RECORD OF DECISION Welsbach/General Gas Mantle Contamination Superfund Site Operable Unit 2: Armstrong Building Gloucester City and Camden, Camden County, New Jersey Site ID: NJD986620995 September 2011 United States Environmental Protection Agency Region 2 New York, New York 500001 DECLARATION STATEMENT SITE NAME AND LOCATION Welsbach/General Gas Mantle Contamination Superfund Site Gloucester City and Camden, Camden County, New Jersey National Superfund Database Identification Number: NJD986620995 Operable Unit 2 (OU2): Armstrong Building STATEMENT OF BASIS AND PURPOSE This Decision Document presents the Selected Remedy for Operable Unit 2 (OU2), the Armstrong Building, at the Welsbach/General Gas Mantle Contamination Superfund site (Welsbach Site), Gloucester City and Camden, Camden County, New Jersey. The Selected Remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act, as amended (CERCLA), and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300 (NCP). This decision is based on the Administrative Record file for the Welsbach Site; the index for the Administrative Record is contained in Appendix IV. The New Jersey Department of Environmental Protection concurs with the Selected Remedy. ASSESSMENT OF THE SITE The response action selected in this Record of Decision (ROD) is necessary to protect the public health, welfare, and the environment from actual or threatened releases of hazardous substances into the environment. DESCRIPTION OF THE SELECTED REMEDY The response action described in this ROD addresses radiologically contaminated building surfaces in the Armstrong Building at the Welsbach Site. It represents the second of four planned remedial phases, or operable units, for the Welsbach Site. EPA issued a ROD for the first Operable Unit on July 23, 1999 to address soil contamination. On September 25, 2005, EPA signed a ROD for the third Operable Unit that indicated that no remedial action was necessary for the surface water, sediments and wetlands at the Welsbach Site. A fourth Operable Unit is planned to address potential groundwater contamination. The major components of the Selected Remedy are: • Decontamination (physical and/or chemical) of radiologically contaminated building surfaces in the Armstrong Building. • Transportation of radiologically contaminated wastes generated during the remedial action to an approved off-site facility. 2 500002 DECLARATION OF STATUTORY DETERMINATIONS Part 1: Statutory Requirements The Selected Remedy is protective of human health and the environment, complies with federal and State requirements that are applicable or relevant and appropriate to the remedial action to the extent practicable, and is cost-effective. EPA has determined that the Selected Remedy represents the maximum extent to which permanent solutions and treatment technologies can be utilized in a practicable manner at the Welsbach Site. Part 2: Statutory Preference for Treatment There are some treatment technologies that may reduce mobility of radionuclides in soil (e.g., stabilization), and reduce the volume of contaminated soil (e.g., soil separation); however, these technologies are not implementable for building materials associated with the Armstrong Building. Therefore, the statutory preference for treatment as a principle element cannot be met. Although the Selected Remedy will not reduce the mobility or volume or radionuclides through treatment, it will reduce the mobility of radioactive contaminants by removal, off-site disposal, and management of the contaminated material at an approved landfill permitted to accept radioactive waste. Part 3: Five-Year Review Requirements Five-Year Reviews will not be necessary since all radiologically contaminated building surfaces above the Remediation Goal for the Armstrong Building will be removed through the implementation of the Selected Remedy. By meeting the Remediation Goal, the Armstrong Building will be released to the property owner for unlimited use and unrestricted exposure. 3 500003 ROD DATA CERTIFICATION CHECKLIST The following information is included in the Decision Summary section of this ROD. Additional information can be found in the Administrative Record file for the Welsbach Site. • Radionuclides of concem and their respective concentrations are found in the "Summary of Site Characteristics" section. • A discussion of the baseline risk represented by the radionuclides of concem may be found in the "Summary of Site Risks" section. This discussion is based on the Baseline Risk Assessment in the 2011 Supplementary Remedial Investigation Report. • Cleanup levels for the radionuclides of concem and the basis for these levels can be found in the "Remedial Action Objectives" section. • A discussion of principal threats may be found in the "Principal Threat Waste" section. • Current and reasonably anticipated future use assumptions for the Armstrong Building used in the baseline human health risk assessment and ROD can be found in the "Current and Potential Site Uses" section. Potential land and groundwater use changes are not dealt with in this ROD because the remedy involves the decontamination of a building. • Estimated costs for each alternative can be found in the "Description of Altematives" section. • Key factors used in selecting the remedy (e.g., how the Selected Remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision) can be found in the "Statutory Determinations" section. Sy/^. 27^ 2^^^ Walter E. Mugdan, Director Date Emergency and Remedial Response Division EPA, Region 2 500004 RECORD OF DECISION DECISION SUMMARY Welsbach/General Gas Mantle Contamination Superfund Site Operable Unit 2: Armstrong Building Gloucester City and Camden, Camden County, New Jersey Site ID: NJD986620995 September 2011 United States Environmental Protection Agency Region 2 New York, New York 500005 TABLE OF CONTENTS SITE NAME, LOCATION, AND DESCRIPTION .................................................................................... 1 SITE HISTORY AND ENFORCEMENT ACTIVITIES ........................................................................... 1 HIGHLIGHTS OF COMMUNITY PARTICIPATION ............................................................................. 2 SCOPE AND ROLE OF OPERABLE UNIT ............................................................................................. 3 SUMMARY OF SITE CHARACTERISTICS ........................................................................................... 3 CHARACTERISTICS OF THE RADIONUCLIDES OF CONCERN ...................................................... 7 CURRENT AND POTENTIAL FUTURE SITE USES ............................................................................. 7 SUMMARY OF SITE RISKS .................................................................................................................... 8 REMEDIAL ACTION OBJECTIVES ...................................................................................................... 12 DESCRIPTION OF ALTERNATIVES .................................................................................................... 13 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ................................................ 15 PRINCIPAL THREAT WASTES ............................................................................................................. 19 SELECTED REMEDY ............................................................................................................................. 19 STATUTORY DETERMINATIONS ....................................................................................................... 20 DOCUMENTATION OF SIGNIFICANT CHANGES ............................................................................ 22 List of Appendices Appendix I: Tables Appendix II: Figures Appendix III: Responsiveness Summary Appendix IV: Administrative Record Index Appendix V: State Letter of Concurrence ii 500006 ACRONYMS AND ABBREVIATIONS ACM Asbestos-Containing Materials AOC Administrative Order on Consent ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act cy Cubic Yards dpm/100cm2 Disintegration per Minutes per 100 Square Centimeters EPA Environmental Protection Agency FS Feasibility Study FSS Final Status Survey GGM General Gas Mantle Holt Holt Hauling & Warehousing, Inc. HVAC Heating, Ventilation and Air Conditioning IEM Integrated Environmental Management, Inc. LLC Limited Liability Company MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NCP National Oil and Hazardous Substances Contingency Plan NJDEP New Jersey Department of Environmental Protection NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PRG Preliminary Remediation Goal Ra-226 Radium-226 RAGS Risk Assessment Guidance for Superfund RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RG Remediation Goal RI Remedial Investigation ROD Record of Decision SARA Superfund Amendments and Reauthorization Act Th-232 Thorium-232 UQSM Unimportant Quantities of Source Material Welsbach Welsbach Company Welsbach Site Welsbach/General Gas Mantle Contamination Superfund Site iii 500007 SITE NAME, LOCATION, AND DESCRIPTION The Welsbach/General Gas Mantle Contamination Superfund Site (Welsbach Site) (Identification Number: NJD986620995) is a multi-property