APPENDIX A REMEDIAL INVESTIGATION REPORT FOR THE ARMSTRONG BUILDING (IEM, 1998) 302316 Remedial Investigation Report for the Armstrong Building Submitted to: Holt Hauling and Warehousing System, Inc. Post Office Box 8268 Philadelphia, Pennsylvania 19101-8268 (609) 742-3153 by: Integrated Environmental Management, Inc. 1680 East Gude Drive, Suite 305 Rockville, Maryland 20850 (301) 762-0502 Report No. 97013/G-6166 July 14, 1998 302317 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page i TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS IV ACKNOWLEDGMENTS VI EXECUTIVE SUMMARY vii FaCIIty '1' H' Istory Vll.. Remedial Investigation Scope vii Findings viii 1.0 INTRODUCTION 1 1.1 Purpose 1 1.2 Regulatory History and Rationale for the RI/FS 2 2.0 SITE INFORMATION 3 2.1 Location and Building Description 3 2.2 Historical Operations 3 2.3 Prior Investigations 3 2.4 Contaminants of Concern 5 3.0 RI APPROACH AND EMPHASIS 6 3.1 Project Goals and Scope 6 3.2 Release Criteria 6 3.3 Radiation Safety Procedures 8 3.4 Quality Assurance 8 3.5 Health and Safety 9 4.0 FIELD INVESTIGATION 10 4.1 Survey Measurement Objectives and Protocol 10 4.1.1 Area Classification for Measurements 11 4.1.2 Survey Units 12 4.1.3 Reference Grid System for Survey Measurements 12 4.1.4 Measurement Locations 13 4.1.5 Deviations from the Work Plan for Measurements 14 4.2 Sampling Objectives 14 4.2.1 Sampling Locations/Areas 15 4.2.2 Sample Collection Frequency 15 4.2.3 Deviations from the Work Plan for Sampling 15 4.3 Laboratory Analyses 15 DRAFT 302318 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page ii 5.0 FINDINGS , 16 5.1 Background Determination, 16 5.2 Affected/Unaffected Areas 16 5.3 Source Nature, Extent and Volume 17 5.3.1 Ambient and Contact Gamma Dose Rates 17 5.3.2 Removable Contamination 17 5.3.3 Total Contamination 18 5.3.4 Sampling Results 18 5.3.5 Analytical Results 19 5.4 Statistical Evaluation of Data 19 5.4.1 Wilcoxon Rank Sum (WRS) Test 20 5.4.2 Quantile Test 21 6.0 QUALITY ASSURANCE/QUALITY CONTROL 23 6.1 Project Personnel Organization and Qualifications 23 6.2 Contractor Surveillance Activities 23 6.3 Sample Collection and Handling 23 6.4 Sample Custody 23 6.5 Laboratory Operations 24 6.6 Data Reduction, Validation and Reporting 24 7.0 ASSESSMENT OF CONTAMINATION LEVELS 25 7.1 Confirmation of Release Criteria 25 7.2 Comparison of Survey Results to Release Criteria 25 7.3 Comparison of Analytical Results to Release Criteria 25 8.0 SUMMARY AND CONCLUSIONS 27 9.0 REFERENCES 29 10.0 TABLES 31 10.1 - Release Criteria 32 10.2 - Summary of Data Quality Objectives 33 10.3 - Sample Containers and Preservatives 34 10.4 - Sample Preparation and Analysis Methods 35 10.5 - Quality Control Measures and Frequency 36 10.6 - Minimum QA Sample Requirements 37 10.7 - Results of Removable Contamination Surveys 38 10.8 - Wilcoxon Rank Sum Test for Second Floor 42 10.9 - Wilcoxon Rank Sum Test for Third Floor 43 10.10 - Quantile Test Results 44 11.0 FIGURES 46 DRAFT 302319 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page iii 11. 1 - Location of Armstrong Building 48 11.2 - Second Floor Layout 49 11.3 - Third Floor Layout 50 11.4 - Project Organization 51 12.0 APPENDICES 52 12.1 - Analytical Results 53 12.2 - RESRAD-BUILD Summary Reports 54 12.3 - Field Instrumentation 57 12.4 - Technical Basis for Beta Measurement Protocol 59 12.5 - Survey Maps and Results 60 12.6 - Sample Locations 61 12.7 - QA/QC Evaluation Results 62 12.8 - Data Comparison Methodology 66 12.9 - Wilcoxon Rank Sum Test Results 68 12.10 - Quantile Test Results 69 12.11 - Personnel Qualifications 73 DRAFT 302320 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page iv ACRONYMS AND ABBREVIA TIONS ALARA As Low As is Reasonably Achievable ANSI American National Standards Institute CDM Camp Dresser & McKee, Inc. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COC Chain of Custody CPM Counts Per Minute DCGL Derived Concentration Guideline Level DPM Disintegration Per Minute DQO Data Quality Objective FADL Field Activity Daily Log FOP Field Operations Plan FS Feasibility Study HEAST Health Effects Assessment Summary Tables HHRA Human Health Risk Assessment Holt Holt Hauling and Warehousing System, Inc HSP Health and Safety Plan IEM Integrated Environmental Management, Inc. LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration MDL Method Detection Limit ILrem/hr microrem per hour mrem millirem MS Matrix Spike MSD Matrix Spike Duplicate NJDEP New Jersey Department of Environmental Protection NPL National Priorities List pCi/g picocurie per gram pCi/1 picocurie per liter QAPjP Quality Assurance Program Project Plan QA/QC Quality Assurance/Quality Control RA Remedial Action RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study