DRAFT FINAL FEASIBILITY STUDY
FOR THE
MONTCLAIR/WEST ORANGE
AND
GLEN RIDGE, NEW JERSEY
RADIUM SITES
Volume I
For Reference
Do Not Take
From the Library
September 13, 1985
PERFORMANCE OF REMEDIAL RESPONSE
ACTIVITIES AT UNCONTROLLED
HAZARDOUS WASTE SITES
US. EPA CONTRACT NO. 68-01-6939
EP 902/9-85-50
1 v.l
<
CAMP DRESSER & McKEE INC.
ROY F. WESTON, INC.
WOODWARD-CLYDE CONSULTANTS
CLEMENT ASSOCIATES, INC.
ICF INCORPORATED
C. C. JOHNSON & ASSOCIATES, INC.
-------
902985501A
o,c. <-. C ,
DRAFT FINAL FEASIBILITY STUDY
FOR THE
MONTCLAIR/WEST ORANGE
AND
GLEN RIDGE, NEW JERSEY
RADIUM SITES
Volume I
September 13, 1985
Prepared for :
U.S. Environmental Protection Agency
26 Federal Plaza
New York, N.Y. 10278
Prepared by :
Camp Dresser & McKee Inc.
Roy F. Weston, Inc.
Clement Associates, Inc.
ICF, Inc.
EPA Contract No : 68-01-6939
Work Assignment Nos : 37-2LB1.0 and 38-2LA9.0
Document Nos : 135-FS1-RT-BFEQ-3
136-FS1-RT-BFER-3
(RW9/23)
-------
EXECUTIVE SUMMARY
FOR
DRAFT FINAL FEASIBILITY STUDY
FOR THE
MONTCLAIR/WEST ORANGE
AND
GLEN RIDGE, NEW JERSEY
RADIUM SITES
September 13, 1985
Prepared for:
U.S. Environmental Protection Agency
26 Federal Plaza
New York, N.Y. 10278
Prepared by:
Camp Dresser & McKee Inc,
Roy F. Weston, Inc.
Clement Associates, Inc,
ICF, Inc.
(RW9/38)
-------
EXECUTIVE SUMMARY
The Montclair/West Orange and Glen Ridge Radium Sites are three non-
contiguous radium-contaminated sites consisting of 45 acres in Montclair, 9
acres in West Orange and 50 acres in Glen Ridge. All three sites are
located in densely residential areas of suburban Essex County in north-
eastern New Jersey.
Radium-contaminated soils have been deposited as fill material around and
under homes in the three sites causing elevated radiation exposures that
pose a danger to the health of the residents of these areas. The radiation
exposures consist of elevated indoor concentrations of radon gas—a decay
product of radium, and elevated outdoor and indoor gamma radiation levels
that approach and sometimes exceed the radiological standards for the
general public.
•
The U.S. Environmental Protection Agency (EPA) contracted with Camp Dresser
& McKee Inc. (COM) to evaluate the feasibility of alternative plans to
remediate the contamination at the three sites. Because several remedia-
tion alternatives will require disposal of large amounts of contaminated
soil, a variety of different disposal alternatives also were evaluated.
The overall objective of the remedial action at the Montclair/West Orange
and Glen Ridge Radium Sites is to minimize or eliminate the potential
health hazard produced by the radioactive-contaminated soils present in the
three communities. The purpose of this study is to provide the information
necessary to select the most appropriate methods to remediate the contam-
ination at the sites and to dispose of the contaminated material. The
study is funded by EPA under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)--known as Superfund.
ES-1
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HISTORY OF INVESTIGATIONS
In 1979, the New Jersey Department of Environmental Protection (NJDEP)
initiated a program aimed at identifying and investigating those locations
in the state which were once the site of radium processing facilities.
Chief among those sites investigated was a facility in Orange, New Jersey
which had ceased operation in the 1920's. Concern over the possibility of
off-site disposal of processing waste prompted an aerial gamma radiation
survey of surrounding areas of Essex County. The survey identified areas
of elevated gamma radiation and suggested the existence of several possible
waste disposal sites. Three were located in the towns of Montclair, Glen
Ridge and West Orange.
In July 1983, the NJDEP, after consultation with the local officials, began
a preliminary investigation of the Montclair and Glen Ridge sites. The
investigation included outdoor gamma radiation surveys, indoor gamma
radiation surveys, and indoor measurement of radon gas.
The results of this investigation became available in late November 1983.
The gamma survey identified several areas in both neighborhoods where dis-
posal of contaminated material was indicated. The indoor radon gas mea-
surements identified a number of houses with radon concentration levels
well in excess of the expected background range. Several houses surveyed
had levels that exceeded the radon concentration occupational limit for
workers in uranium mines. The information available was sufficient to
indicate that there was an imminent and substantial endangerment to public
health.
In early December 1983 State and Federal public health and environmental
officials met to develop a risk assessment and management plan for the Glen
Ridge and Montclair sites. The results of these meetings were summarized
in the Public Health Advisory for Glen Ridge/Montclair that was issued by
the Federal Centers for Disease Control (CDC) on December 6, 1983. This
document advised EPA to remediate homes with elevated radon gas above a
defined health risk level and endorsed EPA's risk management plan, a
ES-2
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three-tier plan graded according to exposure level and time limit for com-
pletion of remedial action. CDC also outlined seven additional areas of
study for EPA and NJDEP to perform in order to characterize the extent and
nature of the radon contamination and the implications on groundwater and
vegetation contamination.
In December 1983, EPA initiated immediate "removal actions" to reduce
residents exposure to radon gas and radon progeny—the radioactive decay
products of radon.
In January 1984, EPA began a field investigation to better define the radon
and gamma levels in the homes and to determine the extent of contamination
in Montclair and Glen Ridge. A second field investigation was begun in
April 1984 at the West Orange site.
In October 1984, the EPA initiated a remedial investigation and feasibility
study at the three sites to:
o Review all previous studies and reports
o Identify data gaps and conduct additional sampling to close them
o Assess the alternatives for cleanup of the sites.
This report details the results of the investigation and alternative
assessment. The next step will be selection of a remedial alternative,
then design and implementation of the selected remedial plan.
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
Prior to undertaking the feasibility study of remedial alternatives, the
remedial investigation team (REM II) compared the site boundaries with the
mapped results of the aerial gamma survey to confirm the site boundaries,
performed indoor gamma surveys and outdoor gamma surveys on a number of
properties not previously investigated, and conducted downhole gamma
logging of boreholes in a number of locations to confirm the presence of
contaminated soils. After the remedial investigation was completed, the
feasibility study was undertaken.
ES-3
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Extent of Contamination
The results of all investigations to date reveal the following:
o 231 properties in the three sites have been identified as
having some type of contamination.
o 45 homes in the three sites have been identified as having
levels of radon exceeding acceptable levels. Eight of these
homes are currently being remediated under the NJDEP Phase I
Remediation.
o 16 homes had average indoor gamma exposures exceeding health
standards. Ten of these 16 are included in the 45 above;
i.e., they have both a radon and gamma problem. Two of the
16 are being remediated in the Phase I program. These two
have both radon and gamma problems.
o In summary, if Phase I is taken to completion, there will be
a total of 43 homes remaining with radiation exposures above
the recommended action levels; 29 homes with elevated radon,
6 homes with elevated gamma and 8 homes with both elevated
radon and elevated gamma.
o 90 homes have average indoor gamma readings along the base-
ment walls or across the basement floors exceeding background
levels (indoor gamma anomalies).
o 220 properties in the three areas have outdoor gamma radia-
tion exceeding background levels (outdoor surface gamma
anomalies).
ES-4
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SCREENING OF REMEDIAL ALTERNATIVES
The remedial technologies that were identified as possible responses for
remediation of the radium-contaminated soils in Montclair/West Orange and
Glen Ridge are shown in Table 1. These technologies were screened in three
phases. They were first evaluated in terms of their technological charac-
teristics—implementability, reliability, previous experience with each
technology and time required to implement each technology. The techno-
logies that passed this first phase of the screening were next screened for
environmental, public health and institutional constraints. Those passing
were then screened for cost. Technologies passing all three screening
phases were identified as candidate remedial alternatives and subjected to
a more intensive evaluation.
In accordance with EPA policy, at least one alternative was included from
each of the following catagories:
o No action
o Offsite disposal or treatment
o Alternatives that attain applicable and relevant Federal
public health or environmental standards
o Alternatives that exceed applicable and relevant Federal
public health or environmental standards
o Alternatives that do not attain relevant Federal public
health or environmental standards.
SUMMARY OF REMEDIAL ALTERNATIVES AND DISPOSAL OPTIONS
Remedial Alternatives
The six candidate remedial alternatives were evaluated in terms of
technical feasibility, environmental, socioeconomic, institutional and
public health impacts. Alternatives 1 through 5 were also evaluated for
costs. Sufficient information is not currently available to estimate the
cost of Alternative 6.
ES-5
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Alternative No. 1, No Action. The existing ventilation systems installed
during the removal action would be removed and quarterly monitoring would
be discontinued. This alternative does not attain public health objectives
or meet environmental standards.
Alternative No. 2, Active/Passive Measures. The existing ventilation
systems would be continued and additional ventilation systems installed.
After completion of Phase I, trench vents would be required to help reduce
radon levels in 12 homes where the existing ventilation systems do not
achieve removal of radon to acceptable levels. In addition 14 homes would
require installation of shielding to reduce exposure to gamma radiation.
This alternative assures the elimination of the adverse health impacts, but
does not meet the relevant environmental standards.
Alternative No. 3, Relocation of Receptors. After completion of Phase I,
43 properties with radon progeny concentrations in excess of 0.02 WL or
average indoor gamma exposure rates in excess of 20 uR/hr would be pur-
chased, the residents relocated, the structures demolished and disposed of,
and security fences placed around the property or group of contiguous
properties to prohibit access. This alternative would assure the elimin-
ation of the adverse health impacts by removing the receptors of contamina-
tion (residents) from the source. It would not attain relevant environ-
mental standards.
Alternative No. 4, Excavation to Eliminate Adverse Health Effects. Con-
taminated soils would be removed from all open lands—to the 5 or 15 pCi/gm
level averaged over 100 square meter area, and from under or around resi-
dences only if the radon progeny concentrations exceed 0.02 WL or if the
average indoor gamma exposure rates exceed 20 uR/hr above background. This
alternative would attain the goal of eliminating adverse health impacts but
would not meet the relevant environmental standards. Additionally, the
risk of future radon migration would necessitate continued radon gas moni-
toring in the community.
ES-6
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For alternatives 1 through 4, restrictions would have to be placed in deeds
requiring that excavation activities on contaminated properties be regu-
lated so that worker and public safety are addressed and to insure that
contaminated soils are properly disposed.
Alternative No. 5, Excavation to Meet Relevant Environmental Standards.
Contaminated soils would be removed from all open lands and from around and
beneath structures to specific radiation levels (5 or 15 pCi/g averaged
over any 100 square meters). This alternative attains all public health
objectives and meets relevant environmental standards. It would allow all
properties remediated to be released for unrestricted use.
Alternative No. 6, Excavation to Eliminate all Contamination. Any soil
within 6 inches of the ground surface exceeding 5 pCi/g and any soil
greater than 6 inches from the ground surface exceeding 15 pCi/g would be
removed from open lands and from around or under structures. This
alternative exceeds both public health and environmental standards and
would allow all properties remediated to be released for unrestricted use.
Disposal Options
The three excavation alternatives--4, 5 and 6--will require disposal of
large quantities of contaminated soil. Therefore, eight disposal options
were evaluated:
Option A - Permanent disposal at a licensed low-level radioactive waste
(LLW) disposal facility in the U.S.
Option B - Interim storage offsite in New Jersey or at another appropriate
location, with later reexcavation for final disposal within 400
miles
Option C - Interim storage onsite in Glen Ridge with later reexcavation for
final disposal within 400 miles
ES-7
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Option D - Permanent disposal at a lined, encapsulated cell in Glen Ridge
Option E - Permanent disposal on site at an unlined, cell in Glen Ridge
Option F - Permanent disposal at a lined, encapsulated cell at each of the
three sites
Option G - Permanent disposal at unlined, areas at each of the sites
Option H - Ocean disposal.
Evaluation of Alternatives
Table 2 presents the overall non-cost evaluation of the remediation alter-
natives. Table 3 presents the cost estimates for alternatives 1 through 3
and excavation alternative 5 combined with the eight disposal options.
Alternatives 1, 2 and 3 are the least costly of the six alternatives and
would require the least time for implementation. Implementation of any of
these alternatives, however, allow for continued adverse environmental
impacts. In addition, the implementation of these alternatives would
not remove all of the radium-contaminated soil which would continue to pose
a public health risk and would require deed restrictions to limit access to
the properties.
Of the excavation alternatives, Alternative 6 has been determined to be
unfeasible because of the degree of difficulty in implementing the clean-up
standard. The cost of verification for such a standard would be more than
an order of magnitude greater than the other two excavation alternatives.
All of the disposal options are technically feasible, and have either been
proven effective or are simple enough in conception that their success can
be predicted with confidence. From a public health viewpoint, all options
will effectively reduce the present health hazards at the sites and there
is no major difference in risk among the options. Likewise, environ-
mentally, the disposal options are all the same.
ES-8
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Any on-site disposal options would present major socioeconomic impacts to
the local communities, therefore the off-site disposal options are more
desirable from the residents' viewpoint. Institutionally, every option
poses problems which EPA and the State of New Jersey must address.
Of the eight disposal options, the least costly are Option E, onsite per-
manent disposal at an unlined encapsulated cell in Glen Ridge, which is
estimated to cost $41.3 million, and Option G, onsite permanent disposal at
an unlined encapsulated cell at each site estimated to cost $41.7 million.
Conclusion
Six alternatives for remediating contamination at the Montclair/West Orange
and Glen Ridge radium-contaminated sites were evaluated. Since three of
these alternatives require disposal of large quantities of contaminaed
soil, eight disposal alternatives were also evaluated.
The results of this draft report is being released for public review, com-
ment and input. EPA will then select a remedial plan for implementation.
(305/3)
ES-9
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TABLE 1
REMEDIAL TECHNOLOGIES
I. On-Site Control and Containment Technologies
A. Source Control
1. Capping
2. Subsurface barriers
B. Protection of Receptors
1. Shielding
2. Sealants
3. Passive collection system
4. Active collection system
5. Ventilation and air cleaning systems
6. Relocation
C. In-Situ Treatment
1. Solution mining
2. In-situ Vitrification
•
II. Removal and Off-Site Treatment/Disposal Technologies
A. Excavation
1. Conventional Excavation
2. Hydraulic mining
B. Transportation and Handling
1. Vehicles
a. Truck
b. Barge
c. Rail
2. Containerization
a. Bulk
b. Drums
c. Wooden or Metal Containers
d. Solidification
3. Transport Options
a. Direct loading/unloading
b. Transfer Station
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TABLE 1 (continued)
C. Interim Storage
1. Uncovered pile
2. Covered waste pile
3. Outdoor storage of containerized soil
4. Indoor storage
5. Moored cargo ship
6. Existing DOD or DOE facilities
D. Volume Reduction
1. Chemical Recovery of Radionuclides
2. Physical Separation
a. Separation by particle size and density
b. Ion exchange
c. Bulk separation at source
d. Bulk mixing
e. Dilution
E. Immobilization of Radionuclides
1. Vitrification
a. Electric furnace fusion
b. Rotary kiln
2. Matrix Isolation
a. Bitumen or asphalt
b. Cement
c. Resins
F. Permanent Disposal
1. RCRA-permitted facility
2. Department of Defense facility
3. Department of Energy facility
4. Licensed commercial low-level waste facility
5. Designed encapsulated disposal facility
6. Road bed dispersal
7. Mine burial
8. Ocean disposal
(6H13/16)
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TABLE 2
NON-COST EVALUATION OF ALTERNATIVES
No, 1
No
Criteria Action
Reliability
Previous
Implementation 0
Time to
Implement +
Air Impact
Groundwater
Impact
Public Health
Impact
Community
Acceptance
Deed
Restrictions
Siting
Problems +
No. 2 Disposal Disposal Disposal
Active/ Alt 3 Alt 4 Alt 5 Option Option Option
Positive Relocation Excavation Excavation A B C
+ + +00
+
+ + 0 0 0
00++ +
0 + + +
+ + 00 + + +
+ + + 0
0 + + +
+ + 0 0 +
Disposal Disposal Disposal Disposal Disposal
Option Option Option Option Option
D E F G H
0 - 0 - -
.
00000
+ + + + +
+ 0 + 0 +
+
-
+
+
+ Denotes positive or beneficial impact
0 Denotes no significant impact
Denotes negative or adverse impact
(RW11/12)
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AH. 1 Alt. 2
No Action Active Meas.
TalDTe 3
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
REMEDIAL ALTERNATIVE COST SUMMARY
($1000)
Alt. 3 Alt. 5
Relocation of Disposal Disposal Disposal Disposal Disposal Disposal Disposal Disposal
Receptors Option A Option B Option C Option D Option E Option F Option G Option H
Excavation & Restoration
Engineering of Excavation
Transport to Interim
Interim Site Selection & Design
Interim Acquisition
Interim Site Construction
Final Site Selection & Design
Final Site Acquistion
Reexcavation
Containerize waste
Transloading Facility
Transport to Final Disposal
Construct Final Disposal
Storage Charges
Relocation of Residents
Demolition and Disposal
Secure Properties
EIS for Ocean Disposal
Port Fees
Load Barges
Ocean Transport
Monitoring
200 16,300 16,300 13,000 15,500 11,900 14,100 9,700 16,200
8,500 8,500 7,800 8,500 7,300 8,500 6,000 8,500
3,500 400 3,500
1 , 300 500 1 , 300
5,400 400 3,800 400
2,800 1,700 2,800
1,300 1,300 500 500 1,500 1,500
500 500 8,800 8,800 9,500 9,500
1,800 3,900
. 38,000
200
36,400 7,800 7,800 700 300 700 300 3,500
7,000 7,000 5,000 3,500 7,200 5,200
73,000
200 800 800 800 800 800 800 800 800
300
100
2,000
200
700
1,900
900
Install /Remove Vent
and Shielding 50 1,100
Operation and Maintenance 2,500
Legal and Administrative . 50 600
Total 100 4,200
400 400 400 400 900 900 300
900 7,800 /.800 7,800 7,800 7,800 7,800 7,800 7,800
7,100 181,000 60,200 56, 700 48,000 41,300 51,000 41,700 52,600
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION 1-1
1.1 Site Background 1-1
1.1.1. Site Description 1-1
1.1.2 Site History 1-6
1.2 Environmental Setting 1-17
1.2.1 Land Use 1-17
1.2.2 Socioeconomy 1-19
1.2.3 Climate and Meteorology 1-21
1.2.4 Topography 1-21
1.2.5 Surface Waters 1-24
1.2.6 Geology 1-24
1.2.7 Groundwater 1-26
1.2.8 Drinking Water 1-29
1.3 Extent of Contamination 1-30
1.3.1 Nature of Contamination 1-30
1.3.2 Remedial Investigation Protocol 1-33
1.3.3* Aerial Gamma Survey 1-34
1.3.4 Outdoor Surface Gamma Contamination 1-41
1.3.5 -Radon Contamination 1-44
1.3.6 Indoor Gamma Contamination 1-46
1.3.7 Subsurface Contamination 1-46
1.3.8 Surface Water and Groundwater Contamination 1-54
1.3.9 Conceptual Model of Contamination 1-59
1.4 Objectivies of Remedial Action 1-61
1.4.1 Remedial Objectives 1-62
1.4.2 Relevant Public Health and Environmental
Standards 1-62
2.0 SCREENING OF REMEDIAL ALTERNATIVES 2-1
2.1 Technical Screening of Remedial Technologies 2-2
2.1.1 Source Control Technologies 2-2
2.1.2 Protection of Receptors 2-5
2.1.3 In-Situ Treatment 2-8
2.1.4 Excavation 2-11
2.1.5 Transportation and Handling 2-12
2.1.6 Interim Storage 2-15
2.1.7 Volume Reduction 2-18
2.1.8 Immobilization of Radionuclides 2-23
2.1.9 Permanent Disposal 2-27
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2.2 Environmental and Public Health and Institutional
Screening of Remedial Action Alternatives 2-35
2.2.1 Source Isolation 2-35
2.2.2 Protection of Receptors 2-38
2.2.3 Excavation with Standard Earth-moving Equipment.. 2-40
2.2.4 Transportation and Handling 2-40
2.2.5 Interim Storage 2-42
2.2.6 Immobilization of Radionuclides by Matrix
Isol ation 2-44
2.2.7 Disposal Options 2-44
2.3 Cost Screening of Remedial Action Alternatives 2-48
2.3.1 Onsite Source Control - Protection of Receptors... 2-48
2.3.2 Removal and Disposal Responses 2-51
2.4 Assembling Remedial Action Alternatives 2-56
2.4.1 Onsite Protection of Receptor Responses 2-56
2.4.2 Removal and Disposal Responses 2-56
3.0 IDENTIFICATION OF CANDIDATE REMEDIAL ALTERNATIVES 3-1
3.1 Alternative No. 1 - No Action 3-3
3.2 Alternatives No. 2 - Active/Passive Measures 3-3
3.3 Alternative No. 3 - Relocation of Receptors 3-7
3.4 Alternatives 4, 5, and 6 - Excavation of Contaminated
Soi 1 s 3-8
3.4.1 Excavation 3-10
3.4.2 Restoration 3-10
3.4.3 Mitigating Measures 3-13
3.5 Disposal Options 3-15
3.5.1 Disposal Option A - Permanent Disposal at a
Licensed Low Level Waste (LLW) Disposal Facility. 3-15
3.5.2 Disposal Option B - Offsite Interim Storage
within the State of New Jersey or at Other
Appropriate Locations and Reexcavation for Final
Disposal within 400 Miles 3-16
3.5.3 Disposal Option C - Interim Storage in Glen Ridge
and Reexcavation For Final Disposal within 400
Mi 1 es 3-24
3.5.4 Disposal Option D - Permanent Disposal at Lined,
Encapsulated Cell in Glen Ridge 3-25
3.5.5 Disposal Option E - Permanent Disposal at an
Unlined, Capped Cell in Glen Ridge 3-29
3.5.6 Disposal Option F - Permanent Disposal at a Lined,
Encapsulated Cell at Each Site 3-31
3.5.7 Disposal Option G - Permanent Disposal at an
Unlined, Capped Cell at Each Site 3-35
3.5.8 Disposal Option H - Ocean Disposal 3-37
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4.0 ANALYSIS OF CANDIDATE REMEDIAL ALTERNATIVES 4-1
4.1 Technical Feasibility 4-1
4.1.1 Alternative 2 - Active/Passive Measure 4-1
4.1.2 Alternatives 3 - Relocation of Receptors 4-4
4.1.3 Excavation Alternatives 4, 5 and 6 4-5
4.1.4 Disposal Options A through H 4-10
4.2 Environmental Assessment 4-18
4.2.1 Physical Environment 4-18
4.2.2 Biological Environment 4-29
4.2.3 Socioeconomic Environment 4-30
4.3 Public Health Evaluation 4-41
4.3.1 Hazard Assessment 4-41
4.3.2 Exposure Assessment 4-48
4.3.3 Risk Assessment 4-58
4.3.4 Summary 4-70
4.4 Institutional Issues 4-71
4.4.1 Interagency Coordination 4-71
4.4.2 Regulatory 4-72
4.4.3 Residential Usage Restrictions 4-77
4.4.4 Facility Siting Constraints 4-77
4.5 Cost Analysis 4-78
5.0 SUMMARY OF ALTERNATIVES 5-1
5.1 Non-Cost Evaluation of Alternatives 5-1
5.1.1 Alternative No. 1, No Action 5-1
5.1.2 Alternative No. 2, Active/Passive Measures 5-1
5.1.3 Alternative No. 3, Relocation of Receptors 5-3
5.1.4 Alternative No. 4, Excavation to Eliminate
Adverse Health Effects 5-4
5.1.5 Alternative No. 5, Excavation to Meet Relevant
Environmental Standards 5-4
5.1.6 Alternative No. 6, Excavation to Eliminate All
Cont ami nati on 5-4
5.1.7 Disposal Options 5-5
5.2 Non-Cost Comparison of Alternatives 5-7
5.3 Cost Comparison of Alternatives 5-8
Glossary and Acronyms
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ATTACHMENT 1 EPA Memorandum: Applicability of Secondary Standards
to the Montclair/West Orange and Glen Ridge Radon
Sites, February 21,1985
ATTACHMENT 2 US Department of Defense Directive, No. 6050.8,
August 24, 1981
ATTACHMENT 3 US Department of Energy Memorandum: Policy on Management
TRU and Low Level Waste
ATTACHMENT 4 EPA Correspondence from W.J. Librizzi, Director of
Emergency and Remedial Response Division, US EPA,
Region II, to DOE Officials
MAPS (G/C)
(DEC31/5)
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LIST OF FIGURES
Figure No. Page
1-1 Location of Montclair/West Orange and Glen Ridge
Radium Sites 1-2
1-2 Montclair Study Area 1-3
1-3 West Orange Study Area 1-4
1-4 Glen Ridge Study Area 1-5
1-5 Montclair Study Area; Stream Bed 1-8
1-6 Development of Montclair Site 1-9
1-7 West Orange Study Area: Course of Wigwam Brook 1-11
1-8 Glen Ridge Study Area: Stream Bed, Sand Pits
and Hill 1-12
1-9 Bedrock Geology of the Northeast New Jersey Area 1-25
1-10 Areas Favorable for Uranium Deposits 1-27
1-11 Surficial Geology of Essex County, N.J. 1-28
1-12 Uranium-238 Decay Series 1-31
1-13 Results of Aerial Gamma Survey 1-36
1-14 Aerial Gamma Isopleths-Montclair Site 1-38
1-15 Aerial Gamma Isopleths - West Orange Site 1-39
1-16 Aerial Gamma Isopleths - Glen Ridge Site 1-40
3-1 Montclair Study Area - Alternatives 2 and 3 3-4
3-2 West Orange Study Area - Alternatives 2 and 3 3-5
3-3 Glen Ridge Study Area - Alternatives 2 and 3 3-6
3-4 Montclair/West Orange and Glen Ridge - Offsite Interim
Storage Pile, Disposal Option B 3-19
3-5 Lined Encapsulation Cell - Disposal Option B, D and F 3-22
3-6 Montclair/West Orange and Glen Ridge - Interim Storage
Pile, Disposal Option B 3-26
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LIST OF FIGURES
(continued)
Figure No.
3-7 Glen Ridge Interim Storage Area - Option C 3-27
3-8 Glen Ridge Permanent Disposal Area, Options G and H 3-28
3-9 Montclair/West Orange and Glen Ridge - Unlined
Encapsulation Permanent Storage Cell Disposal, Options
E and G 3-30
3-10 Glen Ridge Onsite Permanent Disposal Area, Options
F and G 3-32
3-11 Montclair Onsite Permanent Disposal Area, Options
F and G 3-33
3-12 West Orange Onsite Permanent Disposal Area, Options
F and G 3-34
4-1 Average Gross Alpha Air Sample Concentration 4-6
4-2 Average Radon Concentration 4-7
4-3 Pre-Cleanup Radium-226 Surface Concentrations 4-8
4-4 Post-Cleanup Radium-226 Surface Concentrations 4-9
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LIST OF TABLES
Table No. Page
1-1 Demographic Data 1-19
1-2 Property Tax Analysis 1-22
1-3 Climatological Data 1-23
1-4 Criteria for Inclusion or Exclusion of Properties
from Remediation Program 1-35
1-5 Additional Properties for Investigation Identified
from Aerial Survey 1-37
1-6 Summary of Outdoor Surface Gamma Survey Results 1-42
1-7 Summary of Radon Progeny Sampling Results 1-45
1-8 Summary of Indoor Gamma Survey Results 1-47
1-9 Summary of Subsurface Gamma-Logging Investigations 1-48
1-10 Radiochemical Analysis of Split Spoon Samples 1-51
1-11 Radiochemical Analysis of Background Geologic Strata 1-52
1-12 Summary of Split Spoon Analysis Showing Average Depth
of Contamination per Soil Matrix at Each Site 1-53
1-13 Radiochemical Analysis of Sediment Samples 1-55
1-14 Sample Results - Montclair/Glen Ridge Groundwater
Monitoring 1-56
1-15 Remaining Data Gaps 1-58
1-16 Extent of Contamination 1-60
1-17 Dose-limiting Recommendations of NCRP 1-63
1-18 Maximum Permissible Concentrations and National
Interim Primary Drinking Water Standards 1-65
1-19 Health and Environmental Protection Standards for
Uranium Mill Tailings 1-70
2-1 Remedial Technologies 2-3
2-2 Remedial Technologies for Noncost Screening 2-36
-------
LIST OF TABLES
(continued)
Table No. Page
2-3 Remedial Action Responses for Cost Screening 2-49
3-1 Monte lair/West Orange and Glen Ridge Remedial
Alternatives 3-2
4-1 Radon and Radon Progeny Reduction in Remediated
Residences 4-3
4-2 Pre- and Post-Remedial Action Working Levels 4-10
4-3 Tax Revenue Losses Due to Disposal Options 3 through 7 4-37
4-5 Estimated Numbers of People Exposed to Various Levels of
Radon 4-50
4-6 Estimated Number of People Exposed to Various Levels of
Gamma Radiation 4-53
4-7 Estimated Excess Risk of Lung Cancer Associated with
E/posure to Radon-222 and its Progeny 4-60
4-8 Excess Risk of Lung Cancer in the Montclair/
West Orange and Glen Ridge Study Areas 4-61
4-9 Estimated Excess Risk of Cancer Associated with Various
Doses of Gamma Radiation 4-63
4-10 Excess Risk of Cancer Due to Gamma Radiation in the
Montclair/West Orange and Glen Ridge Study Areas 4-64
4-11 Radionuclide Data for Calculating Risks from Ingestion
. of Home Grown Vegetables 4-65
-------
LIST OF TABLES
(continued)
Table No.
