SDMS Document VIIIIIIIIIIIIHIIIilH
109850
RECORD OF DECISION
Welsbach/General Gas Mantle Contamination Site
Gloucester City & Camden, Camden County, New Jersey
Operable Unit No. 3 Surface Water, Sediment, and Wetland Areas
United States Environmental Protection Agency Region 2 New York, New York
September 2005
500001 DECLARATION STATEMENT RECORD OF DECISION
SITE NAME AND LOCATION
Welsbach and General Gas Mantle Contamination Site (EPA ID# NJD986620995) Camden and Gloucester City, Camden County, New Jersey Operable Unit 3
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected no action remedy for the surface water, sediment, and wetland areas in the Welsbach and General Gas Mantle Contamination site (Welsbach Site) study area in Camden and Gloucester City, New Jersey. This remedy was chosen in accordance with the Comprehensive Envirormiental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the Administrative Record file for this site. The State of New Jersey concurs with the selected no action remedy.
DESCRIPTION OF SELECTED REMEDY
The selected no action remedy described in this docimient applies to the third of foiu- plaimed operable tmits for the Welsbach Site. The U.S. Enviroimiental Protection Agency (EPA), in consultation with the State of New Jersey, has determined that no site-related contaminants of potential concem are present at elevated levels in the surface water, sediment, and wetland areas in the Welsbach Site study area. Therefore, no remedial action is warranted, because there is no radiological contamination in the surface water, sediment, and wetland areas in the Welsbach Site study area that poses an unacceptable risk to human health or the environment.
On July 23, 1999, EPA, with support from New Jersey Department of Environmental Protection (NJDEP) selected a remedy for Operable Unit 1 (GUI) at the Welsbach Site, and identified three additional planned operable imits. The QUI remedy included demolition of the former General Gas Mantle Company (GGM) building; excavation of the radiologically contaminated soil and debris at the residential, commercial, and industrial properties at the Welsbach Site; and disposal of this material at a licensed off-site facility. Additional operable units will address potential remedies for the former Welsbach-era building knovsTi as the Armstrong Building (Operable Unit 2), and the groimdwater (Operable Unit 4).
DECLARATION OF STATUTORY DETERMINATIONS
In accordance with the requirements of CERCLA and the NCP, EPA has determined that no remedial action is necessary for the third operable unit (0U3) of the Welsbach Site to ensure protection of human health and the environment.
500002 The primary contaminants at the Welsbach Site are radionuclides in the thorium and uraniimi decay chains and their decay products. Although the levels of some chemical contaminants of potential concem exceeded the ecological guidelines and human health risk levels in the surface water, sediment, and wetland areas in the Welsbach Site study area, these chemical contaminants are not related to operations associated with the Welsbach Company or the GrGM Company.
EPA is aware that NJDEP periodically collects samples of edible fish and shellfish in water bodies throughout the state. NJDEP has fotmd elevated levels of merciuy, dioxins, and polychlorinated biphenyls (PCBs) in its Delaware River samples. Furthermore, NJDEP established fish consumption advisories to address the elevated levels of PCBs and other chemical contaminants in fish from the Delaware River and its tributaries. EPA recommends that people fishing in the area follow the appropriate fish consiunption advisories.
Mr 4W25 George Paviou, Director Date Emergency and Remedial Response Division
500003 DECISION SUMMARY
Welsbach/General Gas Mantle Contamination Site
Gloucester City & Camden, Camden County, New Jersey
Operable Unit No. 3 Surface Water, Sediment, and Wetland Areas
United States Environmental Protection Agency Region 2 New York, New York
September 2005
500004 TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION,
SITE HISTORY AND ENFORCEMENT ACTIVITIES.
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 4
SITE CHARACTERISTICS..... 4
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCES USES 7
SITE RISKS 7
STATE ACCEPTANCE. 15
DOCUMENTATION OF SIGNIFICANT CHANGES 15
APPENDICES
APPENDIX I FIGURES APPENDIX II TABLES APPENDIX m ADMINISTRATIVE RECORD INDEX APPENDIX IV RESPONSIVENESS SUMMARY APPENDIX V STATE CONCURRANCE
500005 SITE NAME, LOCATION, AND DESCRIPTION
The Welsbach/General Gas Mantle Contamination site (Welsbach Site) is a multi-property site centered aroimd two former thoritim gas mantle manufacturing companies in the cities of Gloucester City and Camden, New Jersey. Approximately 100 residential, commercial, and industrial properties make up the Welsbach Site. The Delaware River, Newton Creek, and Martins Lake are adjacent to some of these radiologically contaminated properties. This Record of Decision (ROD) addresses surface water, sediment and wetland areas associated with these water bodies in the Welsbach Site study area.
The U.S. Enviroimiental Protection Agency (EPA) has divided the Welsbach Site into four separate cleanup phases, or operable units. On July 23,1999, EPA, with support from the New Jersey Department of Environmental Protection (NJDEP) selected a remedy for the radiologically cpntaminated soils at the Welsbach Site. The remedy for this first Operable Unit 1 (OUl) included demolition of the former General Gas Mantle Company (GGM) building, excavation of the radiologically contaminated soil and debris at the residential, commercial, and industrial properties at the Welsbach Site, and disposal of this material at a licensed off-site facility. The third Operable Unit 3 (0U3) includes the surface water, sediment and wetland areas in the Welsbach Site study area. Additional operable units will address potential remedies for the former Welsbach-era building known as the Armstrong Building (Operable Unit 2), and the groimdwater (Operable Unit 4).
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site Background
Between the 1890s and 1940s, the Welsbach Company (Welsbach) manufactured gas mantles at its facility in Gloucester City, New Jersey. Welsbach was a major manufacturer and distributor of gas mantles vmtil the electric hght replaced gas hghting. Beginning aroimd 1895, Welsbach imported monazite ore to use as its source of the radioactive element thorium. Welsbach extracted thorium from the ore and used it in its gas mantle manufacturing process. Thorium causes the mantles to glow more brightly when heated. Just after the turn of the century, Welsbach was the largest producer of gas mantles and lamps in the United States, making up to 250,000 mantles per day. Welsbach went out of business in 1940.
A second gas mantle manufacturing company, GGM, located in Camden, New Jersey, was a small competitor to the Welsbach Company. GGM operated from 1912 to 1941. There is little information on its iactivities. It appears that GGM only used refined thorium in its gas mantle manufacturing processes.
EPA initially identified the Welsbach Site in 1980 during an archive search conducted as part of an investigation of the U.S. Radium Corporation Superfimd site located in Orange, New Jersey. Historical U.S. Radium Corporation files indicated that U.S. Radium purchased radiological materials from Welsbach during the 1920s. In May 1981, EPA sponsored an aerial radiological survey of the Camden and Gloucester City area. The survey covered a 20-square-kilometer area surrounding the locations of the former Welsbach and GGM facilities. NJDEP evaluated the data from the aerial survey and identified five areas with elevated gamma radiation levels. The
500006 elevated areas 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 re-analyzed the data from the aerial survey, which subsequently led to the identification of a sixth area, located in Gloucester City, with elevated gamma radiation levels (See Figure 1.)
A description of each Study Area follows:
• Study Area 1 - includes the former GGM facihty and residential and commercial properties that surround the facihty. The former GGM facihty is located in a mixed industrial, commercial, and residential section of Camden.
• Studv Area 2 - includes the location of the former Welsbach facihty and nearby residential/commercial properties. The former Welsbach facility is located in an industrially zoned section of Gloucester City with residential properties immediately to the east. An original Welsbach building, the Aimsfrong building, is still present on the property.
• Study Area 3 - includes residential and recreational properties in Gloucester City, including the Gloucester City Swim Club and the Johnson Boulevard Land Preserve.
• Study Area 4 - includes residential properties in the Fairview section of Camden.
• Studv Area 5 - includes residential properties, vacant land, and two municipal parks near Temple Avenue and the South Branch of Newton Creek in Gloucester City.
• Study Area 6 - includes vacant lots in a residentially zoned area of Gloucester City.
• Surface Water, Sediment and Wetland Investigation Areas - EPA conducted the investigation of surface waters, sediments and wetlands in Study Areas 1,2, 3, 5, and 6 of the Welsbach Site. EPA did not include Study Area 4 in this investigation because the soil contamination in this area is in very small and isolated locations.
In the early 1990s, NJDEP conducted follow-up radiological investigations at more than 1,000 properties located throughout the original five Study Areas. During these investigations, NJDEP identified radiological contamination at the two former gas mantle facilities and at residential, commercial, and industrial properties located near the two facihties. Based on these data, NJDEP conducted some interim remedial measures which included installing concrete, steel, and/or soil shielding inside homes and yards, installing radon mitigation systems at selected properties, and relocating one resident and one business.
In March 1995, EPA prepared a Hazard Ranking System (HRS) report for the Site, and in June 1996, EPA placed the Welsbach Site on the National Priorities List (NPL). EPA, as the lead agency, prepared this decision document with support from NJDEP. Site-related activities are being federally fimded.
From September 1997 to January 1999, EPA conducted a remedial investigation and feasibility study (RI/FS) to investigate the radiological contamination at a number of residential and 500007 industrial properties at the Welsbach Site. On July 23,1999, EPA signed a ROD for OUl (1999 ROD). EPA stated in the 1999 ROD that it would address the potential site impacts to surface water, sediment, and wetland areas in the fiiture.
In April 2001, EPA started the surface water, sediment, and wetland investigation called for in the 1999 ROD. The results of this study can be found in the Screening Level Ecological Risk Assessment Report (March 2002). In January 2005, EPA used sediment data from the surface water, sediment, and wetland investigation to evaluate the baseline human health risk from radionuclides and chemicals of potential concem (Human Health Risk Assessment Addendum, January 2005).
As part of the design investigations for OUl, EPA has investigated nearly 1,000 properties in the Camden and Gloucester City area. Based on information from this investigation, EPA has identified approximately 100 residential, commercial, and industrial properties with elevated radionuchde levels. EPA has completed cleanup activities on over 15 residential properties, a portion of the Gloucester City Swim Club, and the Popcorn Factory property in Study Area 6. At present, EPA is continuing its cleanup efforts on other residential properties in the Gloucester City and Camden area.
Enforcement History
Both Welsbach and GGM went out of business in the early 1940s. To date, EPA has been unable to identify any successor companies.
In September 1997, Holt Hauling and Warehousing, Inc. (Holt), which owned the former Welsbach property at that time, entered into an Adminisfrative Order on Consent (AOC) with EPA. Under the terms of the AOC, Holt agreed to perform an RI/FS on the Aimsfrong Building (the one remaining original Welsbach building). In January 2000, Holt submitted the RI/FS Report for EPA review and approval. Holt's RI/FS identified sporadic radiological contamination on the structural surfaces inside the building. In July 2000, EPA approved Holt's RI/FS Report, and will select a remedy for the Aimsfrong Building in the fiiturebase d on information obtained from Holt's RI/FS.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA has worked closely with public officials and other interested members of the Gloucester City and Camden communities. Their participation and contributions to the site investigation and remediation process have benefited and continue to benefit the Agency in achieving its goal of effectively protecting human health and the environment.
The Proposed Plan and supporting documentation were released to the public for comment on May 24,2005. These documents were made available to the public at:
• The EPA Adminisfrative Record File Room, 290 Broadway, 18th Floor, New York, New York 10007.
• City of Camden Main Library, 418 Federal Sfreet, Camden, New Jersey 08103.
3 500008 • The Hynes Center, 1855 South 4th Sfreet, Camden, New Jersey 80104.
• The Gloucester City Pubhc Library, Monmouth and Hudson Sfreets, Gloucester City, New Jersey 08030.
The initial pubhc comment period was held from May 24 through June 23, 2005. However, at the request of the NJDEP, EPA extended the public comment period to August 2, 2005. Notices of availability for the documents in the adminisfrative record were published in the Courier-Post on May 24, 2005, and July 25,2005. EPA held two public meetings to present the preferred no action remedy for 0U3. The first meeting was held on June 8,2005, at the Welsbach Field Office, and the second meeting was held on July 26, 2005, at the Camden County Municipal Utilities Authority. The purpose of these meetings was to inform local officials and interested citizens about the Superfimd process, to discuss the Proposed Plan and receive comments on the Proposed Plan, and to respond to questions from area residents and other interested parties. Responses to the comments received at the pubhc meetings and in writing during the pubhc comment period are included in the Responsiveness Summary, attached as Appendix FV to this ROD. SCOPE AND ROLE OF OPERABLE UNIT
The decision described in this document relates to the third of four planned operable units at the Welsbach Site. The July 1999 ROD addressed OUl, and specified the demolition of the foimer GGM building, excavation of the radiologically contaminated soil and debris at the residential, commercial, and industrial properties at the Welsbach Site, and disposal of this material in a hcensed off-site facility.
This ROD addresses 0U3, the surface water, sediment, and wetland areas in the Welsbach Site study area. Based on the findings in the Screening Level Ecological Risk Assessment and the baseline Hiunan Health Risk Assessment Addendum reports, the surface water, sediment and wetland areas do not pose an unacceptable risk to human health or the environment for site- related contaminants. Additional operable units will address potential remedies for the former Welsbach-era building known as the Armsfrong Building (0U2), and the groundwater (0U4).
SITE CHARACTERISTICS
As discussed above, the Welsbach Site is a multi-property site that is centered around two former thorium gas mantle manufacturing companies, Welsbach, located in Gloucester City, and GGM, located in Camden. According to the 2000 census data, approximately 11,500 and 79,900 people live in the cities of Gloucester City and Camden, respectively.
Site Area Drainage
The Welsbach Site is located on the westem edge of the Atlantic Coastal Plain in New Jersey in the Delaware River drainage basin. Drainage from the six Study Areas flows into the following water bodies: Newton Creek, including its North and South Branches, the Delaware River, and Martins Lake. The three forks of Newton Creek ultimately flow into the Delaware River. Martins Lake is an isolated water body about a third of an acre in size located in Study Area 5.
. 500009 Newton Creek and its South Branch generally flow west-northwest, and the Delaware River generally flows south. These surface waters are tidal.
In Study Area 1, runoff water from rain events flows into the Delaware River though the municipal storm sewer system. In the basement of the former GGM building, there were underground drains that connected to the municipal storm sewer system.
In Study Area 2, runoff from the residential site properties and a portion of the former Welsbach property flows into the Delaware River through municipal storm sewers. The remainder of the overland runoff of water from the former Welsbach property is comprised of sheet flow (runoff that does not follow a defined chaimel) that flows directly into the Delaware River or Newton Creek.
In Study Area 3, runoff flows into Newton Creek through municipal storm sewers or as sheet flow.
In Study Area 4, runoff flows into either Newton Creek or the North Branch Newton Creek. The runoff from the residential site properties flows into the creeks through municipal storm sewers. Because the radiological contamination in this Study Area is located in very small isolated areas, the water bodies with runoff from this Study Area were not included in the ecological assessment.
In Study Area 5, runoff flows into either the South Branch Newton Creek or Martins Lake. Runoff flows into Newton Creek either through municipal storm sewers or as sheet flow along the surface. A portion of the overland flow from Martins Lake Park empties into Martins Lake.
In Study Area 6, runoff flows into either the Delaware River or Little Timber Creek through storm sewers or as sheet flow.
Surface Water, Sediment, and Wetland Investigation
In April and May 2001, EPA conducted a surface water, sediment, and wetland investigation in five of the six Study Areas in the Welsbach Site study area. The main objectives of this investigation were:
• To determine the presence or absence of radiological contamination in the bottom sediments of the water bodies where on-shore deposits of site-related radiologically contaminated materials were known or suspected.
• To prepare a screening level ecological risk assessment for the radiological and chemical contaminants of potential concem.
• To assess baseline risk to human health and the enviromnent from radionuclides in the surface water, sediment, and wetland areas.
• To provide sufficient data to make either a "no further action" recommendation or recommendations for fiirther studies.
5 500010 EPA conducted the investigation of surface waters, sediments and wetlands in Study Areas 1,2, 3, 5, and 6 of the Welsbach Site. EPA did not include Study Area 4 in this investigation because the soil contamination is in very small and isolated areas.
The investigation included collecting sediment samples and measuring the water quality in Newton Creek, the South Branch Newton Creek, Martin's Lake, and several storm water outfalls in South Branch Newton Creek and the Delaware River. EPA collected 154 sediment samples and 82 water quality measurements. Both radiological and chemical data were collected. EPA collected samples from seven sampling area fransects and 10 storm water outfall locations (See Figure 2).
Since the radionuclides of potential concem also occur naturally, EPA collected ten backgroimd sediment samples from five locations upsfream of the Welsbach Site in Newton Creek and South Branch Newton Creek, as well as in North Branch Newton Creek, Little Timber Creek and Miller's Lake (See Figure 3).
Investigation Results
For the radionuclides of potential concem, the radionuchde concenfrations in the sediments were, on average, equal to levels found in uncontaminated areas in the vicinity of the Welsbach Site (background levels). The average radionuchde concenfrations for thorium and radium in both the sediment and background samples were less than 1.2 picoCuries per gram (pCi/g.)
EPA used the data from the ecological investigation to develop the human health and the screening level ecological risk assessments for 0U3, as described below. Because the data requirements for each of these risk assessments were different, EPA separated the results of the investigation. Table 1.1 presents a summary of the sampling results for the human health risk assessment and Table 5 presents a summary of the sampling results for the screening-level ecological risk assessment.
At all of the sediment sampling locations, EPA detected non-radiological chemical constituents that exceeded the maximum background concenfrations and sediment screening guidelines. These chemicals consisted primarily of polycyclic aromatic hydrocarbons (PAHs), pesticides, and PCBs. However, these chemicals are not site-related. Neither Welsbach nor GGM used these chemicals in their manufacturing processes. In addition, many of these chemicals (e.g., PCBs) were not in common use until after both companies went out of business.
As part of a statewide program, NJDEP periodically collects samples of edible fish and shellfish in water bodies throughout the state. NJDEP found elevated levels of mercury, dioxins, and PCBs in its Delaware River samples. As a result, NJDEP issued fish consumption advisories for fish and shellfish from the Delaware River in the area of the Welsbach Site. This advisory is based on concenfrations of mercury, dioxins, and PCBs in fish. Furthermore, NJDEP has issued a prohibition on fish consumption from the Delaware River and its tributaries in the area of the Welsbach Site because of possible Escherichia coli {E.coli) bacterial contamination. Many of the sewer pipes in the area are combined sewer and storm water, with the overflows going directly to the local water bodies. 500011 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCES USES
The Welsbach 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 foimer 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 entfrely of residential properties. Residential properties and two municipal parks comprise Study Area 5. Study Area 6 consists of residential properties and vacant land in a residential area. The Gloucester City Board of Education planned to build a new middle school on the vacant land in the area, including the former Popcom Factory parcel.
No significant changes in land use are anticipated, except in the area of the former GGM facility where some residential areas may be rezoned for commercial uses. The former GGM facihty was bordered by residential homes located on Arlington Sfreet in Camden. At the time of the 1999 ROD, most of the homes on Arlington Sfreet were abandoned and there was 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. In 2004, the City of Camden demolished the homes on Arlington Sfreet to make way for fiiture commercial use of the property. EPA removed the radiological soil contamination adjacent to the homes and alleyways, removed the building foundations, and backfilled the area with clean fill.
The State of New Jersey classifies Newton Creek and the South Branch Newton Creek as "fresh water - non-frout" (FW2-NT). The State has also classified Martins Lake as FW2-NT. The FW2-NT water classification refers to fresh waters that are generally not suitable for front because of the waters' physical, chemical or biological characteristics, but are suitable for a wide variety of other fish species. Designated uses of FW2-NT waters include: maintenance, migration, and propagation of the natural and estabhshed plant and animal life; primary and secondary contact recreation; industrial and agricultural water supply, and public potable water supply after freatment.
The State of New Jersey classifies the portion of the Delaware River adjacent to Study Area 2 as "Zone 3." Designated uses for Zone 3 include agricultural, industrial and pubhc water supply after freatment; maintenance of resident fish and other aquatic life; migration offish; secondary contact recreation; and navigation. EPA anticipates no significant changes to the classifications of the Delaware River, Newton Creek or Martins Lake.
SITE RISKS
As part of the risk assessment process, EPA looks at the risks posed by a site to both human health and the environment. EPA's risk assessment guidance calls for EPA to consider risk from all radiological and other chemical contaminants of potential concem regardless of whether they are site related. Based on the sediment sampling data from the surface water, sediment, and wetland areas in the Welsbach Site study area, EPA conducted both baseline human health and screening level ecological risk assessments.
n 500012 1999 ROD Human Health Risk Assessment
In the 1999 RI/FS, EPA assessed the potential risk to human health from the radiological contamination in soil at the Welsbach Site. The exposure pathways EPA considered were exposure to extemal gamma radiation and the inhalation and ingestion of radionuclides. The potential receptors of concem were workers, frespassers, and resident adults and children. EPA found that there was unacceptable risk to human health for each of the potential receptors of concem for all of the exposure pathways.
In the 1999 ROD, EPA addressed these risks to human health by selecting a remedy to remove the radiologically contaminated soil and dispose of it at an off-site, licensed facihty. The 1999 ROD also recommended that EPA evaluate current and potential future risk to human health and the envfronment from radionuchdes in surface water, sediment, and wetland areas at a later date.
OU3 Risk Assessment
As discussed above, EPA detected non-radiological chemical constituents in the sediments that exceeded the maximum background concenfrations and sediment screening guidelines. However, EPA determined that these chemicals are not related to the operations of Welsbach or GGM. Since radionuclides are the only site-related constituents foimd in the soils in the Welsbach Site study area, only radiological risks are discussed in the following sections.
Summary of Baseline Human Health Risk Assessment
The baseline human health risk assessment evaluated both current and fiiture cancer risks to young children (0 to 6 years), adolescents (10 to 18 years old), and adults (19 years and older) in the absence of any remedial action and institutional confrols. EPA developed the human health risk assessment using current EPA policy and guidance. A detailed discussion of the data collected and analyzed in this assessment can be found in the Human Health Evaluation: Chemical and Radiological Contaminants in the Delaware River, Newton Creek, and Martin's Lake - Addendum to the Draft Final Remedial Investigation/Feasibility Study Report, January 1999 (Malcolm Pimie, 2005) and the Screening Level Ecological Risk Assessment (March 2002).
EPA uses a four-step process for assessing quantitative human health cancer risks for a reasonable maximum exposure (RME) scenario:
• Data Evaluation or Hazard Identification - identifies the contaminants of potential concem at the site based on several factors such as toxicity, frequency of occuirence, and concenfration.
• Exposure Assessment - estimates the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and the pathways (e.g., ingesting contaminated fish) by which humans are potentially exposed.
500013 • Toxicity Assessment - determines the types of adverse health effects associated with chemical exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects (response).
• Risk Characterization - summarizes and combines outputs of the exposure and toxicity assessments to provide a quantitative assessment of site-related cancer risks.
Data Evaluation: In this step, EPA identified the nature and extent of radiological contamination in environment at the site, such as sediment and fish. EPA selected the contaminants of potential concem in various media {i.e., sediment) based on such factors as toxicity, frequency of occurrence, and fate and fransport of the contaminants in the environment, concenfrations of the contaminants in specific media, mobility, persistence, and bioaccumulation. EPA used simplistic fate and fransport models to evaluate the radionuclides of potential concem (ROPCs) in animal tissue {i.e., fish) associated with the water bodies identified above. The models exfrapolated contaminant concenfrations from sediment to pore water and then to fish. Table 1.2 presents a summary of the predicted contaminant concenfrations in animal (fish) tissue. EPA then used these predicted contaminant concenfrations in the exposure calculations to estimate potential cancer risks. This health protective approach may have resulted in an overestimation of potential cancer risks.
Exposure Assessment: Exposure assessment evaluates pathways by which people are or can be eixposed to the contaminants of potential concem in different media {i.e., sediment). Factors relating to the exposure assessment include, but are not limited to, the concenfrations that people are or can be exposed to and the potential frequency (number of days per year) and duration of exposure (number of years). Table 2 provides the rationale for inclusion or exclusion of potential exposure pathways. EPA identified three pathways of concem; two relating to sediment exposure (ingestion and extemal radiation) and the other to fish ingestion.
Factors relating to the exposure assessment include, but are not limited to, the concenfrations that receptors might be exposed to, and the potential frequency and duration of exposure. The Exposure Point Concenfrations for ROPCs in sediment and fish, as presented in Tables 1.1 and 1.2, were calculated using a 95% Upper Confidence Limit on the arithmetic mean where adequate data were available to support the statistical calculation. EPA used the maximum detected concenfration when adequate statistical information was not availabl/e. EPA's ProUCL Version 3.0 software was used to perform the statistical calculations.
EPA also evaluated exposures to RME individuals. These individuals are regarded as having activity patterns {i.e., fishing) that would bring them into contact with the water bodies more frequently than average individuals. As such, this exposure assessment evaluated current/fiiture . RME child, adolescent, and adults who may recreate in, or consume fish from, the water bodies.
Sediment Exposure. Adolescent exposures were evaluated from direct contact {i.e., incidental ingestion and extemal radiation) with sediment at the water bodies. EPA assumed that adolescents would recreate at the various water bodies for 35 days/year (equivalent to about one day a week over the course of about a nine-month fishing season). EPA also assumed an adolescent ingestion rate of 50 milhgrams per day (mg/day) of sediment and a bodyweight of 60 kilograms (kgs). EPA did not evaluate the
9 500014 potential for exposure to a young child and an adult because these individuals are less likely to frequent the water bodies than an adolescent. Therefore, resulting cancer risks for a young child and an adult would be less than those for an adolescent.
Fish Ingestion. Using the modeled fish concenfrations, EPA evaluated the fish ingestion pathway for young children, adolescents, and adults using the standard default assumptions for fish ingestion of 25 grams/day for an adult and adolescent. EPA modified the ingestion rate for young children based on bodyweight. Exposure duration was based on standard default assumptions for residents; 6 years for a young child, 24 years for an adult, and 8 years for an adolescent fisher. For the Delaware River and Newton Creek, it was assumed that 100% of the portion offish consumed may be contaminated. For Martin's Lake, it was assumed that 50% of the portion of j5sh consumed may be contaminated. This assumption was based on the size of Martin's Lake (approximately one-third of an acre in size and 18 inches deep) and its inability to provide adequate fish population to support a consumption rate of 25 grams/day.
Toxicity Assessment: Toxicity assessment determines the types of adverse health effects potentially associated with exposures to contaminants at the Welsbach Site and the relationship between the magnitude of exposure (dose) and severity of adverse effects (response). It involves determining whether exposure to a radionuclide can cause an increase in the incidence of a particular adverse health effect. Regarding exposure to radionuchdes, the carcinogenic potential due to chronic exposure to the radionuclides present at the Welsbach Site is the only health effect of concem. Long-term radiation exposure has been found to increase the risk of developing cancer in humans. The baseline human health risk assessment used the current consensus toxicity values for radionuchdes from the Radionuchde Health Effects Assessment Summary Tables (April 2001). Table 3 presents the radionuclide-specific toxicity data for the pathways of exposure evaluated in the baseline assessment {i.e., ingestion of sediment, ingestion offish, and extemal radiation).
Risk Characterization: Risk characterization is the final step in the Human Health Risk Assessment process. It combines exposure and toxicity information to provide a quantitative assessment of site risks. Exposures are evaluated based on the potential risk for developing cancer. EPA expresses the likelihood of an individual developing cancer as a probabihty. For example, a 10-4 cancer risk represents a "one in 10,000 excess cancer risk," or an increased risk of an individual developing cancer of one in 10,000 as a result of exposure to site contaminants under the conditions used in the Exposure Assessment. Under the federal Superfund program, EPA's goal of protection is an excess cancer risk of 10-6 or less for the RME individual. Acceptable exposures, as outlined in the NCP, are an individual with excess cancer risk at or below the range of 10-4 to 10-6 (corresponding to one in 10,000 to one in 1,000,000 excess cancer risk). Tables 4.1 to 4.4, summarize the potential for carcinogenic health effects associated with possible exposure to ROPCs in sediment and animal tissue in the water bodies. These tables provide a summary of the potential cancer risks associated with exposure to the medium of concem (i.e., sediment and fish) or "gross" cancer risks and the potential cancer risks from background exposure. To estimate "net" risks, or risks without contribution from background, EPA subfracts the background risks from the gross cancer risks.
500015 10 The results of EPA's risk characterization include:
• Potential for adverse health effects for recreationalists exposed to radionuclides in sediment (via extemal radiation and ingestion) were within EPA's acceptable risk range.
• Potential for adverse health effects for adolescent and young child fishers exposed to radionuchdes in animal tissue (via consumption offish) from the Delaware River, Newton Creek, and Martin's Lake were within EPA's risk range.
• Potential for adverse health effects for an adult fisher exposed to radionuclides in animal tissue (via consumption offish) from the Delaware River and Newton Creek were within EPA's risk range.
• A calculated cancer risk of 3 x 10"^ (i. e., 3 in 10,000) for an adult fisher exposed to radionuclides in animal tissue (via ingestion offish) from Martin's Lake. This risk is within the upper bound of EPA's acceptable risk range. However, EPA concluded that a more realistic cancer risk would be less than 90 % of the calculated cancer risk since the main contributors to the risk estimate {i.e., radium and lead) are bone seekers and are not expected to be present in edible fish tissue.
Screening Level Ecological Risk Assessment
Similar to the human health risk assessment, EPA used the following four-step process for assessing site-related ecological risks for a reasonable maximum exposure scenario:
1) Problem Formulation, a quahtative evaluation of contaminant release, migration, and fate; identification of contaminants of potential concem, receptors, exposure pathways, and known ecological effects of the contaminants; and selection of endpoints for fiirther study;
2) Exposure Assessment, a quantitative evaluation of contaminant release, migration, and fate; characterization of exposure pathways and receptors; and measurement or estimation of exposure point concenfrations;
3) Ecological Effects Assessment, literature reviews, field studies, and toxicity tests, hnking contaminant concenfrations to effects on ecological receptors; and
4) Risk Characterization, measurement or estimation of both current and fiiture adverse effects.
Problem Formulation: As described earlier, radionuclides in the uranium and thorium series are the primary contaminants of potential concem. Table 5 presents a summary of the radionuclides of potential concem and sediment data evaluated in the screening-level ecological risk assessment. '
Exposure Assessment: The screening level ecological risk assessment focused on aquatic organisms, including fish, and did not evaluate the potential risk to higher-level organisms such as waterfowl, muskrats, and beavers. EPA considered fish as the potential receptors of concem
11 500016 for radionuclides because they have more potential for exposure to radionuclides in sediments than do semi-aquatic bfrds and mammals. They are also more sensitive to radiological damage than bottom-dwelling invertebrates (See Table 6).
Ecological Effects Assessment: There are very few studies on ecological risk from radiological contaminants. Therefore, EPA compared the radionuclide concenfrations found in the sediment samples at the Welsbach Site to multi-media benchmarks developed by the U.S. Department of Energy's (DOE's) Oak Ridge National Laboratory (See Table 5). The adjusted benchmarks assume that the sediment and surface water concenfrations are in equilibrium, and thus consider potential surface water exposure. These benchmarks are identified in DOE's 1998 document titied "Radiological Benchmarks for Screening Contaminants of Potential Concem for Effects on Aquatic Biota at Oak Ridge National Laboratory, Oak Ridge, Tennessee." Radiological levels above the benchmark or guideline values would indicate that sediments and surface water could cause harmfiil impacts to ecological receptors.
Risk Characterization: The resuhs of this analysis indicated that the radionuchde concenfrations in sediment and surface water are well below the DOE guideline levels (See Table 5). Furthermore, all of the sediment samples collected had radionuclide concenfrations tiiat were indistinguishable from the background radiation levels found in the area. Therefore, EPA has determined that radionuclides do not cause an unacceptable ecological risk at the Welsbach Site.
Discussion of Uncertainties in Risk Assessment
Human Health Risk Assessment
Some uncertainty is inherent in the process of conducting predictive, quantitative human health evaluations. This uncertainty is associated with each component of the process, including environmental sampling and analysis, chemical fate and fransport modeling, human exposure assessment, and the toxicological criteria used to characterize potential health risks. Uncertainty in any of these components could alter the risk estimates.
Environmental Sampling
Uncertainty associated with envfronmental samphng is generally related to the limitations of the sampling in terms of the number and distribution of samples, while uncertainty associated with the sample analysis is generally associated with systematic or random errors (e.g., false positive or negative results). Thus, exposure may overestimate or underestimate risk depending on how well each environmental medium is characterized.
The use of the maximum detected radionuclide concenfrations in the evaluation of Martin's Lake may have resulted in an overestimation of risks. In addition, sampling locations for radiological analysis were not selected randomly; sampling locations for radiological analysis were generally biased towards potential sources of contamination (e.g., contiguous to areas of know contamination, storm water outfalls, etc.). Therefore, some of the maximum detected ROPC concenfrations used in the evaluation may be biased high and potentially overestimate risks.
500017 12 Fate and Transport Modeling
EPA derived the concenfrations of radionuclides in animal tissue (i.e., fish) by converting sediment concenfrations to pore water concenfrations using fate and fransport modeling. EPA then calculated fish tissue concenfrations using bioaccumulation factors (BAFs). These models were developed for chemicals; however, EPA used these models for the radionuclides in this evaluation because there are no fate and fransport and BAF models for radionuclides. Furthermore, because these models are intended for non-radionuclide chemicals, they do not account for the physical and chemical characteristics of the radionuchdes (i.e., radium, which is a bone seeker, and accounts for approximately 50% of the total risk). Therefore, the calculated risks from radionuchdes in fish may be overestimated.
Human Exposure Modeling
Uncertainties in the exposure assessment are related to estimates of how often an individual would actually come in contact with the contaminants of potential concem, the period of time over which such exposure would occur, and in the models used to estimate the concenfrations of the containinants of potential concem at the point of exposure.
In addition to the calculation of exposure point concenfrations, several site-specific assumptions regarding fiiture land use scenarios, intake parameters, and exposure pathways are a part of the exposure assessment stage of a baseline risk assessment. EPA based these assumptions on site- specific conditions to the greatest degree possible. In the absence of site-specific data, EPA used default parameter values found in EPA risk assessment guidance documents. However, there remains some uncertainty in the prediction of future use scenarios and their associated intake parameters and exposure pathways.
Toxicological Criteria
Uncertainties in toxicological data occur in exfrapolating from high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of radiological contaminants. EPA addresses these uncertainties by making health protective assumptions concerning risk and exposure parameters throughout the assessment. As a result, the baseline human health risk assessment provides upper-bound estimates of the risks to populations near the Site, and it is highly unlikely to imderestimate actual risks related to the site.
Human epidemiological data on carcinogenesis from exposure to ionizing radiation are more extensive than that for most chemical carcinogens. However, these data are based primarily upon studies of populations exposed to radiation doses and dose rates that are higher than the levels of concem in this risk assessment. Use of these data to predict excess cancer risk from low-level radiation exposure requires exfrapolation based on estimated dose-response assumptions. However, the risk estimators used in this assessment are generally accepted by the scientific community as representing reasonable projections of the cancer risks associated with exposure to the various radionuclides.
13 500018 Screening-Level Ecological Risk Assessment
Some uncertainty is inherent in the process of conducting a screening-level ecological risk assessment. Envfronmental sampling and analysis and exposure calculations are prone to uncertainty, as are the available toxicity data used to characterize risks.
Environmental Sampling
Uncertainty associated with envfronmental sampling is generally related to the limitations of the sampling program in terms of the number and distribution of samples, while uncertainty associated with the analysis of the samples is generally related to systematic or random eirors.
Exposure Assessment
Another point of uncertainty hes in the assumption that each of the wildhfe receptor species feeds only upon food items found in the study areas. For species with very small home ranges (e.g., organisms that live in the sediment), this assumption is likely to be close to actuality. However, other receptors (e.g., fish) may consume food sources other than those considered in the assessment, the exclusion of which could either over- or underestimate the potential risk. It is possible that receptors may not feed entirely within the sampling areas, but may look for food in other areas as well.
Screening Benchmarks
The multimedia sediment benchmarks used in the screening-level ecological risk assessment do not include the extemal dose from water, which is considered a minor source of error relative to the extemal radiation from the sediment. Also, the multimedia sediment benchmarks were calculated using default sediment/water partition coefficients and bioconcenfration factors. There is uncertainty associated with these factors.
OU3 Risk Characterization Summary
The primary containinants of potential concem for the Welsbach Site are radionuchdes in the thorium and uranium decay chains. The results of EPA testing did not indicate elevated radionuclide concenfrations in sediments in the Welsbach Site study area. Although the levels of some chemical contaminants of potential concem exceeded the ecological guidelines and human health risk levels in the surface water, sediment, and wetland study area, these chemical contaminants are not related to operations associated with Welsbach and GGM.
EPA's baseline human health risk assessment found that effects from exposures to the radionuclide concenfrations in the sediments are within the upper bounds of EPA's acceptable risk range. In addition, the screening level ecological risk assessment results indicate that the radionuclide concenfrations in the sediments are below EPA's level of concem. Therefore, no remedial action is necessary because EPA has determined that no unacceptable risk to human health and the environment exists from radionuclides in the surface water, sediment, and wetland areas in the Welsbach Site study area.
500019 14 STATE ACCEPTANCE
The State of New Jersey concurs with the selected no action remedy.
DOCUMENTATION OF SIGNIFICANT CHANGES
EPA released the Proposed Plan for 0U3 of the Welsbach Site for pubhc comment on May 24, 2005. The Proposed Plan identified No Action as the preferred remedy for the surface water, sediment, and wetland areas at the Welsbach Site. EPA reviewed all comments received during the public comment period, and determined that no significant changes to the no action remedy, as originally identified in the Proposed Plan, were necessary or appropriate.
15 500020 APPENDIX I
500021 500022 500023 APPENDIX n
500024 TABLE 1.1 Baseline Human Healtli Risl( Assessment Summary of Radionuclides of Potential Concem and Medium-Specific Exposure Point Concentrations Welsbacli/General Gas Mantle Contamination Superfund Site
Scenario Timeframe: Current/Future | Medium: Sediment | Exposure Medium: Sediment 1 Exposure Radionuclide of Concentration Detected (pCi/g)' Frequency of Point SUtistical 1 Exposure Point Potential Concern' Arithmetic Detection Concentration Measure Minimum Maximum Mean (pCi/e) Radium-226 + D 0.9 0.3 E 1.4 E 4/4 0.9 Mean Radium-228 + D 1.1 0.2 E 1.7 E 4/4 1.1 Mean Background Thorium-228 + D 0.5 0.2 E 0.7 E 4/4 0.5 Mean Sediment Thorium-230 , 0.8 0.4 E 1.1 E 4/4 0.8 Mean Thorium-232 0.5 0.1 E 0.8 E 4/4 0.5 Mean Lead-210 + D 0.9 0.3 E 1.4 E 4/4 0.9 Mean Radium-226 + D 0.5 0.3 J 1.0 E 12/13 0.65 95%UCL-N Radium-228 + D 0.6 0.3 1.2 13/13 0.73 95% UCL-N Thorium-228 + D 0.2 0.05 E 0.4 E 13/13 0.27 95% UCL-N Delaware River Thorium-230 0.6 0.4 E 0.9 E 13/13 0.68 95% UCL-N Thorium-232 0.3 0.03 0.6 J 13/13 0.36 95% UCL-N Lead-210+ D 0.5 0.3 J 1.0 E 13/13 0.65 95% UCL-N Radium-226 + D 1.0 0.3 1.8 40/40 1.1 95% UCL-N Radium-228 + D 1.3 0.4 2.4 40/40 1.4 95% UCL-N Thorium-228 + D 0.6 0.1 E 2.3 40/40 0.6 95% UCL-G Newton Creek Thorium-230 1.1 0.5 1.9 E 40/40 1.2 95% UCL-N Thorium-232 0.6 0.2 2.4 E 40/40 0.7 95% UCL-G Lead-210+ D 1.0 0.3 1.8 40/40 1.1 95% UCL-N Radium-226 + D 1.0 0.2 2.1 4/4 2.1 Max Radium-228 + D 1.2 0.3 2.7 4/4 2.7 Max Thorium-228 + D 0.5 0.4 E 0.7 E 4/4 0.7 Max Martin's Lake Thorium-230 0.8 0.5 E LIE 4/4 1.1 Max Thorium-232 0.6 0.3 E 0.9 E 4/4 0.9 Max Lead-210+ D 1.0 0.2 2.1 4/4 2.1 Max Key 1 ^ Decay products (+D) included as appropriate; secular equilibrium assumed between Lead-210 and Radium-226. 2 = Laboratory qualifiers: J - Result is qualified as estimated since concentrations fell between the detection limit and the instrument detection liniiit. E - Qualified estimate as a result of the data validation. pCi/g: Picocuries per gram 95% UCL-N: 95% Upper Confidence Limit of normal data calculated using ProUCL Version 3.0 software. 95% UCL-G: 95% Upper Confidence Limit of gamma data calculated using ProUCL Version 3.0 software. Max: Maximum detected concentration
500025 TABLE 1.2 Baseline Human Health Risk Assessment Summary of Radionuclides of Potential Concem and Medium-Specific Exposure Point Concentrations Welsbach/General Gas Mantie Contamination Superfund Site
Scenario Timeframe: Current/Future 1 Medium: Pore Water 1 Exposure Medium: Animal Tissue (Fish) |
Concentration Detected (pCi/kg) Exposure Point Exposure Radionuclide of Frequency of Statistical Concentration Point Potential Concem* Arithmetic Detection Measure Minimum Predicted' (pCI/kg) Radium-226 + D 0.9 - 0.9 — 0.9 Mean Radium-228 + D 0.1 — 0.1 — 0.1 Mean Background Thorium-228 + D 0.0004 — 0.0004 — 0.0004 Mean Animal — . — Tissue (Fish) Thorium-230 0.0005 0.0005 0.0005 Mean Thorium-232 0.0004 - 0.0004 — 0.0004 Mean Lead-210+ D 0.4 ~ 0.4 — 0.4 Mean Radium-226 + D - - 665 — 665 95% UCL-N Radium-228 + D — — 81.3 — 81.3 95% UCL-N Delaware Thorium-228 + D - — 0.18 — 0.18 95% UCL-N River Thorium-230 — — 0.45 — 0.45 95% UCL-N Thorium-232 - — 0.24 — 0.24 95% UCL-N Lead-210+ D — — 260 — 260 95% UCL-N Radium-226 + D — — 1150 — 1150 95% UCL-N Radium-228 + D - — 161 — 161 95% UCL-N Thorium-228 + D - - 0.4 — 0.4 95% UCL-G Newton Creek Thorium-230 ~ - 0.8 — 0.8 95% UCL-N Thorium-232 - — 0.5 — 0.5 95% UCL-G Lead-210+ D - — 449 — 449 95% UCL-N Radium-226 + D - — 2120 ~ 2120 Max Radium-228 + D - - 297 - 297 , Max Thorium-228 + D — - 0.4 — 0.4 Max Martin's Lake 'niorium-230 - ~ 0.7 — 0.7 Max Thorium-232 — - 0.6 — 0.6 Max Lead-210+ D - - 828 - 828 Max Key 1 = Decay products (+D) included as appropriate; secular equilibrium assumed between Lead-210 and Radium-226. 2 = These concentrations represent modeled, not actual data. Pore water concqitrations were predicted from sediment data; animal tissue concentrations were derived from predicted pore water concentrations pCi/kg: Picocuries per kilogram 95% UCL-N: 95% Upper Confidence Limit of nonnal data calculated using ProUCL Version 3.0 software. 95% UCL-G: 95% Upper Confidence Limit of gamma data calculated using ProUCL Version 3.0 software. Max: Maximum detected concentration
500026 TABLE 2 Baseline Human Health Risk Assessment Selection Of Exposure Pathways Welsbach/General Gas Mantle Contamination Superfund Site
Scenario Exposure Receptor Receptor Type of Medium Exposure Point Exposure Route Rationale for Selection or Exclusion of Exposure Pathway Timeframe Medium Population Age' Analysis
Surface water samples were not collected. However, concentrations of ROPCs in surface water would be much less than concentrations in sediment due to dilution, tidal influences, and partitioning External Radiation None (between sediment and surface water). As such, any risks from exposure to surface water would be less than those for sediment. Therefore, surface water was precluded from this evaluation.
Delaware River, Surface Newton Creek, Recreationalist Adolescent Water Martin's Lake Surface water samples were not collected. However, concentrations Surface of ROPCs in surface water would be much less than concentrations Water in sediment due to dilution, tidal influences, and partitioning Ingestion None (between sediment and surface water). As such, any risks from Current/ exposure to surface water would be less than those for sediment. Future Therefore, surface water was precluded from this evaluation.
Exposure to ROPCs in surface water unlikely through inhalation Inhalation None pathway. Fish from Animal Adult, Delaware River, Extemal Radiation None Exposure to ROPCs in fish unlikely through dermal pathway. Tissue Fisher Adolescent, Newton Creek, (Fish) Young Child Martin's Lake Ingestion Quant Locally-caught fish may be ingested by fishers. Recreationalists may be exposed to sediments by wading or Extemal Radiation Quant recreating along the shorelines. Delaware River, Recreationalists may be exposed to sediments by wading or Sediment Sediment Newton Creek, Recreationalist Adolescent Ingestion Quant tn recreatine alone the shorelines. Martin's Lake o Exposure to ROPCs in sediments unlikely through inhalation o Inhalation None o pathway. Key 1 = An adolescent receptor was selected for quantitative assessment since it is the most sensitive receptor based on the potential for exposure^., frequency) at the Site, as compared to adult or children (0-6 years old) who may be exposed on a less frequent basis. ROPCs = Radionuclides of Potential Concem. Table 3 Baseline Human Health Risk Assessment Cancer Toxicity Data Summary Table Welsbacli/General Gas Mantle Contamination Superfund Site
Weight of Radionuclide of Oral Cancer Evidence/Cancer Slope Factor Units Source Date Potential Concern' Slope Factor Guidelines Description Pathway: Ingestion 1 Radium-226+ D 7.30E-10 Risk/pCi A HEAST 4/16/2001 Radium-228 + D 2.29E-09 Risk/pCi A HEAST 4/16/2001 Thorium-228+ D 8.09E-10 Risk/pCi A HEAST 4/16/2001 |Thorium-230 2.02E-10 Risk/pCi A HEAST 4/16/2001 Thorium-232 2.31E-10 Risk/pCi A HEAST 4/16/2001 Lead-210+ D 2.66E-09 Risk/pCi A HEAST 4/16/2001 Pathway: Fish Ingestion f Radium-226 + D 5.15E-10 Risk/pCi A HEAST 4/16/2001 Radium-228 + D 1.43E-09 Risk/pCi A HEAST • 4/16/2001 Thorium-228+ D 4.22E-10 Risk/pCi A HEAST 4/16/2001 Thorium-230 1.19E-10 Risk/pCi A HEAST 4/16/2001 |Thorium-232 1.33E-10 Risk/pCi A HEAST 4/16/2001 Lead-210 + D 3.44E-09 Risk/pCi A HEAST 4/16/2001 Pathway: External Radiation | Radium-226 + D 8.49E-06 Risk/year per pCi/g A HEAST 4/16/2001 Radium-228+ D 4.53E-06 Risk/year per pCi/g A HEAST 4/16/2001 Thorium-228+ D 7.76E-06 Risk/year per pCi/g A HEAST 4/16/2001 Thorium-230 8.19E-10 Risk/year per pCi/g A HEAST 4/16/2001 Thorium-232 3.42E-10 Risk/year per pCi/g A HEAST 4/16/2001 ||Lead-210 + D 4.21E-09 Risk/year per pCi/g A HEAST 4/16/2001 Key 1 = Decay products (+D) included as appropriate; secular equilibriiun assvuned between Lead-210 and Radium-226. A - Known Carcinogen HEAST = Health Effects Assessment Summary Table.
500028 TABLE 4.1 Baseline Human Health Risk Assessment Risk Characterization Summary - Radiation Cancer Risks Sediment Welsbach/General Gas Mantle Contamination Superfund Site
Scenario Timeframe: Current/Future Receptor Population: Recreationalist Receptor Age: Adolescent (10 -18 years old) Carcinogenic Risk^ Exposure Radionuclide of External Radiation Ingestion Medium Exposure Point Exposure Medium Potential Concern' Background Background Gross Risk Net Risk Gross Risk Net Risk Routes Total Risk Risk Radium-226 + D lE-06 2E-06 -5E-07 7E-09 9E-09 -2E-09 -5E-07 Radium-228 + D 8E-07 lE-06 . -4E-07 2E-08 4E-08 -lE-08 -4E-07 Thorium-228 + D 5E-07 lE-06 -8E-07 3E-09 8E-09 -5E-09 -8E-07 Delaware River Thorium-230 lE-10 2E-10 -2E-11 2E-09 2E-09 -2E-10 -2E-10 Thorium-232 3E-11 5E-11 -2E-11 lE-09 2E-09 -6E-10 -6E-10 Lead-210+ D 7E-10 lE-09 -3E-10 2E-08 3E-08 -9E-09 -9E-09 Totals 3E-06 5E-06 -2E-06 6E-08 9E-08 -3E-08 -2E-06 Radium-226 + D 2E-06 2E-06 5E-07 lE-08 9E-09 2E-09 . 5E-07 Radium-228 + D 2E-06 lE-06 4E-07 5E-08 4E-08 lE-08 4E-07 Thorium-228 + D lE-06 lE-06 -5E-08 7E-09 8E-09 -3E-10 -5E-08 Sediment Sediment Newton Creek Thorium-230 2E-10 2E-10 8E-11 3E-09 2E-09 lE-09 lE-09 Thorium-232 6E-11 5E-11 2E-11 2E-09 2E-09 6E-10 6E-10 Lead-210+ D lE-09 lE-09 3E-10 4E-08 3E-08 9E-09 9E-09 Totals 5E-06 5E-06 8E-07 lE-07 9E-08 2E-08 9E-07 Radium-226 + D 4E-06 2E-06 3E-06 2E-08 9E-09 lE-08 3E-06 Radium-228 + D 3E-06 lE-06 2E-06 9E-08 4E-08 5E-08 2E-06 Thorium-228 + D lE-06 lE-06 -3E-08 7E-09 8E-09 -2E-10 -3E-08 Maitin's Lake Thoriuni-230 2E-10 2E-10 6E-1I 3E-09 2E-09 9E-10 9E-10 Thorium-232 8E-11 5E-11 3E-11 3E-09 2E-09 lE-09 lE-09 tn o Lead-210+ D 2E-09 lE-09 lE-09 8E-08 3E-08 4E-08 5E-08 o o Totals 9E-06 5E-06 4E-06 2E-07 9E-08 lE-07 4E-06 ts) Key Note: The E in the risk values represents exponent. For example 9E-06 = 9x10 . 1 = Decay products (+D) included as appropriate; secular equilibrium assumed between Lead-210 and Radium-226. 2 = Negative cancer risks reflect sediment concentrations that are within the background fluctuation range. TABLE 4.2 Baseline Human Health Risk Assessment Risk Characterization Summary Radiation Cancer Risks Animal Tissue (Fish) Welsbach/General Gas Mantle Contamination Superfund Site
Scenario Timeframe: Current/Future Receptor Population: Fisher Receptor Age: Adult Carcinogenic Risk^ ll Exposure Radionuclide of Fish Ingestion^ Medium Exposure Point • Medium Potential Concern' Background Gross Risk Net Risk Risk Radium-226 + D 7E-05 lE-04 -3E-05 Radium-228 + D 2E-05 4E-05 -lE-05 Thorium-228 + D 2E-08 4E-08 -2E-08 Delaware River Thorium-230 lE-08 lE-08 -lE-09 Thorium-232 7E-09 lE-08 -3E-09 Lead-210+ D 2E-04 3E-04 -7E-05 Totals 3E-04 4E-04 -lE-04 Radium-226 + D lE-04 lE-04 3E-05 Radium-228 + D 5E-05 4E-05 lE-05 Thorium-228 + D 4E-08 4E-08 -lE-09 Animal Tissue Pore Water Newton Creek Thorium-230 2E-08 lE-08 7E-09 (Fish) Thorium-232 lE-08 lE-08 4E-09 Lead-210 + D 3E-04 3E-04 7E-05 Totals 5E-04 4E-04 lE-04 Radium-226 + D lE-04 5E-05 9E-05 Radium-228 + D 4E-05 2E-05 4E-05 Thorium-228 + D 2E-08 2E-08 -8E-10 Martin's Lake Thorium-230 9E-09 6E-09 4E-09 Thorium-232 8E-09 5E-09 5E-09 Lead-210 + D 3E-04 lE-04 lE-04 Totals 5E-04 2E-04 3E-04 Key Note: The E in the risk values represents exponent. For example 5E-04 = 5 x 10^. 1 = Decay products (+D) included as appropriate; secular equilibrium assumed between Lead-210 and Radium- 226. 2 = Negative cancer risks reflect sediment concentrations that are within the backgroimd fluctuation range. 3 = Given its size, Martin's Lake would not be able to sustain a fish population to meet the consumption rate. The evaluation assimied that a fishercoul d obtain i00% of the fish that they may consume fi^om the Delaware River and Newton Creek and only 50% firom Martin's Lake. As such, the backgroimd risk for Martin's Lake is half that for the Delaware River and Newton Creek.
500030 TABLE 43 Baseline Human Health Risk Assessment Risk Characterization Summary Radiation Cancer Risks Animal Tissue (Fish) Welsbach/General Gas Mantle Contamination Superfund Site
Scenario Timeframe: Current/Future iReceptor Population: Fisher fReceptor Age: Adolescent (10-18 years old) Carcinogenic Risl^ Exposure Radionuclide of Fish Ingestion^ Medium Exposure Point Medium Potential Concern' Background Gross Risk Net Risk 1 Risk Radium-226 + D 2E-05 3E-05 -lE-05 j Radium-228 + D 8E-06 lE-05 -7E-06 1 Thorium-228 + D 5E-09 lE-08 -2E-08 1 Delaware River Thorium-230 4E-09 4E-09 -8E-10 1 Thorium-232 2E-09 3E-09 -2E-09 1 Lead-210+ D 6E-05 9E-05 -2E-05 1 Totals 9E-05 lE-04 -4E-05 Radium-226 + D 4E-05 3E-05 lE-05 Radium-228 + D 2E-05 lE-05 6E-06 Thorium-228 + D lE-08 lE-08 -lE-09 Animal Tissue Pore Water Newton Creek Thorium-230 6E-09 4E-09 4E-09 1 (Fish) Thorium-232 5E-09 3E-09 2E-09 Lead-210 + D lE-04 9E-05 2E-05 Totals 2E-04 lE-04 4E-05 Radium-226 + D 4E-05 2E-05 3E-05 Radium-228 + D lE-05 6E-06 lE-05 Thorium-228 + D 6E-09 7E-09 -3E-10 Martin's Lake Thorium-230 3E-09 2E-09 lE-09 Thorium-232 3E-09 2E-09 2E-09 Lead-210+ D lE-04 4E-05 4E-05 Totals 2E-04 7E-05 9E-05 Key Note: The E in the risk values represents exponent. For example 9E-05 = 9 x 10*. 1 = Decay products (+D) included as appropriate; secular equihbrium assumed between Lead-210 and Radium-226. 2 = Negative cancer risks reflect sediment concentrations that are within the background fluctuation range. 3 = Given its size, Martin's Lake would not be able to sustain a fish population to meet the consun^tion rate. The evaluation assumed that a fisher could obtain 100% of the fish that they may consume fix)m the Delaware River and Newton Creek and only 50% from Maitin's Lake. As such, the background risk for Martin's Lake is half that for the Delaware River and Newton Creek.
500031 TABLE 4.4 Baseline Human Health Risk Assessment Risk Characterization Summairy Radiation Cancer Risks Aninial Tissue (Fish) Welsbach/General Gas Mantle Contamination Superfund Site
Scenario Timeframe: Current/Future 1 Receptor Population: Fisher Receptor Age: Young Child (0-6 years old) Carcinogenic Risk^ H Exposure Radionuclide of Fish Ingestion^ ||
Medium Exposure Point • Medium Potential Concern' Background Gross Risk Net Risk Risk Radium-226 + D 6E-06 8E-06 -2E-06 1 Radium-228 + D 2E-06 3E-06 -lE-06 Thorium-228 + D lE-09 3E-09 -2E-09 Delaware River Thorium-230 9E-10 lE-09 -lE-10 Thorium-232 6E-10 8E-10 -3E-10 Lead-210+ D 2E-05 2E-05 -6E-06 Totals 2E-05 3E-05 -9E-06 Radium-226+ D lE-05 8E-06 2E-06 Radium-228 + D 4E-06 3E-06 9E-07 Thorium-228 + D 3E-09 3E-09 -lE-10 Animal Tissue Pore Water Newton Creek Thorium-230 2E-09 lE-09 5E-10 (Fish) Thorium-232 lE-09 8E-10 3E-10 Lead-210+ D 3E-05 2E-05 6E-06 Totals 4E-05 3E-05 9E-06 Radium-226 + D 9E-06 4E-06 8E-06 Radium-228 + D 4E-06 2E-06 3E-06 Thorium-228+ D 2E-09 2E-09 -7E-11 Martin's Lake Thorium-230 7E-10 5E-10 4E-10 Thorium-232 7E-10 4E-10 5E-10 Lead-210+ D 2E-05 lE-05 lE-05 Totals 4E-05 2E-05 2E-05 Key Note: The E in the risk values represents exponent. For example 4E-05 = 4 x lO"'. 1 = Decay products (+D) included as appropriate; secular equihbrium assumed between Lead-210 and Radium- 226. 2 = Negative cancer risks reflect sediment concentrations that are within the background fluctuation range. 3 = Given its size, Martin's Lake would not be able to sustain a fishpopulatio n to meet the consumption rate. The evaluation assumed that a fisher could obtain 100% of the fish that they may consume firom the Delaware River and Newton Creek and only 50% fi-om Martin's Lake. As such, the background risk for Martin's Lake is half that for the Delaware River and Newton Creek.
500032 TABLES. Screening-Level Ecological Risk Assessment Occurrence, Distribution, and Selection of Radionuclides of Potential Concem Welsbacli/General Gas Mantle Contamination Superfund Site
Exposure Medium: Sediment Radionuclide of Minimum Maximum Maximum Screening Background Hazard Sampling Area Potential. Concentration' Concentration' Benchmark Value' Concentration Quotient^ Concern' (pCi/g) (pCI/g) (pCI/g) (pCi/B) West Banl( Newton Creek Transect Itadium-226 + D 0.4 1.3 1.4 E 20 0.06 Radium-228 + D 0.5 1.4 1.7 E NA NA Thorium-228 + D 0.2 E . 0.5 E 0.7 E 148 0.004 Thorium-230 0.5 E IJE 1.1 E 103 0.001 Thorium-232 0.2 E 0.8 E 0.8 E 1100 0.001 Gloucester City Swim Club Transect Radium-226 + D 0.6 1.6 1.4 E 20 0.08 Radium-228 + D 0.7 1.3 1.7 E NA NA Thorium-228 + D 0.2 E 0.8 E 0.7 E 148 0.005 Thorium-230 0.8 E 1.4 E 1.1 E 103 0.001 Thorium-232 0.3 E 0.7 E 0.8 E 1100 0.001 Johnson Boulevard Land Preserve Transect Radium-226 + D 0.6 1.6 1.4 E 20 0.08 I^adium-228 + D 0.7 2.3 1.7 E NA NA Thorium-228 + D 0.1 E 0.9 E 0.7 E 148 0.006 Th6rium-230 0.7 E 0.9 E 1.1 E 103 0.001 Newton Creeic rhorium-232 0.2 E 0.9 E 0.8 E 1100 0.001 Temple Avenue Transect Radium-226 + D 0.8 1.8 1.4 E 20 0.09 Radium-228 + D 1.3 2.2 1.7 E NA NA rhorium-228 + D 0.4 2.3 E 0.7 E 148 0.015 Thorium-230 1.1 E 1.8 E 1.1 E 103 I 0.001 Thorium-232 0.4 2.4 E 0.8 E 1100 0.002 Jogging Track Transect Radium-226 + D 0.7 1.2 1.4 E 20 0.06 Radium-228 -t- D 1.1 1.7 1.7 E NA NA Thorium-228 + D 0.5 E 0.7 E 0.7 E 148 0.004 Thorium-230 0.6 E 1.2 E 1.1 E 103 0.001 Thorium-232 0.5 E 0.8 E 0.8 E 1100 0.001 Jogging Track North Transect Radium-226 + D 0.6 1.5 1.4 E 20 0.07 Radium-228 + D 0.8 2.4 1.7 E NA NA Thorium-228 + D 0.3 0.8 E 0.7 E 148 0.006 Thorium-230 1.2 E 1.9 E 1.1 E 103 0.002 Thorium-232 0.5 0.9 0.8 E 1100 0.001. Radium-226 + D 0.2 2.1 1.4 E 20 0.10 Radium-228+D 0.3 2.7 1.7 E NA NA Martin's Laice Thorium-228 + D 0.4 E 0.7 E 0.7 E 148 0.004 Thorium-230 0.5 E 1.1 E 1.1 E 103 0.001 Thorium-232 0.3 E 0.9 E 0.8 E 1100 0.001 Radium-226 + D 0.3 J 1.0 E 1.4 E 20 0.05 Radium-228 + D 0.3 1.4 1.7 E NA NA Stormwater Thorium-228 + D 0.05 E 0.6 E 0.7 E 148 0.004 Outfalls Thorium-230 0.4 E 2.1 E 1.1 E 103 0.002 Thorium-232 0.03 0.6 E 0.8 E 1100 0.001 Key 1 = Decay products (+D) included as appropriate. 2 = Laboratory qualifiers: J - Result is qualified as estimated since concentrations fell between die detection limit and die instrument detection limit E • Qualified estimate as a result of the data validation. 3 = Source: Bechtel Jacobs Company LLC, 1998 4 = Hazard Quotient (HQ) = Maximum concentration in Sediment/Sediment Benchmaik NA = Not Available. 500033 TABLE 6 Screening-Level Ecological Risk Assessment Ecological Exposure Pathways of Concem Welsbach/General Gas Mantle Contamination Superfund Site
Sensitive Exposure Measurement Environment Receptor Exposure Routes Assessment Endpoints Medium Endpoints Flag (Y or N) Protection of aquatic Direct contact with Impaired reproduction, commimities from Sediment N Fish radionuclides in sediment. growth, and survival changes in stmcture or function Protection of aquatic Direct contact with Siuface Impaired reproduction, coimnunities from N Fish radionucUdes m surface water growth, and survival changes in structure water. or fimction
ot/l o U) 1^ APPENDIX III
500035 r
WELSBACH & GENER2U^ GAS MANTLE (CAMDEN KADIATIOK) OPERABLE UNIT THREE ADMINISTRATIVE RECORD PILE INDEX OF DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.4 Remedial Investigation Reports
P. 300001 - Report: Screening-Level Ecological Risk Assessment 300265 (SLERA). Welsbach/General Gas Mantle Contamination Superfund Site Ecological Investigation. Camden and Gloucester Citv. New Jersey, prepared by Malcolm Pirnie, Inc., prepared for U. S. Army Corps of Engineers, March 2002.
3.5 Correspondence
P. 300266 - Memorandum to Mr. Bob Kerbel, Malcolm Pirnie, from 300267 Ms. Teresa Caputi, NNJ, Malcolm Pirnie, re: Welsbach Ecological Investigation - Surface Water Quality, August 23, 2002. P. 300268 - Memorandum to Mr. Rick Robinson, Remedial Project 300273 Manager, New Jersey Remediation Branch, U. S. EPA Region 2, from Ms. Mindy J. Pensak, Coordinator, Biological Technical Assistance Group, U. S. EPA Region 2, re: Biological Technical Assistance Group Review, Welsbach/General Gas Mantle Contamination Superfund Site, undated.
11.0 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS 11.1 EPA Headquarters
P. 11.00001- Report: Ecological Risk Assessment Guidance for 11.00230 Superfund,: Process for Designing and Conducting
500036 r Ecological Risk Assessments. Interim Final, prepared by U. S. EPA, June 1997.
P. 11.00231- Memorandum to Superfund National Policy Managers 11.00239 Regions 1 - 10, from Mr. Stephen D. Luftig, Director, Office of Emergency and Remedial . Response, re: Issuance of Final Guidance: Ecological Risk Assessment and Risk Management Principles for Superfund Site, October 7, 1999. P. 11.00240- Report: Ecological Risk Assessment, prepared by 11.00245 U. S. EPA, Natural Resource Damages, July 22, 2004.
11.4 Technical Sources P. 11.0024 6- Report: Effects of Ionizing Radiation on Aquatic 11.00366 Organisms, Recommendations of the National Council on Radiation Protection and Measurements, prepared by National Council on Radiation Protection and Measurements, August 30, 1991. P. 11.00367- Report: Environmental Management & Enrichment 11.00398 Facilities. Radiological Benchmarks for Screening Contaminants of Potential Concern for Effects on Aquatic Biota at Oak Ridge National Laboratory. Oak Ridge, Tennessee, prepared by Bechtel Jacobs Company LLC, prepared for U. S. Department of Energy, Office of Environmental Management, July . 1998.
500037 r
WELSBACH & GENERAL GAS MANTLE (CAMDEN RADIATION) OPERABLE UNIT THREE ADMINISTRATIVE RECORD FILE UPDATE INDEX OF DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.4 Remedial Investigation Reports
P. 300274 - Report: Human Health Evaluation, Chemical and 300486 Radiological Contaminants in the Delaware River. Newton Creek, and Martinis Lake, Addendum to the Draft Final Remedial Investigation/Feasibility Study Report, January 1999, Welsbach/General Gas Mantle Contamination Superfund Site, Camden and Gloucester City. New Jersey, prepared by Malcolm Pirnie, Inc., prepared for U.S. Armly Corps of Engineers, January 2005.
500038 APPENDDCIV
RESPONSIVENESS SUMMARY
Welsbach and General Gas Mantle Contamination Superfund Site
INTRODUCTION
This Responsiveness Summary provides a summary of the pubUc's conmients and concems regarding the Proposed Plan for Operable Unit 3 (0U3) of the Welsbach and General Gas Mantle Contamination site (Welsbach Site), and EPA's responses to those comments. 0U3 includes the smface water, sediments, and wetland areas in the Welsbach Site study area. At the time of the public comment period, EPA proposed "no action" for 0U3. All comments summarized in this docimient have been considered in EPA's final decision for selecting a no action remedy for the surface water, sediment, and wetland areas in the Welsbach Site study area.
This Responsiveness Summary is divided into the following sections:
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This section provides the history of community involvement and interest regarding the Welsbach and General Gas Mantle Contamination Site.
n. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS, AND RESPONSES: This section contains summaries of oral comments received by EPA at the public meeting, EPA's responses to these comments, as well as . responses to written comments received diuing and after the public comment period.
in. ATTACHMENTS: The last section of this Responsiveness Summary provides attachments which document public participation in the remedy-selection process for this Site. The attachments are as follows:
Attachment A: the Proposed Plan that was distributed to the public for review and comment;
Attachment B: the public notices that appeared in the Courier-Post;
Attachment C: the transcripts of the public meetings; and
Attachment D: the written comments received by EPA diuing and after the pubhc comment period.
500039 I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
In January 1999, EPA made available for public comment the Proposed Plan and supporting documentation for Operable Unit One (OUl). EPA conducted public meetings in both Gloucester City and Camden to inform local officials and interested citizens about the Superfimd 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 mterested parties. After evaluating comments received during the public comment period, EPA selected a remedy for OUl, which included demohtion of the General Gas Mantle Building and the excavation and off- site disposal of the radiologically contaminated soils at the Welsbach Site. During the OUl public comment period, community interest was moderate in Gloucester City and low in Camden.
On May 24,2005, EPA released the Proposed Plan and supporting documentation for the no action remedy for the surface water, sediment, and wetland areas in the Welsbach Site study area (0U3) to the public for comment. EPA made these documents available to the pubhc in the administrative record repositories maintained at the EPA Region n office (290 Broadway, New York, New York), the 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 Courier-Post on May 24,2005, and July 25,2005. The initial pubhc comment period was held from May 24 through June 23,2005. However, at the request of the NJDEP, EPA extended the pubhc comment period to August 2,2005. EPA held two public meetings to present the preferred no action remedy for OU3. The first meeting was held on June 8,2005, at the Welsbach Field Office, and the second meeting was held on July 26, 2005, at the Camden County Municipal Utilities Authority (CCMUA).
II. COMPREHENSIVE SUMMARY OF MAJOR OUESTIONS. COMMENTS, CONCERNS. AND RESPONSES
PART 1: Verbal Comments
This section summarizes conunents received from the pubhc during the pubhc comment period, and EPA's responses. EPA held public meetings on June 8,2005, at 7:00 p.m. at the Welsbach Field Office, 130 N. Broadway, Gloucester City, New Jersey, and on July 26,2005, at 7:00 p.m. at CCMUA's auditorium, 1645 Ferry Avenue, Camden, New Jersey.
June 8. 2005 Public Meeting
Comments and questions raised by the public following EPA's presentation are categorized by relevant topics and presented as follows:
500040 • Surface Water, Sediment, and Wetland Investigation • Human Health and Ecological Risk • Remedial Action • General Community Concems
Surface Water, Sediment, and Wetland Investigation
Question 1: What were the radionuchde concentrations in the sediment and background samples?
EPA Response: The radionuclide concenfrations found in the background sediments were less than one picoCurie per gram (pCi/g). A comparison of the concenfrations detected in the samples to the average concenfrations found in the background samples indicated that the results were indistinguishable. In other words, the levels found in the sediments adjacent to the site were the same as the concenfrations found in the background samples. These levels are also similar to statewide radionuclide averages for radium and thorium.
Question 2: How were the background sampling areas selected?
EPA Response: The background samples were collected from locations upsfream of the known areas of contamination, thereby minimizing any potential that these samples could have been contaminated by radionuchdes from the site.
Question 3: What was the basis for selecting the sediment sampling locations? Since thorium does not migrate, were the locations selected because EPA believes there might have been dumping in these areas?
EPA Response: EPA selected sediment sampling locations that were adjacent to either potentially contaminated properties, or known contaminated properties in order to determine if contamination migrated from these areas. These properties included the Swim Club, the Land Preserve on Johnson Boulevard, north and south of Nicholson Road, and the Komatsu Yard. The Komatsu Yard is potentially contaminated property along Broadway, north of the Walt Whitman Bridge. In addition, EPA collected samples from outfalls in the Delaware River and Newton Creek. EPA sampled eight storm water runoff outfalls in the Delaware River and two outfalls in Newton Creek.
Question 4: Was the overflow pipe that entered Newton Creek just south of the Little League field still there, and if so, was it sampled?
EPA Response: The pipe is still present. It is one of the outfall points EPA sampled during the investigation.
500041 Human Health and Ecological Risk
Question 1: Were the risks from chemical contaminants included in the risk assessment and were the non-radiological chemicals associated with the site?
EPA Response: EPA conducted a baseline human health risk assessment for both radionuclides and chemicals found in the sediment samples. As part of non-radiological chemical assessment, EPA looked at ingestion offish which were potentially contaminated from the water bodies adjacent to the site. EPA looked at ingestion rates for young children (0-6 years of age), adolescents (10-18 years of age) and adults (greater than 18 years of age) and calculated risks from ingestion of potentially contaminated fish.
EPA also noted that one of the primary chemicals found in the water bodies was polychlorinated biphenyls (PCBs). PCBs have been found throughout the river system and are the basis for a State of New Jersey fish consumption advisory. However, PCBs are not related to the site. In the United States, PCBs were primarily used from the mid-1930s until 1977 when they were banned by EPA. Both the Welsbach Company and General Gas Mantle Company went out of business in the early 1940s, and there is no evidence that they used PCBs.
Question 2: Was the risk assessment based on state or federal standards?
EPA Response: The assessment followed a risk-based approach that includes federal Superfimd and EPA guidance and pohcies. The federal standards for fish ingestion were not used because federal standards, {i.e.. Food and Dmg Adminisfration), assume that an individual would be ingesting fish obtained from more than one source. The risk assessment assumed that a reasonable maximum exposed individual would be consuming his/her entfre fish diet from the water bodies evaluated in the risk assessment.
Question 3: Is there any risk from Martin's Lake since many generations of people in the town swam in the lake?
EPA Response: EPA's investigations at Martin's Lake identified radiological contamination on a very small area on the land, along the northern shore of the lake. The area is only a few cubic yards in size. There is not enough contamination present that would pose a risk for the activities described. To be at risk, a person would have to be in contact with the soil for a long period of time (i.e. daily for 30 years).
Question 4: What were the benchmark criteria EPA used for the ecological risks?
EPA Response: Benchmarks are values that are protective of ecological receptors, such as benthic organisms (organisms that live in sediment). There are a number of sources for the benchmarks. These sources can be found in the Screening Level Ecological Risk Assessment. These criteria are mainly based on hterature values for specific species identified from scientific research.
500042 Remedial Action
Question 1: Does EPA intend to remove the contaminated soil at Martin's Lake?
EPA Response: Yes, EPA will remove the contaminated soils on the land portions along the shore of Martin's Lake. This cleanup is part of the remedy EPA selected in the 1999 ROD. The purpose of this proposed plan for 0U3 was to discuss whether or not the contamination on the land made its way into the water bodies that are adjacent to the site. EPA found no contamination in the sediments of these water bodies.
General Community Concerns
Question 1: How did EPA discover the Welsbach Site, and how does EPA know where the radiological contamination is located?
EPA Response: EPA and NJDEP have conducted several extensive studies throughout Gloucester City and Camden. In the early 1980s, NJDEP used an aerial radiological flyover and identified five areas of radiological contamination. Since 1996, EPA has reviewed numerous historic maps and conducted detailed radiological investigations to identify properties where dumping may have occurred. When EPA compared the aerial radiological flyover with the historic maps, EPA found five additional contanoinated properties.
Question 2: With respect to the aerial radiological flyover, how accurate is it, and does EPA plan to conduct another survey?
EPA Response: An aerial survey will not identify small-scale radiological contamination, such as a small area of contamination in someone's backyard. For this reason, EPA is conducting a ground-based yard-by-yard survey. In the early 1990s, the State of New Jersey investigated approximately 1,100 properties within the original five study areas. EPA later identified a sixth area in Gloucester City, the Popcom Factory parcel, where a middle school is proposed to be built. Within the six study areas, there are oVer 1,200 properties that the EPA and/or the State of New Jersey investigated with more accurate equipment than what is used dming an aerial survey. Once these investigations are complete, EPA will clean up the contaminated properties.
EPA has not conducted another aerial survey since a new survey would only show the same areas that have already been identified. An aerial survey will only show large sites with large amounts of radiological material because the "shine" from highly contaminated areas will block out any nearby low level contaminated areas. Once the contamination from the large areas is removed, there is a chance that a new aerial survey could show some smaller arezis. At present, EPA does not have any plans to conduct another aerial survey, it is something that may be considered in the future after all the work is completed.
Question 3: Have conditions changed since the aerial radiological survey {e.g., moving of fill)?
500043 EPA Response: There are historic aerial photographs for the site from 1930 through 2000. EPA compared and reviewed these aerial photographs and found no new areas of dumping.
Question 4: When did the dumping in the Martin's Lake area start and when did it end?
EPA Response: Based on historical aerial photos, dumping activities were identified on the triangle property between Klemm and Highland Avenues as early as the 1930s. It appears these activities continued through the 1940s, 1950s, and into the 1960s. It is likely there were different generations of waste from multiple sources being deposited on these properties. One source for the contamination at Martin's Lake could be from the nearby contamination at Klemm and Highland Avenues. A portion of the radiologically contaminated soil at Klemm and Highland properties was originally dumped by Welsbach at the Gloucester City Swim Club. EPA was told by the owner of one of the Klemm and Highland properties that when the pools were dug at the Swim Club some of the excess soils were placed on the Klemm property.
Welsbach went out of business in 1940. In the late 1950s when the Walt Whitman Bridge was built, a number of Welsbach buildings were knocked down. EPA believes that some of the building material may have been deposited on the Jogging Track area that was formerly part of Newton Creek. It is possible that some of this material may also have been placed in the Martin's Lake area.
Question 5: How could contaminants from the site get into Martin's Lake?
EPA Response: During the remedial investigation in the late 1990s, EPA identified an area on the land portion of Martin's Lake that had elevated levels of radionuclides. The area is roughly three feet square and the contamination is relatively shallow (approximately 1.5 to 2 feet in depth). During the surface water investigation, EPA conducted additional sampling at Martin's Lake to determine if the contamination found on the land portion extended into the lake. EPA found no contamination in these sediments.
Question 6: How mobile are the radionuclides in sediment and water, how long is thefr half Ufe, and will the radionuclides underwater radiate energy in all dfrections?
EPA Response: Thorium is a heavy metal that does not migrate far in soil. It also has a low partitioning coefficient, which means that if it gets into water it doesn't dissolve into the water. Thorium is a radioactive element, and as part of its radioactive decay process it breaks down into daughter products. Those daughter products release energy as photons, alpha and beta particles, and gamma rays, as part of the decay process. The half life of thorium is 14 bilhon years.
Question 7: Is coal tar radioactive?
EPA Response: No, coal tar is not radioactive.
Question 8: Was radiological material dumped in the old racetrack area of Gloucester City that was filled in during the late 1890s.
^ 500044 EPA Response: During the cleanup of the Popcom Factory, some historic maps were found that identified a tributary of the Delaware River called the Indian Run. Indian Run ran right along the old racefrack area, through the Popcom Factory parcel, and then north. This tributary was filled in from the 1890s through the 1900s. Radiological contamination has been found in Indian Run at several locations including at the Popcom Factory and across the sfreet off 7th Sfreet between Jersey and Charles Sfreets.
July 26.2005 Pubhc Meeting
At this public meeting, EPA presented the proposed no action remedy for OU3 at the Welsbach Site together with the EPA's proposed remedy for the Martin Aaron Superfimd site. A portion of the Welsbach Site is adjacent to the Martin Aaron site. Conunents and questions raised by the pubhc following EPA's presentation regarding the Welsbach Site are presented below.
Question 1: A question was asked, in reference to the Martin Aaron Superftmd Site - were groundwater samples analyzed for radionuclides, and if so what were the results?
EPA Response: EPA collected groundwater samples from monitoring wells located on the Martin Aaron property for radionuclide analysis during the remedial investigation for the Welsbach Site. ITie radionuclide concenfrations in the groundwater samples collected from monitoring wells located on the Martin Aaron property were below drinking water standards. Radionuclide contamination in the groundwater was only foimd in samples collected immediately adjacent to the Welsbach Facility and several dumping areas in Gloucester City and the General Gas Mantle building in Camden.
Question 2: Does EPA use a 48-hour tum-around-time for^oundwater gross alpha analysis?
EPA Response: EPA followed the standard laboratory procedures that were in place during the time of the groundwater sampling.
Question 3: What is the proposed remedy for the Welsbach Site?
EPA Response: EPA is proposing no further action for the surface water, sediment, and wetland portion of the Welsbach Site (0U3):
Question 4: Is further reihediation planned at the General Gas Mantle property beyond the demolition of the building and covering of the property with gravel?
EPA Response: EPA will be removing all the radiologically contaminated soil from the property once funding becomes available. EPA's first priority is to remediate residential areas.
Question 5: Could EPA confirm that radiological samples were collected from wetland areas and used to evaluate human health and ecological risks.
500045 EPA Response: EPA collected sediment samples from three water bodies (the Delaware River, Newton Creek, and Martin's Lake) contiguous to the Welsbach Site for radiological analysis. The data were used to evaluate potential human health and ecological risks.
Question 6: What were the background radionuchde concentrations and were the sediment samples above the background concenfrations?
EPA Response: The average radionuclide concentrations for thorium and radium in both the sediment and background samples were less than 1.2 pCi/g. These concenfrations are consistent with statewide averages for background radionuchde concenfrations. Radionuclide concenfrations were, on average, equal to levels found in uncontaminated areas in the vicinity of the Welsbach Site (background levels).
Question 7: How were the background radionuchde concenfrations used in the calculation of risks?
EPA Response: EPA used the background radionuchde concenfrations to estimate "background radiation" cancer risks. After determining the "background radiation" risks, EPA subfracted the background risks from the total risk from all sources.
Question 8: Were non-site-related chemicals detected in sediment samples?
EPA Response: At nearly all of the sediment sampling locations, EPA detected non-radiological chemical constituents at levels that exceeded the maximum background concenfrations and sediment screening guidelines. In the area of the Welsbach Site, heavily developed industrial areas are located near the surface water bodies. These industrial areas are potential sources of these non-Welsbach site-related chemicals found in the sediment.
Question 9: Do the background concenfrations of radionuchdes in sediment increase the risk to human health and the envfronment from the non-site-related chemicals?
EPA Response: The risk assessment evaluated the potential for adverse effects to human health and the envfromnent from both radionuclides and non-site-related chemicals. Initially, the potential risks from exposure to radionuclides and non-site-related chemicals were evaluated separately. The risks were then combined since individuals may be exposed to both radionuclides and chemicals. EPA found that the contribution from radionuclides did not increase the risk from exposure to the non-site-related chemicals.
Question 10: Was EPA able to determine the source(s) of the non-site-related chemicals detected in sediment?
EPA Response: In the area of the Welsbach Site, heavily developed industrial areas are located near the surface water bodies. These industrial areas are potential sources of the non-Welsbach site-related chemicals found in the sediment.
500046 EPA also noted that the primary chemical of concem in sediments is PCBs. PCBs have been found throughout the river system and are the basis for a State of New Jersey fish consumption advisory. However, PCBs are not related to the site. In the United States, PCBs were primarily used from the mid-1930s until 1977 when they were banned by EPA. Both the Welsbach Company and General Gas Mantle Company went out of business in the early 1940s, and there is no evidence that they used PCBs.
Question 11: Has EPA attempted to locate or identify any former workers who may have worked in the General Gas Mantle building or any residents who may have lived in the vicinity of the facihty to conduct an assessment of thefr health?
EPA Response: The Agency for Toxic Substances and Disease Registry (ATSDR) working with the New Jersey Department of Health and Senior Services performed a health assessment for Gloucester City and Camden as part of the Welsbach Site. They found that there was an increased risk of cancer in the two areas but that this increase was primarily attributed to smoking. ATSDR did not look at historic exposures in the cities.
PART 2: Written Comments
Comments and concerns that were not addressed at the public meeting were accepted in writing during the public comment period. Copies of these comments are included in Appendix D of this Responsiveness Summary. A summary of each written comment received is included below along with EPA's response.
Question 1: An email was received from a professor at Rutgers University, Camden. He indicated that it would be helpful for the public understanding if EPA conducted a follow-up assessment of contamination levels, after remediation is completed. He would like this assessment to show the initial levels as compared to the post-remediation levels of radionuchdes, in order for the public to discern whether or not the EPA did what the ROD requfres.
EPA Response: After the cleanup at each construction unit, EPA conducts a Final Status Survey, consisting of the collection of a statistically significant number of soil samples. The results of these samples are used to determine whether EPA has met the cleanup levels specified in the ROD. If not, additional excavation and sampling is conducted. In addition, post- remediation measurements, including a surface exposure rate scan, and where applicable, radon/thoron levels, are also collected for additional verification. At the conclusion of each remedial action, EPA prepares a Remedial Action Report which summarizes the cleanup activities at the site, and documents that the cleanup has met the ROD requfrements.
Question 2: An email was received from two residents of Haddon Township, New Jersey, a city approximately 10 miles from the Welsbach Site. They have recently noticed a number of crippled, disfigured and otherwise handicapped Mallard ducks in thefr area. They asked if the study that was performed to determine the level, extent and impact of the contamination included study of effects on wildlife, and whether or not the abnormalities seen in the Mallards are in any way linked to the contamination.
500047 EPA Response: The main purpose of EPA's study was to see whether the radiological contamination on the site^properties had contaminated the surface water, sediment, and wetland areas adjacent to these site properties. As part of our investigation, EPA collected both radiological and chemical samples in the Delaware River, Newton Creek, and a small lake in Gloucester City called Martin's Lake.
With the data from these samples, EPA conducted a screening-level ecological and human risk assessment to assess the risk posed by the radionuclides and chemicals we found in the samples. The screening-level ecological risk assessment focused on aquatic biota (fish) and did not evaluate the potential risk to higher-level organisms {e.g.. Mallard duck and other semi-aquatic animals). Fish were considered to be the potential receptors of concem for radionuchdes, since they have more potential for exposure from sediments tiian semi-aquatic birds or manmials, and they are more sensitive to radiological exposure than benthic invertebrates (animals that live in the sediments). For the chemicals of concern, benthic invertebrates were considered the receptors of potential concem, since these organisms have the greatest potential for exposure of the aquatic and semi-aquatic organisms that may use the water bodies.
Part HI - Written Comments Received After Public Comment Period On September 14,2005, EPA received the following comments. These conraients were received well after the public comment period closed. However, as a courtesy, EPA has decided to respond to these conunents in this Responsiveness Suimnary.
Comment 1: During the pubhc meeting it was revealed that radioactivity had been discovered at the Martin Aaron site, which is roughly Yi mile north of the General Gas Mantle site^ and within Study Area 1 of the Welsbach Superfund site. No acknowledgement of this fact was provided in the public handouts for either site. A complete set of the radiological data for the Martin Aaron site should be included in the Martin Aaron RA Selection report. Additionally, the impact of this radioactive material on the proposed disposal of Martin Aaron soils must be evaluated. The likely origin of the radioactivity at the General Gas Mantle site indicates this assessment should be part of the Welsbach site activities.
Response: To date, EPA has not identified any radiological contamination on the Martin Aaron Site proper. EPA found elevated radionuclide concenfrations on the Leitka and Whitman Park properties across the sfreet from the Martin Aaron Site. The Leitka property is identified in the Martin Aaron site Proposed Plan as the South Jersey Port Corporation property. As part of the Martin Aaron Site remedial investigation, EPA investigated the Leitka property and determined that it was not part of the Martin Aaron Superfund Site. EPA will address the radiological contamination on the Leitka and Whitman Park properties as part of the Welsbach Site remedial action. If radiological contamination is found on the Martin Aaron site during response actions at that site, EPA will dispose of the radiological waste in accordance with the cleanup standard identified in the Welsbach 1999 Record of Decision.
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500048 Comment 2: The EPA expended fimds collecting and analyzing sediment and surface water samples for chemical contaminants then expended fimds to conduct human health and ecological risk assessments for those chemicals. Why these funds were expended when there was no intent to use the data should be explained. In addition, this data must be fransmitted to the NJDEP.
Response: While it is tme that site-related contaminants are limited to radionuclides, a trae ecological assessment cannot be accomphshed without a comprehensive understanding of all potential impacts. Therefore, it was essential that non^radiological compounds also be included in the assessment. This is in accordance with EPA guidance. All of the data generated from the sampling and assessment has been provided to NJDEP.
Comment 3: EPA states that the chemicals found in thefr samples were not in use when Welsbach and General Gas Mantle operated, apparently as its justification for not corisidering thefr chemical data when evaluating cleanup options. Both of these facilities had to have used coal and would, therefore, have produced polyaromatic hydrocarbon compounds (PAHs) in thefr coal ash. PCBs, according to the USEPA web site, were manufactured from 1929 to 1977, and thefr presence/use at these sites cannot be excluded. Widespread use of DDT as a pesticide commenced in 1939 (although the compound was created cfrca 1874). The blanket exclusion of Welsbach as a potential source of chemical contaminants is not justified. The potential contribution of the Welsbach site to the contaminated sediments requfres an evaluation.
Response: EPA disagrees that further evaluation of the chemical contamination in the sediments is required under the Superfimd program. The primary contaminants of concem at the Welsbach Site are thorium and radium. If the chemical contamination were related to the Welsbach Site, one would expect that radionuclides would be present in the areas where chemical contaminants were found. The thorium and radium concenfrations were on average, equal to levels found in the background samples in the surface water, sediment, and wetland areas in the Welsbach Site study area.
Coal was extensively used throughout the Camden and Philadelphia industrial region during the 1800s and early 1900s, and elevated levels of PAHs are found in the soils throughout the region. EPA qualitatively evaluated PAHs in the human health risk assessment. EPA evaluated multiple pathways and identified ingestion of fish as the primary pathway of exposure. As described in the Human Health Risk Assessment Addendum, PAHs do not readily bioaccumulate in fish, and therefore, no further quantitative evaluations were necessary.
PCBs were the only non-radiological chemicals of concem identified in the 0U3 Welsbach Site study area that posed an unacceptable risk to human health. As described in the Agency for Toxic Substances and Disease Registry Toxicological Profile for PCBs,
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500049 "... Prior to 1974, PCBs were used both for nominally closed apphcations (e.g., capacitor and fransformers, and heat fransfer and hydraulic fluids) and in open-end applications (e.g., flame retardants, inks, adhesives, microencapsulation of dyes for carbonless duplicating paper, paints, pesticide extenders, plasticizers, polyolefin catalyst carriers, slide-mounting mediums for microscopes, surface coatings, wfre insulators, and metal coatfrigs) (Durfee 1976; EPA 1976a, 1988c; L\RC 1978; Orris et al. 1986; Safe 1984; Welsh 1995)."
These activities were not conducted at the Welsbach or General Gas Mantle gas mantle manufacturing facihties. Furthermore, PCBs were not in wide use when these facihties operated. EPA determined, therefore, that PCBs are not related to the gas mantle manufacturing activities at the Welsbach Site. Therefore, no additional evaluation of PCBs in the surface water, sediment, and wetland areas in the Welsbach Site study area is necessary under the Superfund program. EPA provided the PCB data to NJDEP. NJDEP is currently sfridying the PCBs ui the Delaware River basis under its regulatory authorities.
Although DDT was selected as a chemical of potential concem, EPA determined that it did not pose an unacceptable risk to human health at tiie Welsbach Site. Furthermore, DDT was not in wide use during the time Welsbach and General Gas Mantle operated, and was not identified in soils at the Welsbach and General Gas Mantle facilities.
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500050 ATTACHMENT A
500051 Superfund Program U.S. Environmental Protection Agency Proposed Plan Region II ,<^^^^u.
Welsbach/General Gas Mantle Contamination Site
May 2005 %PROT*^^
EPA ANNOUNCES PROPOSED PLAN Dates to remember: ; • V MARK YOUR CALENDAR This Proposed Plan identifies the preferred No PUBLIC COMMENT PERIOD: Action remedy being considered to address surface May 24-June 23,2005 water, sediment and wetland areas at the Welsbach and General Gas Mantle Contamination Site EPA will accept written comments on the Proposed Plan (Welsbach Site), and provides the rationale for this .during the public comment period. recommendation. PUBLIC METING: June 8,2005 - 7:00 pm The U.S. Envirorunental Protection Agency (EPA) has divided the Welsbach Site into separate EPA will hold a public meeting to explain the Proposed Plan. EPA will also accept oral aitd written comments at the cleanup phases, or operable units. On July 23, meeting. The meeting will be held at EPA's Welsbach 1999, EPA, with support from the New Jersey Field Office at the Old Broadway School, 130 N. Department of Environmental Protection (NJDEP), Broadway, Gloucester City, New Jersey. Prior to the start selected a remedy for Operable Unit 1 (OUl). The of the meeting, EPA will be available from 6:00 p.m. to 7:00 OUl remedy included demolition of the former p.m. to answer questions. General Gas Mantle Building, excavation of the ' radiologically contaminated soil and debris at the For more information, see the Administrative Record at residential, commercial, and industrial properties at the following locations: the Welsbach Site, and disposal of this material in U.S. EPA Records Center, Region II a licensed off-site facility. 290 Broadway, 18* Floor New York, New York 10007-1866 This Proposed Plan addresses surface water, (212)-637-3261 sediment and wetland areas at the Welsbach Site Hours: Monday-Friday - 9 am to 5 pra (designated Operable 3 (0U3)). Additional City of Camden Main Library operable units will address potential remedies for 418 Federal Street the former Welsbach-era building known as the Camden, Nj 08103 Armstrong Building (Operable Unit 2), and the (856)757-7650 groundwater (Operable Unit 4). Hours: Monday through Thursday - 9 am to 8 pm Friday and Saturday - 9 am to 5 pm No Action, as described here, is the preferred Gloucester City Public Library remedy for 0U3. This document is issued by EPA, Monmouth and Hudson Streets the lead agency for site activities, and NJDEP, the Gloucester City. NJ 08030 support agency. EPA, in consultation with (856)456-4181 NJDEP, will select a final remedy for the surface Hours: Monday-12 pm to 9 pm water, sediment, and wetland areas at the Welsbach Tuesday and Friday - 9 am to 5 pm Site after reviewing and considering all Wednesday and TTiursday - 9 am to 9 pm information submitted during the 30-day public Saturday ^ 10 am to 1 pm comment period. EPA, in consultation with NJDEP, may change this preferred remedy if new information or public comments indicate that such EPA is issuing this Proposed Plan as part of its a change will result in a more appropriate remedy. community relations program under Section 117(a) Therefore, the public is encouraged to review and of the Comprehensive Environmental Response, comment on this Proposed Plan. Compensation and Liability Act of 1980, as 500052 amended (CERCLA) and Section 300.430(f) of the from the aerial survey and identified five areas National Oil and Hazardous Substances Pollution with elevated gamma radiation levels. The Contingency Plan (NCP). This Proposed Plan elevated areas included the locations of the two summarizes information that can be found in former gas mantle manufacturing facilities and greater detail in the Final Remedial three mainly residential areas in both Camden and Investigation/Feasibility Study Report (RI/FS) for Gloucester City. In 1993, EPA re-analyzed the Operable Unit 1 (January 1999), the Screening data from the aerial survey. Because of this Level Ecological Risk Assessment (March 2002), analysis, EPA later identified a sixth area in and the Human Health Risk Assessment Gloucester City with elevated gamma radiation Addendum (January 2005), as well as other site- levels. related documents contained in the Administrative Record file for the Welsbach Site. EPA and In the eariy 1990s, NJDEP conducted follow-up NJDEP encourage the public to review these radiological investigations at more than 1,000 documents to gain a more comprehensive properties located throughout the original five understanding of the Welsbach Site and the Study Areas. NJDEP identified radiological Superfund process. contamination at the two former gas mantle facilities and at residential properties located near SITE HISTORY the two facilities.
The Welsbach Site consists of two former gas In 1996, EPA placed the Welsbach Site on the mantle manufacturing sites and numerous National Priorities List (NPL) because of this residential properties in the cities of Camden and radiological contamination. EPA divided the Gloucester City, New Jersey. The companies used Welsbach Site into six Study Areas in Camden and thorium, a radionuclide that emits radiation during Gloucester City (see Figure 1.) A description of radioactive decay, as a part of the manufacturing each Study Area follows: process. Thorium made the mantles glow brightly. • Study Area 1 includes the former GGM Beginning around 1895, Welsbach imported facility and residential and commercial monazite ore as its source for thorium for the gas properties that surround the facility. The mantles In its Gloucester City facility. Just after former GGM facility is located in a mixed the turn of the century, Welsbach was the largest industrial, commercial, and residential producer of gas mantles and lamps in the United section of Camden. States, making up to 250,000 mantles per day. The Welsbach Company appears to have disposed of • Study Area 2 includes the location of the the ore tailings and radiological waste materials on former Welsbach facility and nearby its property and on other properties near the residential/commercial properties. The facility. Welsbach went out of business in 1940. former Welsbach facility is located in an industrially zoned section of Gloucester The General Gas Mantle Company (GGM), located City with residential properties in Camden, New Jersey, was a small competitor to immediately to the east. An original the Welsbach Company in making gas mantles. Welsbach building, the Armstrong GGM operated from 1912 to 1941. There is little building, is still present on the property. information on its activities. It seems that GGM only used refined thorium in its gas mantle • Study Area 3 includes residential and manufacturing processes. recreational properties in Gloucester City, including the Gloucester City Swim Club In May 1981, EPA sponsored an aerial radiological and the Johnson Boulevard Land Preserve. survey of the Camden and Gloucester City area to investigate for radioactive contaminants. The • Study Area 4 includes residential properties survey covered a 20-square-kilometer area in the Fairview section of Camden. surrounding the locations of the former Welsbach and GGM facilhies. NJDEP evaluated the data 500053 • Study Area 5 includes residential cleanup on a portion of the Swim Club property in properties, vacant land, and two municipal 2004. EPA plans to clean up the remaining waste parks near Temple Avenue and the South on this property in the future when additional Branch of Newton Creek in Gloucester cleanup funds become available. City. The third phase involved removal of contaminated • Study Area 6 includes vacant lots in a soil in the backyards and alleyways along residentially zoned area of Gloucester City. Arlington Street in Camden. The Arlington Street properties are adjacent to the former GGM facility. In September 1997, EPA began an RLTS to In January 2004, the New Jersey Housing investigate the radiological contamination at a Mortgage Finance Agency (as part of a number of residential and industrial properties at redevelopment plan for the City of Camden) the Welsbach Site. demolished the homes on Arlington Street. In May 2004, EPA started the cleanup of the radiological In January 1999, EPA finalized the RI/FS, and on contamination in the area around Arlington Street. July 23, 1999, EPA signed a Record of Decision EPA completed this work in August 2004. This for OUl (1999 ROD). EPA stated in the 1999 cleanup will pave the way for the City of Camden ROD that it would address the potential site to redevelop the Arlington Street area. EPA plans impacts to surface water, sediment, and wetland to clean up the remaining subsurface soil areas in the future. contamination in the area around the former GGM facility in a future cleanup phase. In April 2001, EPA started the surface water, sediment, and wetland investigation called for in In October 2004, EPA started the fourth cleanup the 1999 ROD. This Proposed Plan summarizes phase in Gloucester City, on a Study Area 6 the results of this investigation. It also describes property known as the "Popcom Factory". EPA 'EPA's assessment of the potential risk to human plans to complete this cleanup in fall 2005. After health and the environment from the radionuclide EPA completes the cleanup, the Gloucester City contaminants in the surface water, sediment, and Board of Education plans on using this property for •• wetland areas at the Welsbach Site. ball fields for a new middle school that will be built in the area. REMEDIAL ACTIONS IMPLEMENTED TO DATE SITE CHARACTERISTICS
Thus far, EPA's cleanup of the Welsbach Site has As noted earlier, EPA stated in the 1999 ROD that involved four phases. it would evaluate the potential radiological impact to the nearby surface water, sediment, and wetland The first phase involved the demolition of the areas. EPA's first step in this process was to GGM Building in Camden. EPA began demolition identify the ecological characteristics of the area. activities in November 2000, and completed the work in March 2001. The Welsbach Site is located on the westem edge of the Atlantic Coastal Plain in New Jersey in the In March 2002, EPA started the second phase of Delaware River drainage basin. Drainage from the the remedial action, which involved excavation and six Study Areas flows into the following water off-site disposal of radiologically contaminated soil bodies: Newton Creek, its North and South in Study Area 3 in Gloucester City. EPA removed Branches, Big Timber Creek, the Delaware River, almost 47,000 cubic yards (about 70,000 tons) of and Martins Lake. The three forks of Newton radiologically contaminated soil from the Swim Creek ultimately flow into the Delaware River. Club and nearby properties. In January 2004, EPA Martins Lake is an isolated water body located in reassessed the cleanup strategy for these properties Study Area 5. because the size and the scope of the cleanup exceeded the available remedial action funding. Newton Creek and its South Branch generally flow As a result, EPA was unable to complete the west-northwest, and the Delaware River generally 500054 flows south. These surface waters are tidal. The the water bodies adjacent to this Study Area were State of New Jersey classifies Newton Creek and not included in the ecological assessment. the South Branch Newton Creek as "fresh water - non-trout" (FW2-NT). The State has also In Study Area 5, runoff flows into either the South classified Martins Lake as FW2-NT. The FW2-NT Branch Newton Creek or Martins Lake. Runoff water classification refers to fresh waters that are flows into Newton Creek either through municipal generally not suitable for trout because of their storm sewers or as sheet flow along the surface. A physical, chemical or biological characteristics, but portion of the overland flow from Martins Lake are suitable for a wide variety of other fish species. Park empties into Martins Lake. Designated uses of FW2-NT waters include: maintenance, migration, and propagation of the In Study Area 6, mnoff flows into either the natural and established plant and animal life; Delaware River or Big Timber Creek. Runoff primary and secondary contact-recreation; and from this Study Area flows into the water bodies industrial and agricultural water supply, and public either through storm sewers or as sheet flow. potable water supply after treatment. SURFACE WATER, SEDIMENT, AND The State of New Jersey classifies the portion of WETLAND INVESTIGATION the Delaware River adjacent to Study Area 2 as "Zone 3." Designated uses for Zone 3 include Following the ecological characterization, EPA agricultural, industrial and public water supply investigated whether radiological contamination after treatment; maintenance of resident fish and detected in the soils was present in the surface other aquatic life; migration offish; secondary water, sediment, and wetland areas, in and adjacent contact recreation; and navigation. to the Welsbach Site. Radionuclides in the uranium and thorium decay series are the primary Site Area Drainage contaminants detected in land portions of the Welsbach Site Study Areas. Overland mnoff In Study Area 1, mnoff water from rain events ' and/or the storm water collection systems present flows into the Delaware River though the throughout the area could have transported these municipal storm sewer system. In the basement of contaminants into the Delaware River, Newton the former GGM building, there were underground Creek, and the other water bodies of concem. drains that connected to the municipal storm sewer system. In April and May 2001, EPA conducted a surface water, sediment, and wetland investigation in five In Study Area 2, runoff" fromth e residential site of the six Study Areas at the Welsbach Site. The properties and a portion of the former Welsbach main objectives of this investigation were: property flows into the Delaware River through municipal storm sewers. The remainder of the • To determine the presence or absence of overland runoff of water from the former Welsbach radiological contamination in the bottom property is comprised of sheet flow (runoff that sediments of the water bodies where on does not follow a defined channel) that flows shore deposits of site-related radiologically directly into the Delaware River or Newton Creek. contaminated materials were known or suspected. In Study Area 3, runoff flows into Newton Creek through municipal storm sewers or as sheet flow. • To prepare a screening level ecological risk assessment for the radiological and In Study Area 4, runoff flows into either Newton chemical contaminants of concem. Creek or the North Branch Newton Creek. The mnoff from the residential site properties flows • To assess risk to human health and the into the creeks through municipal storm sewers. environment from radionuclides in the Because the radiological contamination in this surface water, sediment, and wetland areas. Study Area is located in very small isolated areas.
500055 WHAT ARE THE POTENTIAL • To provide sufficient data to make either a "CONTAMINANTS OF CONCERN"? "no further action" recommendation or EPA has ideritified several contaminants in the' recommendations for fiirther studies. sediments near the Welsbach Site. These contaminants fall into two categories, those EPA conducted the investigation of surface waters, related to the maiiufacturing process of the sediments and wetlands in Study Areas 1, 2, 3, 5, former Welsbach and General Gas Mantle and 6 of the Welsbach Site. As previously facilities, and those most likely from other discussed, EPA did not include Study Area 4 in industries in the area. this investigation because the soil contamination is in very small and isolated areas. The Welsbach Site-related contaminants of concern are part of the uranium and thorium The investigation included collecting sediment decay chain, specifically radium-226, radium- samples and measuring the water quality in 228, thorium7230, and thorium-232. These Newton Creek (Smdy Area 3), the South Branch radionuclides pose the greatest potential risk to Newton Creek (Study Area 5), Martins Lake human health and the environment at the (Study Area 5), and several storm water outfalls in Welsbach Site; : South Branch Newton Creek and the Delaware River (Study Areas 1, 2, 3, 5 and 6). EPA The Don-Welsbach Site-related contaminants collected 154 sediment samples and 82 water of potential concern foiind in the sediments quality measurements. Both radiological and include arsenic, lead, :benzo(a)pyrene and chemical data were collected. See Figure 1 for an other PAHs, pesticides such as 4,4:'DDE, 4,4'- overview map of the Study Areas. DDT and heptachlor expoxide, and PCBs. EPA also found elevated concentrations of these chemicals in the background samples. EPA collected ten background sediment samples at I locations upstream of the Welsbach Site in Newton In general, the area surrounding the Welsbach Creek and South Branch Newton Creek, as well as Site includes historic and current in North Branch Newton Creek, Little Timber manufacturing facilities that used a variety of Creek and Miller's Lake. chemicals that were not in use or available when Welsbach made gas mantles. This INVESTIGATION RESULTS supports EPA's conclusion that the non- radiological chemicals are not related to the For the radionuclides of potential concem, the WelsbachSite. ^ ^ radionuclide concentrations in the sediments were, on average, equal to levels found in uncontaminated areas in the vicinity of the Welsbach Site (background levels). The average radionuclide concentrations for thorium and potential sources of these non-Welsbach site- radium in both the sediment and background related chemicals found in the sediment. samples were less than 1.2 picoCuries per gram (pCi/g). NJDEP has issued a "do not eat" advisory for fish and shellfish from the Delaware River in the area At all of the sediment sampling locations, EPA of the Welsbach Site. This advisory is based on detected non-radiological chemical constituents in concentrations of mercury, dioxins, and the sediments that exceeded the maximum polychlorinated biphenyls (PCBs) in fish. As part background concentrations and sediment screening of a statewide program, NJDEP periodically guidelines. This information can be found in the collects samples of edible fish and shellfish in Screening Level Ecological Risk Assessment water bodies throughout the state. NJDEP found (March 2002). In the area of the Welsbach Site, elevated levels of mercury, dioxins, and PCBs in heavily developed industrial areas are located near its Delaware River samples. the surface water bodies. These industrial areas are 500056 WHAT IS RISK AND HOW IS rr CALCULATED?
In a Superfund baseline human health risk assessment, EPA analyzes the potential adverse health effects caused by the release of hazardous substances, including radionuclides, from a site. The risk assessment assumes there will be no actions to control or mitigate the releases under current-and future-land uses. The risk assessment evaluates chemicals of concem that are both site related and non-site related. EPA bases its decisions under the Superfimd program on the risk to human health and the environment from site-related contaminants. ,
EPA uses a four-step process in assessing site-related human health risks for reasonable maximum exposure •scenarios. •
Hazard Identification: In this step, the contaminants of concem at the site in varioiis media (i.e., surface water, sediments, and wetlands) associated with the site are identified based on such factors as toxicity, frequency of occurrence, and fate and transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility, persistence, and bioaccumulation.
Eyq)osure Assessment: In ibis step, ihe different exposure pathways through which people may be exposed to the contaminants identified in the previous step are evaluated. Examples of exposure pathways include incidental ingestion of and dermal contact with contaminated sediment, and ingestion offish. Factors relating to the exposure assessment include, but are not limited to, the concentrations that people might be exposed to and the potential frequency and duration of exposure. Using these factors, a "reasonable maximum exposure" scenario, which portrays the highest level of human exposure that could reasonably be expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse health effects associated with chemicaf and radiological exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects (response) are determined. Potential health effects are chemical and radionuclide specific and may include the risk of developing cancer over a lifetime or other non-cancer health effects.
Risk Characterization: This step summarizes and combines exposure information and toxicity assessments to provide a quantitative or qualitative assessment of site risks. Exposures are evaluated based on the potential risk of developing cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancer is expressed as a probability. For example, a 10"^ cancer risk means a "one-in-ten-thousand excess cancer risk"; or one additional cancer may be seen in a population of 10,000 people as a result of exposure to site contaminants under the conditions explained in the Exposure Assessment. Current Superfund guidelines for acceptable exposures are an individual lifetime excess cancer risk in the range of 10"* to 10"* (corresponding to a one-in-ten-thousand to one4n-a-million excess cancer risk). For non-cancer health effects, a "hazard index" is calculated. An HI represents the sum of the individual exposure levels compared to their corresponding reference doses. The key concept for a non-cancer HI is that a "threshold level" (measured as an HI of less than 1) exists below which non-cancer health effects are not expected to occur.
The characterization also identifies risks associatedWith site related and non-site related contaminants. The characterization also considers uncertainties in the components of the assessment including the modeling.
SUMMARY OF SITE RISKS In the 1999 RI/FS, EPA assessed the potential risk As part of the risk assessment process, EPA looks to human health from the radiological at the risks posed by a site to both human health contamination in soil at the Welsbach Site. The and the environment. EPA's risk assessment exposure pathways EPA considered were exposure guidance calls for EPA to consider risk from all to extemal gamma radiation and the inhalation and radiological and other chemical contaminants of ingestion of radionuclides. The potential receptors potential concem regardless whether they are site of concem were workers, trespassers, and resident related. adults and children. EPA found that there was
500057 unacceptable risk to human health for each of the exposure to surface water were not evaluated potential receptors of concem for all of the further. (exposure pathways. EPA identified two categories of RME human In the 1999 ROD, EPA addressed these risks to receptors who might have exposure to human health by selecting a remedy to remove the contaminants of concem in the sediment, fish radiologically contaminated soil and dispose of it (based on modeled concentrations), and in the at an off-site, licensed facility. The 1999 ROD wetlands. The selection of receptors is explained also reconunended that EPA evaluate potential risk in more detail in the Human Health Risk to human health and the environment from Assessment Addendum (January 2005). These radionuclides in surface water, sediment, and receptors are: wetland areas at a later date. • Recreationalists (adolescents 10 to 18 years EPA used sediment data from the surface water, old) who live near the water bodies and sediment, and wetland investigation to evaluate the who may come into contact with sediment risk from radionuclides and chemicals of potential while wading or playing along the concem for both the baseline human health and shorelines. screening level ecological risk assessments. The results of these risk assessments can be found in • Fishers (adolescents, adults, and children the Human Health Risk Assessment Addendum younger than six years of age) who may eat (January 2005) and the Screening Level Ecological fish caught from the water bodies. Risk Assessment (March 2002). Risk Characterization - Radionuclides Human Health Risk The radionuclides of potential concem for the I Exposure Assessment Welsbach Site are the naturally occurring radionuclides in the thorium and uranium decay; EPA conducted the baseline human health risk chains. To evaluate risk from these radionuclides, assessment and focused on the reasonably EPA first collects background radiological samples maximally exposed (RME) individual who would from areas that are not influenced by, or adjacent be spending time on or near the water bodies to, known or suspected areas of radiological adjacent to the Welsbach Site. EPA used models contamination. At the Welsbach Site, EPA to estimate the chemical concentrations in fish collected background radiological sediment (animal tissue) based on the chemical samples at four locations. The average thorium concentrations in the sediments. EPA identified and radium background concentrations ranged sediment and animal tissue as the primary from 0.5 to 1.1 pCi/g. EPA then used these environmental media of concem because sediment concentrations to estimate "background radiation" and animal tissue are or may become, in the future, cancer risks. At the Welsbach Site, the highest readily available for human contact. cancer risk from "background radiation" was within the upper bounds of EPA's acceptable risk EPA evaluated the risks from exposure to the range of 10-^(1 in 1,000,000) to 10^(1 in 10,000). sediments. This analysis found that exposure to the sediments did not exceed EPA's cancer risk After determining the "background radiation" range. Surface water is also an environmental risks, EPA subtracted the background risks from medium of concem. Because of dilution and other the total risk from all sources. For both the factors, the radiological and chemical Recreationalists and Fishers, EPA calculated the concentrations in surface water would be much total cancer risks, minus the background risk, from lower than in the sediments. As noted above, the radiological exposures in the Delaware River, risk from exposure to sediments did not exceed Martin's Lake, and Newton Creek and its EPA's cancer risk range. Since the contaminant tributaries. These risks were also within the upper levels in the surface water would be even lower bounds of EPA's acceptable risk range of 10"* (1 in than those in the sediments, the risks from 1,000,000) to 10-^ (1 in 10,000). The details of this 500058 assessment are in the Human Health Risk linking contaminant concentrations to Assessment Addendum. effects on ecological receptors.
Risk Characterization - Chemical Contaminants • Risk Characterization— measurement or estimation of both current and fiiture EPA also evaluated the non-site-related chemicals adverse effects. of potential concem identified above. Because EPA did not take samples directly from fish, EPA The screening level ecological risk assessment used a model to calculate concentrations in fish focused on aquatic organisms, including fish, and based solely on sediment concentrations. This did not evaluate the potential risk to higher-level model may have over estimated the chemical organisms such as waterfowl, muskrats, and concentrations in fish and the resulting calculated beavers. EPA considered fish as the potential risks. receptors of concem for radionuclides because they have more potential for exposure to radionuclides After evaluating the results of the model and the in sediments than do semi-aquatic birds and risk assessment, EPA found that PCBs are the main mammals. They are also more sensitive to chemical contaminants that exceeded EPA's level radiological damage than bottom-dwelling of concem. Total PCB concentrations ranged from invertebrates. not detected to 14.4 milligrams per kilogram (mg/kg). However, PCBs are not associated with Radionuclide Ecological Assessment the operations at the former Welsbach and General Gas Mantle facilities. Because PCBs are not site There are very few studies on ecological risk from related, EPA will not discuss the risks from PCBs radiological contaminants. Therefore, EPA further in this Proposed Plan. The details of EPA's compared the radionuclide concentrations found in analysis are included in the Human Health Risk the sediment samples at the Welsbach Site to Assessment Addendum. multi-media benchmarks developed by the U.S. Department of Energy's (DOE's) Oak Ridge Ecological Risk National Laboratory (ORNL). The adjusted benchmarks assume that the sediment and surface Similar to the human health risk assessment, EPA water concentrations are in equihbrium, and thus uses a four-step process for assessing site-related consider potential surface water exposure. These ecological risks for a reasonable maximum benchmarks are identified in DOE's 1998 exposure scenario: document titled "Radiological Benchmarks for Screening Contaminants of Potential Concem for • Problem Formulation—a qualitative Effects on Aquatic Biota at Oak Ridge National evaluation of contaminant release, Laboratory, Oak Ridge, Tennessee." Radiological migration, and fate; identification of levels above the benchmark or guideline values contaminants of concem, receptors, would indicate that sediments and surface water exposure pathways, and known ecological could cause harmful impacts to ecological effects of the contaminants; and selection receptors. of endpoints for further study. The results of this analysis indicate that the • Exposure Assessment—a quantitative radionuclide concentrations in sediment and evaluation of contaminant release, surface water are well below the DOE guideline migration, and fate; characterization of levels. Furthermore, all of the sediment samples exposure pathways and receptors; and collected had radionuclide concentrations that were measurement or estimation of exposure indistinguishable from the background radiation point concentrations. levels found in the area. Therefore, EPA has determined that radionuclides do not cause an • Ecological Effects Assessment—literature unacceptable ecological risk at the Welsbach Site. reviews, field studies, and toxicity tests. 500059 Chemical Ecological Assessment chemical contaminants as part of the Welsbach Site remediation. To evaluate the chemical risk to the environment, EPA is aware that the NJDEP has established fish EPA also compared the chemical data from the consumption advisories to address the elevated sediments at the Welsbach Site to guidelines levels of PCBs and other contaminants in fish from developed from various sources. These sources, the Delaware River and its tributaries. EPA including NJDEP guidance on sediment quality recommends that people fishing in the area follow and other ecological toxicity thresholds, are the appropriate fish consumption advisories. identified in the Screening Level Ecological Risk Assessment. EPA has concluded that the radiological contamination from the Welsbach Site does not For a number of chemical contaminants of pose an unacceptable risk to human health and the potential concem, the concentrations in the environment. As a result, EPA recommends that sediments exceeded the ecological guideline levels. no remedial action is necessary for the surface EPA found that the chemical constituents in the water, sediment, and wetland areas at the Welsbach background sediment locations were similar to the Site. samples collected from areas adjacent to the Welsbach Site. Therefore, the ecological risks from SCOPE AND ROLE OF ACTION tiiese chemical contaminants are not discussed further in this Proposed Plan As with many Superfund sites, the problems at the Welsbach Site are complex. As a result, EPA has Conclusion currently organized the work into four phases or operable units (OUs). This is the third of four The primary contaminants of concem for the planned OUs at the Welsbach Site, In the 1999 Welsbach Site are radionuclides in the thorium and RI/FS, EPA assessed the risk from the Welsbach uranium decay chains. The results of EPA testing Site on human health. EPA addressed these risks did not indicate elevated radionuclide in the 1999 ROD. This Proposed Plan addresses concentrations in sediments adjacent to the human and ecological risk to the environment from Welsbach Site. site-related contaminants in the surface water, sediment, and wetland areas. EPA's baseline human health risk assessment found that effects from exposures to the The 1999 ROD selected a remedy for the first radionuclide concentrations in the sediments are operable unit at the Welsbach Site. The remedy within the upper bounds of EPA's acceptable risk included demolition of the former General Gas range. This confirms that there are no adverse Mantle building, excavation of the radiologically impacts to human health from the radionuclide contaminated soil and debris at the residential, levels in the sediments. In addition, the screening commercial, and indusfrial properties at the site level ecological risk assessment results indicate and disposal of this material in a licensed, off-site that the radionuclide concentrations in the facility. sediments are below EPA's level of concem. In the future, EPA will address a remedy for the Although the levels of some chemical second operable unit, the former-Welsbach contaminants of potential concem exceeded the facility's Armstrong Building. In September 1997, ecological guidelines and human health risk levels, Holt Hauling and Warehousing, Inc. (Holt), the these chemical contaminants are not related to owner of the former Welsbach property at that Welsbach and General Gas Mantle operations. time, entered into an Administrative Order on Furthermore, ingestion of the PCBs in fish is the Consent (AOC) with EPA. Under the terms of the main contributor to the cancer risks and AOC, Holt agreed to perform an RI/FS on the noncarcinogenic health hazard. Because PCBs in Armstrong Building (one of the original Welsbach the sediments are unrelated to Welsbach or General buildings). In November 1997, Holt started its RI Gas Mantle operations, EPA will not address these of the Armstrong Building. In January 2000, Holt submitted the RI/FS Report for EPA review and
500060 approval. In July 2000, EPA approved Holt's RI/FS Report. Holt's RI/FS identified sporadic radiological contamination on the stmctural For further information on the Welsbach/General surfaces inside the building. EPA will select a Gas Mantle site, please contact: remedy for the Armstrong Building in the future based on information obtained from Holt's RI/FS. Rick Robinson Natalie Loney The fourth planned operable unit at the Welsbach Project Manager Community Involvement Site will address potential groundwater Coordinator contamination. (212)637-4371 (212)637-3639 [email protected] lonev.natalie(alepa.gov STATE/SUPPORT AGENCY ACCEPTANCE U.S. EPA The State of New Jersey agrees with the preferred 290 Broadway No Action remedy described in this Proposed Plan. New York, New York 10007-1866
COMMUNITY PARTICIPATION
EPA and the State encourage the public to gain a better understanding of the Welsbach Site and the Superfund cleanup process. EPA and NJDEP provide information regarding the cleanup of the Welsbach Site to the public through public meetings, the Administrative Record file for the site, and announcements published in the local newspaper. '
The front page of this Proposed Plan shows the dates for the public comment period, the date, location, and time of the public meeting, and the locations of the Administrative Record files.
EPA Region 2 has designated a point-of-contact for community concems and questions about the Superfund program. To support this effort, the Agency has established a 24-hour, toll-free number the public can call to request information, express concems or register complaints about Superfimd. The Public Liaison Manager for EPA's Region 2 office is:
George H. Zachos Toll-free (888)283-7626 (732)321-6621
U.S. EPA Region 2 2890 Woodbridge Avenue, MS-211 Edison, New Jersey 08837
500061 10 Figure 1- Site Map
Areas 4 Residential Properties
Public Park Grounds X^'^:.^:K^^\ 'SSS^Pife! SOURCE: CAUDBi NJ • UBGS QMMMMAGLE, WELSBACH GENERAL GAS IW^NTLE COr^n-AMINATION $EI^ SITE STUDY AREAS
500062 11 ATTACHMENT B
500063 ^, ..-^^•fr w<». -j^"-^fiyggg* y [^ilM^ll^ « ^. mishostiiigaSa^ojidiu^ spi:^? w«»f !^siiS SjSj Meeting for flieWelsbadi/: p^mliostiiigaFiiybl^^ "^ General Gas Mantle Superfimd Site LVfi-sr-'J The U.S. Environmental Protection Agency invites you to attend a second public meeting to discuss the r|The,|^$toiroi%bitaiffl.vi#mAt;ral Pmtarifigei^^ # to^, ft^attendtoUe'ml«t#beam Proposed Plan to addrras surface water; sediment and addr^'^cai^ei^iaiM^a^ltlcSS^ wetmnd areas at the Welsbach and General Gas Mande Superfimd Site in Gloucester Otj; New Jei^ The meeting will be held at the Camderi County MunidpalUtilities Auditorium ((XMfA) at 1645 ferry Avenue. Camden, New Jersey on Ibesday July 26,2005, at 7:00 PM To request a copy of the Proposed Wan pu can, e-mjdl Nat^e Lonev, Community Involvement CoonHnaton [email protected] or call Natalie: (212) 637-3639 or toll-free at 1-800-3^5009 orvidt EPA's website: ; httpy/www.epa.gov/r^on02/superfand/npVwelsbac h_prc^osal_j)lanJitm The public comment period for this ^posed Bah has been extended to August 2, 2005. All written comments should be mail«l to: > Ridiard Robinson, Remedial Project MaaiagCT U.S. Environmental Protection Agency 290 Broadway; 19th floor New York, NY 100074866 01 o o Or you can e-mail your comments to: o [email protected] ffk
Cmner^Pcsi -- Tu/y XS'r^ooS' Me-n KT^isiT^ii''^'''"'^'^ - —_T?^j :-• .'• ri •—» '••'-• -•'• •'••••*«i—*t-'">i-«i'>»Ai ATTACHMENT C
500065 Page 1 ENVIRONMENTAL PROTECTION AGENCY PUBLIC INFORMATION MEETING % 3 IN RE: 4 WELSBACH/GENERAL GAS MANTLE SITE 5 GLOUCESTER CITY/CAMDEN, NJ 6 7 Wednesday, June 8, 2005 8 9 Transcript in the above matter taken at the 10 former Broadway School, 13 0 North Broadway, Gloucester 11 City, New Jersey commencing at 7 o'clock p.m. 12 13 P R E S E N T O R S: 14 NATALIE LONEY ENVIRONMENTAL PROTECTION AGENCY 15 Community Involvement Coordinator 290 Broadway, 26th Floor 16 NY, NY 10007-1866 (212) 637-3639 17 RICHARD J. ROBINSON 18 ENVIRONMENTAL PROTECTION AGENCY New Jersey Remediation Branch 19 290 Broadway, 19th Floor NY,NY 1007-1866 20 (212) 637-4371 21 MARIAN OLSEN ENVIRONMENTAL PROTECTION AGENCY 22 Risk Assessor 23 24 25
_
Fink & Camey Reporting and Video Services 39 West 37di Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500066 Page 2 1 MS. LONEY: My name is Natalie Loney. 2 I am the Community Involvement Coordinator for the 3 Welsbach Superfund site and with us tonight, as usual, is 4 Rick Robinson, who is the Remedial Project Manager for 5 the site and next to Rick is Marian Olsen. She's the 6 Hiiman Health Risk Assessor. Thank you. 7 Anyway, the purpose of the meeting today is to 8 discuss the proposed plan for 0U3, which is the surface 9 water sediment and wetlands portion of the site. 10 The way these public meetings run, we do our 11 presentation, at the end of which there is a 12 question-and-answeir period. The questions will be 13 primarily regarding the proposed plan that we presented. 14 I know that there may be other questions regarding other 15 portions of the site. I'm just asking that once we 16 complete that portion of it for the administrative record 17 then we can move on to discuss those other questions, 18 okay. 19 We are going to start off, you see, 20 with the introduction followed by background of 21 the site to bring you up to speed on the history 22 of the site. We'll then go into detail about the 23 surface water sediment and wetland study followed 24 by presentation of some of the sampling results. 25 Marian will then talk about the risk assessment. L Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500067 Page 3 1 We will then discuss the conclusion of our 2 investigation and then open up the floor for 3 questions. 4 One t:hing I would ask that you do, 5 and it's a relatively small room so it shouldn't 6 be too difficult, but I ask that you just speak 7 loudly and state your name for the record. 8 I just wanted to go over with you the 9 basic procedure in Superfund and Superfund sites 10 are generally broken down into two phases. 11 The first is the site assessment and 12 the second is the remedial phase. 13 The preliminary is -- the first phase
# 14 or step in the history of a Superfund site is 15 discovery. That can happen. The state can 16 recommend a site for Superfund. We can even -- 17 sites can even be recommended by citizens. And 18 with this site the state spoke to EPA about the 19 Welsbach site and it was -- we continued with an 20 assessment where we looked at the basic site 21 evaluation, we looked at some of the contaminants 22 and a little bit of the history of the site and 23 that information was used in something we call the 24 Hazard Ranking System.
25 Each one of those criteria are given L Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500068 Page 4 1 a score and depending on the score that the site 2 is given it can qualify for the Superfund site 3 list, which is the NPL listing. 4 This site did score high enough 5 within the Hazardous Ranking System and it was 6 recommended for and placed on the Superfund site 7 list. 8 Being placed on that site -- on that 9 list means your site is now eligible for funding 10 under the Federal Superfund Program and Superfund 11 dollars can be used to address the contamination 12 at the site. So now that we've completed the site 13 assessment phase, we have moved into the remedial 14 phase. The site was placed on the NPL and now we 15 conducted a more intensive assessment of the site, 16 a little bit more involved investigation. 17 And what happened during the course 18 of that investigation, which Rick will be going 19 into detail about, is that the results of that 20 investigation, we're proposing that no-further 21 action is required at the site, at this portion of 22 the site, based on those results.
23 If the — in some of the other 24 portions of the site that we have done work in, 25 the soil portion of the site, we did actually go
^^^^X^M^jUfS: Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500069 Page 5 1 through the investigation and feasible study and 2 the results of that investigation indicated that 3 further action was required. 4 We put together a proposed plan. 5 There was a public meeting very similar to this. 6 At the conclusion of that public meeting, we came 7 up with the record or the decision on what action 8 we were going to take to address the contamination 9 and other portions of the site, primary the soil. 10 From the Record of Decision, we moved 11 into the actual design of the remedy, and we 12 ha.ven't yet gone all the way through to the 13 deletion, but portions of the site have been 14 remediated, so I'm going to turn it over to Rick 15 and he's going to go into a little bit more detail 16 about the site history and where we are now. 17 MR. ROBINSON: Thanks, Natalie. 18 I was just going to give you a brief 19 overview, a little bit of the history and then go 20 into a little bit on the study. 21 The Welsbach site was originally 22 identified -- originally started basically back in 23 1885 when an Austrian gentleman named Dr. Carl Van 24 Welsbach invented the process of using thorium in 25 the manufacture of gas mantles, and for those of
cai>.'iifcrf-«.it.>g'-.'a?wgjA»a Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500070 Page 6 1 you who don't know about gas mantles, here's a
» 2 little picture of the mantles from the Welsbach 3 lantern, and what they did is they used thorium, 4 which is a radioactive element and they dipped it, 5 the mantle fabric, in this thorium and it caused 6 the mantle to glow brightly when lit.
7 And in the turn of the 20th century 8 it was competing with the electric light as 9 a source of illumination. 10 In the 1890's the Welsbach Company 11 started up here in Gloucester City, and their main 12 peak -- point of manufacturing of the mantles was 13 around World War I. At the time they had employed 14 over 2600 employees here in Gloucester City and 15 they could make up to 250 mantles per day, and in 16 the early '40s they went out of business. 17 In Camden, there's a much smaller gas 18 mantle manufacturing company and that's called 19 General Gas Mantle. They were in operations from 20 1912 to 1941 and Gas Mantle was a much smaller 21 competitor to Welsbach, and we have little 22 information other than that they made gas mantles 23 and they used and resold radi\am and thorium.
24 The Welsbach site, as Natalie said, 25 was identified as part of the investigation
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500071 Page 7 1 process. 2: In 1980, EPA came across doing a 3 record search of the U.S. radium site in Orange, 4 New Jersey, and there was some literature 5 regarding Welsbach, and as a result EPA then went 6 around and did a helicopter radiological flyover 7 of the Camden and Gloucester City area in 1981. 8 That spawned the New Jersey DEP to come out in the 9 early '90s and investigate over 1100 properties in 10 the Camden and Gloucester City area. 11 As part of the state action, they did 12 a number of interim actions to address immediate 13 health concerns and those actions were basically 14 putting in some steel sheathing, concrete 15 sheathing to shield the radiation and also putting 16 some Radon mitigation systems in some homes. 17 They also purchased two properties 18 and relocated the residents and the business. 19 The site -- we have two study areas, ' 20 two operable units right now out of a total of 21 four that -- where we have a remedy on and the 22 others we are proposing a remedy. 23 Operable unit 1 is the two former gas 24 mantle manufacturing facilities. We have the 25 first one over here at the former Halt facility on
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500072 500073
Page 8 1 Essex Street and King Street. We then have -- 2 we've got the figure. Here it is. 3 You have study area -- the former 4 Welsbach area facility right here. We have the 5 gas mantle manufacturing facility up in Camden and 6 then in Gloucester City we have a number of other 7 satellite areas where the tailings from the 8 Welsbach operation were disposed of. We have the 9 Gloucester Swim Club area. We have what we call 10 the Popcorn Factory where they want to build a new 11 middle school. We have property over off of 12 Temple Avenue and over in the jogging track area 13 of Gloucester City. Then also we have identified 14 a few properties in the Fairview section of 15 Camden. 16 And the soils portion of the site is 17 operable unit one and that mainly consists of 18 residential properties, commercial properties and 19 some municipal park land.
20 Operable unit three, which is the 21 purpose of today's presentation, is the water 22 bodies adjacent to those contaminated areas, the 23 Delaware River, Newton Creek and Martin's Lake.
24 The site was listed on the National 25 Priorities list or Superfund list in 1996 and in
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 Page 9 1 1997 we started the Remedial Investigation i^ 2 Feasibility Study for operable unit one. 3 That RIFS was completed in January of 4 '99 and the Record of Decision was signed in
5 July 1999. 6 The remedy included demolition of the 7 former gas mantle building in Camden, excavation 8 of the radiological contaminated soils at the 9 properties at the Welsbach site and disposal of 10 material at a licensed offsite disposal facility. 11 The ROD also mentioned that the EPA 12 would address the potential site impacts to the 13 surface water sediment and wetland areas in a 14 future study. 15 That study -- that investigation 16 started in April 2001. We completed a screening 17 level ecological risk assessment in March 2002 and 18 in January 2005 we completed a human health risk 19 assessment for the surface water sediment and 20 wetlands. 21 The purpose of this investigation was 22 to determine if the radionuclides from the site 23 contaminated the adjacent surface water, sediment 24 and wetland areas. 25 EPA — and also to evaluate the
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500074 Page 10 1 potential risk to human health and the 2 environment. 3 The s ediment samplings in the area 4 included the Delaware River, Newton Creek and 5 Martin's Lake. 6 There 's a figure on the screen right 7 now that shows one of our sampling transects along
8 the south branch of Newton Creek, although we have 9 the jogging track in this area and Temple Avenue 10 right in through there. 11 As part of the surface water sediment 12 and wetland investigation with radiological 13 contamination, what we do is we have to first 14 conduct a background radiological survey to 15 investigate what the background radiation levels 16 were in the area, and we collected data from five 17 different areas and those are shown on the figure 18 over here. 19 We have the north branch of Newton 20 Creek, the main branch of Newton, over on the 21 south branch of the Newton Creek, Miller's Lake 22 and Little Timber Creek.
23 We collected a number of radiological 24 and chemical samples as part of our investigation 25 and basically it was a limited chemical
^ Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063
500075 Page 11 1 investigation. 2 The primary contaminant at the site 3 is radionuclides, and that's what we are mainly 4 looking at.
5 The sediment sampling results, all 6 the sediment samples for radiological contaminants 7 were within the range of natural background. 8 The chemicals detected in the site -- 9 in the sediment — were not related to the 10 Welsbach site.
11 The sampling data was used for both 12 h\aman health and the screening level ecological 13 risk assessment and these investigation reports 14 are available at the local repositories. They are 15 the Gloucester City Public Library, the Camden -- 16 main Camden Library and also there's a copy at the 17 heart of Camden in the Waterfront south community. 18 I am just going to turn it over to 19 Marian Olsen, EPA Risk Assessor for the site, who 20 is just going to give a brief overview of the risk 21 analysis that we conducted. 22 MS. OLSEN: Thank you. Rick. 23 What I would like to do is just
24 explain the risk assessment process that is used
25 at all Superfund sites.
. Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500076 500077
Page 12 1 What risk assessment does is it 2 provides a framework for us to evaluate potential 3 exposures to contaminants and also to evaluate 4 whether remedial action is appropriate at a site. 5 The risk assessment includes two main 6 components. The first is exposure. How is 7 someone coming in contact with the material, 8 whether it's wading;into the river or swimming. 9 Those are the types of things that would be looked 10 at. 11 We also look at the toxicity of 12 individual chemicals that are found. 13 At this site we also did a separate
» 14 radiological assessment and Nidal is here who 15 basically is the radiation risk assessor for this 16 site. 17 The risk assessment looks at risks in 18 the absence of any institutional controls. For 19 example, at the Delaware River at the current time 20 there are fish, consumption advisories in place 21 which recommend that people do not eat fish 22 because of contamination there, so in our 23 assessment we did not evaluate that., If nothing 24 was happening -- if there were no institutional 25 controls such as fish advisories, what would the
l.-seAiKtM^V^ffi^i'QMMSS'j^^ Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK •* Fax: (212) 869-3063 Page 13 1 risks be in that case. 2 The risk assessment also looks at 3 risks to the reasonably maximally exposed 4 individual. And this is a person whose activity 5 patterns bring them into contact with the river, 6 for example, more frequently than an average 7 person who may be there far less, so we're being 8 protective in making our assvimptions about the 9 exposures. 10 As part of the h\aman health risk 11 assessment, we look at various individuals who may 12 be exposed, so we look at a young child under the 13 age of six. We looked at adolescents who may go 14 to the river and have activities, wading or 15 something there and may be exposed. That would be 16 a group maybe from ten to eighteen years and we 17 also looked at adults. 18 Typically in risk assessments we look 19 at the residents in the area, which is how long 20 would someone be exposed and we include that as 21 part of the assessment. 22 In looking at how people may be 23 exposed, we're dealing with water bodies, so we
24 looked at people potentially eating fish from the
25 river, recreational exposure, wading into the
f^MMeasesX'Si'tinteaMlii^ Fink & Camey Reporting and Video Services 39 West 37di Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500078 .—. 500079 — Page 14 1 river. 2 Those were the types of assessments 3 that were done. 4 We also look at how frequently 5 someone may be there and for what period of time, 6 so all of this is used in the calculation to come 7 up with a calculated risk. 8 As a result of this risk assessment, 9 we basically found that the radionuclides were the 10 primary contaminants related to this site and this 11 was very important in the assessment because they 12 are site-related and we looked at those. 13 What we found were that the cancer 14 risks, the non-cancer hazards for the 15 radionuclides, that's the radiation contamination, 16 were essentially within the risk change and within 17 the Superfund law. There is a specific range that 18 is used to determine whether we're above or below 19 that number and to help make the decisions.
20 We also found that the other exposure 21 pathways that were evaluated also were below — at 22 or below EPA's of level of concern, and what I'd 23 like to do now is turn it back to Rick who's going 24 to talk about another type of assessment.
25 MR. ROBINSON: At EPA, we look at
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 Page 15 1 both h\iman health and risk to hioman health and the 2 environment. 3 As part of the environment risk 4 evaluation, we conducted a screening level 5 ecological risk assessment, and based on the 6 results of all the sampling data, all the sediment 7 data were below the sediment benchmark criteria 8 which indicated that there were no ecological 9 risks. 10 I just want to go through now and 11 just summarize the presentation. We did not find 12 any radionuclides above background levels in the 13 surface water sediment and wetland areas. 14 The human health risks for 15 radionuclides were at or below EPA's level of 16 concern. 17 The ecological risk from the 18 radionuclides were also below EPA's level of 19 concern; therefore, EPA is proposing a no-action 20 remedy for the surface water and sediment and 21 wetland areas at the site. 22 What we'd like to do now, if you 23 would like to submit written comments on this 24 remedy, my name is up there -- name and address .is 25 up there and Natalie's name and address is up
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063
500080 Page 16 1 there. Submit written comments to us by either 2 mail or email. 3 What we would like to do is open it 4 up for questions right now, but while we are on 5 the record for the operable unit three we would 6 like to address the questions relating to this' 7 remedy. 8 If you have other questions relating 9 to the site of what's going on, we would be more 10 than willing to address those questions after the 11 meeting, so if you want to get the light. 12 I will just leave the information up. 13 LANCE COMAS: My name is Lance Comas, 14 C-0-M-A-S. 15 I'm curious to know what the 16 background levels were and what were the 17 concentrations that radionuclides were detected? 18 MR. ROBINSON: This is Nidal Azzam. 19 MR. AZZAM: The background levels 20 were less than one 1.1 PCI, pico curie per gram. 21 We looked at the average 22 concentration of the samples and they were 23 indistinguishable from each area.
24 MR. ROBINSON: Basically what that 25 means is the levels that we found in the sediments
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500081 Page 17 adjacent to the site were the same as the m concentrations we found in the five background 3 areas. We didn't see any difference between the 4 sediment samples collected along Newton Creek -- 5 in the Delaware River outfalls and in Martin's 6 Lake. They were all the same as the background 7 areas for radionuclides. 8 BOB SAUNDERS: Bob Saunders, City of 9 Gloucester. 10 Having read the proposed plan and 11 understanding your scope involves the 12 radionuclides and contamination associated with 13 Welsbach, I understand and read that you also did 14 some chemical studies, but I -- correct me if I'm 15 wrong or I guess maybe perhaps I'm 16 misunderstanding, it doesn't appear that there was 17 a full risk assessment done with the chemicals 18 that were detected. 19 MR. ROBINSON: Marian, do you want to 20 address that? 2i SPEAKER: I fully understand that 22 it's not from the scope of Welsbach. I'm not 23 suggesting it is. 24 MR. ROBINSON: Let Marian explain. 25 MS. OLSEN: We did do a full risk
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Page 18 1 assessment for -- it's called a baseline risk > 2 assessment for the chemicals, and as part of that 3 assessment we looked at ingestion of fish that was 4 potentially contaminated from the river bodies. 5 We looked at ingestion rates for 6 children, young children, adolescents and adults. 7 We did calculate risks from those, but the 8 important thing is that the chemicals that were 9 found were primarily PCB's which have been found 10 in the river system and is the basis for the fish 11 cons\amption advisories and those are not related 12 to the site, and one of the pieces of evidence for 13 that is that PCB's were really not used in the 14 United States until the mid thirties and then 15 through about 1977 when they were banned by the 16. U.S. EPA, so, therefore, they are not related to 17 the activities at the site. 18 MR. ROBINSON: The Welsbach factory 19 went out of business in 1940. 20 SPEAKER: As a point of 21 clarification, I guess, and I'm not arguing the 22 point or suggesting somehow they are associated 23 with Welsbach, but we found this contamination 24 regardless of source and understanding that your 25 scope was pretty much at Welsbach, let's just say
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1 it was ABC Chemical Company in the '40s, who would m 2 request or as part of the City of Gloucester, say 3 I've been directed to request to get that risk 4 assessment done on those chemicals, based on your 5 data it had nothing to do with Welsbach?
6 MR. ROBINSON: We have done the risk 7 assessment. The risk assessment for that is done. 8 You can review that copy of the risk assessment 9 with all the chemical information. It's in the 10 library. 11 SPEAKER: It's relative to the 12 Federal standards or the state standards or both? 13 MS. OLSEN: It's specifically risk- 14 based because there are -- the federal standards 15 for injunction would basically be the Food and 16 Drug Administration's concentrations and those 17 assume an individual would be receiving fish from 18 multiple sources and our risk assessment approach 19 is we look specifically at someone getting their 20 fish meals directly from the river body that we're 21 investigating and that was evaluated in chapter 22 two of the dociunent risk assessment. 23 MR. ROBINSON: Just to let you know. 24 Bob, we have a representative here from NJDEP who 25 after the meeting, if you would like to talk about
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500084 Page 2 0 1 some of the issues she'll be available there to 2 answer any of your question. 3 SPEAKER: I understand and agree that 4 they are not associated with Welsbach. 5 MS. OLSEN: If you would like after 6 the meeting I can show you exactly what and show 7 you the data and how it was analyzed. 8 SPEAKER: Thank you. 9 STEVE MARTIRANO: I'm curious. You 10 mentioned Martin's Lake -- we called it "the 11 pond," how contaminants got in there. Is it 12 flowing underground from some -- the top of the 13 hill or what? 14 MR. ROBINSON: What we found, and let 15 me show you the figure over here. This is 16 Martin's Lake right here. On the north shore of 17 Martin's Lake when we did the remedial 18 investigation back in the late '90s we identified 19 a point on the land portion where there was some 20 elevated readings of radionuclides. It's not a 21 large area. It's a pretty small area. It's three 22 feet by three feet. It's only a couple feet deep 23 and the contamination goes down about a foot and a 24 half to two feet and that's the reason why we did 25 the investigation in Martin's Lake itself to make
Fink &'Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500085 Page 21 1 sure that the contamination that we found on the 2 land portion did not extend into the lake itself 3 or the pond itself.
4 SPEAKER: Now, the only thing you are 5 saying to me, then, they were dumping this stuff 6 all over town at that time? 7 MR. ROBINSON: We found contamination 8 across the street on the triangle property between 9 Clemen Highland and possibly when fill was used to 10 fill in that property somebody may have taken a 11 few shovelfuls and filled in a hole over on 12 Martin's Lake area. That's how we are estimating. 13 SPEAKER: They filled that in. That 14 was basically filled in from stuff from 15 Philadelphia, if I recall right, maybe back in the 16 '40s or '50s sometime. This worries me about 17 spots that flow down that you are talking about. 18 There's got to be other contaminants around. 19 MR. ROBINSON: What we have done, we 20 have done a quite extensive stiidy throughout 21 Gloucester City starting with the aerial flyover 22 and that aerial flyover -- I actually have a copy 23 upstairs and I can show you after the meeting that 24 shows the properties and the regional area where 25 there's contamination. And based on that we have
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500086 Page 22 1 identified a number of properties, and in the 2 beginning designs we then went through old 3 historic maps and looked for where dumping 4 occurred and they matched that up with the 5 radiological flyover and we actually found four or 6 five other properties that were not originally 7 found based on that. 8 SPEAKER: Do you have any information 9 when the dumping quit? 10 MR. ROBINSON: Welsbach went out of 11 business 1940. However, in the late '50s they 12 built the Walt Whitman Bridge. When they built 13 the bridge, they knocked down a niimber of Welsbach 14 buildings. That material, we believe, probably 15 ended up in the jogging track area which was part 16 of a river, so we think a lot of that material 17 ended up in there. 18 Also, we found, based on historical 19 aerial photos, that the triangle property between 20 Clemen Highland, that property there we're seeing 21 dumping as early as the '30s through the '40s, 22 '50s up into the '60s and different generations of 23 waste and from multiple sources.
24 What we also found is in the early 25 '60s when they built the Gloucester City Swim Club
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500087 Page 23 1 they dug the pools out. The pool materials, I was 2 told by the owner of the property, that that 3 material he knows was put on the property he 4 bought later on, so we have material that we know 5 from the swim club area that had radiological 6 contamination was dumped on the property on Clemen 7 Highland. 8 SPEAKER: Yeah, there was a couple « 9 properties torn down on the other side of 10 Broadway. I know they were found to be badly 11 contaminated, too. I know that because my 12 grandfolks worked there. 13 What I'm saying is, I was just 14 curious if this stuff flows through the 15 underground streams or carry-off? 16 MR. ROBINSON: The one thing that's 17 good news about thorium is that it does not 18 migrate. It's a heavy metal. It does not 19 migrate, so the spot where it was dumped, it will 20 not migrate somewhere else. 21 It also has a low partitioning 22 coefficience, which, in laymen's terms, if it gets 23 into the water it doesn't dissolve like into the 24 water. - 25 MR. AZZAM: Thori\am barely moves in
Fink & Carney Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500088 500089
Page 24 1 soil. It doesn't migrate far. It probably moves 2 one inch every five, ten years. 3 SPEAKER: How about water? 4 MR. AZZAM: It doesn't dissolve in 5 the water. 6 SPEAKER: What does it do? 7 MR. AZZAM: It's metal. It just kind 8 of settles in there. 9 MR. ROBINSON: It just — the thorium 10 stays put. The water will flow around it. The 11 thoriiim stays put. 12 SPEAKER: Basically it's a sold metal 13 is what you are speaking of. 14 SPEAKER: Doesn't it radiate out 15 towards whatever is around it? 16 MR. ROBINSON: Would you please state 17 your name for the record. 18 LORRAINE DiCAMILLO: Lorraine 19 DiCamillo.
20 MR. ROBINSON: Could you repeat your 21 question, please?
22 LORRAINE DiCAMILLO: So the thorium 23 is sitting there under water, let's say, I don't 24 know, what, three feet, a foot, whatever. Doesn't 25 it like radiate like out in all different
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK •* Fax: (212) 869-3063 Page 25 1 directions? p 2 MR. ROBINSON: Thorium is a 3 radioactive element, and as part of its 4 radioactive decay process it breaks down into 5 other daughter products. Those daughter products 6 release energies either photons, either Alfa Gamma 7 rays, so that is the decay process. That does not 8 spread. That's from that particle and that emits. 9 SPEAKER: That takes 40 billion years 10 or something? 11 MR. ROBINSON: Well, the half life of 12 thorium is 14 billion years, so the amount of 13 thorium that was put on the earth when the earth
# 14 was created, over half of it hasn't gone away yet. 15 That's why EPA is cleaning this up because this 16 stuff won't naturally attenuate. It won't go 17 away. 18 TRACY GRAHAM: I'm concerned about 19 Martin's Lake. You are talking in this back row 20 people of -- generation after generation of people 21 that swam in Martin's Lake. Three of us did. 22 We're old enough, I hate to admit it, but we swam 23 in Martin's Lake and I remember when that lake -- 24 when there was runoff and now it's running off a 25 lot and dirt runs off with it. How about the dirt
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063
500090 Page 26 1 that runs out with that water? 2 MR. ROBINSON: What we found is that 3 there's just a very small isolated portion on the 4 land -- on the northern shore that there's some 5 elevated readings. It's not widespread throughout 6 it. It's only a couple cubic yards worth of 7 contamination most likely. There's not a lot of 8 contamination there that would pose any risk for 9 the activities that you have described. You would 10 have to be living on the soil for a long period of il time. 12 SPEAKER: Is there any possibility of 13 them removing it? 14 MR. ROBINSON: 'Part of the remedy 15 that we'have selected back in the 1999 ROD was to 16 remove the radiological contamination anywhere we 17 found it on the land portions of the site, and the 18 purpose of this remedy was to discuss whether or 19 not the contamination on the land made it into the 20 water bodies that are adjacent to the site and 21 when we went into this we had no idea knowing what 22 Welsbach did with their waste. Did they dump it? 23 Did it end up in the wetlands or did they just 24 dump it on the land, and it appears that it was 25 just dumped on the land and never made it into the
Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500091 Page 27 1 wetlands. 2 BILL WHITLOW: That speaks to my 3 question which is the basis for your selecting the
4 sites that you did for sampling was because of -- 5 I take what you are saying is you don't expect the 6 thorium to migrate either on the surface or in the 7 water but you picked sites because you thought 8 there might have been dumping there? 9 MR. ROBINSON: There were a number of 10 outfalls from the Delaware River. There were 8 11 storm water runout outfalls that would have gotten 12 any rain water from anywhere involved in this 13 area, the vicinity of Gloucester City. We 0 14 measured all the outfalls in the Delaware River. 15 There's also two outfalls that went into Newton 16 Creek that we sampled. We also sampled adjacent 17 to either potentially contaminated properties or 18 known contaminated properties. 19 There's a property that we call the 20 Kumatzu yard on the north part of Broadway on the • 21 north side of the Walt Whitman Bridge. There's a 22 big empty lot in there. There's potential 23 radiological contamination on that property. 24 We've not confirmed it yet, but when we did our 25 wetland studies, we studied sediments along that
i«iiu^ift™f*t>a«asii::;. 500092 Page 28 1 bank. 2 Also along the swim club adjacent to 3 where the contaminated areas are, we sampled right 4 along those. 5 Over on the land preserved portion of 6 Johnson Boulevard we sampled along the sediments 7 and also down north of Nicholson Road and south of 8 Nicholson Road on the south branch of Newton Creek 9 we sampled through there, so anywhere there was a 10 potential for or we knew there was contamination 11 we took samples of the sediments. 12 SPEAKER: Have you done a subsequent 13 aerial survey to evaluate the radiological 14 activity and compare it to what you saw earlier? 15 MR. ROBINSON: We have not done .16 another aerial survey. What we are doing right 17 now is we are doing field investigations. There's 18 1100 properties that the state looked at for -- 19 within the original five study areas that they've 20 come up with in the early 1990's. We found a 21 sixth area which is now Gloucester City, which is 22 the Popcorn Factory parcel where they want to 23 build a middle school. That's what we call study 24 area six. 25 Within those six study areas there's WJi.ijAii.Vat.-.iilAl-MK'Vii.A-J'i Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500093 Page 29 1 probably over 1200 properties that we — the EPA 2 or the state has looked at, and of those 3 properties our first goal is to study them all 4 with detailed equipment versus a regional kind of 5 a study with a flyover. 6 After we complete those studies, we 7 then clean up those properties. We probably will . 8 not do another confirmatory flyover. 9 If we do one, it will probably be 10 after we complete all the work because when you 11 deal with the radiation you get what's called 12 shine and the shine from a contaminated -- highly 13 contaminated area will block out all the other # 14 contamination around it. You want to remove those 15 higher properties that are contaminated and then 16 you would survey possibly at the end. 17 (At this time, there was an off the 18 record discussion.) 19 MR. ROBINSON: I don't know if that 20 answered your question or not. 21 SPEAKER: Why don't you do a second 22 flyover? 23 MR. ROBINSON: The reason why we 24 don't do another large scale overview is because 25 it won't show you anything different because of Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500094 Page 3 0 1 the shine from the higher properties. 2 MR. AZZAM: The ground survey is more 3 accurate than the flyover. 4 SPEAKER: That's only if there hasn't 5 been any relocation to fill through the original 6 area. 7 MR. ROBINSON: What we have done, we 8 have a record of aerial photography that goes back 9 from 1930 through basically 2 000 was the last one 10 that we flew. 11 We've compared the aerial photography 12 as time went on to see if areas where new dvimping 13 areas went on and where we know where the 14 contamination is. We have not found any 15 additional new dump areas that could have been 16 opened or areas from when we knew contamination 17 was that was moved. 18 SPEAKER: That sounds like you are 19 limiting it to large scale rather than people 20 taking their dirt and moving dirt from one 21 backyard to another backyard? 22 MR. ROBINSON: Well — Doug, do you 23 have anything you want to add to that? 24 Doug is the design engineer for the 25 Army Corps of Engineers and he's doing the design 4fci!ai'«i*siiwi!.-ai«»i>*t«ili; »^ 2 MR. ELLEMA: I think the question at 3 hand is with the aerial flyovers and Nidal has 4 already tested this, that the accuracy for the 5 aerial flyover will not pick up the radiological 6 contamination in someone's backyard, let's say, in 7 a small area of my backyard and it was moved over 8 here. That will not show up under any aerial 9 flyover survey. That's why we were doing the 10 ground-based yard-by-yard type survey where we get 11 the accuracy. 12 If we were to refly this, it will 13 only show the same areas that we already know 14 about, the Popcorn Factory, the aerial over 15 Highland Glen and the large sites with the large 16 amounts of radiological materials. It won't tell 17 us anything different than the big sites that we 18 already know. 19 MR. ROBINSON: What it may do, if we 20 remove the contamination and the large areas are 21 removed, there's always a chance that one would 22 see something smaller show up, so I don't know if 23 we will do that. It's something that will have to 24 be considered in the future. 25 KELLY McNICHOLAS: I have a question Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500096 Page 32 1 about the -- were those, samples outside of the 2 scope of the initial aerial survey? 3 MR. ROBINSON: Which samples? 4 MS. McNICHOLAS: The ones for this . 5 background samples for this part. 6 MR. ROBINSON; Our background 7 samples -- the aerial flyover — actually, I have 8 a copy -- Lisa, can you run upstairs to the 9 bulletin board outside of my office? There's a 10 copy of the aerial flyover up there. 11 The aerial flyover encompassed 12 about -- I believe it was like a 50 kilometer area 13 throughout South Camden, Gloucester City and 14 points east of Gloucester and a number of those 15 areas on -- I believe most of those samples where 16 we took background were within that flyover and 17 after the meeting I can show you the map, and I'm 18 pretty sure that it did include those areas. 19 MS. McNICHOLAS: Was it within the 20 area of concern for that? " My understanding is you 21 took this big picture and then from that big 22 picture you started refining where -- 23 MR- ROBINSON: The aerial flyover in 24 '81 identified probably over 20 different 25 properties that the state went out and field *at!vj*fi5S;i<»i«*^*>>'A-s'J Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500097 Page 33 1 checked, and of those they narrowed it down to t 2 five properties where they identified radiological 3 contamination. And then in the late '90s when the 4 City of Gloucester was planning on doing --buying 5 a property or I guess they already had the 6 property, they were proposing to place -- some 7 kind of a facility on the Popcorn Factory 8 property. They did a study and found radiological 9 contamination on it. 10 We subsequently looked at the flyover 11 and we found that it was shown on there and that's 12 what led us to go back in our design to any 13 potential areas within the Welsbach that had both f 14 elevated flyover readings and a history of 15 dumping% 16 LORRAINE DiCAMILLO: Now, coal tar, 17 that's not radioactive, right? The coal tar is 18 not a radioactive substance? 19 MR. ROBINSON: No. 20 LORRAINE DiCAMILLO: So, was that 21 contamination there from the PSE&G site as well as 22 the thorium? 23 MR. ROBINSON: Well, if you want to 24 just question about the Popcorn Factory parcel, we 25 can answer that after the presentation regarding L •Tn^^^S^Srin^^^SiSSSi Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK •* Fax: (212) 869-3063 500098 Page 34 1 the wetland area. 2 SPEAKER: My understanding suggests 3 from the little bit of research I've done with the 4 Superfund program and radiation is that there is 5 what they call a zero threshhold. How does 6 that -- how does that play into this and are we 7 confident or should we be confident that the 8 sampling sites for the streams are far enough away 9 from where the contamination was to really reflect 10 a background, a true background? 11 MR. ROBINSON: When we select a 12 background location, it's upgradient and it's 13 not -- Mike -^ we selected -- 14 MICHAEL BARONE: My name is Michael 15 Barone. I work for Malcolm Perry, Incorporated. 16 We selected background locations that 17 were upstream of the known areas of contamination, 18 so there's no possible way they could have been 19 contaminated by any radionuclides from the site. 20 MR. ROBINSON: What we found here 21 were similar to statewide averages. 22 MS. LONEY: If there are no further 23 questions, we are going to end the public meeting 24 that's looking at the — 25 SPEAKER: I arrived late. I don't Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500099 Page 3 5 ' 1 know what was covered or if we have any questions 2 on something in particular right now? 3 MS. LONEY: Right now we were just 4 going over the presentation and we were talking 5 about the proposed no action on the sediment 6 surface water and wetland portion of the site. 7 SPEAKER: Are we talking about just 8 the school site? 9 MS. LONEY: No, that's what we are 10 going to do now. 11 So, if there are no further questions 12 about -- 13 SPEAKER: I do have a question 14 because my home is on the list. I was told the 15 contract was awarded to be cleaned up and I was 16 told work was supposed to begin before October. 17 MR.•ROBINSON: That's a different — 18 if you have questions regarding any other issues 19 at the site, we can discuss them after -- if you 20 have questions relating to, you know, the surface 21 water sediment wetlands we'll address those right 22 now while the court reporter is here. 23 LOUISA LEWELLEN: There used to be an 24 overflow pipe coming into Newton Creek right 25 between — on -- just south of the Little League Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500100 Page 3 6 1 field. You can't even see it. If there's 2 anything coming in there through that pipe and I 3 think they took care of Martin's Lake -- 4 MR. ROBINSON: It's still there and 5 we sampled the outflow into the river there. 6 That's one of our sampling points. Actually, it 7 runs from Highland Lake across the property 8 between Clemen Highland, then across the jogging 9 track and enters the south branch of Newton Creek. 10 That's the drainage in the area right now — 11 LOUISA LEWELLEN: Is that pipe still 12 there? 13 MR. ROBINSON: Yes. It's a titled 14 pipe. During high tides it does flow into -- from 15 Newton Creek into Highland Lake and in low tide it 16 flows back out. We sampled the sediments from.the 17 outflow of that pipe as part of our investigation. 18 LOUISA LEWELLEN: We are concerned 19 about the way Martin's Lake is not draining. 20 MR. ROBINSON: Right. 21 LOUISA LEWELLEN: Thank you. 22 SPEAKER: I just have a question. 23 What are the benchmark criteria for the ecological 24 risks? How do you do that? 25 MR. ROBINSON: There's a number of L iiffi(ai«t;;iei^sSK;;ia«sii***c; 2 after the meeting, but if Mike wants to go -- 3 MR. BARONE: They are in the 4 ecological risk assessment report and they are 5 largely based on literature niombers, based on 6 scientific research. 7 SPEAKER: I don't understand what 8 they are. What are the criteria that you used? 9 MR. BARONE: It's basically 10 benchmarks which are protected of ecological 11 receptors meaning benthic organisms, for examples. 12 A benthic organism is an organism 13 that lives in sediment. 14 SPEAKER: So you are looking at just 15 like the health of a standard wetland or something 16 like that? . 17 MR. BARONE: Yes. 18 SPEAKER: Thank you. 19 SPEAKER: Little Timber Creek, that 20 flows quite a ways up. I was wondering -- it goes 21 around past where there used to be a racetrack 22 which was filled in back in the '90s, 1890's, 23 somewheres around there or a little before that. 24 I imagine probably some of that stuff was dumped 25 in there. There was also a gas pump. Fink & Camey Reporting and Video Services 39 West 37Ui Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500102 Page 3 8 1 MR. ROBINSON: We are familiar with I» 2 where the racetrack area is and actually where the 3 racetrack area is it's over closer to Gloucester 4 Point, I guess, and over -- what we found is 5 during the clean up of the Popcorn Factory 6 property we found some old historic maps that 7 showed a tributary that went -- of the Delaware 8 River that was called Indian Run and Indian Run 9 ran right up along where the racetrack area was 10 and up through the Popcorn Factory parcel and then 11 north. That was filled in in the 1890's through 12 the 1900"s and we found some radiological 13 contamination in Indian Run in a couple locations, 14 one at the Popcorn and one across the street over 15 off of 7th Street between Jersey and Charles. 16 Thank you. 17 18 (Hearing concluded.) 19 20 21 22 23 24 25 L I Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500103 Page 39 1 CERTIFICATION 2 3 I, Deborah McNally, do hereby certify that 4 the witness in the foregoing deposition was duly sworn to 5 testify the truth, the whole truth and nothing but the 6 truth in the within-entitled cause; that said deposition 7 was taken at the time and place therein stated; that the 8 testimony of said witness was reported by me, a Certified 9 Shorthand Reporter and Registered Professional Reporter, 10 and was thereafter transcribed under my direction into 11 typewriting, and that this is a true and correct 12 transcript of same. 13 I further certify that I am not counsel 14 for, nor in any way related to any of the parties to this 15 suit, nor am I in any way interested in the outcome 16 thereof. 17 18 Deborah A. McNally, CSR, RPR 19 20 21 22 23 24 25 Fink & Camey Reporting and Video Services 39 West 37th Street * New York, New York 10018 (800) NYC-FINK * Fax: (212) 869-3063 500104 vl July 26,2005 1 '; Page I O.S. ENVIRONMENTAL PROTECTION AGENCY REGION 11 IN REGARD TO THE MATTER OF: WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE -AND- TRANSCRIPT OF PROCEEDINGS MARTIN AARON SUPERFUND SITE OF PUBLIC-MEETING * * * * * TUESDAY, JULY 26, 2005 ***** Transcript in the above matter taken at CAMDEN COUNTY MUNICIPAL UTILITIES AUTHORITY AUDITORIUM, 164 5 Ferry Avenue, Camden, New Jersey, commencing at 7:00 p.m. Certified Shorthand Reporting Services Arranged Through MASTROIANNI & FORMAROLI, INC. 709 White Horse Pike Audubon, New Jersey 08106 (609) 546-1100 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500105 July 26, 2805 Page 2 Page 4 1 APPEARANCES: 1 PUBLIC PORTIONINDEX 2 ENVIRONMENTAL PROTECTION AGENCY 2 3 NATAI m LONEY - COMMUNITY INVOLVEMENT RICHARD CHAPIN: PAGE 40 COORDINATOR - PUBUC OUTREACH BRANCH 3 4 290 BROADWAY OLGAPOMAR. ESQUIRE: PAGE 61 26TH FLOOR 4 ROCiHK NOGAKI: PAGE 72 5 NEW YORK, NEW YORK 10007 5 (212)637-3639 JANENOGAKI: PAGE 80 6 6 RICHARD J. ROBINSON - PROJECT MANAGER BARBARA PFEIFFER: PAGE 93 7 WELSBACH/GENERAL GAS MANTLE 7 290 BROADWAY ROY JONES; PAGE 94 8 19TH FLOOR g NEW YORK, NEW YORK 10007 CHARLES LYONS: PAGE 98 9 (212)6374371 9 10 JOHN PRINCE - EMERGENCY & REMEDIAL RESPONSE BOB SPIEGEL; PAGE 103 DIVISION 10 KFI,LYFRANaS: PAGE 120 n MARTIN AARON 11 290 BROADWAY PETER MONTAGUE: PAGE 125 12 NEW YORK, NEW YORK 10007 12 (212)637-4380 HELENE PERSON: PAGE 135 II 13 14 THEODORE CARRINGTON: PAGE 136 15 14 16 15 17 16 18 17 19 18 19 20 20 21 21 22 22 23 23 24 24 25 25 Pages Page 5 1 PRESENTATON INDEX 1 MS. LONEY: My name is Natalie Loney, 2 WELSBACH/GENERAL GAS MANTLE 2 I'm the community involvement coordinator for the PRESENTATION BY RICHARD ROBINSON 3 Martin Aaron Site, I'm also the community involvement 3 PAGE 9 4 coordinator for the Welsbach/General Gas Mantle 4 MARTIN AARON SUPERFUND SITE 5 Superfimd Site. Most of you are — msybe — many of PRESENTATION BY JOHN PRINCE t 6 you may be aware of the fact that there is another 5 PAGE 18 7 superfimd site in Camden — the City of Clamden, 6 8 particularly in this portion of the — in tiiis 7 g 9 portion of Camden, Waterfront South, there is flie 9 10 general Gas Mantle Facility and since we were coming 10 11 here to talk about Martin Aaron and the proposed plan 11 12 to address contamination at the Martin Aaron Site, we 'l2 13 thought it fitting that we also discuss the woik diat 13 14 is - the proposed plan rather for contamination at 14 15 the Welsbach Site, so this meeting actually will be 15 16 covering both the Martin Aaron Superfimd Site and the 16 17 Welsbach - a portion of the Welsbach Site. 17 18 We're going to start with the Welsbach IS 19 portion and then we'll move on to the - to the 19 20 Martin Aaron portion of the everiing. 20 • 21 We have a - since this is a public 21 22 meeting and we are going to be discussing a proposed 22 23 ' 23 plan, all of this information is being recorded by 24 24 our court reporter, so I would ask that at the end of 25 25 the presentation ^^ilen we do the Q and As that you Pages 2 to 5 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500106 July 26,2005 Page 6 Pages 1 state your name for the record and speak clearly. 1 the preliminary assessment, we now move into I* 2 I've already covered the introduction 2 something called the RIFS, the remedial and 3 portion. This is the agenda for the evening. For 3 investigation and feasibility study. 4 the Welsbach portion of the presentation. Rick 4 What that basically is is we go out and 5 Robinson, wiio is the remedial project manager for the 5 gather information, actually go to Ae site and do 6 Welsbach Site, will be coming to talk about — talk 6 pretty extensive investigation, sampling, that sort 7 about — give you flie information about the projxjsed 7 of thing and that information helps us to determine 8 plan for Welsbach. 8 the nature and extent of the contamination and that 9 I wanted to go over with you all 9 information is the basis for the proposed remedial 10 briefly, it looks a little bit confiising but it 10 action plan which is what we're talking about this 11 really isnt, this is the milestones in the siq>erfimd 11 evening. 12 process and I just wanted to talk briefly about where 12 The proposed remedial action plan, once 13 we came from and wiiere we are with regard to the- 13 we've defined the nature and extent of contamination 14 to. the continuum of the life cycle of a superfimd 14 at the site, we then have to figure out well, what's 15 site. 15 the best way of addressing it, what's the best way of 16 Initially, there's a — >*iienever a 16 cleaning up the site. 17 superfimd site comes into existence, it usually 17 We put together this document that looks 18 starts off with discoveiy. Many times a site might 18 at available technologies and what is die best 19 be identified by a state entity, the New Jersey 19 approach to addressing contamination at any 20 Department of Environmental Protection, sometimes it 20 particular site. 21 may even be a concerned citizen that notifies EPA and 21 Tonight, we're going to be presenting 22 we begin an investigation and we may — it may 22 that proposed plan, that proposed remedial action 23 actually turn out to be something more and may become 23 plan, what does EPA Aink is the best way to address 24 a superfimd site. 24 the cleanup. And we're going to be talking about the 25 Once a site discovery takes place, we go 25 Martin Aaron Site and in addition the Welsbach Page 7 Page 9 \^ 1 through something called a preliminary assessment and 1 Facility. 2 a site inspection. What h^pens in the preliminary 2 Once we've completed this proposed 3 assessment is that we begin to collect any available 3 remedial action plan, there will be a document 4 data and information about any known or suspected 4 forthcoming called the record of decision. That is 5 releases at that facility. The technical phase 5 the document that says, well, EPA — we — ftisi s 6 follows the site inspection v/here we actually go out 6 the — this is what we believe is the best remedy, 7 and do preliminary inspection of the site. 7 this is the decision that has been made out of 8 That information is put together in 8 those - the series of alternatives for cleanup, this 9 something — and we go through something called a 9 is the one that has - we've decided oa 10 hazardous ranking ~ hazard ranking system. That- 10 Once we've made our decision as what — 11 that information, gleaned from the information search 11 how to clean up the site, we then go into Ae latter 12 in the site inspection, each site is scored and once 12 phases ofremediationofa site, actually designing 13 it gets a particular number, it then qualifies for 13 Aat particular -that particular cleanup and then 14 and is then listed on the >JPL, the National 14 moving on to actually building it, w^iatever — or 15 Priorities List, which is a list of all of the 15 whatever flie — whatever the selection is. If it 16 superfimd sites in the country. 16 requires construction on site or off site, thaf s 17 Martin Aaron has gone through this 17 this phase. 18 process and — both Martin Aaron and Welsbach have 18 We then - once we've gone through all 19 gone through this process and they were both listed 19 of th|f;and the actual cleanup begins, goes into the 20 on the NPL making them federal superfimd sites, they 20 operaiion & maintenance mode. For some sites, the— 21 then become eligible for superfund dollars. 21 once it goes through O & M and the contamination is 22 Once we go through the site assessment 22 cleaned up from a particular site, that site then 23 phase and the site is listed as a superfimd site, we 23 becomes eligible for deletion off the of the 24 then move into the remedial phase or the cleanup. 24 superfimd list 25 We - once the site is listed, we've ah-eady begin 25 It then is removed from the list, if s Pages 6 to 9 [email protected] Mastroiarmi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500107 July 26, 2005 Page 10 Page 12 L 1 no Icoiger listed as a superfund site. It is, for all 1 radiological flyover identified five areas in Camden 2 intents and purposes, a clean site. 2 and Gloucester City wiA elevated radiological 3 So from discoveiy, through the 3 readings. 4 preliminary inspection, through listing, fromlistin g 4 Then in Ae early'90s, Ae Stale of New 5 to designing the remedy,t o implementing Ae remedy, 5 Jersey came out and investigated over 1,100 6 to cleaning up and finally deletion of Ae site from 6 properties m boA communities and as a result of 7 Ae siqjerfimd list 7 Aose investigations, Aey did a number of interim 8 And tliis - let me go back for a second. 8 actions such as moving out Ae current owner or Ae 9 I'm going to turn over Ae podium to Rick Robinson, 9 owner at Ae time of Ae Gas Mantie building in 10 he's going to be presenting, again, on Ae 10 Camden, Ste-Lar Textiles, and relocated Aem and Aey 11 Welsbach/(jeneral Gas Mantie Facility. 11 also put shields in basements and - and relocated 12 I just want to let you know, again, Ae 12 one resident in Gloucester City. 13 way Ae evening will move forward, we'll do Ae 13 After Ae state did Aeir interim 14 presentation on boA sites. At Ae end of Ae 14 actions, Aey decided Aat Ae list - Aat Ae site 15 presentations, we'll open Ae floor for questions. 15 was a little bit larger Aan Aey could handle 16 Again, please speak — state your name for Ae record 16 Aemselves and so Aey proposed it to Ae NPL. 17 and please speak clearly for Ae court reporter. 17 The Welsbach Site is currently four 18 MR. ROBINSON: Thanks, Natalie. 18 operable units. Operable Unit 1 includes Ae remedy 19 Again, my name is Rick Robinson, I'm Ae 19 for Ae cleanup of Ae boA gas mantle facilities, 20 project manager for Ae Welsbach/General Gas Mantle 20 Ae residential properties, commercial properties and 21 Superfimd Site. Welsbach/General Gas Mantle Site is 21 some municipal park properties and Aat ROD was 22 located in Ae cities of boA (Camden and Gloucester 22 signed in July 1999 and Ae cleanup for Aat work is 23 City, riljustshowyoum^ in a few minutes. 23 currently underway. 24 Little bit on Ae site histoiy. Backiri 24 Today, we're here to talk about OUS 25 1885, Dr. Carl Vaughn (phonetic) or Welsbach invented 25 which is Ae surface water bodies adjacent to Ae Page 11 Page IS 1 Ae process of manufacturing gas mantles using 1 Welsbach Site, Ae Delaware River, Newton Creek and a 2 Aorium and what Aorium does, it makes Ae manties 2 small lake in Gloucester City called Martins Lake. 3 glow brightly and gas mantles, as shown in Ae 3 Here's a site photograph, aerial 4 picture here, gas manties are Ae — like in a 4 photograph, showing Ae site. There's Ae two study \ 5 camping lantern and wlien you — when Ae gas gets in 5 areas in Camden. Waterfront SouA we call Study Area 6 Acre, it lights up wiA bright white light 6 1, we have Ae Fairview section of Camden which is 7 And back at Actum of Ae century, 7 Study Area 4 and Aen we have four study areas in 8 Aey were ~ Aey were used as - in competition wiA 8 Gloucester City. 9 electric light until electric light basically put Ae 9 Here's a closeup aerial of Ae Study 10 gas mantle industry out. 10 Area 1 in Camden, currently we are at CCMUA right in 11 But Ae Welsbach Facility is located in 11 here, Ais is Feny, this is Broadway. Over SouA 12 Gloucester City off of Essex Street and along King 12 4A and Jefferson is Ae former gas mantle facility 13 Street and in 1890s, Aey started manufacturing Ae 13 in yellow and up in Ae blue in Ae right-hand comer 14 gas manties and by 1940, Aey went out of business. 14 of Ae map is Ae Martin Aaron Facility. 15 And in Camden, over on 4A and Jefferson 15 And as we were doing our background 16 is Ae General Gas Mantie Facility and Aat was a 16 investigation to collect some background samples, we 17 much smaller competitor to Ae Welsbach Facility. 17 collected some samples up in Ais area which we 18 Little information on General Gas Mantle is really 18 happened to find some radiological contamination Aat 19 known. We know Aat Aey used and resold radium and 19 appears to be related to Ae General Gas Mantle 20 Aoriiun, Aey did not process any ores as did 20 Facility. We're currentiy investigating Aat right 21 Welsbach. 21 now. 22 The site was originally identified in 22 The 1990 ROD remedy included demolition 23 1980 v^en Aey did a record search of Ae U.S. radium 23 of Ae former gas mantie building in Camden, 24 site in Orange, New Jersey and Aen in 1981, EPA 24 excavation of Ae radiological contaminated soils and 25 sponsored an aerial radiological flyover and Aat 25 debris at Ae Welsbach Site and disposal of material Pages 10 to 13 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500108 July 26, 2005 Page 14 Page 16 1 at an offsite landfill. 1 water sediment and wetiand areas, Ae human healA i» 2 In Aat ROD, EPA also stated Aat what 2 and ecological risks from Ae radionuclides were at 3 addressed potential site impacts to Ae surface water 3 or below EPA's level of concem and, Aerefore, EPA 4 sediment and wetlands area in a fiiture study. And in 4 proposed no action for Ae surface water and sediment 5 . April200I, we started Aat study. We completed an 5 in wetland areas at Ae site. 6 ecologica] screening level assessment in March 2002 6 And Aat concludes Ae Welsbach 7 and in January 2005, we completed a human healA risk 7 presentation. 8 assessment for Ae surface waters, sediment and 8 MS. LONEY: Comment period. 9 wetiands. 9 MR. ROBINSON: Oh, yes. What we have 10 The ptirpose of Ae investigation was to 10 done is we extended Ae Welsbach public conmient 11 detemiine if Ae radionuclides from Ae site 11 period for OU3 until August 2,2005, we have copies 12 contaminated Ae adjacent water bodies and evaluate - 12 of Ae proposed plan at Ae table and you're to 13 Ae risk to human heal A and Ae environment The 13 submit written comments to myself or Natalie Loney 14 sediment sampling areas included Ae Delaware River 14 and our names are in Ae — and addresses are in Ae 15 storm water out falls, Newton Creek, and a small like 15 proposed plan also. 16 in Gloucester City. 16 On Aat note, I'd like to turn it back 17 EPA also collerted background samples as 17 to Natalie and I'll switch Ae presentations. 18 part of its investigation and we collected background 18 MS. LONEY: Thank you. Rick. 19 samples from Newton Creek, Ae north branch of Newton 19 Now, we're just - we're going to move 20 Creek, souA branch of Newton Creek, Little Timber 20 ahead and talk about Ae Martm Aaron Superfund Site 21 Creek and a small lake in — I think it's called 21 proposed remedial action plan. 22 Millers Lake, small lake called Millers Lake, it's 22 Part of what we do at EPA, particularly 23 souA — souAeast of Gloucester City. 23 around superfund sites, includes community 24 As part of our sediment sampling, we 24 involvement v^ich is what my role is. Part — if s 25 collected sediment and radiological and chemical 25 important for us to hear Ae concerns of a community. Page 15 Page 17 # 1 samples in Ae Delaware River, Newton Creek and Ae 1 Aaf s why we obviously have a public meeting, in 2 background areas. And Ae results of Aat samplmg 2 addition copies of Ae proposed plan are available to 3 indicated Aat all Ae radiological samples we 3 you. Acre was a — a mailing was sent out, Ae 4 collected in Ae sediment areas were all wiAin Ae 4 proposed plan can be accessed online, I did receive 5 range of backgroimd. 5 some calls from folk wiio wanted a hard copy mailed to 6 The chemicals Aat we found in Ae 6 Aem, I did Aat as well, so Aere is an^le 7 sediments were not related to Ae Welsbach Site and 7 opportunity, apart fromthi s evening, to review Ae 8 Ae sample data from ~ sample data Aat we collected 8 document at lengA and submit your comments to us. 9 was used for boA human healA and screening level 9 The comment period for Ae Martin Aaron 10 ecological risk assessments. And Aese reports are 10 proposed plan is - starts July 15A and it ends 11 available at Ae local information repositories, Ae 11 August 15th, so after this evening — after we've 12 Gloucester City Library, Ae (Camden Public Libraiy 12 done — completed our presentation, even if you 13 downtown and also Ae Heinz Center here in Ae 13 aren't — unable to make a comment tonight, but you 14 Waterfront SouA community. 14 have an opportunity to do so at a later date, you can 15 To summarize risk assessment, Ae 15 submit comments to myself and we'll give you Ae 16 exposure paAways, the cancer risk and non-cancer 16 information for Ae RPM for Ae site, Mark Austin, 17 hazards for all Ae radionuclides were vrithin EPA's 17 boA of our names, addresses, phone numbers and 18 risk range or below EPA's level of concem and Aat 18 E-mail addresses are on Ae proposed plan and you 19 Ae sediment samples were ~ for Ae ecological risk 19 could send comments to us eiAer tonight or you can 20 assessment, Ae sediment samples were also below Ae 20 E-mail or mail us your comments. 21 sediment benchmark criteria and Acre were no 21 In addition, copies of Ae proposed plan 22 ecological risks. 22 are available at Ae C^amden Public Library and if s 23 So to summarize Ae Welsbach 0U3 23 available in Waterfiunt SouA at Ae Heinz Center. 24 investigation, we found no radiologicals — 24 These are some of Ae names of people 25 radionuclides above background levels in Ae surface 25 who you can contact for additional information about Pages 14 to 17 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500109 July 26, 2005 Page 18 Page 20 1 Ae Martin Aaron Site, John Prince, who will be doing 1 So in context, we saw from Rick's > 2 Ae presentation this evening, he is Ae section 2 presentation, Aat Ae — Ae — this section of 3 chief, Mark Austin is Ae - Mark Austm is Ae 3 Waterfront SouA includes, as he highlighted, several 4 remedial project manager of Ae site, I think you're 4 properties Aat are associated wiA Ae Martin Aaron 5 familiar -with this name, Aat's me, and Ae site 5 Site. 6 attorney is Michael Van — I always pronoimce his 6 The two lots Aat are highlighted here, 7 namely incorrectly, so I'll just say Michael. You 7 and we'll look at m much closer detail, are on each 8 could also contact him. 8 sideofBroadway, one is where a company called 9 If you - if you cant get all - you 9 Martin Aaron and several oAer drum reconditioning 10 dont have to worry about jotting down all this 10 facilities operated and Aen Acre's property across 11 information right now, we can provide you wiA it at 11 Ae street Aat's owned by Ae SouA Jersey Port 12 Ae end of Ae meeting. 12 Corporation, it's also known as Ae Lika (phonetic) 13 I did make mention of where you could 13 property and it was also a subject of EPA's 14 get additional information about Ae site. The 14 investigation because at one time, Martin Aaron, Ae 15 information repositories, if you happen to be m New 15 company, leased Aat property, so it became within 16 York City, you could pay us a visit at 290 Broadway, 16 Ae scope of Ae investigation for Aat reason. 17 we have all of Ae documentation associated wiA work 17 For Ae Martin Aaron Site, we looked at 18 at Ae site Aere, in addition Acre's Ae library in 18 oAer areas, too, as you vrill see in Ae 19 Camden and also in Ae Heinz Center. 19 investigation. Now, one obvious question Aat— 20 In addition, Ae proposed plan is on the 20 Aat comes to mind when you look at a little property 21 EPA web page and you can access Aat at home or if 21 Aat involves a few Jots as identified here is why is 22 you don't have computer access, you can go to your 22 Ais site relatively small when Ae Welsbach site and 23 local library or you could take a hard copy of Ae 23 Ae General Gas Mantie Site was - seemed to spread 24 document wiA you Ais evening. 24 into a number of different areas and Ae distinction, 25 I'm going to turn over Ae clicker and 25 you'll see, comes from Ae types of operations Aat Page 19 Page 21 1 pointer and magic wand to John Prince and he's gomg 1 took place Aere. 2 to be discussing Ae proposed plan for Martin Aaron. 2 The size of Ae Aorium sites is 3 MR. PRINCE: Thank you, Natalie. 3 substantially derived from wiiat Aey were doing. 4 I would like to mention wiA regard to 4 They brought ore in that had Aoritmi in it, for 5 Ae public comment period that we have received a 5 instance, and Aey needed to mill it and remove Ae 6 request for an extension to Ae Martin Aaron public 6 Aoriumforuseand Aen Aey had lots of ore left 7 comment period and we're evaluating Aat request and 7 over and Aat ore kind of went all over Ae place 8 if- if the comment period is going to be extended, 8 and, hence, Aat sort of reflectsA e size of that 9 it will be in an announcement in Ae newspaper, so we 9 site. 10 will — we will make that information available if, 10 I'll go through some of Ae histoiy here 11 indeed, Ae comment period is to be extended beyond 11 and you'll see if s a little bit more localized, a 12 August 15A. 12 little bit more concentrated on Ae lots Aat we 13 Now, we have, wiA regard to Martin 13 really focused on. 14 Aaron, a lot of information Aat I might present and 14 Now, we've narrowed down to primarily 15 Ihavelotsofslides Aat detail a number of 15 Ae Martin Aaron lot which is this one sort of in Ae 16 different aspects of a relatively complex 16 middle of this block which is surrounded by Broadway, 17 investigation, I'm going to try and call it down to a 17 Jackson, 6A Street and Everett. The SouA Jersey 18 reasonable amount of information for a couple of 18 Port Corporation property is over here across 19 reasons, one, so that we can get to the questions and 19 Broadway and Aere are couple of oAer landowners in 20 comments part of Ae evening which, frankly, tends to 20 this area or separately owned lots. A property Aat 21 bring out Ae ~ what we might have missed anyway in 21 we refer to as a scrap yard immediately to Ae north 22 the presentation and it's why many of you are here 22 of Ae Martin Aaron lot, a currentiy operating meat 23 and, in essence, what I'm doing is summarizing 23 processing facility Comarco and Aen Ae Ponte 24 information that is also available in the proposed 24 Equities Property also immediately to Ae souA down 25 plan. 25 here where Aere is several large buildings. Pages 18 to 21 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500110 July 26, 2005 Page 22 Page 24 1 1 will note on Ais map Aat - and 1 removing some of Ae facilities Aat were used to 2 you'll see this in more detail in Ae proposed plan 2 reconAtion or clean up Ae drums and Aen do some 3 Aat Aere is a building here Aat has a sort of a 3 fencing and put up some signs so Aat people knew 4 reverse "L" shape Aat appears to be two separate 4 Aat accessing this property posed some kind of a 5 buildings because Acre's a property line Aat runs 5 risk and it reached Ae property to a point wiiere 6 down Ae middle of it 6 Aese immediate risks were really adAessed short of 7 In fact, Aose buildmgs were - Aat 7 someone trespassing on to Ae fenced off properties. 8 building was all built apparently at one time and 8 Also, during this period of time, Ae 9 Aen some time later, Ae lots were broken up 9 City of Clamden concluded Aat Ae Martin Aaron 10 differentiy and a lot line appears to go right down 10 building itself just wasnt - wasnt likely - it 11 Ae middle of it, and Fll clarify some of Aat by 11 posed risks, physical risks, and so Aey had Aat 12 going into some of Ae — some of Ae history. 12 building demolished wiA EPA's sort of oversight to 13 A lot of information here, even more in 13 make sure Aat it was done appropriately. 14 Ae proposed plan, Tm just going to hit on a couple 14 And during Aat same time wiien all Aese 15 of Ae highlights. The-Ae main sort of central 15 emergency activities were taking place, EPA, at DEP's 16 part of Ae facility, this part where it says Martin 16 request, evaluated Ae site for Ais National 17 Aaron, Inc. was originally a taimery, Ais is going 17 Priorities List or this superfund list and Ae 18 back mto Ae 1880s at least and maybe earlier and it 18 conclusion was, yes, Aere was enough residual 19 was used for tannery operations probably mto Ae 40s 19 . contamination Aere after Aese emergency response 20 and Aen related operations into — into Ae '60s. 20 activities Aat were unknown Aat it qualified for 21 A subsequent site use was related to 21 Ae superfund list and Aen it went Arough Ais 22 Martin Aaron, Inc. which was a company Aat would 22 process of evaluating Ae extent of contamination and 23 accept drums Aat were empty or also almost empty 23 Ae process of Aen evaluating what sort of remedies 24 from various facilities, would clean Aem out and 24 would be appropriate to come to sort of a final 25 would recondition Aem, paint Aem and make Aem 25 resolutions for Ais site so it could be cleaned up. Page 23 Page 25 l» 1 available for reuse. Martin Aaron was one of several 1 so it would be protected for Ae community and Aen 2 companies that operated Aere. They happened to be 2 Aat — so Aat it could be reused. 3 Ae one Aat got saddled wiA Ae name. There was 3 And Aat brings us to — really to our 4 anoAer name of Ae site. There was anoAer company 4 site investigation. We did a soil investigation 5 called Rhodes Drums Aat operated in, in essence, Ae 5 looking for oAer buried material Aat we might have 6 part of Ais building Aat sticks out into Martin 6 missed evaluating Ae one standmg builAng, what we 7 Aaron, Inc. on to that property. 7 call Ae Rhodes building to Ae degree Aat we could 8 We've also drawn in or shaded in where a 8 and Aen collected soil samples and Aose soil 9 building Aat was owiied and operated by Ae Martin 9 samples were on Ae - Ais block encompassing Aose 10 Aaron Company was located on Ais map. There is some 10 various lots Aat we talked about before and Aen 11 oAer businesses in Ae area Aat may have jdso 11 Aey were also on Ais SouA Jersey Port Corporation 12 contributed contamination to Ae area in general, 12 property because of, as I had mentioned earlier, 13 maybe some of it is on these lots as a result, but 13 Martin Aaron's, the compan/s, use of Aat &cility. ] 4 it's primarily based on Ae studies Aat we 14 Now, it appears Aat Aey used it only 15 performed, Ais tannery operation and Aen Ae 15 to store drums Aat were Aen processed across Ae 16 subsequent drum reconditioning operation Aat we 16 street and its Ae really — apparently Ae 17 focused on, EPA focused on, because Aat's where Ae 17 processing ~ Ae cleaning up process Aat ended — 18 contaminant ~ contaminants pointed us. 18 that is related to Ae spills. 19 The drum reconditioningoperation s ended 19 And so one of Ae conclusions of EPA's 20 in Ae 1990s and, unfortunately, as wiA many sites 20 investigation was, yes. Acre's some contamination oni 21 of this nature, it didn't endvety neatly, there were 21 SouA Jersey Port, it was a little difficult to 22 a number of drums left over, some buried material and 22 determine whether, in fact, it was really ' • 23 Aat's when firstDEP , Ae state, and Aen EPA got 23 attributable to Aese various operations Aat took 24 involved in first addressing emergency conditions, 24 place across Ae street at Martin Aaron or even from 25 removing hazards Aat were immediate, removing drums. 25 Ae tannery operation Aat was some years earlier. Pages 22 to 25 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500111 July 26, 2005 Page 26 Page 28 1 One aspect of our investigation was 1 Ae sort of center of this Martin Aaron Facility > 2 collecting borings, so we'd collect surface samples, 2 wiiere Acre's some sort of different colored markings 3 deeper samples of soils and Aen send Aem off to Ae 3 is sort of Ae center of Ae tannery operation and 4 laboratory and also evaluate sort of Ae strata, Ae 4 also pretty much Ae center of Ae subsequent drum 5 sorts of soils Aat we foimd. 5 reconditioning operation. 6 One of Ae Aings Aat we found 6 Now, drum reconAtioning coul^ be 7 throughout Ais entire area is Aat Aere is a layer 7 anything because Aey bring in 55-gallon drums from 8 of fill material, manmade material, Aat probably 8 just about any facility Aat might have Aem to get 9 started coming in around Ae 1860s. Earlier Aan 9 rid of and so what we found Aere, wivat we might have 10 Aat, Ais was pretty much swampy land and wasn't 10 seenissortofw4iatwe-v\iiatwefoundalotof 11 really available to be used, but apparentiy as Camden 11 different contaminants of various groupings, some 12 expanded, Ais sort of material started to come into 12 pesticides, some PCBs, some metals, some of this 13 Ais area and pretty much everywhere we looked, we 13 arsenic contamination very well may be attributable 14 found Ais sort of layer of fill, it's not very 14 to some of Ae drums, some of Ae PAHs may even be 15 surprising in an urban area and Aere tend to be some 15 attributabJetosomeofAe drums Aat came in, but 16 contaminants in Ais sort of fill material, ifs not 16 Ae primary Aing Aat we found Aaf s clearly 17 very surprismg. 17 associated wiA Aese drum reconditioning operations 18 And New Jersey, actually, has done some 18 are volatile organic compounds or industrial type 19 evaluationsofvariousareasofAe state Aat are 19 solvents and Aese we found in abundance, again, sort 20 mostly urban and has identified some areas Aat Aey 20 of in Aese same areas and we've highli^ted on Ais 21 call containing historic fill, it was brought in many 21 figure, which is reproduced m Ae proposed plan, 22 years ago making Ae land useable, Aere are some 22 some areas where we found levels of contamination 23 consequences to Aat and Ais is one of Aose areas 23 eiAer arsenic or Aese VOCIs or volatile organic 24 Aat Aey have identified as containing Ais sort of 24 compounds at levels Aat are clearly much higher Aan 25 historic fill. 25 could be attributable to any sort of urban fill type Page 27 Page 29 1 In taking Aese samples, we also 1 setting and they're clearly associated wiA 2 identified some areas of contamination Aat are 2 operations Aat took place at this facility. 3 clearly associated wiA Martm Aaron and probably 3 One of AeoAer conclusions, Aough, 4 some contamination Aaf s associated wiA Ae earlier 4 Aat we Aew was not really what we found at Ais 5 tannery operations. 5 SouA Jersey Port Ck)rporation property. New 6 Now, Aere is sort of two different - 6 Jersey - Ae State of New Jersey ^proached EPA wiA 7 completely different operations, Ae tanneiy would 7 regard to Aat property and said, you know, we Aink 8 have used, in particular, a lot of pesticides because 8 Aat you might consider Aat really Aat facility, 9 Acre's meat products and Acre's hides and Acre's 9 vAile it may have been used by Martin Aaron, doesnt 10 all sorts of opportimities for rats to be encouraged 10 really have Ae same character, it doesnt seem to - 11 to come into a tanneiy area and so Aere are ~ Ae 11 Fm going to talk about groundwater in a minute, but 12 use of arsenic base pesticides is pretty consistent 12 it doesnt really seem to have Ae groundwater 13 WiA a tanneiy facility. 13 contamination component Aat, again, is associated 14 AnoAer Amg that's frequently 14 wiA Aese really high levels mAe middle of Ae 15 associated vriA a tanneiy facility is Aat Aey need 15 Martin Aaron Site, so Aere are oAer WjtyS to address 16 to dty Ae hides and so Aey would need to heat large 16 sites and one of Aem would be sort of not including 17 spaces and Ae ~ and they would tend to use coal and 17 them as part of Ae NPL site, but seek a 18 coal is also associated wiA some of Aese urban fill 18 redevelopment opportunity Aat would involve capping 19 material Aat I mentioned earlier especially some ~ 19 to prevent e>qx)sure to any material Aat we did find 20 a group of contaminants called polyaromatic 20 Aere and a — sort of a protective capping and Aen 21 hydrocarbons or PAHs, some of Aose are cancer 21 a reuse. 22 causing. 22 ' And Ae EPA agreed to that assessment of 23 We did find some of Aose contaminants 23 this facility and so it really isnt carried forward 24 on Ais site. Some of them appear to Jilign with some 24 in this study. This study really focuses on Ae area 25 of the areas where coal was stored many years ago and 25 where Ae tannery was and Ae area where Ae Martin Pages 26 to 29 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500112 July 26,2005 Page 30 Page32 1 Aaron operation was located. 1 relatively low levels, Aey were even in some of 2 You will also see on this slide Aat 2 Aesewells Aat were a little bit off of Ae main 3 Acre's a whole oAer area where we identified 3 fecility. Several - this well is about 3 maybe 4 contamination Aat isnt - arent Aese really, 4 400 feet away from this sort of area where Ae actual 5 really high levels, but clearly are unacceptable and 5 releases took place. 6 Aaf s, fi-ankly, what we found at SouA Jersey Port, 6 This well is — this last well is ~ has 7 we took samples on this right of way over here, on - 7 veryrelatively low levels of contamination. This is 8 across Ae street here and down — we took some 8 sort oftaking Aat picture and slicing it sideways, 9 borings down here, too, and found sort of this 9 so here we have Ae site area, this is Ae ground 10 pattern which, again, isnt too surprising where- 10 surface up here and Aese markings are about 20 feet 11 while it's not Martin Aaron levels, it's certainly 11 each. This infoimation is available in oAer 12 not pristine eiAer. 12 settings where we can talk about it after Ae meeting 13 I wouldnt want you to be left wiA Ae 13 and if you want to get more clarity about this 14 impression Aat Aese soils are sort of available for 14 figure, but you'll see Aat Aere are little lines 15 contact, almost all of this area is fenced. And Ae 15 marked in here and each one of Aose Imes represents 16 sampling Aat we were doing, for instance, along this 16 one of our monitoring wells installed for Ae purpose 17 right of way and in some of Aese areas Aat are 17 of this study. 18 right along Ae edge of Ae property and sort of 18 Andsomeof Aem —manyof Aemare 19 outside of Ae fence Ime, in essence, required us to 19 relatively shallow and Aen several of Aem are quite 20 dig or pour throu^ a concrete or asphalt to even 20 deep because we wanted to understand Ae complete 21 reach a point where we could sample. 21 picture of Ae groundwater. What we see here is 22 So it's our definition of wliat EPA 22 wiiaf s called Ae PRM aquifer, Ae 23 Ainks ofas surface soils, it's sort of in Ae first 23 Potomac-MagoAy-Rairtan aquifer, and it consists 24 couple of inches, but Aat doesnt mean Aat we could 24 of - ifs a sandy - sandy soils wiA layers of clay 25 even collect, in Ais case, a sample right at Ae 25 and it's — in particular Aere is sort of a — some Page S1 Page 33 1 surface. 1 confining layers down here that — of clsty and ifs 2 The healA risks Aat we - oh, I'm 2 pretty difficult for water, let alone contaminants, 3 sorry. Let's talk about Ae groundwater first. We 3 to move beyond Ais point and Acre's a — we sort of 4 Ad a relatively comprehensive ground water 4 suspect Aat Ae contamination, based on Ae sampling 5 investigation and found a pattern of contamination in 5 Aat we've done, doesnt go - isnt able to 6 Ae groundwater Aat matches in some fashion Ae type 6 penetrate deeper than this. 7 of contamination Aat we found in Ae soil. A number 7 Now, municipal water in Ais area does 8 of contaminants were found m Ae groundwater, but 8 come primarily from —from pumping of wells. The 9 primarily it was an area of arsenic contamination and 9 nearest well to Ais facility is down gradient, it is 10 an area of Aese volatile organic compounds or VOCs. 10 down here, way down here, but ifs about a mile and a 11 This smaller circle is an area where Ae 11 half away and ifs called -1 believe ifs called 12 arsenic groundwater contamination was quite higli. It 12 Emergency Well No. 7 and it is only used in emergency 13 is also associated -1 mean we did find it in some 13 seAngs when Acre's some issues wiA oAer wells 14 of Aese other wells, but ifs quite high here and it 14 Aat Aey cant operate Aem for some reason and Aey 15 drops offquite precipitously as we watched Ae 15 still need to have a water supply. 16 groundwater wells as we sort of moved off site. 16 We have sanpled Aat well several times, 17 Let me show you anoAer figure Aat 17 ifsalsoona regular - as part of our study, just 18 might tell us Ae story a little bit better. But in 18 as a precaution, Aat well was sampled, we didnt 19 essence, here's Broadway. The direction of 19 find anyAmg attributable to Ae site. It is also 20 groundwater flow is kind of from Ae norAwest to Ae 20 sampled, as all municipal water supplies are sampled, 21 sou Aeast and it's sort of told a little bit better 21 on a regular basis. It has noAing to do wiA Ais 22 by this red circle which is associated wiA Aese 22 superfimd program. 23 VOCs, the volatile organic compounds, which are a 23 This green marking up here is basically 24 little bit more soluble in water and you'll see Aat 24 AeextentofAe arsenic Aat we found, not deeper 25 Aey move - Aey were ~ Aey were even at, albeit. 25 Aan about 40 maybe 50 feet It is pretty much in an Pages 30 to 33 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500113 July 26,2005 Page 34 Page 36 1 area nearby w^ere Ae soil contamination Aaf s 1 focuses on — primarily on addressing Aese source I 2 really high m arsenic is also located and Ae 2 areas, Ae arsenic hotspots and Aese VOC hotspots, 3 volatiles are — take a slightly bigger swaA, but 3 Aat we know are really much hi^er Aan anything 4 Aey are not terribly far off Ae site eiAer and 4 Aat we found on any neighboring properties clearly 5 Aey are most highly — Ae levels of contamination 5 attributable to releasest o Ae groundwater and we're 6 are much higher near Ae surface within Ae first 40 6 recommending, after evaluating, as I say, a number of 7 or 50 feet. 7 on site remeAes, a number of more complex solutions 8 This map identifies eveiy location where 8 and more expedient and for Ae area more 9 we found any hit including a hit way down here wliich 9 comprehensive solution of excavating it and taking it 10 is — was above a drinking water standard but not 10 away to a secure landfill for Asposal. 11 particularly highly elevated. 11 There would still be residual levels of 12 The heal A risks associated wiA Ae 12 contamination Aat are more associated wiA this sort 13 site are associated wiA — primarily wiA future 13 of urban fill type material Aat would remain after 14 use, however trespasser exposures are also a concem 14 Aat soil excavation is complete and our proposal for 15 if someone were to go through - get over a fence or 15 Aose areas is a capping and land use control type 16 go through a fence. 16 response Aat, based on conversations Aat we've had 17 The exposure or heal A risks are 17 wiA city and wiA a number of oAer interested 18 primarily associated, Aough, wiA Ae potential for 18 parties, fits vriA a reuse of this property in any of 19 reuse. There are some oAer factors, obviously Ae 19 a couple ofcommercial type end uses. 20 area where Ae groundwater is contaminated should not 20 One — one possible end use Aaf s 21 be used and are in above drinking wateir standards, 21 memorialized m Ae master plan from Ae city is 22 and Aat poses a riskwer e Aat water to be used. 22 possibly a farmers market type settmg and wiA a 23 And - and Aere is an area wiiere, as I 23 sort of capping type remedy, Aat would result in no 24 say, Aere are very high levels of site 24 exposure to a subsequent use like Aat. OAer uses 25 contamination, primarily VOC!s and arsenic, where Ae 25 Aat involve construction buildings also would be Page 35 Pages? 1 soils Aemselves pose a continuing discharge, Ae EPA 1 consistent wiA Aat type of reuse. 2 believes, into Ae groundwater, so Aere is a source 2 For Ae groundwater, after Ae soil 3 of groundwater contamination. 3 remedy is done, we've removed Ae sources and Acre's 4 So Aaf s a — about as short as 1 could 4 a protective cap to prevent direct contact, EPA 5 do in summarizing kind ofwiiat we found. We're going 5 expects Aat they'll still be - still will be 6 to get into more details because you're gomg to ask 6 residual groundwater contamination, boA of arsenic 7 some good questions or clarifications and we'll try 7 and ofVOCs and so we've proposed a kind of an 8 andanswersomeof Aose questions w^ien we get to 8 aggressive approach to Aat which is to liy and 9 Aat part of Ae meetmg. 9 remove Aose contaminants through wliaf s called a ] 0 We looked at a whole range of remedies, 10 pump and treat type scenario. 11 ifs part of Ais process, ifs called Ae 11 The — this sort of sandy aquifer wiiere 12 feasibility study and evaluated a number of ways of 12 a lot of Ae contaminants in Ae groundwater are 13 ad Aessing Ae soils and a number of ways of 13 relatively close to Ae surface is generally amenable 14 adAessing Ae groundwater. I'm not going to go mto 14 to Ais type of pumping remedy. 15 Ae details of Ae many alternatives Aat we 15 There are some unknowns Aat we will 16 evaluated for soils or groundwater, instead I'm going 16 have to sort of explore as we go through Ae process, 17 to go to what EPA's proposal is for boA of Aese 17 but Ae steps would be someAing like Ais, complete 18 media. 18 Ae soil remedy, we'd install a series of extraction 19 The process Ae EPA goes through 19 wells Aat would not conflict wiA Ae reuse type of 20 is relatively complex, it requires us to evaluate a 20 plan for Ais property, so Aat could sort of go 21 number of criteria, Ae/re listed here, again, ifs 21 ahead, Aere would be some sort of a treatment 22 described in great detail in Ae proposed plan and 22 facility Aat would be placed at Ae Martin Aaron 23 feasibility study to - so Aat we can judge Aese 23 Facility Aat would bring Ae groundwater contaminant 24 alternatives Aat we consider against each oAer. 24 levels down to a level so Aat Aey could be 25 The preferred alternative for soils 25 discharged to Ae municipal sewer system and Aen Ae Pages 34 to 37 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500114 July 26, 2005 Page 38 Page 40 1 CCMUA would be available to accept Aat - Aat waste 1 MS. LONEY: Anycme? 2 and really - ifs really Ae utility's auAority 2 MR CHAPIN: My name is Richard Chapin, 3 Aat would sort of set Aose standards how — how 3 C-h-a-p-i-n, I am president of Chapin Engineering, a 4 much treatment would be required before it could be 4 OHisulting environmental engineering finn on behalf 5 Ascharged and Aaf s - Aat process might take some ^5 of EWA, an environmental advocacy group m New 6 time m terms of pumping, but ifs sort of turn it on 6 Jersey, I have conducted a review of Ae prq)osed EPA 7 and do monitoring and maybe make some adjustments. 7 plan, Ae 25-pager. 8 but,aslsay, sort ofa reuse approach could Aen 8 I havent locked at Ae feasibAty 9 follow on. 9 study in detail, so Aese ccanments are based on Ae 10 As we described earlier, Ae next steps 10 information Aat is presented in Ae plan. These are 11 are Aat we con^lete a comment period on EPA's 11 down in writing, we will gladly give you a copy of 12 proposal, hear what Ae community has to say tonight 12 Aem by Ae end of Ae meeting and EWA will be glad 13 and Aen in writing and evaluate Aat against what . 13 to transmit Aem toyou . I will say that this was 14 our proposal is, consult vriA Ae state and Aen EPA 14 written wiAout knowledge of Ae Acaium problem or 15 selects a remedy. 15 potential Aorium problems, so Aere's probably going 16 And Aen Aere's some stages Aat 16 to be some supplemental questions Aat will be put 17 follow, Natalie described Aem in some detail, and 17 forth. 18 maybe we can get mto Aat a littie bit more m 18 The proposed plan talks about excavating 19 comments or questions and I Aink it would be 19 28,000 some cubic yards of ccmtaminated soil. 20 appropriate to sort ofswitch to Aat part of Ae 20 Apparentiy, this plan is based on usmg 300 parts per 21 meeting. 21 million of total arsenic as a cleanup goal to 22 I'm going to, I Aink, put up Ais map 22 Astinguish site versus historic fill; is that 23 and maybe just leave it up for Ae time bemg because 23 correct, because that was not clear? 24 Aere may be some questions. 24 MR. PRINCE: Yes, Aat is correct 25 We're going to now start — actually. 25 MR. CHAPIN: The historic fill - Ae Page 39 Page41 1 Natalie, why dont you sort of set up Ae question 1 document talks about historic fill, but it does not 2 and answer part. 2 identify wiA any specificity what Aat historic fill 3 MS. LONEY: What I'll ask people to do 3 is. 4 is just come up to Ae microphone, I didnt use it. 4 Thaf s very important because in New 5 but I told you my kids Aink I'm loud anyway, so when 5 Jersey Ae definition of historic fill material is 6 you want to ask your question, I'd just ask Aat you 6 very specific in Ae state's technical regulations 7 come up to the microphone, state your name for Ae 7 and it excludes ores and slags and oAer things fitim 8 record, ask your question and we'll adAess it 8 processing of metals such as Ae chromium Aat's all 9 accordingly and spell your name as well. 9 over Jersey City, such as Ae Aorium slag and ores 10 A SPEAKER: Is Ais conunent period as 10 Aat are down Aere, so can you tell me exactiy what 1J well or ifs just questions? 11 Ae historic fill is? 12 MS. LONEY: You can - you can ask a 12 MR. PRINCE: It appears to predate all 13 question, you can make a comment. 13 of Ae operations Aat we were evaluating. It's not 14 A SPEAKER: On boA sides? 14 clear from Ae boring logs Aat it had, for instance. 15 MR. PRINCE: Oh, yes. 15 a character of ores and it doesnt appear to meet 16 MS. LONEY: Yes, on boA - everything 16 Aat particular exemption, ifs also Ae subbase for 17 that was presented tonight, boA Ae Welsbach/General 17 Ais whole area. 18 Gas Mantle Site and the Martin Aaron Site, you can 18 MR. CHAPIN: I understand Aat, but from 19 ask questions and/or make comments. 19 a technical point of view in Ae regulations wheAer 20 MR. PRINCE: I would ask Aat you - if 20 or not you can call it historic fill, meaning wheAer 21 you have questions about boA, thaf s fine, along 21 or not Ae presumption of leaving it in place applies 22 • wiA stating your name and spelling your name for our 22 depends on wheAer or not ifs an ore based material 23 court reporter, if you could also identify to whom - 23 or not 24 to which site the questions are identified for 24 Is it coal ash? I mean you can identify i 25 because Aat will help us to - in response. 25 coal ash. Is Aere coal ash Aere? | Pages 38 to 41 [email protected] Mastroiarmi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500115 July 26, 2005 Page 42 Page 44 1 MR. PRINCE: Well, Aere is - Aere are 1 area not attributable necessarily to operations that > 2 coal remnants on Ae facility Aat are 2 took place here and operations that clearly took 3 attributable - clearly attiibutable to Ae operation 3 place here. 4 of, we think, Ae tannery because we have some old 4 We, EPA, expects a coping type remedy 5 figures, we have some sense of where coal was stored 5 wiiich is frequently used for levels of arsenic as 6 and where some of Aese operations took place, ifs a 6 high as 300 parts per million as a way of assuring 7 fingaprint Aough, of chemical contamination, ifs 7 thalcontact wiA elevated levels of arsenic 8 not necessarily attributable to coal ash as it — you 8 associated wiA this site and probably not In this 9 know, Ae certain clinker of debris Aat came out of 9 general study area are — are protected from direct 10 a coal fire —a coal fire of some sort 10 contact wdiich is Ae threat thaf s posed by — by 11 MR. CHAPIN: So Aen Ae DEP has 11 this - by arsenic. 12 approved Ae use of 300 ppm as a site specific 12 Now, we also concluded that it was just 13 cleanup goal? 13 inappropriate to leave Aese higher levels becaxise 14 MR. PRINCE: DEP is evaluating - still 14 Aey were clearly associated wiA Ae facility and 15 evaluating Ae proposed plan. 15 because Aey are probably a source of this 16 MR. CHAPIN: Okay. 16 groundwater problem. 17 MR. PRINCE: And Aey are aware of our 17 MR. CHAPIN: How deep are Aese 18 assessment of all of Ae data Aat was collected in 18 excavations going to be? 19 Ais area and Aat we - Aat we attempted to make - 19 MR. PRINCE: 6 to 8 feet apparently, 20 to make a distinction between arsenic Aat — where 20 Aat's what we've seen so far. 21 ifs questionable because Aere's - Aere are hits 21 MR. CHAPIN: To get to Ae 300? 22 of arsenic greater Aan 20 parts per million in all 22 MR. PRINCE: Yeah. It may be deeper in 23 sorts of— 23 some places. 24 MR. CHAPIN: Everywhere. 24 MR. CHAPIN: Til make an observation. 25 MR. PRINCE: In all sorts of places in 25 If you - your report indicates Aat Aere will be a Page 43 Page 45 1 our study footprint and ifs our understanding Aat 1 five-year review on Ae protectiveness of any c^, 2 Aaf s not too surprising, so w^at we were seeking 2 ril just make an observation Aat New Jersey 3 was trying to find a pretty clear footprint of what S regulations require a certification of institutional 4 is clearly associated wiA Ae — Ae operations Aat 4 engineering controls every two years. 5 took place here and what may be — maybe is 5 MR. PRINCE: Well, Aere's a whole oAer 6 associated WiA wherever Ae fill came from wiA 6 set of ^plicable state regulations Aat we also 7 oAer operations and we — EPA conservatively 7 support for Ais particular property and Aat's part 8 identified Aat sort of cutoff at 300 parts per 8 of - Aaf s actually part of Ais remedy as well. 9 million. 9 It involves taking measures - lef s 10 MR. CHAPIN: When do you expect Ae DEP 10 assume Aat Ais facility is going to get reused and 11 to get back to you on Aat 300 level because Aat's 11 Aat ifs going to be a use Aat's a betterment for 12 astronomical compared to my experience in Ae State 12 Ae community, Aaf s what - certainly what I want 13 of New Jersey? 13 Well, ifs going to be in our proposal a 14 The State of New Jersey currently uses 14 cap and Aat certainly is - cant be Ae end of Ae 15 20 ppm as background, Ae/re going to go down 8 in 15 stoiy because Aere has to be controls on a cap and 16 Ae proposed Aings and your risk assessment says 1.6 16 Aaf s part of what DEP expects of sites Aat are 17 is appropriate for an industrial commercial worker, 17 capped as well, Aaf s what Ae/re evaluating for - 18 so 300 seems very high. 18 as a remedy for Ais SouA Jersey Port Corporation 19 MR. PRINCE: Well, I dont want to- 19 Site across Ae street where not only would you cq) 20 MR. CHAPIN: And we dont have to debate 20 it, but Aen Aere's e)q>ectations Aat Ae landowner 21 Aat here, you're right. 21 or a responsible party would set in place rules for 22 MR. PRINCE: I dont want to 22 use of Aat land so Aat Ae cap wouldnt be 23 misrepresent what Ae remedy calls for because we 23 Asturbed, so Aat it would get fixed if it ages and 24 are — we, EPA, made a ~ was trying to assess a 24 so Aat Ae - if Aere is some need to disturb Ae 25 distinction between urban fill that is found in this 25 cap for some site use reason Aat it's done in a -•"^ "l^r—*-^""f-^-V'-'fr''f^ jlfiir L2-4M3aai'ift atatff*! «'*ia^*(ta«K*«ftrrtrt«rirtf.TWiwWKam Pages 42 to 45 [email protected] Mastroiarmi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500116 July 26,2005 Page 46 Page 48 1 1 protective way and Aaf s part of our expectations, 1 Aere's a table in my comments, my alternative — I !• 2 too. 2 looked slowly at Ae capital costs, I do have 3 MR. CHAPIN: Your Alternative S4, your 3 questions about your present worth value for one 4 document says ifs going to take five monAs to 4 thing, but I looked at Ae capital costs. 5 complete and in Aat five months, you're going to 5 For your Alternative S4, you're going to 6 essentially get rid of 28,00 cubic yards of 6 spend $6.4 million to take out 28,000 cubic yards or 7 contaminated soil. 7 $229 a yard as a rough unit cost. 8 Your Alternative S6 which essentially 8 For 6, you're — for Alternative 6, 9 seems to be Ae total removal option is going to take 9 you're going to spend $8.3 million and take out 10 away an additional 36,500 cubic yards of soil, but S6 10 64,500 cubic yards which is a buck a hundred 29 11 is scheduled to take four years. 11 dollars, maybe Aaf s economy to scale or something 12 So you're saying you can take — if 12 like Aat, but if s significantly different 13 Aere's a total of 64,000 some cubic yards of 13 The more important unit numbers Aat I 14 contaminated soil Aat has to be adAessed, you're 14 took out were -1 made some assumptions about 15 saying Aat we can get rid of Ae first 28,000 yards 15 construction time. For example, if you have a 16 in five months and Ae second 36,000 yards is going 16 fi ve-monA construction time for S4 and you allow two 17 to take anoAer three and a half years, Aat doesnt 17 weeks upfront for mobilization and two weeks at Ae 18 make any sense, ladies and gentlemen, none 18 back end for mobilization, Aat leaves you four 19 whatsoever, front Ae point of view from an effective 19 months worth of on site Agging time and at five days 20 and efficient excavating contractor loading trucks, 20 aweek,Aafs so many days of digging time, worked 21 it just dont make no sense, so I suggest Aat 21 out to 80, as a matter of fact. 22 something has to be looked at as a time fi'ame. 22 If you divide 80 into Ae tonnage you're 23 MR PRINCE: Okay. Thank you. fmnot 23 going to remove, you wind up wiA 350 cubic yards a 24 certain of— fm not certain of Aose time firunes — 24 day or nine big truck loads a day which is a 25 MR. CHAPIN: They're right in your 25 reasonable rate for excavation and removal of Page 47 Page 49 | P 1 contaminated soils in a dig and hole operation, my 1 documents. 2 MR. PRINCE: That's fine. And we can 2 experience ifs vety doable by a good contractor. 3 provide a — obviously all of Ae ~ all of Ae 3 Unfortunately, if take Ae average - if 4 comments and questions Aat get raised here, Ae EPA 4 you take Ae workdays Aat you're going to do Aat in 5 doesnt just - Aey dont just disappear, we record 5 wliich is some 80 and you divide Aat into Ae $6.4 6 Aem for reasons so Aat - because we're — we need 6 million, you come up wiA an average daily cost of 7 to know ~ we want to make sure we have a record 7 $80,000 which is fantastic. Now, wheAer or not 8 later so Aat we can know how to and, in some cases, 8 Aat's what you meant I dont know, but Aat's what 9 who to respond to and Aen we also are obliged to 9 it comes out to. 10 weigh Aose decisions against what our proposal was, 10 Looking over to the S6 alternative, 11 maybe finds errors, maybe make clarifications in — 11 you're wind up working for some 940 days over Ae 12 prior to selecting a remedy, so Aere may be some - 12 entire period which averages out to 69 cubic yards a 13 Aere may be some mistake Aere. 13 day or 1.7 truck loads a day wliich is an extremely 14 I mean I would — I would make an 14 inefficient and ineffective operation. The daily 15 observation Aat Aere is an active facility Aere 15 number works out to $8,800 a day wiiich is not an 16 and some — Aere's some contamination attributable 16 unusual number for an excavation contractor. 17 to Aat and so Aere may be some factors Aat — 17 The point I'm Uying to make is Aat 18 MR CHAPIN: Not three and a half years. 18 Aere's fundamental things Aat seem to be assumed in 19 MR. PRINCE: Okay. Thank you. 19 generating your costs Aal just dont make any sense 20 MR. CHAPIN: I just dont believe it's 20 wJA a basic review of it which leads you — leads me 21 three and a half years. I dont Aink you meant for 21 to suspect or me to question wheAer or not Ae 22 it to be Aat difference because it doesnt make any 22 whole — you know, you maybe need to go back and take 23 sense. 23 a fiindamental look al Ae assumptions in Ae 24 I also took a look at Ae difference m 24 development of your alternatives for soil to see 25 Ae numbers between Ae costs between Ae ~ and 25 where Aese things jive. Pages 46 to 49 [email protected] Mastroiarmi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500117 July 26,2005 Page 50 Page 52 1 See, Aese Amgs dont make sense 1 Vapor Intrusion Guidance, Ae draft 2002 version, it > 2 because to me, as someone who's been doing this for 2 suggests Aat you start sort of wiA a screen before 3 29 some years, Aey dont make sense to me, Aey just 3 you go in and you do sampling inside and we're going 4 dont make sense and I dont know Aat you need to 4 to be starting wiA Aat. 5 comment one way or AeoAer, rebuttal of Aat 5 We're going to be looking to see what 6 Aat's just my comment and, like I said, you'll have 6 data are necessaty in order to evaluate Ais rather 7 a copy of this, I'll be glad to give it to you. 7 Aan just immeAately go into people's homes when we 8 On Ae groundwater, couple of comments. 8 dont necessarily know Aat Aere is a reason for 9 Vety traditional pump and treat program was selected, 9 Aat. 10 Ae plumb, as identified in your document in Ae 10 There's a process of oirtline in Ae 11 upper 20 feet of Ae groundwater is some Aousand 11 Vapor Intrusion Guidance Aat suggests we start at 12 feet long and 600 feet wide. 12 Ae vety beginning of Ae process and move forward 13 As an observation to Ae souAeast of 13 through, we collect Ae data Aat helps to build Ae 14 Aat site, Aat plumb flows under houses Aat are 14 case of suggesting Aat vapors are migrating from Ae 15 currently residential, occupied. 15 plumb upwards. 16 And so I have to ask, has Aere been any 16 MR. CHAPIN: Okay. Thank you. Of 17 consideration been given to vapor intrusion in Aose 17 course, you've got no defined end point for your pump 18 residential homes, yes or no, and Aen we can take it 18 and treat which is not unexpected because you never 19 from Aere? 19 do. You never know until you tum Ae pump on -1 20 MR. PRINCE: Yes, Aere has. There is 20 would love to have a copy of Aat figure, by Ae way. 21 Ae possibility of Aat - it could be - it could be 21 You dont - you never know until you tum it on. 22 a paAway, certainly a good reason to take an action. 22 In looking at your data, something 23 MR. CHAPIN: Has anybody looked yet or 23 struck me immediately. You have TrichloroeAylene 24 is Aat something Aat we're going to do during Ae 24 and TetrachloroeAylene in Ae ground — 25 design phase? 25 MR. PRINCE: We do. Page 51 Page 53 1 MR PRINCE: No, we haven't We havent 1 MR. CHAPIN: - and you have it in Ae 2 done Aat part of Ae study yet. 2 groundwater. Youalsohavecis-l,2DichloroeAylene 3 MR: CHAPIN: And it will be looked at in 3 and Vmyl Chloride which are biodegradation products 4 Ae design phase to see how Ae specifics of Ae 4 of Aose previous mentioned chlorinated solvents. 5 system were put togeAer and where extraction wells 5 MR. PRINCE: Thafs true. 6 are and all Aat good stuff? 6 MR. CHAPIN: So you have active 7 MR. PRINCE: Yes. Michael, do you have 7 biodegradation going on today and you have Aat m 8 anyAing to add to Aat because 1 - you know, Ais 8 Ae face of relatively high arsenic concentrations. 9 is mentioned vety briefly in Ae proposed plan. 9 You — arsenic is an inhibitoty confound 10 Michael Sivak is our risk assessor and happens to 10 to biological activity and you have' acti'vity going on 11 know a lot about vapor intrusion. 11 in Ae face of a relatively high concentration which 12 MRSrVAK: Yeah, we're vety familiar 12 means you got some good tough biology down Aere 13 wiA Ae concept of vapor intrusion. Thank you for 13 which, to my mind when I read Aat and I looked at 14 bringing Aat up, Aat is someAing Aat we discussed 14 Ae fact Aat you were talking about $6.6 million for 15 to dale. Right now, EPA will be looking at vapor 15 groundwater treatment, I immediately questioned if 16 intmsion as we move forward. We have concentrations 16 some sort of in-situ in place process such as 17 of VOCs in Ae groundwater Aat we will be using 17 injection wiA a hyAogen release compound to 18 against EPA's process to evaluate Ae meAods for 18 stimulate Ae anaerobic bacteria Aat degrade Ae 19 vapor intrusion and Aat's Ae process Aat we will 19 chlorinated had been considered because m most cases 20 be using as we move forward. 20 Aaf s markedly more cost effective and efficient 21 MR. CHAPIN: So you're not planning, at 21 Aan a traditional pump and treat? 22 Ais time, to send anybody mto Ae houses wiA a 22 MR. PRINCE: We evaluated in Ae 23 sniffer just to make sure Aere's noAing going on m 23 feasibility study which I'm afraid you havent — 24 Ae basement? 24 MR. CHAPIN: I dont have Ae 25 MR. SIVAK: Well, if you read EPA's 25 feasibility study. Pages 50 to 53 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500118 July 26, 2005 Page 54 Page 56 1 MR. PRINCE: Right 1 MR. PRINCE: Ri^t 2 MR CHAPIN: I only have your summary 2 MR CHAPIN: - how do you - that deep 3 dociunent and I reaAly admit Aat Aere may be 3 one Aere, go to Ae left of Aat in Aat upper zone, 4 details Aere Aat I Adnt look at, but Ad you look 4 iq>per, upper, yeah, that one, how do you know that's 5 at in-siA stimulation of Ae biology to get at it 5 continuos out Aere? And I say Aat because Ae 6 Aat way? 6 Potomac-MagoAy aquifer is notorious for having holes 7 MR. PRINCE: We looked at - we Ad look 7 all over Ae place, notorious. 8 at some volatile - some ways of addressmg volatile 8 MR PRINCE: There is - Aere is - I'm 9 oi^anics in Ae subsurface. Ifs possible Aat 9 not a geologist but I'll do my best 10 Ae - and this is Ascussed in some detail m Ae 10 MR CHAPIN: That's fine. 11 proposed plan and m greater detail m Ae 11 MR PRINCE: The PRM aquifer has a 12 feasibility study, it is possible Aat after Ae 12 number of different units Aat are very well 13 source is removed, Ae volatile organics, because 13 understood and Ae Upper PRM which is generally 14 Aere's a relatively high degree of natural 14 Aought to be within Ae first hundred to a hundred 15 biodegradation Aaf s ongoing, Aat Ae plume — Ae 15 20 feet is very similar in character to what we found 16 groundwater plume attributable to Aese VOCs may 16 when we put in most of our wells in this area. 17 degrade, to a great degree, on its own. 17 We did put in some wells in whaf s 18 One of Ae factors Aat we were - and 18 Ais - what was clearly known to be what's called 19 so, to some degree, Ae groundwater alternatives Aat 19 Ae Middle PRH this is actually Ae Upper Middle PRM 20 we centered on were Aose Aat we were confident 20 aquifer and, again, what we found is vety consistent 21 could do something about Ae arsenic. 21 wiA what one finds in ~ in this aquifer and so to 22 So while Ae pumpmg is gomg to take 22 some degree, this is based on wells Aat we have in 23 place generally m this area, we know Aat 23 place and to some degree, ifs based on knowledge of 24 biodegradation, this process of bugs or bacteria 24 Ae aquifer itself. 25 Aaf s naturally occurring m groundwater m many 25 MR. CHAPIN: I have anoAer question. Page 55 Page 57 1 places can have some actually beneficial effect on 1 You show a Ime of volatiles here. This 2 Ae VOCs, ifs not going to do anyAing about Ae 2 contamination of volatiles has penetrated Aat layer. 3 arsenic. 3 If s not a hole and it penetrated Aat layer. Now, 4 So while some of Aose alternatives 4 we all know Ae permeability of a clay to a 5 were — were considered, we really focused more on 5 chlorinated solvent is not Ae same as its 6 someAing Aat we knew could adAess Ae arsenic. 6 permeability to a water. 7 MR. CHAPIN: Well, sir, 1 submit to you 7 And so if it penetrated this in here, 8 Aat Ae technical program to use in — use 8 how do we know it Adnt get below this one here? 9 enhance - you talked about natural attenuation, not 9 MR. PRINCE: Well, aside from Ae feet 10 putting someAing down Aat's going to actively 10 Aat we put wells in Aere? 11 aggressively go after Ae organics and I put forth to 11 MR. CHAPIN: No, you dont have a - you 12 you Aat I believe you should be looking at someAmg 12 have a well down here. 13 Aat does that coupled ~ fm not saying you 13 MR. PRINCE: I'msony. TTiisisa 14 shouldnt be pumping to get Ae arsenic out of Ae 14 cartoon, okay. This is a cartoon Aat shows an 15 groundwater, if s probably needed. 15 example ofwhere we put wells. 16 But I'm saying you actually could couple 16 MR. CHAPIN: No* no. "Iliis is supposed 17 Aat in so Aat you're not pumping also for ten 17 to be a geologic cross section Aat's supposed to 18 years, Aat's someAing I believe you should be 18 actively represent Ae boring lines, right? No? 19 taking a look at it, in my professional opinion, so 19 MR. PRINCE: Fme. 20 be it 20 MR. CHAPIN: I apologize for being 21 On Aat particular map, you show silt 21 wrong. Ifs a cartoon. 22 and clay layers continuous across certain areas of 22 MR. PRINCE: Right ImeanAafsAe 23 Ae site and how do you know Aat Aey are when you 23 one way to describe it, yes. If s a depiction of Ae 24 dont have any borings in Aose locations? 24 site. 25 If you go to Ae vety deep one — 25 MR. CHAPIN: Why are we here talking Pages 54 to 57 [email protected] Mastroiarmi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500119 July 26, 2005 Page 58 Page 60 1 about a specific technical subject using cartoons? 1. MR. PRINCE: I dont know Aat Aere's 2 Thank you for your time, I ^preciate 2 anything Aere. There's no - we Adnt find 3 it I still want to know why this is here and I 3 anything in Ae screening. 4 would like to know how this stops here when you dont 4 MR. CHAPIN: Did Ae screening Aat you 5 have anything over here below it or you dont 5 do consist of a paper study or was it walking Ae 6 mAcate Aat you do? 6 ground - 7 MR. PRINCE: Thank you. 7 MR. PRINCE: No, walldng over Ae ground 8 MR. ROBINSON: I'd just like to follow 8 surface and doing an evaluation. 9 up wiA one thing wiA respect to Ae radiological 9 MR. CHAPIN: And so in Aat Ime Aere, 10 work - cleanup Aat we're doing is Aal when we find 10 Aere may be something of Aorium at Aat border? 11 Aorium contamination on a property, we're removing 11 MR. PRINCE: It's possible. 12 it down, we're removingal l Ae contamination oirt, 12 MR. CHAPIN: Ifs possible. And would 13 we're not capping anything, we're removing all Ae 13 Aat area be excavated as part of this remedy? 14 Aorium. 14 MR. PRINCE: Parts of it are- 15 Our cleanup is level is 5 picoCuries per 15 MR CHAPIN: It depended on wheAer if s 16 gram and Aat's for Aorium and radium and we're 16 Aorium Aere, is Aat going to be excavated m a 17 domg Ae sum of Ae ratios. 17 different way? 18 So we're taking Ae sums of Ae Aorium 18 MR PRINCE: Some of Aat area is part 19 daughters and Ae radium daughters and our cleanup is 19 of Ae area Aat is within this source area for a — 20 5. So if we find Aorium contamination on a 20 particular for arsenic, I believe, and Aaf s sort of 21 property, we'll remove it 21 right up against Aat property Ime and so we — I 22 MR. CHAPIN: Thank you. One last 22 expect Aat in terms of Ae design of Ae remedy, 23 question, has — have any of Ae samples on Ae 23 finding exactly where Aese cut lines would be and 24 Martin Aaronson [sic] property Aat we're talking 24 Aen an excavation, we would answer some of Aose 25 about here, not Ae one across Ae street where you 25 questions. Page 59 Page 61 1 found it, any of Ae samples on Aat property been 1 MR. CHAPIN: Thank you. 2 tested for radiological? 2 MS. POMAR: Good evening, my name is 3 MR. PRINCE: There's a screening process 3 Olga Pomar, I'm an attorney at SouA Jersey Legal 4 Aat all sites go through Ae beginning of Aeir — 4 Services, I'm here on behalf of two community groups, 5 when removal actions are started, so thaf s all Ae 5 SouA Camden Citizens m Action and Ae SouA Jersey 6 way at Ae beginm'ng, emergency response, Aat 6 Environmental Justice Alliance and I have seven 7 involved a survey of Ais whole area, didnt find 7 issues Aat I'd like to briefly adAess, a few are 8 anyAing. 8 comments and a few are questions. 9 There is one area Aat A ternis ~ if 9 My first one is a question about Ae 10 we're moving ahead wiA Ae remedy, Aere's one area 10 fimding. You know, I've been hearing for years Aat 11 that acmally may have some concems of Aat nature 11 Ae superfund program has basically no money 12 and ifs - ifs Ais strange sort of property line 12 remainmg, Aat Aere's a real crisis wiA Aal, 13 here Aere happened to be ~ used to be a creek Aere 13 Aere's no - Aere's littie infoimation about where 14 Aat is not as old as a lot of Ais oAer fill 14 Ae money is going to come from and we've been 15 material. 15 sitting wiA bated breaAe waiting for cleanup for 16 And Ae Sou A Jersey Port, some of Ae 16 three superfimd sites Aat affect Ae City of Camden. 17 contamination Aat Aey found is actually sort of in 17 So is it now - can you give us some 18 Aat same zone, so Aere's some possibility Aat, for 18 assurance Aat Aere is, m fact, fimding to 19 whatever reason, when Aat was filled in across Ae 19 remediate Ae site properly, is Aat money Aaf s 20 street and Aere are a few hits of Aese Aorium ores 20 already been set aside or are we still in Ae 21 Aat are found Aere, ifs possible Aat Aere might 21 pipeline? 22 be someAing Aere, so- 22 MR. PRINCE: The monies Aemselves, just 23 MR CHAPIN: Is Aere any place else on 23 as far as Ae whole process works, if ifs an abandon 24 Ae site where Aere's any radioactivity oAer Aan 24 site and it needs to rely on federal funds and state 25 Aat historic pre-cut? I understand Aat completely. | 25 fimds, Ae - Aere's a second sort of step Aat Pages 58 to 61 [email protected] ; Masti-oianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professional 500120 July 26, 2005 Page 62 Page 64 1 comes next which involves this remedial design which 1 we expect to come mto play on this site. 2 is sort of like a construction project plans like you 2 There are some questions abom Ae — lb 3 were building someAing only we're sort of unbuilding 3 Aere's some liability questions, some issues Aat 4 someAmg and they're very detailed for safety and 4 need to be resolved before we reach Aat pomt, but 5 samplmg and various mechanisms for assuring Aat Ae 5 Aat's a stage at this site. 6 work is done safely. 6 MS. POMAR: Well, let me just - well, 7 And Aen Aere's part of it which is 7 is Ae companies Aat actually operated in Martin 8 simply Ae budgeting part how much is it going to 8 Aaron, Martm Aaron company itself and Rhodes, 1 9 cost and what sort of - you know, what are Ae real 9 assume Aey're like bankmpt, defimct, no longer in 10 costs going to be for acmally performing Ae real 10 existence? 11 nuts and bolts stuff. 11 MR. PRINCE: Thafs correct. 12 Ifs al Aat stage, at Ae completion of 12 MS. POMAR: And have you had any 13 Ae remeAal design, Aat — when we know what Ae 13 mdication from Aese eiAer potential responsible 14 costs are, not Aese sort of comparison type costs 14 parties how Aey're gomg to respond to this, wheAer 15 Aat are in Ais feasibility study Aat we Aen 15 Aey're gomg to assume any responsibility or contest 16 request to get on Ae pipelme, so Aaf s — we're 16 responsibility? 17 this — for abandoned sites like, for instance, Ae 17 MR. PRINCE: We have had some meetmgs 18 Welsbach Site and 1 Aink Rick can probably - well, 18 wiA a group Aat has formed, m response to EPA 19 you're really asking about Martin Aaron? 19 sending out a number of Aese letters, and Aat group 20 MS. POMAR: Yes, I'm asking abom Martin 20 is of — you know, sort of still in Ae formative 21 Aaron. 21 stage and Aey're, I'm certain, going to evaluate our 22 MR. PRINCE: Okay. The-Aat's how 22 remedy and provide comments. 23 this mechanism works, so something like 18 monAs 23 And Aen Aere will be a point after 24 after Ae record of decision would be signed for Ais 24 we've signed a record of decision where we will have 25 site, we'd be — have Aose design documents in place 25 Ais document, Ais remedy, and at Aal point we, in Page 63 Page 65 1 and we'd be ready to say, okay. Congress, we need 1 essence, put it before Aem and say, hey, are you — 2 money, Ae state would go through a similar process 2 is Ais something Aat you are interested m 3 and we'd secure funds and — and Aen are Ae — you 3 performing. 4 know, for a site like Aat are Ae fimds secured. 4 And just Ae way Ais process works, 5 At Ae time of a record of decision, no. 5 groups like Aat tend to not form until Aere's 6 For Ais Martin Aaron Site, Aere are - 6 really sort ofa concrete someAing for Aem to do, 7 Aere are oAer ways Aat sites are cleaned up and 7 so ifs a little early for Aem to necessarily all be 8 for ~ for Ae Martin Aaron Site, EPA has identified 8 togeAer. 9 a number of companies Aat are, what we refer to, as 9 MS. POMAR: So basically we dont know 10 potentially responsible parties and Aey are 10 what Aeir responsibility is going to be at Ais 11 companies Aat worked wiA or had some sort of 11 pomt? 12 business relationship wiA eiAer Martin Aaron, Inc. 12 MR. PRINCE: No, we dont. 13 or some of Ae oAer drum reconditioning facilities 13 MS. POMAR: And is Aere fimdingwiA m 14 Aatoperatedoutof Aat facility and EPA has 14 Ae superfund program for whatever it is you guys 15 identified a group of Aem as Ais potentially 15 need to do to get to Ae record of decision stage? 16 responsible parties. 16 MR PRINCE: Yes. And if - ifs 17 What typically would happen in Aat case 17 possible Aat we Will sit down wiA Aese compames 18 is Ae EPA would tum to Aose parties and say, would 18 after Ae remedy is selected and we'll have 19 you - would you like to perform Ae cleanup work 19 discussions Aal will, for various reasons, mdicate 20 wiA EPA overseeing Ae work and Aen Aey'd be 20 Aat we dont vrant Aem to do Ae work. 21 paying for Ais design phase, get our approval in Ae 21 I mean some viable companies, Ae^ve 22 design Aat Aey're going to do it appropriately and 22 got money, Aey - Aere's - Aere are a number of 23 Aen Aey would subsequently oversee a cleanup. 23 issues Aat need to be resolved, but EPA may conclude 24 There's some oAerwayis, sort of oAer 24 Aat we want to do Ae design instead and at Aat — 25 ways Aat Aat can be done, but Aat is a phase Aat 25 and we would also be able to secure fimding to do Ae Pages 62 to 65 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500121 July 26; 2005 Page 66 Page 68 1 design which is Ae next — sort of Ae next actual . 1 conclusive Aal you couldnt make it part of Ae > 2 physical phase of work. 2 site. 3 MS. POMAR: So you say Aere is fimding 3 MR PRINCE: Thank you. 4 to do Ae design? 4 MS. POMAR: My third comment is Aat- 5 MR.PRINC:E: There will be - Aere 5 I just want to note Aat, you know, now we have Aese 6 would be if we chose to go Aat way, yes. 6 companies Aat are defimct and left this mess, but 7 MS. POMAR: Okay. But what we dont 7 unfortunately this was a mess a long time m Ae 8 have is any ~ you know, any definite prospect for 8 making. 9 fimding Ae actual remediation? 9 I mean Aey were - looking again at Ae 10 MR PRINCE: Yes. If it needs to come 10 DEP's files,Ae y go back to 1972 and m 1981, Aere 11 from Ae fund itself it cant even get in line until 11 were complaints and compliance orders by EPA because 12 we reach Aat point where we have a complete design. 12 of leaks on Ae site. Between'83 and'87, Aere 13 MS. POMAR: Okay. And do you know how 13 were 11 notices of violations issued, Aere were two 14 much money Aere is left in Ae superfimd right now 14 administrative orders and yet all of this time while 15 nationwide to do any cleanup work? Ifs a negative 15 all Ais was gomg on and Aere were inspections, 16 number probably. 16 Aere was soil samples, Aey found all this hazardous 17 MR PRINCE: The fimdsAa t are 17 smff being dumped right on to Ae ground, but Aese 18 available for cleanups sort of come fromtw o areas, 18 facilities just kept operating and operating and were 19 one is Aat Aere are settlements from sites Aat — 19 never closed down and fm not aware of fines being 20 where EPA has — you know, EPA has spent money in Ae 20 paid or any of Aese conditions remedied even Aough 21 past Aere are parties out Aere, we — private 21 Ais was right - you know, evety - you know, people 22 parties, we seek settlements, we get settlements and 22 at DEP and EPA were aware of what was gomg on. 23 Aat — Aat money Aen goes back to be available for 23 My fourA issue was Aal we're vety 24 spenAng at oAer sites. 24 concerned, and this probably goes to Ae heart of Ae 25 MS. POMAR: But do you know if Aere is 25 whole remediation plan, as to why you Adnt consider I Page 67 Page 69 1 any fimds available now? 1 a proposal for full remeAation Aat wouldnt require 2 MR. PRINCE: And Ae oAer way Aat 2 capping and wouldnt require limiting this to 3 funds are available for Ae superfund is Aat 3 industrial use. 4 Congress allocates a certain amount of money each 4 You know. Waterfront SouA has so many 5 year and Aat amount of money has been fixed at 5 contammated sites, it is such an unfairly burdened 6 someAmg ~ I'm sony. I'm not exactly sure, 6 community and it is so inappropriate to keep, 7 something less than 200 million. 7 quote/unquote, remediating sites by paving Aem and 8 MR. ROBINSON: I Aink a hunAed and 80 8 leaving Aem and not having Aem be able to be fully 9 or so. 9 used because Aeir use is limited to mdustriai use. 10 MR. PRINCE: A hunAed and 80 million 10 So I looked at your alternatives and S6, 11 per year for Ae past I believe, three years for all 11 as this gentieman pointed out, did allow for taking 12 sites around the countty. 12 out more soil Aan S4 which you chose. Obviously, I 13 MS. POMAR: Okay. Moviiigon. This I IS Aink S6 is a better altemative Aan S4 because ifs 14 know you've already covered in your presentation, but 14 more Aorough remediation, but even S6 says Aat 15 I'd just like to note for Ae record Aat ifs a 15 you're still gomg to need to restrict use on this 16 concern Aat you're separating the SouA Jersey Port 16 property which suggests Aat even Aat altemative 17 Corporation Site from Ae rest of Ais because I've 17 doesnt totally take care of Ae problem. 18 reviewed Ae Martin Aaron file Ae DEP had on — you 18 And I noticed m your report Aat it 19 know, in its document repositoty and it seemed like 19 said, well, Ae city has no problem wiA it bemg 20 early indications did show a connection, similar 20 continued for industrial use, but Aaf s not a 21 types of contaminants and the common use of Ae site. 21 decision Aat residents in Ae community had input 22 So if Ais gave an opportunity for us to 22 on. 23 get Ae Port Corporation Site remediated, ifs a 23 Waterfront SouA has 22 contaminated 24 shame not to take advantage of that opportunity and, 24 sites Aat Aey're all paved over and all zoned for 25 you know, I'm not sure Aat what you found is so 25 industrial, Aat is - you know, Aaf s going to kill Pages 66 to 69 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500122 July 26,2005 Page 70 Page 72 L 1 Ais community. Ifs going to make it impossible for 1 request and let us know by newspaper. »• 2 people to continue living here wiA paved m 2 I mean we really, need to know now 3 contaminated industrial sites, so we really think 3 wheAer we need to Oy to get something to you by Ae 4 Aat you should have considered Aat as an 4 15 A or wheAer we will have more time and if you 5 altemative and evaluated Aat along wiA Ae oAer 5 cant give us a decision tonight we'd appreciate, 6 alternatives. 6 you know, letting Ae few of us who are here know 7 Also, on your cleanup criteria, I guess 7 right away so Aat we dont have to check Ae 8 this is Pomt No. 5, we already talked about this 300 8 newsp^jer evety day for Ae next monA and not know 9 arsenic level, Aat seems vety froublmg knowing Aat 9 how much ofa huny we have to be in to get Ae 10 Ae New Jersey Non-residential Soil Cleanup Criteria 10 comments to you. Thank you. 11 is only 20. I looked at your Table 1 which compares 11 MR PRINCE: WiA regard to Ae 12 Ae New Jersey Non-residential Soil Cleanup Criteria 12 comments,.we'll assure — I assure you that we will 13 to your source area cleanup goals and noticed Aat 13 let — I'm not sure how to do it aside from Ae 14 arsenic, Ae New Jersey standard is 20, Ae DEP 14 newspaper, to make sure we cover evetyone. We, for 15 . direct contact standard is 1.6 and Ae source area is 15 instance, can— 16 300. I also noticed Aat Vmyl Chloride, Ae EPA 16 MS. LONEY: If Ae comment period is, m 17 direct contact is .75, New Jersey Non-residential 17 fact extended, we do have Ae sign-in sheet and we 18 soil Clean Up is 7 and you're proposing 10. 18 will eiAer notify you by E-mail if you left your 19 Now, from Ae perspective of Ae 19 E-mail address or we will mail - mail some 20 community, you know, it really doesnt matter to us 20 information to you. 21 wheAer ifs historic fill, wheAer it got Aere from 21 MS. POMAR: Okay. 22 Ae tannety, wheAer it got Aere from somewhere 22 MR NOGAKI: My name is Roger Nogaki, 23 else, if if s a heal A hazard, if ifs contaminating 23 I'm from Evesham, New Jersey, I'm Ae chairman of Ae 24 Ae groundwater, if ifs not allowing fiill reuse of 24 Ellis Site Task Force Committee in Evesham Township, 25 Ae site, ifs a problem and at Ae vety least it 25 it's a committee Aat was put togeAer m 1983, Aere Page 71 Page 73 1^ 1 should be cleaned up to ^propriale standards wheAer 1 were five local residents who were concerned about a 2 you characterize it as historic fill or not. 2 drum recycling superfimd cleanup site m our 3 Next on Ae healA assessment I really 3 community vety similar to what you have here. 4 am not prepared to speak much on Ae healA 4 And I want to tell you Aal I look at 5 assessment at Ais point bm I did notice Aat as 5 your plans and I've heard your plans and all and it 6 usual, Aese heal A risks are evaluated in a vacuum 6 has a striking similarity to some of Ae plans and 7 not considering Ae conditions of Ais community and 7 some of Ae presentations Aat were given to us back 8 Ae people who live and work here because Ais area 8 in Ae early and mid '80s about cleanup al our site 9 is so contaminated, I mean we know ifs go two 9 and so fd like to share some of my experiences wiA 10 superfund sites, all Aese contaminated sites, three 10 Ais because I've been working wiA Ae — wiA 11 major facilities, three Title 5 facilities and lots 11 representatives from Ae New Jersey Department of 12 ofsmall sources of pollution. 12 Environmental Protection and members of Ae EPA on 13 SotodoahealA risk assessment Aat 13 just Ais subject cleaning up this hazardous waste 14 only considers exposure from Ais one site really 14 site in our community, superfimd site. 15 doesnt take into consideration what Ae siAation 15 It also was an abandoned drum recycling 16 here is in Ais community and, in general, as an 16 facility and I dont want to belabor a whole lot of 17 issue of Environmental Justice because Ais community 17 Ais, but Aere was a few Aings Aat I learned about 18 has been so unfairly burdened for so long, we Aink 18 Ais whole process which I'd like to share wiA Ae 19 Aat's all Ae more reason why you should impose Ae 19 Camden community and I certainly extend my hope Aat, 20 most strict standards when you design a remediation 20 you know, if you need some advice, Aose of you who 21 plan. 21 are from Camden, if you do form — I would suggest 22 And finally my last pomt is on Ais 22 you do form a citizen's committee like we Ad in 23 notion of Ae extension for comments. Yes, we do 23 Evesham Township, we got Ae backing of our local 24 want an extension to submit written comments, ifs 24 mayor and council and have Aat backing for 22 years. 25 not helpfiil for you to say you'll consider Ae 25 So I would say Aat you know, this Pages 70 to 73 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500123 July 26", 2005 Page 74 Page 76 1 township - and it sounds - it seems like Camden 1 situation. 2 City has some people who have essentially initialed 2 So what we Ad was we hired an 3 this process where citizens want to become involved 3 independent consultant who could advise us on Ae 4 m whaf s h^pening in Aeir community and I think as 4 quality of Ae engineering reports and such Aat were 5 Ae speaker before me mentioned Aal there's a 5 brought to us by DEP and Ae EPA and, you know, it 6 situation here where Ae people have an overburden of 6 really helped out because our group working, wiA Ae 7 industrial contaminants in Aeir neighborhood Aal 7 government, has helped to really address Ae cleanup 8 affect Aeir bealA and, you know, Ais neighborhood, 8 and Ae efficiency of Ae cleanup. 9 souA Camden neighborhood, is really overburdened by 9 Now, ifs only been m Ae past ten 10 many, many different types of industries Aal are 10 years that we've really been able to make substantial 11 affecting Aeir healA and Aese people are 11 strides in Ae cleanup of this site. We cleaned i^ 12 battlmg -1 know personally people down here who 12 all of Ae ground contamination, all Ae soils Aat 13 have died as a result ofsome of Ae contaminants 13 were contaminated, aU Ae heavy metals Aal were m 14 Aat Ae/ve been exposed to over Ae years and kids 14 Ae soils, Ae hydrocarbons, all Ae VOC, everything 15 are sick m Ais neighborhood. 15 Aat was in Ae soil down to couple of feet was 16 I mean 25 to 35 percent of Ae chilAen 16 removed from Ae site, so Aere's not any contaminant 17 in Ais area are sick wiA asthma You know, I mean 17 left Aere. 18 Aese are Amgs Aal are just unconscionable. 18 Our big problem is in Ae groundwater. 19 If it were in any oAer neighborhood, if 19 Now, when you talk about Ae about PRH Ae PRM for 20 it was m Marlton, Aere would have been a hue and 20 SouA Jersey is Ae most inqxKtant aqmfer for 21 Cty by all Ae citizens m MarltOn because, for Ae 21 potable drinking water m our area and all of us 22 most part, where - you know, Ae educational level 22 throughout SouA Jersey depend on Ae PRM. Ahnost 23 is much higher Aan it is m tiiiscity , our healA is 23 evetybody inSouA Jersey depends on Ae PRM as Aeir 24 much better, we can spend Ae time to fight cleanup 24 major source of water. It is Ae major source of 25 situations like Aey have down here. . 25 water. Page 75 Page 77 1 Maybe Aey dont have Ae resources down 1 So when you talk about contamination 2 here, but Aose of us who have gone through it are 2 like Ais, eventually ifs gomg to keep on spreadmg 3 certainly willing to come down and help Aem wiA 3 and Aen all Ae oAer communities are gomg to have 4 this. 4 to clean up Aeir water. 5 And one of Ae Amgs Aat I learned 5 Now, this community, Camden, already is 6 about this process is, which is a great thing about 6 faced wiA groundwater contamination, Aeir wells are 7 our democracy m this countty, is Aal we, citizens, 7 already contaminated, Aey've had to put filters on 8 have Ae right to question our government you are 8 and do some substantial cleanup. So I would say 9 our government representatives and what we have found 9 Aat, you know, you should mvite Ae local community 10 is Aat in Ae beginning, Ae government is like - 10 to sit down wiA you and go over what your plans are 11 like Ae faAer and we're going to tell you what has 11 for Ae cleanup m Aeir community because ifs Aeir 12 to be done and how ifs going to be done and just 12 community, ifs Aeir lives, ifs Aeir children, 13 trust me because, you know, we are educated m this 13 ifs Aeir ability to fimction as a family unit 14 process, Ais is ourjob and we know how best to 14 Aat - Aat is most important and we're destroying 15 handle Ae situation. 15 it down here m Ais community. 16 Well, ifs not always true because in 16 ' I mean Ais site here alone, Ais sewage 17 our particular case, as an example, we put m a pump 17 treatment plant which is, you know, considered to be 18 and treat system over Ae objection of our local 18 one of Ae most modem technically — top of Ae 19 citizen's group. The pump and treat system Aat was 19 technical order sewage treatment plants, but I want 20 designed to be put in Aere wouldnt work, it was an 20 to tell you someAing, I've been down here at picnics 21 old technology. -1 dont know what your pump and 21 out here on Ae street here in Ais vety community 22 treat system is going to be Aat you're proposing for 22 and I want to tell you Aat Ae smell is so bad at 23 Ais site, but if ifs Ae same old technology Aat 23 times you cant eat 24 we had, it can go on for a hunAed years, 200 years, 24 Now, Aese people who live down here, I 25 300 years, you're never going to clean lip Ae 25 can go home and eat, but Aese people who live down | ' I'l^arn^iiwW^'iT/r'iJtti-nmT? Pages 74 to 77 [email protected] Mastroiaimi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500124 July 26, 2005 Page 78 Page 80 1 here Aey have to eat, too, and Aey have to eat 1 MR. PRINCE: Thank you. p 2 through Ae horrible smells Aat come from this 2 MS. NOGAKI: My name is Jane Nogaki, 3 plant, so, you know, whatever we do, whatever you 3 N-o-g-a-k-i, and I am secretaty of Ae board of Ae 4 plan to do, you should plan to mvite Ae community 4 New Jersey Environmental Federation and I'm asking 5 groups to work wiA you on Ae plan and not shove 5 some questions and making some comments tomght on 6 down Aeir throat you know, what you consider to be 6 behalf of Ae New Jersey Environmental Federation, 7 Ae right plan. 7 ifs Ae state's largest environmental organization, 8 Now, your plans may be right okay, Aey 8 we have 70,000 mdividual members and 100 member 9 may be right, but giving Aese folks an opportunity 9 groups. 10 to participate in Aat is most important and I Aink 10 We're also a member of Ae SouA Jersey 11 Aaf s what you have to consider. 11 Environmental Justice Alliance and we share Ae 12 And, you know, I dont know where your 12 concems Aat have been mentioned previously by Olga 13 office is, but we dealt a lot wiA -1 personally 13 Pomar on behalf of Camden residents. 14 have dealt a lot wiA Ae DEP over Ae years. I mean 14 As one of Ae groups who is active in 15 I've been up Aere — some years I've been up Aere 15 passage of Ae superfund act Ae original mtent of 16 evety monA meeting wiA DEP people, I take time off 16 Ae law, you know, back m Ae '80s was to get in, do 17 from my work, I go up Aere and I do battle wiA Ae 17 remedial actions, cleanup sites fest and make 18 DEP folks, all right 18 polluters pay. 19 After we got over Ae hurdle of, you 19 And one of Ae things Aat - Aat 20 know, I'm beating up on you or you're trying to hold 20 citizens pushed for m Ae law was cleanup Aat was 21 someAing back from me and we all started working 21 permeant not containment you know, but actual 22 togeAer, Aaf s when We started finding new 22 physical removal or neutralization of contaminants to 23 technologies and we have mtroduced some new 23 healA based standards and, again, making Ae 24 technologies which we are now examining in 24 polluter pay. 25 conjunction wiA DEP and Ae EPA representatives to 25 The problem wiA Ae actual p Page 79 Page 81 1 improve our water treatment system on our site and 1 implementation of Ae law is Aat too often cost and 2 we're not dumpmg one smgle Aop of Aat water mto 2 responsibile party influence is making cleanups Aat 3 Ae municipal utility auAority sewer systems, ifs 3 are basically caps and containments raAer Aan 4 going right back to Aat site and noAmg Aat comes 4 physical removal and Ais doesnt serve to protect 5 off of Ais site Aat you treat should go into Ae 5 Ae heal A of Ae residents, ifs basically a Way to 6 sewage treatment plant for Clamden County Sewage 6 leave contamination on site and we Aink it negates 7 Treatment Facility here, should not go, should stay 7 Ae whole initial purpose of Ae law. 8 right on Ae site, keep it Aere, use it to flush Ae 8 And Ae reason it does is Aat whatever 9 system and make sure you have a technology Aaf s 9 is left m Ae soil is going to continue to leach 10 gomg to meet Ae needs of your particular system. 10 down into groundwater wheAer it's historic fill, you 11 Now, m our particular Amg, we found 11 know, wheAer ifs from a tannety, wheAer ifs from 12 Aat - we're looking at a dual face extraction 12 Ae drum recycling, Aat contaminated soil has to be 13 system which we feel will substantially upgrade Ae 13 removed, all of it That should be Soil Remediation 14 pump and treat system Aat we currently have. 14 Remedy No. 7, okay, which doesnt appear in your 15 Now, Aere's a couple of oAer 15 remedies, but Aafs Ae remedy we're suggesting. 16 technologies Aat we're also looking at for Afferent 16 Soil Remedy No, 7 would be cleaning up 17 parts of this Aing, our water treatment Amg, so I 17 all Ae contammated soil at Ae site to what's 18 Aink Aat Aese are Ae kind of Aings you folks 18 called residential standards, healA based standards, 19 ought to consider and I think ifs very important to 19 so Aat Ae site would be suitable for any use in Ae 20 include Ae community. 20 fiiture. 21 To cut Ae community out by saying, you 21 Why clean up a site halfway, you know, 22 know, we're only going to give you a certain period 22 to meet some kind of, you know, mterim standard 23 of time Aat you can have input into Ais record of 23 when, really, you're only going to get one shot at a 24 decision I Aink is wrong. I think Ae whole process 24 cleanup, it should be done Ae right way to healA 25 should include Aat Thank you. 25 based standards so Aat Ais site is available for Pages 78 to 81 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500125 July 26, 2005 Page 82 Page 84 1 any potential use, residential, recreational, school 1 front of someone's house, if Aafs Ae mechanism to 2 or mdustriai. 2 evaluate that, Aat should be done immeAately. 3 And Aen I would also propose Aat Aere 3 You know, part of Ae goal of superfimd 4 be an additional Groundwater No. 6 added and Aat is 4 was to take Aese emergency remeAal actions to 5 to clean up Ae groundwater to healA based standards 5 prevent eminent hazard to healA and 1 think Aat 6 to drinking water standards and Aat all Ae 6 groundwater plume gomg off site poses an immeAate 7 groundwater be returned to Ae site. 7 risk to healA. 8 Using Ae sewer system to remediate a 8 I want to ask a question. You talked 9 superfund site is unacceptable. You're basically 9 about raAonuclides al Ae site bemg screened for, 10 usmg dilution ofa sewer system 80 million gallons a 10 were Aey actually analyzed for m groundwater, 11 day to dilute Ae contaminants to make Aem, you 11 raAonuclides? Was Aere an analysis of 12 know, meet some numerical standard at Ae end of Ae 12 radionuclides done -1 mean groundwater at this — 13 pipe, but it doesnt really isolate Aose 13 Ae site I'm referring to is Ae Martin Aaron? 14 contaminants, it just pushes Aem out through Ae 14 MR. ROBINSON: Well, when EPA Ad its 15 sewer system. 15 groundwater mvestigation as part of Ae remeAal 16 So, again, to repeat, Groundwrater 16 mvestigation for Ae Welsbach Site back m Ae late 17 Treatment No. 6 would be to clean up Ae groundwater 17 1990s, we took a number of groundwater samples irom 18 to drinking water standards and to retum it to Ae 18 Ae Martin Aaron Property. 19 site, undemeaA Ae site. 19 The wells - Ae Martin Aaron wells were 20 One Amg -1 happen to serve on Ae 20 in place at Aat time and we sampled Aem as part of 21 same Ellis Site Task Force wiA Roger Nogaki and one 21 Ae Welsbach Site and we found no raAological 22 Aing Aat happened at our site in Evesham was Aat 22 contamination m Ae groundwater. 23 because it took so long to get through remedial 23 MS. NOGAKI: You Adnt find any or it 24 design, record of decision and Ae constraction 24 was below increments of drinking — 25 design, it was over ten years before Ae soil was 25 MR. ROBINSON: I dont recall off Ae Page 83 Page 85 1 cleaned up at Ae site which meant Aat Ae plume of 1 top of my head, but Aey were below drinking water 2 groundwater contammation got much larger and much 2 standards and I believe - I'm not - of all Ae 3 more contaminated. 3 samples we sampled, Ae only contamination Aat we 4 The course of action was to do Ae soil 4 found m Ae groundwater was immeAately adjacent to 5 cleanup first as one operable unit and Aen Ae 5 Ae main sources — source areas such as Ae General 6 groundwater contamination subsequent to Aat and Ae 6 Gas Mantle buildmg m Camden and Ae Welsbach 7 problem wiA Aat is Aal Ae groundwater got much 7 Facility m Gloucester City and some of Ae dun^ 8 worse and went much further offsite and so I would 8 areas m Gloucester City. 9 recommend Aat Ais groundwater situation be 9 MS. NOGAKI: Okay. Thank you. 10 adAessed immediately because a Aousand feet of 10 MR PRINCE: And we can make Aat data 11 plume in five years from now and ten years from now 11 available to you. 12 is not going to be a Aousand feet of plume, it could 12 MS. NOGAKI: Okay. And I'm just 13 be 5,000 feet of plume. I dont know, you know, how 13 wondering, you know, back Aen, were you usmg Aat 14 fast Ais has migrated at what rate, but ifs not 14 48-hour gross alpha turnaround time test, were you 15 going to stay Aat way, ifs going to get larger, so 15 screening — analyzing wiAm 48 hours for gross 16 if Aere isnt any immediate action to contain Aat 16 alpha? 17 plume, ifs only going to spread. 17 MR. ROBINSON: I'd have to go back and 18 And, again, I would reiterate Ae point 18 look at Ae results. Off Ae top of my head, I dont 19 Aat the Edison Wetlands Associates' technical 19 know, but ^^atever Ae protocols were at Ae time, it 20 consultant made is Aat Ae vapor intrusion Aat 20 was approximately 1998, so if Aose procedures were 21 could be occurring right now to people that live 21 in place, Aen we followed Aem. 22 adjacent to that area could be threatening Aeir 22 MS. NOGAKI: And, again, I would just 23 healA and that, I consider, an eminent hazard. 23 reemphasize Aat Ae off site contamination Aat goes 24 I Aink that Ae necessaty screenmg, 24 undemeaA Ae Port facility is probably evidence 25 wheAer ifs soil screening on a right of way in 25 Aat Aere is enough soil contamination on Ae Port Pages 82 to 85 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500126 July 26,2005 Page 86 Page 88 1 facility to warrant a cleanup Aere as well, 1 attributable to particular uncontrolled releases Aat !• 2 especially when you say Aat Aedfrection of Ae 2 are identified as — and m this case, Aey are Ae 3 groundwater flow is gomg from norA to souAeast and 3 taimety operation and — and Ae subsequent drum 4 you can see Aat Ae plume artually begins over on 4 reconAtioning operation. 5 that site or do you think Aal that's — 5 So EPA's proposed remedy is tying to 6 MR. PRINCE: This picture is sort of 6 strike a balance between a protective remedy Aat 7 strong for purposes of presentation here, but Aere 7 does a complete solution for whaf s clearly 8 are oAer momtoring wells Aat are placed on Aat 8 associated wiA Ae releases and Aen a remedy Aat 9 property and this — Aese plumes Aat we've found 9 is, fi-ankly, pretty common m many parts of Ae New 10 here were not found over Aere. Now, it doesnt mean 10 Jersey and across Ae countty for levels of 11 that evety well - 11 contamination Aat are, while unacceptable for direct 12 MS. NOGAKI: Now, you dont Aink Aat 12 contact, can be adAessed through some sort ofa 13 Aere's any contribution at all from Ae SouA Jersey 13 cappmg or reuse plan, some sort of facility even 14 Port Facility located across Ae street toward Aat 14 if - sort of a park like facility Aat just has a 15 groundwater flow? 15 barrier between whatever residues are left and 16 MR. PRINCE: In terms of groundwater 16 what — and where people are actually gomg to be 17 contamination, Ae well - Ae well 'data doesnt 17 fimctioning and to Ae degree Aat -1 dont want 18 support Aat — Aat assertion, no. 18 you to Aink Aat we are evaluating Ais site in a 19 MS. NOGAKI: Okay. So, again, just to 19 vacuum, we have met wiA interested groups m Ae 20 conclude Aat Ae emergent - Ae long emergence of 20 community, we have met wiA Ae city and ifs pretty 21 this superfimd site here 20 years after its initial 21 clear Aat Ae plan for this particular property is a 22 mvestigation cries out for an immediate action at 22 commercial type or Hght industrial type reuse and — 23 Ais site and I know Aal superfund sites tend to 23 so some of Ae assumptions Aat Aen follow on m 24 take a really long time even when Aey get started 24 Ais process are based on Aat starting pomt, Aey 25 into Ae pipeline, but I Aink more remedial action 25 arent based on a startmg point of, well, Ais is Page 87 Page 89 1 needs to be taken at this site because, oAerwise, 1 ejqjected to be a pristine residential type 2 youknow, millions ofdollars will be spent on a 2 uncontrolled use type setting at Ae end of Ae day. 3 design and a constmction plan and Ae lengA of time 3 MS. NOGAKI: Well, we just disagree on 4 Aal passes before, you know, a shovel gomg m Ae 4 Aat philosophy of what Ae cleanup should be and as 5 ground to remove contaminated soil or a pump and 5 I said fix)mA e start, environmental advocacy groups, 6 treat system starting to pull back a plume is gomg 6 citizen groups felt Aat Aere shouldnt be a 7 to be, you know, ten years from now and Aal is just 7 bifurcated standard of cleanup based on fiiture use, 8 simply unacceptable m a community Aal has, you 8 Aat Ae cleanup should be, you know, to Ae best 9 know, high cancer rates for lung cancer, high asthma 9 cleanup standard, Ae healA based standard Aat 10 rales, contaminated drinking water problem, high lead 10 would allow unrestricted use, you know, Aat Aal 11 m Ae soil m all Ae residential and mdustriai 11 should be Ae standard of cleanup because you dont 12 areas, ifs completely overburdened and Ae superfund 12 know what Ae fiiture use of a property is going to 13 program is one chance to start to make Aose remedies IS be, you know, it might be industrial use tomorrow, 14 happen and it should happen here and it should happen 14 but, you know, six months or a year fit>m Aen, Aere 15 soon. Thank you. 15 might be a decision to say, you know what, lef s put 16 MR. PRINCE: I'd like to respond to a 16 some residential units here or we need this for a 17 couple of points, if I may. One of Ae items Aat 17 school site or let's make it a park or instead ofa 18 we're - we ~ who are working on Ais evaluation m ] 8 farmer's inarket, how about a real farm in Camden. 19 Ais particular site have stmggled wiA is - is 19 You shouldnt condition, you know, Ae 20 attempting to sort out what is related to a superfimd 20 future use of a site based on some prospect of a 21 problem and what is not and - so ifs not Aat we're 21 business arrangement and, you know, a fiiture buyer 22 looking at Ae site in Ae vacuum of only looking at 22 when, you know, a cleanup is really forever, it 23 what Ae releases are, but to some degree Aafs 23 should be forever, it should be unrestricted, it 24 what's expected of Ae superfund problem - program, 24 should allow any future possible use and Aafs — 25 ifs not meant to solve problems Aat arent | 25 you know, thaf s Ae philosophical difference Aat we Pages 86 to 89 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500127 July 26, 2005 Page 90 Page 92 1 have here, but I really feel Aat it was Ae mtent 1 And 1 would like to reiterate Aat Ae > 2 in Ae original law - 2 area Aafs contaminated is known and ifs not being 3 MR. PRINCE: And you - well, you have 3 used, so Aafs a piece of good news. 4 Aat philosophical difference wiA Ae law as ifs 4 The age of Ae plume is such Aat we 5 written, Aough. I mean I will -1 will Asagree 5 believe Aal it is, m essence, at its size and Aat 6 wiA you to - well, philosophically I might agree 6 ifs — apparentiy Ae levels at Ae fiuthestmos t 7 wiA you. I would Asagree wiA you Aat Ae content 7 pomt are vety close to drinking water standards 8 of superfimd law as written is Aat EPA evaluates 8 already and we think Aat ifs, m essence, m a 9 what Ae future land uses are experted to be based on 9 decay for Ae VOCs as it leaves Ae site. 10 consulting Ae ovwner, m this case, Aafs not really 10 Be Aal as it may, EPA is pnposmg a 11 relevant but Ae — m particular, Ae city m this 11 remedy Aat altenqrts to meet groundwater standards 12 case who is ~ has a plannmg process, this parcel is 12 throughout this zone and what you are objecting to, 13 in Aat planning process and fm not certain Aere's 13 m particular, is Aat Ae process diat we are 14 really much disagreement in Ae sort of larger scale, 14 proposmg is Aal once we pull it om of Ae ground, 15 sort of master plan scale while Aere may be 15 we do some sort of treatment to meet a standard that 16 disagreements about oAer lots m Waterfront SouA, I 16 is set by Ae municipal sewage auAority and Aen 17 dont Aink Aere's much disagreement about Ae 17 Ascharges mto Aeir system because Aey would 18 planned future use of this particular formerly 18 accept it and we Ad look at some of Ae oAer 19 industrial expected to fiiture be non-residential type 19 alternatives, we Ad look at meAods of— I think 20 use for Ais particular property and Aafs a vety 20 someone - it may have been you who mentioned sort of 21 important - in fact, integral part of EPA's analysis 21 flushing - 22 of Ae site. 22 MS. NOGAKI: Remjection. 23 I would also like to — 23 MR PRINCE: A reinjection and Aere are 24 MS. NOGAKI: Well, I Aink ifs just 24 a number of factors Aal make Aat pretty hard to do 25 cost driven. You know, ifs going to be a cheaper 25 here. I'm - we werent confident Aat it would be Page 91 Page 93 1 cleanup. Youknow, Ae fiitureus e of Ae site-you 1 successful, so ifs not Aat we didnt lode at it, 2 know, ifs just like why wouldnt EPA want to go for 2 ifs Aat given Ae local conditions, it seemed like 3 Ae best possible cleanup, ifs cost, you know, and I 3 Aere - it might fail as a meAod of disposmg of 4 recognize, yes, cost is one of Ae, you know, things 4 Ais treated water, so ifs not — we did evaluate 5 Aat you have to look at, but say Aal Aafs, you 5 that and Ae altemative Aat we — we recommended 6 know, what it is, dont pretend Aat ifs, you know, 6 anoAer approach because it seemed much more likely 7 because ofsome, you know, economic development, ifs 7 to succeed. 8 a matter of cost 8 MS. NOGAKI: Was Aere anyAmg else? 9 MR. PRINCE: Well, as I say, we can 9 MR. PRINCE: No. Thank you. 10 Asagree about Ae content of Ae law, but we're — 10 MS. PFEIFFER: My name is Barbara 11 Aere's a process Aal EPA is obliged to follow m 11 Pfeiffer, P-f-e-i-f-f-e-r, and I am a resident and 12 evaluating sites and I would contend Aat Aafs Ae 12 Ais is a lot to understand, I would just hope Aat 13 process Aat we're going through here. 13 you could extend Ae public comment period. There 14 MS. NOGAKI: Well, Aere's also a part 14 are many residents in Waterfront South, so I hope you 15 m Ae law Aal says community acceptance of a remedy 15 dont only consider Ae commercial value of what 16 is an important— 16 you're doing - what you're doing because Ae 17 MR. PRINCE: Absolutely. 17 residents, even Aough you say Ae site is going to 18 MS. NOGAKI: - stiategy as well. 18 be commercial, from what I understand, it affects 19 MR. PRINCE: Absolutely. 19 residents, too, so Ijust —Aere are many people 20 I would also like to mention wiA regard 20 mterested, Aere are many people who care about Ae 21 to your comments Aal you had observed Aal it was 21 residents of Waterfront SouA and not just Ae money 22 a - it was necessaty Aat EPA approach Ae 22 Aafs gomg to come from Ae commercial properties, 23 groundwater as if Ae goal, were to clean it all up 23 people have lived here all Aeir lives for 24 and - and to reach drinking water standards for Ais 24 generationsand —sol dojust —Idontseewhy 25 area Aafs contaminated. 25 you could not extend Ae public comment period so Pages 90 to 93 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500128 July 26, 2005 Page 94 Page 96 1 Aat we can really have a lot of input. There are a 1 SouA. !• 2 lot of people mterested. 2 Now, Aere is a science advisoty board 3 MR. PRINCE: EPA frequentlyextend s 3 Aafs associated wiA Waterfront SouA and we 4 public comment period as much - public comment 4 actually tried to meet wiA Aem over Ae past couple 5 periods as much as 30 days, so Aat would be a 60-day 5 of weeks and we havent been successfiil, and domg 6 public comment period into, I guess, middle of 6 Aatjust because ofAe timing, and we would 7 September and Ae type of response Aat we hear at 7 actually welcome Ae opportunity to meet wiA Aat 8 meetings like this is obviously a major influence 8 group, in part, because Aey have certain expertise 9 anA unfortunately, ifs not specifically my decision 9 Aal Aey can bring to environmental issues and a 10 to make, but we will certainly resolve that and based 10 certain sort of knowledge Aal maybe oAers in Ae 11 on experience at oAer sites, I would expect Aat we 11 community wouldnt have and it might be useful for us 12 probably will extend it. 12 to speak wiA Aem. 13 MR. JONES: My name is Roy Jones, 13 A member of EPA, a Dave Rossoff 14 coordinator of Ae SouA Jersey Environmental Justice 14 (phonetic) who is here tonight is a member of Aat 15 Alliance and — I just had some dental work so you 15 science advisoty board and, unfortunately, it just — 16 might have to tolerate me. 16 Ae timing of schedules hasnt worked out so Aal 17 I have some questions. One, who are 17 we've been able to meet before Aem, but we would 18 some of Ae responsibile parties? 18 welcome Aal opportunity if it could be made to work. 19 MR. PRINCE: You know, could I provide a 19 MR JONES: Well, I do have a pomt 20 list to you separate from Ais meeting just because I 20 I'm not certain you're avrare that m this city, you 21 dont have it 21 can be — you can be cited for a parking ticket for 22 MR. JONES: Okay. And Ae second 22 $17. Ifyoujust dont happen to pay for it wiAm a 23 question is, Aere was a number of violations really 23 certain period, you'll get a warrant And if it 24 starting from 1972 and Aen it just went completely 24 Adnt go to your right adAess, Aen Ae police 25 ridiculous between '83 and '87 which is about — 25 could pick you up and lock you up for a $ 17 parking li Page 95 Page 97 1 well, from '83 to 1998 which is about 15 years of 1 ticket 2 violations. You cited Aem, right— 2 And yet you had Ais company for years 3 MR. PRINCE: EPA. 3 violating Ae law, no one was arresteA you dont 4 MR. JONES: - and yet Ae company was 4 really have a serious record of fining this company 5 not shut dowTi, could you explain why not? 5 and Aenat Ae end of Ae day, today, nearly 6 MR. PRINCE: Fm afiaid Aat I cant 6 30 years later, you tell us Aat we're gomg to 7 explain Aat in part, because Aey were cited under 7 meet — in terms of Ae cleanup standard we're going 8 a program called RCRA (phonetic) Aat deals wiA 8 to do really what amounts to minimal cleanup 9 operating facilities and Ae primaty - Ae primaty 9 standards. 10 jurisdiction for RCRA happens - is typically Ae 10 And I would suggest to Aat - to you is 11 state and most of Ae - most of Ae violations were 11 Ais, people are affected in Ais city evety day, in 12 cited by Ae state. 12 particular Ais community, you should clean this site 13 I can -1 can clarify what Ae process 13 up to Ae highest standard you owe Aat to Ae 14 was back Aen in written responses, but I dont 14 people m this community. 15 really have Ae details of sort of Ae sequence of 15 People are locked up and penalized for 16 events tonight 16 welfare fraud for trying to get an extra dollar for 17 MR. JONES: And you said Aere were some 17 food stamps and you allowed Ais corporate predator 18 interested groups Aat you met wiA in Ae city, now 18 to destroy Ais community. At Ae end of Ae day, no 19 who were Aey? 19 one was ever penalized in any real way because of 20 MR. PRINCE: Well, obviously, we've met 20 this. 21 wiA Ae city, we've met wiA Heart of (Camden, we've 21 And now we hear today Aat how you're 22 met wiA - what oAer groups have we met wiA? 22 going to clean Ais site up really is going to be at 23 MS. LONEY: I cant remember. 23 a minimal level, so my point to you is Aat you owe 24 MR. PRINCE: Sorty. Waterfront SouA, 24 Ae people of Ais community, in particular Camden, 25 we met wiA some representatives from Waterfront 25 at least Ae cleanup of this site at Ae hi^est Pages 94 to 97 [email protected] Mastroianni & Formaroli, Inc. &56-546-1100 Professionals Serving Professionals 500129 July 26,2005 Page 98 Page 100 1 1 possible standard and we would like to know and 1 MR. ROBINSON: We're going to be r 2 expose Aese responsible parties Aat have been 2 removing all of Ae radiological contamination from 3 hiAng behind Ae law and hidmg behind Ae EPA and 3 , Aal property, we have a design m place and we're 4 DEP professionalism or lack of it and destroying this 4 awaiting federal fundmg for Aat work. 5 minority community. 5 MR. LYONS: Okay. Thank you. That's 6 So at Ae end of Ae day, you should 6 what I needed to know. 7 clean Ais site up at Ae highest possible standard, 7 MR. ROBINSON: Okay 8 Aafs my point, because Aey violated Ae law, you 8 MR. LYONS: Regarding Ae Martm Aaron 9 allowed Aem to skate - escape any penalty and Aen 9 Site, based on what I've heard this evening, Aere is 10 today many people here are sick and Ae after affects 10 an obvious need to continue Ae evaluation of Ae 11 of this site will contmue for Ae next 30 or 40 11 scientific remedies for cleaning up Ae site. 12 years. 12 I would agree Aat fiill cleanup is Ae 13 So Ae idea Aat you met wiA Ae city 13 goal, should be Ae goal for Ais as any oAer 14 when Ae city now is engaged in a wholesale of 14 contaminated site which bears such close proximity to 15 displacement of hunAeds of people, you really should 15 people working and living m this community and not 16 listen to Ae citizens is my point. 16 beingascientist Ihavenoway ofevaluatmg 17 And finally, I do want a list of Ae 17 wheAer one solution is better Aan anoAer, but 18 responsible parties because my group will be a part 18 Aere seems to be — seems to have been enough 19 of, at least, exposing Aese people for what happened 19 discussion tomght Aat opens Ae door to more 20 in Ais neighborhood. Thank you. 20 evaluation of what is a better remedy. 21 MR. PRINCE: Thank you. 21 As obvious is Ae need to extend Ae 22 MR. LYONS: My name is Charles Lyons, 22 public comment period, and I understand from your 23 L-y-o-n-s, I'm chief of planning for Ae City of 23 response is Aat Aafs likely to h^pen, so we 24 Camden. I have met wiA EPA staff boA on this 24 welcome, you know, more time for people to take in 25 project, the Martm Aaron project as well as Ae 25 Ae information and to respond accordingly. I Page 99 Page 101 1 Welsbach. 1 Environmental justice is Ae hallmark of 2 I have essentially one question and four 2 what Ae City of Camden's concem is for this 3 comments. My first question, I was out m Ae 3 community and has been since we first started Ae 4 hallway talking wiA Andy Krick (phonetic) and so I 4 Waterfront SouA Environmental Plannmg Task Force 5 missed Ae part about what's happenmg m Camden 5 back in 1999. We want to emphasize Aat m Ais 6 regarding Ae Welsbach Gas Mantie Site. What is Ae 6 particular case, environmental justice equals 7 remedy? 7 environmental health. 8 MR. ROBINSON: This is Ae remedy for 8 This is, as ifs been said time and time 9 Ae groundwater - not Ae groundwater, for Ae 9 again, a severely impacted community Aat has a wide 10 surface water sediment wetiand areas Aat are 10 range of heal A threatening, if not life threatening 11 adjacent to Ae Welsbach contaminated property and we 11 illnesses directly responsible from Ae environment, 12 found no radiological contamination m Ae water 12 so we would like to see more done to adAess Ae 13 bodies, and, Aerefore, we're proposing no remeAal 13 people at Ae same time as you're adAessing what to 14 action. 14 do wiA contaminated property. 15 MR. LYONS: Okay. But previously EPA 15 I believe a more comprehensive, as 16 Region 2, under Ae superfund program, demolished Ae 16 Ms. Pomar pointed out in her comments, to talk about 17 Welsbach Factoty and covered Ae site wiA gravel. 17 environmental heal A as it applies to one side and 18 MR. ROBINSON: TTiafs Ae General Gas 18 not take into consideration that Aere are 15 oAer 19 Mantie Facility on SouA 4A Sfreet? 19 contammated sites in Ais one neighborhood misses 20 MR LYONS: Right 20 Ae point 21 MR. ROBINSON: Yes. 21 We have to look at the cumulative affect 22 MR LYONS: Is Aal Ae extent of Ae 22 of whaf s going on wiA Gas Mantle, wiA Martin 23 action Aat you're going to take to clean Aat site? 23 Aaron, wiA Ae highway, Camden fron and Metal, so 24 MR. ROBINSON: No. 24 forA and so on and I believe because of initiatives 25 MR. LYONS: Okay. 25 taken by New Jersey Department of Environmental Pages 98 to 101 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500130 July 26, 2005 Page 102 Page 104 1 Protection an opportumty has presented itself for at 1 MR SPIEGEL: And did you find any site 2 least Ae last 12 months to address environmental 2 related raAological contaminates in Ae wetiands or 3 healA issues from an inner agency standpomt and I 3 m Ae stream? 4 would mvite EPA to woric vety closely wiA DEP and 4 MR ROBINSON: No. 5 Ae city and Ae Camden County Department of HealA 5 MR SPIEGEL: No. 6 m looking at a way to accurately assess Ae 6 MR ROBINSON: All Ae levels were at 7 environmental intact on people's healA here and Aen 7 background levels. 8 devise sort some of remedy. 8 MR SPIEGEL: Okay. Because it says 9 Regarding Ae site reuse for Martin 9 Aal later on Aat you subtracted Ae background 10 Aaron. The Waterfront SouA Redevelopment Plan calls 10 levels from what was found to calculate Ae risk? 11 for Aat site to be reused for commercial. This is 11 MR ROBINSON: Correct 12 m keeping wiA Ae fact Aat Broadway is one of Ae 12 MR SPIEGEL: So were Aere anything 13 most significant commercial comdors m Ae City of 13 besides background levels Aere? 14 Camden as well as Camden County. 14 MR. ROBINSON: When you look at 15 While we are aware Aat Comarco Port 15 raAonuclides, ifs not — Ae background is a range 16 Products is looking to expar\d and Aal would be Ae 16 of background, so you have a range ranging from less 17 only mdustriai use, I would envision, encroaching on 17 Aan a picoCuries per gram up to a couple of 18 this site, we were proposmg a farmer's market 18 picoCuries per gram and what you do is you take a 19 primarily so that we would get to Ae most stringent 19 number of samples and you take a statistical — 20 levels of cleanup to adequately protect food and 20 perform a statistical analysis on Aat data and you 21 people on Ae site. 21 come up wiA a median or mean number and Aafs Ae 22 So while we do not envision Aat Ais 22 number you use as a background number and Aen we 23 will ever be housmg, we believe cleaning Ais site 23 take Aat number and we subtract Aat number from a 24 properly will allow a neighboAood commercial 24 general sample and to see what Aal number comes out 25 enterprise that will serve Ae residents to flourish. 25 to be. Sometimes ifs negative, sometimes ifs Page 103 Page 105 # 1 And finally, Ae City of Camden joms 1 positive. 2 wiA all oAer environmental justice, environmental 2 MR. SPIEGEL: So Ad you find levels of 3 healA advocates to call for a full and effective 3 raAologicals m Ae wetiands or m Aat area Aat 4 parmership of community, government and busmesses 4 were consistent wiA what you considered to be 5 such as task forces Aal we've already established 5 backgrounds levels? 6 and Aat have been suggested by Ae gentleman from 6 MR. ROBINSON: Correct Background 7 Evesham Township to have a fiill and effective 7 levels, yes. 8 partnership and do Ais project to improve Ae 8 MR. SPIEGEL: So you Ad find - so you 9 quality of life in Waterfront SouA which, to us, is 9 did find radiologicals Aere, but you considered Aem 10 Aegoal. It is not important to fix Ae blame. It 10 to be background levels or below background because 11 is more important to fix Ae problem. 11 you subtracted out Ae background levels - what you 12 MR. SPIEGEL: My name is Bob Spiegel, 12 considered to be background levels from Aal? 13 I'm Ae executive director of EWA, we're a nonprofit 13 MR. ROBINSON: Yes. 14 advocacy group based in Central New Jersey. And Ais 14 MR. SPIEGEL: And Aen it says Aat you 15 was Ae first time I actually looked at Ae second 15 had a variety of non-site related contaminants. 16 cleanup plan for Ae Gas Mantie Company and I had a 16 arsenic, lead, benzo(a)pyrene, PAHs, pesticides - a 17 couple of questions and Aen a couple of concems. 17 number of different pesticides, PCBs, Aose were all 18 The first question really revolves 18 additionally found in Ae sediments in Ae creek? 19 around Page No. 5 where you talk about Ae potential 19 MR. ROBINSON: Yies, Ae Delaware River 20 contaminants of concems Aat were evaluated and 20 and Newton Creek. 21 maybe you can clarify Ae fact Aat you evaluated 21 MR. SPIEGEL: Okay. And Aat was based 22 certain radiological contaminants in Ae wetiand 22 on data collected by EPA? 23 areas as part of Ais evaluation and Aen looked at 23 MR. ROBINSON: Yeah, as part of our 24 Ae risk posed by Aose contaminants. 24 analysis, we did a — we did a — boA chemical and 25 MR ROBINSON: Yes. 25 radiological samplmg. Pages 102 to 105 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500131 July 26, 2005 Page 106 Page 108 1 MR. SPIEGEL: And if you were - so you 1 Aat. ^ 2 did Ais analysis as part of your characterization of 2 MR. BARONE: Basically, for Ae 3 Ae work Aat you were domg at Ae site, but your 3 radiological contamination, we estimated risks due to 4 goal was to identify radiological contamination at 4 natural background which we identified at these areas 5 Ae site which is Ae only Aing you're going to be 5 here, we came up wiA Aal risk. Then we took our 6 responsible for adAessmg? 6 samples Aat were collected throughout Ae water 7 MR. ROBINSON: Yeah. What we did is 7 bodies and also estimated Aose risks. We found Aat 8 when you - we had a superfimd site on Ae land 8 Aose risks were identical to risk due to natural 9 portion, we wanted to see if Aat contamination made 9 backgrounA however we also subtracted out natural 10 it into Ae water bodies and Aen when we do an 10 background from our samples to come up wiA Ae net 11 evaluation of Ae water bodies, ifs EPA's policy to 11 risk. 12 look al all chemicals of concem. 12 MR. SPIEGEL: And Ae areas Aat you 13 And right now — when we did Ais study, 13 sampled to get natural backgrounA how Ad Aose 14 we didnt know if Aere was radiological 14 levels compare wiA like anoAer area farther outside 15 contamination in Aat water body and after Ae study, 15 Camden, are Aose above what Aey consider to be — 16 we found Aat Aere was no radiologicals, we did find 16 were Aose consistent with, lef s say, oAer areas 17 Ae chemical contamination in Ae water bodies, 17 like Princeton or - 18 however because Aere is no RAD m Ae water bodies, 18 MR.. ROBINSON: They were similar - Ae 19 Aen Ae water bodies are not part of Ae superfimd 19 background levels Aat we found m our 20 site. 20 radiological — our radiological background samples 21 MR. SPIEGEL: Well, you did find 21 Aat we collected in Aose five areas were basically 22 radiation, but you considered Aat radiation to be 22 identical to Ae statewide averages, so it was really 23 background — 23 no different. 24 MR. ROBINSON; Background levels. 24 MR. SPIEGEL: So Aere wasnt any spikes 25 MR. SPIEGEL: - levels? 25 higher or lower? I Page 107 Page 109 1 MR. ROBINSON: Yes. 1 MR ROBINSON: WiAin Ae range of 2 MR. SPIEGEL: So you looked - and Ae 2 background, Aey were all within Aat same range. 3 risk assessor, maybe he can touch upon it if he's 3 MR. SPIEGEL: What, you added Aem all 4 still around. 4 up and Aen divided by five, is — 5 MR. ROBINSON: No, Michael wasnt Ae 5 MR. ROBINSON: Well, it depends on - ' 6 risk assessor for Ae Welsbach Site, but I have 6 no, Aere was more Aan Aat many samples. Ifs — 7 someone who — here who can help on some of Aose — 7 we had to take a number of samples to give us a 95 8 MR. SPIEGEL: Okay. Well, I'm fryingt o 8 percent confidence limit so Aat we're - we — that 9 understand how Ae riskwa s calculated and why Aere 9 Ae number is a valid number. 10 was no action, why no action was bemg proposed for 10 MR. SPIEGEL: If you took Ae - Ae 11 that site. 11 numbers Aal you found m Ae sediments in Ae 12 So you separated out Ae 12 surfacewater, Ae total number of san^les, and you 13 non-radiological contamination when you did your risk 13 added m all Aose oAer chemicals Aat were non-site 14 assessment you separated out Ae background levels 14 related Aat you sampled for, but had no mtentions 15 of radiation Aal you found where you considered to 15 of, I guess, cleaning up as part of this cleanup, 16 be background and Aen taking what's left, you 16 would Ais site - would Aese wetlands present a 17 calculated out Ae risk for Aat site, Ae 17 risk to human heal A and Ae environment? 18 wetlands - Ae surface water, is Aat Ae correct 18 MR. ROBINSON: If you look at Ae risk 19 meAodology Aat you used? 19 assessment report it did mdicate Aat Aere were 20; MR. ROBINSON: Mike, do you want to come 20 unacceptable risks m Ae surface water boAes for 21 up? This is Mike Barone wiA Malcohn Kiemey 21 Ae chemicals of concem oAer Aan Ae — excluding 22 (phonetic) and Malcolm Kiemey was Ae company Aat 22 AeRAD. 23 Ad Ae remedial mvestigation for us for Ais 23 So Ae RAD showed no risk,howeve r Ae 24 operable unit and Mike is Ae risk assessor for 24 chemicals - Ae PCBs were Ae primaty contaminant of 25 Malcolm Kiemey and he can go over the background on 25, concem that did have a-show of risk. ae>jtife«±ocatiaaMa>a(faefcs*^>j Pages 106 to 109 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500132 July 26,2005 Page 110 Page 1,12 1 MR. SPIEGEL: And - but Ae - normally 1 MR. SPIEGEL: Okay. Well, just Aat r 2 you're saying Aat Ae background wouldnt present a 2 some of Ae language you use in your proposed plan 3 risk, but in - if you took Ae background levels 3 kind of maybe is technically accurate, bm does not 4 Aat were present and added Aat to Ae chemical 4 give you, I guess, Ae proper information like when 5 contaminants, would Aat mcrease Ae risk at all in 5 you talk about your contammates of concem at Ae 6 any substantial way? I'm just trying to understand 6 vety end, it says Aat, m general, Ae area 7 your process because ~ 7 surrounding Ae site mcludes historic and current 8 MR. ROBINSON: I know where you - you 8 manufacturing facilities Aat used a variety of 9 want to say for Ae synergistic effect — 9 chemicals Aal were not m use or available when 10 MR. SPIEGEL: Is Aere any increase m 10 Welsh [sic] made gas manties and this supports EPA's 11 risk above backgrounA Aafs basically what I'd like 11 conclusion Aal Ae non-radiological chemicals are 12 to find out? 12 not related to Ae Welch Site. 13 MR. ROBINSON: The risk wiA Ae 13 MR. ROBINSON: The Welsbach. 14 chemicals of concem, mostly Ae PCBs, were - what's 14 MR. SPIEGEL: fm sorty. The Welsbach 15 Ae best way — you want to — I'm not a risk 15 Site. 16 assessor, so Aafs why I'm — a risk assessor who 16 When — as far as I know, lead has been 17 did our risk assessment — 17 around for a vety, vety long time and arsenic has 18 MR. SPIEGEL: I'm not eiAer, but I play 18 been around for quite sometime as well and so, again, 19 one on TV. 19 you know, Ae wording of this is kind of a little 20 MR. ROBINSON: Our risk assessor didnt 20 deceiving because it leaves one to Ae conclusion 21 show — wasnt able to make it tonight, so she's Ae 21 Aat, you knoW, Aat Aese are definitely not site 22 one who usually answers Aose questions. 22 related and Aese chemicals, you know, just werent 23 MR. BARONE: We didnt find any risks 23 around at Ae time Aat this site was in operation. 24 associated wiA any of Ae RAD samples Aat we 24 MR. ROBINSON: Generally, Ae primaty 25 collected, so if you take Aose risks and you add 25 chemical contaminant of concern, again, is Ae PCBs Page 111 Page 113 1 Aem to any risk that you had from chemicals, 1 and Ae PCBs came into wide use well after Welsbach 2 non-radiological chemicals, Aey wouldnt increase 2 went out — Welsbach and General Gas Mantle went out 3 Ae risks, Ae total risks. 3 of business. 4 MR. SPIEGEL: So it wouldnt increase it 4 MR SPIEGEL: Sure. But Aafs Ae way 5 at all ifone does not impact AeoAer? 5 it should be reflected, not just lumping all Ae 6 MR. BARONE: Thaf s coirect 6 chemicals into Aal category: 7 MR. SPIEGEL: And did you - were you 7 Speaking on Ae Martin Aaron Site, Aere 8 able to locate Ae sources of Aose non-site related 8 was number of technical comments niade by Rich Chapin 9 contaminants? 9 Aal reflected E WA's position on Ae cleanup, and I 10 MR. ROBINSON: No, ifs basically 10 only have to two to add. One is I think Ae EPA 11 ubiquitous throughout Ae water boAes. 11 needs to immediately screen Ae residoitial homes for 12 MR. SPIEGEL: But Aere was no - 12 vapor intrusion. 13 nothing in proximity to Ae location that — 13 As we know in Endicott New Yoik and 14 MR. ROBINSON; Not Aat we could find. 14 oAer locations throughout Ae countty, vapor 15 Basically, as part of our investigation work, you 15 intrusion is now looked — being looked at as a 16 know, we determined Aat - we were informed Aal 16 significant exposure paAway for public healA and to 17 Aere's a "do not eat fish" asJvisoty for Ae Delaware 17 wait until Ae data shows eminent harm or Aat Ae 18 River and Ae water bodies adjacent to Ae site 18 potential for eminent harm may be exposing Aese 19 properties and Ae primary level - contaminate of 19 residents to adAtional insults Aal Aey're already 20 concem Aafs driving Aat "do not eat fish" 20 experiencing, so Aafs Ae first Aing. 21 advisoiy is PCBs. 21 Fd like to know what goes mto getting 22 So Ae State of New Jersey actually 22 Aat evaluation, getting Ae Tagget trailw 23 right how is - has a - is starting to look at Ae 23 (phonetic) from Ae EPA to come up here from Edison 24 issues and Aere's a representative here w^o can talk 24 to do a quick evaluation, is Aat someAing that can 25 to you after the meeting about that. 25 be done in an expedited way? ri'Htriihfi/t'iM'-inHiirH'^' Pages 110 to 113 [email protected] Mastroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500133 July 26; 2005 Page 114 Page 116 1 MR. SPfVAK: PeAaps, I wasnt vety 1 groundwater to figure om is Ais an immediate I 2 clear m my earlier response and 1 qwlogize for 2 threat, can we deal wiA - do you we need to deal 3 Aat. EPA has looked alAe issue of volatiles in 3 wiA it right away or can we sort of roll it out as 4 Ae groundwater al this site, so I dont want anyone 4 we do Ae subsequent mvestigations or additional 5 in Ae audience to think Aat we're not taking Ais 5 mvestigations so Aat we're getting kind of Ae best 6 issue vety seriously. EPA is committed to looking at 6 data Aal we can get 7 vapor intrusion at this site as well as all of our 7 At Ais pomt ifs not appropriate to 8 sites, so Aafs Ae first issue is Aat you need to 8 or — to get to Tagget unit out Aere as you suggest 9 recognize Aat we are looking al it okay. 9 to go mto Aese homes and look for alternate sources 10 We have started looking al Ae v^x)r 10 of- 11 intrusion mvestigation of Ais site by looking at 11 MR. SPIEGEL: So looking al EPA's 12 where Ae highest concentrations of VOCs were. We 12 cartoon up Aere, how would you say Aat Ae — you 13 dont immediately go out and start sampling homes, we 13 know, Aat adequately reflects, m oAer words, Ae 14 look to see where is our plume, where are Ae highest 14 level of - to Ae ground water al Ae - where Ae 15 concentrations of contaminants in our plume, where 15 residential homes are? 16 are Aose highest concentrations relative to occupied 16 MR SPIVAK: Okay. I'm a risk assessor, 17 bmldings, residential buildmgs, commercial 17 so Ais is a really, really bad diagram for me to 18 buildings, what is Ae likelihood Aat Ae vapor 18 look off of I look at Ae one -1 look al Ae maps 19 intrusion phenomenon or Aat fate and transport 19 where it shows Ae plumes and Ae contours and Ae 20 paAway is going to occur at Aese sites, we've 20 concentrations Aat we're seeing in Ae wells 21 afready started looking at Aat. 21 relative to Ae occupied stractures and based on 22 We recognize Aat Ae highest 22 Aat, we compare Aose concentrations to EPA's Vapor 23 concentrations m VOCs m Ae groundwater at Ais 23 Intrusion Guidance, Ae screenmg levels Aat are 24 site in Ae shallow Upper PRM are concentrated in Ae 24 presented in Aere, we apply our judgment regardmg 25 center of Ae site where Aere are no buildings 25 fate and fransportmechanism s associated wiA Ae I Page 115 Page 117 1 currently m existence. 1 subsurface geology at Ais particular site, we look 2 We do recognize Aat Aere are occupied 2 al Ae types of stmctures we're dealing with, we 3 structures, occupied homes at Ae souAem portion of 3 look at Ae levels of VOCs in Ae groundwater and we 4 Ais property, but Aat Ae wells in Aat area are 4 draw our conclusions based on Aat 5 not indicating concentrations anywhere near what 5 MR SPIEGEL: And what are you using for 6 we're seeing in Ae primaty source area for VOCs. 6 your risk based model, what number? 7 We are evaluating this, we recognize 7 MR SPIVAK: We're using Ae 8 Aat ifs not - Ae concentrations Aat we're seeing 8 concentrations Aat are presented in EPA's Draft 9 in Ae plume as it extends down in Aat area are 9 Vapor Inttusion Guidance, Ae November 2002 document 10 nowhere near as high as what we're seeing at Ae 10 MR SPIEGEL: The concentration is 11 source area, we will be looking at Aat in Ae 11 .0 — what is Ae concentration being used for in 12 future, Aere is not an immediate threat to public 12 comparison for Ae risk assessment? 13 heal A in Ae environment from Ae vapor intrusion 13 MR SPIVAK: For what chemical are 14 paAway and Aat needs to be made clear. You — 14 you — 15 MR. SPIEGEL: Is Aat based on a 15 MR SPIEGEL: For Ae volatiles. 16 numerical risk assessment? 16 MR SPFVAK: Evety VOC would have its 17 MR. SPfVAK: If s based on screening Ae 17 own chemical specific screening value. 18 data Aat we have right now for Ae Upper PRM. 18 MR SPIEGEL: Well, TCE is Ae one 19 MR. SPIEGEL: Okay. So ifs based on 19 you're looking at right? 20 basically numerical, not actually any data collected 20 MR SPIVAK: Well, Aere are a number of 21 from ~ 21 VOCs here at Ais site, but we do have TCE at Ais 22 MR SPIVAK: We have not collected soil 22 site. The 10 to Ae -6 concentration for TCE in 23 gas data. Any soil gas data Aat we get would 23 indoor air would be 0.016 micrograms pa- cubic meter, 24 volatilize from Ae groundwater, so we're looking at 24 Ae upper bound of Aat risk range would be 1.6 25 Ae primaty source of Ae contamination which is Ae 25 micrograms per cubic meter, but Aose are indoor air Pages 114 to 117 [email protected] Masfroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500134 July 26,2005 Page 118 Page 120 I 1 concentrations. We dont have indoor air 1 just is Aat I also agree wiA Ae oAer speakers 2 ccmcentraticHis, we have groundwater concentrations, 2 Aat came up here Aal Ae 300 number is excessive 3 so we'd have to back calculate Aat. 3 for looking at Ae arsenic levels and I would suggest 4 The numbers Aat are m Ae Vapor 4 Aat Ae community and Ae township fight tooA and 5 IntriisiOn Gmdance al Ae 10 to -6 number, Ae policy 5 nail to - and also Ae DEP to go for Aat 20 number 6 is MCL at 5 micrograms per cubic meter. We do exceed 6 because if we start looking al sites and allow 300 7 Aat we are at about 11 micrograms per cubic meter at 7 ppm to be Ae standard mdustty is gomg to say, 8 our maximum detected concentration, I believe, of TCE 8 look at this, we should have 300, we should have 500, 9 ingroundwater, IthinkAatitwas 11. 9 Ae standards will just keep gomg up and up wiA Ae 10 MR. SPIEGEL: So if s in Ae upper 10 cleanup. 11 boundaries of that? 11 The cleanup standard I believe Ae 12 MR. SPFVAK: Thafs Ae 10 to Ae -6 12 healA based criteria for arsenic, is .6, if I'm 13 range, we have a risk range of 10 to Ae -6 - 1S correct for Ae heal A based criteria, 20 was used 14 MR. SPIEGEL: lOtoAe-4, 14 because it was an economic number, it used to be 2, 15 MR SPIVAK: - to 10 to Ae -4, right, 15 Aen it became 20, Aen 20 became Ae standard but 16 so we are certainly within that range. 16 ifs not a heal A based number. 17 MR SPIEGEL: Okay. And does Aal - do 17 So now we're looking at having several 18 you &ctor in also Aal Ae air quality raAus is 18 hunAed parts per million be Ae number Aafs, 19 poOT here and that Ais may be exacerbated by Ae 19 quote/unquote, acceptable and I would encourage DEP 20 fact Aat you know, generally speaking, Ae air 20 and Ae residents and evetybody to not accept Aal. 21 quality around here is really not good to begin wiA? 21 Thank you. 22 MR SPFVAK: Yeah, Aafs a really, 22 MR. PRINCE: Thank you. 23 really tough issue and I Aink John talked about Aat 23 (Brief recess was taken.) 24 a littie bit earlier. Unfortunately, when we look al 24 MR.FRANaS: My name is Kelly Francis, 25 superfimd sites, we look al site related 25 I'm currently president of Ae Camden County Branch l» Page 119 Page 121 1 contamination. We look at all Ae contamination 1 of Ae NAACP, we are headquartered in Ae City of 2 Aafs out Aere, but we focus our risks on our site 2 Camden for Ae past 60 some years. I've been a 3 related contaminants and, you know, Aafs Ae way — 3 resident of Camden for — smce 1949. There's one 4 Aafs Ae way Aat our process is, Aafs Ae way 4 technical Aing I want to clear up. 5 Aal Ae law is structured. I mean we could debate 5 On page 11 of Ae Welsbach/General Gas 6 Aat but Aafs Ae way Aat Ae law is stmctured. 6 Mantle Contamination information sheet page 11, 7 MR. SPIEGEL: So if s everyAing 7 Study Area 3 geographically, is Aal in Ae ri^t 8 operates in a vacuum, so to speak? 8 location geographically for Study Area 3? 9 MR. SPIVAK: We have a responsibility 9 MR ROBINSON: Sttidy Area 3 is in 10 under Ae superfimd law to look at what are Ae risks 10 Gloucester City. 11 associated wiA Ae site contaminants now and m Ae 11 MR. FRANCIS: Okay 12 fiiture if no remedial action occurs, Aafs how we 12 MR ROBINSON: And it's Ae area along 13 have to develop our risks, Aafs what we have to 13 Essex Street Essex Street and Ae railroad, and also 14 lode al under Ais approach. 14 includes Ae — a yard up on Broadway souA of Newton 15 Are Aere oAer risk paradines out Aere 15 Creek. Here's Newton Creek. This is Ae Ime 16 that would allow more ofa cumulative risk based 16 between CJamden — Ae red line on Ae map is dividing 17 approach, yes, Aere are, EPA is working on a variety 17 between C^amden and Gloucester City. So Study Area 3 18 of fiameworks like Aal, but you also have to 18 is in Gloucester City. 19 understand Aat Ae superfund process is vety - is 19 MR. FRANCIS: All right But now on 20 vety descriptive in what we look at and what we have 20 page 11, you have it located in Camden, Study Area 3 21 auAority over and what we evaluate and Aose are 21 located in Camden. 22 vety different processes and you understand Aat, I 22 MR. ROBINSON: There's an arrow Aat on 23 know you do, you understand Aat, and we're focused 23 Ais map, doesnt quite point to Study Area 3. 24 on what we can look at. 24 There's a — 25 MR. SPIEGEL: Okay. And my last conunent 25 MR FRANCIS: This is Camden, Ais is Pages 11810 121 [email protected] Masfroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500135 July 26, 2005 Page 122 Page 124 1 Ae Morgan Village area. 1 So my question is, is Aal anyone's I 2 MR. ROBINSON: There's an arrow Aal 2 responsibility to idaitify and tty to locate Aose 3 didnt reproduce. 3 inAviduals for a potoitial healA screening? 4 MR. FRANCIS: Oh, okay. All right I 4 MR ROBINSON: Well, at EPA, we're only 5 know Aaf s Ae Morgan Village area Okay. Ijust 5 responsible for Ae cleaning up of Ae soils, not for 6 wanted to be clear on Aal. 6 Ae prior studies. Al part of EPA's evaluation early 7 My comments are Aat I'm mtimately 7 on in Ae project Ae Agency for Toxic Substances 8 familiar wiA Ae General Gas Mantie Site because I 8 and Disease Registry or ATSDR in working WiA Ae New 9 was a letter carrier in 19-up until 1970 and I 9 Jersey Department of HealA and I guess now its Ae 10 delivered mail to Aat facility al Ae time Aal it 10 Department of HealA and Human Services. 11 was a sewing factOty. I dont know Ae name -1 11 MR PRINCE: Senior Savices. 12 cant recall Ae name of Ae - 12 MR ROBINSON: Senior Swvices. They 13 MR. ROBINSON: Ste-Lar Textiles. 13 did a heal A assessment of boA 'sup>erfiind sites — 14 MR. FRANCIS: Ste-Lar Textiles it was. 14 sorty. The assessment of Ae Welsbach Site— 15 Okay. It had several owners over Ae years, but 15 Welsbach factory area in Gloucester City and Ae 16 around 1970 when 1 concluded my service in Ae area, 16 General Gas Mantle in Camden, as part of Ae Welsbach 17 Aere were dozens of women — primarily women who 17 Site, and Aey found Aat there was an increase risk 18 worked m Aat buildmg and, of course, Arlington 18 ofcancer in Ae areas, but it was mainly relatedt o 19 Sfreet adjacent to it was row homes on boA sides of 19 smoking, but Aey didnt go back looking at Ae 20 Ae sfreet Aere were wall to wall row homes which I 20 historic. 21 delivered mail to up until 1970 and across Ae sfreet 21 So Ae answer to your question, EPA does 22 Aere was Ae old Howland Croft Mill (phonetic) which 22 not have Ae — ifs not our mission to go and do 23 had several sewing factories also, Aere was Sterlmg 23 Aose lands of investigations. It would be through 24 Levitt (phonetic), (Toleman Wraps (phonetic), Tmy 24 Ae State Department of HealA and Senior Savices if 25 Women, Aey manufactured garments for females and 25 Aat were to take place. Page 123 Page 125 1 Aere were dozens — maybe hunAeds of women, 1 MR FRANCIS: And HealA and Senior 2 primarily women who worked in Aose factories as 2 Services. Okay. Also, incidentally, I'm also a 3 seamstresses 3 member of Ae Department of Environmental Protection, 4 So my concem is is has Aere ever been 4 Ae Environmental Justice Advisoty Council here m 5 any attempt to locate or identify many of Ae workers 5 Ae State of New Jersey. Okay. Thank you very much. 6 who worked in Aose bmldings and Ae residents who 6 MR MONTAGUE: My name is Peter 7 lived in Aose homes because we're talking — I dont 7 Montague, M-o-n-t-a-g-u-e, I'm from New Brunswick, 8 know how much longer Ae facility operated after 1970 8 New Jersey. The reason I'm concerned about this 9 because Aafs when I left Ae area as a letter 9 site — well, I'm wiA Ae New Jersey Environmental 10 carrier. 10 Justice Alliance, I'm not representing Aem here 11 But is Aal anyone's responsibility or is 11 tonight but I generally take an environmental 12 Aat EPA's responsibility to tty to locate or 12 justice perspective on Aese issues and so Aere are 13 identify Aose former residents and employees because 13 two reasons Aat I'm concerned about this site. 14 we're talking - m my experience, we're talking 14 One is Aat it is clearly an 15 35 years ago and a lot of Aose people are still 15 environmental injustice unfolding before our eyes in 16 alive today I'm sure, if Aey havent deceased from 16 Ais community wiA Ae cleanup of Ae Martin Aaron 17 Aose related illnesses, but some attempt I believe, 17 Superfund Site and I'm concerned because every time 18 should be made to fry to locate or identify Aose 18 you cap a site wiA a little asphalt and walk away 19 persons and maybe some kind ofa heal A screening or 19 from it leaving contamination in Ae ground, you 20 testing to see if Aere have been any detrimental 20 poison Ae future, you poison Ae Ature for 21 affects to Aeir heal A as a result of exposure to 21 everybody and Aaf s what's happening here today. 22 Ae radioactive - radioactivity in Aat area and 22 1 have specific requests and I'm going 23 also Ais is a combined residential and mdustriai 23 to run through Aese because ifs late. One, please 24 commercial area, Broadway mostly commercial, west of 24 put all Ae documents for Ais site on Ae worldwide I 25 Broadway was mostly industrial 25 web, simply tum Aem in to PDF documents, scan Aem, Pages 122 to 125 [email protected] Masfroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500136 July 26, 2005 Page 126 Page 128 1 tum Aem mto PDF and put Aem on Ae web so Aat 1 supposed to be reviewed evety five years, who's gomg 2 people m Oregon can look at what's happemng here 2 to do Aat. You're making huge assumptions about Ae 3 and compare it to Aeir site and see what kind of 3 socialcapacityofAe system to care about Aese 4 cleanup is bemg achieved here. 4 Aings m Ae fiiture. There's really only one way to 5 My guess is Aat if Ais site were m 5 protect Ae future population Aat will be affected 6 Princeton, New Jersey, we'd have a different cleanup 6 by this site and Aafs to clean it up Aoroughly 7 proposed. I dont know Aat for sure, but I'm 7 now. Any oAer remedy is a crjqj shoot You're 8 guessing. 8 pretending to know whaf s gomg to happen m Ae 9 And to be able to make Aose comparisons 9 fiiture and you cant know whaf s going to h^pen in 10 as to whaf s h^pemng m various kinds of 10 Ae flittire. 11 communities and wiA similar sites and what are Ae 11 Somecsie should explain al s(»ne pomt 12 remedies proposed is vety important for citizens to 12 what it means - what Ae comment means on Page 5 13 be able to learn whaf s Ae real basis on which 13 that Ae groundwater at this site is bemg influenced 14 cleanup decisions are made. 14 by Ae municipal wells. The groundwater at Ae site 15 ThirA key information is missing, take 15 is bemg influenced by municipal wells? They're, I 16 a look al Ae last sentence on Ae box on Page 7, it 16 presume, sucking water towardAem . That seems to be 17 just dribbles off mto noAing. You cant get a real 17 an mteresting - a littie tidbit thaf s not 18 understanding from Ae box on Page 7 as to what your 18 explained m your — m your handout. 19 risk assessment meAod is. Key mformation is 19 I would say, again, Aal this site needs 20 missing m preparation for a public hearing. 20 to be cleaned up Aoroughly and enq^hasize again that 21 Now, EPA has been conducting public 21 this site needs to be cleaned up Aoroughly. There 22 hearings since when, 1970, so we're 35 years into 22 is no substitute for cleaning it up. 23 knowing how to conduct public hearings and you have 23 Now, why would this community not get 24 arrows Aat dont reproduce, you have information 24 Ae best possible remedy. 1 dont really know, bm I 25 missing from some of Ae printed handouts, you have 25 do know fi-om your own documents that trouble was Page 127 Page 129 1 acronyms Aat are used but are not explained in Ae 1 identified on Ais site in nineteen eighty - at 2 box on Page 6, it starts off NCP says. 2 least as early as 1981 and nothing was done about it 3 Well, Fve asked several people in Ae 3 In 1987, Ae presence of hazardous 4 audience, what is NCP, nobody here has a clue. So 4 waste, drums, sludge was identified and yet 5 you've used an acronym Aat means someAmg to you, 5 accordmg to your documents, some of Aese drums 6 it means noAing to your audience and yet you're 6 werent even removed from Ae site until 2001, so 7 pretending to be holding a public information session 7 this site has been - has been known to be 8 where you're informing Ae public and hearing back 8 contaminated for at least 20 years and you've known 9 from Ae public. You really need to focus on doing a 9 Aat Aere were drums on Ae site for at least 10 good job of public participation and Ais is not 10 14 years and you've left it 11 evidence ofa good job of public participation. 11 It appears Aat Ais is not a high 12 Fencing Ae site, what you call an 12 priority for government It appears Aat somebody 13 engineering confrol, I believe, does not keep 13 doesnt really care about this site, so Aat, to me, 14 chil Aen out ofa site. It invites chil Aen to climb 14 is sort of a default position Aat Ais site is a 15 Ae fence and get in. We've known Ais for 25 years 15 place Aat you all dont really care about and if you 16 from superfimd sites. 16 really do care about it, Ae burden is on you to show 17 Page 11 says that Ae site would have to 17 Aat and giving it a second best cleanup will simply 18 be reviewed evety five years, but, you know, Aere 18 confirm Ae suspicion Aat this is a community Aafs 19 are people in Congress Aat dont want EPA to be - 19 been written off and Aat nobody cares about, but 20 even be around in five years, suppose Aose people 20 Aafs what you propose. 21 prevail. Who would have guessed ten years ago Aat 21 As Jane Nogaki said, you dont even have 22 Ae City of Camden really wouldnt have a municipal 22 in your documents an option of real cleanup. You 23 government anymore. The city is in arrears, ifs 23 obviously havent even considered or put a price tag 24 broke. 24 on a true cleanup of Ais site Aat would not end 25 If you walk away from Ais site and ifs 25 wiA some kind ofa cap or engineering confrols or Pages 126 to 129 [email protected] Masfroiaimi & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500137 July 26, 2005 Page 130 Page 132 1 some — pirttmg some kind ofa fence around it or a 1 risk assessment The firstadministrato r of EPA, 2 layer of concrete to supposedly protect ftiture 2 William Ruckleshouse said in 1984, we should remember 3 generations from Ae contaminants. 3 Aal risk assessment data can be like Ae captured 4 I suppose - now, I'm guessmg, but I 4 spy. If you torture it long oiough, it will tell you 5 suppose you didnt want to do Aal because if you 5 anything you want to know. 6 proposed a real cleanup and put a dollar value on it 6 Now, I dont want to accuse anybody of 7 and Aen came back and said, well, we really cant 7 torturing Ae data to reach a preordained conclusion, 8 afford Aat, you'd be really saying to Ais 8 but since you didnt even put out Ae best most 9 community, your healA really isnt worth Aat much 9 expensive option of total cleanup, we know Aat 10 money, we're just not gomg to spend Ae kind of 10 you're playing wiA Ae data to some extent you're 11 money Aat it would really take to clean this place 11 allowing money or something else to influence what 12 up and so you dont want to lay out Ae real option 12 you will tell Ais community is possible. 13 of cleaning it up and so all you've given people is a 13 So fm wondaing if somebody somewhere 14 bunch of crummy options and say, we're gomg to pick 14 hasnt allowed politics or money to ento- into Aeir 15 Ae second crummiest. 15 assessment of what should be done m this community. 16 Tell people Ae truA, lay it out for 16 Maybe Ais is a community Aat doesnt matter, maybe 17 Aem. Tell Aem what it would really cost to clean 17 this is a community Aal can be writtai ofii maybe if 18 Ais Amg up Ae way superfimd back when it called 18 we did Aese same risk assessments in Princeton or 19 for permeant remedies back in Ae old days, what 19 Upper Saddle River, we'd reach a different conclusion 20 would a permanent remedy at this site cost? A 20 about what needed to be done and what was possible 21 permanent remedy is not a layer of asphalt. 21 and how much money we should spend as a society to 22 Now, lef s talk about your general — 22 preserve Ae heal A and mtegrity of Aose 23 your general risk assessment technique. I know we've 23 communities. 24 got at least two risk assessors in Ae room. 24 The results of quantitative risk 25 Now, we know Aat from your documents 25 assessment are not reproducible from laboratory to Page 131 Page 133 1 Aat Ae site has antimony, arsenic, barium, cadmium, 1 laboratoty or from risk assessor to risk assessor. 2 chromium, leaA mercuty, selemum and Aallium in Ae 2 The National Academy of Sciences said in 1991, risk 3 metals department Aen you've got VC)Cs and Aere's 3 assessment techniques are highly speculative and 4 no great - there's no list of VCXTs, Aere's a vety 4 almost all rely on multiple assumptions of fact some 5 short list, Aen you've got semi volatiles, Aen 5 ofwhich are entirely untestable. 6 you've got PAHs, Aen you've got mention of 6 So risk assessment is really kind of 7 pesticides and PCBs. 7 bogus. It doesn't take mto consideration multiple 8 Now, your healA risk assessments dont 8 exposures, different people can reach different 9 take into consideration multiple sfressors occurring 9 conclusions, Aere's lots of judgment involved. Ifs 10 at Ae same time. The science cant support it 10 not really scientific, ifs an art it's a political 11 There arent even agreed upon protocols for assessing 11 art and yet you are presenting it to this community 12 Ae heal A consequences of exposure to nine or ten 12 as our risk assessment shows Aat Ais will be 13 metals plus an unknown number of pesticides plus 13 protective of public heal A. 14 PCBs, plus PAHs. 14 Well, pardon my french but Aafs 15 The timing of exposure in Ae 15 bullshit You dont know what's protective of public 16 development of an organism is critical, as we know, 16 health except to not expose people to toxic 17 for understanding Ae toxicity. If a person is 17 materials. Ifyou dont expose people to toxic 18 exposed in Ae womb through someAing Aat Aeir 18 materials, you can say Aat you will not be 19 mother does and Aat happens to be Ae week when 19 influencing Aeir heal A by exposure to toxic 20 Aeir eyes are developing, maybe Ae/ll be bom wiA 20 materials. 21 a cataract or maybe they'll be bom wiA some vision 21 I noticed m your presentation Aat you 22 problem and if you expose Aat mother and Aat fetus 22 used Ae word low levels. Well, when a person is 23 two weeks later, you might see a different affect or 23 exposed to TCE and Aallium and PCBs and mercuty and 24 no affect at all. 24 lead, you dont know whaf s a low level of TCE 25 Politics can enter into quantitative 25 because you dont know whaf s a biologically Pages 130 to 133 [email protected] Masfroiaimi & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500138 July 26,2005 Page 134 Page 136 1 effectivelevelofTCEand Aat would be low. 1 problems m Ae neighboAood, and Aat in Aose !• 2 If it werent biologically effective and 2 discussions we perioAcally ask for updates on whaf s 3 you knew Aat for sure, you could justify calling it 3 gomg on wiA Ae superfund sites and we get some 4 a low level, but you dont know whaf s a biologically 4 comments on where you are. 5 effective level for a fetus whose moAer is already 5 But I want to -1 want Ae record to be 6 under sfress because she's living next to a sewage 6 clear Aal our meetings have not been about Ae 7 freatment plant a garbage incmerator, oAer 7 Martin Aaron Superfimd Site anA Aerefore, please 8 superfimd sites, a cement plant 8 let Ae record be clear Aat you have not worked wiA 9 You dont know whaf s a low level, you 9 Ae Heart of Camden wiA regard to fiiture use of Ae 10 dont know what's a biologically meffective level 10 site or cleanup meAodology. 11 and yet you use Aat language as ifyou did know and 11 Government entities have twisted our 12 Aafs misleadmg. You should just say we dont know 12 Ascussions in Ae past. We eiicourage and would host 13 wAal — we dont know. You should be honest. 13 more community dialogue on this specific topic and, 14 There's a lot of talk about cancer here 14 of course, support Ae communitys request for an 15 and Aen Aere's a lot of talk about non-cancer 15 extension of Ae comment period. Thank you. 16 affects, but you dont know vety much about 16 MR. CARRINGTON: Theodore Carrington, 17 non-cancer affects. You dont even have - m most 17 C-a-r-r-i-n-g-t-o-n, I guess -1 havent been 18 cases, you dont even have protocols for deteimining 18 appointed, but I'm here as part of Ae (Central Jersey 19 what will cause a non-cancer affect. 19 Environmental Justice Alliance and I want to just 20 For example, reproductive affects, 20 echo a little bit what was said by Mr. Lyons and 21 affects on a person's metabolism, affects on a 21 Mr. Jones about Ae heal A of Ae citizens Aat 22 person's immune system, affects on a person's nervous 22 are — Aat live adjacent to this site and alAough 23 system, affects on a person's hormone system or 23 you said EPA does not really talk abom domg healA 24 endocrine system, affects on growA and development 24 screenings, but ifs certainly within your purview to 25 and affects on a person's behavior. 25 recommend and I certainly would like for EPA to go cm Page 135 Page 137 1 You dont even have protocols for 1 record to recommend Aat Aose people who live in 2 determinmg toxic affects Aat lead to behavioral 2 Ais area who have been surrounded by all Ae sites 3 changes, so you've left Aem out of Ae risk 3 Aal Mr. Montague mentioned and countiess oAers here 4 assessment Aey're not m Aere, but we know Aat 4 today have mentioned Aal - Aat Aeir healA has 5 lead by itself causes behavioral changes, it causes 5 certainly been affected and - or lef s find out if 6 people to become aggressive and nasty and maybe even 6 it has been affected by all of Aese sites. 7 violent Is Aere any aggressive, nasty, violent 7 1 mean some of Aese toxics Aat have 8 behavior m Camden? I wonder if lead from Ais site 8 been in Ae grounA airbome, dust down m Ae water 9 might induce more of it 9 levels, so, you know, Ae citizens of Ae SouA 10 So you really have an obligation to 10 Camden should be - have Aeir heal A checked and 11 clean up Ais site, Aere's no reason not to unless 11 find out Ae amount of contamination within Aeir 12 Ais community isnt worA it And if Ais community 12 systems and I certainly, again, would like to see 13 isnt worA it, just say so. Just tell Ae community 13 this Regional 2 group make that as a strong 14 what Ae deal is, Aey can take it Aey understand. 14 recommendation and Aere's no way to determine what 15 Thank you vety much. 15 Ae heal A affects are unless Aere's a real 16 MR. PRINCE: Thank you, Mr. Montague. 16 comprehensive heal A screening of all Ae citizens 17 Would you like me to respond to some of Aal? 17 Aat live m this area and even as Mr. Kelly sai A 18 MR. MONTAGUE: You could respond m 18 for Aose people who are formally in this area 19 writing. The community would love to hear it 19 because Ae healA affects are probably fremendous. 20 MR. PRINCE: We will. Thank you. 20 And also I'd like to go on record also 21 MS.PIERSON: Helene Pierson, 21 to say Aat because this is Ae summertime and if s 22 P-i-e-r-s-o-n, Heart of Camden. Ijust wanted to say 22 hard to get people togeAer to extend Ae public 23 for Ae record Aat we appreciate Aat Ae EPA at Ae 23 comment period. Thank you. 24 Heart of (Camden's request has Aus far participated 24 MR. PRINCE: Thank you. I Aink we may 25 m really, our focus, on air quality, Aere's lots of 25 havereachedAe end of our meeting, fll stay a , Pages 134 to 137 [email protected] Masfroianni & Formaroli, Inc. 856-546-1100 Professionals Servmg Professionals 500139 July 26,2005 Page 138 1 couple of exfra minutes. The comment jjeriod I 2 information on Ae extension will be forAcoming and 3 we really appreciate you all taking some time this 4 evening. 5 This is —this is a lot of vety 6 difBcuIt information, ifs hard work for us to tty 7 and present it ifs hard to absorb and appreciate 8 Aat you've all stayed for Ae whole time to fry ~ 9 to tty and understand Aese two sites. Goodnight 10 (Meeting concluded at 10:26 p.m.) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I Page 139 1 . CERTIFICATE. 2 3 4 I, Stacy A. Shuchman, a Notaty Public and 5 Certified ShorAand Reporter of Ae State of New 6 Jersey, and Commissioner of Deeds for Ae 7 Commonweal A of Pennsylvania, do hereby certify Aal 8 Ae foregomg is a true and accurate transcript of 9 Ae testimony as taken stenographically by and before 10 me at Ae time, place and on Ae date hereinbefore 11 set forA. 12 I do fiuther certify Aat I am neiAer a 13 relative nor employee nor attomey nor counsel of any 14 of Ae parties to Ais action, and Aat I am neiAer 15 a relative nor enployee of such attomey or counsel 16 and Aat 1 am not financially mterested m Ais 17 action. 18 19 • 20 Stacy A. Shuchman, C.S.R. 21 Notaty Public, State of New Jersey My Commission Expires September 5,2006 22 Certificate No. XI 02034 23 24 25 Pages 138 to 139 [email protected] Masfroianni & Formaroli, Inc. 856-546-1100 Professionals Serving Professionals 500140 1 CERTIFICATE 2 3 4 I, Stacy A. Shuchman, a Notary Public and 5 Certified Shorthand Reporter of the State of New 6 Jersey, and Commissioner of Deeds for the 7 Commonwealth of Pennsylvania, do hereby certify that 8 that the foregoing is a true and accurate transcript 9 of the testimony as taken stenographically by and 10 before me at the time, place and on the date 11 hereinbefore set 'forth. 12 I do further certify that I am neither a 13 relative nor employee nor attorney nor counsel of any 14 of the parties to this action, and that. I am neither 15 a relative nor employee of such attorney or counsel 16 and that I am not financially interested in this 17 action. 18 19 20 Stac:tacyy A>S ShShudhmanu , C.S.R. 21 Notary Public^ State of New Jersey My Commission Expires September 5, 2006 22 Certificate No. XI 02034 23 24 25 500141 ATTACHMENT D 500142 "Oneill, Owen" To Rick Robinson/R2/USEPA/US@EPA Dear Mr. Robinson, I read the EPA bulletin (#05064) released May 26, 2005 regarding the cleanup of the above site. We live in Haddon Township, Camden County NJ, which is within 10 miles of the cleanup site in Gloucester and Camden. Over the past several years we have noticed a number of crippled, disfigured and otherwise handicapped Mallard ducks in our area which we did not see previously. We know that ducks in our area transit to and from the Delaware River in that area, because this past winter we saw 5 or 6 of them in our lake and creek that came in contact with the oil spill that occurred in the river. One was captured and taken to Tri State Bird Rescue and Research in Newark, Delaware where he was treated and then we released him back in our area. My question is whether the study that was performed to determine the level, extent and impact of the contamination included study of affects on wildlife, and whether or not the abnormalities seen in the Mallards are in any way linked to the contamination. Thanks for considering our question and concem. Joan and Owen O'Neill 503 Estaugh Avenue Westmont, NJ 08108 856-858-1589 500143 Bill Whitlow To Rick Robinson/R2/USEPA/US@EPA, Natalie Dear Rick, Natalie and Marian, Thanks for the information about the Welsbach site. You all did an excellent job of presenting information and of listening to the community. I hope you get credit within your agency for that; in my experience, it is a very unusual to find at EPA someone who actually listens. From the perspective of public communication, I do think it would be extremely helpful for the agency to do a follow-up assessment of contamination levels, so you could show, in a simple and direct fashion, what the contamination level was that put Welsbach/General Gas Mantle on the NPL, and what it is now, after your remediation efforts (as well as what your target level was). It should show that you've done what you are supposed to do. Frankly, I find all the discussion about the technical details of one remediation effort or another is the sort of information that makes my eyes glaze over, without giving me a satisfactory answer to the question of whether the threat has been abated. Thanks again, Bill Whitlow J.W. (Bill) Whitlow, Jr. Professor of Psychology Rutgers University-Camden 311 N. Fifth Street Camden, NJ 08102-1405 phone: (856) 225-6334 or (856) 225-6494 fax: (856) 225-6602 email: [email protected] Web: http://www.camden.rutgers.edu/~bwhitlow 500144 EWA September 15,2005 Mr. Rick Robinson Project Manager U.S. EPA 290 Broadway New York, NY 10007-1866 Re: Comments for Welsbach/General Gas Mantle Contamination Site Proposed Cleanup Plan for 0U3 Dear Mr. Robinson: Attached, please find comments prepared by Chapin Engineering on behalf of Edison Wetlands Association regarding the proposed cleanup plan for Welsbach/General Gas Mantle Contamination Site. As a non-profit organization advocating for enviroiunental justice and proper cleanup of contaminated sites throughout New Jersey, we are concerned by EPA's No Action proposal for OU3 and recommend that you reconsider the decision based on the comments provided by Chapin Engineering. Sincerely, Robert Spiegel Executive Director Via: Email ([email protected]) Edison Wetlands Association, Inc. • 2003 State Hwy. 27 • Edison, New Jersey 08817 Telephone 732-287-5111 • Fax 732-287-5129 • >vww.edisonwetlands.ore 500145 A PROFESSIONAL CORPORATION "EXCELLENCE IN ENVIRONMENTAL ENGINEERING'' R.W, Chapin, P.E. President MEMO TO: Bob Spiegel, Edison Wetlands Association FROM: R.W. Chapin, P.E. DATE: 09/14/05 RE: Welsbach/General Gas Mantle Superfimd Site, Camden, NJ Review of Proposed Remedial Action, OUS, dated May 2005 According to the USEPA's Proposed Plan, the Welsbach Site consists of two former gas mantle manufacturing sites (Welsbach and General Gas Mantle) and "ntunerous" other properties in Camden and Gloucester City, NJ proximate to these former manufactiuing locations. The companies used radioactive Thorium to manufacture gas mantels that would glow brightly. The tailings fi-om the processing of Thorivmi ores and other radioactive wastes are the contaminants of concem for the Welsbach site.' Welsbach operated from 1895 until 1940, while General Gas Mantle operated from 1912 to 1941. The USEPA issued its summary of its proposed remedial action for Operable Unit 3 (the "EPA Stmimary") in May 2005. The EPA Summary presents of the preferred altemative for addressing contaiiiination of surface water, sediment and wetlands areas at the Welsbach site, including a rationale for its sielections. The selected remedy is No Action. This selected remedy was presented and discussed at the July 26, 2005 pubhc meeting in Camden. This memo provides comments on the EPA Summary, which is 11 pages in length and includes one figure, as well as comments based on information provided at that meeting. . The proposed remedial action for the Martin Aaron Superfimd Site was also presented and discussed at the July meeting. The selected altemative is No Action. This is based on the EPA finding that radionuclide concentrations in the sediment samples were essentially no different than "background"; consequently, neither the hvmian health nor ecological risk assessment foimd vmacceptable risks. The EPA investigations of Operable Unit 3 (0U3) included analysis of samples for "Chemical contaminants", although the list of specific chemicals is not stated. The EPA found that PCBs are the "main chemical contaminant" in the sediments that exceed EPA's "level of concem" for human health risk. No other chemical is discussed, and EPA stated that PCBs are not associated with the Welsbach site, hi general, the EPA states that no chemical contaminant found by their investigation is associated with the Welsbach site, and does not address any chemical contamination in their proposed remedy. This is also the case for the ecological risk assessment, although "a number of chemical contaminants" exceeded ecological impact guidelines. Conmients on the Welsbach proposed plan follow. 27 QUINCYROAD BASKING RIDGE. NJ 07920 908 647 8407 (fax) 908 647 6959 (email) [email protected] 500146 A PROFESSIONAL CORPORATION "EXCELLENCE LNENVIRONMENTAL ENGINEERING" MEMO TO: Bob Spiegel, Edison Wetlands Association FROM: R.W. Chapin, P.E. DATE: 09/14/05 RE: Welsbach/General Gas Mantle Superfimd Site, Camden, NJ Review of Proposed Remedial Action, 0U3, dated May 2005 • During the pubhc meeting it was revealed that radioactivity had been discovered at the Martin Aaron site, which is roughly Vi mile north of the General Gas Mantle site, and within Study Area 1 of the Welsbach Superfimd site. No acknowledgement of this fact was provided in the pubhc handouts for either site. A complete set of the radiological data for the Martin Aaron site should be included in the Martin Aaron RA Selection report. Additionally, the impact of this radioactive inaterial on the proposed disposal of martin Aaron soils mtist be evaluated. The likely origin of the radioactivity at the General Gas Mantle site indicates this assessment should be part of the Welsbach site activities. • The EPA expended fimds collecting and analyzing sediment and surface water samples for chemical contaminants then expended fimds to conduct himian health and ecological risk assessments for those chemicals. Why these fimds were expended when there was no intent to use the data should be explained. In addition, this data must be fransmitted to the NJDEP. • EPA states that the chemicals foimd in their samples were not in use when Welsbach and General Gas Mantle operated, apparently as its justification for not considering their chemical data when evaluating cleanup options. Both of these facilities had to have used coal and would, therefore, have produced PAH compoimds in their coal ash. PCBs, according to the USEPA web site, were manufactured from 1929 to 1977, and their presence/use at these sites cannot be excluded. Widespread use of DDT as a pesticide commenced in 1939 (although the compoimd was created circa 1874). The blanket exclusion of Welsbach as a potential source of chemical contaminants is not justified. The potential contribution of the Welsbach site to the contaminated sediments requires an evaluation. 27 QUINCY ROAD BASKING RIDGE, NJ 07920 908 647 8407 (fax) 908 647 6959 (email) [email protected] 500147 APPENDIX V 500148 RPR-S7-S002 J.7:i r l-KUn:KtntUiHi XUIN I-IUI & rrc oiar noM oj±n ' ^X^XL.(-i—• I iw-'—' Richard J.CixJcy Department of Environmental Protection Brailley M. Campbell CommissioQcr >*rrinj,' Oitvrrnor SEP 2 9 Honorable Alan J. Steinberg, Regional Administrator United States Environmental Protection Agency Region II 290 Broadway New York, NY 10007-1866 Re: Record of Decision (ROD) for Operable Unit #3 Wel.sbach/General Gas Mantle Contamination Superfund Site Gloucester City & Camden, Camdoi County Dear Mr. Steinberg: The New Jersey Department of Environmental Protection (Department) has completed review of the July 2005 Draft Record of Decision (ROD) for Operable Unit #3 (0U3), the surface water, sediment and wetland areas. We are pleased to concur with the chosen remedial alternative. The chosen remedial alternative for 0U3 is the no action remedy described in the ROD document and applies to the third of four planned operable units for the Welsbach site. As stated in the ROD, the U.S. Environmental Protection Agency (EPA) has determined that no site-related contaminants ofaoncem are present at elevated levels in the surface vvaler, .sediment, and wetland areas adjacent to the Welsbach Site. Therefore, no remedial action is warranted, because there is no radiological conumination in tlie surface water, sediment, and wetland areas adjacent to the Welsbach Site that pose an unacceptable risk to human health or environment. We appreciate the opportunity lo participate in the remedial decision making process and ihc efforts of USEPA lo address this contaminated site. Ifyou have any questions, please do not hesitate to call me at (609) 292-1250. h J. Sccbode, Assistant Commissioner emediation and Waste Management Program Ntnv Jenty it an E(jual Opporlunlry Employer 500149 Recycled faper RPR-27-200S 17: IT PKOPI: REMEDIRTION MST & RE 609 984 6514 T0:91£1E6374393 P:Ea0 cc: Rick Robinson, USEPA Yan Ling Juang, NJDEP OWR Nancy Stanley. NJDEP BER Ann Charles, NIDEP BEERA Karen Kloo, NJDEP BCR 500150