RPD Relative Percent Difference RSP Radiation Safety Procedure SOP Standard Operating Procedure SOW Statement of Work TEDE Total Effective Dose Equivalent USDOT United States Department of Transportation DRAFT 302321 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page v USEPA United States Environmental Protection Agency USNRC United States Nuclear Regulatory Commission Welsbach Welsbach/General Gas Mantle Contamination Site WL Working Level WP Work Plan WRS Wilcoxon Rank Sum DRAFT 302322 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page vi ACKNOWLEDGMENTS This Remedial Investigation (RI) report was prepared by Integrated Environmental Management, Inc. (IEM) on behalf of Holt Hauling and Warehousing System, Inc. (Holt), a subsidiary of Holt Oversight and Logistical Technologies. As the lead regulatory agency, the United States Environmental Protection Agency (USEPA), Region II Office, provided technical review and oversight for the project. Comments on all documentation were also solicited from Malcolm• Pirnie, the USEPA contractor providing on-site surveillance of RI activities, and from the New Jersey Department of Environmental Protection (NJDEP). The IEM authors of this report were Alex J. Boerner, C.H.P.; Brian A. Kelly, C.H.P., P.E.; R. Alan Duff, R.R.P.T., and Carol D. Berger, C.H.P. Overall management of this project was provided by Ms. Berger (program manager) with assistance from Mr. Kelly (peer reviewer and RI/FS specialist). Management of field operations was provided by Mr. Duff (Field Manager). Management of laboratory operations was provided by Mr. Ronald Eidson, Outreach Laboratory (Outreach), in Broken Arrow, Oklahoma. Oversight of field quality assurance/quality control (QA/Qc) aspects was provided by Mr. Boerner (IEM) and Mr. Nidal Azzam (Malcolm Pirnie). Laboratory QA/QC oversight was provided internally by Mr. Eidson and Mr. Brian Duzan (Outreach) and externally by Mr. Boerner. DRAFT 302323 HOLT HAULING AND WAREHOUSING SYSTEM, INC. "Remedial Investigation Report for the Armstrong Building" July 14, 1998 Page vii EXECUTIVE SUMMARY On behalf of Holt Hauling and Warehousing System, Inc. (Holt), Integrated Environmental Management, Inc. (IEM) conducted a remedial investigation (RI) in the Armstrong Building at the former Welsbach/General Gas Mantle Contamination Site (Welsbach) in Gloucester City, New Jersey. The site is now owned by Holt. The onsite work associated with the RI was performed between March 23 and April 10, 1998. The RI and its associated Feasibility Study (FS) are being conducted in conformance with a consent order issued by the United States Environmental Protection Agency (USEPA) for the Armstrong Building under Docket No. 97-0104 [USEPA, 1997a]. The USEPA, Region II Office, is the lead regulatory agency for this project, with other USEPA offices and the New Jersey Department of Environmental Protection (NJDEP) providing supporting roles. The Armstrong Building is located at 701 North Broadway, Gloucester City, New Jersey. It is one of three buildings located in the northwest porti on of Holt's property, on a 65-acre tract that extends west from King Street to the Delaware River, and south from the Walt Whitman Bridge to Monmouth Street. The building itself consists of a basement and three (3) stories, constructed of reinforced concrete and masonry. The building contains an estimated 200,000 square feet (ft2) of floor space. The closest residence is located approximately 300 feet to the east of the building. Facility History Welsbach operated its facility from about 1895 until 1940, manufacturing incandescent lantern gas mantles containing natural thorium, a radioactive element. Gas mantle production entailed the processing of monazite ores to extract Thorium-232 e32Th)and Radium-228 e28Ra). 228Rais one of thorium's radioactive progeny. The 232Thwas used in the manufacture of gas mantles, while the 228Rawas used to make luminescent paint. After Welsbach vacated the property, it was later discovered that residual contamination remained inside the Armstrong Building and in certain outside locations. The magnitude of this contamination was subsequently evaluated by the NJDEP and later by a USEP A contractor. The extent of contamination was considered sufficient to place the property on the National Priorities List (NPL) for clean-up under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Remedial Investigation Scope Limited investigations of the Armstrong Building were conducted previously by the USEPA, NJDEP, a USEPA contractor, and IEM. The collection of additional data was necessary, however, to provide sufficient information for verifying previous results, filling data gaps, and completing this RI report and the subsequent FS.