4-18 Estimated Cost : Alternatives 1,2, and 3
4-19 Estimated Cost of Disposal Option A
4-21 Estimated Cost of Disposal Option B
4-22 Estimated Cost of Disposal Option C
4-23 Estimated Cost of Disposal Option D
4-24 Estimated Cost of Disposal Option E
4-25 Estimated Cost of Disposal Option F
4-26 Estimated Cost of Disposal Option G
4-27 Estimated Cost of Disposal Option H
5-1 Non-Cost Evaluation of Alternatives
5-2 Montclair/West Orange and Glen Ridge
Remedial Alternative Cost Summary
Page
4-81
4-82
4-83
4-84
4-85
4-86
4-87
4-88
4-89
5-2
5-9
(DEC31/5)
-------
-------
1.0 INTRODUCTION
Elevated radiation exposures that approach and sometimes exceed the radio-
logical standards for the general public have been identified in the Mont-
el air/West Orange and Glen Ridge study areas. Elevated outdoor and indoor
gamma radiation levels and indoor radon concentrations in excess of ex-
pected background ranges have been found. The source of the elevated
radiation exposure is known to be radium-contaminated soil that has been
deposited as fill material in several discrete pockets throughout the study
areas.
1.1 SITE BACKGROUND
1.1.1 SITE DESCRIPTION
The Montcl air/West Orange and Glen Ridge Radium Sites include three non-
contiguous radium-contaminated sites located in residential areas of
suburban Essex County in northeastern New Jersey. Figure 1-1 shows the
location of the three sites. The irregular closed lines indicate the
boundaries of the study areas.
The Montclair study area covers approximately 45 acres encompassing parts
of the Towns of Montclair and of West Orange. Figure 1-2 shows the
Montclair study area in greater detail. The West Orange study area covers
approximately 9 acres in the Town of West Orange. Figure 1-3 shows the
West Orange study area in greater detail. The Glen Ridge study area covers
approximately 50 acres encompassing parts of the Town of Glen Ridge and
Town of East Orange. Figure 1-4 shows the Glen Ridge study area in greater
detail.
1-1
-------
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*/ * i^f /••-,' ^»
• %/' ; * ~-,j / /••.''!«**
•> \ j?' / -. / , j-. •/ / .'/
; • N V ,^S ,• 7 .//•
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-------
1-s a|g 13fri*. ;•— =r- -
Cj cfc I2t = isZ::i= I
~b-£jg]-- n! '- »T=
-S—rtr- uTl 5 j __• _u '— y • 1 —i
LEGEND:
STUDY AREA PERIHETER
SCflLE: N.T.S.
SOURCE: HUS CORPORflTIOH
CDM
environmental engineers, scientists.
planners & management consultants
FIGURE: I-4
MONTCLAIR / WEST ORANGE AND 6LEN RI06E
RADIUM SITES
GLEN RIDGE STUDY AREA
1-5
-------
LEGEND:
STUDY AREA PERIHETER
SCflLE: N.T.S.
SOURCE: HUS CORPORflTIOH
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-2
MONTCLAIR / WEST ORANGE AND 6LEN RID6E
RADIUM SITES
MONTCLAIR STUDY AREA
1-3
-------
en
, J
a
0
Q
R
LJ
pa
k
t-"-
r
h.
LEGEND
STUDY AREA PERIHETER
SCflLE: N.T.S.
SOURCE: HUS CORPORflTIOH
COM
environmental engineers, scientists. •
planners & management consultants
FIGURE: 1-3
MONTCLAIR / WEST ORANGE AND 6LEN RID6E
RADIUM SITES
WEST ORANGE STUDY AREA
1-4
-------
LEGEND:
_ STUDY AREA PERIMETER
APPARENT CORE OF GAMMA
ACTIVITY
— — — COURSE OF FORMER STREAM
....... ROUTE OF CONDUIT
SCALE: N.T.S.
SOURCE: HUS CORPORRTIOH
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-5
nONTCLAIR/WEST ORANGE AND 6LEN RI06E
RADIUM SITES
MONTCLAIR STUDY AREA:
STREAM BED
1-8
-------
1.1.2 SITE HISTORY
In 1979, the New Jersey Department of Environmental Protection (NJDEP) ini-
tiated a program to identify and investigate locations within the State
where radium processing facilities formerly existed. One such facility is
the former U.S. Radium plant in Orange, New Jersey. Because of concern
about the possibility of past disposal of radium byproducts and waste
material at locations distant from the processing facilities, NJDEP re-
quested that the U.S. Environmental Protection Agency (EPA) conduct an
aerial survey to detect any elevated gamma radiation levels that might
exist. In 1981, EPA conducted a helicopter survey of 12 square miles of
Essex County. The survey identified approximately 53 areas of elevated
gamma radiation. As a result of further investigation, NJDEP and EPA
identified three distinct areas within the residential communities of
Montclair, West Orange and Glen Ridge where the disposal of waste material
appeared to have occurred. Based on the initial screening surveys, the
Center for Disease Control (CDC) outlined, in a December 6, 1983 memo,
additional studies needed by the EPA and the State of New Jersey to
evaluate all potential health risks related to the situation.
Development of Sites
The radium and radium-products industry in New Jersey flourished from the
early 1900's to the middle and late 1920's. In the later part of that
time, the knowledge of the hazards of radium and the discovery of richer
pitchblende ore in Africa caused the radium industry in the United States
to go into a sharp decline. By the 1930's, the radium-processing industry
had all but disappeared from the United States.
Sections of the Montclair/West Orange and Glen Ridge Radium Sites were
developed for residential use in the middle and late 1920's. Before
development, these areas had been used as dumps for ash and rubbish.
1-6
-------
Montclalr
Development within the Montclair site appears to have occurred mostly be-
tween 1910 and 1940. Inspection of old street maps of the site indicates
that the section of the site to the north of the Montclair/West Orange
border was essentially undeveloped by 1925. Harrison Avenue and High
Street, which border the most heavily contaminated areas, and Virginia
Avenue, which cuts through the center of the contamination, however, had
been active thoroughfares since before 1900. Records show that a stream
once ran along the present route of Nishuane Road, cutting the corner at
Virginia Avenue and continuing though what are now backyards of houses on
Fremont Avenue and Franklin Avenue (Figure 1-5). Long-time residents
recall the stream bed being used as a dump for ash and rubbish prior to
development of the site. The first houses erected in the area of most
severe contamination were built in 1927. A storm culvert was laid in the
roads in 1934, approximating the course of the former stream bed.
By 1940, the only two areas left undeveloped were an estate on the east
side of High Street and three streets connecting Harrison Avenue to
Nishuane Road: Southern Terrace, Homewood Way and Wilfred Street. By
1947, Wilfred Street had been demolished and an extension of Franklin
Avenue cut through the old right-of-way (Figure 1-6). Since then, a number
of houses throughout the contaminated area have been demolished and new
ones constructed on the lots. Records suggest that there has been frequent
excavation throughout the site for installation and repair of utilities.
The portion of the site on the West Orange side of the border was com-
pletely developed by 1940. Street maps prior to this date suggest that the
roads between Watson Avenue and Franklin Avenue were demolished and relaid
several times between 1900 and 1940. This activity stopped with the
construction of Whittlesey Street and Fremont Avenue sometime between 1925
and 1936, and the demolition of a parallel road between Fremont and Watson.
By 1940, the current streets were in place and, aside from maintenance of
utilities, no major construction has since occurred in this section of the
site.
1-7
-------
WESTERN PORTION OF MONTCLAIR SITE 1940
WESTERN PORTION OF MONTCLAIR SITE 1985
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-6
nONTCLAIR/WEST ORANGE AND 6LEN RI06E
RADIUM SITES
DEVELOPMENT OF
MONTCLAIR SITE
1-9
-------
STUDY AREA PERIMETER
APPARENT CORE OF GAMMA ACTIVITY
_ _ — FORMER COURSE OF BROOK
PRESENT COURSE OF BROOK
OPEN CULVERT
_ UNDERGROUND
SCflLC: N.T.S.
SOURCE: HUS CORPORRTIOH
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-7
MONTCIAIR/WEST ORANGE AND 6LEN RI06E
RADIUM SITES
WEST ORANGE STUDY AREA:
COURSE OF WIGWAM BROOK
1-11
-------
LEGEND:
STUDY AREA PERIMETER
APPARENT CORE OF GAMMA ACTIVITY
FORMER COURSE OF STREAM
LOCATION OF FORMER SANDPIT
LOCATION OF FORMER WOODED HILL
SCflLE: N.T.S.
SOURCE: HUS CORPORflTIOH
COM
environmental engineers, scientists.
planners A management consultants
FIGURE: 1-8
nONTCLAIR/WEST ORANGE AND 6LEN RID6E
RADIUM SITES
GLEN RIDGE STUDY AREA:
STREAM BED. SAND PITS AND HILL
1-12
-------
West Orange
The streets that mark the boundary of the West Orange study area can be
identified from topographic maps as early as 1898. These maps also show a
north-south stream (Wigwam Brook) crossing the site and fed by a stream
entering the site from the northwest. Longtime residents report that the
areas near the brook were used a dump for ash and rubbish until the two
streams were channelized as part of a WPA project. Wigwam Brook's course
was changed by this project so that it entered and exited the site approxi-
mately 100 feet further west than it had formerly (Figure 1-7). The
smaller stream flowing in from the west was replaced by a buried tile pipe
running between Alan Street and Wilfred Avenue. The slope to the stream
was also made less steep and the area that is now James Court was made
level. During this same period, the owners of the northeast corner of the
site terraced their property for use as a truck and bus lot. Street maps
show Alan Street changing from a through street to a dead-end road at this
time, but there is no evidence that Alan Street had ever been completed as
a through street. Houses were built on Alan Street as early as 1926 and on
James Court as early as 1930.
A 1940 aerial photo shows the site completely developed, except for the lot
at 40 Mississippi Avenue, where Wigwam Brook exits the site. The area to
the north and northeast of the site shows up as an undeveloped, wooded
area. From this time to 1961 there was considerable filling or dumping
activity in this area, followed by construction of an apartment complex.
Development of the area was completed by 1961.
Glen Ridge
Development of the Glen Ridge study area began in the early 1920's. Prior
to that time, the major features of the site, as determined from a series
of topographic maps dated from 1900 to 1936, were a group of three sand
pits (Figure 1-8). Two were in the southwest section of the site, in the
area of Somrner Avenue, Hawthorne Avenue and Glen Park Road. The Glen Ridge
Municipal Yard was built over the third. The maps also show a stream ori-
ginating near the present corner of Sommer and Hawthorne Avenues, running
1-10
-------
east through the southeast corner of the present Barrows Field and exiting
the site. Another stream originated just outside the site where Madison
Street ends today and flowed into the first stream described. Neither
stream is shown on the topographic maps from 1936 or later, nor are they
visible in aerial photographs. Long-time residents in the study area
report that the depressed area that is now Barrows Field was used as an ash
and bottle dump and was filled in the 1930's. They also describe the
existence of'sand and gravel banks on the south side of Carteret Street,
and a pond somewhere in the central area of the site. Dates for the
existence of the pond and gravel banks are uncertain. Residents also
referred to a steep hill in the southeast portion of the site, evident in a
1940 aerial photo.
Only Carteret Street is shown on the 1925 topographic map, with Hawthorne
Avenue completed as far as its intersection with north side of Carteret.
Construction records show Lorraine Street and Madison Street being
constructed in 1927 and 1928, with houses being built in the mid-19301s.
By 1936, all streets except Victor Avenue were shown on the map.
By 1940, the entire area north of Carteret Street had been developed.
South of Carteret Street was an undeveloped area comprising what are now
eight houses on Carteret Street and the eastern half of Victor Avenue.
This area was covered by the wooded hill described above. The buildings in
the municipal yard had also been constructed by 1940. The aerial photo
shows evidence of contemporary fill activity in the eastern half of Barrows
Field near Midland Avenue and a large vacant area off site south of the
hill. About this time, storm drains were rebuilt along Carteret Street.
Runoff from the field was collected at catchbasins within the field and
routed to a storm sewer main on Carteret Street.
By 1951, the hill had been leveled and new houses added on Carteret Street.
Victor Avenue was completed a few years later. In 1984, the drainage sys-
tem within Barrows Field was filled and a French drain dug in the field
behind the houses on Midland Avenue, which connects to the Midland Avenue
main.
1-13
-------
History of Investigations
In July 1983, NJDEP began preliminary field investigations in Montclair and
Glen Ridge to assess the extent of the contamination problem. NJDEP con-
ducted an initial outdoor gamma survey on public thoroughfares, and sub-
sequently received permission from residential property owners to perform
indoor and outdoor gamma surveys and to take indoor radon measurements.
In December 1983, State and Federal public health and environmental offi-
cials met to develop a risk assessment and management plan for the con-
tamination problem in the area. The results of these meetings were sum-
marized in the Public Health Advisory for Glen Ridge/Montclair that was
issued by the Centers for Disease Control (CDC) on December 6, 1983. This
document advised EPA to remediate homes with radon gas and radon progeny
above a defined health risk level and endorsed EPA's risk management plan
which broke radon exposure levels into tiers and assigned a time limit for
completion of remedial action for each-tier. CDC also outlined seven addi-
tional areas of study for EPA and NJDEP to perform in order to define the
radon and gamma contamination perimeter, characterize and locate the source
material, and determine the potential for groundwater contamination and
contaminant uptake via vegetation ingestion.
In December 1983, EPA initiated an immediate remedial action to reduce the
exposure of residents to the radon gas and radon decay particles. This
removal action involved fitting the 22 homes having the highest concentra-
tions of radon gas with ventilation systems to introduce fresh air and
alleviate the immediate health threat from the radon gas.
In January 1984, EPA began a field investigation using a Field Investiga-
tion Team (FIT) to identify the boundary of contamination and to quantify
excessive gamma and radon levels in the affected areas of Montclair and
Glen Ridge. In April 1984, the investigation was extended to include the
non-contiguous West Orange site. Residents in the three communities who
had air sampling conducted in their homes were notified of the sampling
1-14
-------
results by EPA when the values were determined. Surface gamma survey re-
sults were provided to homeowners following the data analysis. The EPA
investigation identified 45 homes with elevated and excessive levels of
radon gas.
EPA initiated a second field investigation with FIT in April 1984 to
characterize the nature and location of contaminated material that was
causing the elevated radon and gamma levels. EPA continued to collect data
on the contaminated areas through the summer and fall of 1984 to more fully
define the extent of the contamination problem.
In May 1984, a task force composed of representatives from EPA and NJDEP
proposed a pilot study under the direction of EPA to acquire additional
data for the remedial investigation and feasibility study as well as to
develop construction estimates for evaluating the cost of various remedial
alternatives. Twelve homes in the three communities with varying degrees
of contamination and types of construction were selected by EPA. After
completing the preliminary design, EPA decided to delay the pilot study
until the end of the remedial investigation and feasibility study (RI/FS),
then scheduled to begin in the near future.
The data gathered by EPA during the two field studies were used by the
NJDEP to initiate its own Phase I Study in November 1984 to clean up the 12
properties identified by EPA and the NJDEP task force. NJDEP believed that
the cleanup of the sites could be expedited by this Phase I Study and that
technical feasibility, cost data, and soil volume estimates generated by
the Phase I Study would assist EPA in the final design and construction of
its recommended alternative for cleanup of both sites.
In August 1984, NJDEP released a proposal to temporarily store the ex-
cavated contaminated soil from the Phase I Study in the West Orange Armory.
Residents in West Orange expressed strong opposition to this proposal
during a well attended public meeting. Based on this community opposition,
the NJDEP withdrew its proposal to store the radium contaminated soil at
the West Orange Armory and eventually selected a disposal site in Beatty,
1-15
-------
Nevada, which is owned by U.S. Ecology, Inc., to receive the Phase I Study
excavated soil. In February 1985, the New Jersey State legislature
appropriated $8 million from the New Jersey general budget to support Phase
I. Governor Kean of New Jersey signed this legislation in April 1985. Ex-
cavation for the NJDEP Phase I began in June 1985 and is scheduled for com-
pletion in the fall of 1985.
Remedial Investigation
The Montclair/West Orange and Glen Ridge radium sites were included on the
proposed EPA Superfund National Priorities List (NPL) in October 1984, and
on the final NPL in February 1985 as two sites.
In November 1984, EPA initiated its remedial investigation and feasibility
study on the two sites. The purpose of the RI/FS was to:
o Review all previous studies and reports
o Identify data gaps and conduct additional sampling to close them
o Assess the alternatives for permanent remedial action at the
sites.
The review of previous studies and reports and identification of data gaps
were completed in February 1985 and presented as an Interim Report.
EPA and its contractors contacted local officials in the three communities
to obtain permission to test and sample affected municipal properties. In
addition, EPA, working with NJDEP, contacted approximately 400 homeowners
residing on site for permission to sample and survey their properties in
order to verify the exact location and volume of the radium-contaminated
soil. Over 80 percent of the residents contacted by the EPA and its
technical and community relations contractor staff granted permission for
testing and sampling of affected properties.
1-16
-------
EPA completed the remedial investigation of the Radium sites in April 1985.
The EPA will release the draft RI/FS reports to the public and will conduct
a public comment period so that residents may comment on the draft feasibi-
lity study report. EPA will prepare a responsiveness summary to all verbal
and written public comments submitted to the agency throughout the public
comment period. The EPA responsiveness summary will be included as part of
the Record of Decision on the selected alternative for cleanup of the
radium sites.
1.2 ENVIRONMENTAL SETTING
The description of the environmental setting of the Montclair/West Orange
and Glen Ridge Radium sites identifies land use and climatic conditions
within the site areas as well as natural and manmade features.
1.2.1 LAND USE
The areas of contamination in Montclair, West Orange and Glen Ridge consist
of older, well established residential neighborhoods with single- and two-
family homes. Some commercial, recreational and institutional uses exist
near the sites. The following paragraphs describe the on-site land use and
adjacent land use.
Montclair
Land use within the Montclair study area is entirely residential, with some
small businesses along Harrison Avenue, immediately outside the site bound-
ary. A recreational park, Nishuane Park, with ball field and basketball
courts, is located about 500 feet north of the site, adjacent to Nishuane
School. Located within one half-mile of the Montclair area are the
following schools and health-care related facilities:
o Nishuane School
o Brookside School
o Montclair Community Hospital
1-17
-------
o Our Lady of Lourdes School
o Edison Junior High School
o Washington Street School
o Montcalm Manor Nursing Home.
West Orange
Land use within the West Orange site is primarily residential. There is a
bus company with parking lot, office and garage at the northeast corner of
the site. There are no other businesses in the immediate vicinity. Apart-
ment complexes have been built to the north and northeast. The site is
near Eagle Rock Reservation (a county park) but is considerably below it in
elevation. Located within one half-mile of the West Orange area are the
following schools and health-care related facilities:
o Our Lady of Lourdes School
o Edison Junior High School
o Montclair Community Hospital.
Glen Ridge
Land use within the Glen Ridge study area is primarily residential. There
is a recreational facility (Barrows Field) in the east central portion of
the site, consisting of a park area, baseball fields and basketball courts.
Part of the eastern section of the site is used as a municipal garage and
storage area. Land use in the immediate vicinity is almost entirely resi-
dential, with a few small businesses on Carteret Street in Blcornfield, east
of the site, and Ridgewood Avenue, near the southwest corner of the site.
There are no health care facilities located within one half-mile of the
Glen Ridge area but there are the following schools:
o Holy Name School
o Franklin School
o Linden Avenue School.
1-18
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1.2.2 SOCIOECONOMY
The population of all three towns includes middle and working class income
groups as well as a significant percentage of higher income households.
Many elderly people have lived in the area for over 30 years. In the last
decade, however, young families have moved to the area in search of afford-
able and convenient housing.
Population data, derived from the 1980 U.S. census, is summarized in Table
1-1. The populations within the site boundaries are similar to each other
in age distribution, although the median age at the West Orange study area
is lower than at the other two sites. Roughly 6 percent of the combined
population of the site are children of less than 5 years of age. Adults
over 65 years constitute almost 15 percent of the combined populations.
Income data are presented in Table 1-1 as indicators of the relative
incomes for the populations within the sites. Census data for household
income are not broken into small enough groups to differentiate the sites
from the surrounding areas. The values themselves are not to be taken as
actual household incomes since they have been obtained from voluntary
reports.
The occurrence of radiologically contaminated soils in Montclair/Glen Ridge
and West Orange has been widely publicized. The publicity has adversely
affected each of these communities in that there is a perception that
property values have declined. Property values based on sales have not
demonstrated a decline. However, there are fewer prospective buyers who
are willing to overlook the presence of contamination on a property. Con-
sequently, properties have been considerably more difficult to sell (Bron-
nander, 1985).
In 1984 the Essex County Board of Taxation granted petitioners of 39
properties a tax relief. In Montclair, 32 properties received a tax relief
over a 2-year period based on a policy that specified a home could receive
a 20 percent tax relief if there were soil contamination and 50 percent if
1-19
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TABLE 1-1
DEMOGRAPHIC DATA
(1980 U.S. Census)
Montclalr
Site
Total
Population
Age: 65
5 to 64
V 65+
o
Median Age
Number of
Households
Average True
House Value
Average Household
Income
1053
52
851
150
39.3
288
$49,300
$21,300
West Orange
Site
184
10
148
26
33.8
63
$58,600
$21,300
Glen Ridge Total
Site
622
48
481
93
37.4
253
$67,500
$32,000
1859
110
1480
269
38.2
604
-------
the home had radon contamination requiring installation of a ventilation
system (Carradonna, 1985). In Glen Ridge, 22 properties were granted a tax
relief by the County; however, the Town did not recognize the judgement and
appealed it in the State courts (Ebert, 1985). West Orange has been more
flexible, granting tax relief to eight properties, some of which are
adjacent to other properties with contamination. These tax reliefs have
resulted in lost tax revenue to Montclair and West Orange, and Glen Ridge
also stands to lose revenue (Table 1-2).
A decreased tax base will have a more severe impact on Glen Ridge than on
either Montclair or West Orange. Glen Ridge has a smaller residential tax
base than the other towns and virtually no commercial or industrial tax
base. The tax bases in both Montclair and West Orange have significant
commercial and industrial component that are not affected by the
contaminated areas.
1.2.3 CLIMATE AND METEOROLOGY
The Montclair/West Orange and Glen Ridge sites are located in north central
New Jersey and are influenced by a moderate climate. Table 1-3 provides
the monthly climatological data for temperature, precipitation, wind
direction and wind speed at the Newark, New Jersey, Weather Service Office
Airport Meteorological Station averaged over a 30-year period. The sta-
tion, located at Newark International Airport, is about 8 miles from the
si tes.
Based on the annual evapotranspiration rate of about 25 inches, net preci-
pitation is about 16.5 inches. Periodically, the area will receive heavy
periods of precipitation resulting in considerable runoff.
1.2.4 TOPOGRAPHY
The topography of the Montclair/West Orange and Glen Ridge sites is govern-
ed by the Triassic lowlands of the Piedmont Physiographic Province and the
northeast-southwest trending Watchung Mountains, which rise 600 feet above
sea level and approximately 200 feet above the Triassic lowlands.
1-21
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TABLE 1-2
PROPERTY TAX ANALYSIS BASED ON PROPERTIES THAT
PETITIONED AND RECEIVED TAX RELIEF IN 1984 DUE TO
THE RADIOLOGICAL CONTAMINATION IN THEIR COMMUNITIES
Montclair
West Orange
Glen Ridge*
Average Tax Relief
Percent Reduction
(Over 2-year Period)
35%
20%
35%
Tax Rate
(1984 Essex Co.
Ratables) 8.81%
Average Assessed
Value of Houses
that Petitioned
for Tax Relief** $34,700
Number of Properties
Receiving Tax Relief 32
Average Reduction in
Property Taxes to
Petitioners $1,070
Total Loss in Tax
Revenues to the Town $34,240
3.19%
$69,300
8
$774,
$6,192
4.01%
$74,400
22
$-597
$13,134
*Petitioners granted tax relief by Essex County, but not recognized
by Town of Glen Ridge. Basis for granting petition currently in
litigation in the State courts.
**Based on Essex County Board of Taxation current assessed value of houses,
(6H6/9)
1-22
-------
Month
TABLE 1-3
CLIMATOLOGIC DATA
New Jersey Weather Service Office
Newark International Airport, Newark, NJ
30 Year Average
Prevailing Average Wind
i i v. v u i i i u*j nv*-iu^t.niiivi
Temperature( F) Precipitation (in.) Wind Direction Speed (mph)
January
February
March
Apri 1
May
June
July
August
September
October
November
December
Annual
31.4
32.6
40.6
51.7
61.9
71.4
76.4
74.6
67.8
57.5
46.2
34.5
53.9 (Avg)
2.91
2.95
3.93
3.44
3.60
2.99
4.03
4.27
3.44
2.82
3.61
3.46
41.45 (Total)
NE
NW
NW
WNW
SW
SW
SW
SW
SW
SW
SW
SW
SW (pre-
vailing)
11.2
11.6
12.1
11.4
10.0
9.3
8.8
8.7
9.0
9.3
10.1
10.7
10.2(Avg)
(4H9/3)
1-23
-------
Montclair and West Orange are located in the eastern foothills of the First
Watchung Mountain. The general slope of both sites is southeast, with
actual terrain in Montclair sloping towards Nishuane Road and Fremont
Street. The West Orange site slopes steeply towards Wigwam Brook.
The Glen Ridge site is located approximately 7,200 feet east-southeast of
the First Watchung Mountain. The general si ope.of the Glen Ridge site is
southeast, but the terrain slopes toward an old stream bed that ran from
the corner of Sonmer Avenue and Hawthorne Avenue through the southeast
corner of Barrows Field.
Considerable terracing and filling has occurred on all three sites.
1.2.5 SURFACE WATERS
There is no surface water flowing through either the Montclair or Glen
Ridge sites. Surface drainage from each site flows in a southeasterly
direction and drains into municipal storm sewers that carry it djrectly to
Wigwam Brook. This brook originates in Montclair and passes through the
West Orange site. After passing through Orange and East Orange, it dis-
charges into the Second River in Watsessing Park in 81 cornfield. The point
of discharge for the Second River is the Passaic River near Branch Brook
Park in Newark.
1.2.6 GEOLOGY
The underlying bedrock of the Glen Ridge, Montclair and West Orange study
areas is of the Piedmont Plateau of the Newark Group's Brunswick Formation
(Figure 1-9). The Brunswick Formation is a nonmarine intermontane basin
deposit at least 6,000 feet thick with a general northeast-southwest strike
and a 10° dip northwestward. It consists predominantly of reddish brown
siltstones interbedded with red sandstone. Lower portions of the Brunswick
contain isolated deposites of conglomerate. The Brunswick is considered an
important source of groundwater for the surrounding area.
1-24
-------
LEGEND
Dtk Skunnemunk
Ob 9«ll»ol«»
Kaitout*
Sal Otcktr A Longwood
So.p Sreenpond ft Lonjwood
€h Hardy ttan
•Cl L*ith»lllt
Pcb Prfcambrlon
Trb Sruniwlck
Tr» Stockton
Trbi Boiolt
Trdb Oloboit
Trl uockatong
Trc Border Conglomtratt
Kmr Rarltan-Maqothy
GLEN RIDGE,
MONTCLAIR.
WEST ORANGE
STUDY AREA
USGS/ORANGE
7'30' QUAD
(Miles)
4,0 4
Source: WATER QUALITY MANAGEMENT PLAN
OlvitlON .1 WAIfl IISOUICIS
1.1 llpl'lllll l| Illirllllllll fllllllill
Report 208
STUOY AREA
DRAINAGE BASM
CDM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-9
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
RADIUM SITES
BEDROCK GEOLOGY OF THE
NORTHEAST NEW JERSEY AREA
1-25
-------
Extensive field surveys of exposed Brunswick section during a National
Uranium Resource Evaluation (MURE) study revealed no indication of
anomalous radioactivity. The study concluded that the Brunswick was a
geologically unfavorable uranium host.
Beneath the Brunswick Formation in descending stratigraphic position are
the Lockatong and Stockton formations (Figure 1-10). The formations are at
least 1,000 feet thick in the study areas and lie a minimum of 6,000 feet
below the surface. Major exposures of these formations outcrop east of
Essex County in the New York and New Jersey Palisades and fault blocks in
western and central New Jersey. Although these formations are favorable
uranium hosts, their distance from the sites is sufficient to negate any
possible influence on background levels of radioactivity in the study area.
The sediment overburden consists primarily of unconsolidated deposits of
Pleistocene glaciers and post-glacial meltwaters. Figure 1-11 indicates
that the Montclair and West Orange sites are situated on a ground moraine.
This deposit is composed of till, a heterogeneous unstratified sediment
deposited directly by the glacier. The Glen Ridge site is underlain by
stratified drift, deposited by post-glacial meltwater streams. These
deposits are organized into beds of similar sediment size (stratified).
Units of sand, silty sand and sand and gravel typify the site.
Soil boring logs confirm the stratified nature of Glen Ridge sediments but
indicate a rough stratification of sediments at the Montclair site.
Overburden characteristics in Montclair may be closer to those described
for stratified drift. Boring logs place the depth to bedrock between 28
and 84 feet at the Glen Ridge site and between 18 and 20 feet at the
Montclair site. Depth to bedrock at the West Orange site is estimated to
be less than 20 feet.
1.2.7 GROUNDWATER
The Brunswick Formation is the main source of groundwater in Essex County.
Water is stored and transmitted through an interconnected system of
secondary joints and fractures. This type of porosity characteristically
1-26
-------
USGS/ORANGE
7'30" QUAD
LEGEND:
READING PRONG
FAVORABLE FOR ANATECTIC AND ALLOGANIC URANIUM DEPOSITS
STOCKTON FORMATION
FAVORABLE FOR NON-CHANNEL CONTROLLED, PENECONCORDANI
SANDSTONE URANIUM DEPOSITS
ILOCKATONG FORMATION
'FAVORABLE FOR ORGANIC-RICH, TERRESTIAL URANIUM DEPOSITS
SCALE 1"=16 miles
COM
environmental engineers, scientists.
planners A management consultants
FIGURE: 1-10
MONTCLAIR/WEST ORANGE AND 6LEN RID6E
RADIUM SITES
AREAS FAVORABLE FOR
URANIUM DEPOSITS
1-27
-------
'7 v / /~i
\ \ JL f tr
Source: Water Quality Management Plan Dlv. of Water Resources
N.J. Dept. of Environmental Protection
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: I-II
nONTCLAIR/WEST ORANGE AND 6LEN RIDGE
RADIUM SITES
SURFICIAL GEOLOGY OF
ESSEX COUNTY, N.J.
1-28
-------
imparts confined or semiconfined conditions to the Brunswick aquifer since
waters move only along open fracture planes. Major fracture systems in the
study area run transverse to bedding planes (nearly vertical) and trend
northeast-southwest. Groundwater will tend to move more readily in this
direction as recorded in pump tests conducted on Essex County wells. Pro-
duction wells in Essex County are completed to depths between 300 and 400
feet, indicating that fracture systems remain permeable to at least these
depths. A previous EPA study determined that groundwater is moving to the
southeast in the bedrock aquifer. This direction is transverse to the
strike of major fracture systems within the aquifer and could in effect
impede the vertical migration of contaminants.
The unconsolidated overburden aquifer is not extensively utilized for
domestic or industrial supplies. Monitoring wells completed in this unit
indicate an east-southeasterly direction of flow. The primary source of
recharge for the area is along the southeastern face of the first Watchung
Mountain, including the study area. Watsessing Creek and Second River may
constitute areas of discharge for the overburden aquifer sVstem.
•
1.2.8 DRINKING WATER
Surface water constitutes the major portion of the supplies for the towns
of Montclair, West Orange and Glen Ridge; However, deep aquifer wells are
a significant supplementary source. The only deep wells near the study
area used for drinking water are to the north and northeast of the sites,
upgradient of the inferred groundwater flow. Radiological testing of
samples from the water systems serving the three sites and surrounding com-
munities shows that gross alpha activity in the drinking water supplies is
near background levels.
1-29
-------
1.3 EXTENT OF CONTAMINATION
This section provides an assessment of the problem at the Montclair/West
Orange and Glen Ridge Radium sites, including a description of the nature
of the problem and the extent of the contamination as evidenced by existing
data.
1.3.1 NATURE OF CONTAMINATION
Elevated radiation exposures that approach and sometimes exceed the
radiological standards for the general public have been identified in the
Montclair/West Orange and Glen Ridge study areas. The source of the con-
tamination is known to be radium-contaminated soil which has been deposited
as fill material throughout the study areas.
Radium and the other elements of the uranium-238 decay series (Figure 1-12)
occur naturally throughout the earth's crust. Naturally occurring deposits
contain the members of the decay series in definite proportions, known as
"secular equilibrium." An unusually high concentration of-these isotopes
has been found in the soil from the sites indicating that the deposit is
man-made, possibly resulting from activities such as radium processing.
Solubilities of radium and thorium salts in water range from slightly
soluble to very soluble depending on soil temperature and pH and on the
anions present. In the slightly acid soils of the Radium Sites, thorium
will generally be more soluble than radium. Their gaseous decay product,
radon, is relatively more water soluble than salts of either metal. The
migration of the three elements through soil is only limited by the avail-
ability of water to act as a carrier. Radon, an unreactive gas, will read-
ily diffuse from its substrate either to the air or to pore spaces within
the soil. Therefore, pathways of exposure at the Montcl air/West Orange and
Glen Ridge radium sites include air, soil, groundwater and surface water.
The contaminated soil is causing elevated radiation exposures in the two
following ways:
1-30
-------
At. El.
No
U
92
Po
91
Th
90
Ac
89
"•u
4.51 x 10*
"•u
^8o^°5
»«Po '*/.
a /
B/^
/
"*Th
34,
I
Ro:
88
F,
87
Rn
86
At
85
Po
84
B>
83
Po
82
Tl
81
DOT*
tlfl min /»
"*P,
7^'
a
z«Ro
,£20 r«n
a
Z»Rn
3.825 doyi
3.05
3
mm
a
s
26.8mm
"'At
13
z"Bi
a
'
19. 7 mm
tlOy
1.32
a
mm
16x10-*
22
a
/
1384 Ooys
««B. 'I
SO' doyt
5^
(Oftpfc
0 StoDW
IO.T '
4J min
Source: Sawyer, C.N. and McCarty, P.L.
FUNDAMENTALS OF CHEMISTRY FOR ENVIRONMENTAL ENGINEERS
McGraw-Hill, N.Y. 1978.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-12
MONrCLAIR/WEST ORANGE AND GLEN RIDGE
RADIUM SITES
URANIUM-238 DECAY SERIES
1-31
-------
(1) External exposure from gamma radiation, and
(2) Internal exposure by inhalation of alpha particle emitters (radon
and radon progeny).
A third exposure, ingestion of contaminated soil, water or vegetation, was
determined not to pose a major risk to public health, but it was recom-
mended that gardens not be located where contamination exists near the soil
surface (CDC memo to NJDEP, June 12, 1984, and EPA memo, June 4, 1984).
Units of Measure
Radionuclides. The concentration of a radionuclide in the soil is measured
in terms of its activity per weight of dry soil. The activity units used
are picocuries per gram of dry soil (pCi/g). The concentration of an
isotope in water is measured in picocuries per liter (pCi/1).
Gamma Radiation. Radiation exposure in air is measured in roentgens (R),
milliroentgens (mR) or microroentgens (uR). For human health purposes,
doses of radiation are measured in rems, millirems (mrem), or microrems
(urem). This unit is based on the amount of ionizing energy in the radia-
tion. For gamma radiation, 1 roentgen is approximately equal to 1 rem.
Therefore, a radiation rate of 1 uR/hr on a gamma survey instrument, cali-
brated to the specific energy field of the gamma source at the site, is
approximate to a dose of 1 urem/hr.
Alpha Emission. Radium-226 decays to the gas radon-222, which, in turn,
decays to short-lived particles called progeny. From a public health
viewpoint, these radioactive particles are chiefly important as alpha
emitters. Alpha particles are important from a biological standpoint
because they are strongly ionizing and, although effective over only a very
1-32
-------
short distance, impart the greatest damage to tissue. Radon progeny become
attached to participates suspended in the air, which can be inhaled and
trapped in the bronchial passageways.
Radon progeny exposure is measured in terms of working levels (WL). This
unit is employed because of the difficulties inherent in characterizing the
complex mixtures of radon progeny present under different circumstances.
One working level is equivalent to 100 pCi/1 of radon-222 in 100 percent
secular equilibrium with its progeny.
1.3.2 REMEDIAL INVESTIGATION PROTCOL
The primary purpose of the remedial investigation was the identification of
properties and residences to be targeted for remediation. Detailed
methodology and results of the RI are presented in the Report of the Reme-
dial Investigation of the Montclair/West Orange and Glen Ridge Radium Sites
(August, 1985). The planned approach to the investigation is described in
the Work Plan (March 1985).
The protocol for selecting properties for investigation is summarized as
follows:
(1) Compare site boundaries with the map of the results of the aerial
gamma survey to confirm site boundaries.
(2) Perform surface gamma surveys on all onsite properties to define
the areal extent of contamination.
(3) Evaluate results of radon progeny sampling to identify residences
with radon progeny concentrations above background levels.
(4) Perform indoor gamma surveys on residences with radon progeny
levels above background and on residences where surface gamma
radiation anomalies were found near or adjacent to residences.
1-33
-------
(5) Perform subsurface investigations to determine depth and thickness
of contaminated layers, and the nature and radionuclide activities
of the contaminated material.
The criteria for the inclusion or exclusion of properties from the remedia-
tion program are given in Table 1-4.
1.3.3 AERIAL GAMMA SURVEY
In 1981, EPA, through the Department of Energy, contracted the firm of EG&G
Energy Measurements to conduct an aerial gamma radiation survey of the area
surrounding the former U.S. Radium processing plant in Orange. The re-
sulting map is reproduced in Figure 1-13, with selected isopleths (lines of
equal gamma activity) emphasized. Uncertainty in the positioning of the
isopleths is +/- 100 feet, based on the precision of the USGS topographic
base map, the precision of the surveying technique employed, and precision
of the reproduction.
While aerial surveys provide an estimate of ground gamma activity ground-
truthing by surface gamma surveys are necessary to provide a more accurate
estimate of surface gamma activities. Two isopleths have been emphasized
for each site on Figure 1-13. The inner ring (E) represents gamma acti-
vities of 9.5 uR/hr at 3 feet above the ground. The gamma activities of
the areas within these isopleths are definitely elevated with respect to
background gamma levels for the area and should be investigated.
The outer isopleths (D) represent gamma activities of 8.5 uR/hr. These
values are near enough to background to be attributed to shine (radiation
energy at a distance from the source) from contaminated areas. However, to
be conservative, all properties within the D-isopleths should also be in-
vestigated. Table 1-5 shows the additional properties within the D-isopleth
in all three sites that require groundtruthing. If any property at the
edge of the D-isopleth is shown to have a gamma anomaly, the investigation
should extend to a minimum of 100 feet beyond the D-isopleth boundary to
account for the documented precision of the isopleth. Figures 1-14, 1-15
and 1-16 show the isopleths applied to maps of the individual sites. The
1-34
-------
TABLE 1- 4
CRITERIA FOR INCLUSION OR EXCLUSION OF PROPERTIES
FROM REMEDIATION PROGRAM
Definite Inclusion
Any property where the indoor or outdoor gamma survey performed by any surveyor
identified an anomaly. Anomaly is defined as a gamma radiation reading above
background level s.
Definite Exclusion
Any property where the radon progeny working level (WL) value was less than
0.007 and the outdoor survey performed by the RI team did not identify any
anomaly.
Tentative Exclusion
(a) Any property that is outside of the D-isopleth of the aerial gamma
survey.
(b) Any property where the radon progeny WL sample was less than 0.007 and
the outdoor gamma survey performed by the RI team or the FIT did not
identify any anomaly. This category is contingent on the understanding
that several surface gamma surveys performed by the FIT did not detect
all elevated gamma anomalies due to the use of a radiation detector
limited in its detection of low intensity gamma anomalies and lack of
grid point data collection methodology.
Tentative Inclusion
(a) Any property where the radon progeny WL is greater than or equal to
0.007.
(b) Any property that is inside the D-isopleth on the aerial gamma survey and
did not have the minimum investigation as defined in the remedial
investigation protocol.
(6H4/16)
1-35
-------
COM
environmental engineer*,
planners A management contuHants
FIGURE: 1-13
MONTCLAIR/WEST ORAN6E AND 6LEN RID6E
RADIUM SITES
RESULTS OF AERIAL GAMMA SURVEY
1-36
-------
TABLE 1-5
ADDITIONAL PROPERTIES FOR INVESTIGATION
IDENTIFIED FROM AERIAL SURVEY
Montclair West Orange Glen Ridge Total
Properties outside of RI
but inside "D" isopleth 37 8* 14 59
(> 8.5 uR/hr)
*includes portions of grounds at 2 apartment complexes
(6H6/9)
1-37
-------
LEGEND:
^•^•m SITE BOUNDARY
_-.__ E-ISOPLETH (9.5>jR/hr)
,D-ISOPLETH (8.5>iR/hr)
EXTENSION OF SITE BOUNDARY
BASED ON E-ISOPLETH
iEXTENSION OF SITE BOUNDARY
BASED ON D-ISOPLETH
SCflLE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-14
nONTCLAIR/WEST ORANGE AND 6LEN RID6E
RADIUM SITES
AERIAL GAMMA ISOPLETHS-
MONTCLAIR SITE
1-38
-------
SITE BOUNDARY
D-ISOPLETH (S.BjiR/hr
EXTENSION OF SITE BOUNDARY
BASED ON D-ISOPLETH
SCflLE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-15
MONrCL AIR/WEST ORANGE AND GLEN RIDGE
RADIUM SITES
AERIAL GAMMA ISOPLETHS-
WEST ORANGE SITE
1-39
-------
SITE BOUNDARY
__«. E-ISOPLETH (9.5>iR/hr)
D-ISOPLETH (8.5^R/hr)
EXTENSION OF SITE BOUNDARY
BASED ON D-ISOPLETH
COM
environmental engineers, scientists.
planners & management consultants
FIGURE: 1-16
nONTCLAIR/WEST ORANGE AND 6LEN RI06E
RADIUM SITES
AERIAL GAMMA ISOPLETHS-
GLEN RiDGE SITE
1-40
-------
outermost boundary indicated on each map represents the maximum extension
of the study area boundaries to account for the +/-100 feet precision of
the isopleth.
1.3.4 OUTDOOR SURFACE GAMMA CONTAMINATION
Surface level and waist level scans and surveys were made at 544 properties
across the three sites. Offsite exposure measurements were made to deter-
mine the background gamma exposure rate for the area. The mean background
exposure rate measured was 8.6 uR/hr with acceptable values ranging about
the mean to a maximum of 11.2 uR/hr. Properties with any gamma reading
greater than 11.2 uR/hr were considered to have "anomalies". Results of
the outdoor surface gamma surveys are summarized in Table 1-6.
Gamma emissions are attenuated by soil cover and other materials interposed
between source and detector. Therefore, surface gamma surveys alone are
not adequate to define the extent or the degree of contamination. Anoma-
lies of low intensity could result from small amounts of material at the
surface or from larger quantities below the surface. Highly contaminated
soil with a few feet of clean cover could show only background levels of
radiation at the surface. However, surface surveys are a useful tool for
delineating areas where contamination lies near the surface.
Montclair
Surface gamma anomalies in properties and streets affect an estimated area
of approximately 236,000 square feet (see map attachments). The areas of
heaviest suspected and confirmed contamination center along Nishuane Road
in Montclair and between Franklin Avenue and Fremont Street. The area
corresponds to a former stream bed believed to have been used as a dump
site. Surface gamma anomalies from 100 to 500 uR/hr were generally con-
fined to these areas. The remaining parts of the site contained spotty
clusters of surface gamma anomalies mostly between 10 to 15 uR/hr. The
properties to the northeast of 92 High Street are free of surface gamma
anomal ies.
1-41
-------
TABLE 1-6
SUMMARY OF OUTDOOR SURFACE GAMMA SURVEY RESULTS
Number of Properties
within Study Area
Number of Properties
Surveyed
Number of Properties
with Anomalies*
Exposure Rate Range (uR/hr)
Highest Reading
Lowest Reading
Montclair
296
272
136
500+
5
Uest Orange
63
60
24
250
5
Glen Ridge
256
212
60
500+
5
Total s
615
544
220
Estimated Area Affected
(sq ft) 236,000
Remaining to Survey**
Properties within RI 20
Boundary
Properties outside RI 37
Boundary but Inside
D-isopleth on Aerial Gamma
Survey
35,500 182,000 453,500
31
14
59
* Properties with any reading above 11.2 uR/hr, the estimated upper range for
outdoor surface gamma background exposure rate, were considered to have
anomalies.
**The estimate of additional properties to perform outdoor surveys was based on
inclusion of only those properties which were not surveyed by the RI or FIT.
All other properties not accounted for in this table were definitively or
tentatively excluded based on the inclusion/exclusion criteria given in
Table 1-1.
(6H4/16)
1-42
-------
West Orange
Surface gamma anomalies in West Orange affect an estimated 35,500 square
feet (see map attachments). The surface gamma anomalies are most prevalent
at the north side of the dead end of Alan Street and the southeast corner
of the intersection of Alan Street and James Court. This area was formerly
an ash and bottle dump until the mid-1930's, when Wigwam Brook was diverted
and channelized and the terrain was modified to prepare for residential
development. It is suspected that radium-contaminated material along or
under the original stream bed may have been covered when it was channel-
ized. Surface gamma anomalies are distributed along the length of Alan
Street, down to the brook, where gamma activities up to 250 uR/hr were
detected. Several less intense anomalies are distributed along the present
course of the brook and there is one isolated anomaly beneath a residential
garage.
Glen Ridge
Surface gamma anomalies in Glen Ridge affect an estimated 182,000 square
feet (see map attachments). The areas of heaviest suspected and confirmed
contamination occur in the back of the residences on Carteret Street north
of Barrows Field and at the Barrows Field Ball Park itself. This area was
formerly a depression used as an ash and bottle dump and filled in the
1930's. Surface gamma anomalies up to 500 uR/hr were prevalent in this
area. Surface gamma anomalies were also distributed along parts of
Carteret Street, the entire length of Lorraine Street, and discrete areas
throughout the site.
The locations of three former sand pits (two in the area of Sommer Avenue,
Hawthorne Avenue and Glen Park Road and the third in Glen Ridge Municipal
Yard), showed no evidence of outdoor surface gamma anomalies. Addition-
ally, the perimeter properties of the site, in particular Ridgewood Avenue,
Madison (one exception) Street and Fair Street, are free of surface gamma
anomalies.
1-43
-------
1.3.5 RADON CONTAMINATION
Both NJDEP and EPA conducted indoor air sampling for radon gas and radon
progeny inside residences within the site boundaries. Residences were
grouped into tiers based on ranges of radon progeny working levels estab-
lished by CDC in December 1983. The ranges for the tiers are shown in
Table 1-7.
Tier D is based on the range of values deemed to be within acceptable
health standards for radon progeny levels. During the remedial investi-
gation, Tier D was divided into two statistically derived subtiers to
differentiate radon progeny levels at or below background from those above
background. Off-site radon progeny measurements showed a mean background
value of 0.002 WL, with acceptable background values ranging about the mean
to a maximum of 0.007 WL. This 0.007 WL value was used during the remedial
investigation as an environmental indicator of nearby contamination. Re-
sults are summarized in Table 1-7.
Residences are labelled with their radon progeny tiers on the attached
maps. For the most part, elevated radon progeny levels were found in resi-
dences situated over or near areas with elevated surface gamma readings.
There are a significant number of residences, however, with elevated radon
progeny levels where the nearest surface gamma anomaly is further than 20
feet away. All of these residences are in Tier D+, which is a category
based on indications of environmental contamination rather than health
hazards. The elevated readings could result from natural variations be-
tween air samples taken for radon progeny analysis or from radium-
contaminated material buried too deeply for detection at the ground sur-
face. Such buried material could be detected by indoor gamma surveys along
the floors and walls of the basements. Several houses are situated over
low-intensity gamma anomalies, yet are at Tier D or background levels.
This is a credible relationship as radon progeny concentration depends not
only on the proximity of a source but also on the availability of passages
into the residence and the air exchange rate. A change in either condition
could increase the radon progeny level.
1-44
-------
TABLE 1-7
SUMMARY OF RADON PROGENY SAMPLING RESULTS*
Montclair West Orange Glen Ridge Totals
Number of Residences
within study Area
Number of Residences
288
62
253
603
Sampled
Tier A: > 0.5 WL
Tier B: > 0.1 WL to 0.5 WL
Tier C: > 0.02 WL to 0.1 WL
Tier D+ _> 0.007 WL to 0.02 WL
Tier D: < 0.007 WL
Remaining to Sample:
Residences Within RI Boundary
Residences Outside RI
Boundary but inside
D-isopleth on Aerial Gamma
Survey
190
2
11
13
43
121
98
37
54
0
2
2
9
41
8
8
212
0
8
7
35
162
41
14
456
2
20
23
87
324
147
59
*The radon progeny values were selected from the grab and quarterly RPISU
(radon progeny intergrated sampling unit) monitoring data. For those houses
that had more than one sample, the highest basement radon progeny value was
used to classify the home for the purposes of the investigation protocol.
EPA Standards 40 CFR 192.12 applicable to the general population in any
occupied or habitable building state that in no case shall radon progeny
exceed 0.03 WL, and a reasonable effort should be made to achieve a
concentration that averages 0.02 WL annually.
(6H6/9)
1-45
-------
1.3.6 INDOOR GAMMA CONTAMINATION
Gamma radiation surveys were performed in the basements and living areas of
homes classified as Tier A, B or C for radon progeny concentrations. In
addition, basement level surveys were performed in homes grouped in Tier D+
and homes where outdoor surface gamma surveys indicated the possibility of
contaminated materials adjacent to or beneath the foundation of the house.
Surveys of offsite properties were used to calculate a maximum value for
background gamma intensity. The mean indoor background exposure rate was
9.2 uR/hr, with background values ranging to a maximum of 10.6 uR/hr.
Residences with average readings along the basement wall or across the
floor that were greater than this maximum background value were considered
contaminated. Results are summarized in Table 1-8.
1.3.7 SUBSURFACE CONTAMINATION
Determining the areal extent of contamination, as was done by surface gamma
surveys, does not characterize the extent of contamination sufficiently to
allow evaluation of remedial alternatives. Subsurface investigations were
performed at selected surface gamma anomalies to determine the depth of
contamination, the concentrations of radionuclides and the distribution of
natural and fill materials in the contaminated areas. The subsurface
tests performed were downhole logging of gamma activity and radiochemical
analysis of split-spoon samples. A parallel investigation was performed
off site to determine normal values for uncontaminated materials.
Downhole Gamma-Logging
Gamma activities were logged at 6-inch intervals along the depth of bore-
holes drilled at numerous locations in areas believed to be contaminated.
This data was used to estimate the depth and thickness of layers of con-
taminated material by assessing the relative intensity of gamma radiation
at these locations. The results are summarized in Table 1-9.
1-46
-------
TABLE 1-8
SUMMARY OF INDOOR GAMMA SURVEY RESULTS
Montclair West Orange Glen Ridge Total
Number of Residences in Study
Area
Number of Residences
Surveyed
Number of Residences
with Anomalies*
Number at Background
288
69
59
10
62
13
5
8
253
49
26
22
603
131
90
41
Exposure Rate Range (uR/hr)
Highest Reading
Lowest Reading
186
8
Number of Residences to Survey** 148
357
6
28
266
7
75
251
* Residences with average gamma readings along the basement wall or across the
floor greater than 10.6 uR/hr, the estimated upper range for indoor gamma
background, were considered to have anomalies.
**Number of residences to survey is based upon RI investigation protocol, i.e.,
residences with radon progeny values >^ 0.007 WL or with outdoor surface gamma
readings > 10.6 uR/hr.
(6H4/16)
1-47
-------
TABLE 1-9
SUMMARY OF SUBSURFACE GAMMA-LOGGING INVESTIGATIONS
West Orange
Glen Ridge Montclair Total
Total Boreholes Gamma Logged
RIM Boreholes
FIT Boreholes
Maximum Depth of Contamination
61
13
48
9.5 ft
74
15
59
16 ft
198
12
186
12.5 ft
333
40
293
Based on Borehole Gamma-Logging
Average Thickness of
Contaminated Layer Based on
FIT Borehole Gamma-Logging
4.7 ft
5.2 ft
4.1 ft
(6H4/16)
1-48
-------
The maximum gamma activity readings in counts per minute (cpm) in all three
sites were usually found between 1 and 5 feet below the surface, with
decreasing gamma activity above and below those levels. The thickness of
the layer of maximum contamination varies widely throughout the sites, from
a few inches to several feet.
Montclair. In Montclair, near Harrison Avenue, the maximum contamination
is at a depth of 1 foot, with total contaminated soil ranging from the
surface to a depth of 4 feet. Along Franklin, the maximum is at 2-1/2 feet
depth, and the range extends from 1 to 5 feet below the surface. On the
corner of Nishuane and Franklin, the maximum contamination is at 3-1/2 feet
with the range of contaminated soil going from 1 to 10 feet.
West Orange. West Orange presents a different scenario. There are some
spots of contamination along the parkways on either side of the west end of
Alan Street where maximum contamination is at 1 foot depth and the range of
contaminated soil extends from the surface to 3 feet depth. Further east
on Alan Street the center of the contaminated layer moves.from 2 feet down
to 4 feet below the surface at the end of the street near the brook. In
the front yards of James Court, the maximum contamination is found between
3-1/2 and 4-1/2 feet. The contamination seems to follow the original slope
of the land, dipping towards the brook.
The subsurface investigation in West Orange along the channelized part of
Wigwam Brook and the piped tributary did not show evidence of contamination
above the 15 pCi/gm subsurface soil standard extrapolated from downhole
gamma activity. However, five of seven boreholes along Wigwam Brook had
gamma activity above background. The holes with elevated activity are
along the portion of the present channel which coincides with the original
course of Wigwam Brook. The two holes near the channel that are at back-
ground radiation levels are along the new portions of the brook, away from
the brook's former course.
Glen Ridge. In Glen Ridge the depth of maximum contamination varies across
the site. At the west end of Barrows Field, near Hawthorne Avenue, the
maximum contamination is at a depth of 1 foot, with contaminated soil rang
1-49
-------
ing from the surface to a depth of 11 feet. Near the center of the field,
contamination extends from the surface down to 16 feet. At the east end,
near the intersection of Carteret Street and Midland Avenue, the maximum is
at 2 feet, with the contamination ranging from 2 to 8 feet below the sur-
face. Limited borehole gamma-logging in the areas of the three former sand
pits did not show any evidence of contamination.
Analysis of Split-Spoon Samples
Split-spoon samples were taken in the areas of highest contamination. Re-
sults of the analyses of split-spoon samples taken on site are summarized
in Table 1-10. Results of analyses made on samples taken for background
evaluation are in Table 1-11.
Radionuclide concentrations vary widely across the sites, as do the rela-
tive ratios of radium, thorium and uranium. The average ratio of thorium
to radium, however, is close to unity and the majority of the. samples pre-
sent ratios near unity. Concentrations of uranium in the samples taken .
were higher than background but always lower than either thorium or radium.
Subsurface Strata
Analysis of the borehole and well geologic profiles indicate that the sites
contain three general types of strata: an upper organic soil horizon, a
middle layer of fill material, and a layer of dark reddish brown fine or
silty sand and gravel indicative of native material, either from the
Pleistocene glacial deposits, or from the fractured shale bedrock of the
Brunswick Formation.
It is estimated that the most heavily contaminated materials, the fill
(mostly ash and cinder) and the "sandy" fill (fill mixed with sands, silts
and clays), together make up 45 percent of the total contaminated volume.
Table 1-10 demonstrates a great difference in radionuclide concentrations
between topsoil, fill and the underlying native materials. Table 1-12
shows the mean thicknesses of the strata.
1-50
-------
TABLE 1-10
RADIOCHEMICAL ANALYSIS OF SPLIT-SPOON SAMPLES
Sample Type
No. of Samples
Ra-226
(pCi/gm)
Th-230
(pCi/gm)
U-234
(pCI/gm)
Organic Soil
Fill
"Sandy" Fill
Native Material
5
10
13
21
107
172
876
2.9
123
193
891
2.5
8.2
37
90
1.6
(6H6/9)
1-51
-------
TABLE 1-11
RADIOCHEMICAL ANALYSIS OF BACKGROUND GEOLOGIC STRATA
i
l_n
t-0
Ra-226 (pCi/g)
Th-230 (pCi/g)
U-234 (pCi/g)
Surface Soil
Range
Overburden
Range
Native Shale
Range
1.64
(0.92-2.74)
1.64
(1.06-2.41)
2.13
(1.10-4.35)
0.62
(0.27-1.79)
0.18
(0.09-0.28)
0.61
(0.05-3.27)
0.25
(O.*08-1.00)
0.19
(0.05-0.33)
0.18
(0.01-0.53)
(RW6/43)
-------
TABLE 1-12
SUMMARY OF SPLIT SPOON SOIL ANALYSIS SHOWING AVERAGE THICKNESS OF
CONTAMINATED SOIL MATRIX AT EACH SITE
(FEET)
Organic Fill "Sandy "Fill
Native Materials
01
OJ
Total Depth
of Contamination
Monte lair
West Orange
Glen Ridge
0.6
0.8
0.4
1.1
1.6
3.2
1.7
0.1
1.5
4.7
2.7
3.4
8.1
5.2
8.5
(RW6/42)
-------
1.3.8 SURFACE WATER AND GROUNDWATER CONTAMINATION
Sediment samples taken from storm sewers at each site were analyzed for
radium-226, thorium-230 and uranium-234. Results are presented in Table
1-13. All sample values are within background ranges determined from up-
gradient sources with the exception of samples taken from catch basins at
the corner of Nishuane Road and Franklin Avenue in Montclair, and the
corner of Lorraine Street and Midland Avenue in Glen Ridge. The elevated
concentrations in these samples suggest that contamination from surface
runoff may reach Wigwam Brook.
There is no surface water flowing through either the Montclair or Glen
Ridge site. Two water samples taken from Wigwam Brook, within the West
Orange site, showed less than 1.0 pCi/1 of radium-226, the detection limit
of the analysis.
Groundwater samples from monitoring wells installed at Montclair and Glen
Ridge are analyzed quarterly for gross- alpha activity, gross beta activity,
radium-226 and vanadium. Locations of deep and shallow wells are shown on
the map attachments. Results of the three sampling rounds completed are
presented in Table 1-14. These results indicate that elevated levels of
gross alpha and radium-226 activities exist in five wells located in the
unconsolidated shallow aquifer (M-S-1, M-S-3, M-S-4, GR-S-1, and GR-S-2).
In the consolidated rock aquifer the values are at background levels. Well
GR-S-2, which shows elevated activities, is upgradient from the D-isopleth
used as a boundary of contamination. The well showed evidence of fill
material in cuttings; however, the area immediately around the well has not
been radiologically characterized. A potential for downward migration of
contaminants from the unconsolidated to the rock aquifer does exist, but
there are at present too few data points to estimate the degree of poten-
tial .
1-54
-------
TABLE 1-13
RADIOCHEMICAL ANALYSIS OF SEDIMENT SAMPLES
Sample Location
Ra-226 (pCi/gm) Th-230 (pCi/gm)
U-234 (pCi/gm)
Montclalr
Graham Ct.
(upgradient)*
Amelia St.
Nishuane Rd.
West Orange
Susan Ct.
(upgradient)*
Alan St.
Mississippi Ave.
Glen Ridge
Ridgewood Ave.
(upgradient)*
Carteret St.
Midland Ave.
1.02 +/- 0.48
2.03 +/- 0.75
9.74 +/- 1.02
<2.5
<1.2
1.29 +/- 0.59
1.00 +/- 0.55
<0.54
1.50 +/- 0.77
0.25 +/- 0.02
1.95 +/- 0.09
5.91 +/- 0.22
2.07 +/- 0.13
1.26 +/- 0.11
1.20 +/- 0.17
1.08 +/- 0.09
1.31 +/- 0.09
10.6 +/- 0.3
<0.25
0.20 +/- 0.12
1.2 +/- 0.4
1.0 +/- 0.4
0.60 +/- 0.35
0.33 +/- 0.10
0.44 +/- 0.12
1.0 +/- 0.4
<0.70
*Background sediment sample locations upgradient of the site.
(6H6/9)
1-55
-------
TABLE 1-14
SAMPLE RESULTS - HONTCIAIR/GLEN RIDGE GRONMftTER MONITORING RESULTS
II 1st Quarter Results || 2nd Quarter Results II 3rd Quarter Results
II 8/27/84-8790/84 II 12/4/84 - 12/5/84 II 3/6/85- 3/8/85
II II II
Hell | (Gross Alpha (Gross Beta (Ra-226 ((Gross Alpha (Gross Beta |Ra-22t (Vanadiial (Gross Alpha (Gross Beta (Ra-226 IVanadiw
Nuatoer ||pCi/l 2SO IpCi/l 2SD pCi/1 2SO llpCi/1 2SO IpCi/l 2SO IpCi/l 2SD «9/l llpCi/1 2SD IpCi/l 2SD IpCi/l 2SD «yi
M-S-1 ||14.( 5.4 120.4 3.6
H-R-1 || 0.2 1.2 | 6.5 2.6
H-S-2 1(10.6 3.9 121.0 3.6
M-R-2 || 7.2 4.1 | 5.5 2.9
H-S-3 1(26.5 B.O 137.2 6.4
H-R-3 (1 5.2 3.0 I 7.7 2.7
H-S-4 || * | *
H-R-4 (1 1.2 2.4 | 4.8 2.4
GR-S-1 1(22.4 3.2 (24.2 5.4
GR-R-1 (1 0.1 1.6 | 4.7 3.7
GR-S-2 (1 8.1 3.3 118.7 5.0
GR-ft-2 || 0.3 1.2 122.6 5.1
M-S-3 || 6.4 1.6 111.9 3.0
GR-R-3 || 0.2 1.0 I 4.2 2.3
GR-S-4 || 4.4 2.3 111.4 3.0
6R-R-4 || 2.8 1.6 I 4.6 2.3
M-B-1 || 0.9 2.9 | 0.3 2.3
M-T-1 (1 1.2 2.6 I 3.0 2.3
GR-T-1 1(13.7 5.8 I 3.5 2.5
1 1 1
3.8 1.2 || * | *
N/A || 0.5 1.2 110.7 2.6
N/A || 7.1 4.9 115.0 4.2
N/A || 1.8 1.1 I 4.0 2.1
11.8 0.6 II * | *
N/A || 1.9 0.9 I 5.4 2.2
N/A || * | *
N/A || 0.9 1.4 | 2.6 1.9
2.4 0.1 1118.1 6.4 130.0 5.7
N/A || 0.2 1.1 | 1.3 1.7
N/A 1(19.5 8.3 130.0 7.0
N/A || 0.7 1.5 I 3.8 1.9
N/A || 2.7 3.9 I 6.5 2.4
N/A || 1.0 1.6 1 3.8 1.9
N/A || 3.0 4.1 112.6 3.4
N/A || 1.4 0.8 153.0 4.4
N/A II 1.1 1.9 1-0.1 1.8
N/A || 0.8 1.4 | 3.1 2.0
0.250.04 II 1.5 1.5 1 1.1 1.7
*
0.4 0.1
3.3 0.2
0.2 0.1
*
0.2 0.1
*
0.0 0.1
4.0 0.2
0.2 0.
1.8 0.
0.0 0.
0.9 0.
0.0 0.
0.9 0.
0.0 0.
0.0 0.
0.0 0.
0.2 0.
ii
* II *
0.006 11-0.5 9.4
0.100 II 8.8 4.9
0.005 II 1.1 1.2
* 1137.7 13.7
0.011 || 1.8 3.4
* II 0.1 2.4
0.004 || 1.7 2.5
0.110 || 9.6 8.3
0.004 H-0.4 2.0
0.100 1115.9 9.8
0.00911-0.8 1.8
0.038 || 3.6 3.6
0.003 11-0.9 2.3
0.012 || 2.2 2.1
0.004 11-0.7 3.0
(.001 || 3.6 2.3
0.001 || 0.1 2.4
0.004 II 1.2 1.2
*
20.9 7.0
26.8 7.2
7.9 3.6
123.9 24.0
8.0 3.8
25.7 4.6
4.9 4.0
16.1 4.4
3.4 2.6
26.8 7.6
12.9 3.8
4.0 1.7
3.2 1.6
12.2 2.1
4.3 3.0
30.2 5.4
25.7 4.6
5.2 3.5
*
0.5 0.
1.7 0.
0.2 0.
0.3 0.
2.2 0.
0.0 0.
0.3 0.
0.6 0.
0.0 0.1
3.4 0.2
0.0 0.
0.4 0.
0.2 0.
0.5 0.
0.3 0.
0.0 0.
0.0 0.
0.3 0.1
*
0.017
0.073
0.009
0.042
0.044
0.007
0.008
0.053
0.013
0.078
0.010
0.029
0.016
0.040
0.013
(0.001
0.007
0.002
Source: FIT Groundwater Quarterly Monitering Program. NUS Letter Report to EPA, June 17, 1985
-------
Remaining Data Gaps
Although the investigation was as comprehensive as time and resources per-
mitted, a number of properties remain that need to be more fully investi-
gated before they can be definitely included or excluded from a remedial
program. In the interim, the program should be considered to include these
properties as well.
Some properties are not sufficiently characterized because it was not poss-
ible to gain access for investigation. Others require further work because
investigation was incomplete. There are three categories of incomplete in-
vestigation. In the first, the property was not scheduled for an investi-
gation because of limited time or resources. This group included proper-
ties outside the current site boundaries, which were identified from the
results of the aerial gamma survey. In the second, radon gas sampling was
performed on the first floor of a residence, but not in the basement, where
radon progeny would be expected to accummulate. In the third, outdoor sur-
face gamma surveys, performed without the grid point method along with the
probe at waist height and using a dectector with. l"xl" crystal, did not
always reveal the presence of elevated gamma radiation. Nongrid-point/
waist-height surveys are sufficient for evaluation of public health
hazards, but later surveys using a grid-point and ground-level detection
methodology revealed areas of contamination that the previous survey had
missed. Remaining data gaps are summarized in Table 1-15.
The transport of radioactive contaminants into surface water and ground-
water has been given limited study. The intent was to collect and analyze
sufficient data to determine the need for a separate investigation on the
the extent and significance of potential groundwater and surface water
contamination. The study has determined that there is contamination in the
upper unconsolidated groundwater aquifer (or aquifers) in Montclair and
Glen Ridge. There are also elevated radioactive levels of sediments in the.
catchbasins associated with the surface water flow into Wigwam Brook. On
the basis of this preliminary data, further investigation will be necessary
to determine its significance to public health.
1-57
-------
TABLE 1-15
REMAINING DATA GAPS
Montclair West Orange Glen Ridge Total
Surface Gamma Surveys
Needed*
(never performed by the
RI or FIT)
Within RI Boundary 20 3 8 31
Outside RI Boundary but
inside D-isopleth 37 8 14 59
Radon Progeny Sampling Needed
Within RI Boundary 98 8 41 147
Outside RI Boundary but
Inside D-isopleth 37 8 14 59
Indoor Gamma Surveys
Needed** ' 140 18 41 199
*The remedial investigation found that many surface gamma surveys performed by
FIT were adequate to identify homes of public health risk but they did not
detect gamma anomalies of low intensity. This is presumably due to the lack of
grid-point data collection methodology and use of waist-level rather than
ground-level survey methods. The criteria for inclusion/exclusion described
in Table 1-4 is based in part on the fact that the RI and FIT investigations
used different methodologies.
**Per the investigation protocol described in section 1.3.2 (Methodology), the
RI used 0.007 WL as an environmental indicator to prioritize the identifica-
tion of potentially contaminated properties. However, to be conservative all
properties may need to have an indoor survey.
(6H6/9)
1-58
-------
1.3.9 CONCEPTUAL MODEL OF CONTAMINATION
The source of elevated radon progeny and gamma radiation levels in the
Montclair/West Orange and Glen Ridge sites has been identified as radio-
actively contaminated soil and various fill materials deposited at the
sites at some time during the period from 1920 to 1940. These soil and
fill materials contain radium-226 and thorium-230 at concentrations high
enough to be a potential danger to the health of residents within the
sites.
Residential neighborhoods have been constructed over the dumpsites with the
result that contaminated material is now buried beneath homes, roadways and
parks. The estimated extent of contamination is quantified in Table 1-16.
Eighty percent of the volume of contaminated soils in Table 1-16 has been
verified with borehole gamma logging. The remainder of the volume was
extrapolated from nearby properties showing contamination or from confirmed
volumes of similar anomalies at other locations.
As a result of site investigations, it is believed that large amounts of
contaminated fill, mostly ash and cinders, were deposited in a few loca-
tions at each site, primarily in depressions in the land along stream beds.
Contamination was spread by natural vectors, such as stream transport and
surface runoff. Material was also moved about during construction activi-
ties. Some was apparently used as fill around homes and under roads and
driveways as the area developed. The result has been a large number of
surface deposits scattered widely throughout the site. There is a small
contribution from contaminated mortars and asphalts.
The scattered distribution of contaminated material at the surface and its
irregular distribution at depth make volume estimates based on surface and
subsurface gamma measurements very uncertain. In addition, the distribu-
tion of radionuclides in the fill materials is very irregular. Average
radionuclide concentrations represent samples taken from the areas of high-
est radioactivity and averaged over the entire site. The estimates of area
1-59
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TABLE 1-16
EXTENT OF CONTAMINATION
Montclair West Orange Glen Ridge
Total Volume of Contaminated
Soil (cu yd) 49,000
Average Activity of
Contaminants (pCi/gm)
Ra-226 217
Th-230 224
Number of Properties
With Outdoor Gamma Anomalies 136
Number of Residences with
Indoor Gamma Anomalies 59
Number of Residneces with
Radon Progeny Concentrations
>0.02Wl 26
Number of Residences with
Gamma Exposures >20 uR/hr
9,000
88
97
24
5
64,000
220
232
60
26
15
Total
Total Area of Contamination
(sq ft) 236,000 35,500 182,000 453,500
122,000
220
90
45
Above Background
Total Number of Properties
with Contamination
9
144
3
25
4
62
16
231
(6H6/9)
1-60
-------
and volume obtained for these sites, therefore, do not result from the
actual determination of where radionuclide concentrations exceed regulatory
limits. Rather, they result from observations of gamma activity and inter-
polation of that activity to estimate radium concentration. Gamma radia-
tion can be detected at a distance from its source, providing either a high
or low estimate of source size, depending on the amount of shielding bet-
ween source and detector. Therefore, the estimate of source material (pCi
of Ra-226) may be much higher or lower than the actual amount present.
From the results of the split-spoon samples, it appears that the radium
present within the fill material is spotty in distribution. Samples taken
very near each other, each showing highly elevated gamma activity at the
same depths, reveal radium concentrations that vary from approximately 500
pCi/gm to background levels. In the fill strata, therefore, estimates of
contamination based only on gamma measurements will be too high.
The RI did demonstrate that there are several distinct materials involved:
high-activity organic soil and fill and low-activity natural material
underlying the fill. While both types present elevated radionuclide con-
centrations, it is possible that they can be dealt with separately based
solely on visual characterization. Separation of the contaminated and
uncontaminated portions of the fill material may be more difficult, but may
be possible due to the large differences in gamma activity.
The RI also determined that thorium-230 is present across the sites in the
same range of concentrations as radium-226. Thorium is also a contaminant
of public health concern.
1.4 OBJECTIVES OF REMEDIAL ACTION
While there is no acute hazard immediately threatening the health of the
residents in these areas, the elevated gamma radiation, radon and radon
progeny concentrations pose a chronic health hazard.
1-61
-------
EPA, CDC, NJDEP and the New Jersey Department of Health (NJDOH) evaluated
the available exposure data and concluded the following: that the major
health threat was from the elevated radon levels, and that these levels
were elevated sufficiently in some of the houses to pose an imminent and
substantial endangerment to public health and to support the initiation of
a removal action under CERCLA (Czapor, et al. 1984).
1.4.1 REMEDIAL OBJECTIVES
The overall objective of the remedial action at the Montclair/West Orange
and Glen Ridge Radium Sites is to minimize or eliminate the potential
health hazard produced by the radioactive contaminated soils present in the
three communities. The focus of this feasibility study is to determine the
appropriate action for control of contaminated source material. The pri-
mary objective of remediation will be the isolation or removal of the con-
taminated soil to reduce exposure to people living and working in struc-
tures in the contaminated area.
1.4.2 RELEVANT PUBLIC HEALTH AND ENVIRONMENTAL STANDARDS
Health-Related Standards
The 1971 dose-limiting recommendations of the National Council on Radiation
Protection and Measurements (NCRP) are presented in Table 1-17. The limit
for maximum individual gamma exposure is 500 mrem per year, and exposure to
the general population is restricted to no more than 170 mrem per year
above the background radiation level. The 500 mrem per year total indivi-
dual radiation limit would translate to about 60 urem/hr for a continuous
24-hour exposure. The 170 mrem per year limit would translate to about 20
urem per hour above background for continuous exposure (24 hours per day).
The Surgeon General's guidelines for exposure to radon and radon progeny
(for Grand Junction, Colorado, 1972) limit working level exposure of radon
progeny in 100 percent equilibrium with radon to 0.02 WL for residences and
0.03 WL for commercial structures. An occupational limit of 0.33 WL has
also been set for radiation workers.
1-62
-------
TABLE 1-17
Dose-limiting recommendations of NCRP (I97lt.
Occupational exposure limits
Whole body, gonads. lens of eve. red bone
marrow
Skin
Hands
Forearms
Other organs, tissues and organ systems
Penile women (with respect to fetus)
5 rem in any one year
15 rem in any one year
75 rem in any one year (25/qtri
30 rem in any one year (10/qtri
15 rem in any one year (5/qtr)
0.5 rem in gestation period
Dose limits for the public, or occasionally exposed individuals
Individual or occasional
Students
Population dose limits
Genetic
Somatic
Emergency dose limits—lifesaving
Individual (older than 45 yr if possible)
Hands and forearms
Emergency dose limits—less urgent
Individual
Hands and forearms
Family of radioactive patients
Individual (under 45 yr)
Individual (over 45 yr)
0.5 rem in an>. one year
0.1 rem in any one year
0.17 rem av. per year
0.17 rem av. per year
100 rem
200 rem.
25 rem
100 rem.
additional (300 rem total)
total
0.5 rem in any one year
5 rem in any one year
Source: NCRP, 1971. Table 6.
1-63
-------
The maximum permissible concentrations of relevant radionuclides in air and
water for members of the general public taken from 10 CFR 20, and the
relevant maximum contaminant levels from the National Interim Primary
Drinking Water Standards are displayed in Table 1-18.
Cleanup of Lands and Buildings
There are no directly applicable standards governing remediation of lands
contaminated with radium-226. The EPA has, however, promulgated standards
for remedial action on lands contaminated with radium-bearing tailings from
inactive uranium mill sites (40 CFR 192.12) that are relevant for excava-
tion of contaminated materials. While the purpose for the processing of
the original material may be different for the Montclair/West Orange and
Glen Ridge sites, the waste streams, exposures, and exposure pathways are
similar to the mill tailings contamination problem. The public health
risks are sufficiently similar to the Montclair/West Orange and Glen Ridge
sites that application of the CFR 192 standards is appropriate, although
not legally required.
An internal agency memorandum between Sheldon Meyers, Director of EPA's
Office of Radiation Programs, and William Librizzi, Director of Region II
Emergency and Remedial Response Division, on September 17, 1984 transmits
the recommended criteria for use in the cleanup of radium-contaminated
soils in Glen Ridge, Montclair and West Orange. These recommended cri-
teria, as discussed below, are summarized in Attachment 1.
EPA evaluated the risk associated with the dispersal of tailings off the
site and concluded that the principal risk to humans is the exposure to
radon progeny products inside buildings. EPA accepted and implemented the
objective established in the CDC memo dated December 6, 1985 for the clean-
up of tailings from around existing structures to achieve an indoor radon
progeny concentration (RDC) of less than 0.02 WL. For open lands, the pur-
pose of removing the contamination is to remove the potential for excessive
indoor radon progeny concentrations that might arise from new construction
on contaminated land. The radioactive contaminant levels for all areas
1-64
-------
TABLE 1-18
MAXIMUM PERMISSIBLE CONCENTRATIONS1 AND NATIONAL INTERIM PRIMARY
DRINKING WATER STANDARD FOR RELEVANT RADIONUCLIDES FOR GENERAL PUBLIC
. . Maximum
MPC In Air1 MPC In Water Contaminant
(pCi/1) (pCi/1) Level i
(pCi/1)
Potassium-40
Radium-226
Radon-222
Thorium-230
Uranium-234
1 Adapted from 10 CFR 20,
£ A f\ f*c n 1 >i i n u« A*« T j* •* A ft
7,000 300,000
0.003 30 3
3
0.00008 2,000
0.02 30,000
Appendix B, Table II.
(6H6/9)
Standard specifies that the limit refers to combined concentrations of
Ra-226 and Ra-228.
1-65
-------
released for unrestricted use will not exceed 5 picocuries of radium per
gran of soil above background in the top 15 centimeters of soil, averaged
over a 100-square-meter area, and would not exceed 15 picocuries of radium
per gram of soil above background in any 15-centimeter layer below that
depth, averaged over a 100-square-meter area. The 5 pCi/g and 15 pCi/g
Ra-226 concentration limits for 15-cm surface and subsurface layers were
considered adequate to limit indoor RDCs to below 0.02 WL. Although these
standards are based on health risks, they can be used as a basis for the
attainment of environmental goals and will be considered as relevant
environmental standards.
A secondary concern was to limit exposure to people from gamma radiation.
According to 40 CFR 192.12 the level of gamma radiation in any occupied or
habitable building must not exceed the background level by more than 20
microroentgens per hour (20 uR/hr). This limit can be traced back to the
1971 dose-limiting recommendation of 170 mrem/year limit for exposure to
the general population.
The 40 CFR 192 standards state that residual radioactive materials should
be removed from buildings exceeding 0.03 WL. In cases where levels are
between 0.02 and 0.03 WL, the use of sealants, filtration devices, or
ventilation devices is encouraged to avoid the excessive costs of addi-
tional removal of contaminated material to meet the objective of 0.02 WL.
Strict interpretation of 40 CFR 192 standards would permit leaving material
underneath buildings if the health standards of 0.03 WL and 20 uR/hr are
met. However, this would not protect the residents from future distur-
bances to the ground or to utilities entering the basement of the affected
building that would allow the radon concentrations in the home to increase
beyond the health standard. A more conservative approach would be to re-
move all soil known to have contaminants above the 5 and 15 pCi/gm limit
(the 5/15 standard).
1-66
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In addition to the maximum limit for radium 226, Nuclear Regulatory Com-
mission (NRC) guidelines (1982) for decontamination of facilities and
equipment prior to release for unrestricted use specify that in the event
of ocurrence of mixtures of radionuclides, the fraction contributed by each
radionuclide to its guideline must be determined, and the sum of these
fractions can not exceed 1. There are two special cases for which this
rule must be modified:
f- r
(1) If Ra-226 is present, then the fraction for Ra-226 should not be
included in the sum if the Ra-226 concentration is less than or
equal to the Th-230 concentration. If the Ra-226 concentration
exceeds the Th-230 concentration, then the sum should be evaluated
by replacing the Ra-226 concentration by the difference between
the Ra-226 and Th-230 concentrations.
(2) If Ac-227 is present, then the same rule given in for Ra-226
relative to Th-230 applies for Ac-227 relative to Pa-231.
The guidelines for the other radionuclides that may be present at the site
are as follows:
Soil Criteria1
Radionuclide (pCi/g above background)
U-Natural2
U-2383
U-2344
Th-2305
U-2354
Pa-231
Ac-227
Th-232
75
150
150
15
140
40
190
15
1-67
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1. Except for Ra-226, these guidelines represent unrestricted-use
residual concentrations above background averaged across any
2
15-cm-thick layer to any depth and over any contiguous 100-m
surface area. The same conditions prevail for Ra-226 except for
soil layers beneath 1.5 m; beneath 1.5 m, the allowable Ra-226
concentrations may be affected by site-specific conditions and
must be evaluated accordingly.
2. Localized concentrations in excess of these guidelines are
o
allowable, provided that the average over 100 m is not exceeded.
However, DOE ALARA (as low as reasonably achievable) policy will
be considered on a site-specific basis when dealing with elevated
localized concentrations.
3. One curie of natural uranium means the sum of 3.7 x 10 disinte-
grations per second (dis/s) over any 15-cm thick layers from U-238
10 Q
plus 3.7 x 10iu dis/s from U-234 plus 1.7 x 10* dis/s from U-235.
One curie of natural uranium is equivalent to 3,000 kilograms or
6,600 pounds of natural uranium.
4. Assumes no other uranium isotopes are present.
5. The Th-230 guideline is 15 pCi/g to account for the production of
Ra-226 as the decay product of Th-230. Ra-226 is a limiting
radionuclide because its decay product is Rn-222 gas.
Application of these guidelines to the Montclair/West Orange and Glen Ridge
radium sites requires that the 5/15 standards be met with regard to both
Ra-226 and Th-230. Since there appear to be concentrations of thorium-230
greater than the concentration of Radium-226 throughout the sites, excava-
tion will be designed to ensure that the maxmum thorium and radium concen-
trations will be less than 5/15 pCi/g above background, as required by re-
gulations.
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DOE guidelines (order 5480.1A) allow for a more liberal interpretation of
the 40 CFR 192 regulations. They specify that the 5 to 15 pCi/gm regula-
tions apply to soil layers within 1.5 meters of the ground surface but not
below 1.5 meters, "the allowable Ra-226 concentration may be affected by
site specific conditions and must be evaluated accordingly." EPA does not
make the depth distinction; it instead requires compliance based on achiev-
ing the 5/15 standards over a 100-meter-square area. Other supplemental
standards are addressed by the 40 CFR 192 regulation itself in Section
192.21 as presented in Table 1-19. An EPA internal memorandum addresses
the application of secondary standards to the Montclair/West Orange and
Glen Ridge sites, (see Attachment 1). Because of the residential nature
of these communities, an exemption to the 5/15 excavation criteria in open
lands would not be allowed.
Transportation
Federal Regulations. In Section 173.403 of the July 1, 1983 revisions to
49 CFR 173, radioactive material, for transportation purposes, is defined
to be any material that has a specific activity greater than 0.002 uCi/g
(2000 pCi/g).
Section 173.421 states that radioactive materials whose activity per pack-
age does not exceed the limits specified in section 173.423 are exempted
from the specification packaging, shipping paper and certification mark-
ings, and labeling requirements if they meet certain minimal packing re-
quirements. One of these requirements specifies that the radiation level
at any point on the external surface of the package (in a shipment) does
not exceed 0.5 millirems per hour. The average radium-226 concentration of
the contaminated soils is estimated to be 210 pCi/gm. If secular equili-
brium between radium-226 and its decay products is assumed, the total
specific activity is approximately 10 times the radium-226 activity. How-
ever, this estimate is biassed high, since it is based on analysis of soil
samples taken from areas of highest gamma actvity. Therefore, the specific
activity of the wastes to be transported may well be under the limit of
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TABLE 1-19
PART 19; -
SuBPART A
192.02
AAD CN«IROW state tnat pays part of the cast* and m consultation as
appropriate «un otner govemacnt agencies and affected Indian tribes.
192.21 Criteria for Applying Supplemental Standards
The laplownting agencies My ape'/ standards >n lieu of tne standards of Subpa-ts A or B if
certain circumstances e>ist, as defined in 192.21.
192.22 Supplemental Standards
•Fede'a! agencies laRlexentmj Suoptrti A and S «*j in lieu tne'f:' praceeS Pu's.i". ts •.••s
sectior. *itn respect to generic or individual situations aeeting tne elig'C'IU/ reQy'ranerii
of 192.21.'
(«) '. . .the ii«'e«entin; tq(*;\ti sn«l 1 select and Of'or* reneoial actions tnat coo* ts
close to aeeting tne otherwise applicable standards as is reasonable unde- tne
circuastances.'
(b) '. . .rea«dia' actions snail, in addition to satisfying me standards of SuOpun specified cna>-
-------
2000 pCi/gm. Because of heterogeneities in the wastes, some mixing of
wastes may be necessary to ensure that individual shipments do not exceed a
total specific activity of 2000 pCi/gm.
Another major federal regulation concerning transport of the wastes is the
gross vehicle weight limit of 36,000 kg (80,000 Ib) (Pub. L. 97-424, HiCgh-
way Improvement Act of 1982) which applies to all states.
State and Local Regulations. Several state and local governments have
issued regulations and passed statutes that impose restrictions on ship-
ments of radioactive materials. The U.S. Congress has, by statute, given
DOT preemptive regulatory authority over state and local jurisdictions in
the matter of transportation of radioactive materials. The U.S. Supreme
Court has recently upheld this preemptive authority in a case where the
city of New York filed suit against DOT, challenging DOT's regulatory
authority (U.S. Supreme Court, 1984).
Although state or local regulations regarding the transport of radioactive
materials are preempted by federal law (Federal Materials Transportation
Act, Section 12, Title I, of Public Law 93-633), a state or local munici-
pality has the option of filing with the Department of Transportation for a
nonpreemption determination (i.e., a waiver of preemption). A state or
local requirement influencing the transport of radioactive materials will
cease to be preempted by Federal law if, upon application for the nonpre-
emption determination, the Secretary of the Department of Transportation
finds that the state or local ruling (1) provides an equal or greater level
of public safety than the Hazardous Materials Transportation Act or regula-
tions issued thereunder, and (2) does not burden commerce. Nonpreemption
determination, therefore, does offer the state or local area a recourse in
the case of disputes over Federal preemption.
Packaging and Shipping
Packaging and shipping of low-specific-activity (LSA) radioactive material
is governed by 49 CFR 173.393, which applies both to small quantities of
1-71
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material, such as samples, and bulk shipments. Packaging is also covered
under 49 CFR 173.395. Marking and labeling are covered by 49 CFR 172.300
and 172.400.
The regulations specify that bulk shipments of LSA material must have an
average estimated radioactivity concentration of less than 0.001 millicurie
per gram (10 pCi/gm) with Ra-226 and Th-230 contributing not more than 1
percent of that total (10 pCi/gm). The contaminated soils in Montclair,
West Orange and Glen Ridge have activities far below these levels. Trans-
port vehicles must be placarded and there must be no leakage of material
from the vehicle.
For both packaged materials and bulk shipments, radioactivity at the pack-
age surface is limited to 200 millirem/hr (200,000 uR/hr) at any point.
Again, the soils at the three radium sites have activities far below this
level.
Interim Storage
The regulations developed by DOE for their FUSRAP (Formerly Utilized Sites
Remedial Action Program) sites appear to be most relevant to the interim
storage scenarios described in this document and are summarized below-.
(1) Control and stabilization features will be designed to ensure, to
the extent reasonably achievable, an effective life of 50 years
and, in any case, at least 25 years.
(2) Rn-222 concentrations in the atmosphere above facility surfaces or
openings will not (1) exceed 100 pCi/1 at any given point, or an
average concentration of 30 pCi/1 for the facility site, or (2)
exceed an average Rn-222 concentration at or above any location
outside the facility site of 3.0 pCi/1 (above background).
(3) For water protection, use existing State and Federal standards;
apply site-specific measures where needed.
1-72
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Final Disposal
The design features of the final disposal site will conform to the 40 CFR
192 performance guideline and requirements specified in Subpart A. Control
will be designed to:
(1) Be effective for up to 1,000 years, to the extent reasonably
achievable, and, in any case, for at least 200 years
(2) Provide reasonable assurance that release of radon-222 from
residual radioactive material to the atmosphere will not:
(a) Exceed an average release rate of 20 picocuries per square
meter per second
(b) Increase the annual average concentration of radon-222 in air
at or above any location outside the disposal site by more
than one-half picocurie per liter
(3) Prevent inadvertent human intrusion
(4) Ensure that existing or anticipated beneficial uses of ground and
surface water would not be adversely affected
(5) Provide flood protection (as required), runoff and sediment
control, and wastewater treatment (as required).
(7H1/4)
1-73
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REFERENCES FOR CHAPTER 1
Reports
ARIX Corporation, Report to the EPA on the Results of the Delta Gamma
Surveys, June 5, 1984.
Camp Dresser & McKee, Report of the Remedial Investigation of the
Montclair/West Orange and Glen Ridge Radium Sites, August, 1985.
Czapor, John V., Kenneth Gigliello and Jeanette Eng, Radon Contamination in
Montclair and Glen Ridge, New Jersey: Investigation and Emergency
Response, November 1984.
NUS Corporation, Superfund Division, Results of the Source Characterization
Program: Glen Ridge Low Level Radiation Site, Glen Ridge, New Jersey, July
12, 1984. Montclair Low Level Radiation Site, Montclair, New Jersey, July
12, 1984. West Orange Low Level Radiation Site, West Orange, New Jersey,
October 12, 1984. (3 Volumes)
O.H. Materials Co., Radiological Engineering Assessment Reports (13
Volumes) October-December 1984.
US Environmental Protection Agency, Region II and New Jersey Department of
Environmental Protection, Investigation of Radiological Contamination in
Montclair/Glen Ridge, New Jersey, April 6, 1984
Bendix Field Engineering Corporation, National Uranium Resource Evaluation:
Newark Quadrangle, Pennsylvania and New Jersey, March 1982, (USDOE Document
PGJ/F-123(82)).
Nichols, William D., Groundwater Resources of Essex County, New Jersey,
USGS Special Report No. 28, 1968.
1-74
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REFERENCES FOR CHAPTER 1 (continued)
Bell, Christy, Radioactive Mineral Occurrences in New Jersey, NJGS Open
File Report No. 83-5, 1983
Kasabach, Haig, Memo to Steven Kuhrtz, NJDEP concerning "Review of Historic
Photos and Maps Covering Glen Ridge, Montclair and East Orange - Radon
Investigation," December 13, 1983.
Baker, Steven J., Site Analysis - Orange, Glen Ridge and Montclair, New
Jersey. USEPA/Environmental Monitoring Systems Laboratory, TS-PIC-84056,
April 1984.
Vroeginday, Barry, Letter to Ken Gigliello, EPA, Region II, concerning
Results of the First Quarter Radiological Monitoring Progam in Montclair
and Glen Ridge, New Jersey, November 13, 1984.
Vroeginday, Barry, Letter to Ken Gigliello, EPA, Region II, concerning
Results of the First and Second Quarter Radiological Monitoring Progam in
Montclair and Glen Ridge, New Jersey, February 8, 1984.
Vroeginday, Barry, Personal Communication to William Smith, concerning
Results of the Third Quarter Radiological Monitoring Progam in Montclair
and Glen Ridge, New Jersey, May 23, 1985.
Houk, Vernon, N., Center for Disease Control, Department of Health and
Human Services, Letter to William N. Hedeman, Jr., USEPA, concerning Health
Advisory for Radon Exposure in Homes in Glen Ridge and Montclair, New
Jersey, December 6, 1983.
1-75
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REFERENCES FOR CHAPTER 1 (continued)
Meetings and Telephone Conversations
Kathy Bronnander, Helen de Seal a Realty, Telephone Conversation between
Emily Pimentell of Camp Dresser & McKee Inc., June 21, 1985
Jean Carradona, Township of Montclair Tax Assessor, Telephone Conversation
between Emily Pimentell of Camp Dresser & McKee Inc., June 20, 1985
Robert Ebert, Township of Glen Ridge Tax Assessor, Telephone Conversation
between Emily Pimentell of Camp Dresser & McKee Inc., June 21, 1985
Joseph Scatturo, Township of West Orange Tax Assessor, Telephone Conversa-
tion between Emily Pimentell of Camp Dresser & McKee Inc., June 21, 1985.
D.L. Conyers, Commonwealth Water Company, Letter to Gracie Coffey, Camp
Dresser & McKee Inc., May 28, 1985.
David Stybel, Passaic Valley Water Company, Telephone Conversation with
Gracie Coffey, Camp Dresser & McKee Inc., June 8, 1985.
Nassir Butt, NJDEP Engineer for Essex County, Telephone Conversation with
Gracie Coffey, Camp Dresser & McKee Inc., June 8, 1985.
Tom Restaino, Public Health Official, Montclair, NJ, Telephone Conversation
with Gracie Coffey, Camp Dresser & McKee Inc., June 7, 1985.
Maurice Modine, Township Engineer, Glen Ridge, NJ, Telephone Conversation
with Gracie Coffey, Camp Dresser & McKee Inc., June 7, 1985.
Township Engineer, Bloomfield, NJ, Telephone Conversation with Gracie
Coffey, Camp Dresser & McKee Inc., June 6, 1985.
1-76
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Assistant City Engineer, Orange, NJ, Telephone Conversation with Gracie
Coffey, Camp Dresser & McKee Inc., June 5, 1985.
Tony Scillia, Water Department, East Orange, NJ, Telephone Conversation
with Gracie Coffey, Camp Dresser & McKee Inc., June 5, 1985.
Joe Melko, Water Department, South Orange, NJ, Telephone Conversation with
Gracie Coffey, Camp Dresser & McKee Inc., June 6, 1985.
(7H1/4)
1-77
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2.0 SCREENING OF REMEDIAL ALTERNATIVES
The problem of radioactively contaminated surface and subsurface soil in
the Montclair/West Orange and Glen Ridge study areas may be addressed by
the three general response actions described below:
(1) No Action Response - In this response, no action is taken to remediate
the contamination or reduce the hazard to residents at the three sites.
The ventilation systems now in place will be removed and no further
monitoring of conditions at the sites will be performed.
(2) Onsite Source Control Response - This response involves leaving the
contaminated material on site and reducing the hazard to the population
by using engineering barriers. This response can also include measures
such as restrictions on excavation and construction in the contaminated
area or relocation of residents.
(3) Decontamination and Release Response - This response involves removing
contaminated materials from the site so that it may be released for
unrestricted use. Materials would be transported off site to an
acceptable disposal area.
The objective of remedial response is to minimize or eliminate the poten-
tial health hazard presented by the radioactive soils through control of
gamma emissions, radon emanations and dispersal of contaminants by wind,
water or human vectors.
Each general response action may include several possible applicable
combinations of technologies. This chapter identifies and screens the
technologies considered in the development of the candidate remedial
alternatives. The technologies that remain after screening have been
formulated into complete response actions and are assessed further based on
such nontechnical considerations as environmental and public health
impacts, institutional acceptability, and cost.
2-1
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2.1 TECHNICAL SCREENING OF REMEDIAL TECHNOLOGIES
The remedial technologies examined are listed in Table 2-1. Technologies
determined to be too difficult to implement, that would not achieve the
remedial objective within a reasonable time period, or that appear
unreliable or not fully demonstrated were eliminated from consideration.
2.1.1 SOURCE CONTROL TECHNOLOGIES
One method of reducing the public health hazard resulting from radio-
actively contaminated soil is to isolate the source material from the
public. This can be accomplished by constructing surface and subsurface
barriers between the source material and the receptors. Barrier techno-
logies considered include capping and subsurface barriers such as liners or
slurry walls.
Capping
Capping consists of sealing or covering an area with a layer of materials
of low permeability. Capping the contaminated land would reduce radon and
gamma emissions and also reduce the radium migration caused by infiltra-
tion. However, horizontal migration of the radon gas through the soil and
migration of radium in the groundwater could still occur. Therefore, cap-
ping alone will not adequately reduce the hazards posed through air and
water contamination.
Subsurface Barriers
Subsurface barriers in combination with capping would best achieve the
goals of shielding the public from the source material and reducing the
migration to groundwater systems. The capping and barrier material should
be designed for long-term performance to meet the EPA objective of reliance
on passive controls. A liner is a subsurface barrier across the sides and
bottom of a disposal cell. Capping materials in a lined cell (encapsula-
2-2
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TABLE 2-1
Remedial Technologies
I. On-Site Control and Containment Technologies
A. Source Control
1. Capping
2. Subsurface barriers
B. Protection of Receptors
1. Shielding
2. Sealants
3. Passive collection system
4. Active collection system
5. Ventilation and air cleaning systems
6. Relocation
C. In-Situ Treatment
1. Solution mining
2. In-situ Vitrification
II. Removal and Off-Site Treatment/Disposal Technologies
A. Excavation
1. Conventional Excavation
2. Hydraulic mining
B. Transportation and Handling
1. Vehicles
a. Truck
b. Barge
c. Rail
2. Containerization
a. Bulk
b. Drums
c. Wooden or Metal Containers
d. Solidification
3. Transport Options
a. Direct loading/unloading
b. Transfer Station
2-3
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TABLE 2-1 (continued)
C. Interim Storage
1. Uncovered pile
2. Covered waste pile
3. Outdoor storage of containerized soil
4. Indoor storage
5. Moored cargo ship
6. Existing DOD or DOE facilities
D. Volume Reduction
1. Chemical Recovery of Radionuclides
2. Physical Separation
a. Separation by particle size and density
b. Ion exchange
c. Bulk separation at source
d. Bulk mixing
e. Dilution
E. Immobilization of Radionuclides
1. Vitrification
a. Electric furnace fusion
b. Rotary kiln
2. Matrix Isolation
a. Bitumen or asphalt
b. Cement
c. Resins
F. Permanent Disposal
1. RCRA-permitted facility
2. Department of Defense facility
3. Department of Energy facility
4. Licensed commercial low-level waste facility
5. Designed encapsulated disposal facility
6. Road bed dispersal
7. Mine burial
8. Ocean disposal
(6H13/16)
2-4
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tion) would completely surround the contaminated materials, preventing
infiltration of the cell by water and reducing radon and gamma emissions.
To ensure that the barriers are performing adequately, environmental moni-
toring may be required. The technologies required for long-term monitoring
of the air and water around the enclosed areas have been established and
are currently in use at storage sites for uranium mill tailings.
Capping and subsurface barriers are appropriate for the large volumes of
soils in the most heavily contaminated portions of the sites. However,
these technologies are unsuitable for the smaller volumes of lower radio-
nuclide concentration scattered throughout the sites since the areas in-
volved are not large enough for economical treatment. These materials may
be excavated, placed over the heavy contamination and capped.
The use of encapsulation as a permanent or interim source control techno-
logy will be further screened for environmental and public health impacts
and institutional considerations. Capping alone will be further considered
»
(Section 2.1.6) as part of the interim storage technologies.
2.1.2 PROTECTION OF RECEPTORS
Shielding
Engineering solutions can be employed to protect the residents within their
homes. The public health hazard caused by gamma radiation from the con-
taminated soil would be effectively reduced by constructing a shield of
dense materials such as lead, concrete or dense earth. Applying shielding
to the outside of a house would not be useful in most cases of elevated
indoor gamma activities since readings that indicated a health hazard were
usually found along floors. Use of outdoor shielding would also interfere
with the construction of trench vents that may be installed to reduce radon
concentrations (discussed below). Lead or concrete are much preferred
construction materials to dense earth for remediating indoor gamma
problems, thus earth was screened out. Either lead foil or concrete may be
2-5
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used, depending on the particular structural application. Other materials
such as sheetrock or plywood may be useful for certain applications. The
selection of material to be used is a design function, and not appropriate
to this screening. Lead or concrete shields were passed on for further
screening for the specific purpose of reducing gamma radiation exposures.
Sealants
Shielding alone will not prevent the accumulation of radon and radon
progeny inside homes. To reduce the hazards from this exposure, other
technologies must be considered. Cracks and openings into basements could
be sealed to prevent migration of radon into homes. This approach is
simple to implement, but may not be sucessful in reducing indoor radon
levels. If a path remains for radon to enter, through an incomplete or
deteriorated seal, for example, working levels could actually increase as
ventilation in the sealed area would be reduced. As with any remedial
action that leaves the contaminated soil in place, an ongoing monitoring
and maintenance program would be needed to ensure the effectiveness of the
remediation. The use.of sealants alone was considered an unreliable
technology and screened out.
Passive Collection System
The migration of radon gas into residences can be reduced by installing a
passive collection system (trench vents) around each house. Trench vents
would be constructed by excavating a deep, narrow trench along the founda-
tion, down to the bottom of the footing, and back filling with gravel. The
low resistance path formed would channel gas migration away from the house.
The trenches would be capped to prevent rainwater infiltration and vertical
pipes would be installed to vent gas to the atmosphere.
Trench vents have the advantage of being simple to install and maintain.
They would not, however, collect radon generated from contamination below
houses and would require long-term monitoring to evaluate their effective-
ness in decreasing indoor radon concentrations. Passive collection is an
2-6
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unsatisfactory solution by itself, and will only be considered for use when
supplemented by active systems as described below.
Active Collection System
Trench vents can also serve as part of an active collection system. An
active system can be created by creating a negative pressure at the outlet
of the vent using fans or blowers, or by creating a positive pressure to
drive the radon gas toward the vent. Since the remedial objective is to
reduce radon and radon progeny inside houses, rather than to collect radon
gas, the simple approach would be to generate a positive pressure inside
the houses by drawing in air from outside.
Ventilation Systems
The existing removal action consists of active ventilation systems, in some
cases combined with the use of seals around utility lines. These systems
draw air from the outside into the houses, diluting the radon present to
lower concentrations. The ventilation systems have been shown to be effec-
tive in reducing the concentration of radon and radon progeny down to be-
tween 5 percent to 35 percent of their initial concentrations in the base-
ments of residences. However, the radon progeny concentrations in some
homes could not be maintained below the desired levels.
The ventilation systems can be installed quickly and their effectiveness is
seen immediately. A considerable amount of maintenance is required to
assure efficient operation, and these systems' useful life is only about 10
years. The units are very noisy and disturbing to the residents and they
increase the home heating and cooling expenses. During the first summer of
operation of the ventilation systems, an unforeseen problem occurred: they
brought large amounts of humid air into the house causing condensation
indoors with accompanying wall and ceiling damage. Another disconcerting
effect of the ventilation systems is that, while the radon concentrations
are reduced in all levels of the house, the reduction is greater on the
basement level and decreases in the upper levels of the home, where
2-7
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residents spend most of their time. The performance of the ventilation
systems may be improved by installing a passive collection system around
each house. This modification would decrease the potential for radon to
migrate into the house and would increase the potential for the radon in
the basements to be driven directly outdoors, rather than through the upper
levels of the house.
Active ventilation systems, in combination with sealants for openings, were
passed on for further screening. Passive collection will be considered
further only as a modification to the active ventilation systems now in
place. Shielding inside houses will be considered only where necessary to
reduce gamma exposures.
Relocation
Relocation of the affected residents should also be considered as a reme-
dial technology. This action would involve the purchase of the affected
properties and installation of simple security measures to discourage in-
trusion, as has bqen done at other hazardous waste sites. The existing
public health threat would be eliminated by removing the receptors from the
source of the hazard. This option is not fully satisfactory, since it
would not totally eliminate the problem of radon gas migration beyond the
fenced-in site. Migration of radium through the soils by infiltration
caused by precipitation would still occur. However, since it will minimize
the public health threat, this technology was also passed on for additional
screening.
2.1.3 IN-SITU TREATMENT
Solution Mining
A potential treatment for the contaminated soil at these three sites is a
variation of a process called "in-situ solution mining" used by industrial
uranium extraction and processing companies in the western United States.
2-8
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Briefly, this process involves sinking a series of spaced perimeter wells
into the radionuclide-rich soils. A solution that will solubilize the
contaminated materials present is injected into the ground through these
perimeter wells, dissolving the radionuclides and other metals. Central
recovery wells are installed to withdraw the solution, which is passed
through a filter system to extract and concentrate the radioactive
material. A 90 percent removal efficiency from the soil has been reported
for mines in the western United States.
Advantages of this system are that it can be installed directly around
homes and would not require any evacuation or relocation of residents. The
removal efficiency, if realized, would reduce the amount of soil requiring
disposal since soil concentrations could be reduced to below 15 pCi/gm in
most of the contaminated areas. However, it is doubtful that the reported
efficiency could be obtained at the low concentrations present in the soil.
Although this technology has been proven at other sites, extensive site
testing and evaluation would be required to insure that the solubilization
process is effective at the low concentrations present. The complex nature
of the process would probably limit its use to the central locus of con-
tamination at each of the three sites and not to the discrete pockets found
scattered around the study areas.
The contaminated materials at these sites are not the dry sandy soils found
in the western mining areas. The radium seems to be most frequently asso-
ciated with the ash and cinder fill material. The applicability of solu-
tion mining to this material is unknown. In addition, the natural subsoil
of the area, unsorted glacial till, is not conducive to processes dependent
on permeability and flow. The overburden shows evidence of clay lenses
causing confined and semiconfined groundwater systems that would probably
not support direct injection and extraction of solutions through the con-
taminated area. Contamination of the groundwater systems below the over-
burden could occur, especially if pockets were shielded from the pumping
effects of the extraction wells by clay lenses. Because of questions of
direct applicability, environmental impact and efficiency, this technology
was not considered further.
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In-Situ Vitrification
In-situ vitrification can be used to convert radioactive-contaminated soils
into a stable glass-like solid mass. This is achieved by passing electri-
cal current through four graphite electrodes set up in a square array em-
bedded into the ground to the desired depth. Electrical resistance heating
melts any substance that falls within the area defined by the four
electrodes. Upon melting, the radioactive elements in the soil are evenly
distributed throughout the mass of molten material. Once the electrical
current is turned off and the electrodes removed, a sudden quenching effect
occurs, freezing all the melted material. What remains is a vitrified mass
of cubic configuration.
Vitrification is applicable to a wide range of soils. Its major advantage
is that the vitreous product is more stable relative to leaching, struc-
tural change and radon emissions. The hazards of handling the materials
would be removed and public exposure lessened. Leach tests using a Soxhlet
extractor with samples of vitrified soil gave leach rates that were about
the same as for Pyrex glass and one-fifth the rates obtained from bottle
glass. Tests on 100 - 200 - gram samples of uranium mine tailings showed
that radon emissions were reduced from 22 to 1,400 times below those for
untreated sands. Emissions from treated fine-grained particles were much
lower than those from treated sands. (Fines make up between 36 percent and
40 percent of the Montclair, West Orange and Glen Ridge waste.)
There are several major drawbacks to the in-situ vitrification process.
o Off-gases are produced that must be treated to remove radioactive
and nonradioactive pollutants.
o Electric power requirements are large. The high level of soil
moisture at the three sites would drastically increase the power
requirements, and therefore the costs. Based on an estimated
removal volume of 122,000 cubic yards and 21 percent soil moisture,
an estimated 54,000 mega watt hours (MWH) of electric power would
be required to vitrify all soil removed.
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o The effects of vitrification have only been tested for sands and
sandy soils. Bench tests would be needed to determine the response
of the ashes and organic soils found at the three radium sites.
o The applicability of in-situ vitrification to residential areas is
questionable. Conductive paths between electrodes are necessary
and residential areas offer numerous interferences to conduction
such as underground utilities, fuel oil storage tanks, septic tanks
and even large tree root systems.
o Temperatures up to 1200°C are needed to achieve vitrification.
This would assure complete destruction of any life forms in the
soil, not only within the vitrification cell but for a large area
surrounding the process areas.
o Finally, the verification that all wastes have been vitrified would
be extremely difficult.
Once again, the process would only be applicable to centralized areas of
contamination and not to the scattered pockets of contaminated soil located
throughout the three sites. The centralized areas and large surrounding
buffer zones would have to be purchased and fenced off. While these areas
might be released for future use, they would not be appropriate for use as
residential living areas. Because of the large energy requirements and the
major negative environmental impacts associated with the high temperatures
needed, this alternative was not considered further.
2.1.4 EXCAVATION
Conventional removal of the contaminated soil with earthmoving equipment
such as bulldozers, backhoes, front-end loaders and scrapers is feasible
for this project. Techniques for removing contaminated soils by con-
ventional excavation have been proven at Maywood and Middlesex, New Jersey,
and Canonsburg, Pennsylvania. At these same sites, it was demonstrated
that conventional dust control and runoff control techniques were
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sufficient to protect workers and the general public during excavation. If
desired, special operating techniques can be applied to minimize exposure
of the workers. Excavation methods are described in more detail under
Section 3.2.1.1. Conventional excavation was passed on for further
consideration.
Wastes could also be removed as a slurry using hydraulic mining techniques.
This would require construction of massive pumping, processing and drying
facilities and consume massive amounts of water. The relatively low acti-
vity of the soils and resulting low health hazard does not warrant such a
complex, expensive removal. This excavation technique was not considered
further.
2.1.5 TRANSPORTATION AND HANDLING
Three transport modes were considered for shipment of Montclair/West
Orange, and Glen Ridge soils: truck, barge and rail. Transportation is
well developed in Essex County and the surrounding area. There are several
major highways readily accessible from the site, and a number of rail yards
operate in the area.
Truck
Soil could be carried from the site in bulk form using dump trucks or in
containerized form on flat-bed trailers. Economy of scale encourages the
use of larger trucks to carry fewer loads. Less handling would also be
required, decreasing public health risks. The limit to truck size is the
bearing capacity of the roads. From an engineering standpoint, it appears
that 16 yard dump trucks, carrying a maximum load of 14 cubic yards, can be
used to transport soil out of the towns.
Barge
Barges could be used to transport the soils to an inland or ocean disposal
site. There a number of wharves deep enough for the draft of the barges
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within 30 miles of the sites, all within the New York Port District. For
inland disposal sites, wharves for unloading the soils would have to be
identified. There is currently no east coast facility available (section
2.2.7). For disposal at a west coast disposal facility, barges would need
to be routed by way of the Panama Canal to a point on the west coast of the
U.S. for unloading.
The main obstacle to barge transport is the availability of resources.
Under the Merchant Marine Act of 1920, ocean movement would have to be in
U.S. vessels. A study by Bechtel National (1984) stated that there were
only 20 bulk carriers in the U.S. merchant fleet suitable for this service,
and that most of them were quite old. Tug and barge combinations suitable
for hauling bulk material were found to be primarily dedicated to hauling
coal and phosphate rock. It would be unfeasible to commit these vessels
for the period of several years needed to haul all of the contaminated
soils to a west coast site.
It would be more feasible to use existing barges to bring the soils to an
ocean disposal site (Section 2.1.9). Transport by barges was passed on for
consideration as part of an Atlantic Ocean disposal option.
Rail
Rail transport is an alternate mode of transport and, like the other two,
acceptable for both bulk and containerized shipment of the soils. In
general, two types of railcars can be considered: bulk-handling cars or
flat cars on which trailer vans containing containerized or packaged
materials are placed. Bulk handling railcars include open and covered
hoppers, high- and low-side gondolas and side dump cars.
For bulk transport by rail, a loading/unloading facility would have to be
constructed to transfer soils from the dump trucks to the cars. The exist-
ing commercial disposal facilities have unloading facilities that are
dust-controlled for worker protection and decontamination facilities for
vehicles leaving the disposal sites. Containerized soils would be best
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loaded onto flat-bed semitrailer trucks on site. These could then be
transferred to a trailer-on-flatcar (TOFC) ramp at the rail transfer point,
loaded onto flatcars and then transported by rail to a TOFC ramp near the
disposal site.
Implementation of truck or rail transport would be more feasible than barge
transport since fewer loading facilities would be necessary. Rail and
truck transport are both available and both have been proven to work in
similar projects.
Containerization
Transportation regulations for shipment of radioactive materials do not
demand any special containerization of the Montclair, West Orange, and Glen
Ridge soils. If, through source separation, materials are segregated so
that the average activity of soils for shipment approaches the limits
imposed by transportation regulations, they must then be containerized to
meet shielding requirements.
Appropriate containers include 55-gallon drums, steel boxes, or wooden
crates. Drums are readily available and are a safe method of transporting
the soil since they can be sealed and lined, if necessary. The volume of a
55-gallon drum is small; it holds slightly more than 7 cubic feet or
approximately 1/4 cubic yard. The quantity of drums necessary to transport
the wastes, therefore, would be in excess of 500,000. This estimate does
not include containerization of other materials, such as excavated pave-
ments or rubble from buildings, which may also require disposal.
Other containers include B-12V steel boxes. These have a capacity of 44
cubic feet, therefore fewer of them would be needed, reducing the time
required for loading, handling and record-keepng. Wooden crates are not as
strong as steel boxes; the largest allowable crates have a gross weight
limitation of 500 to 550 pounds depending on the type of wood. This would
allow a maximum of 5 cubic feet of soil to be transported, less volume than
that of a 55-gallon drum. Wooden crates are less suitable containers and
are not considered further.
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Containerizing the soils is mechanically more complex than shipping in
bulk. It is also more costly, both in the equipment and materials required
and in the amount of time and labor needed. Containerized soils would be
more expensive to transport. The loading requirements of the transporta-
tion regulations would affect the option selected.
Another approach, related to containerization, is to bind the soils into a
solid block. Solidification will have the benefits of reducing radiation
and radon exposure to workers handling the blocks and reducing radon flux
and leach rates of radionuclides when the blocks have been disposed of. As
with containerization, needs for equipment, materials, time and handling
would be increased. A plant would be required for the solidification
process. Solidification is discussed more fully under matrix immobiliza-
tion (Section 2.1.8).
Transport Options
There are two options for the removal and transport of the soils: direct
loading/unloading and use of transfer stations. Transportation by truck
will not necessitate use of a transfer station unless weight limitations
force the use of small dump trucks at the site. This requirement would
force a transfer of the load to larger, more economical dump trucks at an
offsite loading facility.
Transport by rail necessitates use of a transfer station at the rail yard
near the site, where soils will be transferred from dump trucks to rail-
cars. The option of transferring trailers directly to flatcars (TOFC)
would not be feasible for bulk shipment of the soils but could be used for
the containerized soils. The trailers could be transferred to flatcars
when the remaining soils are transferred to the gondolas or hopper cars.
2.1.6 INTERIM STORAGE
Interim storage of contaminated soils may be required while a permanent
disposal facility is sited and constructed. Storage options considered
must prevent dispersal of contaminated material by wind or runoff and limit
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radon emanations to levels developed by DOE for their FUSRAP sites. They
must also limit gamma radiation exposures to workers and the general
public.
Uncovered Pile
Options that include uncovered storage piles were not considered since they
provide no protection from dispersal or radon emanations.
Covered Pile
In this alternative, excavated soil would be received at the storage site
and deposited in bulk on an asphalt pad. Asphalt is less expensive and
more durable than materials such as rubberized or plastic liners. The pile
would be covered with a plastic liner and a layer of topsoil for protection
from dispersal by wind and rain. Radon emanation would be attenuated by
the Liner and the layer of topsoil. The topsoil would also serve as a
shield from gamma radiation exposure.
The interim storage site at Middlesex, New Jersey, is based on this design,
excluding the covering layer of topsoil. Current monitoring of the site
demonstrates the design to be successful.
Since the pile would not be covered during construction, and because of the
possibility of splits in the liner, a leachate collection system should be
considered with this option. This issue is discussed in Section 3.2.2.
The covered pile option was considered further.
Outside Storage of Containerized Soils
Containerized soil would be received at the storage site and placed on an
asphalt pad. If B-12V boxes are used, each container would be covered with
a steel plate bolted into place. If drums are used, they would be covered
with steel lids and closed with lock-rings. Blocks of solidified soil
would be covered by tarpaulins or plastic sheet to prevent weathering.
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Containers would be separated by enough space to allow visual inspection of
each container, and would be placed on steel railings to prevent contact
with the ground surface and facilitate removal of the containers.
This option provides greater protection for workers at the storage site and
for the public, since the soil is completely contained upon arrival and
would not require direct handling. There is no potential for dispersal by
wind or rain, and both radon emanations and gamma radiation would be
attenuated. In addition, subsequent removal of the soil would be greatly
facilitated. This option was considered further.
Indoor Storage
Under this option an air support or frame support building is assembled on
a pad and the soil pile or sealed containers are stored inside the struc-
ture. The advantage of this storage method is that it provides an addi-
tional measure of. protection to the materials stored. The additional
radiological advantage to receptors outside the building is negligible.
There will be an increase in radon concentrations inside the building.
This option was considered further.
Moored Cargo Ships
Cargo ships of large capacity would be purchased or leased for the duration
of storage. The contaminated soil would be drummed and palletized before
loading, and provisions made to structurally support the bottom layers to
prevent crushing of the bottom drums and to allow visual inspection of the
drums. Bulk loading the soil directly into the cargo holds is also a feas-
ible alternative. This raises the additional concern of decontamination of
the vessels. On-board personnel would provide security and maintain ship-
board functions. This option provides the advantage of limiting the size
of the exposed population. Additional shielding measures would have to be
taken for the protection of the shipboard crew. This option was considered
further.
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Existing POD or DOE Facilities
There are a number of Department of Defense (DOD) and Department of Energy
(DOE) low-level radioactive waste sites operating throughout the United
States. Three DOE sites are within 30 miles of the Radium sites: Middle-
sex, Maywood and Wayne, New Jersey. A fourth DOE site is at Canonsburg,
Pennsylvania. The option of storing the wastes from the study areas at one
of these sites will be subjected to further screening.
2.1.7 VOLUME REDUCTION
Reduction of transportation and disposal costs for the contaminated soils
removed from the Montclair/West Orange and Glen Ridge Radium Sites may be
achieved by reducing the volume of material to be handled. The result
would be a smaller volume of more concentrated radioactive waste to trans-
port and dispose, and a volume of materials of much lower activity subject
to disposal as nonradioactive waste.
Technologies identified for volume reduction can be classified as chemical
recovery of radionuclides or as physical separation of materials into frac-
tions of different activities. These are discussed below.
Chemical Recovery of Radionuclides
For the chemical recovery of radionuclides, volumes of soil are treated
with strong acids or bases to extract the metals from their solid matrix.
The resulting extract can then be concentrated by evaporation or treated
further to precipitate the metals.
Carbonate leaching is a traditional process used in the uranium processing
industry to extract uranium from ore tailings. Radium and thorium are ex-
tracted poorly. Carbonate leaching is inappropriate for this site since
the contaminants requiring extraction are radium and thorium.
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Sulfuric acid leaching is another traditional process for uranium extrac-
tion. Radium and thorium are also efficiently removed from ores and tail-
ings using sulfuric acid. The remaining residue is highly acidic.
Phosphate leaching is a nev/er process than carbonate or sulfuric acid
leaching and is still in the experimental stage. It has been demonstrated
to remove both thorium and radium from acid leach tailings.
These processes can be employed in heap leaching or in more complex process
trains. In heap leaching, the materials are placed on an impermeable pad
and the extracting reagent allowed to percolate through the pile. The
leachate is collected by a passive system for further processing. More
complex systems would control a variety of process parameters such as
temperature, agitation rate, or holding time, in a sequence of operations
to improve the efficiency of the extraction.
The processes identified above have been applied to refuse piles resulting
from uranium extraction processes with the goal of economically reclaiming
the remaining radionuclides for resale. Because activities of the
Montclair/West Orange and Glen Ridge contaminated soils are so low, re-
covery for resale is not feasible.
Chemical recovery of radionuclides should be considered technically un-
feasible, based on the following concerns:
o Proven technologies have been developed for materials with
much higher activities than those in the radium sites. Low
concentrations require longer holding times and result in
larger volumes of more dilute solution.
o Proven technologies have been developed for the sandy tail-
ings resulting from uranium processing. The response of the
contaminated material found at these sites (radioactive fines
mixed in a soil or ash matrix) towards acid treatment is un-
known and will need to be determined by laboratory testing.
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o Acid leaching will result in a large volume of acidified
residue that will require further treatment before disposal.
o Any chemical process scenario will require piloting, design
and permitting. If no facility is available within the pro-
jected remediation time frame, design and construction, with
its additional permitting and zoning requirements, will add
to the time and expense.
o Should institutional considerations allow the siting of a
process facility, problems of decontaminating equipment and
decommissioning the facility remain to be addressed.
Physical Separation
Separation by Particle Size and Density. Laboratory analysis of soil
samples from the three radium sites demonstrated that most radioactivity
was found in the silt fractions (smaller than 200 mesh) and that larger
particles (8 mesh and larger) were mostly free of contamination. While
sieving is impractical for the large quantity of soil to be excavated,
other methods based on particle size and density may be used to remove the
coarser fraction from the more radioactive fines.
Air separation techniques involve feeding material onto a screen (or per-
forated plate) at a relatively low rate and blowing air at low pressure up
through the screen at sufficient velocity to carry the lighter particles
(e.g., silt) into a second chamber. The heavy material (gravel and sands)
is discharged from the end of a screen into the hopper.
A common approach uses a vibrating screen that separates materials of
different density by the frequency of the screen oscillations. This separ-
ation occurs on the surface of a sloped screen, causing the denser material
to proceed from the inlet to the discharge end of the screen while the
lighter material remains on the screen.
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Inertia! separators accelerate particles, which then travel distances
characteristic of their mass£s. Heavier, inorganic particles travel
farther than light or organic particles.
Flotation separates particles of different densities suspended in a liquid
medium. Settling rates are controlled by the density of the liquid and by
aeration, which provides additional buoyancy to the smaller particles.
The processes described above would require extensive piloting to determine
the response of the complex mixtures found at the three sites. Although
some separation could be achieved, the overall usefulness of particle
separation is questionable. Both contaminated and noncontaminated samples
have been shown to contain particles of the same sizes, although size dis-
tributions differ. For example, the lowest and highest radioactivities
were found in brown and white sands, respectively. These sands are not
separable by particle size or density. Furthermore, each method would
leave contaminated material suspended in an air or water stream, requiring
treatment. This technology is not considered further.
• •
Ion Exchange. In the ion exchange process, a liquid stream, usually
aqueous, with a low concentration of metal ions, is passed through a bed of
ionic resin. The metal ions adsorb on the resin at a rate dependent on the
concentration of the ion in the liquid, the relative affinities of the ion
for the liquid and resin phases, and the number of available binding sites
on the resin. The resin can then be disposed of in its wet form or it can
be incinerated and the ash disposed.
The ion exchange process has proven to be successful for a number of wast-
ewaters containing metals and should be considered as a feasible technology
in itself. However, it does require a liquid stream to convey the ions.
For the current study, this would require producing a leachate from the
contaminated soils. As leaching was ruled out as a remedial technology in
section 2.1.7.1, the application of ion exchange was not considered
further.
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Bulk Separation. In bulk separation, excavated materials are carried to an
area of low radioactivity or to a shielded pad and scanned for gamma
activity. Materials with activities that indicate contamination above
standards are separated from materials with lower activities. Soils with
low activities would be disposed of under less stringent standards or left
at the site.
Fill material, particularly ash and cinders, has been identified as the
most highly contaminated matrix at the three radium sites. Visual identi-
fication can be used to assist in identifying materials for separation.
Areas of high radioactivity must be characterized in detail for depth and
distribution of contaminants during predesign work. Beside being necessary
for the design of the remedial excavation, the results of the characteriza-
tion will determine the detailed mechanics and feasibility of bulk separa-
tion. If volumes of contaminated material are not distinct enough to be
separated or are too scattered, or if the overall volume reduction would be
small, bulk separation may be unfeasible. Current knowledge of the dis-
tribution of contamination suggests that highly contaminated soil is found
in discrete locations within the fill and is a small portion of the total
amount of soil to be removed. There is evidence that some of the con-
tamination is actually in the form of small nodules made up of extremely
concentrated and fine grained radioactive material adhered onto lumps of
ash and cinders.
Bulk separation will be retained as an option, but, since it is integral to
the excavation option, should be considered as a part of the excavation
design.
Bulk Mixing. In addition to bulk separation of soils at the source,
materials slightly above regulatory standards can be mixed with materials
below the standards to dilute their activity. The desired result is to
reduce the amount of material above the standards which must be removed.
Materials with activities below the standards may remain onsite. This
process is technically feasible, but, as it is an extension of bulk
separation, should also be considered as part of the excavation design.
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Dilution. The contaminated soils could be mixed with clean fill to dilute
the radionuclide concentration to levels below standards. The resulting
mixed fill would not be subject to the same disposal restrictions as the
soil at the sites.
There are several technical drawbacks to this approach. Large volumes of
clean fill will be required to dilute the radionuclide concentrations in
the soil to levels which meet standards. For example, if the radium
standard is 15 pCi/gm, based on 40 CFR 192, and the clean fill has a con-
centration of 1 pCi/gm, then 1.61 million cu. yd. of clean fill would be
required to dilute the soil. The large volume of clean fill to be obtained
and mixed fill requiring disposal is clearly prohibitive. The transporta-
tion and handling requirements for the clean fill alone would be over 13
times the requirements for the undiluted excavated soil.
In addition, dilution may not succeed in spreading the radium among the
fill. Analysis of split-spoon samples taken in the remedial investigation
suggests that contamination may be concentrated in discrete nodules of
material. These nodules may remain intact through the mixing process,
producing high local radioactivities in the mixed fill.
The dilution method of reducing radionuclide concentrations will not be
considered further.
2.1.8 IMMOBILIZATION OF RADIONUCLIDES
Immobilization of radionuclides has three potential benefits:
o Leachability of the radioactive metals is reduced because of
increased binding with the matrix.
o Radon emissions are diminished by lower material porosity.
o The resulting solid product is more easily handled and less
subject to dispersal.
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The two major approaches to immobilization of radionuclides are vitrifica-
tion and matrix isolation.
Vitrificaton
Vitrification is a process whereby the soils would be partially or com-
pletely melted to obtain a vitreous (glass) slag-like material. Vitrifica-
tion methods require high temperatures and large amounts of energy to drive
off water and melt the contaminated residues. The two vitrification tech-
nologies identified below require removal of the contaminated soils to an
offsite facility. In-situ vitrification has been discussed in Section
2.1.3.
Electric Furnace Fusion. Electric furnace fusion can be used to melt the
contaminated soils to a form that can be poured into molds and cooled. The
product, a composite of glass and crystallites, could then be buried. The
vitreous product is more stable relative to leaching, radon emissions and
structural changes (as discussed in Section 2.1.3) than the soils.
Radioactive and nonradioactive offgases are generated during heating, and
these must be treated. The process itself will require large amounts of
electric power (as discussed for in-situ vitrification).
Rotary Kiln. Coal-fired rotary cement kilns can be used to sinter the
contaminated materials. This requires a less expensive energy input than
the electric furnace, with the same advantages with respect to the product.
Locations for siting are limited by the need to stockpile large amounts of
coal (a total of approximately 8000 tons). Appreciable amounts of fly ash
and scrubber sludges would be generated, increasing waste handling and
disposal requirements.
For both processes, facilities must be located or constructed. This will
require piloting of the process to characterize the process parameters and
the nature of the product and waste streams. Permitting is also required.
Problems of equipment decontamination must also be addressed.
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These processes are technically unfeasible: electric furnace fusian,
because of the power requirement; and rotary kiln sintering, because of the
waste streams produced.
Matrix Isolation Methods
Matrix isolation methods consist of mixing the radioactive material with
some other material that hardens into a solid. This solid material can
then be buried. Matrix materials that have been used include asphalt or
bitumen, cements and polymers such as urea-formal del dye resin. Such
methods have been used routinely for shorter-lived low-level radioactive
wastes. Most solidification systems in the United States now use either
cement or organic polymer resin as the solidification matrix.
Bitumen or asphalt.
Asphalt (bitumen) can be mixed with contaminated soils and the temperature
raised to drive off water. The molten material is poured into molds, or
pits, where it solidifies. Either commercial emulsified asphalt or molten
base asphalt can be used. A number of methods "for mixing asphalt with soil
(continuous or batch process) and evaporating the liquid have been
developed. All are technically feasible. This process requires no heat to
expel water.
Asphalt has the advantage of good coating and adhesive properties, and it
is insoluble in water. It is chemically inert, resistant to ionizing
radiation, and reduces the rate of radionuclide leaching 100 to 1000 times.
The increase in volume due to the matrix is small compared to the other
immobilization techniques. Disadvantages to the use of asphalt occur in
regard to process requirements and safety. Heating bitumen releases fumes
that pose toxic inhalation and dermal hazards. Mixing is complex and
requires strict temperature control. Hot asphalt is a fire hazard; its
fumes are also combustible. Asphalt processes produce a wastewater high in
organic contaminants, requiring additional waste treatment processing.
Wastewater resulting from processing soils from the radium sites would also
be radioactive.
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Cement. Portland cement can be mixed with radioactive soils. Various
additives can be used to improve the properties of the final product. The
cement process is cheap, mixing is simple, equipment costs are low and no
heating is required. Processing can take place at the source or at the
disposal site, using conventional cement-mixing equipment. Cement is a
very good radiation shield. However, although the chemical and physical
properties of cement are well known, the properties of the final product
will be influenced, and probably not improved, by the characteristics of
the soils mixed into it. It will not greatly reduce leaching of radio-
nuclides or radon emanations. It does, however, have the advantage of
diluting the radiation source.
Resins. Radioactive soils can be mixed with urea-formaldehyde or other
organic resins and catalyst either in reactors or in disposal receptacles.
Polymerization can take place at ambient or elevated temperatures, depend-
ing on the resin-catalyst system selected. The resulting solid does not
bind the mater.ials chemically; rather, the soils are trapped in voids
formed by the long-chain molecules of the polymer.
The polymerization process is simple and the technology well developed.
The polymer will reduce Teachability and may reduce radon emanations. The
solid will not be subject to dispersion. Disadvantages are that the radio-
active solids need to be dewatered before mixing, and may need to be com-
pletely dried. If structural stability of the product is of concern, the
polymerization process will need to be controlled for pH and proper mixing.
Resins with long curing times will allow the soil materials to separate
into areas of different density.
All three methods have been demonstrated to be reliable matrices for
low-level radioactive wastes. Both asphalt and cement matrices can retain
their structural integrity for up to 200 years. However, the increase in
volume due to the matrix is approximately 30 percent. This increase will
be reflected in increases in transportation requirements. Each of the
three options require that the product be formed in some sort of container,
further increasing handling requirements.
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The matrix isolation options are acceptable from a technical standpoint and
will be carried on for further screening.
2.1.9 PERMANENT DISPOSAL
The most recent EPA guidelines on selection of an appropriate facility for
off-site management of hazardous substances requires that a judgement be
made as to the overall acceptability of the facility to receive the sub-
stance and the acceptability of the containment unit within the facility
that will receive the hazardous substance. Disposal of radioactive
material is generally controlled at this time by the Department of Energy
(DOE) and the Nuclear Regulatory Commission (NRC). EPA, under the Reor-
ganization Plan No. 3, 1970, has the authority for regulating radioactive
waste not regulated under the Atomic Energy Act of 1954. While radium is a
licensed material under the 1954 Act, NRC has no authority over it and DOE
control has been limited to its management of LLW disposal sites and the
regulations it has implemented through such clean-up programs as its
Uranium Mill Tailings Radiation Control Act (UMTRA) program. As of this
time, EPA has not dealt with radium disposal. However, the EPA is in the
process of developing generally applicable environmental standards for land
disposal of low level radioactive waste and the regulations will cover
disposal of radium as a Naturally-Occuring and Accelerator-Produced Radio-
active Material (NARM). The expect to publish their proposed standards for
public comment in early 1986.
RCRA-Permitted Facility
Radium is not listed as a RCRA controlled substance. There was a question
as to whether the soils at Montclair/West Orange and Glen Ridge could be
considered RCRA wastes if they were mixed with a listed waste or exhibited
one of the RCRA characteristics of ignitability, reactivity, corrosivity or
EP toxicity. However, samples were subjected to all the RCRA tests and the
soils have not proven to be RCRA wastes.
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Since there is no explicit federal regulations for radium disposal at this
time, disposal of radium is controlled by the individual states in their
permitting of disposal facilities. Radium contaminated soils may be dis-
posed of in a RCRA facility providing it is permitted for that waste and is
in compliance with the most recent RCRA requirements and all other appli-
cable requirements of the laws governing radioactive substance disposal.
One of the RCRA facilities closest to the sites is the SCA facility in
Model City, New York, which at this time is not permitted to take radium
wastes. Discussions with the operators indicate that the facility is not
likely to modify its permit, given that the waste is regulated by other
authorities and that other legal disposal units are available.
In addition to the points discussed above, RCRA facilities are not appro-
priate for the long-term control of the radium-contaminated soils for three
other reasons. First, the type of groundwater control achieved by the
double lined, leachate collection and monitoring well systems required for
RCRA facilities is too stringent considering the environmental hazards and
migration potential of these soils. Second, the type of cover specified
for RCRA facilities may not be sufficient to reduce the radiation and radon
concentration at the surface to acceptable levels as specified under 40 CFR
192. Third, and most importantly, the duration of control required by the
RCRA regulations does not meet the control standards set by 40 CFR 192 for
uranium mill tailings. Radium-226 has a half-life of 1620 years so control
requirements attempt to offer protection to the public for up to 1000 years
and to show conformance to acceptable control criteria for at least 200
years. RCRA facilities do not have such lengthy post-closure periods
during which monitoring is required. For these reasons this option was not
considered further.
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Department of Defense Facility
Use of a Department of Defense (DOD) facility for disposal or storage of
non-DOD owned hazardous materials is prohibited by DOD policy directive
6050.8 (August 24, 1981) (see Attachment 2) and through the 1984 Military
Construction Authorizaton Bill, P.L.98-407 Section 805. Exceptions are
allowed through the Assistant Secretary of Defense (Manpower, Reserve
Affairs, and Logistics) who may grant exceptions if such action is essen-
tial to protect the health and safety of the public from imminent danger
and such action does not compete with private enterprise. Since the con-
straints on the use of DOD facilities are institutional, negotiations for
an exception would be the responsibility of the EPA and DOD.
Should the action be considered necessary to protect public health, the
policy emphasizes that the use of DOD facilities can only be for temporary
storage and will be terminated once the emergency situation "no longer
exists." Therefore, this option was not considered further for either in-
terim storage or final disposal.
Department of Energy Facility
There are several existing Department of Energy (DOE) facilities in the
general area of the Montclair, West Orange and Glen Ridge sites. Three are
in New Jersey (Middlesex, Maywood and Wayne) and are being remediated under
the FUSRAP (Formerly Utilized Site Remedial Action Plan) program of DOE.
One is located in western Pennsylvania at the Canonsburg site, a DOE reme-
diation under its UMTRA (Uranium Mill Tailings Remedial Action) program.
Each site has a contamination problem similar to that at the Montclair/West
Orange and Glen Ridge sites. The Middlesex, Maywood and Wayne sites are
being used for interim storage of excavated soils in a controlled, covered
pile. At the Canonsburg site, the contaminated soils are being permanently
encapsulated in the disposal facility constructed at the site.
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The option of using an existing DOE Storage Site was passed on for further
screening.
Licensed Commercial LLW Facility
There are presently three active licensed disposal sites for commercial low
level waste: Beatty, Nevada; Richland, Washington; and Barnwell, South
Carolina. Barnwell is not permitted to receive radium wastes and will not
be considered further.
Both the Beatty and the Richland facilities have permits to take the radium
226, thorium 230 and uranium 234/238 wastes. At Richland, wastes are only
accepted in containers and only 25,000 Ibs of source material (radium and
thorium) can be placed in the disposal trenches before they are covered
with a minimum of 8 feet of soil. Beatty will accept shipments of bulk
soil or containerized soil and will accept up to 16,300 Ibs of source
material before being covered with a minimum cover of 3 feet plus 2 feet of
soil mounded over the trench.
A question exists regarding the appropriateness of using the engineering
controls offered by LLW facilities for the relatively low-activity radium-
contaminated soils. LLW facilities are designed for a much higher radio-
active hazard, and disposing of the low-activity soils in such facilities
would be extremely wasteful of the limited LLW storage space left in this
country. Both sites have a minimum total activity requirement of 2 pCi/g
(2000 pCi/g). The Montclair/West Orange and Glen Ridge soils have been
conservatively estimated as containing about 200 pCi/g of radium-226 and
some soils may have a total activity approaching the 2 pCi/g limit, but it
is doubtful that the entire shipment would meet this requirement.
Technically speaking, both facilities can accept the material, therefore,
the use of both facilities will be carried on for further screening.
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Designed Encapsulated Disposal Facility
A new encapsulated disposal facility complying to 40 CFR 192 regulations
could be constructed to permanently control these soils and reduce any
future environmental or public health impacts. The design of such a dis-
posal facility could follow the existing DOE conceptual design developed
for the UMTRA program. Such a facility is presently being constructed at
the Canonsburg, Pennsylvania, site and is believed to offer more than ade-
quate protection of public health with erosion-proof barriers designed to
insure long-term control of the radionuclides. It will be carried on for
further screening.
Roadbed Dispersal
One of the situations under which 40 CFR 192 regulations would allow appli-
cation of supplemental standards is the case of tailings buried under hard
surface public roads. It is clear that EPA considered the health hazards
of such situations to be limited and that long-term control could be
assured, since roads would probably not be reexcavated to build residences
or occupiable buildings. The majority of the contaminated material at the
Montclair/West Orange and Glen Ridge sites appears to be easily compacted
and suitable for use as structural fill. Because of this, and the agency's
acceptance of tailings under public roads, disposal of the contaminated
material under roadbeds is addressed.
To achieve the length of control specified by the relevant 40 CFR 192
regulations, it is assumed that only newly constructed interstate highways
would be appropriate for such dispersal, as the chances of new highways
being re-routed and reexcavated are less than for other types of roadways.
However, the existing highway construction projects in New Jersey are cut
and fill projects that will probably have a net surplus of fill. Even if a
need for fill exists, it would only be in low areas prone to flooding,
(e.g., wetlands in the northern New Jersey project for the extension of
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Route 287) and would produce questionable environmental impacts on surface
and groundwater systems in those areas. In addition, a potential hazard to
workers who could be exposed during any major reconstruction of the highway
would still exist. For these reasons, roadbed dispersal was not considered
further.
Mine Burial
Disposal of the radium-contaminated soil in a deep underground geological
repository (i.e., an existing worked-out mine) is a viable option; the
stability and appropriateness of such formations for long-term disposal
have been studied by the NRC for quite some time. However, such action is
not warranted given the low activity of these soils. Deep geological
disposal is normally considered applicable to such high-hazard waste as
spent nuclear fuel, high-level and transuranic waste.
Furthermore, there are not that many deep mine areas available in New
Jersey. Most of the mining is relatively shallow trap rock mining. There
are three potential deep mine areas: Franklin mines (Franklin Borough),
Mount Hope mines (Rockaway Township), and the Ringwood mines (Ringwood
Borough). The Franklin mines are still in use and it is not expected that
the owners would be willing to release them as disposal sites. The Ring-
wood mines are now all closed and plugged. Some also contain chemical
hazardous wastes and mixing of the radioactive soils with such waste would
not be advisable. The Mount Hope mines are the only available mines, and
once again, it is not expected that the private owners would want to re-
lease them as long-term repositories, precluding any future use of the
mines for other purposes. The water in the Mount Hope mines was proposed
by NJDEP for use during the 1980-81 drought as an auxiliary drinking water
supply. There is also talk, though it is still in the planning stage, of
using the mines as a pump storage facility for generation of hydroelectric
power during peak electricity demands.
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In summary, while deep mine burial would accomplish the control objectives,
it is not warranted for such low-activity waste, especially since the mines
have exhibited potential for use as alternate water and energy supplies.
Ocean Disposal
Technical considerations show that ocean disposal, as an option for perman-
ent disposal of the soils after interim storage, is feasible.
The methods described are based on existing procedures utilized by dif-
ferent authorities for the ocean dumping of sewage, industrial sludges
flyash, dredged materials and excavated soils, and should therefore be
considered to be proven technologies.
Disposal may follow one of two options, either dispersal of loose soil or
containment on the sea bottom, depending on the selected disposal site and
the institutional and regulatory requirements that are imposed. It would
be desirable to package the soils so that neglible leaching or dispersal of
materials would take place until the radionuclides present decayed to in-
nocuous levels. Because of the long half-lives of thorium-230 and radium-
226, it would be more reasonable to rely on natural dispersal mechanisms
and the relatively low initial concentrations of the radio nuclides to
limit the increase in radioactivity at the disposal site. Containerization
or matrix immobilization of the soils should still be considered as their
use would restrict the hazards of dispersal to the deep waters at the site.
Loose soil could be loaded onto the barges with clamshell buckets or by
conveyor belt or dumped directly onto the barge. Containment could be in
dedicated container ships or could be satisfied by cementing the soil into
concrete blocks. If the latter is the case, cementing would be done at the
interim storage loading facility, and the blocks would be transported on
flatbed trucks and loaded onto barges using crawler cranes.
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The barges or container ships would be towed to the site by oceangoing tugs
secured by contract. Barges will be the bottom-dump type and dumping would
occur while the barge is under tow, under the supervision of the regulatory
authorities. After dumping, barges would be decontaminated with ocean
water at the dumpsite. The location of the dumpsite has not yet been
determined but most definitely will be within the 200 mile authority zone
of the United States.
A number of wharves of sufficient draft for barges are located within 30
miles of the sites, therefore transportation costs would be relatively low.
Dock facilities could be easily secured by contract with the owner/operator
of the selected facility. The wastes would be transported to the port in
16-yard dump trucks. Decontamination facilities for the trucks will have
to be constructed at the dock. Fugitive dust emissions could be controlled
by keeping soil surfaces moist using ocean water, and runoff could be
collected, settled to remove particulates and discharged into surrounding
waters. Runoff could also be used in place of ocean water to control
fugitive dust emissions.
Barges dedicated to the project could each carry a maximum load of 4500
tons (3000 cubic yards), requiring a minimum of 41 barge loads.
In conclusion, ocean disposal appears to be technically feasible for the
final disposal of the Montclair/West Orange and Glen Ridge soils and will
be analyzed further.
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2.2 ENVIRONMENTAL. PUBLIC HEALTH AND INSTITUTIONAL SCREENING OF
REMEDIAL ACTION RESPONSES
The remedial action technologies that have passed technical screening have
been formulated into response actions and are listed in Table 2-2. The
next step in screening is to consider noncost factors (i.e., environmental
and public health impacts and institutional constraints) affecting imple-
mentation of each response.
2.2.1 SOURCE ISOLATION
Encapsulating the contaminated soils on site with a cap of clean earth, or
earth and plastic sheet, and a liner suitable to site conditions, will
satisfy public health criteria by reducing gamma emissions and radon
emanations to near background levels, and eliminate the potential for dis-
persal by wind.
These measures will not cause any significant environmental deterioration,
but improvement will be marginal, at best, since no environmental effects
have been demonstrated for the exposures at the three sites. Human intru-
sion can be further limited by erecting a fence around the encapsulated
area. Institutional control and maintenance will be required to preserve
the integrity of the remedial alternative. This maintenance should not be
considered as an institutional constraint peculiar to encapsulation since
any land-disposal or storage option faces this problem.
Separate encapsulation is not appropriate for the smaller volumes scattered
throughout the three sites. These may be excavated and encapsulated with
the majority of the contamination at a centralized location on-site.
Public health and environmental risks resulting from excavation are dis-
cussed in Section 4.
A centralized storage cell will require the purchase of some residential
properties. While normally avoided by EPA, this action may be appropraite
for these sites. The purchase of these homes is not for the purpose of
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TABLE 2-2
REMEDIAL ACTION RESPONSES FOR NONCOST SCREENING
I. Onsite Control Responses
A. Source Isolation
1. Encapsulation
B. Protection of Receptors
1. Active/Passive Measures
2. Relocation
II. Removal and Off-Site Treatment/Disposal Responses
A. Excavation with standard earth-moving equipment
B. Transportation and Handling
1. Vehicles
a. Truck
b. Barge
c. Rail
2. Containerization
a. Bulk
b. Drums
c. Metal boxes
3. Transport Options
a. Direct loading/unloading
b. Transfer station
C. Interim Storage
1. Covered pile
2. Outdoor covered containerized soil
3. Covered steel containers
4. Indoor storage
5. Moored cargo ship
6. Existing DOE facilities
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TABLE 2-2 (Continued)
D. Immobilization of Radionuclides by Matrix Isolation
1. Bitumen or asphalt
2. Cement
3. Resins
E. Disposal Options
1. Department of Energy facility
2. Licensed commercial low-level waste facility
3. Designed encapsulated disposal facility
4. Ocean disposal
(6H6/14)
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removing receptors, as it was at Love Canal and Times Beach. The purchase
of properties at the Radium sites is proposed in order to construct a
facility and may be allowable on the principle of eminent domain. It will
be considered as a disposal option in the final evaluation of remedial
alternatives and will be costed as such.
2.2.2 PROTECTION OF RECEPTORS
Active/Passive Systems
Ventilating enclosed spaces, installing passive trench vents, and sealing
openings that provide routes for radon to enter will serve to reduce radon
progeny working levels in affected homes. Shielding can be added in those
homes with elevated gamma activities, although shielding outdoor areas is
less feasible.
In addition to the technical difficulties with this option, described in
Section 2.1.2, there is a major institutional objection. EPA regulation 40
CFR 192 limits the use of active measures, such as ventilation of air
cleaning, to cases where the unremediated working level is less than 0.03.
All Tier A and B and most Tier C homes, as defined in Section 1.3.4, are
ineligible for active measures as an option for permanent remediation. In
addition, homes remediated by active measures require mom'tori'ng of radon
progeny in the home. The sentiment favoring the inviolability of a
person's home runs deeply enough to be regarded seriously as an institu-
tional constraint. Experience at the three radium sites shows that a
number of homeowners object to the repeated intrusions of investigation and
monitoring. The number of refusals is likely to increase as the program
continues, hampering its effectiveness.
Restrictions on construction around the home will have to be instituted and
there is the possibility that future resettling of the houses may cause
additional homes to need systems and monitoring.
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The active and passive engineering response will meet the public health
goals of eliminating the elevated radon and gamma exposures but it will not
meet relevant environmental standards. Such technologies do not prevent
dispersal of contamination by wind, water or human intrusion. However,
since CERCLA guidance allows consideration of alternatives that prevent or
minimize threats to public health but do not attain relevant environmental
standards, this response option will be carried on to cost screening.
Relocation of Receptors
Relocation of receptors is another response that would eliminate the
elevated radon and gamma exposures meeting public health goals but not
achieving, the relevant environmental standards. Dispersal of contamination
would still be possible as stated above for active/passive measures. This
action would rely chiefly on institutional controls to restrict public
exposure to the contaminated soil. The EPA policy on the role of
institutional controls is described in the Federal Register notice of the
40 CFR 192 standards. The Agency "considers that protection from long term
hazards associated with radioactive waste should primarily rely on passive
control measures." Institutional controls are useful as "secondary control
measures" only.
A major institutional objection to this response action is the opposition
the public may present at the prospect of abandoned properties within the
residential commuhities of Montclair, Glen Ridge and West Orange. .Resi-
dences could be demolished and the property graded and even landscaped, but
the land would still have to be restricted and fenced from the public.
In spite of these environmental and institutional objections, this option
will also be carried on to cost screening as it meets the CERCLA guidance
and will effectively minimize the current public health threat to the resi-
dents at the sites.
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2.2.3 EXCAVATION WITH STANDARD EARTH-MOVING EQUIPMENT
Excavation of the soils by conventional methods is the only technically
feasible method for removing the source material. It is also the insti-
tutionally preferred option for dealing with the source of the radiation
hazard. There will be transient negative environmental impacts during
excavation but no permanent deterioration if the sites are properly re-
stored. There will be no significant public health impact during the
excavation, and removal of the source will result in reducing public health
risks to acceptable levels. Environmental and public health impacts of
excavation are discussed more thoroughly in Section 4.
Bulk separation or mixing with soils of lower activity to reduce the volume
of soils requiring disposal will take place during excavation. The posi-
tive impact of these processes will be reduction of the amount of material
transported and handled at the disposal sites. Negative impacts will be
lengthening of excavation time, with a proportional increase in risks.
Comparison of the benefits of volume reduction to the risks of extending
the excavation period are deferred to the remedial design.
2.2.4 TRANSPORTATION AND HANDLING
Vehicles
All three transport modes are acceptable from public health and environ-
mental perspectives since they will not greatly increase traffic outside
the immediate area of the sites. Institutional restrictions will be local
and cannot be addressed adequately until destinations and routes have been
selected.
Accident scenarios have been developed for both rail and truck transport
options. Rail transport appears to be a much safer method based on number
of accidents per veicle mile travelled. This is undoubtedly due to the
smaller volume of traffic and low population density along transit routes.
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Removal of the soils from the individual towns by truck would require that
towns provide variances from their imposed weight limitations. Weight
limits of 4 tons have been imposed by the Town of West Orange. Glen Ridge
and Montclair do not have any weight limitations and go by county restric-
tions. The only county road in the area that has a weight limit is Eagle
Rock Avenue which is not necessary for use in this project.
Because town garbage trucks, comparable in weight to 16 yard trucks, are
used on these same streets, a variance to the imposed weight limitations
will be requested. From an engineering standpoint, it appears that 16-yard
dump trucks, carrying a maximum load of 14 cubic yards, can be used to
transport soil out of the towns. Further, the trucks need not travel more
than a few blocks to reach the unrestricted county roads.
Containerization
The proposed containerization options (bulk loading, drums and B-12V boxes)
are explicitly permitted by federal regulations. They are therefore
presumed to have no adverse environmental or public health impacts. No
institutional constraints are foreseen. All three options will be costed.
Transport Options
Any handling of contaminated material increases the public health and
environmental risks involved. However, these risks are more strongly
affected by the form of the material and type of containerization than by
the number of transfers of material. Institutional constraints will be
local, and depend on the specific scenario proposed. In the absence of a
detailed scenario, analysis of transport options will be deferred to the
remedial design.
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2.2.5 INTERIM STORAGE
Covered Waste Pile, Covered Steel Containers, Indoor Storage
These three interim storage options were selected for screening because of
their negligible adverse public health and environmental impact. Insti-
tutional constraints on the use of these options will result from siting
considerations, rather than the option itself. These options are screened
for cost under Section 2.3.
Moored Cargo Ships
It is difficult to predict the public health and environmental impacts of
this option. Exposure will be limited to a small group of workers during
loading and maintenance of the vessels. The ships will then be moved away
from the loading area and moored.
The public health risks from the contaminated material may not justify the
cost of setting up and maintaining these" facilities. Locating a safe
mooring spot for approximately 10 ships, away from shipping lanes, must be
considered as a potential obstacle.
This option is also screened for cost.
Existing DOE Facilities
There are several existing DOE sites in the area of the Radium sites. The
general DOE policy has been that commercial low-level waste will not be
accepted at DOE storage sites. It is not clear if storage of EPA-generated
waste must conform to this policy.
Correspondence with DOE officials (provided in Attachment 3) has resulted
in the following list of institutional objections to using a DOE facility
for disposal of the contaminated soils from Montclair/West Orange and Glen
Ridge:
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DOE policy avoids the situation in which the commercial waste
disposal facilities are pre-empted in their business
opportunities by the federal government.
DOE policy is to not pre-empt a State's control over the
manner of disposal or the fees it would normally collect
should a commercial facility be used for disposal.
DOE wishes to avoid providing a tacit approval to any delay
in the siting of a disposal facility by a regional compact
mandated by the low-level Radioactive Waste Disposal Act of
1980.
In order for DOE to accept quantities of EPA-generated waste,
it would be necessary to issue a Federal Register Notice to
establish a fee for service. This would require considerable
effort and resource commitment.
The existing local DOE facilities at Canonsburg and Middlesex
are owned by the federal government, but each has an existing
DOE/State/local agreement which precludes addition of mater-
ials from other locations. A new agreement would have to be
negotiated and could undermine the DOE relationship with the
local community. The facility in Maywood is currently owned
by the Stepan Chemical Company and DOE is in the process of
obtaining title to the land. DOE has a local agreement with
the town of Maywood to locate material originating solely
from the Stepan Chemical Company activities at the Maywood
site. It is possible that EPA could negotiate an agreement
with Stepan Chemical to accept the Montclair/West Orange and
Glen Ridge waste but it is doubtful a private company would
consent to such an arrangement. Currently the town of
Maywood is voicing loud objections to the DOE plan to locate
the contaminated soils from Lodi at the Maywood facilities.
A proposal from EPA to store Montclair/Glen Ridge soils there
would undoubtedly cause even greater public furor.
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Due to the extensive institutional objections, this option will not be con-
sidered further for interim or permanent disposal.
2.2.6 IMMOBILIZATION OF RADIONUCLIDES BY MATRIX ISOLATION
The public health and environmental benefits of matrix isolation are that
gamma emissions, radon emanations and leaching of radionuclides are atten-
uated. Dispersal by wind is prevented and dispersal by human intrusion is
discouraged.
Use of asphalt introduces health and environmental hazards because of the
quantity of fumes generated and the risk of fire from the hot asphalt. The
resin process involves risks from exposure to the resin monomers and acid
catalyst. The benefits from immobilizing the concentrations of radio-
nuclides present at the three sites does not justify these additional
ri sks.
The cement matrix option is both technically feasible and environmentally
safe. However, its benefits will only be useful with the ocean disposal
option and so will be costed with that, option.
2.2.7 DISPOSAL OPTIONS
Since use of an existing DOE facility was screened out in the previous
analysis of the interim storage options, the disposal options that remain
for non-cost screening are licensed commercial LLW facilities, designed
encapsulated disposal, and ocean disposal.
Licensed Commercial LLW Facility
While both Beatty and Richland have enough disposal space to last them at
their current rate of acceptance until the mid-1990s, the planned use of
these facilities by their respective states as LLW facilities under the
1980 Low Level Radioactive Waste Policy Act may pose an institutional
barrier to their acceptance of the large volume of soils from
Montclair/West Orange and Glen Ridge.
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After December 31, 1985, the facilities will principally accept wastes from
generators in-state or from a member state of a newly formed regional
compact. The Governor of Washington has repeatedly announced intentions to
close the doors to all outside generators on that date. Washington has
joined with Oregon, Utah, Hawaii, Alaska, Idaho and Montana to form the
Northwest Regional Compact with the Richland facility designated as their
disposal site. A Rocky Mountain Compact has been proposed with Beatty
accepting wastes from Wyoming, Colorado, New Mexico and Nevada.
Currently there are no restrictions on the volume of material accepted at
either Beatty or Richland. However, beginning January 1, 1986, the Beatty
license will only allow them to accept a maximum of 200,000 cubic feet per
year if an amendment to the 1980 Low Level Radioactive Waste Policy Act
sponsored by Congressman Udall of Arizona is passed. Most of this capacity
will be reserved for their compact states. An amendment to their license
would be required to accept greater quantities. It is doubtful that the
State of Nevada would increase this amount by very much in light of their,
and the other states within the compact, future needs. If the State of
Nevada did allow them to accept greater quantities, the Udall Amendment
would also place an additional $10 per cubic foot surcharge on waste from
non-compact states.
If the Udall Amendment is passed restricting the acceptance volume to
200,000 cubic feet per year and assuming that 100,000 cubic feet per year
was allowed for the New Jersey soils, it would take 33 years to complete
the disposal action for the Montclair/West Orange and Glen Ridge soils.
Because of these institutional barriers, the facility at Beatty will not be
considered further.
Richland's maximum acceptance volume after January 1, 1986 will be
1,200,000 cubic feet per year. If the Udall Amendment is passed, all of
this will be dedicated to their own and the Northwest Compact States'
disposal needs, according to the present Governor of Washington. However,
if an amendment to their license was granted by the State, Richland could
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conceivably accept all the soils from Montclair/West Orange and Glen Ridge
providing they were containerized. Therefore disposal at the commerical
facility in Richland, Washington will be carried to cost analysis.
Designed Encapsulated Disposal Facility
The use of a designed encapsulated cell for disposal of the contaminated
soils was the institutionally preferred disposal option for waste from the
Canonsburg site. It is predicted to be an environmentally sound method of
containment, being modeled after existing RCRA requirements for long-term
containment of chemical wastes.
The major institutional objection to the use of such a facility is the
problem of siting a radioactive waste facility for the off-site disposal
options. For on-site disposal there will be no need for a siting study
under current CERCLA requirements. However, since it is probable that the
state will have to site a LLW facility under the 1980 LLW Disposal Act, and
an encapsulated disposal facility could be co-located with the LLW faci-
lity, this option will be carried on for cost screening.
Ocean Disposal
The environmental impacts of ocean disposal of the radium-contaminated
soils appear to be minimal. Previous environmental impact statements on
ocean disposal of similar types of wastes (FUSRAP and Niagara Falls storage
site soils) have predicted that the radium-226 content of bottom water
flowing out of the contaminated sediments would only be raised by 2 percent
from existing background concentrations of 0.1 pCi/1.
Likewise, the public health impact of ocean disposal is also estimated to
be minimal. Sandia National Laboratories performed a preliminary study on
the Middlesex wastes and estimated that the 50-year dose commitment from
radium-226 (the isotope of greatest concern for both the Middlesex and
Montclair/West Orange and Glen Ridge sites) to a person receiving all his
food for 50 years from organisms living in the disposal site, through all
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possible pathways in the ocean food chain, is negligible in comparison to
the dose from background radium-226 in the body.
The Marine Protection, Research and Sanctuary Act of 1972 allows Ocean
Disposal permits to be issued only when no alternative means of disposal
exists. Under this act, ocean disposal is subject to regulation by EPA,
which requires the agency to evaluate permit applications for disposal of
materials not prohibited by the Act, including low-level radioactive waste.
The permitting process is elaborate and will include Congressional
authorization of the disposal activity as a requirement.
The primary international control on ocean dumping is the Convention on the
Prevention of Marine Pollution by Dumping of Wastes and Other Matter,
commonly known as the London Dumping Convention (LDC). The United States
is a contracting party to this convention, which includes definitions and
recommendations for the ocean disposal of radioactive wastes from the
International Atomic Energy Agency (IAEA). As of 1982, EPA was considering
the incorporation of LDC rules and IAEA recommendations into the U. S.
ocean disposal regulations. If there is a "de minimus" definition
established in the near future it is possible that the soils from the
radium sites may be classified in a category other than radioactive waste
and released from some of the restrictions currently in place.
The 2-year moratorium on ocean disposal enacted by Congress on January 6,
1983 expired January 7, 1985. Opposition within the United States to the
increased hazards of land burial of waste, the increasing awareness of the
costs of waste disposal and the assessment of the small impact of these
soils on the environment and public health should encourage Congressional
approval of the required permit. Although it is not certain that the
legislative atmosphere will be conducive to approval of such a project with
the time-frame projected for interim storage of the soils, this option will
be passed on to cost screening.
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2.3 COST SCREENING OF REMEDIAL ACTION RESPONSES
In this section, the response options which have passed technical and non-
cost screening are compared for cost. Table 2-3 lists the options that
remain. Costing is based on figures developed from reports of remediations
at other sites, engineering studies and information from vendors, and are
intended for comparisons of relative magnitude only. The actual cost
factors used are described in Appendix E. Remaining options are then
assembled into alternatives and their costs are compared.
2.3.1 ONSITE SOURCE CONTROL - PROTECTION OF RECEPTORS
Active and Passive Measures
For this alternative, the 43 residences remaining after the Phase I Remedi-
ation program that have radon progeny concentrations or gamma exposures
above acceptable levels will be remediated using engineering methods. The
objective of this response is to reduce radon progeny concentrations and
gamma radiation exposures to levels that meet relevant public health goals
as follows:
1. Radon progeny to concentrations less than 0.02 WL
. 2. Gamma radiation to levels less than 20 uR/hr (170 mR/yr) above
background.
The scenerio that is costed is based on data gathered from the quarterly
RPISU monitoring and the FIT and Remedial Investigations:
Twenty-one additional residences will need ventilation systems at
$15,000/unit. Twelve homes, who have not achieved the desired 0.02 WL of
radon progeny as an annual average, will require trench vents at about
$60,000 each, including cost of soil disposal. Fourteen homes will require
shielding on the floor to reduce gamma radiation. Two of these homes will
2-48
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Table 2-3
Remedial Action Responses for Cost Screening
I. On-Site Source Control Response
A. Active/Passive Measures
B. Relocation of Receptors
II. Removal and Off-Site Treatment/Disposal Responses
A. Excavation
B. Transportation and Handling
1. Vehicles (truck, barge, rail)
2. Containerization (bulk, drums, metal boxes)
•
C. Interim Storage
1. Covered Waste pile
2. Covered steel containers
3. Indoor Storage
4. Moored cargo ship
D. Disposal options
1. Richland
2. Designed encapsulated facility
3. Ocean disposal
(dec. 54/6)
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also require shielding on the walls. Based on the median value needing
attenuation, 2 inches of concrete or 0.5 inches of lead foil on sheetrock
would be needed. Concrete shielding on the 14 homes would cost about
$170,000 and lead shielding would cost $310,000. Legal and administrative
costs along with operation and maintenance costs for 200 years, which in-
quarterly monitoring for radon and annual monitoring for indoor gamma, will
add an additional $3.5 million. Total costs for this option would be about
$4.7 million if concrete shielding is used and $4.8 million if lead
shielding is used.
Relocation of Receptors
Under this response, the 43 properties which have indoor radon progeny or
indoor gamma exposures that exceed public health standards prior to the
installation of interim remedial measures, would be purchased and the
residents permanently relocated.
The 43 properties identified include 37 homes with indoor radon progeny
exceeding the public health standards (8 of which also had indoor gamma
exposures exceeding the public health standards) plus 6 homes with indoor
gamma exposures exceeding the public health standards. The 43 properties
identified do not include 8 properties with indoor radon progeny exceeding
the public health standards, that are currently being remediated by the
NJDEP Phase I remediation.
The purchase of 43 properties and relocation of the residents is estimated
at $6.0 million. Demolition, disposal, restoration, construction of a
security fence, legal, administrative, and operation and maintenance costs
will add approximately $2.0 million for a total estimated cost of $8.0
million.
2-50
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2.3.2 REMOVAL AND DISPOSAL RESPONSES
Excavation
All alternatives screened for cost will include excavation of contaminated
soils from the Montclair/West Orange and Glen Ridge Radium Sites. The
total cost of excavation and restoration based on 122,000 cubic yards of
contaminated soil is estimated at $25.5 million. Costing subsequent to
excavation is based on an excavated volume of 122,000 cubic yards. Engi-
neering and radiological monitoring costs are estimated at $8.0 million
while legal and administrative costs are estimated at $5.0 million.
Transportation and Handling
Vehicles. Local and in-state transportation is best accomplished by bulk
transport of soil in 16 cu. yd. dump trucks at a cost of $400/day. For
distances to 400 miles there would'be additional charges for expenses.
Rail transport was not costed for the local or in state options.
Barging was only feasible for use with the ocean disposal option and will
be costed with that option.
For transport across country to Richland, Washington, both truck and rail
options were considered. Since soil must be containerized at Richland, the
option would necessitate the transport of about 507,000 55-gallon drums.
For the rail option, these drums could be loaded into flat-bed semitrailer
trucks and transferred to flatcars at the rail transfer point. Shipment by
rail at $193/ton is estimated to cost between $35 and $36 million.
Use of flat-bed semitrailer trucks for the 3000 mile trip across the
country at about $1.40/mile and 14 cu yds a shipment, would cost about
$36.6 million.
2-51
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The costs for rail and trucks transport across country are similar, how-
ever, since rail transport is proven to be safer, it will be selected as
the long distance transit option for final evaluation.
Containerization
Costs for containerization of the 122,000 cubic yards of soil are given
below. Each cost includes packaging soils, sealing, drums or boxes,
labelling the drum or box, recordkeeping, and loading onto trucks:
Drums (at 6.5 cf/drum = 506,769 drums) $38 million
B12V Boxes (at 39 cf/box = 84,500 boxes) $40.6 million
Based on their availability and slightly lower costs, drums will be passed
on as the container option for final evaluation.
Interim Storage
Covered Pile. This alternative involves locating and preparing a site,
transporting the soil to the site by truck, and constructing the storage
pile. The interim storage site is assumed to within 160 miles of the
excavation site and the materials would be carried by truck with no con-
tainerization and no trans!oading.
Siting and construction costs for this alternative are estimated at $7
million dollars. Transportation costs and operation and maintenance costs
are estimated to add $5 million for a total of $12 million. This estimate
does not include reexcavation for final disposal.
Covered Steel Containers. This response is similar to the covered pile
estimated above except that the wastes will be containerized in 55 gallon
drums or B-12v steel boxes adding an estimated $38.0 million for 55 gallon
drums and $40.6 million for B-12v steel boxes. The construction costs
2-52
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would be less than for siting a covered pile, totalling about $5.6 million
for a pad for drums or $3.0 million for the steel boxes. Transportation
costs for this alternative would be increased by $1 million. The cost of
this response exclusive of excavation and restoration costs is between
$50.3 million and $53.6 million depending on the type of container used.
Indoor Storage. It is estimated that construction of an air-supported
structure of large enough volume to contain the excavated soil in bulk
piles would require 500,000 sq. ft. of area for 10 ft. high piles and is
estimated at $10 million. Comparable steel structures for containerized
soils would require 1.4 million sq. ft. and are estimated at $30 million.
These costs must be added on to the costs for covered piles or covered
containers. Although the building is salvagable, the additional radio-
logical protection is not with the enormous cost. In addition, radon
emanating from the soil would accumulate inside the buildings, unless
additional ventilation is provided. This option is not cost-effective.
Moored Cargo Ships. This alternative includes the leasing of 10 cargo
ships for 6 years, truck transportation of the soils to a port in the
Philadelphia area, loading the ships, 6 years of operation and maintenance
and off-loading and decontamination of the ships.
Cost ($ million)
Containerization
Transport to Dock
Leasing of 10 Ships
Loading of Ships
Dock and Wharf fees
Unloading and
Decontamination
Bulk
$0
4.1
34.0
1.2
1.2
2.2
Containerized
$38.0
3.5
34.0
1.9
1.7
2.1
TOTAL 42.7 81.2
2-53
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These costs range from four to seven times the construction cost of the
covered bulk storage pile on land. These costs are based on a leasing fee
for a 6-year period. These costs, combined with the uncertain costs after
the 6-year period for continued leasing, make this response cost
prohibitive.
Final Disposal
Encapsulation Onsite. This alternative includes purchase of land within
the three communities, transportation of the soils, construction of an
encapsulated cell, maintenance and monitoring.
For the on-site option consisting of a single lined cell in Glen Ridge, the
purchase of land would cost about $9 million, encapsulation about $6.0
million and transportation about $0.7 million. O&M and other costs would
bring the total about $24.5 million.
Encapsulation Offsite. This alternative assumes that a new disposal site
is constructed within 400 miles of the interim storage site. It includes
obtaining and preparing the site, transporting the soil to the site, encap-
sulating the soil, maintenance and monitoring.
The cost of obtaining and constructing the off-site disposal facility is
estimated to be $8.8 million. Transporting the soil to the site would cost
an additional $8.0 million and encapsulation would cost about $6.0 million.
O&M and other administrative costs would bring the total to about $22 mil-
lion.
Disposal At Low-Level Waste Site (Richland, Washington). This alternative
includes excavating the contaminated soils, containerizing them in drums,
and transporting the drums by rail to the LLW site at Richland, Washington,
operated by U.S. Ecology, Inc. The cost of containerizing, transporting
and storing the contaminated soils are estimated at $150 million.
2-54
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This alternative is not cost-effective when compared to encapsulation on
site or off site. However, because of strong state and local preferences,
it will be considered further.
Ocean Disposal. At this time, the alternative of ocean disposal is
prevented by institutional constraints discussed section 2.2.7. Because of
the possibility that these constraints will be loosened during an interim
storage period, this study will consider preliminary cost estimates.
This alternative includes truck transport to a port 10 miles from the ex-
cavation site, loading the soil onto barges, towing to the 106 mile site,
dumping the soil and returning the barges. Costs will heavily depend on
whether containerization is determined to be necessary since the space
needs at the dock, the type of handling and the amount wastes that can be
transported are all dependent on the containerization option.
The costs estimated below are based on the scenerio of dock space rented at
a near-by port, with additional space needed if the soils are to be pro-
cessed into cement blocks. Hardened cement blocks will increase handling
costs and will have to be transported to the dock rather than directly
loaded as bulk.soil.
Cost ($ million)
Item Bulk
Cement Blocks
Ship Bulk
Truck Transported to
Dock
$ 1.2
$ 1.2
$ 1.2
Dock Space Rental
Costs
Loading
Trip Costs
Containerization
TOTAL
0.2
0.9
1.6
3.9
0.3
2.0
2.1
4.0 (cementing)
9.6
0.2
0.9
0.7
7.0(shiphul1s)
10.0
2-55
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The costs above do not include engineering, legal, administrative and,
monitoring costs or the costs for an EIS. These costs are expected to add
an additional $4 to $5 million.
2.4 ASSEMBLING REMEDIAL ACTION ALTERNATIVES
The remedial responses that passed technical, environmental and insti-
tutional screening and were costed in Section 2.3 are summarized below.
2.4.1 ONSITE PROTECTION OF RECEPTOR RESPONSES
Estimated Cost
($ million)
1. Active and Passive Measures
Concrete $4.7
Lead $4.8
2. Relocation of Receptors 8.0
2.4.2 REMOVAL AND DISPOSAL RESPONSES
Excavation costs will depend on the amount of soil excavated. If the full
122,000 cu. yds are excavated the cost is estimated to be $38 million.
Truck transport will be used locally, barge transport for the ocean dis-
posal option and trailer on flatcar transit for transport across country to
Richland, Washington.
Drums will be the container choice for any of the containerization options.
Interim storage will consist of an outdoor covered pile at a cost of $12
million.
2-56
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Final disposal options consist of the following:
Option Cost ($ million)
1. Encapsulation Onsite 24.5
2. Encapsulation Offsite 22.0
3. Disposal at Richland 150.0
4. Ocean Disposal
Bulk 3.9
Cement Blocks 14.6
The protection of receptor responses meet the goal of minimizing the public
health threat but they do not remove the contamination source and have many
technical, environmental and institutional disadvantages. However, since
they can be implemented in the shortest amount of time and are the least
expensive alternatives, they will be carried on to final analysis.
The removal and disposal responses are 1 to 2 orders of magnitude more
costly than the protection of receptor responses. However, they remove the
public health threat by removing and controlling the contamination source.
Interim storage is not necessary for encapsulation onsite or disposal at
Richland. Its costs should be added, along with the cost of reexcavation
(about $2 million), to the encapsulation offsite and ocean disposal op-
tions. Transportation costs from interim to final cannot be costed as
distances are not known.
2-57
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Revised Disposal Cost Estimates
Option Cost ($ million)
1. Encapsulation Onsite 24.5
2. Encapsulation Offsite 36.0 + transportation
3. Disposal at Rich!and 150.0
4. Ocean Disposal
Bulk 17.9 + transportation
Cement Blocks 28.6 + transportation
All disposal options, except disposal at Richland, are within the same
range and will be carried on to final evaluation. Disposal at Richland is
clearly the least cost-effective option, but it too will be passed on
because of strong State and local preferences.
(311/5)
2-58
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REFERENCES FOR CHAPTER 2
REPORTS
Baerger, Dr. Paul, Letter to Christopher Daggett, EPA, Region II,
concerning Lease of cargo ships for ocean dumping of radioactive soil from
Montclair, Glen Ridge. West Orange Sites, April 29, 1985
Battelle Pacific Northwest Laboratory, Ocean FUSRAP: Feasibility of Ocean
Disposal of Materials, December 1982.
Center for Environmental Education, The 1985 Citizen's Guide to the Ocean,
1985.
Envirosphere Company, Engineering Feasibility Study and Health Physics
Evaluation of a Proposed Temporary Storage Site for Radioactively
Contaminated Soil, August 1984
International Atomic Energy Agency, Convention on the Prevention of Marine
Pollution by Dumping of Wastes and other Matter, August, 1984.
Marine Protection, Research and Sanctuaries. Act of 1972, P.L. 532 (As
amended January 6, 19.83
NLO, Inc., Project Report of Phase I Remedial Action of Properties
Associated with the Former Middlesex Sampling Plant, September 1981-
Science, U.S. Considers Ocean Dumping of Radwastes, March, 1982.
United States Department of Energy, Oak Ridge Operations Office, Remedial
Action Work Plan for the Middlesex Landfill Site, August 1984.
United States Department of Energy, Final Environmental Impact Statement,
Remedial Actions at the Former Vitro Rare Metals Plant Site, Canonsburg,
Washington County, Pennsylvania, Volume I. July 1983 (DOE/EIS - 0096-F
Vol. I.
United States Department of Energy, Final Environmental Impact Statement,
Remedial Actions at the Former Vitro"Rare Metals Plant Site, Canonsburg,
Washington County. Pennsylvania, Volume II, Appendices. July 1983,
(DOE/EIS - 0096-F Vol. II
United States Department of Energy, Draft Environmental Impact Statement
for Long-Term Management of the Existing Rad"
The Niagara Falls Storage Site, August 1984.
for Long-Term Management of the Existing Radioactive Wastes and Residues at
1<
United States Department of Energy, Engineering Evaluation of Alternatives
for the Disposition of Niagara Falls Storage Site, Its Residues and Wastes,
January 1984.
United States Department of Energy, Engineering Evaluation of Alternatives
for the Disposition of of Niagara Falls Site, Its Residues and Wastes,
January 1984.
-------
REFERENCES FOR CHAPTER 2 (continued)
United States Environmental Protection Agency, Remedial Action at Waste
Disposal Sites, June 1982.
United States Environmental Protection Agency, Identification of Cost
Factors for the Ocean Disposal Alternatives for Low-Level Radioactive
Waste, December 1984.
United States Environmental Protection Agency, Report to Congress: On
Administration of the Marine Protection, Research and Sanctuaries Act of
1972, as amended (P.L. 92-532) and Implementing the International London
Dumping Convention, January, 1981 - December, 1983.
United States Environmental Protection Agency, Development of a Working Set
of Waste Package Performance Criteria for the Deepsea Disposal of Low-Level
Radioactive Waste, November, 1982.
United States General Accounting Office, Hazards of Past Low-Level
Radioactive Waste Ocean Dumping have been Overemphasized, October 21, 1981.
United States Office of Radiation Programs, A Survey of the Available
Methods of Solidification for Radioactive Wastes, November 1978.
Meeting and Telephone Conversations
July 26, 1985 Telephone Conversation between W. Smith of Camp, Dresser &
McKee, Inc. and M. Morrow of New York/New Jersey Port Authority
July 26, 1985 Telephone Conversation between W. Smith of Camp, Dresser X
McKee, Inc and dispatcher of Reinauer Towing
July 29, 1985 Telephone Conversation between W. Smith of Camp, Dresser &
McKee, Inc. and F. Jannuzzi of Weeks Stevedoring Company, Inc.
(DEC45/9) .
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3.0 IDENTIFICATION OF CANDIDATE REMEDIAL ALTERNATIVES
In accordance with EPA policy, the candidate remedial alternatives consi-
dered must include at least one alternative from each of the following
categories:
1. Alternatives specifying offsite storage, destruction, treatment, or
secure disposal of hazardous substances at a facility approved under
the Resource Conservation and Recovery Act (RCRA). Such a facility
must also be in compliance with all other applicable EPA standards
(e.g., Clean Water Act, Clean Air Act, Toxic Substances Control Act).
2. Alternatives that attain all applicable or relevant federal public
health or environmental standards, guidance, or advisories.
3. Alternatives that exceed all applicable or relevant federal public
health and environmental standards, guidance, and advisories.
*
4. Alternatives that meet the CERCLA goals of preventing or minimizing
present or future migration of hazardous substances and protect human
health and the environment, but do not attain the applicable or rele-
vant standards. (This category may include an alternative that closely
approaches the level of protection provided by the applicable or
relevant standards).
5. No action.
The relevant standards, guidance and advisories are discussed in Section
1.4.2.
Four approaches have been evaluated for dealing with the radiologically
contaminated material at Montclair/West Orange and Glen Ridge: no action;
maintenance and extention of the existing removal action of ventilating
affected homes; relocation of residents; and excavation and disposal of
contaminated soils. Table 3-1 lists the alternatives and options described
in this section.
3-1
-------
TABLE 3-1
MONTCLAIR/WEST ORANGE AND GLEN RIDGE REMEDIAL ALTERNATIVES
Alternative No. 1 No Action
This alternative consists of removing the existing ventilation systems and
performing no additional remedial actions, allowing the conditions at the
Montclair/West Orange and Glen Ridge sites to return to the way they were
prior to EPA intervention.
Alternative No. 2 Active Measures (Status Quo)
This alternative consists of extending the existing removal action, th
-------
Remediation of the residences included under the NJDEP Phase I Study is not
considered as part of the alternatives discussed in this chapter.
3.1 ALTERNATIVE 1 - NO ACTION
This alternative consists of removing the existing ventilation systems and
performing no additional remedial actions. The ongoing quarterly monitor-
ing programs would be discontinued. The Montclair, West Orange and Glen
Ridge sites would be allowed to return to the conditions existing prior to
EPA intervention.
This alternative would not attain public health goals or meet environmental
standards.
3.2 ALTERNATIVE NO. 2 - ACTIVE/PASSIVE MEASURES
For this alternative, the 43 residences with elevated radiation exposures
above acceptable levels, that remain after the completion of the Phase I
Remediation program, will be remediated using engineering methods. The
objective of the response actions is to reduce radon progeny concentrations
in the residences to less than 0.02 WL and reduce gamma exposures to less
than 20 uR/hr above background.
In residences where the annual average radon progeny concentration remains
above 0.02 WL after installation of the ventilation system, trench vents
would be constructed to assist in attaining this objective. Residences
with elevated indoor gamma exposures would have shielding installed to
bring average exposures in a single room down to 20 uR/hr or less above
background, and maximum exposure rate readings below 60 uR/hr. Outdoor
gamma exposures would be controlled by limiting access to areas of high
gamma radiation. Lead or concrete would most likely be used as shielding
materials because of their proven effectiveness, but selection of the
material and details of its installation must be dealt with on a case-by-
case basis. Quarterly monitoring would be continued to determine the
effectiveness of these actions.
The affected residences are identified in figures 3-1, 3-2 and 3-3. Cur-
rently, 16 homes, excluding those in the State's Phase One Study, have
active ventilation systems in place. Under this alternative 21 additional
3-3
-------
LEGEND:
STUDY AREA PERIMETER
RESIDENCES DESIGNATED FOR ACTIVE VENTILATION SYSTEMS: ALTERNATIVE 2
RESIDENCES DESIGNATED FOR SHIELDING: ALTERNATIVE 2
RESIDENCES DESIGNATED FOR BOTH VENTILATION AND SHIELDING: ALTERNATIVE 2
ALL SHADED RESIDENCES ARE INCLUDED IN ALTERNATIVE 3
SCflLE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-1
MONTCLAIR: ALTERNATIVES 2 and 3
MONTCLAIR STUDY AREA
3-4
-------
STUDY AREA PERIMETER
RESIDENCES DESIGNATED FOR ACTIVE VENTILATION SYSTEMS: ALTERNATIVE 2
RESINENCES DESIGNATED FOR SHIELDING: ALTERNATIVE 2
RESIDENCES DESIGNATED FOR BOTH VENTILATION AND SHIELDING: ALTERNATIVE 2
ALL SHADED RESIDENCES ARE INCLUDED IN ALTERNATIVE 3
SCALE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-2
WEST ORANGE: ALTERNATIVES 2 and 3
WEST ORANGE STUDY AREA
3-5
-------
LEOEND:
" STUDY AREA PERIMETER
RESIDENCES DESIGNATED FOR ACTIVE VENTILATION SYSTEMS: ALTERNATIVE 2 ^ 8>
KSXM RESIDENCES DESIGNATED FOR SHIELDING: ALTERNATIVE 2
B2&223 RESIDENCES DESIGNATED FOR BOTH VENTILATION AND SHIELDING: ALTERNATIVE 2
ALL SHADED RESIDENCES ARE INCLUDED IN ALTERNATIVE 3
SCALE: N.T.S.
COM
environmental engineers, scientists. •
planners & management consultants
FIGURE 3-3
GLEN RIDGE: ALTERNATIVES 2 and 3
GLEN RIDGE STUDY AREA
3-6
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systems would be installed. Of the 16 systems now in place, 12 do not meet
the objective of maintaining average indoor radon progeny concentration of
0.02 WL. These residences require the installation of trench vents. Con-
taminated soils excavated during the construction of the trench vents would
be containerized and transported to a licensed low level radioactive stor-
age facility.
Shielding to reduce indoor gamma exposure would be required in a total of
14 homes excluding the homes in the Phase I program. Shielding would
consist of 2 inches of concrete or 0.5 inches of lead bonded to sheet rock
on the basement floor. If lead is used, plywood flooring would be placed
on top of the lead shield. Two homes would also require lead shielding on
the basement walls. Those basements that are presently finished would be
refinished as necessary.
This alternative would assure the elimination of the adverse health
impacts, but would not meet the relevant environmental standards.
3.3 ALTERNATIVE 3 - RELOCATION OF RECEPTORS
Under this response, the 43 properties which have indoor radon progeny or
indoor gamma exposures that exceed public health standards prior to the
installation of interim remedial measures would be purchased and the resi-
dents permanently relocated.
Elevated radiation exposures are defined as annual average indoor radon
progeny concentrations greater than 0.02 WL, average indoor gamma exposure
rates more than 20 uR/hr or single indoor gamma exposure readings greater
than 60 uR/hr. At the completion of the Phase I program, a total of 43
residences would have to be bought under this alternative. They are shown
in figures 3-1, 3-2, and 3-3.
Residents currently living in houses with elevated radiation exposures
would move from these houses. The Federal Emergency Management Authority
(FEMA) would coordinate the purchase of each house and property at fair
3-7
-------
market value and would reimburse the residents for reasonable relocation
expenses. After purchase, the homes would be demolished and properties
regraded and fenced to discourage trespassers. Security of the properties
including maintenance of the fences would continue for an indefinite
period.
Relocating the residents at risk from elevated radiation exposures would
assure the elimination of adverse health impacts, but would not remove the
source of the hazard. This alternative would not attain relevant environ-
mental standards.
3.4 ALTERNATIVES 4, 5, AND 6 - EXCAVATION OF CONTAMINATED SOILS
There are three excavation alternatives for the radioactively contaminated
soils at the Montclair/West Orange and Glen Ridge sites. These are des-
cribed below:
Alternative 4 - Excavation to Eliminate Adverse Health Effects:
Contaminated soil would be removed from all open land to achieve radium
concentrations less than 5 or 15 pCi/gm, averaged over any 100-square-meter
area, as described in 40 CFR 192. A total of 141 properties within the
three sites will need to be excavated to meet this "open land" standard.
Excavation of radioactively contaminated materials under any occupiable
building would follow the stated objectives of 40 CFR 192. An implication
of this standard is that removal of residual materials would not be neces-
sary if the health objectives of 0.02 WL and 20 uR/hr of gamma radiation
are met. Excavation around or beneath buildings would only be required for
43 residences within the three sites.
This alternative would not meet the relevant environmental standards (40
CFR 192) but would attain the goal of eliminating adverse health impacts.
3-8
-------
Alternative 5 - Excavation to Meet Relevant Environmental Standards (40 CFR
192):
Contaminated soil would be removed from all open land and from around and
beneath all buildings to achieve radium concentrations less than 5 or 15
pCi/gm, averaged over any 100-square-meter area, as described in 40 CFR
192. This alternative would entail excavating in open lands a total of
231 properties with radium contamination, including excavating under and
around 90 residences within the three sites.
This alternative would eliminate adverse health impacts and meet the rele-
vant environmental standards.
Alternative 6 - Excavation to Eliminate all Contamination:
Any soil that is shown statistically to be contaminated would be removed.
Soils within 6 inches of the ground surface would be considered contami-
nated if radium concentrations are above 5 pCi/gm and deeper soils would be
considered contaminated if radium concentrations are above 15 pCi/gm. Ex-
cavation would be performed in open lands and around and below buildings,
as required.
This alternative would assure the elimination of health effects, would ex-
ceed environmental standards and assure the elimination'of all contamina-
tion.
The techniques of excavation and restoration are similar for all three
alternatives. Where contaminated soils are known to exist under basement
slabs or crawl spaces, the residents would be temporarily relocated during
excavation and any furnishings and stored items in the basement or crawl-
space would be removed, placed in storage and returned upon completion of
remediation.
3-9
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3.4.1 EXCAVATION
Prior to commencing excavation a detailed site investigation would be con-
ducted and detailed plans would be prepared by the design contractor for
each property on which radioactively contaminated soils exist. These plans
would include, but not be limited to, the following information:
(1) Detailed topographic survey showing the property boundaries,
streets, utilities, sidewalks, curbs, driveways, fences, walls,
location of structures, trees, shrubs and type of ground cover
(2) Area! extent and depth of contaminated materials
(3) Location of all boreholes
(4) For those properties where radioactively contaminated soils are
known to exist under the crawl space, basement slab or footing,
detailed plans of the basement level, or foundation in the case of
a home with only a crawl-space, would be prepared showing footing
depth and thickness, foundation type and thickness, structural
supports, location of all mechanical equipment and utilities,
layout of any rooms, the location and depth of the contamination
and all boreholes.
Excavation in open lands would be performed with the hand tools or machi-
nery that are appropriate to the quantity of soil to be removed and the
depth at which the contaminated soil is found.
Excavation of contaminated soils under basement slabs or crawl spaces would
be carried out utilizing one of the following techniques:
(1) Where contaminated soils exist under a basement slab to a depth
that removal would not affect the structural integrity of the
foundation footing, a portion of the basement wall and the base-
ment slab would be removed and the contaminated soils excavated by
3-10
-------
hand. After verification of removal to the specified criteria,
clean structural backfill would replace the contaminated soils re-
moved. A new basement slab would be poured and the basement wall
repaired. All basements will be restored to their pre-remediation
condition.
(2) Where contaminated soils^exist under a slab or crawl space as well
as under the foundation footing, and where sufficient room exists
on the property to do so without disturbing large trees, the resi-
dence would be moved off the foundation to facilitate mechanical
excavation. The foundation footing and basement slab would be
removed and disposed of along with the contaminated soils.
Structural backfill would replace the soil removed and a new
footing poured. The residence would then be moved back to its
original location. The foundation walls and slab would be recon-
structed and the residence lowered onto the new foundation. The
basement would then be restored to its pre-remediation condition.
(3) Where contaminated soils exist under the basement slab and under a
portion of the footing, and where insufficient room exists on the
property to move the residence off the foundation, underpinning of
the foundation, removal of a portion of the foundation wall and
removal of the slab would be required to remove the contaminated
materials. This method of remediation would require hand excava-
tion. After removal of the contaminated soils, structural back-
fill would be placed, a new slab poured, the foundation wall re-
stored, and the basement restored to its pre-remediation condi-
tion.
(4) Where contamination exists under the basement slab or crawl space
and under the footing, and the structural integrity of the resi-
dence is such that it cannot withstand remedial methods 1 through
3, it would be necessary to purchase the property and demolish the
residence in order to complete the remediation. In such cases,
the property would be purchased at the fair market value and the
3-11
-------
expenses of relocation of the residents paid. The properties
falling into this category will be identified during the detailed
design phase.
On a number of properties, it would be necessary to remove contaminated
soils from beneath garages or storage sheds. In order to accomplish this,
the contents of the structure would be removed and placed in storage and
the structure demolished. After the contaminated soil is removed and re-
placed with clean structural backfill, a new structure would be constructed
and the contents returned.
In certain locations, contamination is known to exist within the streets
and around the utility lines. These areas would also be excavated to meet
the requirements of 40 CFR part 192.12(a). Utilities affected by the con-
struction activities would be supported where possible. In some instances
it would be necessary to remove and replace the existing utilities.
3.4.2 RESTORATION
All properties remediated by excavation would be restored as closely as
possible to their original condition. Clean structural backfill and top
soil would replace the contaminated materials removed. All material used
as backfill would be obtained from approved sources and checked for
radiological and chemical contamination prior to use.
All structures, sidewalks, driveways, curbs, patios, steps, decks, fences,
etc. would be reconstructed. Basements would be restored as described
above in Section 3.4.1. Any landscaping removed would be replaced in kind.
Should it be necessary to remove large trees and mature shrubs, they would
be replaced in kind with smaller trees and shrubs. All lawn areas dis-
turbed during construction would receive 6 inches of new clean topsoil and
be reseeded. Areas containing other types of ground cover would be
restored in kind.
3-12
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3.4.3 MITIGATING MEASURES
Dust Control
Strict dust control measures would be implemented during the excavation and
handling of the radioactively contaminated soils. The use of water sprays
with surfactants at emission sources would be employed, and emphasis would
be placed on dustproofing and decontaminating homes within the areas to be
excavated. Additional controls could include the use of covers over the
excavated areas and the use of other types of dust suppressors. Air moni-
toring equipment would be set up around the perimeter of the excavation
site to measure airborne particulates and their level of radioactivity.
Excavation activities would be stopped and the excavation area would be
covered during periods of high winds.
Soil Erosion and Sediment Control
To prevent the erosion of soil from the construction site and the deposi-
tion of sediment into the receiving waters, straw bale sediment barriers or
silt fences would be utilized in accordance with the guidelines of the U.S.
Soil Conservation Service. During inclement weather excavation activities
would cease and the excavation areas would be covered to prevent the ero-
sion of contaminated soils into areas previously remediated. In addition,
run-off would be channeled to a detention area where it would be radiologi-
cal^ monitored prior to release.
During restoration activities, mulching of seeded areas would be required
to prevent erosion of the restored areas.
Equipment Monitoring and Access Control
To guard against contaminated materials spreading onto residential streets,
all equipment would be monitored for radiation and decontaminated as neces-
sary prior to leaving the site.
3-13
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All construction personnel would wear suitable protective clothing, would
pass through an access control point and would be radiologically scanned to
prevent radioactive materials from leaving the site. All construction per-
sonnel would also be required to successfully complete a health, safety and
radiological training course appropriate to their job.
Excavation Control
As excavation proceeds, trained field personnel would monitor the levels of
contamination in the excavation area by means of a hand-held scintilio-
meter. The cut-face and bottom of the excavation pits would be scanned to
estimate when contamination exceeding the applicable EPA standards has been
removed. Soil samples would also be taken to determine the extent of con-
tamination remaining. Prior to backfilling the excavated area, gamma mea-
surements would be taken and soil samples would be composited over the area
of concern and analyzed for thorium and radium content. Laboratory results
would be analyzed statistically to ensure compliance with the cleanup stan-
dards. NJDEP will certify that the standards have been met. Observed
anomalies would be investigated for potential deposits that exceed the EPA
standards. Should this occur, the area would have to be re-excavated to
ensure that the contamination is removed to below standards.
The major material-handling activities at the Montclair/West Orange and
Glen Ridge sites would be the excavation and shipping of the radioactively
contaminated materials and the importation and placement of structural
backfill.
The remediation of the sites would be carried out over a 2-year period by
phasing the remediation into groups of properties as engineering con-
straints dictate.
Typical construction equipment would consist of backhoes, front-end
loaders, dump trucks and fork-lifts. The size of all equipment utilized at
the site would be restricted by maneuverability, limited clearance between
structures and weight restrictions.
3-14
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3.5 DISPOSAL OPTIONS
For each of the three excavation alternatives presented in section 3.4
there are eight disposal options, allowing for a total of 24 remedial
alternatives involving excavation. The volume of soil to be excavated
under alternative 6 cannot be estimated at this time. Therefore, excava-
tion/disposal scenarios have been developed for alternatives 4 and 5 only
as described in the following sections.
3.5.1 DISPOSAL OPTION A - PERMANENT DISPOSAL AT A LICENSED LOW LEVEL WASTE
(LLW) DISPOSAL FACILITY
Under this option the contaminated materials would be excavated according
to the criteria of the selected excavation alternative and transported to a
LLW disposal facility for permanent storage.
The radioactively contaminated materials would be loaded into and trans-
ported in 55-gallon drums using flat-bed semitrailer trucks, to a trans-
loading facility at a rail yard. There the material would be transloaded
into trailer vans, which would then be loaded on to railroad flat cars for
shipment to the LLW disposal facility at Richland, Washington. Strict com-
pliance with all federal and state regulations regarding the transportation
of low-level radioactive waste would be maintained. Variances may be re-
quired from the municipalities of Montclair, West Orange and Glen Ridge
waiving weight restrictions on municipal streets.
All trucks utilized to haul contaminated material would be inspected prior
to use. All drums would be decontaminated prior to being loaded onto the
trucks. Predesignated routes would be traveled and an emergency response
program would be established to respond to any accidents. When the ship-
ments arrive at a west coast TOFC facility, the trailer vans would be off
loaded from the flat cars and driven to the Richland facility where the
drums would be off loaded and placed in trenches.
3-15
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3.5.2 DISPOSAL OPTION B - OFFSITE INTERIM STORAGE WITHIN THE STATE OF
NEW JERSEY OR AT OTHER APPROPRIATE LOCATIONS AND REEXCAVATION FOR
FINAL DISPOSAL WITHIN 400 MILES
Under this option the contaminated materials would be excavated to the
criteria of the selected excavation alternative and transported to an in-
terim storage facility within New Jersey or at another appropriate loca-
tion. Transportation would be in bulk form using 16-cubic-yard dump trucks
as described for Option A.
At the interim storage facility the truck would be monitored after dumping
and decontaminated as necessary prior to leaving the site. A transloading
area for loading the contaminated materials onto larger trucks and/or rail
cars would not be required since the dump trucks would travel directly to
the interim storage facility.
Based upon the excavation alternative selected, the volume of radioactive
materials removed for interim storage and ultimate disposal from each site
would vary. Health and safety guidelines for the proposed storage cell
have been previously established and published by Envirosphere Company (a
division of Ebasco Services Incorporated) in a report to MJDEP entitled
Engineering Feasibility Study and Health Physics Evaluation of a Proposed
Temporary Storage Site for Radioactively Contaminated Soil, dated August
1984.
Interim Storage
The interim storage option selected as most economically feasible is an
outdoor covered storage pile. Excavated soil would be delivered to a site
by covered dump truck and deposited on an asphalt pad. It would then be
spread and compacted in small lifts. Upon completion the stockpile would
be capped and monitored until such time as a permanent disposal solution
for the material is ready to be initiated.
3-16
-------
A temporary storage site has not yet been selected. Therefore, a rea-
sonably adaptable generic holding cell has been developed that can be
placed in a variety of locations. A maximum stockpile height of 10 feet
was also established as desirable, so that a 12-foot security fence around
the area would provide a visual barrier, as well as a barrier to tres-
passers.
The storage site evaluation was developed without knowing the geography and
topography of the site. Therefore, it is assumed that a reasonably level
site would be selected and that preparation costs would consist of site
clearing and subsurface investigations.
Given the height restriction, a land area of approximately 10 acres would
be required for the pad area. Allowing for a storm water detention area
and a buffer area, the total land area required for the interim storage
site would be approximately 18 acres. The height of the storage pile would
vary depending upon the excavation alternative selected. The heights for
alternatives 4 and 5 are shown below.
Excavation
Alternative
Alternative No. 4
Alternative No. 5
Volume of
Excavation
(cu yd)
119,000
122,000
Area of
Storage Pile
(sq ft)
422,500
422,500
Height of Interim
Storage Pile
(including topsoil )
(ft)
8.6
8.8
Contaminated soil would be delivered to the site in dump trucks and deposi-
ted onto an asphalt pad laid to fit the restrictions of the site selected.
For this alternative, an area 650 feet x 650 feet (9.7 acres) at the sur-
face has been established. The material would be placed and compacted in
small lifts (a series of 6-inch layers) while leaving the edges of the
stockpile at a slope of 30 degrees off the horizontal plane so as to
stabilize the pile and minimize erosion.
3-17
-------
The storage pile would then be covered to reduce air emissions and the
potential of surface water and groundwater contamination. An acceptable
method is to cover the pile with an 80 mil-thick ethylpropylenediene
monomer (EPDM) liner. This liner would also serve to prevent escape of
radon gas. The liner would then be covered with a 1-foot-thick layer of
seeded topsoil. Figure 3-4 depicts this pile.
Proper attention to the protection of the stockpile during emplacement of
soil would be necessary. It would be necessary to continually monitor the
soil moisture content and to spray water as necessary to prevent the con-
taminants from becoming dispersed by the wind. However, excessive watering
would create runoff and this must be avoided.
The stockpile must also be covered at the end of each workday and during
inclement weather with a plastic sheet or waterproof tarpaulin.
Electric service would be provided along the perimeter of the site to pro-
vide power for air monitoring equipment and lighting that would be neces-
sary during the storage period.
Since the pile would be covered during storage, runoff from the pile would
not contain radioactive contaminants. However, runoff from the pile would
be channeled to a detention basin where it would be.monitored and treated
as necessary prior to discharge to surface waters or to the local storm
water system.
It may become necessary at some future date to collect and monitor leach-
ate. This would most likely happen if the design service life of the in-
stallation is exceeded or if the EPDM liner should puncture or split,
allowing rainwater to pass through the pile. Costs for this system would
depend on its capacity and are not included here. The need for such a
system would also be related to the attention given to long-term mainten-
ance of the storage pile.
3-18
-------
.. . 650'
/- EDGE OF ASPHALT SLAB
ft
\
—
/
f "
1111111
CONTAMINATED SOIL-/
~~x
111]
TOP SOIL
INI
/
\
o
ir>
vo
PLAN
12' HIGH FENCE
(ALL AROUND)
650'
I1 TOP SOIL & SEEDED
y-80 MIL EPDM LINER
i / ,.„„.....,,... 3
k-•'-
V_
8" GRAVEL
"-6" ASPHALT SLAB
•RUNOFF DITCH
(ALL AROUND)
; •; /0:/^'V';i'fr!i''••••'''"'" "
SCALE: N.T.S,
CDM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-4
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
OFFSITE INTERIM STORAGE PILE
DISPOSAL OPTION B
3-19
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Permanent Disposal Site
After a permanent low level radioactivity disposal facility has been sited
within the State of New Jersey, or at another appropriate location within
400 miles, the material at the interim storage facility would be required
to be reexcavated and transported to the final disposal facility.
The permanent disposal facility design would be similar to the encapsula-
tion cell designed for the Canonsburg, Pennsylvania facility under the
Uranium Mill Tailings Remedial Action (UMTRA) Project.
For the purposes of this feasibility study and to satisfy the design objec-
tive, the encapsulation cell consists of the following:
(1) A 1-foot-thick layer of coarse sand, placed on undisturbed earth,
to serve as a capillary break and prevent the upward migration of
water into the encapsulation cell
(2) An encapsulation cell liner consisting of a 2-foot-thick layer of
locally available borrow materials. The liner should have a perme-
ability such that the potential for water buildup within the cell
is minimized, while migration of radioactively contaminated mater-
ials is inhibited.
(3) The layer of radioactively contaminated materials excavated from
the sites. The radioactively contaminated materials would be
placed on the liner, spread and compacted. The placement of the
contaminated material would begin at one end of the encapsulation
cell to the required height, so that construction of the encap-
sulation cover could proceed as additional contaminated materials
are being emplaced. This method of construction would minimize
the areal extent of the contaminated materials that would be
exposed to the elements.
3-20
-------
(4) An encapsulation cell cover designed to inhibit infiltration of
surface water into the cell and to retard the release of radon
gas. This cover would consist of a 1-foot layer of bentonite-
modified clayey soil and 2 feet of compacted clayey materials,
similar to the Canonsburg site.
(5) A 1.5-foot-thick layer of rip-rap to help prevent erosion, and act
as a barrier against burrowing animals and plant root penetration.
(6) A 1-foot layer of topsoil that would serve as a base for shallow-
rooted vegetation.
(7) Drainage swales around the perimeter of the cell that would chan-
nel any stormwater runoff to a detention basin where it would be
monitored prior to release to local surface waters.
(8) A secondary means of removing contaminants from stormwater runoff
may be necessary, depending on the effectiveness of the sedimenta-
tion basin in removing contaminants. A combination of metals pre-
cipitation and filtration should prove an effective means of
treatment.
A conceptual design for the encapsulation is shown in Figure 3-5.
Determinations of depth to groundwater would be made during the siting pro-
cess and the cell constructed so that it is above the high groundwater
table.
Monitoring wells would be installed around the perimeter of the cell to
detect any possible breach in the cell.
The total area required for the cell would be approximately 11.25 acres
(700 feet by 700 feet). Allowing for a buffer area around the cell, and a
detention basin area, a total area of approximately 25 acres should be con-
sidered for the final disposal site.
3-21
-------
CO
I
ro
COVER
3'-0" THICK
SELECT SOIL
l'-0" THICK
RIP-RAP
j5 /-I'-6" THICK
SELECT
SOIL
r- ENCAPSULATED RADIOACTIVELY
CONTAMINATED MATERIAL
RIP-RAP
2'-6" THICK
LINER
2'-0" THICK
CAPILLARY
BREAK
I'-O" THICK
SELECT
FILL
MATERIAL
FILTER BED
0'-9" THICK
ORIGINAL GROUND
SURFACE
DETENTION
BASIN
5'-0"
l—RIP-RAP
I1-6" THICK
SCALE: N.T.S.
CDW
environmental engineers, scientists.
planners A management consultants
FIGURE 3-5
LINED ENCAPSULATION CELL
DISPOSAL OPTIONS B, D AND F
-------
The thickness of the encapsulation cell would vary depending upon the ex-
cavation alternative selected. The volume, area and thickness of cell for
each excavation alternative are shown below. The thickness of the pile
(8.5 feet) includes cap, liner and capillary break. Actual height above
ground surface will depend on depth to groundwater.
Excavation
Alternative
Alternative No. 4
Alternative Mo. 5
Volume of
Excavation
(cu yd)
119,000
122,000
Area of
Encapsulation Cell
(sq ft)
490,000
490,000
Thickness of
Encapsulation
(ft)
14
14.2
Proper attention to the protection of the stockpile during emplacement of
soil would be necessary. It would be necessary to continually monitor the
soil moisture content and to spray water as necessary to prevent the con-
tamination from becoming dispersed by the wind. However, excessive water-
ing would create runoff and this must be avoided.
The stockpile must also be covered at the end of each workday and during
inclement weather with a plastic sheet or waterproof tarpaulin.
Electric service would be provided along the perimeter of the site to pro-
vide power for air-monitoring equipment and lighting that would be neces-
sary for the design life of the facility.
The design of the cover, as indicated, would exceed the design objectives
for a final disposal facility since the radon emanation from the encapsula-
tion would be reduced to background levels and allow the site to be re-
leased for limited use, such as a park or recreational area.
3-23
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3.5.3 DISPOSAL OPTION C - INTERIM STORAGE IN GLEN RIDGE AND REEXCAVATION
FOR FINAL DISPOSAL WITHIN 400 MILES
Under this alternative Barrows Field in Glen Ridge and a number of homes
surrounding the field would be purchased and the homes demolished to create
a temporary storage site. Barrows Field was specifically selected from the
possible storage locations within the three sites to minimize the number of
homes that would have to be bought and demolished. