmen: and to eliminate or minimize the risk K ingestion. dermal contact, and inhalation is 3 x 10' ; human heauh and the environment. The sources _ this hazard index is below EPA's acceptable level of r radiation include both contaminated soil and •>. indicating that adverse, noncarcinogenic health structural materials. Direct radiation, inhalation. meets from such exposure are unlikely. ingestion of plants and soil are potential pathways. EPA proposes the following remedial action The following are the dominant radiological exposure objectives for the Site: pathway risks for the various exposure scenarios evaluated for the Welsbach/GGM site. At residential • Eliminate or minimize the potential for properties and the former Welsbach Facility, the humans to ingest, come into dermal contact majority of risk is from exposure to external gamma with, or inhale particulates of radioactive radiation, or direct radiation. Occupants of the constituents or to be exposed to external former GGM Facility (current and future trespassers gamma radiation in order to achieve the level and future site workers) are at risk primarily from of protection required by the NCP (10'^ to inhalation of thoron decay products. Future 10'6 risk range). construction worker risk is primarily due to direct radiation, although inhalation of particulates • Prevent long-term exposure to thorium- and containing radioactive material also contributes a radium-contaminated material (e.g., soil) with significant portion of the risk. concentrations greater than 5 pCi/g. 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

EPA Region 2 - February 1999 Page 10 500075 • Prevent exposure to indoor concentrations of inactive uranium processing sites. EPA considers the radon gas and radon decay products greater cleanup standards in 40 CFR 192 to be relevant and than 4 pCi/L and 0.02 WL', respectively. appropriate for the Site. The relevant portions of 40 CFR 192 include limiting exposure to: radon deca\ • Prevent direct contact with building surfaces products to levels less than 0.02 WL and radium exhibiting total surface thorium contamination concentrations (implemented as the sum of Ra-22t> exceeding 0.026 uCi/m2 above background. and Ra-228) to 5 pCi/gram. EPA, in Directive No 9200.4-25, states that whenever the 5 pCi'g radium • Prevent migration of thorium-contaminated soil cleanup standard is determined to be relevant and material that could result in the exposures appropriate at a CERCLA site which contains both described above. radium and thorium in the waste, the 5 pCi g cleanup standard also applies to thorium (implemented as the • Comply with chemical-, location-, and action- sum of Th-230 and Th-232). specific ARARs. 4 In achieving the remedial action objectives for the EPA. in the Office of Solid Waste and Emergency Site, EPA would rely on the ALARA principles used Response (OSWER) Directives No. 9200.4-18, and at other radiological contaminated sites in New No. 9200.4-25. developed health guidelines for Jersey. Applying ALARA principles means taking limiting exposure to ionizing radiation from radium additional measures during implementation of the and other sources. To further ensure protectiveness, remedial action, beyond those required to meet a those health guidelines can be supplemented by specified cleanup goal, to assure protectiveness. An selecting response actions which reduce exposures ALARA approach is being used because of the long- resulting from ionizing radiation to levels that are As lived nature of radionuclides, the difficulty in Low As Reasonably Achievable (ALARA2) taking eliminating routes of exposure, limitations of the into consideration technical, economic and social analytical equipment to detect radionuclides. and site- factors. specific factors which ,;.ay make it necessary to remove material at levels below 5 pCi/g to achieve EPA recommends that indoor radon concentrations in adequate public health protection. homes should not exceed 4 pCi per liter of air (pCi/1). In 40 CFR 192, "Standards for Cleanup of Land and EPA's experience at the other radiological Buildings Contaminated with Residual Radioactive contaminated sites in New Jersey has shown that the Materials From Inactive Uranium Processing Sites," remedial action objectives noted above can be EPA enacted standards for limiting exposure to radon achieved by incorporating ALARA principles. decay products and gamma radiation. While this Therefore, by using similar remedial action objective' regulation is not directly applicable to this site the Welsbach/GGM Site would pose no unacceptable because the Welsbach and GGM Facilities are not risk for residential uses after cleanup, and would result in a cleanup that is protective under CERCLA.

' Exposure to 4 pCi/l of air for radon corresponds to an To meet the remedial action objectives outlined approximate annual average exposure of 0.02 WL for above, EPA plans to excavate radiologically radon decay products. contaminated soils and waste materials, and dispose of them off-site. Excavation of soils will eliminate th References for ALARA principles -"Radiation threat of physical migration of contaminants, as well Protection Guidance to Federal Agencies for as potential exposure through various pathways Occupational Exposure", 1987, Federal Register 52, (ingestion, inhalation, dermal contact, external No. 17, 2822; and "Federal Guidance Report No. 11", gamma radiation, etc.)- Contaminated soils will be September 1988. EPA-520\1-88-020.

EPA Region 2 - February 1999 Page 11 500076 shipped off-site to a licensed commercial facility for permanent long-term management. 'SUMMARY OF REMEDIAL ALTERNATIVES _

The planned response action for buildings, specifically CERCLA requires that each remedv be protective ot at GGM, is decontamination, demolition, and off-site human health and the environment, oe cost effective. disposal of contaminated materials to reduce comply with other statutor- laws, and utilize exposures within acceptable levels for future use of permanent solutions and alternative treatment the property. technologies and resource recover, alternatives to the maximum extent practicable. In addition, the statute Any potential ecological risks and adverse impacts includes a preference for the use of treatment as a from existing radiological contamination on the principal element for the reduction of toxicit\. properties addressed under this action will be mobility, or volume of hazardous substances. minimized because the contaminated soils will be CERCLA also requires that if a remedial action is removed and backfilled with clean soil. There are selected that results in hazardous substance's, also limited habitats for ecological receptors at the pollutants, or contaminants remaining at a site above properties addressed under this action. Furthermore, levels that allow for unlimited use and unrestricted by removing the radiologically contaminated waste, exposure. EPA must review the action no less than the surface water and sheet flow pathways will be every five years after the start of the action. eliminated as routes of exposure. This Proposed Plan evaluates the Remedial Wetlands are not present at both the former Welsbach Alternatives for addressing the contamination anu GGM facilities. However, wetlands are present associated with the Site. Cleanup alternatives were in Areas 3 and 5, along the South Branch of Newton evaluated for the Vicinity Properties, the former Creek. During the remedial design. EPA will Welsbach Facility and the General Gas Mantle delineate wetland areas whi.h are actually or Facility. The alternatives include: No Action, potentially impacted by contamination or remedial Engineering Controls, und Excavation and Off-Site activities. Disposal.

SCOPE AND ROLE OF ACTION Vicinity Properties

The goal of the proposed remedial action is to The Vicinity Properties include residential, minimize or eliminate the potential health hazard commercial, and public properties where radiological posed by all radiologically contaminated soils and contamination was identified in soils situated structural materials at the Site. Because of the large outdoors and/or beneath buildings, and properties geographical area associated with this project, not all with indoor air contamination. potentially contaminated areas were evaluated during the RI. EPA will investigate additional areas as part Vicinity Properties Alternative 1 (V-l) - of the remedial design to delineate the full extent of No Action contamr tion. The Armstrong Building, ground water, Su. ^ace water, and sediments, will be Estimated Capital Cost: $0 addressed in future Operable Units. Estimated Annual Operation and Maintenance (O&M) Cost: $0 Estimated Present Worth: $0 Estimated Implementation Period none

EPA ." sgion 2 - February 1999 Page 12 500077 A "No Action" alternative is evaluated for every time to design and construct the remedy is from three Superfund site to establish a baseline for comparison to five years. with remedial alternatives. Under this alternative, no remedial action would be performed at the Site. Vicinity Properties Alternative 3 (V-3) - Previous interim remedial actions implemented by Excavation and Off-Site Disposal NJDEP would not be maintained. Current institutional controls including fencing would not be Estimated Capital Cost: $13.408.560 maintained. Because hazardous substances would Estimated Annual O&M Cost: $0 remain at the Vicinity Properties above acceptable Estimated Present Worth: S13.408.560 levels, five-year reviews would be required. Estimated Implementation Period 3-5 years

Vicinity Properties Alternative 2 (V-2) - Under this alternative, soil on the Vicinity Properties Engineering Controls contaminated above 5 pCi/g greater than background would be excavated and disposed of at a licensed Estimated Capital Cost: $900,000 off-site facility. Radiologically contaminated building Estimated Annual O&M Cost: $99,000 demolition debris would also be excavated and Estimated Present Worth: $1.810,000 disposed of off-site. EPA will replace these areas Estimated Implementation Period 3-5 years with clean fill. The total volume of soils requiring disposal at the Vicinity' Properties is estimated to be Under this alternative, outdoor gamma shielding 11.000 cubic yards. The total volume of buried would be placed at each property which has - demolition debris at the Vicinity Properties is contaminated soil. The gamma shield would consist estimated to be 2.250 cubic yards. of a geotextile liner, fill material, 6-inches topsoil, and vegetation (seeding or sod). The thickness of the fill Where contamination is suspected underneath material will vary from 6 inches to 42 inches, based buildings, this alternative includes removing concrete on the shielding requirements of each property. A flooring and underpinning the buildings. After the total of approximately 75,000 square feet of coverage removal of contaminated soil, a new concrete floor would be installed. would be constructed. Approximately 21 properties would require concrete floor removal and In addition, indoor gamma shielding would be placed replacement. Underpinning is estimated to be inside buildings exhibiting unacceptable exposure required at one property. levels. The shielding would consist of concrete or steel as needed. The concrete would range from 4 The estimated time to design and construct the inches to 7 inches thick, and about 1.5 inches of steel remedy is from three to five years. Provisions would sheeting would be placed on wall surfaces. need to be made for the temporary relocation of Approximately 2,000 square feet of concrete and 60 residents and businesses during construction of this square feet of steel coverage would be installed. alternative. During excavation, short-term provisions Finally, if any property buildings exhibit elevated to prevent dust generation and protect workers would radon/thoron levels, a sub-slab ventilation radon be required. mitigation system would be installed. Welsbach Facility Institutional controls, such as deed restrictions, would be required to ensure the protectiveness of the The former Welsbach Facility is presently owned and remedy. Because hazardous substances would remain operated by Holt, as a cargo storage and oversea at the Vicinity Properties above acceptable levels, shipping operation. Radiological contamination on five-year reviews would be required. The estimated the property is present in the outdoor portion of the

EPA Region 2 - February 1999 Page 13 500078 storage area. Most of the contamination is located in Welsbach Alternative 3(\V-3) - Excavation and a single contiguous area, with smaller elevated areas Off-Site Disposal scattered across the property. The Armstrong Building is not included in the remediation Estimated Capital Cost: S18.50:oc>0 alternatives. Holt is preparing an RI/FS that will Estimated Annual O&M Cost: SO address the remedial alternatives for that building. Estimated Present Worth: $18.503.560 Estimated Implementation Period 3-5 years Welsbach Alternative 1 (\V-1) - No Action Under this alternative, all soil contamination at the Estimated Capital Cost: $0 Welsbach site above 5 pCi/g greater than background Estimated Annual O&M Cost: $0 would be excavated and disposed of at a licensed Estimated Present Worth: $0 off-site facility Contaminated building demolition Estimated Implementation Period none debris which is currently buried on-site because of former demolition activities would also be*excavated Under this alternative, no remedial action would be and disposed of at an appropriate off-site facility. performed at the Site. Current institutional controls EPA will replace these areas with clean fill. The including fencing would not be maintained. Because volume of soils above the cleanup standard is hazardous substances would remain on the property estimated to be 19,400 cubic yards. The volume of above acceptable levels, five-year reviews would be buried demolition debris requiring disposal is required. estimated to be 4,400 cubic yards. During excavation, short-term provisions to prevent dust Welsbach Alternative 2 (W-2) - Engineering generation and protect workers would be required. Controls Subsurface contamination on the Welsbach Facil; Estimated Capital Cost: $5,690,000 averages about 11 feet in depth. In the area of the"' Estimated Annual O&M Cost: $44,000 deepest contamination, underground tunnels dating Estimated Present Worth: $6.180.000 from around the turn of the century are present. Estimated Implementation Period 3-5 vears These tunnels extend down to anout 10 to 12 feet in depth. These tunnels can act as conduits to carry Under this alternative outdoor gamma shielding radon gas to nearby residential properties. As a would be placed in the areas of the former Welsbach result, the remedy includes excavation of the property that have soil contamination. The gamma contamination to these depths to prevent any future shield would consist of steel covered by asphalt. The radon migration problems and to protect future steel would range in thickness from 1 to 5 inches, workers from elevated gamma radiation levels. The with a 4-inch asphalt cover. Approximately 53,000 estimated time to design and construct the remedy is square feet of area would be covered by the steel from three to five years. shielding. General Gas Mantle Facility Institutional controls, such as deed restrictions, would be required to ensure the protectiveness of the The GGM building is presently inactive and in a remedy. Because hazardous substances would remain dilapidated state. The building has been boarded shut on the property above acceptable levels, five-year and fenced in by NJDEP Radiological contamination reviews would be required. The estimated time to on the property exists both inside and outside the design and construct the remedy is from three to five bui.ding. Inside the building, cr- j-ninatio- :s present vears. in ruilding materials and in am- ;~.t air. Outside the GGM Facility, soil contamination is primarily Ic _id

EPA Region 2 - February 1999 Page 14 500079 to the immediate southwest of the GGM building building and restricting access to the building forever. extending into South Fourth Street. Two smaller would be required. Because hazardous substances areas of contaminated soils are situated to the would remain on the property above acceptable northeast of the building and in the alleyway adjacent levels, five-year reviews would be required. The to the eastern side of the building. estimated time to design and construct the remedy is from two to three years. General Gas Mantle Alternative 1 (G-l) - No Action General Gas Mantle Alternative 3 - Excavation and Off-Site Disposal of Soil and Estimated Capital Cost: $0 Building/Demolition Debris Estimated Annual O&M Cost: $0 Estimated Present Worth: $0 G-3A: Demolition and Disposal Estimated Implementation Period none Estimated Capital Cost: •S2.309.560 Under this alternative, no remedial action would be Estimated Annual O&M Cost: $0 performed at the Site. Previous interim remedial Estimated Present Worth: $2.309.560 actions would not be maintained. Current Estimated Implementation Period 1-2 vears institutional controls including fencing would not be maintained. Because hazardous substances would Under this alternative for the GGM property, soil remain on the property above acceptable levels, contaminated above 5 pCi/g greater than background five-year reviews would be required. would be excavated and disposed of at a licensed off-site facility. Contaminated building demolition General Gas Mantle Alternative 2 (G-2) - debris which is currently buried on-site because of Engineering Controls former demolition activities would also be excavated and disposed of off-site. EPA will replace these areas Estimated Capital Cost: $122,000 with clean fill. The volume of soil and buried Estimated Annual O&M Cost: $23,000 demolition debris at GGM is estimated to be 650 Estimated Present Worth: $381.000 cubic yards and 60 cubic yards, respectively. Estimated Implementation Period 2-3 years Under this alternative, the former General Gas Mantle Under this alternative, outdoor gamma shielding building would be demolished, and the demolition would be placed at the former General Gas Mantle debris would be disposed of with the contaminated property. The gamma shield would consist of either a soil. The volume of building materials to be soil shield or a concrete shield. The soil shield would demolished is estimated to be 1,400 cubic yards. include a geotextile liner, fill material, six-inches During excavation and demolition, short-term topsoil, and vegetation (seeding or sod). The provisions to prevent dust generation and protect thickness of the fill material will range from six to 24 workers would be required. The estimated time to inches. The thickness of the concrete will range from design and construct the remedy is from one to two six to eight inches. Approximately 5,000 square feet years. of coverage would be required. Areas of contamination extending into South Fourth Street G-3B: Decontamination, Demolition and Disposal would be covered with an additional 4 inches of asphalt. Estimated Capital Cost: $1,736,56C Estimated Annual O&M Cost: $C Also under this alternative, significant institutional Estimated Present Worth: $1,736,560 controls, including permanently boarding shut the Estimated Implementation Period 1 -2 yean

EPA Region 2 - February 1999 Page 15 500080 This alternative essentially would be the same as 3 A GLOSSARY OF EVALUATION CRITERIA above, except that the demolition of the building would proceed in steps. First, the wood structural Threshold Criteria materials and roofing would be removed. This debris Overall Protection of Human Health and the Environment: This would be disposed of with the contaminated soil and criterion addresses whether or not a remedy provides adequate is estimated to be approximately 450 cubic yards. protection and describes how risks are eliminated, reduced or The remainder of the building (approximately 950 controlled through treatment, engineering controls or cubic yards of primarily masonry and concrete) would institutional controls. then be decontaminated using pressure washing Compliance with Applicable or Relevant and Appropriate before demolition. The building would then be Requirements (ARARsV This criterion addresses whether or not demolished and the debris would be crushed and sent a remedy will meet all of the applicable or relevant and off-site for disposal. The estimated time to design appropriate requirements of other environmental statutes or and construct the remedy is from one to two years. provide grounds for invoking a waiver.

4 EVALUATION OF REMEDIAL ALTERNATIVES" Primary Balancing Criteria Long-Term Effectiveness and Permanence: This criterion refers Each of the above alternatives was evaluated against to the ability of the remedy to maintain reliable protection of specific criteria on the basis of the statute ry human health and the environment over time once cleanup goals requirements of CERCLA Section 121. Nine criteria have been met. are used in evaluating the alternatives. The first two Reduction of Toxicitv. Mobility and Volmr. -out criteria are threshold criteria which must be met by Treatment: This criterion addresses the anticipated performance each alternative. The next five criteria a . the of the treatment technologies that a remedy mz\ employ. primary balancing criteria upon which the analysis is r based. The final two criteria are referred to as Short-Term Effectiveness: This criterion im.. • • s the period time needed to achieve protection and any ac — ? impacts o_ modifying criteria and are applied, following the human health and the environment that ma> n. posed during the public comment period, to evaluate state and construction and implementation period unti : :eanup goals are community acceptance. achieved

A comparative analysis of these alternatives, based Implementabilitv: This criterion examines the technical and upon these criteria, is presented below. administrative feasibility of a remedy, includ..-.<_ availability of materials and services needed to implement a particular option.

Overall Protection to Human Health and the Cost: This criterion includes capital, operation and maintenance Environment costs, and net present worth.

The No Action Alternatives (W-l, V-l, G-l) would Modifying Criteria not be protective of human health and the State Acceptance: This criterion indicates whether, based on its environment because the Site would remain in its review of the Rl/FS reports and the Proposed Plan, the State current contaminated condition. Therefore, the No concurs with, opposes, or has no comment on the preferred Action Alternatives have been eliminated from alternative. consideration and will not be discussed further. Community Acceptance: This criterion will be addressed in the Record of Decision following a review of the public comments Under the Engineering Controls Alternatives (W-2, received on the Rl/FS reports and the Proposed Plan. V-2, G-2), potential ex-.sure routes of gamma radiation would be sh: -d by concrete and/or steel sheeting. The shieldir... >uld have to be maintained, and institutional controls, such as deed restrictions,

EPA Region 2 - Februan -'J 9 Page 16 500081 would be required to ensure that these alternatives Energy Act (AEA).3 Since Welsbach processed are protective. monazite ores to extract thorium. EPA has determined Section 1 l(e)(2) of the AEA to be For the Excavation and Off-Site Disposal Alternatives relevant and appropriate. Because the waste (W-3, V-3, G-3), all radiological contamination above materials from the Welsbach Facility and its cleanup standards would be removed and disposed of operations are an AEA Section 1 l(e)(2) waste off-site in a licensed disposal facility. Institutional material, they must be disposed of at a licensed controls would not be necessary. All unacceptable facility in accordance with AEA requirements. risks to human health and the environment would be eliminated by the excavation and off-site disposal of The Excavation and Off-Site Disposal Alternatives the radiologically contaminated waste. (W-3, V-3, G-3) would comply with all ARARs. All contamination above the 40 CFR 192 cleanup Compliance with Applicable or Relevant, and standards would be excavated and sent off-site for Appropriate Requirements disposal. The Engineering Controls Alternatives (W- 2, V-2, G-2) would comply with all ARARs that limit Actions taken at any Superfund site must meet all exposure to gamma radiation and radon. However. ARARs of federal and state law, or provide grounds the Engineering Controls Alternatives would not for invoking a waiver of these requirements. There comply with 40 CFR 192, because the contaminated are three types of ARARs: action-specific, chemical- material would remain at the Site. specific, and location-specific. Action-specific ARARs are technology or activity-specific Long-Term Effectiveness and Permanence requirements or limitations related to various activities. Chemical-specific ARARs are usually The Excavation and Off-Site Disposal Alternatives numerical values which establish the amount or (W-3, V-3, G-3) are all effective and permanent. concentration of a chemical that may be found in, or They are considered a final remedial action. The discharged to, the ambient environment. Location- contaminated material would be removed from the specific requirements are restrictions placed on the Site and stored in a controlled, licensed facility. concentrations of hazardous substances or the conduct of activities solely because they occur in a The long-term effectiveness of the Engineering special location. Controls Alternatives W-2 and V-2 would be uncertain. Contaminated material would remain in For the Welsbach/GGM site, no requirements are place, and the engineering controls would require applicable for the cleanup of the radiological deed restrictions and long-term monitoring. In contamination. However, as discussed earlier, addition, the engineering controls would have to be portions of the federal regulations governing the maintained forever because the half-life of thorium is cleanup of uranium mill tailings from inactive uranium 14 billion years. processing sites, at 40 CFR 192, have been determined to be relevant and appropriate. These Alternative G-2 (Engineering Controls for General provide the radon decay products standard of 0.02 Gas Mantle) would not be effective in the long-term WL and soil cleanup criteria of 5 pCi/g. In addition, waste materials produced at the former Welsbach 3 Facility would be considered "by-product" material as "By-product" material means (1) any radioactive material defined by Section 1 l(e)(2) of the U.S. Atomic (except special nuclear material) yielded in or made radioactive by exposure to the radiation incident to the process of producing or utilizing special nuclear material, and (2) the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content.

EPA Region 2 - February 1999 Page 17 500082 because of the dilapidated nature of the building, even The Engineering Control Alternatives involve less if the building were completely sealed. intrusive activities, and pose less of a threat to workers and the surrounding community than the Reduction of Toxicirv. Mobility, or Volume Through Excavation and Off-Site Disposal Alternatives. ~" Treatment However, both the Engineering Control Alternatives and the Excavation and Off-Site Disposal Alternatives No treatment technology is known today that can involve intrusive activities, including, in some cases. substantially reduce the toxicity, mobility, or volume temporary relocation of residents. of radioactive materials found at the Site, and meet the 40 CFR 192 cleanup standards. The total amount The Excavation and Off-Site Disposal Alternatives of radioactivity cannot be altered or destroyed, as is have a greater potential adverse impact in the short often possible with chemical contaminants. term because of the excavation of radiologically- Therefore, none of the remedial alternatives fully contaminated soil. For future workers, this could satisfy this evaluation criteria. lead to increased short-f.erm exposure to ration, gamma radiation, and soil radionuclides. Dust However, the Excavation and Off-Site Disposal suppression techniques and/or other measures would Alternatives (W-3, V-3, G-3) would lead to some be required to minimize the impacts of this reduction in the mobility of the material because alternative. However, under Alternative V-2 radioactive contaminated materials would be (Engineering Controls for the Vicinity Properties), contained in a secure landfill cell. Alternative G-3 there would be some increased short-term risk to with Option B (the General Gas Mantle workers during the installation of the radon mitigation Decontamination and Demolition Alternative) would systems. This is due to the need to excavate under reduce the volume of contaminated building debris to the foundation of homes that require radon be disposed of off-site by pressure washing the mitigation. radioactive contamination off the floors and walls before demolition. The contaminants would be Implementabilitv concentrated in the filtrate after pressure washing. Only this filtrate would have to be disposed of in a The Excavation and Disposal Alternatives (W-3. V-3, licensed facility. G-3) are readily implementable. Similar activities have been utilized at other radiological ly- Short-Term Effectiveness contaminated sites around the country. There is an available off-site disposal facility, which is accessible Both the Engineering Control Alternatives (W-2, V- by both truck and rail. However, the continued 2. G-2) and the Excavation and Off-Site Disposal availability of this off-site disposal facility is required Alternatives (W-3, V-3, G-3) provide effective short- for implementation of these alternatives. term protection, and become effective as they are implemented at individual properties. The estimated Implementation of the Engineering Controls time to design and construct the remedial alternatives Alternatives V-2 and G-2 may pose some difficulties. for the former Welsbach Facility (Alternatives W-2 Under Alternative V-2 (for the Vicinity Properties), and W-3) and the Vicinity Properties (Alternatives there may be some difficulty in getting the consent of V-2 and V-3) is from three to five years. For the all of the property owners to restrict future work on former GGM Facility, the estimated time to design their properties. EPA would have to reach and construct the Engineering Control Alternative agreements with individual property owners to file G-2 is from two to three years, and for the Off-Site Declarations of Environmental Restrictions i.e., deed Disposal Alternative G-3 from one to two years. restrictions) on their properties. For Alternative G-2 (for General Gas Mantle), it would be difficult to

EPA Region 2 - February 1999 Page 18 500083 keep the building permanently sealed from State Acceptance trespassers. The State of New Jersey is currently evaluating the Cost Proposed Plan.

Alternative V-2 includes construction costs of Community Acceptance $900,000 to implement engineering control measures at the Vicinity Properties. Annual O&M costs are Community acceptance of the preferred alternatives estimated to be $99,000. The present worth cost of will be evaluated after the public comment period Alternative V-2 is $1,810,000, with O&M costs ends and will be described in the Record of Decision assumed for 3'"- years. Alternative W-2 includes for the Site. construction coats of $5,690,000 to implement engineering control measures at the former Welsbach Facility. Annual O&M costs are estimated to be PREFERRED ALTERNATIVE______$44,000. The present worth cost of Alternative W-_ is $6,180,000, with O&M costs assumed for 30 years. Based on the information available to evaluate the Alternative G-2 includes construction costs of remedial alternatives against the nine criteria, EPA $122.000 to implement engineering controls at the recommends the Excavation and Off-Site Disposal General Gas Mantle Facility. Annual O&M costs are Alternatives (V-3, W-3, and G-3 with Option B) as estimated to be $23,000. The present worth cost of the preferred alternatives for the cleanup of the Alternative G-2 is $381,000, with O&M costs contaminated soil and building materials at the Site. assumed for 30 years. The radionuclides in question have half-lives far greater than 30 years, so any of the Rationale for the Preferred Alternatives Engineering Controls remedies must be maintained effectively forever. For each of the three property types, EPA's preferred alternative is the excavation and off-site disposal Alternative V-3 includes construction costs of alternative. Alternatives V-3, W-3, and G-3 with $13,408,560 to excavate the radiologically- Option B are the most protective alternatives. contaminated soil at the Vicinity Properties and dispose of the waste at an off-site disposal facility. The radioactive half-life of thorium-232, the primary Alternative W-3 includes construction costs of contaminant of concern, is 14 billion years. Remedies $18,503,560 to excavate the radiologically- that would isolate wastes containing thorium and the contaminated soil at the former Welsbach Facility and uranium series radionuclides permanently from the dispose of the waste at an off-site disposal facility. public and the environment are preferable. Alternative G-3 - Option A involves construction costs of $2,309,560, and includes demolishing the Alternatives V-3, W-3, and G-3 result in a permanent General Gas Mantle building and disposal of all the solution to the radioactive contamination. The building debris at an off-site disposal facility longevity of these chemicals of concern (thousands to Alternative G-3 - Option B involves construction billions of years) favors excavation which costs of $1,736,560, and includes decontaminating permanently removes the contaminants from their the General Gas Mantle building before its current uncontrolled locations. Commercial disposal demolition. There are no O&M costs associated with at a licensed facility with an appropriate closure plan the Excavation and Off-Site Disposal Alternatives will ensure that these radiological wastes are (W-3, V-3, G-3 Options A and B). 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 19 500084 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 V- 3, 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 1^99 Page 20 500085 MAILING LIST ADDITIONS

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 U.S. Environmental Protection Agency 290 Broadway, 26th Floor New York, NY 10007-1866

Name ______Address

Telephone Affiliation^

EPA Region 2 - February 1999 Page 21 500086 Superfund Fact Sheet xv ERA Welsbach/General Gas Mantle Contamination Site Gloucester City/Camden, New Jersey February

INTRODUCTION Study Area Four: residential properties in the Fairview section of Camden. This summary highlights the U.S. Environmental Protection Agency's (EPA's) Proposed Plan for the Study Area Five: residential properties, vacant land cleanup of contaminated soils and building materials at properties, and two municipal parks near Temple Avenue the Welsbach/ General Gas Mantle (Welsbach/GGM) and the South Branch of Newton Creek in Gloucester Superfund site in Camden County, New Jersey. City.

Investigations at the Welsbach/GGM site have shown Study Area Six: vacant lots in a residential zoned area that some commercial, residential, and public of Gloucester City. properties located in the Camder and Gloucester City area contain soil contaminated to varying degrees with thorium, radium, and uranium. Mark Your Calendar These contaminants are radioactive and associated with waste materials generated in the manufacturing activities that took place at the former Welsbach and Public Meetings: General Gas Mantle facilities. Both facilities used radioactive elements, specifically thorium, in the Gloucester City production of gas mantles, were used for lighting Pine Grove Fire Station #2 purposes in the late 19th and early 20th centuries. on Radium, uranium and thorium are associated with Tuesday, February 23,1999 at 7:00 p.m. mantle production process. Camden Radioactive elements such as thorium, radium or Camden County Municipal Utilities Authority uranium are unstable and as a result release energy. Auditorium Thorium releases energy in the form of alpha particles, on beta particles or gamma radiation. This radioactive Wednesday , February 24,1999 at 7:00 p.m. decay also forms radon gas. Radon gas is odorless, colorless and tasteless and can Availability Sessions • informal question and be harmful if people are exposed to it over many years. answer sessions: Gamma radiation also may pose health problems to people who come in contact with the wastes over long Gloucester City periods of time. Pine Grove Fire Station #2 on Tuesday, February 23,1999 WELSBACH/ GENERAL GAS MANTLE SITE 1:00 - 4:00 p.m.;

The Welsbach/GGM site is comprised of properties Camden within the following six study areas: Camden County Municipal Utilities Authority Auditorium on Study Area One: a mixed industrial, commercial, and Wednesday February 24,1999 resioential zoned section of Camden which includes 1:00 -4cQOp.m. the former GGM facility and residential and commercial properties which surround the facility. nr Study Area Two: an industrial zoned property in The public comment on the proposed Gloucester City along the Delaware River, formerly llacch3,i 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 Land Preserve. 500087 REMEDIAL INVESTIGATION AND FEASIBILITY While some of the activities proposed for site cleanup STUDY may be disruptive to individual homeowneis or the community, EPA will work with affected residents and the In 1997 ERA began a remedial investigation and community to ensure a safe and quick cleanup of the feasibility study (RI/FS) to determine the source and site. extent of radiological contamination in the Camden and Gloucester City area and to evaluate cleanup EPA relies on public input to ensure that the concerns of alternatives. The areas investigated during the RI/FS the community are considered in selecting an effective included the former Welsbach facility, the former GGM remedy for each Superfund site. To this end. EPA has facility, and 20 of the radiologically contaminated made the RI/FS report, Proposed Plan, and supporting properties identified during earlier investigations documentation available to the public for a public conducted by the New Jersey Department of comment period from February 1, 1999, to March 3. Environmental Protection (NJDEP). The findings of 1999. EPA considers all public comments before the remedial investigation were then used to prepare a selecting a final cleanup plan. For more information feasibility study, which evaluates cleanup alternatives. please contact: Natalie Loney. Community Relations Coordinator at (212) 637-3639 or Rick Robinson, Project THE PROPOSED PLAN Manager at (212) 637-4371.

In addition to the RI/FS, ERA has prepared a Proposed The RI/FS report which presents the results of field Plan for the Welsbach/GGM site which identifies EPA's investigations conducted to date at these properties has preferred cleanup alternatives for the radiologically been completed. Copies of the RI/FS report. Proposed contaminated properties. The alternatives which were Plan, and supporting documentation are available at evaluated include: No Action; Installation of EPA's offices at: Engineering Controls; and Excavation and Off-Site th Disposal of Contaminated Materials. 290 Broadway, 18 Floor New York, NY EPA's preferred alternative is Excavation and Off-site 10007-1866 Disposal of Contaminated Materials. This alternative (212) 637-4308 calls for the removal and off-site disposal of radioactively-contaminated soil. The excavated areas and at the following repositories: will be backfilled with clean soil. Where necessary, contaminated building material will be removed and City of Camden Main Library replaced with clean material. Removal of contaminated 418 Federal Street of soils and building materials will eliminate potential Camden, NJ 08103 gamma radiation and radon exposure through various (609) 757-7650 pathways (ingestion, inhalation, dermal contact, etc.). Hynes Center m The planned response action for the former GGM 1855 South 4 Street building, is decontamination, demolition, and off-site Camden, NJ 80104 disposal of contaminated materials. All contaminated (609) 966-9617 material will be taken to an approved off-site disposal facility. Gloucester City Public Library Monmouth and Hudson Streets The estimated volumes of contaminated material from Gloucester City, NJ 08030 the site properties are: (609)456-4181

• Vicinity Properties: SUMMARY soil -11,000 cubic yards; demolition debris - 2,250 cubic yards; The Proposed Plan presents EPA's preferred remedy for the cleanup of contaminated properties which are part of • Former Welsbach Facility: the Welsbach/GGM site. EPA proposes to excavate soil -19,400 cubic yards; contaminated soil and waste materials; decontaminate demolition debris - 4,400 cubic yards; (as appropriate), demolish, and remove contaminated debris and building material; dispose of the • Former GGM Facility: contaminated soils and waste materials in a licensed off- soil - 650 cubic yards; site disposal facility; and restore the affected properties demolition debris - 60 cubic yards; with clean fill. The proposed remedy would provide a building materials - 450 cubic yards. permanent cleanup response and would be protective of human health and the environment. 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.

500088 Appendix B

Public Notices

500089 .Torn, 19. Proof of Publication of Notice h The Pliaddphia hqunr Una** Act No. 1*0, fJL. 977, My 9, 1976

Commonwealth o/ Pennsylvania ss.: County of Philadelphia

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

February 99 and the...... day of. ..A.D. 19......

Affiant further deposes that he is duly authorized Copy or itofico or

by Philadelphia Newspapers, Inc., a corporation, f •- 'Z *>, t^fUBUC MEETING .-'.".. -. ~-r •'*» •- .Propoaao- Plan to be Olecusssd for WeWMck/Oofteral publisher of THE PHILADELPHIA IN- ' . Oao Mantle Contamination Superfund SHe . ' -. Cemdsn/Olouoeeier City. New Jersey The United Statae Environmental Protection'Agency QUIRER, a daily newspaper, to verify the forego- (EPA) will hold Two Informational public meetings to die* cuss the f Indlnga of a recently completed remedial Inves- ing statement under oath, and also declares that tigation and teealblllty study (RI/FS). and announce the proposed remedy for the cleanup of residential and other affiant is not interested in the subject matter of properties which comprise the Wetabacn/Generai Oa» Mantle Contamination Supertund site. The RI/FS waa conducted to determine the source and extent of radia- the aforesaid notice or publication, and that all tion contamination In the area and to evaluate cleanup allegations in the foregoing statement as to time, alternatives. The first public meeting to discuss the flncl- place and character of publication are true. . . ,•- -Mth* Pine QroveFtre Station «>. ^f toeated at Ninth end Jereey Avenue

"heaecond meeting will be held on: .. at the Camdan County trinity Aulnomy* emlttui IMHI . loealed at 1B46 Ferry Avenue In Camden, New Jaraey . • - • t*-r.-fc-f.w\ ,v..r.* . - • >-- .. - -, The RI/FS evaluated three altematrvea for addreealno ra- U dlologlcaUy contaminated eoll and atructural material*. . 1 2) Englnaertng and Inatttutlonal Convota '^^-'r*- • .: I ' 8) Excavation and Off-Site Olipoaal < -••>•-.".;•- EPA'a propoaad cleanup remedy la Alternative 13. the Excavation and Off-She Olepoaal Alternative. Under tMa alternative.' the radiological contaminated material would be removed and tranaported off the alte for dt»- poaal. All of tha aoove aiterativea are outltnad and die-

on' public Input to anaure that the concern* of - ihe community are conaidered In aaiactlog an effective rr»rneo> for each Superfund eite. To thla and. EPA naa made1 the RI/FS rapon, Propoaad Plan, and aupportlng ydocumantailon available to the public for a public com- 'ment. parted from Feoruary 1. IM* to IMoren 3. IBM. Com men ta muat bo received on or before March 3. ia«a. Sworn to and subscribed before me this...... f.5. The final declalon document will Include a summary of public commenta and EPA reaponaaa. Coploa of the RI/FS report. Propoaad Plan, and aupponing documentation are available at EPA-a office at 20O Broadway. 1 eth 1 Floor. New YorK. NY lOOO7-18Be. (212)837-4308. and at day of ...... Feb.?. }.*.*.?. jjhalonowtnalnK — ...... City of Camderi >«18FederaJ Street

'ary Public. _.__ _. . ____ . Written commenta on tna Propoaad Plan should be aont NOTARIAL SEAL My Commission Expires: RlchardJ. Roblnaon-oreall Natalia Loney - Margaret C. Ruchalski. Notary Put*c U.S. Environmental , U.S. Environmental u .", Protection Agency -•• -. Protection Agency ~ City of Phttsdetphia. Ph«a. County : 20O Broadway. 1 atn Floor - - 2BO Broadway. 28th Floor ' NMVOTK. NYirmn7.iaee NewYorK.NY 1OO07-1888 My Commission Expires Mty 27. 200° ____(212)837-383?______500090 ' PUBLIC MBBTINO •' i transported off the site tor, •Proposed Plan I* be Dls-> disposal. All of the above ol-i— 1 fussed for Welsboch/a*n>t ternallves ore outlined and ! iui «ro1 <•«» Mantle *••/•» discussed In the Proposed t STATE OF NEW JERSEY Contamination Juperteftd*. Plan. EPA relies on public,, ss " • Cite •'- • •' .«") Input to ensure that the con- CAMDEN COUNTY i. ! iGarnde n/Oloucester, Clrv<>. corns ol the community are,) ! ••*". . . New Jersey. , The United State* Environ-: Supertund site. To this end,.) .mental Protection Agency EPAhasmodemeRI/FSre-i I.(EPA) will hold two Infer- port. Proposed Plan, and) i * motional public meetings 1*1 supporting documentation [ .dfacusl the findings of a re- • available to the Public for a t i lAtntly completed remedial public comment period! O investigation and feasibility* from PEBRUAHY1, IWIo , O .'iA

•- I'Jrt the Comde'n County Utlll-,. once on the ...... 2nd. ;;fy Authority's auditorium.',!• ,- ••••<* ...... EEb...9.9...... 'Jbcoted at IMS Perry Ave^ writter n commends on the* ; riii* In Camden, New Jersey;, f Proposed Plan should baj lJheRf/FS evaluated three' sent to: .-.»,!. y,,/3 • alternatives for addrasslnd (Richard J. Robinson • *' ' 'logically contomlnot'',U.S. Environmental Protect , 281239 084021 #34827 1 •d soil and structural mate-. lion Agy. , , ... .„ rid *tals.. Th.Thevy or.-'•-are: T .-..,- 2M Broadway, Itth Ft. ..,.«••• New York, NY 10007-tMe ,, •*!.' No action ' ;l... 99 i. Engineering and ' • «"" OR CALL: NATALIE LO- „ MALCOLM PIRNIE I NC Olhslltutlonol Centrals ' J **' NEY .,9 :5. Excavation and '.' ',' ".£ U.S. Environmental Protec- INTERNATIONAL B 'Off-SiteDisposal ' ' •" tion Agy. , . • i^PA's proposed cleanup no Broadway, 26th Fl. ''/ ATTNJ BOB K(ERE E remedy Is Alternative »3. New York, NY 1»M7-IMe , , „ =-, 4t>e Excavation and Off-Site (212) A37-3*3e : \Puthe MAHMAH NJ 074 Disposal Alternative. Under un»Qt iithls alternative, the radiologically contaminated ma- •ERSEV tOM/SM 1 ferial would be removed and GLOUCESTER OTY NEWS. THURSDAY FEBRUARY •» :99Q

1 !c tn>l :r.K' .'v tr". .rtit. iJu: A1| rode from Momgomerv to case on behalf ot a female P ""• ' "liege ourathleK--.iistoni.ru.. 1 All Sclma „,, fln,nv ,0 Mcn> Jlnjele Sbf w q(UK scouu wiiti those scholar, and ncn »ilh lema.c star< v jl.ar.jr • 'U'. ; u:j GirlS... phis with Or Mamn Lu- blunt and to the point snips in tneir rockets car. The iampsrn sisters ,c..u...4fr..M«i> ther King Lately though. Under we C.M! Rights get a good look at vou ' uieMcoiajes -.r.eRj:- coaches salaries are still shc s oe™ Ol"> pleading Act of !°8o the la» pro- Dr Dllnc Everen .s :em fin-. :ne Anceior: - neme fouiht over1 I tile cases of college and ,ects j:'.' of vocr ciris- tne E"«ume Director ,v tne Nuiew ,:..ier< ano m>« • oufdxe never believed high scnooi temaic ath- public, pma:r ar.j par,'- "" Satioru. \ssocianor. me îsnl iin- jr.O'tr.j:- i. jiiaaar - - r->:rn inai 1 *ould still be lesnfv- letes and nehnng for their cruai schoo, atniete.. said 01 uins anj Women .r. lust ba»«tbai. >onfj.. ins in :oun about these fair share of the S500 mil- Williams bt>om shc USM to * 3 "dd I1>K"% jnc; "" oasic nehti Us the ia» lion national athletic "So please, go after «ach and an athletic Ji- surs ipound Thev re out us mandated and the scholarship pie vour fair snare of ihe reclor 'n s«ourt)ar. Vir- there toon, tan, mo-t -•: M^TII:^:: Mren kc: scnoois have no choice in Vema loves a winner budget, pursue vour fair Slma ~hfs °«n ' "li the time ûinc in anonvm- Ihe matter and ilwavs makes ,t to the share of that «™ nme. participant in the rapidiv ir. wort empn hieacher> ( 'A o;\t-nnr Oklj Vema Williams works Women's Final Four in and. by all means. rfrmW (Hanging world of the sir! Please ceieprate their Sure remained tint for the National Women* March. She. too. is a win- that vou plav some of your athlete in Amenca nch and proud Rision rn uiin a ;i is *m Law Center As a teen she ner. having never lost a games in prime nme 1 8:00 "Flrst parents and supporting sins m >rvns coaches must aiwavs real ihe iov.ii ie\e. > JL Perm Suic member that the courts Jon l need uie L oncresi Dcleonardis and j«t Oito HAMBLETON-STEWART REALTORS Stsfny Uivp have alreadv answered or the Supreme Court s Pascone combined i pomis while Muggir m HJMMIM 28 S Broadway. 64oucerter City Hid**!* rartwf almost any obstacle a help. 11151 cet oul ot vou: puveii j lemt'K tfir »*T »«T" 456-3144 Wifiw Santfi school or administrator easvchair and go 10 3 ieadiny: ihe Lions \M *"l"y Girwini Serving fh« area since 1898 Mil (xwor may throw at an individual game pointi NicMk DiMMMwir you'll sec »>ons of us cvervwhereNI athlete or team. Alwavs be Yes' Without question. In the senior diunoi Fittnunj; Insh rrm. CLOl'CESTZH CITY 3 bedrooms, beautiful move-in condition home w-remodeled »,„, ^ Knool or schoo, lcmaic spons iei!en0i bath w- fiberglass shower wsliding doors, plenty of natural wood cabinets. L-counter » board first listed above Wh\ not unbeaten. Minnmc •*" lazy susans. ss sink, newer w,w in living room, stairs & hall. 1" floor laundry', master ..Q,, ,' , « , , ^ u, e to over Oklahoma : cornm n 0 plcasc c t Iun None Dames Dann bedroom »-dual closets $59.900 pennon together and be »we the V»< i note and and David Jac GLOUCESTER CITY 3 bedrooms, 1 ", bath, beautiful hardwood floors & chestnut respectful vet firm celebrate a local female combined tor ~ p< mm. 3 ceiling fans, modem kitchen w,dbl stainless steel. L-counter & rut wood cabi- Frankly, there's no need athlete that we ve over- Manuel Mamnez chi nets, new dishwasher, garbage disposaL security system, central atr. microwave, pano. for mgcr tra,^ vour looked and not listed to- in ? points lor fenced yard, storage bam. move-in condinon. Only J74.900 Sldc a holding four aces dav Tell us their storv Cowboys I Conn. b< GLOUCESTER CITY 3 bedrooms, great opportunity! Huge detached home only m "Slav calm and be pa- ^" êws addmi u PO Louie Deleonardis need of cosmetic TLC. 2 possible bedrooms on 3 floor. New heater, remodeled batfa w.' veni, giving parents the Box lit Gloucesttr Cm. \J points beat Perm Stai plumbing fora 1" floor bath, pvc sewer line. 3yrs main roof & lyr kitchen roof entrance „„, around has been the 01010 foyer, possible 203k Only $57.900 normal routine. However. 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Transcripts of Public Meetings

500093 1

3 U.S. Environmental Protection Agency's (EPA's) 4 Proposed Plan for Cleanup of Superfund Sites 5 Public Hearing 6

9 February 23, 1998 10 ____--_----__----- 11 Public Meeting of the U.S. Environmental 12 Protection Agency (EPA) held at the Pine Grove Fire 1) station #2, Gloucester City, New Jersey, before 1* Linda A. Burns, Shorthand Reporter and Notary Public 10 of the State of New Jersey, on the above date, 16 cornmencing at 7:00 p.m.

DEGNAN & BATEMAN, INC (609) 547-2565 500094 1 EPA MEMBERS IN ATTENDANCE: 2 Richard J. Robinson, Project Manager Pat Evangelista, Team Leader 3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch

4 MALCOLM PIRNIE REPRESENTATIVES IN ATTENDANCE: 5 Robert Kerbel, Associate Alan Fellman 6 ATSDR REPRESENTATIVES IN ATTENDANCE: 7 Arthur Block, Sr. Regional Representative 8 ALSO PRESENT: 9 Bob Saunders, Emergency Management Coordinator 10 INDEX 11 Witness Page John Becks(ph) 50 12 Sue Marks(ph) 56,79 Mike Grabowski 74,85 13 Unidentified Speaker 76 Unidentified Speaker 88 14 Theresa Graham 91 Ed German 92 15 EXHIBITS 16 (There were no exhibits marked at this time.) 17

DEGNAN & BATEMAN, INC. (609) 547-2565 500095 EPA Public Meeting - 2/23/99

1 MS. CERVANTES-GROSS: I just wanted 2 to start by thanking all of you for coming 3 here tonight to talk with us about the 4 Welsbach/General Gas Mantle Superfund site 5 and post cleanup. We will be talking with 6 you about all of the cleanup here and will 7 be giving you different information about 6 the study that was done and the 9 alternatives that we have looked at as far 10 as what we are proposing. 11 Just to introduce people who are here 12 tonight from EPA and who are involved in 13 the cleanup, we have Rick Robinson who is 14 the project manager for EPA for this site. 15 Pat Evangelista is the team leader for us 16 at EPA and oversees all of the Superfund 17 sites in our region, New Jersey, and all 18 the sites that deal with radioactive 19 contamination. 20 Alan Fellman is with Malcolm Pirnie, 21 a contractor that works with EPA to 22 actually do the investigation and cleanup, 23 as well as Bob Kerbel who is also with 24 Malcolm Pirnie.

DEGNAN & BATEMAN, INC. (609) 547-2565 500096 EPA Public Meeting - 2/23/99

1 And obviously, everyone here knows 2 Bob Saunders who has been doing so much 3 work with us and will be here long after 4 we're gone. And Artie Block is also here 5 from ATSDR, the Agency for Toxic Substances 6 and Disease Registry, part of the Federal 7 Department of Health and Human Services. 8 And ATSDR works with us on a consultation 9 basis and works with us closely to look at 10 these Superfund investigations that we do 11 and gives us information on potential 12 health impacts. 13 As well, I also wanted to introduce 14 Linda Burns who is the stenographer who 15 will be taking down all of the comments 16 that you make tonight. And that's why we 17 are here tonight, to hear from you, your 18 thoughts, your comments, your concerns. 19 And to take any questions you have about 20 what we will be discussir.g tonight and what 21 our proposed cleanup will be for the 22 contamination for the site. 23 And just to point out, my name is 24 Mary Helen Cervantes, I'm with EPA as

DEGNAN & BATEMAN, INC. (609) 547-2565 500097 EPA Public Meeting - 2/23/99

1 well. And I work in the area of Superfund 2 Community Relations. The Superfund program 3 stresses, as we do throughout all of the 4 programs, community involvement and 5 community participation. We feel we can do 6 a much better job by having you involved 7 and telling us what you hear, see and know 8 about the community, your community, in 9 which you live. You know what's happening 10 here a lot better than we do most of the 11 time. So again, that's why we are here 12 tonight, to hear your comments and 13 concerns. 14 In order for us to do that and to 15 make sure that we get everything down, if 16 you could, after we go through our 17 presentations, if you could hold your 18 questions until the end. We will try to 19 move through it as quickly as possible to 20 make time for questions. 21 When you have questions or want to 22 make a statement, state your name clearly 23 so that Linda can get that down and speak 24 up so we can get it all down. So at the

DE6NAN & BATEMAN, INC. (609) 547-2565 500098 BPA Public Meeting - 2/23/99

1 end of the comment period, which ends on 2 March 3, which is next Wednesday, we'll 3 take comments on what we're proposing up 4 until next Wednesday. Afterwards we will 5 do a responsiveness summary, which we'll go 6 through all the comments and all cf your 7 concerns and we'11 write a summary 8 responsive to that. But what you say 9 tonight and whatever comments you have, 10 that will actually go into the official 11 record. So you don't have to write it down 12 afterwards. We'll take it down right here 13 as you say it. 14 I also just wanted to point out that 15 Natalie Loney, whom you may have met, works 16 with EPA and is the assigned Community 17 Involvement Coordinator for the site. So 18 I'm just sitting in for her today. She 19 just had a baby on Valentine's Day, but you 20 will see here throughout all of the other 21 meetings throughout the year. She is the 22 one who is assigned just to work with you 23 and to handle your questions and concerns 24 and to make sure you're involved as much as

DBGNAN & BATEMAN, INC (609) 547-2565 500099 BPA Public Meeting - 2/23/99

1 possible and we want you to be involved in 2 the process here. 3 Just a couple of things very 4 quickly. We have various project 5 initiatives that will help you understand 6 -- you'll see there's a lot of technical 7 information, but there are programs that 8 are available to help you understand the 9 technical information. And if anyone is 10 interested in those programs, I will talk 11 to you about those afterwards. They are 12 numerous. But just talk to me afterwards 13 if you'd like. 14 I'll now turn it over to Pat and Pat 15 is going to go through the Superfund 16 program in general. 17 MR. EVANGELISTA: Good evening, 18 ladies and gentlemen. Thanks for coming 19 out tonight and participating in our 20 meeting. 21 Just to reiterate a little bit of 22 what Mary Helen said, we highly encourage 23 all of you to come forward and identify any 24 comments, concerns or questions that you'd

DBGNAN & BATBMAN, INC. (609) 547-2565 500100 EPA Public Meeting - 2/23/99

1 like to nave answered. If not tonight, you 2 know, anytime in the near future. We'll 3 hand out business cards if you'd like and 4 feel free to call us at any time. 5 What I'm going to do now for you is 6 give you a little briefing on what 7 Superfund is about so that you maybe 8 understand better why we're here and what 9 kind of process we've been following and 10 are going to follow until we're done with 11 this particular site. 12 Back in 1980, Congress gave EPA the 13 authority under a law that's known to us as 14 the Comprehensive Environmental Response 15 and Liability Act. And then five or six 16 years later they amended that law to give 17 us what we currently have today. Our 18 process always beings with somehow an 19 identification to the agency that there's a 20 problem in a certain area. And that's what 21 you see up on the screen as the discovery 22 or CBRCLIS. The CERCLIS is simply a 23 program or process we use to track site 24 progress.

DBGNAN & BATEMAN, INC. (609) 547-2565 500101 EPA Public Meeting - 2/23/99

1 Then we move into what's known as the 2 preliminary assessment or site inspection. 3 We go out and we try to ascertain, on a 4 preliminary basis, what kind of a problem 5 we're dealing with so that we can funnel 6 all of that information into a hazard 7 ranking system. Based on the hazard 8 ranking system we are able to rate that 9 problem or that site, if you will, and if 10 the score, based on the ranking, exceeds or 11 is higher than 28.5, which was somehow 12 selected very arbitrarily, the site ends up 13 on what's known as the National Priorities 14 List. This is a prioritization list that 15 the agency uses to deal with the sites that 16 are on it. 17 From the National Priorities List we 18 are then able to authorize federal money to 19 proceed into what is known as the Remedial 20 Investigation/Feasibility Study. The 21 Remedial Investigation/Feasibility Study is 22 a very detailed study of the problem or the 23 site or the properties, if you will. 24 Perhaps you've seen us out there taking

DE6NAN & BATEMAN, INC. (609) 547-2565 500102 10 EPA Public Meeting - 2/23/99

1 soil samples. You may have seen our 2 contractors. You may be aware of our field 3 office. 4 So we've been gathering data on this 5 site for the past year or so. That data is 6 then analyzed to formulate alternatives 7 that we can further evaluate to identify 8 the preferred cleanup option to address the 9 contamination that's out there. Those 10 cleanup options are identified in the 11 Feasibility Study and the Feasibility Study 12 is used to generate the proposed plan. 13 The proposed plan -- I guess we went 14 public with it back on February 1 -- "went 15 public with it," meaning we identified it 16 in public notice, in the newspapers, for 17 your knowledge. It's available for your 18 review. We have copies of it here tonight 19 if you'd like a copy. And in that proposed 20 plan we proposed to you what we'd like to 21 do to clean up this site. And Rick will 22 get into a lot of that detail. 23 After the public comment period ends 24 we'll proceed into a Record of Decision,

DEGNAN & BATEMAN, INC (609) 547-2565 500103 11 EPA Public Meeting - 2/23/99

1 after having considering all of your 2 comments and concerns. That Record of 3 Decision will formally identify the 4 cleanup. The cleanup will then be designed 5 under what's known as a remedial design. 6 That design will identify all of the 7 specifications that the contractor will 8 need to follow in order to clean up your 9 properties. That, in effect, is the 10 cleanup. 11 Once the agency has determined that 12 the cleanup has occurred pursuant to all of 13 the specifications, we give it a clean bill 14 of health, if you will, and we remove it 15 from the National Priorities List or delist 16 it from the NPL. 17 That essentially describes our 18 process. If you have any questions I'd be 19 happy to answer them for you later. At 20 this point I'll pass it onto Rick Robinson, 21 the Project Manager for the site. 22 MR. ROBINSON: Thanks again, Pat. 23 Just for background, the site is 24 located both in Catnden and Gloucester

DBGNAN & BATEMAN, INC. (609) 547-2565 500104 12 EPA Public Meeting - 2/23/99

1 City. It comprises two former Gas Mantle 2 manufacturing facilitie some residential 3 properties, commercial properties, 4 municipal park lands and vacant land. 5 As part of the State's investigation 6 early on, in the early 1990s they divided 7 the site into a number of study areas. And 8 as we were going on with our investigation, 9 we followed along with their study areas. 10 The first one, Study Area 1, is the 11 General Gas Mantle Facility in Camden and 12 the surrounding properties. 13 Study Area 2 is the former Welsbach 14 Facility here in Gloucester City and the 15 surrounding properties. 16 Study Area 3 is the residential area 17 in Gloucester City, including the Johnson 18 Boulevard Land Preserve. 19 Study Area 4 is the residential area 20 in the Fairview section of Camden. 21 Study Area 5, the residential 22 properties and also some municipal parks in 23 Gloucester City. 24 And Study Area 6, some vacant

DEGNAN & BATBMAN, INC. (609) 547-2565 500105 13 EPA Public Meeting - 2/23/99

1 properties in the residential area in 2 Gloucester City. 3 Study Area l, again, the General Gas 4 Mantle facility in Camden. And there is a 5 photograph of the area with the General Gas 6 Mantle building highlighted (indicating). 7 There's a photograph of the General Gas 8 Mantle building on the corner of Jefferson 9 Street. 10 Study Area 2 is the former Welsbach 11 facility. It's now owned by Holt with the 12 Gloucester terminal. The Armstrong 13 building is the last remaining building 14 from Welsbach's operation. And the area in 15 pink right in here (indicating) is the 16 location of the former Welsbach building 17 that was demolished around 1975, 1976. And 18 that is the main contamination area on that 19 property. There's a photograph of the 20 Armstrong building as it is today. There's 21 the Walt Whitman Bridge in the background. 22 Study Area 3 is Gloucester City. 23 Gloucester City Swim Club is highlighted 24 and the Johnson Boulevard Land Preserve.

DEGNAN & BATEMAN, INC. (609) 547-2565 500106 14 EPA Public Meeting - 2/23/99

1 Study Area 4, again, is the Fairview 2 section of Camden. And we only found a few 3 properties in this part of the site that 4 were identified as having elevated levels 5 of gamma radiation. 6 Study Area 5 is in Gloucester City 7 and includes the former Helsbach dump area 8 on Temple Avenue and contamination in the 9 park areas along Johnson Boulevard there. 10 And Study Area 6 is a newly 11 identified area and we call it the Popcorn 12 Factory. You can ask Bob Saunders as to 13 how that name came about. And there's a 14 photograph of the Popcorn Factory and 15 vacant lot. And the area in red is the 16 small area of contamination that we found 17 with radiological components. 18 Going to the site history now. In 19 about 1885 a Dr. von welsbach invented a 20 process using thorium to manufacture gas 21 mantles. For those of you who don't know 22 what a gas mantle is, you know in a camping 23 lantern, you can see over on the left 24 (indicating), and in a street light right

DEGNAN & BATEMAN, INC. (609) 547-2565 500107 15 EPA Public Meeting - 2/23/99

1 here (indicating), that is the gas mantle. 2 And what they did is take a sock-like 3 material and they dipped it in the thorium 4 solution. And when it dried, it was lit. 5 And it produced a very brilliant white 6 light. 7 And in about 1890 Welsbach started 8 manufacturing the gas mantles here in 9 Gloucester City. And at the turn of the 10 century they were the world's largest 11 manufacturer of gas mantles. And by the 12 1940s they finally went out of business 13 when the electric light put the gas light 14 industry out of business. 15 In Camden, General Gas Mantle 16 manufactured gas mantles from about 1912 to 17 1941. They were a much smaller company 18 than Welsbach. They were a small 19 competitor. There is very little 20 information that we know about the Gas 21 Mantle's activities other than it used and 22 resold radium and thorium in the production 23 of gas mantles. 24 What we've termed vicinity properties

DEGNAN & BATEMAN, INC. (609) 547-2565 500108 16 EPA Public Meeting - 2/23/99

1 are all the other properties that we found 2 at the site, excluding the General Gas 3 Mantle facility and the Welsbach facility. 4 And they were contaminated as a result of 5 either disposal of the ore tailings from 6 the Welsbach operation or building debris 7 when buildings were demolished. Like when 8 they built the Walt Whitman Bridge, some of 9 the buildings were knocked down. Or from 10 former workers bringing contamination home 11 with them. 12 Previously the site was identified in 13 1980 during an archive search of the U.S. 14 Radium Site in Orange, New Jersey. And in 15 May 1981 EPA sponsored an aerial fly-over 16 where a helicopter flew over the area with 17 gamma detectors and was searching for gamma 18 radiation. And as a result of that the 19 State then conducted preliminary screening 20 surveys in the mid 1980s and in the early 21 1990s they investigated over a thousand 22 properties in both Camden and Gloucester 23 City. 24 And as a result of that they

DEGNAN & BATBMAN, INC. (609) 547-2565 500109 17 EPA Public Meeting - 2/23/99

1 identified about 20 properties that needed 2 -- that they felt needed some more 3 immediate measures taken. And as a result 4 they installed some radon/thoron 5 ventilation systems in a number of homes. 6 They installed concrete or steel sheeting 7 on properties, in people's basements. And 8 they also purchased one property and 9 relocated the residents. 10 In 1992 the State also removed 11 radioactive material in the General Gas 12 Mantle building and relocated the current 13 occupant at the time, Ste-Lar Textiles, and 14 they sealed up the building to restrict 15 access. 16 The State's investigation -- they 17 base their surveys on just surface exposure 18 rates, indoor radon sampling and they 19 performed very limited surface soil 20 samples. However, they did not really look 21 in the subsurface at all. They made no 22 estimates on the amount or extent of 23 contamination and were just looking to 24 address the more immediate potential health

DEGNAN & BATEMAN, INC. (609) 547-2565 500110 IB EPA Public Meeting - 2/23/99

1 time. BPA's involvement at the site became 2 official when it was placed on the National 3 Priorities List in June of 1996. And then 4 that's when I was given the site and 5 started the investigation process. 6 Currently the General Gas Mantle 7 building is inactive and boarded shut. 8 Welsbach is currently owned by Holt and is 9 an active facility. And with the vicinity 10 properties, the immediate health concerns 11 were addressed either by the State's 12 remedial actions or by the BPA removal 13 action. Like what we did in the park in 14 December around the Ponytail(ph) Field. 15 And here's a photograph of the excavation 16 where we removed the top three feet of 17 surface contamination. We're hoping to 18 ship that material. It's being temporarily 19 staged around the Popcorn Factory and we're 20 going to ship that off in about three 21 weeks. Today we had somebody out there 22 sampling that material in preparation for 23 shipment. 24 Right now I'd like ~o turn this

DEGNAN & BATBMAN, INC. (609) 547-2565 500111 19 EPA Public Meeting - 2/23/99

1 Right now I'd like to turn this 2 portion of the talk over to Alan Fellman. 3 And Dr. Fellman will talk to you a little 4 bit about the radiation issues. Thank 5 you. 6 MR. FELLMAN: My background is in 7 health physics and radiation sciences. So 8 I'm going to spend just a few minutes to 9 give you a few points about some of the 10 terminology and some of the components 11 regarding radioactivity that hopefully will 12 help you follow along with the materials 13 that you have been given to read and some 14 of the things that you're hearing tonight. 15 And then later on I'11 come back and have a 16 few words about the risk assessment that we 17 did, which is a component of the Superfund 18 remedial investigation. 19 You've already heard some terms 20 related to radioactivity. And I just want 21 to hit on some of the key ones. When we 22 measure radioactivity, when we want to 23 identify a quantity of radioactive 24 material, we need different units than what

DEGNAN & BATEMAN, INC. (609) 547-2565 500112 20 BPA Public Meeting - 2/23/99

1 we're more traditionally used to because 2 we're not talking about a mass. He can't 3 describe the weight of the material, what 4 we're concerned about is the rate that 5 these atoms are decaying, undergoing 6 radioactive decay. 7 The term we use, the unit, is called 8 pico Curies. When we're talking about how 9 much is in dirt or how much is in water, we 10 express it as a concentration, pico Curies 11 per gram or pico Curies per liter of 12 water. Now this term is indicative of how 13 much. It does not really address what kind 14 of dose one received or what the risk is 15 from that material. The point being that, 16 ten pico Curies per gram of one type of 17 radioactivity might give someone a 18 different dose and have a different risk 19 associated with it than ten pico Curies per 20 gram of a different radioactivity. 21 When we talk about dose of radiation, 22 and that's really related to the risk, we 23 use a unit called millirem. And that's a 24 measure of the potential for biological

DBQNAN & BATBMAN, INC. (609) 547-2565 500113 21 BPA Public Meeting - 2/23/99

1 effect as a result of that radiation. 2 Basically what we're measuring is energy 3 that is coming from the radioactivity that 4 is emitted from that radioactive material 5 and is absorbed in the biological tissues. 6 And that energy that's transferred from the 7 radioactivity to the tissues is the subject 8 of what could then ultimately lead to a 9 biological effect or a health effect. 10 Obviously, the greater the dose the 11 greater the risk. There are several 12 different types of radioactivity and you've 13 heard some of previous speakers say the 14 words thorium, radon, radium. All of these 15 are different elements that have 16 radioactivity associated with them. They 17 emit different types of radioactivity. 18 Alpha particles and beta particles 19 and gamma rays are the three more common 20 types of radioactivity and they're really 21 the ones that we're concerned about here. 22 They have different properties. Alpha 23 particles are relatively heavy. They 24 travel slowly and they are not penetrating,

DEGNAN & BATEMAN, INC. (609) 547-2565 500114 22 BPA Public Meeting - 2/23/99

1 which means that they will not travel very 2 far. If they're emitted from surface soil 3 they will be stopped within one to two 4 inches of air. They cannot get through a 5 sheet of paper. 6 Beta particles on the other hand have 7 an intermediate amount of penetrating 8 ability. They're smaller than alpha 9 particles but they do have some mass 10 associated with them. So while they can 11 get through a sheet of paper, they will be 12 stopped by something like a piece of wood. 13 Gamma rays on the other hand are very 14 similar to X-rays. They have no mass 15 simply. It's simply packets of energy. 16 It's sometimes referred to as penetrating 17 radiation because it can travel fairly 18 significant distances through air, paper, 19 wood. And it takes a more dense media to 20 absorb that energy and stop the gamma rays 21 such as concrete or lead. 22 The problem here, by and large what 23 we're dealing with are what's known as ore 24 residues. The by-product of the thorium

DE6NAN & BATEMAN, INC. (609) 547-2565 500115 23 BPA Public Meeting - 2/23/99

1 extraction processes that were implemented 2 by the Welsbach company who left them with 3 large piles of dirt which contained these 4 ore residues with elevated concentration of 5 radioactivity. 6 In this schematic here, the area 7 that's shaded in blue tends to show 8 potential areas with these elevated levels 9 of thorium. And if that were the case, 10 what you can get, radon gas which is 11 mobile, which can emanate from this dirt 12 into the indoor atmosphere. Fortunately 13 we've seen very little of that at the 14 Welsbach General Gas Mantle sites. Much 15 more frequently would be the case where 16 there would be some of this material in an 17 outdoor area where the influx of the gas 18 into an indoor environment isn't likely to 19 happen. But there the potential exposure 20 would be from the gamma radiation that's 21 emitted to an occupant who would be 22 occupying, that would get a dose of that 23 gamma radiation. 24 At this point I'm going to let

DEGNAN & BATEMAN, INC. (609) 547-2565 500116 24 EPA Public Meeting - 2/23/99

1 Bob Kerbel speak for a few minutes. He's 2 been our Project Manager from Malcolm 3 Pirnie throughout the investigation and 4 he'll take you through some of the key 5 points in that investigation. 6 MR. KERBEL: I just want to give you 7 a little insight of the type of 8 investigation we did in the community so 9 you can kind of see everything in the 10 nutshell and see the type of work we've 11 been doing. 12 There are three areas we looked 13 into. Two of the industrial facilities, 14 the former Welsbach facility and the 15 General Gas Mantle facility. And then 16 there was the vicinity problem, basically 17 everything else. I assume most people here 18 are homeowners and your home would come 19 under that vicinity property category. 20 If there's anything good about this 21 type of work from our standpoint as 22 investigators it's that it's easy for us to 23 detect this type of contamination. It 24 gives off gamma radiation. So we basically

DEGNAN & BATEMAN, INC. (609) 547-2565 500117 25 EPA Public Meeting - 2/23/99

1 walk over the property with meters similar 2 to this. And we might have come to your 3 property and walked over the property in 4 search for elevated levels of radiation. I 5 have a little meter here. And we'd take 6 those readings and walk over your entire 7 property. 8 Then if we find something we take 9 soil samples and test for radiological and 10 chemical contaminants. We only test for 11 chemical contaminants at industrial 12 properties because there's always a chance 13 that there could be some chemical 14 contamination just given the industrial 15 nature of those areas. 16 Once we find an area, we have to come 17 up with a volume, how much is there. So we 18 put a boring into the ground and these can 19 be either shallow or deep. The only reason 20 there's not a deep check mark under 21 vicinity properties is because we really 22 didn't have deep contamination on 23 residential properties. That was really at 24 the industrial sites that we needed to go a

DEGNAN & B A T E M A N, INC. (609) 547-2565 500118 26 EPA Public Meeting - 2/23/99

1 little deeper. And as Alan alluded to, if 2 there's soil contamination in the area, 3 that gives off radon gas that could get 4 into the household, so we test for that as 5 well. 6 On the industrial properties we also 7 do something called alpha/beta measurements 8 where we would actually sample structural 9 materials. Because sometimes we might run 10 into a question, whether it's the soil 11 under the building or the building material 12 itself that might be contaminated. So we 13 might test that. 14 This isn't too easy to see, but I 15 want you to use your imagination a little 16 bit. Let me try to get your eyes to focus 17 here. This is the former Welsbach facility 18 that was located along the Delaware River. 19 The Delaware River is up there on top, you 20 can see a smoke stack. And King street 21 would be at the lower end of the picture. 22 But if you could imagine, this is the early 23 part of the century. There's no DEP; 24 there's no environmental protection

DEGNAN & BATEMAN, INC. (609) 547-2565 500119 27 EPA Public Meeting - 2/23/99

1 agency. The hazards associated with 2 radiation really aren't known yet. Things 3 like nuclear power are decades in the 4 future yet to come. And as Rick said they 5 made gas mantles here. Things like X-rays 6 that the doctor does now were still being 7 discovered at that time. 8 But at this facility, they brought 9 ore in. So basically on this facility 10 there was a pile of dirt that they would 11 extract the thorium from to use in these 12 gas mantles. So at the time it was really 13 a prosperous business until the electric 14 light bulb came into play and put them out 15 of business. But at that time the hazards 16 weren't really known. 17 In future years, in the last couple 18 of decades, we're more aware of the hazards 19 associated with radiation. So now someone 20 said, you know what, we should go back to 21 all these facilities that did this in the 22 early part of the century. Because the 23 sand that contained thorium, that could 24 potentially be radioactive. So we should

DEGNAN & BATEMAN, INC. (609) 547-2565 500120 28 EPA Public Meeting - 2/23/99

1 go back to these facilities to see if, 2 indeed, there is radioactive material on 3 these sites. 4 So years later they come back to the 5 site but now there's no building here. The 6 circle is basically where the facility 7 would have been. So what we do is just 8 what I told you earlier, we walk over the 9 entire site and it takes a number of weeks 10 to do it because it's so large, and we look 11 for elevated levels of radiation. Because 12 at the beginning the thought is, if the 13 building is gone, it's conceivable that 14 they had these huge basements and they 15 knocked the building down and filled the 16 basement and then paved over it. 17 So we go over the entire site, we 18 look for the elevated levels and then we 19 bring them back to our office and we have 20 special programs that help us see what the 21 radiation levels are. Now this is a bird's 22 eye view looking down at this site now. 23 And wherever you see a colored area, those 24 are elevated radiation levels. That's a

DE6NAN & BATBMAN, INC. (609) 547-2565 500121 29 BPA Public Meeting - 2/23/99

1 clear signal for us that there is 2 contamination on the site. And then we go 3 back and take soil samples to see that it 4 is thorium. And we do borings to see how 5 deep it is. Ballpark approximately ten 6 feet deep in locations. 7 Alan is going to come back and talk 8 more about risk, but I just.want to give a 9 little perspective to it. When we do this 10 work it's not like we dress up in suits or 11 anything. We just wear our regular work 12 cloths and work in these areas and get our 13 measurements and so on. For the people 14 that work for Malcolm Pirnie, I'm 15 responsible for their health and safety. 16 And for me, the real risk is that they 17 don't get killed by a truck going through 16 the yards rather than the radiation wells. 19 Another thing to keep in mind, this 20 is not like an oil spill that's spreading 21 out there. It's been there for 50 years. 22 It really doesn't move around unless you 23 mechanically move it to another location. 24 When I mentioned that soil pile from 50 to

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1 100 years ago, what if you had a 2 residential property, they removed a tree, 3 there's a hole in the ground and they took 4 that soil to fill the hole. That's the 5 type of thing we're looking for now. 6 The General Gas Mantle building, let 7 me just tell you a little bit about what we 8 have here. It's all closed up now. Again, 9 as Alan was telling you, the radon levels 10 coming from the ground underneath the 11 building, that is indeed what's happening 12 here. Since it's all boarded up, there's 13 no ventilation so there is a high radon 14 level. There is some soil contamination, 15 nowhere near as extensive as at the 16 (INAUDIBLE) facility. 17 And it is a longer building and it IB does come out into the street at South 19 Fourth Street. And there are some building 20 materials. The building is vacant. 21 There's nothing in there. There's wood 22 floors and some of those wood floors are 23 contaminated. They would have to be 24 decontaminated before the building is

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1 demolished. But Rick Robinson will come 2 back and talk a little about that. 3 I assume most people here are 4 property owners. So the last category is 5 the vicinity properties. So let me touch 6 base a little more on this one. The goal 7 here is to get to the cleanup as soon as 8 possible. And we were fortunate in this 9 case that the State went to a thousand 10 properties. So we didn't want to go to a 11 thousand properties all over again and 12 investigate those properties. But what we 13 had to do is see that we could use the 14 State's data. So we went to 20 properties 15 and we compared our data to the State 16 data. And we agreed with their data. 17 So then we took their data and 18 categorized it. The State went to 19 approximately 1,000 properties. Here it's 20 1,088. When we looked at the State data, 21 we said approximately half, 449 properties 22 are clean. We can't find any indication of 23 contamination on those properties. 24 Then there's another category we put

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1 on that we call suspect properties. That's 2 585 properties. Now suspect properties are 3 our grey area. If a property was adjacent 4 to a contaminated property, we 5 automatically called it suspect because we 6 want to check it out because it's adjacent 7 to that contaminated property. 8 Throughout the State people test 9 their homes for radon and get elevated 10 levels of radon in certain locations. That 11 might have happened here and it would be 12 perfectly normal. But we question is that 13 because of the normal radium in the soil, 14 or is it a sign that there might be some 15 soil contamination from the Welsbach 16 facility. 17 We use the term natural background 18 radiation because there's radiation all 19 over but there's an average. And these 20 properties might have had levels on the 21 high end of that. If you live in a brick 22 home, that may be a reason that it's high. 23 But we want to go back to those properties 24 to really break them either way, if it's

DEGNAN & BATSMAN, INC. (609) 547-2565 500125 33 EPA Public Meeting - 2/23/99

1 the contaminated category or the clean 2 property category. 3 And then the bottom line is we have 4 54 contaminated properties. Properties 5 that clearly had some contamination on them 6 from our results and the State's. And we 7 came up with a volume for this for our 8 estimate in the future. 9 Before I let Alan come back and talk 10 again about risk, I just want to mention on 11 suspect properties, again it's our grey 12 area. The contamination on all these 13 properties might be a small spot that we 14 can take away and put in a pail. We might 15 have to bring a backhoe in there to dig it 16 out. But the suspect properties, we would 17 think that most of those properties can be 18 moved to the clean category eventually. 19 But we don't know that for sure and we 20 won't know until we actually do the testing 21 on that property. 22 So I'll let Alan come back and talk a 23 little bit about health risks. 24 MR. FELLMAN: Whenever I talk to

DE6NAN & BATEMAN, INC. (609) 547-2565 500126 34 EPA Public Meeting - 2/23/99

1 people about the risk of radiation, it's 2 always a good frame of reference to say a 3 few words first about natural background 4 radioactivity. It's very helpful when you 5 realize that we live on a radioactive 6 planet. And as a result of that, we're 7 constantly being bombarded by 8 radioactivity, no matter where we are, 9 having nothing to do with the Superfund 10 site. 11 There are several different sources 12 of natural radioactivity and they're listed 13 in this table. Cosmic and cosmogenic refer 14 to things coming from the atmosphere, the 15 upper atmosphere. 16 Terrestrial radioactivity is the 17 natural thorium, radium, uranium that's in 18 the ground, in the soil, in the rocks. And 19 we get most of that 28 millirem per year 20 from terrestrial sources which comes from 21 gamma radiation. 22 Inhaled radiation, we're talking 23 mostly there about radon gas. On average, 24 in the average house, anytime you put four

DEGNAN & BATEMAN, INC. (609) 547-2565 500127 35 EPA Public Meeting - 2/23/99

1 walls and a ceiling together you're going 2 to get some level of radon gas. And on 3 average we get a dose of about 200 millirem 4 per year. 5 And then the internal emitters, 6 referring to the radioactivity that we 7 carry around in our bodies from natural 8 sources such as potassium 40, which is a 9 small but significant component of all the 10 potassium on the planet. There's a little 11 bit of these in soil, in the plants, 12 vegetables and fruit and so forth. And so 13 we're constantly ingesting and excreting 14 some of this radioactivity. And as a 15 result of it being in our bodies we receive 16 a dose on average of 40 millirem per year. 17 There's also a host of consumer 18 products that have one or another type of 19 radioactivity associated with it. And you 20 can see it's a pretty diverse list. And 21 the last one that we show there are gas 22 mantles. We know a little bit more about 23 them than we'd like to. 24 Adding a few more things to those

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1 that you see here on this slide, I have a 2 little show and tell here. Most everybody 3 who works in ray field has one of these. 4 This is a piece of Fiestaware(ph) which 5 you'll find in almost any antique show. 6 And this orange color -- I don't know why 7 they call it yellow cake -- but the glaze 8 that they apply to give it this orange 9 color is called yellow cake. And it has a 10 fair amount of natural uranium in it. 11 This meter here is called a Geiger 12 viewer detector, the common name is a 13 pancake probe because of the shape. It has 14 very low background. When you turn it on, 15 from regular background radiation, this is 16 what you'll hear, the sporadic beep. Each 17 time a photon or a gamma ray is interacting 18 inside the detector, it makes a click. And 19 then, as you can tell when I get close to 20 the Fiestaware, there's quite a 21 difference. If I move one to two feet 22 away, you can hear how rapidly that level 23 of radioactivity decreases. As we remove 24 ourselves from the source, the level drops

DEGNAN & BATEMAN, INC. (609) 547-2565 500129 37 BPA Public Meeting - 2/23/99

1 off fairly rapidly. So again, a very high 2 level right out of the source, but by the 3 time I get within three feet apart, there's 4 very little, if any, impact right here. 5 Now, another thing that's kind of 6 interesting is that for those of us who 7 have been told by our doctors that we have 8 to reduce our salt intake because of 9 hypertension or heart problems, they say, 10 go get some salt substitute from the 11 grocery store. What you're getting is not 12 a salt substitute, it's potassium chloride 13 instead of sodium chloride. 14 And as I said earlier, of all the 15 potassium on the planet, a very small 16 rraction is radioactive. And there's no 17 difference from the potassium that's in 18 here than the potassium that's in a banana 19 or potato or any other potassium-rich 20 food. And the difference is not quite what 21 you'd hear with the Fiestaware, but you do 22 hear a difference. And again, that's 23 natural potassium 40 emitting beta 24 particles and gamma rays. And this is what

OEGNAN & BATBMAN, INC. (609) 547-2565 500130 38 EPA Public Meeting - 2/23/99

1 we need to eat to protect us from 2 hypertension. Again, it doesn't cause a 3 big dose. I just want to illustrate the 4 fact that there's radioactivity all around 5 us, even in the things that we eat. 6 When we talk about dose effect 7 relationship, about being exposed to 8 radiation, there's one point --if you get 9 nothing else -- there's one point that I 10 think is very important for you to 11 understand. And that is that what we know 12 about radiation is that, yes, it is most 13 definitely a human carcinogen. But we know 14 that because of studies that have been done 15 on populations of people that have been 16 exposed to very, very high doses of 17 radiation, compared to background, compared 18 to the levels that we have at some of the, 19 quote, unquote, contaminated properties 20 here. These would be groups such as the 21 Japanese who survived the atomic weapons 22 blast at the end of World War II. Several 23 groups of patients, who back in the '20s 24 and '30s and '40s were treated for various

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1 ailments with radiation. Whereas now, the 2 medical community uses radioactivity to try 3 to help destroy cancer cells. Back then it 4 used to be a treatment for certain 5 diseases. So 20, 30, 40 years later there 6 are these populations treated with these 7 high doses of radioactivity who were 8 followed and were found to suffer from high 9 or increased levels of cancer. 10 So what do we do as public health 11 scientists? We know that when the dose is 12 very high we see excess cancer. Now we've 13 got the lower dose and you can see in this 14 curve, what I'm talking about earlier with 15 the Japanese and some of these other 16 groups, they're up here in the dose 17 response curve. We know the dose is very 18 high and we see the health effect or the 19 risk of cancer is easy to measure. What we 20 have down here is what I call an area of 21 great uncertainty. There are no data that 22 we can point to that will show that at the 23 levels that we1re exposed to from 24 background radiation and from levels that

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1 are slightly greater than background such 2 as some of the properties that have these 3 thorium residues on them. There are no 4 data that show that people exposed at those 5 levels are actually suffering from 6 increased incidents of any type of cancer. 7 But the fact that I can say that 8 doesn't mean that we can then dismiss or 9 would want to say there's no problem, let's 10 forget about it. He make an assumption. 11 He assume that there's a linear risk. He 12 assume what's called no threshold, that as 13 soon as you get any dose of radiation, we 14 assume there's some risk. It might be very 15 small. He certainly can't measure it and 16 the truth of the matter is, there may be no 17 risk at all. 18 But we assume that there is a risk. 19 And when we end up at a risk level, when we 20 do our risk assessment part of this 21 investigation, we come up with a number and 22 compare that to what EPA has determined to 23 be the acceptable risk range. And if our 24 models project a risk greater — that is

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1 greater than the risk range that EPA is 2 looking to obtain, that becomes the basis 3 for a cleanup. The way the Superfund law 4 is written, EPA needs to demonstrate a risk 5 greater than what they found to be 6 acceptable and to use that then as a reason 7 to go forward with an action. 8 At this point I'll stop and Rick will 9 pick back up and discuss the alternatives 10 for the sites. 11 MR. ROBINSON: Thanks, Alan. Now 12 what we're going to talk about is, based on 13 the results of the remedial investigation 14 we evaluated a number of alternatives for 15 the cleanup. And we evaluated alternatives 16 for the three property types we discussed 17 earlier, the vicinity properties, the 18 Welsbach facility and for the General Gas 19 Mantle facility. And for each of the three 20 property types we evaluated, we evaluated a 21 No Action Alternative; an Engineering 22 Controls Alternative; and an Excavation and 23 Off-site Disposal Alternative. 24 The No Action Alternative is an

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1 alternative that we have to do on each 2 Superfund site. And we have to compare the 3 other alternatives versus what if we did 4 nothing. If we left it alone, what are the 5 risks. So the No Action Alternative is 6 something that we have to do. In this case 7 here, it was determined that there is a 8 risk above EPA's criteria, as Alan just 9 told you. And as a result we're not going 10 to talk about the No Action Alternative 11 anymore. And we're not even going to 12 consider it right now. 13 For the vicinity properties, for the 14 Engineering Controls Alternative, it's 15 Alternative V-2. Outdoor gamma shields 16 would be required on approximately 50 17 properties; indoor gamma shields on 18 approximately 20 properties ,• and radon 19 mitigation systems would be needed on 20 approximately 4 properties. As a result we 21 would need to have deed restrictions on the 22 property, limiting future work on that 23 property. And we would have to negotiate 24 that with each property owner. The State

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1 of New Jersey would be responsible for 2 enforcing those restrictions. And we would 3 have to go back every five years to make 4 sure that it was protected and the shields 5 were still effective. 6 For the Alternative V-3, the 7 Excavation and Off-site Disposal 8 Alternative, all the soil and debris above 9 our cleanup standards would be excavated 10 and disposed of off-site. And under this 11 alternative, the contaminated materials 12 would all be removed. The mobility of the 13 contaminants would be eliminated and there 14 would be no significant institutional 15 controls remaining on the properties. The 16 properties would be safe for future reuse 17 and the remedy would be protective of human 18 health and environment. 19 For the Welsbach facility, 20 Engineering Controls, again we would need 21 outdoor gamma shields. He would need deed 22 restrictions limiting future site work. 23 And we would have to go back every five 24 years to make sure that it was protected

DEGNAN & BATEMAN, INC. (609) 547-2565 500136 44 EPA Public Meeting - 2/23/99

1 and that the shields were still effective. 2 Alternative w-3 for the Welsbach 3 facility, all the soil and debris above our 4 cleanup standards would be removed and 5 excavated and sent off-site for disposal. 6 All of the materials, again, would be 7 removed from the property, mobility of the 8 contaminants would then be eliminated, and 9 there would be no controls remaining. 10 For General Gas Mantle, again for the 11 Engineering Controls Alternative, G-2, 12 again outdoor gamma shields. For the Gas 13 Mantle building, we would have them 14 permanently board the building shut. We 15 would have to restrict access against the 16 building, and we would have to go back 17 every five years to make sure that it was 18 still effective controls. 19 For the Excavation and Off-site 20 Disposal Alternative G-3, we evaluated two 21 options for the buildings. For the General 22 Gas Mantle facility under Option A, the 23 building would just be demolished and the 24 building materials would be sent off-site

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1 as contaminated materials. 2 For Option B, we would first go in 3 and try to decontaminate the building and 4 then this would reduce the volume of 5 material that needed to go to off-site 6 disposal. For both options all materials 7 would be moved from the site and there 8 would be no significant institutional 9 controls. 10 And now we'll just go into some 11 summaries. The summary of the cost for the 12 vicinity properties. The engineering 13 controls would cost about $2 million 14 dollars to implement. And the Excavation 15 and Off-site Disposal would cost 16 approximately a little over $13 million 17 dollars. 18 For the Welsbach facility, the 19 engineering controls, almost $6 million 20 dollars. And the Excavation and Off-site 21 Disposal, $18.5 million dollars. 22 For the General Gas Mantle facility, 23 the Engineering Controls Alternative just 24 under $400,000. And the Excavation and

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1 Off-site Disposal for Option A which was 2 the straight demolition of the building is 3 just over $2 million dollars. And for the 4 decontamination and demolition of the 5 building, just under $2 million dollars. 6 As a result, EPA's preferred 7 alternative is the Excavation and Off-site 8 Disposal Alternative, V-3, W-3 and G-3. 9 And with the General Gas Mantle facility it 10 would be Option B, decontamination prior to 11 the demolition. 12 In summary, the total cost of the 13 selected remedies combined is almost $34 14 million dollars. Where do we go to next 15 now? The next steps, right now we're at 16 the process soliciting public comment. And 17 as Mary Helen told you earlier, we're here 18 to respond to your verbal comments tonight 19 and we're also encouraging you to submit 20 written comments, if necessary. And after 21 we receive public comments, we select a 22 remedy in a document that's called a Record 23 of Decision (ROD). And once we sign the 24 Record of Decision, EPA can then start the

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1 design process. 2 Our focus will be on the residential 3 properties first. And then followed by 4 that the commercial and industrial property 5 cleanups, we plan on starting the field 6 investigations on the suspect properties in 7 the fall of this year. And we'll hopefully 8 start the design and investigation on the 9 potential contaminated properties also in 10 the fall. And we're also going to try to 11 start the demolition process of the General 12 Gas Mantle building sometime this year and 13 hopefully finish in one to two years. The 14 General Gas Mantle building is in a very 15 sad state of disrepair. Vandalized a 16 number of times. The wood floor is a fire 17 hazard. We'd like to get the building down 18 as soon as possible. 19 The plan right now is to start the 20 cleanup activities on the individual 21 properties in about three to five years. 22 One of the processes with the design is 23 that because it's an individual nature of 24 the property -- because the contamination

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1 is on an individual property, we have to do 2 a specific design on each individual 3 property. And it takes time to generate 4 the design activities on all these 5 different properties and put it together in 6 a package so that we can have a contractor 7 go in and do the cleanup all at once. 8 We're also in the process of 9 conducting a ground water investigation. 10 And that's underway right now to make sure 11 there is no radiological contamination from 12 the site in the ground water. We don't 13 believe we'll find that much, but thorium 14 itself does not like water. It doesn't go 15 into water, into solution. But we're 16 testing the ground water anyway just to 17 confirm that there is no radiological 18 contamination there. 19 We're also going to investigate the 20 wetland areas around Newton Creek, around 21 the Johnson Boulevard Land Preserve and 22 along Temple Avenue where there's two 23 former dumps as well as the Welsbach 24 operation.

DE6NAN & BATEMAN, INC. (609) 547-2565 500141 49 BPA Public Meeting - 2/23/99

1 And that's the end of our 2 presentation. We'd like to invite you to 3 ask any questions. We're all here to 4 answer them. 5 6 7

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1 MR. EVANGELISTA: Before we get 2 involved in the questions and answers, I 3 just wanted to point out that we have some 4 handouts up front. One provides you with 5 factual information, sort of a summary fact 6 sheet. Hopefully it kind of reiterates 7 what I opened up with at the initial part 8 of the meeting. If you have any questions 9 now is a good time to raise them.

10 MS. CERVANTES-GROSS: Or if you just 11 have a comment. If you could just state 12 your name again before you give us your 13 question. 14 MR. BECKS: My name is John Becks(ph) 15 (INAUDIBLE). I live on the 900 block of 16 Somerset Street. I'm about eight houses 17 from where you were doing the cleanup 18 earlier. 19 Did they come around -- did you or 20 the State come around to individual homes 21 in that area to test our homes? And what 22 steps are being taken for that? 23 MR. ROBINSON: You might have to show 24 us on one of the maps where Somerset Street

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1 is. 2 MR. SAUNDERS: Johnson Boulevard, the 3 ponytail, almost catty-corner, right in 4 those blocks. 5 MR. ROBINSON: I would have to look 6 at the State information on whether or not 7 that part of Somerset Street was included 8 in the investigation. We could let you 9 know if there is any information on your 10 property --if the State did survey it or 11 not. If you don't believe they did --

12 MR. BECKS: No, I don't. 13 MR. SAUNDERS: That area -- actually 14 the whole town --we get a lot of false 15 positives, which is what we want. They go 16 back through that area to see if it's 17 construction of the home material. And in 18 that area the only thing they saw was along 19 the Johnson Boulevard area of houses in 20 Gloucester, (INAUDIBLE), in that immediate 21 area. 22 MR. BECKS: Why wouldn't they be? 23 MR. SAUNDERS: We went out. I can 24 show you on one of the colored pictures

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1 where it was done.

2 MR. BECKS: And was it? 3 MR. SAUNDERS: Yes, it was done. Was 4 the house done? No. Plus the construction 5 date of those homes -- that was called the 6 homes, like, that (INAUDIBLE) and a lot of 7 the construction predated the site. The 8 homes were built -- that whole section on 9 Somerset Street predated a lot of the dump 10 area. The wetland area that was all 11 wet.ands in the '50s. So that's some of 12 the ones where we didn't see anything. 13 When I say "we," EPA. There was nothing to 14 indicate that there was any concern 15 whatsoever in that area (INAUDIBLE) quite a 16 few feet to make sure. 17 Some of the pictures -- here some 18 people made mention of (indicating). 19 People want to make sure again and again 20 and again, to make sure. So that's why it 21 may be contaminated here. We are going to 22 look here and here and here and here again 23 (indicating). The last thing anybody wants 24 to do is do this wrong.

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1 I live around the block. I have -- 2 was my house tested? No. Because I know 3 the age of when they were built, how it was 4 built. Where Dr. Kelly lives, that area, 5 that predated the dump. So the homes built 6 before the dump (INAUDIBLE) they weren't 7 (INAUDIBLE). However, as part of this 8 randomly (INAUDIBLE). They did go out. 9 MR. ROBINSON: If you'd like and you 10 are concerned, we can just go over and do a 11 quick walkover while one of our contractors 12 is out here. 13 MR. BECKS: I'm concerned too, in 14 talking with various neighbors, it was a 15 common practice at the time when they were 16 filling the wetlands, that people go home 17 and pick up building materials, bring them 18 home to your site, wood and such. And 19 that's a concern. 20 MR. FELLMAN: Part of the answer is 21 that this fly-over data kind of laid out 22 the boundaries of the different study 23 areas, as starting points. And not looking 24 at a map, you know, I suspect that your

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1 home is probably outside of the boundaries 2 that the fly-over gave us to start with. 3 MR. BECKS: I was doing some work in 4 my basement about a week and a half ago. I 5 tore out the closet and there was building 6 material from Welsbach. 7 MR. ROBINSON: Really. If you could 8 please leave your name. I have a 9 contractor who's here with me today doing 10 some fieldwork and we can make an 11 appointment and scan your property. We'll 12 need to do that this week. 13 MR. BECKS: I have two very small 14 children that my wife and I love dearly. 15 MR. SAUNDERS: That's the kind of 16 information -- some people think they're 17 going to get in trouble. 18 MR. BECKS: Well, that's why I came 19 here. That's not the only reason. I was 20 planning on coming when I first read it in 21 the Gloucester City News. The only way 22 that I knew about this meeting was from 23 that article in the Gloucester City News. 24 I can see by the amount of people that

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1 apparently nobody cares or everyone wasn't 2 informed. 3 MR. SAUNDERS: This is what we did. 4 Gloucester City News was given the same 5 data as the Courier and as the Inquirer. 6 And all those areas of people who live in a 7 house (INAUDIBLE) there was suspect 8 condition. So now you're looking at quite 9 a few hundred people and this is generally 10 the response. 11 MR. BECKS: I only really get the 12 Gloucester City News. I don't read the 13 Courier or the Inquirer. 14 MR. SAUNDERS: In fairness to EPA, a 15 lot of these residents who had questions, a 16 lot of them have called to complain. And 17 we'll give them the information -- plus the 18 residents we've sat down with. And I'll • 19 show you what we have here, a demarcation. 20 MR. BECKS: There was a lot of people 21 filling in tree holes from dirt piles down 22 at the end of the street. 23 MR. SAUNDERS: But the fly-over would 24 have shown that.

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1 MR. ROBINSON: He can schedule a time 2 tomorrow morning. We'll still be here in 3 town. We can make an appointment with you 4 or anytime at your convenience when we're 5 down here. If you know of anybody else who 6 are not in these areas who have other 7 Welsbach materials, we're very, very 8 interested in trying to find those homes. 9 Like a former worker who used to work there 10 may have brought some stuff home with him. 11 It's very, very hard to do the entire 12 town. And we need help from the public on 13 that. 14 MR. 3AUNDERS: As always, if you get 15 the word out, they can call us 24 hours a 16 day and we'll take a quick sample. That's 17 the beauty. We can meter it and say, yes, 18 it's there; no, it's not. We want to do 19 that with a whole host of the materials. 20 MR. BECKS: Thank you. 21 MS. CERVANTES-GROSS: Anyone else 22 have a comment or a question? 23 MS. MARKS (ph) : My name is Sue 24 Marks. I live in Bellraawr. I was a

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1 resident of Fair-view for many years. I 2 have a couple of questions and I spoke to a 3 couple of gentlemen earlier. 4 I have a cancer study here that I 5 sent to the EPA (INAUDIBLE) a couple of 6 weeks ago. I received a copy of this and 7 in here, one of things that stood out for 8 me was, it says higher cancer incidents 9 from the Welsbach General Gas Mantle site 10 appear to be due to significantly higher 11 lung cancer incidents in the population, 12 especially in males. 13 Do you -- and maybe you're not the 14 right people to ask -- but to me I'm 15 concerned about the health aspect of what 16 has seemed to be a long-term problem here. 17 As I said, I used to live in Fair-view and 18 my house -- I just saw on one of the poster 19 boards there -- was basically right 20 directly behind one of your highly 21 contaminated homes. I'm concerned about 22 the residents' health. And I guess what I 23 need to know is, the people that are living 24 in these homes that are the 54 contaminated

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1 homes, what will be done with them, to 2 them, for them, while this remedial work is 3 going on? In other words, A, will they be 4 moved out of their home; B, will they be 5 monitored for any sort of health problems 6 as the remedial work is going on? To me 7 that's one of my greatest concerns. 8 I think, Bob, you and I had spoken 9 about this earlier. I don't know where 10 this came from. I don't know how it's in 11 reference to this Welsbach site. But I 12 have to know that it must be connected 13 somewhere. 14 MR. ROBINSON: For the answer to the 15 health study, we have Artie Block here from 16 ATSDR. And his agency is the one who 17 sponsored the State investigation. 18 MR. BLOCK: Let me just take a 19 moment. Again, my name is Arthur Block. 20 I'm a Senior Regional Representative for 21 ATSDR. 22 As was mentioned by Mary Helen, ATSDR 23 is the Agency for Toxic Substances and 24 Disease Registry and is part of the

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1 Department of Health and Human Services. 2 We are primarily, and our main mandate and 3 responsibility, is environmental health. 4 We work very closely with the Federal EPA, 5 the State, the community, whatever it is to 6 identify if there are any health needs or 7 health concerns associated with 8 environmental exposure. And that's 9 basically our main role. 10 One other thing I'll tell you about 11 our agency, my agency, is that it is an 12 independent environmental health agency. 13 In other words, we look at situations that 14 affect you, the community, on an 15 independent basis. We look at all the data 16 that was put in front of us and we evaluate 17 that data independently of other agencies. 18 And we give you our health call as to what 19 is up or what's going on in your 20 community. I'm not going to spend too much 21 more time on this. Here's the information 22 and certainly if after the meeting you want 23 to speak more to me about our agency, you 24 can have this information about ATSDR. And

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1 there's a lovely young lady over here who 2 says she's a computer geek, so I'm going to 3 pass this onto you, which is our web page. 4 And we also have some more of that if 5 you're into computer information. And 6 actually you can get a lot of information, 7 more than I could ever tell you tonight, 8 about contaminants, about how they impact 9 on human health. So if you want that 10 information I can certainly pass that along 11 to you too. And I'll certainly give you my 12 card and, as Pat indicated, if you have any 13 follow-up questions. 14 I'm not a scientist. I'm just like 15 you guys. But I work in public health so 16 there may be some specific questions, if 17 you do come up with any, that refer to a 18 specific science or physic radiation. I'll 19 refer those to Alan. He is a health 20 physicist and the person who can give you 21 the scientific readouts. I'll give you the 22 readout from the point of view of just 23 common people like ourselves. 24 If you look at the houses that, as

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1 they existed 50, 60 years ago or the area 2 around there 50, 60 years ago -- I wish we 3 were able to take one of these machines and 4 read what people were exposed to back then 5 and at what level. We don't know. We 6 don't know. That is the bottom line. 7 Nobody knows. It takes time for cancer to 8 develop. It doesn't happen overnight. And 9 it takes a lot of dosage, constantly being 10 exposed to these high doses. These are 11 things that just come out. And that's how 12 I understand it. 13 To get exposed on a normal basis, as 14 indicated, we do commonly get exposed to 15 radiation in different levels. Most of 16 that is not of public health concern. 17 People who generally worked in these 18 situations and got a constant exposure to 19 them, these are the people who developed -- 20 or in the case, you know, of the Japanese, 21 where you have a huge, huge amount of 22 dosage coming at you at one time. So these 23 things we know about. 24 Now, let me also make some other

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1 statements about the study. And that 2 hopefully will get to your question. Is 3 lung cancer -- can it be associated or is 4 it biologically causable that radiation can 5 cause lung cancer? The answer is yes. But 6 looking at the numbers and what was given 7 to ATSDR and the New Jersey Department of 8 Health who did the evaluation of the 9 sampling that was done, these dosages were 10 not high enough or should not have been 11 high enough to give you lung cancer. 12 That's the short and long of it. 13 But nonetheless, ATSDR, my agency, 14 along with the New Jersey Department of 15 Health and the Department of Health and 16 Human Services decided to take a look. And 17 you won't be surprised to hear that in New 18 Jersey there are other sites like this. So 19 you have Maywood in Maywood, New Jersey. 20 You have the West Orange, Montclair area, 21 all similar radon exposures. New Jersey 22 and ATSDR decided, well, let's take a look 23 because communities generally are concerned 24 about cancer and understandably so,

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1 radiation issues around these type of 2 Superfund sites. 3 So we pick these three areas here, 4 this whole bottom area (indicating), and 5 those other two that I just mentioned. If 6 you read the study, you'll find out that 7 with an examining of the cancer risks 8 around a one- or two-mile area of those 9 Superfund sites, there was no elevated 10 cancer of any type found associated with 11 the exposure to radon or radiation. Didn't 12 find it. Didn't find it in Montclair. 13 Didn't find it in Maywood. 14 What we did find, what you're 15 bringing up is, yes, there was elevated 16 lung cancer found here in this area. 17 What's kind of interesting is, you have the 18 same type of contaminant. 19 If you look at the history of all of 20 these sites, they're very similar. And yet 21 you have just one elevation of one type of 22 cancer, lung cancer, in this area. What 23 you would want -- what you might expect to 24 find is that if this is all similar

DEGNAN& BATEMAN, INC. (609) 547-2565 500154 64 EPA Public Meeting - 2/23/99

1 contamination, all similar exposures to 2 people, that you'd find lung cancer here 3 and find lung cancer in Maywood and you'd 4 find lung cancer also in the Montclair, 5 west Orange area. 6 Is radiation the cause for the 7 increased lung cancer? In all honesty, I 8 cannot say to you standing in front of you, 9 and I wouldn't say that, that it isn't 10 possible. It is possible. The probability 11 of it is probably much less than that. 12 Okay. Beyond that, it would take a very -- 13 you'd have to study the individual people 14 themselves to find out --to rule out 15 other, what are called, confounders. 16 What are these confounders? These 17 confounders are things like occupational 18 exposure that causes lung contamination. 19 Smoking, that we know has a direct 20 association with lung cancer. These are 21 the confounders that, if you pursued this 22 further, you may find, yes, there was a lot 23 of smokers out there. Or, yeah, they were, 24 in fact, occupationally exposed. And that

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1 elevated number that was found from that 2 study will start to decrease or it should. 3 Unless we rule out all other 4 confounders and you're stuck with, yeah, 5 it's the radiation. That's what that study 6 was trying to find out. Is there any 7 similarities in the occurrence of cancers 8 within those three -- around those three 9 given Superfund sites and there wasn't any 10 found. Other than the one elevation of 11 lung cancer here. And that was the purpose 12 of the study. It wasn't necessarily to 13 associate Superfund sites and cancer. That 14 was not the purpose. The purpose was to 15 see if there was any commonality of the 16 exposures and things like that from the 17 Superfund sites. 18 Let me stop there. Having heard what 19 Alan said, having heard what I said, are 20 there more concerns than that? Did I 21 somewhat, kind of, sort of, answer your 22 question? 23 MS. MARKS: Yes. It's just my 24 concern that we live in the area that's

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1 very polluted. 2 MR. BLOCK: It's a very real 3 concern. 4 MS. MARKS: Exactly. And the 5 Welsbach problems coupled with this study 6 just alarmed me more than I thought. 7 I do have a couple other questions.

8 MR. EVANGELISTA: At this point I'd 9 like to address the other part of your 10 question regarding how the EPA will deal 11 with affected residents whose property will 12 require cleanup. 13 As Rick and I touched upon a little 14 earlier, we talked about the remedial 15 design phase of the project. At that point 16 EPA will look at each of these individual 17 properties that will require cleanup and 18 design an approach for cleaning up that 19 property. And each property will be 20 different. You may have a property that 21 has several bricks in the backyard that we 22 will essentially pick up and take away. We 23 may have another property where we may have 24 to excavate a certain volume of soil that's

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1 elevated in levels of radioactivity which 2 we'll also move away. 3 Whatever you may have as far as a 4 cleanup that's required, the agency will 5 and hopes to work very cooperatively with 6 the property owner. Our intent or our 7 approach will be as we've applied it in 8 other sites like Montclair where we'll work 9 as closely as we can with the property 10 owner to impose as little inconvenience as 11 possible. 12 You touched a little bit upon 13 relocation. If there's a need for 14 relocation, which we hope there won't be, 15 but if there is a need then EPA will work 16 as closely with the property owner as 17 possible to provide as temporary relocation 18 as possible. And, of course, that will be 19 at our expense or the Superfund's expense. 20 But we hope that that will not be the case 21 for any of the properties. But I'm not out 22 here to tell you tonight that that's not 23 ever going to be the case on any of these 24 projects. That may very well be the case

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1 on some of the projects. So we'll just 2 have to wait and see and we'll do our best 3 to keep you as informed as possible in as 4 timely a fashion as possible. 5 MR. SAUNDERS: Say I live in a house 6 that there's known contamination there, I 7 understand remedial measures have already 8 been taken (INAUDIBLE) shields as discussed 9 earlier. So right now, if you're in the 10 house (INAUDIBLE) we know we're going to 11 protect you. There's a lot of (INAUDIBLE) 12 that don't care about the health issues, 13 they just care about the trees and birds. 14 That's the farthest thing from the truth. 15 (INAUDIBLE) and then we go from there. And 16 we have been somewhat criticized in 17 (INAUDIBLE) and using overkill. And yes, 18 we do take overkill and we wear it as a 19 badge of honor. (INAUDIBLE) some of the 20 people over at the Popcorn Factory, I'd 21 much rather be brought before my governing 22 body -- there are quite a few Council 23 people here -- I'd much rather be brought 24 on the carpet for overkill than not doing

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1 enough. And the direction is always 2 overkill. It's never not enough. So here 3 that's what we've taken. EPA, they have 4 gone above and beyond in many, many 5 situations. 6 MS. MARKS: Would there be any sort 7 of follow-up, I mean, like a health study 8 done on the residents after your remedial 9 work takes place? Will you be tracking 10 them for a period of time to see if they 11 develop any sort of problems or any 12 long-term problems due to -- maybe before 13 your remedial work started and before these 14 temporary structures were put into place? 15 MR. SAUNDERS: Would you be able to 16 speak for the purpose of contamination? 17 MR. BLOCK: Your question is more, as 18 I understood it, they're going to begin the 19 remedial and then -- did I sense that you 20 think you're going to be exposed to 21 something during that time period and 22 then --

23 MS. MARKS: NO; no. 24 MR. BLOCK: Okay. I did

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1 misunderstand then. 2 MS. MARKS: I understand the way it's 3 going to occur, what I'm saying is, these 4 people, evidently, I assume some of them 5 have been living in these contaminated 6 homes for some time. Will there be some 7 sort of a health study done on them before 8 the remedial work starts and then would 9 there be a follow-up study just to track 10 the situation to see if anything — they 11 have incurred any sort of medical problems? 12 MR. FELLMAN: in a sense that first 13 health study is what ATSDR funded to the 14 State. Because the only health effects 15 that we associate with exposure to 16 radiation is cancer. There aren't other 17 illnesses that we look at as indices of 18 radiation exposure. So it's either 19 elevated cancer or not. And so that first 20 look, in effect, is the study that you've 21 looked at. Now whether there's going to be 22 an additional study done or another study 23 done down the road -- I think -- 24 MR. BLOCK: The bottom line, is there

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1 a health plan? 2 MR. ROBINSON: It's not planned. 3 MR. FELLMAN: It's not part of this 4 process. 5 MR. BLOCK: It doesn't require it 6 from the viewpoint of looking at the site 7 and how the impact on health would be. So 8 the short answer is no. But I know Bob 9 wanted me to just discuss the Cancer 10 Registry. 11 Are all of you familiar with the 12 State Cancer Registry? Is there anyone who 13 needs information on that and how it works 14 and what it's there for? Are you okay with 15 that? Because I'll spend a moment on that 16 if you'd like. 17 New Jersey, like all 50 states 18 throughout the nation, maintains what is 19 called a Cancer Registry. Some states do 20 it better than others. And, in fact, 21 they're funded very well to maintain a good 22 Cancer Registry. And within the states 23 there are mandated laws that hold -- 24 hospitals and physicians who diagnose

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1 cancer must report that cancer incident to 2 the State. And once it's reported, then it 3 comes into the registry system. 4 And the reason for that is, 5 obviously, all of us are concerned about 6 cancer. Not only for research reasons, but 7 certainly we want to know how much cancer 8 is out there and specifically within our 9 own areas. Are there more elevated cancers 10 overall? Why? Because that then may 11 prompt further investigations. A perfect 12 example of that is just north and east of 13 here, Toms River. And I'm sure a lot of 14 you have heard about that. And our agency, 15 ATSDR, along with the New Jersey Department 16 of Health is very, very much into that 17 childhood cancer investigation at this 18 point. 19 So this Cancer Registry maintains all 20 of the reported incidents. And actually 21 this is kind of interesting. Prior to Toms 22 River, the New Jersey Cancer Registry was 23 probably four to five years behind in terms 24 of keeping up with the data that was

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1 entering in. After Toms River, all of a 2 sudden money came into the Cancer 3 Registry. And now it's probably -- and I'm 4 not kidding you about this -- New Jersey's 5 Registry is a gold mark standard registry. 6 But something like that had to happen. And 7 there are other states in the union who are 8 not very good with keeping their data. But 9 New Jersey is exemplary with its program. 10 Now what that does is -- and when you 11 get into the issue of statisticians and 12 numbers and how big populations are in 13 terms of how do you measure what's 14 happening in one community as opposed to 15 another community, what they do is -- I'm 16 simplifying it, really -- I have to. I 17 really don't understand all of it. I'm not 18 a statistician. 19 What they do is take comparable 20 populations in numbers and size and their 21 socioeconomic background. And they compare 22 these two populations which are similar and 23 look at the cancer rates or incidents 24 within those populations, they should be

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1 similar. Everything else being equal, they 2 should be similar. But if something pops 3 out, whether it be bladder cancer or lung 4 cancer or brain cancer, that just doesn't 5 gel, that pushes the investigative health 6 system to go further, what's in this 7 neighborhood that may be causing it, to do 8 further investigation. 9 MR. SAUNDERS: In an indirect way, 10 yes, there is a follow-up indirectly. 11 MR. GRABOWSKI: Mike Grabowski. I'm 12 just wondering if your house is found 13 contaminated and you don't want to live 14 there, you want to sell, there's a problem 15 there. But the State of New Jersey has a 16 disclosure on it. You have to tell the 17 Realtor. What happens with that? 18 MR. ROBINSON: Well, I guess that's 19 one of the grey areas of the process with 20 an individual property that has 21 contamination on it and the property owner 22 wants to sell it. 23 For EPA, what we can do to a 24 potential purchaser --we can enter into an

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1 agreement with the purchaser to give them a 2 prospective purchaser agreement to not be 3 held liable for any cleanup costs associated. 4 That way it may be helpful with the 5 transfer. So that he wouldn't be taking on 6 liability. However, with respect -- 7 MR. EVANGELISTA: And assurance that 8 it will be cleaned up.

9 MR. ROBINSON: Right. 10 MR. GRABOWSKI: Do I have to put down 11 the limit of contamination in the area? 12 MR. EVANGELISTA: We would be able to 13 inform them at an appropriate time when 14 we've properly investigated your property 15 -- if it's your property that we're 16 talking about -- yes, we'll have cut lines 17 as we call them, where the contamination IB is, an estimate of the volume, etc., etc. 19 If someone's interested in your property, 20 we can provide them with a document that 21 says EPA is going to clean up this property 22 and is not going to hold you accountable 23 for it in any way, shape or form. 24 MR. GRABOWSKI: It will be pretty

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1 tough to sell the property. 2 MR. EVANGELISTA: I understand that, 3 sir. 4 MR. GRABOWSKI: Nobody would want to 5 buy it, I don't think. 6 MR. EVANGELISTA: I understand. And 7 I guess the other part that may give you 8 comfort, we've been moving along in this 9 project extremely quickly. You may look at 10 other Superfund projects where an RI/FS has 11 gone on for three, four, five years. We've 12 completed this process in what some would 13 say is record time, we did it in a year. 14 And we hope to continue moving that quickly 15 so that we can restore your property and 16 others to a form where it may be attractive 17 for selling or you may be comfortable with 18 it again.

19 UNIDENTIFIED SPEAKER: I Own a 20 property on Temple Avenue that goes right 21 into Newton Creek, concreted over. My son 22 was told recently by a lawyer from Malcolm 23 Pirnie that -- I had wanted to either give 24 him the property or sell it, get it out of

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1 my hair, so to speak. And the lawyer told 2 him that he would be responsible for the 3 cost of the cleanup. 4 MR. KERBEL: Just to be clear, it 5 wasn't a Malcolm Pirnie lawyer. I don't 6 know if --

7 UNIDENTIFIED SPEAKER: He had spoken 8 to Steve McNally(ph). 9 MR. KERBEL: Steve is right here.

10 UNIDENTIFIED SPEAKER: And he was 11 referred to a lawyer. 12 MR. ROBINSON: I think Steve referred 13 your son to me.

14 UNIDENTIFIED SPEAKER: Oh, was that 15 you?

16 MR. ROBINSON: Yes, I'm Rick 17 Robinson. 18 MR. KERBEL: We don't have the 19 authority. 20 MR. ROBINSON: Your son spoke to me 21 and I basically told your son it's in his 22 best interest to talk to an attorney to 23 find out from an attorney himself, his own 24 attorney. I didn't give him any legal

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1 advice. I just told him it would be in his 2 best interest to talk to an attorney prior 3 to any transfer. Because he doesn't want 4 to take on any liability knowing that he's 5 buying a contaminated property. I'm just 6 giving him advice, you know. I would 7 contact an attorney. And I was just --

8 UNIDENTIFIED SPEAKER: And if I died 9 tomorrow and he inherited the property, he 10 would not have to pay for the cleanup?

11 MR. ROBINSON: He would not. 12 MR. EVANGELISTA: And neither would 13 you. 14 MR. ROBINSON: It's a different story 15 when someone purchased the property not at 16 full-market value and they try to buy a 17 property for, you know -- they know it's 18 contaminated and they're getting it for, 19 like, three cents on the dollar or ten 20 cents on the dollar. That's where EPA 21 would then go back to that person who's 22 buying it cheaply and say, hey, you're 23 buying it not at the fair-market value and 24 we may want to get some of that money

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1 back. That's where the issue is. 2 MR. BLOCK: May I say one more thing 3 about the Cancer Registry? I just want to 4 point out the fact that the local County 5 and City here are trying to get information 6 from the New Jersey Cancer Registry to do 7 some type of follow-up also. So they're 8 attempting to get that information. 9 The Cancer Registry information is 10 extremely confidential and private. And 11 it's designed under law to be that way. So 12 to get that information, sometimes you have 13 to jump through hoops to try to get that 14 information. But I know your City and 15 County are attempting to get that 16 information to do some additional follow-up 17 work. Is that correct?

18 MR. SAUNDERS: Yes. 19 MS. CERVANTES-GROSS: Any other 20 questions or comments? 21 MS. MARKS: Just two more. I wanted 22 to address the issue of the alternatives. 23 One, obviously, was a No Action Alternative 24 which, for obvious reasons, would never

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1 work. The second, the Engineering Controls 2 Alternative. And the third, the excavation 3 and demolition of the various properties. 4 Is it my understanding that the EPA 5 is suggesting that the demolition and 6 excavation go forward? Has a decision been 7 made on that? 8 MR. ROBINSON: The decision won't be 9 made until EPA hears all the public 10 comments. And we're patiently waiting to 11 hear your responses today, your verbal 12 comments, and any written comments that are 13 submitted. As Mary Helen said earlier, our 14 public comment period ends on March 3, next 15 Wednesday. So after next Wednesday, then 16 EPA sits back and writes responses to all 17 of the questions and will formally select a 18 remedy in a document called the Record of 19 Decision. And attached to the Record of 20 Decision is another document that we call 21 the responsiveness summary, which 22 summarizes the verbal responses today that 23 we're given and the written responses 24 also.

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1 So that's why we have a court 2 reporter here today and she's taking down 3 your questions and my answers. So all that 4 will be part of the record. 5 MR. SAUNDERS: At the local level, 6 our (INAUDIBLE) is March 3. And on that 7 document would be a resolution (INAUDIBLE) 8 in our City that supports that. I asked 9 for a telephone campaign and that would be 10 such (INAUDIBLE). That is something they 11 need to make (INAUDIBLE) what is the 12 interest here. And we support them 13 totally. It's part of what has to occur 14 and we do have (INAUDIBLE) in that office 15 and our governing body (INAUDIBLE). 16 MS. MARKS: And I would hope that the 17 City of Camden would do likewise. Although 18 I would have to say in my years -- you 19 think you got 25 people here tonight -- 20 you'll probably be lucky if you get ten 21 tomorrow night. Unfortunately, a lot of 22 City residents aren't real anxious to go 23 into the CCMUA at night. So that may not 24 give you a real indication. Has anyone

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1 there been in touch with the mayor over the 2 situation? 3 MR. ROBINSON: I've been in contact 4 with the City of Camden, the mayor's 5 assistant. 6 MS. MARKS: Okay. I would like to 7 see the City of Camden put forth the same 8 kind of resolution to remove and excavate 9 the sites. 10 MR. EVANGELISTA: I guess based on 11 what we've seen and heard thus far, it's 12 our anticipation that the decision will be, 13 in fact, to excavate both Camden and 14 Gloucester City. 15 MR. FELLMAN: In the proposed plan, 16 that's what EPA is indicating is EPA's 17 preference. So they need to have reasons 18 why not to go forward with that, as opposed 19 to having to be convinced to do it. 20 MS. MARKS: Okay. One more 21 question. When you excavate these sites 22 and remove the contaminated material, it 23 will be put onto a truck and trucked out of 24 the area to wherever your hazardous waste

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1 facility is? 2 MR. ROBINSON: Most likely we will 3 probably ship it by rail. 4 MS. MARKS: Okay. If you ship it by 5 rail it's obviously not going to be put on 6 the train right here in Gloucester City -- 7 MR. ROBINSON: We would hope to find 8 a site here in Gloucester City to ship it 9 out. 10 MS. MARKS: On rail? 11 MR. ROBINSON: On rail. 12 MS. MARKS: You're going to have it 13 come right from the contaminated site in 14 Gloucester City to the rail? 15 MR. ROBINSON: Or the nearest rail 16 transfer -- 17 MR. SAUNDERS: We have two staging 18 areas. If you're getting to or worrying 19 about spilling something, if you have an 20 opportunity I can take you to the tankers 21 they go in. They are totally encapsulated. 22 MS. MARKS: You're not going to bring 23 it in from Camden? Incinerator ash has -- 24 MR. SAUNDERS: We have sites here in

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1 Camden and Gloucester City (INAUDIBLE) put 2 on a truck. Just like you had (INAUDIBLE) 3 that stuff. 4 MS. MARKS: what is your estimate -- 5 MR. SAUNDERS: Now you said three 6 weeks. That's beyond anybody's control 7 here. 8 MS. MARKS: The problem is low

9 (INAUDIBLE).

10 UNIDENTIFIED SPEAKER: But your 11 earlier statement that the stuff was 12 falling out the top and containers were 13 open and totally (INAUDIBLE) totally sealed 14 at the top. I wasn't -- 15 MR. SAUNDERS: They were just --if 16 your concern is about falling out -- 17 MS. MARKS: That is my concern that 18 some of it will be falling out as you put 19 it in and maybe it isn't all carried away. 20 MR. ROBINSON: We have a lot of 21 experience in dealing with contamination, 22 removing radiological contamination waste. 23 We just completed a very large excavation 24 in an Essex County site and a number of

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1 homes in Orange, New Jersey and Montclair. 2 That material is transported by truck and 3 sent out to Utah. Trucks moving it every 4 day, moving it for four or five years now. 5 MS. MARKS: I wasn't insinuating that 6 there was -- 7 MR. ROBINSON: The material is not 8 hazardous waste; it's radioactive waste. 9 MR. GRABOWSKI: Something should be 10 on those trailers. In my neighborhood 11 where I have a store, kids are jumping that 12 fence and playing in that area. Now why 13 shouldn't that be marked off as hazardous 14 waste? 15 MR. SAUNDERS: Well, as I said 16 before, I hope you're calling the police 17 when children are there. The (INAUDIBLE) 18 site you saw with contamination is under 19 gravel and dirt. There's a fence. In 20 order to get into those trailers 21 (INAUDIBLE) to get into that property. 22 MR. GRABOWSKI: Why don't you have 23 signs up? 24 MR. SAUNDERS: The other issue is,

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1 depending on the type of radiation you 2 have, it depends on how you placard it. At 3 that level there isn't an appropriate 4 placard. It's too low. 5 MR. FELLMAN: The labeling on the 6 container for this type of waste is 7 outlined in the Department of 8 Transportation regulations. And the levels 9 are such, or this type of waste is such, 10 that it doesn't warrant the type of label, 11 I guess, that you're looking for. 12 MR. GRABOWSKI: How high is that 13 rating on that site? 14 MR. FELLMAN: The rating? 15 MR. GRABOWSKI: Reading; reading. 16 The reading that you're getting. 17 MR. FELLMAN: I haven't scanned those 18 containers so I couldn't answer that other 19 than to say it's clearly elevated because 20 if it wasn't, it would not have been 21 removed from the park. So there's 22 something there. How high? I don't know. 23 MR. EVANGELISTA: You're not talking 24 about placards that should be on them for

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1 shipment, you essentially just want some 2 warning signs for kids. 3 MR. GRABOWSKI: You know, like Bob 4 said, call the police. I work too and my 5 wife can't constantly sit by the window and 6 watch. 7 MR. ROBINSON: What we'll do is, 8 we'11 arrange for signs to be placed on the 9 fence. 10 MR. SAUNDERS: This is the problem we 11 have. If we speak to X amount of neighbors 12 and try to accommodate the wishes of most 13 neighbors in this township, that's the 14 problem. We're never going to make 15 everybody happy. Some people want signs. 16 The vast majority of people indicate to me, 17 if we don't have to have signs, they really 18 appreciate it. 19 MR. FELLMAN: They want it to be 20 invisible. They don't want signs right 21 next to their homes. 22 MR. GRABOWSKI: I think it's stupid. 23 MR. FELLMAN: And you're entitled to 24 that opinion. But this is what people are

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1 telling Bob and other folks. 2 MR. GRABOWSKI: They're afraid 3 because if they want to sell their house, 4 nobody is going to buy it. 5 MR. SAUNDERS: It's going to be 6 remediated as soon as possible. It's also 7 going to be certified clean. And nothing 8 will be done on there until that's done. 9 We can say confidently for the neighbors of 10 the Popcorn Factory, that site is safe for 11 you and everyone else. And we say that 12 with full confidence. The items that are 13 staged there will be removed. Those types 14 of things are there to make sure that the 15 residents, children and everyone else are 16 safe, we're not going to tell you things 17 that we don't know as exist today.

18 UNIDENTIFIED SPEAKER: Mike sees 19 these people in the suits, but they're 20 dealing with the removal every day. But if 21 you go and you walk, you're not going to 22 get that type of exposure. Is that what 23 you're concerned about, Mike? 24 MR. GRABOWSKI: No. The children in

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1 the neighborhood. I live catty-corner from 2 that. I don't know if my property is 3 contaminated or not. 4 MR. SAUNDERS: In order for the kids 5 to get into the containers -- 6 MR. GRABOWSKI: They're not getting 7 into the containers. They're covered. But 8 they're getting into the property 9 (INAUDIBLE) before the fence (INAUDIBLE). 10 MR. SAUNDERS: I think even if you 11 patrolled it (INAUDIBLE). It's an example 12 of overkill. The City has done more to 13 protect our residents than (INAUDIBLE). 14 Required us to put more gravel at the site, 15 to be more protective of our residents. So 16 even if a child is standing (INAUDIBLE), 17 it's somewhat misleading that the 18 contamination is underneath. 19 So again, as Alan said, (INAUDIBLE) 20 it's, like, months and months and months of 21 not moving it. We used overkill and are 22 protective of that site. And I appreciate 23 your concerns. And they're valid. And 24 we've taken --if they tell us this is good

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1 enough, we go a few more steps.

2 UNIDENTIFIED SPEAKER: As far as 3 getting from point A to point B, I live in 4 the (INAUDIBLE) hundred block of Somerset 5 Street. And as a truck would back in, they 6 would put a tarp down. The truck would 7 back over top of this tarp, seal it, and 8 actually broom the truck off and everything 9 around those tires was broomed off. I 10 thought it was total overkill protection 11 for us, the residents of the City, and I 12 loved it. Before that truck moved, three 13 or four guys would walk around it and sweep 14 every tire, every little nook and cranny. 15 It was amazing how they did it. 16 MR. EVANGELISTA: In addition to 17 that, getting back to the containers on the 18 Popcorn property, not only are they covered 19 with the locked covers, but inside the 20 material is covered with clean fill. So 21 even if someone opens the cover and gets in 22 there, they're jumping onto -- 23 MR. GRABOWSKI: I didn't know you had 24 clean fill on top of that.

DE6NAN & BATEMAN, INC. (609) 547-2565 500181 91 EPA Public Meeting - 2/23/99

1 MR. EVANGELISTA: So there's that 2 additional protective measure that's been 3 taken. Like the gentleman said, everything 4 is done with overkill. 5 MR. SAUNDERS: They are metal too. 6 The tops are sealed shut metal units, not 7 open containers. There are several things 8 they would have to do to get to the 9 problem. 10 MS. CERVANTES-GROSS: Any other 11 comments or questions? Thank you for 12 coming and, again, you have until next 13 Wednesday if you have any other questions 14 or comments. And you may have seen on the 15 board outside here, there is additional 16 information on the individual properties in 17 the areas. Thank you. ]_g ********

19 MS. CERVANTES-GROSS: Can we go back 20 on the record for some additional comments, 21 please? 22 MS. GRAHAM: Theresa Graham and Ed 23 Gorman, Chairman of the Community 24 Playground, Fort Nassau, that will be

DEGNAN & BATEMAN, INC. (609) 547-2565 500182 92 EPA Public Meeting - 2/23/99

1 placed at Johnson Boulevard right in the 2 middle of the jogging track. And our 3 concerns are the safety of any contaminants 4 on there. We were told that an overall was 5 done of the top of it and there doesn't 6 appear to be any right there. 7 And our concern is that we'11 put 8 $110,000 into the building of this 9 playground and then come April 7th or nth 10 we'll have it finished, and then what 11 happens to it if later on you find 12 something there. We want to be assured 13 that our property, if anything has to be 14 done, will be taken care of by DEP, I 15 guess. 16 MR. GORMAN: By somebody. 17 MR. GRAHAM: By somebody. Because a 18 lot of time and effort on the part of this 19 community as a whole has gone into this 20 project. And we want to safeguard the 21 children of the community above all. 22 MR. GORMAN: Is there any fast 23 tracking or something they could test 24 before we actually build it on April 7?

D E G N A N & BATEMAN, INC. (609) 547-2565 500183 93 BPA Public Meeting - 2/23/99

1 MS. GRAHAM: Is there any kind of a 2 boring that they could come down and do to 3 totally assure us? Because we're already 4 contracted in for the beginning of this 5 project on the 7th. Thank you. g ********

DEGNAN & BATEMAN, INC. (609) 547-2565 500184 94

1 CERTIFICATE

2 STATE OF NEW JERSEY 3 I, LINDA A. BURNS, Shorthand Reporter and Notary 4 Public of the State of New Jersey, do hereby certify 5 that I reported the public hearing in the 6 above-captioned matter and that the foregoing is a 7 true and correct transcript of the stenographic notes 8 of testimony taken by me in the above-captioned 9 matter. 10 I further certify that I am not an 11 attorney or counsel for any of the parties, nor a 12 relative or employee of any attorney or counsel 13 connected with the action, nor financially interested 14 in the action. 15 16 17 18 19 20 21 22 Linda A. Burns 23 24 Dated: March 4, 1999

DEGNAN & BATEMAN, INC. (609) 547-2565 a A. Burns 500185 ary Public Appendix D

Written Comments

500186 3-03-1999 3 = 43PM UUUUUfciitK i T r me.

RESOLUTION

#R-05t -99 A RESOLUTION ENDORSING THE|ENVIRONMENTAL PROTECTION AGENCY'S PLAN FOR CLEANUP OF RADIOLOG1CALLY CONTAMINATED PROPERTIES i WHEREAS, the United States Environment!) Protection Agency has investigated vahous sites in Gloucester City and Camdon in rclatiqiship to the Welsoach/Genenl Mantle Supcrfund Contamination She, including the four areas in Gloucester Chy listed below: a) Study Area Two - an industrial zonal property along the Delaware River, formerly occupied by the Wclsbach Cc -poration and a residential area to the immediate east: b) Study Area Three - residential and recrer lional properties, including the Johnson Boulevard Land Preserve; c) Study Area Five - residential proper ies, vacant land properties, and two municipal parks near Temple Avenue anc the South Branch of Newton Creek, d) Study Area Six - vacant lots in a resident al zoned area of Gloucester City: and i WHEREAS, the E.P.A.'$ investigations have shown properties in the above stated locations to contain soil contaminated to van-ing degre :s 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 follov ing alternatives to address the findings stated above: a) No action; b) Installation of engineering controls; c) Excavation and off-site disposal of contai linated materials; and WHEREAS, the locations of this contamination re almost entirely located in residential and recreational areas, and the cost of excavation i id off-site disposal, estimated to be $31,9 t2T 120.00, shall be born entirely by the United State Environmental Protection Agency. NOW, THEREFORE, BE IT RESOLVED thit the Mayor and Common Council of Gloucester City do hereby endorse the excavation and oftpsite disposal of contaminated materials from the Welsbach/General Mantle Superfund Contamination Sites which are located in Gloucester City.

Robert T. German. Mayor

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

500187 2

3 U.S. Environmental Protection Agency's (EPA's) 4 Proposed Plan for Cleanup of Superfund Sites 5 Public Hearing 6

7 _.__-__-__--._____ February 24, 1998 8 __._——.._-.__._.. 9 Public Meeting of the U.S. Environmental 10 Protection Agency (EPA) held at the Camden County 11 Municipal Utilities Authority Auditorium, Camden, 12 New Jersey, before Linda A. Burns, Shorthand Reporter 13 and Notary Public of the State of New Jersey, on the 14 above date, commencing at 7:00 p.m.

15 16

17 18 19 20 21

DE6NAN & BATEMAN, INC. (609) 547-2565 500188 1 EPA MEMBERS IN ATTENDANCE: 2 Richard J. Robinson, Project Manager Pat Evangelista, Team Leader 3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch

11 INDEX Witness Page 12 Donna Maggio(ph) (INAUDIBLE) 41,47 13 Olga Pullman(ph) 44 14 EXHIBITS 15 (There were no exhibits marked at this time.) 16 17

18 19

DE6NAN & BATEMAN, INC. (609) 547-2565 500189 EPA Public Hearing - 2/24/99

1 MS. CERVANTES-GROSS: We're going to 2 go ahead and start. I just wanted to thank 3 everyone one coming here tonight and we'll 4 be giving you several presentations 5 tonight. My name is Mary Helen 6 Cervantes-Gross. I'm with the EPA and I'm 7 here actually, standing in temporarily, for 8 Natalie Loney whom most of you know. She 9 just had a baby boy on February 14 and she 10 will be back out here in the future to work 11 with you again. 12 But with us here tonight is 13 Rick Robinson, Project Manager for the 14 Welsbach General Gas Mantle Superfund site; 15 Pat Evangelista, who is the team leader 16 with the EPA overseeing various types of 17 radiation sites and other types of sites 18 throughout the region. Here as well is 19 Arthur Block with ATSDR. He works with the 20 EPA's Agency for Toxic Substances and 21 Disease Registry, as well as a consultation 22 business on health-related issues. Here 23 tonight also is Alan Fellman as well as 24 Bob Kerbel, both with Malcolm Pirnie who

DEGNAN & BATEMAN, INC. (609) 547-2565 500190 EPA Public Hearing - 2/24/99

1 are contractors for EPA working on both 2 investigation of the sites and put together 3 much of the information that you will hear 4 tonight. 5 And I just wanted to remind everyone 6 that what you say tonight, whatever 7 questions you have, what comments you have • 8 --we have Linda Burns here who is a 9 stenographer and who is officially taking 10 down all of your questions and comments and 11 they will go into the official record. And 12 at the end of the public comment period, 13 which ends next Wednesday, March the 3rd, 14 we will review all of the comments chat we 15 have received both here tonight and at the 16 meeting that we had last night in 17 Gloucester City. We will also review any 18 written comments that we have, and we will 19 prepare a responsiveness document answering 20 or responding to any comments that you 21 have. As well, all of these comments will 22 be looked at before we make a final 23 decision, because that's what we do with a 24 Superfund program. Throughout the program

DE6NAN & BATSMAN, INC. (609) 547-2565 500191 EPA Public Hearing - 2/24/99

1 we come out to the community before we make 2 final decisions in an attempt to answer any 3 questions or concerns you have, so that we 4 are sure to address those in its final 5 decision. 6 So with that I will turn it over to 7 Pat who will talk to you a little bit about 8 the Superfund program in general. 9 MR. EVANGELISTA: Welcome. Before I 10 get started in my part of the meeting this 11 evening, I'd like to introduce to you, as 12 well, Fred Mumford who is here representing 13 the New Jersey Department of Environmental 14 Protection. What I'd like to do in getting 15 the meeting started is to just talk to you 16 a little bit about the Superfund process 17 and how it works and just to familiarize 18 you or remind you of how it works. 19 Back in 1980 Congress handed the EPA 20 a law known as the Comprehensive 21 Environmental Response and Liability Act 22 and amended it five or six years later. So 23 it's what we're working with at this site 24 today.

DE6NAN & BATEMAN, INC. (609) 547-2565 500192 EPA Public Hearing - 2/24/99

1 It starts out with what's known as 2 discovery. Discovery is the part of the 3 process where we are actually made known of 4 the site and it warrants us to follow up 5 and perform what's known as a preliminary 6 assessment or site inspection where we 7 gather information that we need to do 8 what's known as a hazard ranking. In 9 performing the ranking we generate what's 10 known as a hazard ranking score. And if 11 that score is or exceeds 28.5, the site 12 ends up on what's known as the National 13 Priorities List. 14 This allows us as EPA to perform 15 what's next in the process and this is 16 known as a remedy investigation feasibility 17 study. That's what we would call the more 18 detailed investigation of the site to 19 gather all of the information that we need 20 about that site to generate alternatives 21 that we would look into for remediating the 22 problem or cleaning up the problem. And 23 those alternatives are evaluated in the 24 feasibility study part of that remedial

DEGNAN & BATEMAN, INC (609) 547-2565 EPA Public Hearing - 2/24/99

1 investigation. 2 The alternatives are then evaluated 3 according to certain criteria and, you 4 know, at the end of that process we would 5 recommend a cleanup alternative that we 6 would put before you, the public, and 7 concerned citizens. And that part of the 8 process is what's known as the proposed 9 plan. 10 The proposed plan is what we 11 presented as of February l and is subject 12 to your review and comment. And that's 13 part of the reason why we're here tonight. 14 As a result of the public comment 15 period, we generate what's known as a 16 transcript, hence our stenographer here. 17 And that transcript is added to the record 18 of decision which formalizes the agency's 19 decision, your comments inclusive, of 20 course. 21 After that we enter into what's known 22 as remedial design. We actually design the 23 nuts and bolts of the remedy that the 24 agency has selected.

DBGNAN & BATBMAN, INC. (609) 547-2565 500194 EPA Public Hearing - 2/24/99

1 From there we enter into the cleanup 2 phase and ultimately we certify it as clean 3 and acceptable for future use. And we 4 delete the site from the National 5 Priorities List. 6 That's basically the process. If you 7 have any questions I'd be happy to answer 8 them for you later. Thank you. 9 MR. ROBINSON: I'll just go into a 10 little bit of background on the site. As 11 most of you know the site is located both 12 in Camden and in Gloucester City. And it 13 comprises the two former gas mantle 14 manufacturing facilities. It also includes 15 residential properties, commercial 16 properties, municipal park lands in 17 Gloucester City and vacant land. 18 As part of the State's investigation 19 early on, they divided the sites into study 20 areas. And for the purposes of our 21 investigation we followed those study 22 areas. And the first study area is where 23 we are right now in Camden around the 24 General Gas Mantle facility and the

DEGNAN & BATEMAN, INC. (609) 547-2565 500195 EPA Public Hearing - 2/24/99

1 surrounding properties. Study Area Two is 2 Gloucester City, the former Welsbach 3 facility. Study Area Three is also in 4 Gloucester City. It comprises residential 5 properties and land preserve. Study Area 6 Four, some residential properties in the 7 Fairview section of Camden. And Study Area 8 Five, residential properties including 9 municipal parks in Gloucester City. And 10 Study Area Six is also some vacant land 11 properties in Gloucester City. 12 Again, Study Area One is around the 13 General Gas Mantle facility here in 14 Camden. And this is a photograph of the 15 area and the General Gas Mantle building is 16 highlighted. There's a photograph of the 17 famous General Gas Mantle building. 18 Study Area Two is the former Welsbach 19 facility, it's now owned by Holt. The 20 Gloucester terminal is there on Kings 21 Street. And the Armstrong building is the 22 last remaining building from Welsbach's 23 operation. 24 Study Area Three is Gloucester City

DEGNAN & BATEMAN, INC. ,609, S47-2S6S 10 EPA Public Hearing - 2/24/99

1 and it comprises the swim club area and 2 Johnson Boulevard Land Preserve. 3 Study Area Four is in the Fairview 4 section of Camden. And we only had a few 5 properties in that area that had some 6 elevated gamma radiation levels. 7 Study Area Five is Gloucester City 8 and comprises a dump area off of Temple 9 Avenue and municipal park lands. 10 Study Area Six is a newer identified 11 area in Gloucester City. We call it the 12 Popcorn Factory. 13 Site history: In about 1885 a 14 Dr. Carl Auer von Welsbach invented the 15 process of using thorium to manufacture gas 16 mantles. And just to let you know, gas 17 mantles are the material that's used for 18 camping lanterns or in the street lights. 19 Right there is a gas mantle (indicating). 20 And what they did is they took a sock of 21 material and dipped it in a solution of 22 thorium. And when the sock dried and they 23 lit it, it produced a very brilliant white 24 light. And as a result the thorium is

DBGNAN & BATEMAN, INC. (609) 547-2565 500197 11 EPA Public Hearing - 2/24/99

1 radioactive. And that's what we're here to 2 clean up. 3 In the 1890s welsbach started 4 manufacturing the gas mantle and by the 5 turn of the century they were the world's 6 largest manufacturer of them. And in the 7 early '40s they went out of business when 8 the electric light put gas lighting out of 9 business basically. 10 Very little is known about General 11 Gas Mantle. We know they operated from 12 around 1912 to 1941. We just know that 13 they probably used radium and thorium. 14 They didn't manufacture -- they didn't 15 process any ores. They just bought the 16 ores -- bought the refined radium and 17 thorium. And they manufactured gas 18 mantles. 19 What we've termed all of the other 20 properties that are associated with the 21 radiological contamination here, besides 22 the Welsbach facility and the General Gas 23 Mantle facility, we call them vicinity 24 properties. And they were contaminated

DEGNAN & BATEMAN, INC. (609) 547-2565 500198 12 EPA Public Hearing - 2/24/99

1 either from disposal of ore tailings from 2 Welsbach, or building debris from when they 3 knocked some building down, or when they 4 built the bridge back in the early '50s, or 5 from workers bringing contamination home 6 with them. 7 Previous investigations: The site 8 was initially identified in 1980 as a 9 potential radiation site during search of 10 the U.S. Radium site in Orange, New 11 Jersey. And in 1981 EPA sponsored an area 12 fly-over to search for gamma radiation. 13 And a helicopter came over the area looking 14 for excess gamma radiation levels. 15 In the mid-1980s the State went out 16 conducting preliminary screenings in the 17 area. And in the early 1990s they 18 investigated over a thousand properties 19 throughout Camden and the Gloucester City 20 area. Based on those results they 21 identified about 20 properties that they 22 felt that needed more immediate action. 23 And as a result they installed some 24 radon/thoron ventilation systems in some

DEGNAN & BATEMAN, INC. (609) 547-2565 500199 13 EPA Public Hearing - 2/24/99

1 homes. They put concrete or steel sheeting 2 down to shield for gamma radiation. And 3 they purchased one property in Gloucester 4 City and relocated the resident. 5 Also, in 1992 they removed 6 radioactive materials from the old General 7 Gas Mantle building. They relocated the 8 occupant at the time, Ste-Lar Textiles. 9 And they sealed up the building to restrict 10 access. 11 The State investigation: They base 12 their contamination levels on surface 13 exposure rates, indoor radon sampling and 14 limited surface soil samples. However, 15 they didn't perform any subsurface 16 sampling. They made no estimate on the 17 amount or extent of contamination. And 18 they were just looking to address any of 19 the immediate potential health concerns at 20 the time. 21 EPA's involvement at the site, again, 22 when the site was placed or took the lead 23 --we took the lead on the site when the 24 site was placed on the Superfund list back

DEGNAN & BATEMAN, INC. (609) 547-2565 OQ 14 EPA Public Hearing - 2/24/99

1 in June of 1996. Currently, the General 2 Gas Mantle facility is inactive and boarded 3 shut. Welsbach is an active facility, now 4 owned by Holt. And the vicinity 5 properties, any immediate health treats 6 were either addressed through interim 7 measures performed by the State or by EPA 8 removal action last December in the park in 9 Gloucester City. 10 I'll now turn it over to Alan Fellman 11 from Malcolm Pirnie and he will give you a 12 real brief overview on radiation. 13 MR. FELLMAN: I just want to spend a 14 few minutes going over a couple of the 15 terms regarding radioactivity that will 16 hopefully make it a little easier for you 17 to understand. 18 Some of the things we're saying about 19 the conditions of these properties, when we 20 talk about radioactivity we're not talking 21 about a typical product that we measure in 22 pounds or address in terms of mass. We're 23 more concerned with the amount or the rate 24 at which the radioactive atoms are

DEGNAN & BATEMAN, INC. (609) 547-2565 500201 15 EPA Public Hearing - 2/24/99

1 decaying. And the unit that we use to 2 describe that is called pico Curies, which 3 we abbreviate pCi. 4 Now when we have radioactivity in 5 soil, we express the amount as 6 concentration in pico Curies per gram of 7 soil. And if we're talking about 8 radioactivity in water or liquid, then we 9 would express it as pico Curies per liter, 10 pCi/1. 11 Again, now this is only indicative of 12 how much there is. It doesn't really 13 address the dose or the risk. To do that 14 we need some other terms. The dose of 15 radiation is expressed in the unit known as 16 millirems. And what we are expressing when 17 we quantify millirems, that's a measure of 18 how much energy, which is released from the 19 radioactive emissions, is transferred from 20 those atoms into an absorbing media such as 21 the human body. The amount of energy 22 that's deposited is used to determine what 23 the dose is and, of course, the higher the 24 dose the higher the risk.

DE6NAN & BATEMAN, INC. (609) 547-2565 500202 16 EPA Public Hearing - 2/24/99

1 There are several different types of 2 radioactivity that are emitted from 3 thorium, uranium, radium, radionuclides 4 that are associated with this waste 5 material. Alpha particles are the heaviest 6 of these. They have mass. They travel 7 very slowly. And they can be shielded by 8 something as thin as a piece of paper. 9 Beta particles are intermediate in 10 penetrating ability. They can be 11 transferred through a piece of paper but 12 are more likely to be stopped by a piece of 13 wood. 14 On the other hand, gamma radiation, 15 also known as photons, have no mass. 16 They're simply packets of energy. And they 17 are also sometimes referred to as IB penetrating radiation. These are things 19 that are more likely to get through paper 20 or wood. And it takes something denser or 21 thicker to shield them, such as concrete or 22 . lead. 23 The problem that we have here for the 24 most part has to do with the radioactive

DEGNAN & BATEMAN, INC. (609) 547-2565 500203 17 EPA Public Hearing - 2/24/99

1 residue being present in dirt. And when 2 the dirt gets moved from the Welsbach or 3 General Gas Mantle facility onto an 4 adjacent or vicinity property, it can be 5 put in the ground either adjacent to a 6 structure or in some cases beneath a 7 structure. When the radioactivity decays 8 several of the -- most of the radionuclides 9 are solid. They don't travel; they don't 10 really go anywhere. They stay where they 11 are placed. But at one point in the 12 process the resultant atom that's formed is 13 a gas, radon. And if the radon gas is 14 formed in soil that's either up against the 15 side of a building or beneath the building, 16 now you've got something that's mobile and 17 can emanate from the soil into the building 18 resulting in a potential medical threat. 19 For people who don't have that 20 problem but where there's this type of 21 radioactivity associated with the soils 22 some distance from a structure, in that 23 case the potential exposure to the gamma 24 radiation that's emitted from the ground is

DEGNAN & BATEMAN, INC. (609) 547-2565 500204 18 BPA Public Hearing - 2/24/99

1 part of the radiation dose to a person 2 occupying that area. 3 Also, the next few minutes will be 4 spent going over the field investigations 5 that Malcolm Pirnie has performed for EPA 6 over the last couple of years and 7 Bob Kerbel will be talking about that. 8 MR. KERBEL: I know some of you were 9 here at the meeting we had a year ago, but 10 I'll just go over in the nutshell again the 11 type of work we've been doing in the two 12 communities. We did investigations at the 13 former Welsbach facility and the General 14 Gas Mantle facility, they are industrial 15 facilities. Now anything beyond the border 16 of those two facilities we term vicinity 17 properties. The term residential property, 18 that's categorized into the vicinity 19 property category. 20 Now, if there's anything good from 21 our standpoint as investigators, it's that 22 this material is easy to detect. We have 23 meters that we walk over the property and 24 it's easy to detect if there's an elevated

DEGNAN & BATBMAN, INC (609) 547-2565 19 EPA Public Hearing - 2/24/99

1 radiation level. So we did that on all of 2 the properties. And then if we found an 3 elevated radiation level we would go back 4 and take a radiological sample and send it 5 to the laboratory to confirm that it was 6 indeed due to thorium or radium. 7 On the industrial sites, given the 8 industrial nature of the property, we also 9 checked for chemical contaminants. One of 10 the focuses of our RI/FS report that we're 11 putting together is to come up with a cost 12 of how much it would cost to clean this 13 up. So we need a volume. So if there was 14 contamination, we had to know how deep the 15 contamination was. So we put in shallow or 16 deep borings, depending where we were. If 17 you notice, there's not a deep check mark 18 on the soil borings for the vicinity 19 properties. That's only because, in 20 general, the contamination was really on 21 the surface of the property. As Alan was 22 telling you, radon gas can get in a home so 23 we check for radon in any structure that 24 might have been on a property. And we also

DEGNAN & BATEMAN, INC. (609) 547-2565 500206 20 BPA Public Hearing - 2/24/99

1 did alrl-a/beta measurements for structural 2 material sampling. Because in some cases, 3 especially on the industrial properties, 4 the contamination wasn't always associated 5 with soil but the building material 6 itself. 7 Let me work you through this so you 8 can kind of understand the process. This 9 is an old picture of the Welsbach facility 10 which existed about, you know, the early 11 part of the century. Just to give you some 12 bearings here because I know it's not a 13 good picture. The Delaware River is on 14 top. You can see the smoke stack of that 15 facility. Kings Street is on the bottom. 16 This is Gloucester City. But if. you can 17 imagine, they made these gas mantles at the 18 beginning of the century. The hazards 19 associated with any materials having 20 radioactivity associated with it really 21 weren't known at that time. Things like 22 X-rays were just being discovered and 23 nuclear power -- things like that were 24 decades in the future yet to come.

DEGNAN & B A T E M A N, INC. (609) 547-2565 500207 21 EPA Public Hearing - 2/24/99

1 But as years went by and in the past 2 couple of decades, we became aware of the 3 hazards that could be associated with any 4 radioactive materials. And someone 5 prudently said we should go back to all of 6 these facilities that operated in the early 7 part of the century and check to see if 8 there were, indeed, some radioactive 9 materials associated with those 10 properties. 11 So if you could imagine, you had a 12 facility like this (indicating) and you had 13 this mound, basically, of sandy-like dirt 14 that was there and they processed the 15 thorium out of that sand. So what happened 16 is years later we go back to that property 17 to see if we can find anything. Of course, 18 the facility is gone by now. But the 19 circle showing where the facility used to 20 be, it's actually a large 52-acre sprawl at 21 this cargo area. 22 But if you could imagine, let's say, 23 if you had these large buildings, they 24 probably had large basements associated

DEGNAN & BATEMAN, INC. (609) 547-2565 500208 22 EPA Public Hearing - 2/24/99

1 with them. And they knocked down the 2 building, you would assume, and maybe put 3 them in those large basements and paved 4 over it. So the first thing we would do is 5 go over this entire property doing the 6 surface exposure rate we talked about to 7 look for elevated levels of gamma 8 radiation. And we did that over the course 9 of several weeks. And then we take that 10 information back with us to our office and 11 we have computer programs where we can look 12 at the data. 13 And we go back now, this is a bird's 14 eye view looking down at the facility, and 15 all the different colors are where we do 16 have elevated levels of radiation. So 17 clearly there was something and is 18 something on that property. We go back to 19 locations like this and take soil samples 20 to see that it is thorium causing the 21 elevated levels, and it is. And we do the 22 borings to see how deep it is to come up 23 with a volume. So that's really what goes 24 on at the Welsbach facility.

DE6NAN & BATEMAN, INC. (609) 547-2565 5Q0209 23 EPA Public Hearing - 2/24/99

1 To -jump a little closer to home here 2 in Camden, to tell you a little bit about 3 what we've done. This is the General Gas 4 Mantle facility. And as Rick told you, 5 it's boarded up now. And as Alan alluded 6 to, this material gives off radon gas. But 7 there's no ventilation in this building 8 because the windows are all boarded up. So 9 when we go in there to work in that 10 building, there are elevated levels of 11 radon levels. There is soil that is 12 contaminated under the building and 13 adjacent to the building. And it does come 14 out somewhat onto South Fourth Street, 15 along with the sidewalk and into the street 16 somewhat. 17 So that will eventually need to be 18 removed or remedied as Rick will talk 19 about. The building is vacant. There are 20 wood floors. Those woods floors as well 21 have some contamination associated with 22 it. So if this building were to be 23 demolished there may be a need to remove 24 those floors before any demolition takes

DEGNAN & B A T E M A N, INC. (609) 547-2565 500210 24 EPA Public Hearing - 2/24/99

1 place. 2 I just wanted to touch on this now 3 but Alan will come back and talk a little 4 bit more about risk. But when we do work 5 on properties like this, it's not like 6 we're all dressed up in special equipment. 7 He wear our regular work clothes and we 8 walk throughout the building with the 9 meters. A real hazard that's associated 10 with it, from our standpoint, is if we have 11 somebody fall through a floor while we're 12 in the building rather than the radiation 13 problem itself. But Alan will talk a 14 little bit more about risk. 15 We'll talk about the vicinity 16 properties now. One of the problems is 17 there is such a large geographical area 18 associated with this site where 19 contamination could end up. If we were to 20 have gone throughout the whole community 21 and start from scratch, it would have taken 22 us years to do this. But fortunately the 23 State and Fred's group, they were here 24 previously and they went through over a

DEGNAN & BATEMAN, INC. (609) 547-2565 500211 25 EPA Public Hearing - 2/24/99

1 thousand properties and investigated those 2 properties. 3 Now, when we started this project we 4 didn't want to go out and reinvestigate all 5 of these properties. We wanted to use the 6 State's data. But we had to be sure we 7 could use that data. So we went to 20 8 properties and we compared our data to the 9 State's data. And we agreed that we can 10 use the State's data to somewhat categorize 11 these properties. 12 We went through all of the State's 13 data and we categorized the properties 14 something like this. Ballpark thousand 15 properties that the State went to, 16 approximately half, 449, we don't see any 17 evidence that there's contamination 18 associated with those properties. Then we 19 have the category we call suspect 20 properties. It's a pretty large grey area 21 for us. What that category means is that 22 we're not 100 percent sure that they're 23 clean. We're not 100 percent sure that 24 they may be contaminated either. But we do

OEGNAN & BATEMAN, INC. (609) 547-2565 500212 26 EPA Public Hearing - 2/24/99

1 want to go back and test those properties. 2 If a property was simply adjacent to 3 contaminated property, we call that a 4 suspect property and we put it in this 5 category. If it had an elevated radon 6 level -- many homes in New Jersey have 7 elevated radon. But in this case we tend 8 to ask ourselves, is that due to normal 9 radiation associated with the soil or is it 10 due to the Welsbach facility. We're not 11 sure right now so we want to go back and 12 check. 13 There's radiation all over. It's a 14 natural thing and it ranges. There's an 15 average. It's high in locations and low in 16 others. In some cases you could live in a 17 brick home and the levels could be higher 18 than you normally expect. But we would put 19 it in this category. So there are 585 20 properties that we would want to go back to 21 now and kind of do additional testing 22 eventually and either move them over to the 23 clean category or if we needed to move them 24 to the contaminated properties category.

DEGNAN & B A T E M A N, INC. (609, 547-2565 27 BPA Public Hearing - 2/24/99

1 And then finally there's a category 2 where we have potentially contaminated -- 3 they are properties that, based on the data 4 we have available, the evidence suggests 5 that there is contamination on those 6 properties. And we used our investigation 7 from the 20 we went to to come up with a 8 volume of materials to estimate a cleanup 9 cost associated with the project. And Rick 10 will come back and talk a little bit more 11 about that in a couple of minutes, right 12 after Alan talks a little bit more about 13 health risks. 14 MR. FELLMAN: Before you can really 15 get a handle on the risk from exposure to 16 radiation, it's helpful, I think, to 17 understand that we live on a radioactive 18 planet. And as a result we're constantly 19 being exposed to natural sources of 20 background radiation. The items that are 21 listed on this table break down the 22 components of background radiation. 23 He are radiated from the atmosphere. 24 He receive radiation from natural levels of

DE6NAN & BATEMAN, INC. (609) 547-2565 500214 28 EPA Public Hearing - 2/24/99

1 radionuclide in soil and rock, many of the 2 same radionuclide that we have ^n the waste 3 stream at the Welsbach and General Gas 4 Mantle facilities; uranium, thorium, 5 radium. 6 Inhaled radioactivity, that 200 7 milligrams per year, is the average dose in 8 North America from radon gas. Any time you 9 put four walls and a ceiling together, 10 you're going to get some level of indoor 11 radon that's going to deliver a dose. And 12 the average radon level is about one to one 13 and a half pico Curies per liter there, and 14 that's going to give you your 200 15 milligrams. 16 Internal emitters is referring to the 17 various radionuclide that we store in our 18 body tissues. As a reflection of the fact 19 that there's radioactivity naturally in 20 soil, then when we grow fruit and 21 vegetables and all sorts of products, some 22 of that radioactivity is taken up and some 23 of it is ingested. There's natural 24 potassium which is an essential

DEGNAN & BATEMAN, INC. (609) 547-2565 500215 29 EPA Public Hearing - 2/24/99

1 micronutrient. We ingest potassium in lots 2 of different products. A small fraction of 3 that potassium is radioactive. 4 So we carry around these 5 radionuclide. We ingest them every day. 6 We excrete them every day. And as a result 7 of their being in our bodies, we're exposed 8 to a dose of about 40 millirem per year. 9 There's also a whole lot of 10 radioactivity in lots of different types of 11 consumer products. And as you read through 12 some of these, you can see that there's 13 quite a range. And I brought a couple of 14 items that add to those. 15 This is Norton salt substitute. If 16 you need to keep your sodium intake to a 17 minimum because of high blood pressure or a 18 cardiac problem, your doctor may suggest 19 that you use potassium chloride instead of 20 sodium chloride. And as I just said, some 21 potassium is radioactive. And there's no 22 way to separate out the radioactive 23 potassium from the nonradioactive 24 potassium.

DEGNAN & BATEMAN, INC. (609) 547-2565 500216 30 EPA Public Hearing - 2/24/99

1 This instrument is known as a pancake 2 detector. And as you can hear, from 3 natural sources it has a very low 4 efficiency, you'll get sporadic clicks. 5 When I hold the salt substitute up, you get 6 a slightly positive response and it's easy 7 to hear the difference. Again, that's 8 natural potassium in the salt substitute 9 that the detector can see. 10 Here is a smoke detector. Everybody 11 should have these in their home. And one 12 of the components of the smoke detector is 13 one micro Curies of Americium 241, a 14 man-made radionuclide. And when I hold 15 this meter up to the source, again you can 16 hear the instrument respond. 17 This is a piece of Piestawear(ph). 18 It's made in the Southwest, covered with a 19 glaze known as yellow cake. And that glaze 20 has a lot of natural uranium in it. 21 There's a lot of radioactivity here. There 22 are people who eat off of these and you'll 23 find these in antique shops, at antique 24 shows all around the country. So I can

DE6NAN & BATEMAN, INC. (609) 547-2565 500217 31 EPA Public Hearing - 2/24/99

1 either leave that here and radiate my 2 colleagues or move it back out of range a 3 little bit. 4 We're concerned about radiation dose 5 because radiation is a known carcinogen. 6 That is the only health affect that we need 7 concern ourselves with. There are no acute 8 short-term health problems associated with 9 exposure to radiation with the exception of 10 very, very high doses which are not 11 possible from environmental issues such as 12 what we have here. 13 So we're worried about cancer. We 14 know that people who have been exposed to 15 very high levels of radioactivity in those 16 populations, there is most definitely an 17 increase in the incidence of cancer. When 18 we set public health policy in this 19 country, we assume that there is a risk of 20 cancer when we're exposed to any dose of a 21 carcinogen, no matter how small. Now, the 22 fact of the matter is, when we look at the 23 scientific data, we don't really know if 24 that's true or not.

DEGNAN & BATEMAN, INC. (609) 547-2565 500218 32 EPA Public Hearing - 2/24/99

1 Because what we have here is, again, 2 what's known as a dose response curve or 3 dose response line. As the dose increases 4 -- so up here in this range (indicating) 5 we're looking at high doses such as the 6 Japanese who survived the atomic weapons 7 blast, groups of patients who were radiated 8 for various ailments in the '30s or '40s 9 before medical science realized that that 10 wasn't the way to go. The radium dial 11 painters who were basically ingesting 12 radium while they painted watch dials 13 during the 1920s. Several of them died 14 from acute illnesses but most of them 15 survived and went on to live 20, 30, 40, 50 16 years. And in that group there was 17 elevated cancers. So these are groups who 18 got very high doses and we know that the 19 incidence or cancer or the health effect or 20 risk was elevated. 21 Now we get down to the lower end of 22 the curve where I showed you, just a few 23 minutes ago, background radiation, that we 24 all get a couple hundred millirems per

DEGNAN & BATEMAN, INC. (609) 547-2565 500219 33 EPA Public Hearing - 2/24/99

1 year. So now we're down in this area of 2 the curve (indicating). And now we've got 3 this type of a waste stream where there may 4 be additional exposure on the magnitude 5 similar to what we're getting from 6 background. And what do we know about 7 that? 8 Well, we don't have any scientific 9 data that would show that people who are 10 exposed to these levels are actually going 11 to suffer increased numbers of cancer. We 12 don't know that. The scientific studies or 13 physical tests are not powerful enough to 14 discern that when we're talking about a 15 disease or group of disease that is 16 afflicting one out of every four Americans 17 to begin with. So you just can't measure 18 it at these low levels. This is what we 19 call an area of great uncertainty. 20 However, EPA's policy is to assume 21 that there is some risk at these low 22 levels. And when the risk that we 23 calculate based on the data that we 24 generate during our studies, when that is

OEGNAN & BATEMAN, INC. (609) 547-2565 500220 34 EPA Public Hearing - 2/24/99

1 placed in a risk assessment model and it 2 shows us a risk that's unacceptable 3 relative to the acceptable risk range that 4 EPA has established, EPA can then use that 5 information as the basis to go forward with 6 the cleanup. 7 And now I'll let Rick talk about 8 cleanup alternatives. 9 MR. ROBINSON: For the Welsbach/ 10 General Gas Mantle site we evaluated 11 cleanup alternatives for the three property 12 types we just discussed: The Welsbach 13 facility, the General Gas Mantle facility, 14 and for the vicinity properties. The three 15 alternatives that we looked at were the No 16 Action Alternative; an Engineering Controls 17 Alternative; and Excavation and Off-site 18 Disposal Alternative. 19 As part of the Superfund process, EPA 20 has to look at a cleanup based on a No 21 Action Alternative. What if we did 22 nothing, what would be the result? And 23 based on the risk assessment that Alan just 24 explained a little bit, we found that there

DEGNAN & BATEMAN, INC. (609) 547-2565 500221 35 EPA Public Hearing - 2/24/99

1 was a risk and, therefore, we were going to 2 take an action. And as a result, we're not 3 going to talk about no action anymore. 4 For the vicinity properties, the 5 Engineering Controls Alternative, it would 6 require outdoor gamma shields on 50 7 properties; indoor gamma shields on about 8 20 properties; and radon mitigation systems 9 on about 4 properties. And the excavation 10 and off-site disposal alternative, if any 11 property was found to have contamination 12 above our cleanup levels, we would take the 13 material off site for disposal, dig it up 14 and take it off site. 15 The Welsbach facility, again, the 16 Engineering Controls Alternative, we would 17 put outdoor gamma shields on the property. 18 We would have to have deed restrictions 19 limiting future site work. And we would 20 have to go back every five years to make 21 sure that the remedy would still be 22 effective. 23 For the excavation and off-site 24 disposal alternative for the Welsbach

OEGNAN & BATEMAN, INC. (609) 547-2565 36 EPA Public Hearing - 2/24/99

1 facility, again, we find the contamination 2 above our cleanup level so we would dig 3 that material up and send it off-site for 4 disposal. 5 For the General Gas Mantle facility, 6 Engineering Controls Alternative would 7 require outdoor gamma shields around the 8 outside of the building. We would have to 9 permanently board-shut the building. We 10 would have to have deed restrictions 11 limiting future access to the site. And we 12 would have to go back every five years to 13 make sure the remedy would still be 14 effective. 15 Then for the General Gas Mantle, the 16 excavation and off-site disposal 17 alternative, we have two operations. The 18 first option is we would take the building 19 down and dispose of the whole building as 20 contaminated material. The second option, 21 Option B is we would first try to 22 decontaminate the building, take the 23 radioactive material out of the building. 24 And that would reduce the volume of

DEGNAN & BATEMAN, INC. (609) 547-2565 500223 37 EPA Public Hearing - 2/24/99

1 materials that would have to be sent 2 off-site for disposal. 3 The alternatives of the engineering 4 controls, again, just to summarize, we 5 would have to have deed restrictions on the 6 property limiting future site work. The 7 State would have to be responsible for 8 enforcing those restrictions. And we would 9 have to go back every five years to make 10 sure it would still be effective. 11 For the excavation and off-site 12 disposal alternative, all of the 13 contamination above our cleanup standards 14 would be excavated and sent off-site for 15 disposal. And that would result in, again, 16 the contaminated materials being removed 17 from the site. Mobility of the 18 contaminants would be eliminated. And 19 there would be no significant institutional 20 controls remaining on the properties at 21 all. The properties would be safe for 22 future reuse and protective of human health 23 and environment. 24 Just to go over the summary of the

DEGNAN & BATEMAN, INC. <609) 547-2SS5 38 EPA Public Hearing - 2/24/99

1 costs, for the engineering controls for the 2 vicinity properties would be about a little 3 over $2 million. And for the excavation 4 and off-site disposal on the vicinity 5 properties, just over $13 million dollars. 6 For the former Welsbach facility, the 7 engineering controls just under $6 million 8 dollars. And for the excavation and 9 off-site disposal alternative, eighteen and 10 a half million dollars. 11 For the General Gas Mantle facility, 12 the engineering controls is just under 13 $400,000. And the excavation and just the 14 demolition and disposal alternative option, 15 just over $2 million dollars. And for the 16 decontamination and demolition, just under 17 $2 million dollars. 18 EPA1s preferred remedy action is the 19 excavation and off-site disposal 20 alternative for both the vicinity 21 properties, Welsbach and General Gas Mantle 22 facility. For the General Gas Mantle we 23 have Option B, which is the decontamination 24 of the building prior to demolition. The

DEGNAN & BATEMAN, INC. (609) 547-2565 500225 39 EPA Public Hearing - 2/24/99

1 total cost of the remedy is just under $34 2 million dollars. 3 Now we go to what do we next, the 4 next steps. The first thing that we're 5 doing right now is respond to public 6 comment. We're here today to take your 7 verbal comments. And also, again we have a 8 public comment period for written comments 9 which ends next Wednesday, March 3. And we 10 invite the public to send in written 11 comments as well as your comments today. 12 Once we receive all of the comments, 13 we select a remedy in a document called a 14 Record of Decision (ROD). And once we sign 15 that ROD, EPA can start the design of the 16 cleanup. 17 Our focus will be first on the 18 residential properties and then we'll go to 19 the commercial and industrial properties. 20 We hope to start the investigations on the 21 suspect properties in the fall, later this 22 year, and also start the design 23 investigations on the potentially 24 contaminated properties this year also.

DEGNAN & BATEMAN, INC. (609) 547-2565 500226 40 EPA Public Hearing - 2/24/99

1 And we also plan to demolish the General 2 Gas Mantle building as soon as we can, 3 hopefully in one to two years. 4 This actual cleanup on these 5 individual properties we estimate about 6 three to five years from today. We're also 7 in the process right now of conducting a 8 ground water investigation to make sure 9 that none of the contamination from the 10 site is getting into the ground water. And 11 we also have to investigate some wetland 12 areas in Gloucester City around Newton 13 Creek that are next to some of the known 14 contaminated areas. 15 16 17 18 19

DEGNAN & BATEMAN, INC. (609) 547-2565 500227 41 EPA Public Hearing - 2/24/99

1 MR. ROBINSON: Now we'd like to open 2 the meeting up for some comments and 3 questions. 4 MS. CERVANTES-GROSS: If you have any 5 questions about what we discussed tonight. 6 MR. ROBINSON: Please state your name 7 for the record.

8 DONNA MAGGIO(PH) (INAUDIBLE): I have 9 a question with the houses on Arlington 10 Street. When you say you're going to 11 excavate the back yard, how deep is it 12 going to go and what's going to be done for 13 the people while you're doing this? Will 14 this pose any problems for people? What 15 are you going to do to protect them? 16 MR. ROBINSON: Right now on Arlington 17 Street we have not done any volume samples 18 or estimate of the depth of contamination 19 on Arlington Street. That will be done in 20 the design phase. We estimate right now, 21 by what we've seen on other properties that 22 are similar to contamination there, the 23 contamination is about one to two feet. 24 Generally we try to work around the

DBGNAN & BATEMAN, INC. (609) 547-2565 500228 42 EPA Public Hearing - 2/24/99

1 residents and make sure that they're not 2 severely impacted by the work. 3 DONNA MAGGIO: This doesn't pose any 4 sort of a problem, digging up? 5 MR. ROBINSON: We're going to try to 6 minimize any potential impacts through 7 controls during our construction phase. 8 MR. FELLMAN: The impacts are 9 (INAUDIBLE). They are not health related. 10 DONNA MAGGIO: That's what I'm 11 wondering. 12 MR. FELLMAN: when these things are 13 removed, it's done in a controlled way so 14 that dust is minimized. If necessary, soil 15 is wet before taking it off. Before things 16 are sent out., say, in a truck to travel 17 over public roads, the trucks are scanned 18 and the wheels. This is all done in a very 19 prescribed manner so that contamination is 20 not spread. 21 DONNA MAGGIO: Is there a work plan, 22 a document, yet? 23 MR. ROBINSON: When we go to 24 construction, after we've completed the

DEGNAN & BATEMAN, INC. (609) 547-2565 500229 43 EPA Public Hearing - 2/24/99

1 remedial design, we'll have another meeting 2 prior to the actual demolition or the 3 construction activities. We'll present to 4 you our plan on how we're going to proceed 5 with that phase, the action. 6 MR. EVANGELISTA: We'll intend to 7 make these plans available in repositories 8 for review. 9 DONNA MAGGIO: I have a question as 10 far as the radon in the basements. Are you 11 going to check for radon in the basements? 12 MR. FELLMAN: Well, that's part of 13 the study protocol when we go to any of the 14 suspect properties. The properties that 15 we've been to through the remedial 16 investigation, we scan for gamma radiation 17 indoors and outdoors. We take soil 18 samples, put holes in the ground and take 19 down hole measures, and put radon detectors 20 in the basements and measure for radon. 21 That's typically part of the protocol. 22 The reason why there have been so few 23 properties or structures with elevated 24 radon out of the many properties

DEGNAN & BATBMAN, INC. (609) 547-2565 500230 44 SPA Public Rearing - 2/24/99

1 investigated here is because most of the 2 contamination, where it exists, is out in 3 the yard somewhere as opposed to being 4 adjacent to or underneath the house. If 5 you have — like on Arlington Street where 6 that kind of strip of contamination is 7 toward the rear of the property, closer to 8 the alleyway, the radon gas that was formed 9 in that material is emanating up into the 10 outdoor atmosphere as opposed to if that 11 material was underneath the homes emanating 12 up and would be intercepted by a house and 13 get into the basement. That's when you get 14 the higher level or volume of this stuff. 15 MS. PULLMAN(ph): My name is Olga Pullman. 16 I'd like to first of all say, great, BPA 17 has selected the most thorough cleanup 18 alternative of the three products. I think 19 that's very important for the health and 20 safety of the residents and also the future 21 of this neighborhood. 22 I was just wondering, to make it 23 clear in my own mind what you're saying, 24 the level of cleanup is going to be to

DBGNAN & BATBMAN, INC. (609) 547-2565 500231 45 EPA Public Hearing - 2/24/99

1 remove anything contaminated and bring in 2 fresh fill for any empty areas? And it's 3 your position that after that, that land 4 could be used for anything, residential, 5 playgrounds, parks, vegetable gardens, that 6 level of cleanup?

7 MR. ROBINSON: Yes. 8 MS. PULLMAN: Is that definite? The 9 money has been approved for that project? 10 MR. ROBINSON: Before we can actually 11 get any money for a cleanup we have to go 12 through a design. Once we get the design 13 altogether, we'll be going out to request 14 money from EPA headquarters for the 15 project. Until we complete the -- we're 16 still three to five years away from that. 17 As you see from our presentation, there's a 18 lot of things we have to look at to gather 19 information together.

20 MR. EVANGELISTA: I just wanted to 21 add that behind the scenes that's what's 22 known as Record Review Board. And what we 23 did before we identified our preferred 24 alternative and the projected cost estimate

DE6NAN & BATEMAN, INC. (609) 547-2565 500232 46 KPA Public Hearing - 2/24/99

1 is we took the site and all of the 2 information before this Board within EPA 3 which consists of representation throughout 4 the country. And they gave us a nod of 5 approval that they're okay with the costs 6 associated with it. We don't anticipate 7 any problems in funding the project in the 8 anticipated time frame. 9 MS. PULLMAN: In terms of checking 10 property, I happen to notice where the 11 Arlington Street property is located, the 12 General Gas Mantle, you haven't yet checked 13 the properties on the other side that's not 14 shown on the map, kind of adjacent to it 15 heading north. Is that something you're 16 going to include in this investigation? 17 MR. KBRBBL: That sounds like data 18 the State collected, but we didn't in the 19 last year go into these properties. 20 MR. ROBINSON: Those maps were 21 generated or based on information that the 22 State provided to EPA. As part of our 23 investigation and our next phase in the 24 design, we're going to look at the

DBGNAN & BATBMAN, INC. (609) 547-2565 500233 47 EPA Public Hearing - 2/24/99

1 properties adjacent to known contaminated 2 or potentially contaminated properties. 3 And we'll look at those properties and add 4 them on. In future maps they'll include 5 other properties that the State has not

6 (INAUDIBLE). 7 DONNA MAGGIO: I just had a question 8 with the time frame. So you think you 9 could demolish the General Gas Mantle 10 within one to three years? 11 MR. ROBINSON: One to two years.

12 DONNA MAGGIO: From now? 13 MR. ROBINSON: Yes. We're hoping 14 sooner. As soon as we get the remedy 15 approved the sooner we'll start the process 16 of taking the building down. 17 MS. PULLMAN: What's going to be your 18 next series of steps when you're going to 19 inform the community about what's going 20 on? 21 MR. ROBINSON: Once we select the 22 remedy and the Record of Decision -- and in 23 the Record of Decision will be all your 24 verbal responses today, that's why we have

DEGNAN & BATEMAN, INC. (609) 547-2565 500234 48 BPA Public Hearing - 2/24/99

1 the court reporter here, and any written 2 comments submitted -- that will be in the 3 responsiveness summary attached to the 4 Record of Decision. Once we sign the 5 Record of Decision we'll place that 6 document in the local repositories: One in 7 Camden's main library, one in Gloucester 8 City's public library, and in the Hynes 9 Center of Camden. The next public meeting 10 we'll have is when we're ready to start the 11 construction, most likely the General Gas 12 Mantle demolition, hopefully later this 13 year. If we could move the people along. 14 MR. BVANGELISTA: "People11 meaning 15 BPA management. 16 MS. PULLMAN: So, of course, you'd 17 let us know if something were to happen. 18 If you discover that the scope of work was 19 greater than you thought and you had to 20 reconsider your plans, at what point would 21 you let the community know that, before you 22 make the final Record of Decision? 23 MR. EVANGELISTA: At this point we 24 don't anticipate reconsidering anything as

DBGNAN & BATSMAN, INC. (609) 547-2565 500235 49 EPA Public Hearing - 2/24/99

1 far as what we've proposed in the proposed 2 plan or discussed this evening. The only 3 way that we would reconsider anything would 4 be based on public comment. And based on 5 what we've seen and heard thus far, both 6 here and in Gloucester City, there's 7 nothing indicative of our changing our 8 minds. 9 MR. ROBINSON: Everyone is in favor 10 of us digging the material up and taking it 11 off-site.

12 MS. PULLMAN: Good. 13 MS. CERVANTES-GROSS: In addition, as 14 we pointed out, there are still 500-some 15 properties that we consider as suspect * 16 properties. So in the design -- as we go 17 through the design phase, there will be 18 additional investigation of those 19 properties, to include those properties in 20 what we're proposing. Once we go out there 21 to confirm if they have elevated levels 22 above our cleanup levels, those properties 23 would be included in -- most of the 24 vicinity properties.

DEGNAN & BATEMAN, INC. (609) 547-2565 500236 50 EPA Public Hearing - 2/24/99

1 MR. FELLMAN: Fed into the design 2 process that will be ongoing and current. 3 MR. KBRBEL: There's a lot of 4 variability when we say contaminated 5 properties. It could range from just a 6 small spot where somebody might have to 7 almost come in with a shovel and put it in 8 a barrel and get it off; to maybe a backhoe 9 might have to come in and scrape the top 10 off. So there's a lot of variability. 11 MS. PULLMAN: I just realized at this 12 point you can't say exactly how many 13 properties you're going to have to do 14 cleanup and what level it will be. I'm 15 just being paranoid here. At any point you 16 could reconsider the plan if you rediscover 17 it's a greater scope of work or whatever.

18 MR. ROBINSON: NO. If we find 19 contamination it will be taken away.

20 MS. PULLMAN: All right. 21 MS. CERVANTES-GROSS: Any Other 22 questions or comments? 23 Okay. I that's it. 24 MR. ROBINSON: Thank you very much

DBGNAN & BATBMAN, INC. (609) 547-2565 500237 51 EPA Public Hearing - 2/24/99

1 for attending and hopefully we'll see you 2 soon with the progress of taking the 3 building down. 4 MR. EVANGELISTA: There are some 5 handouts that are on the table and you're 6 welcomed to take a copy. 7 ********

OE6NAN & BATEMAN, INC. (609) 547-2565 500238 52

1 CERTIFICATE

23 24 Dated: March 4, 1998

500239 DB6NAN & BATEMAN, INC. (609) 547-2565 '""" . LindaA-Burns Notary Pubhc Mv Commission T>.r,3.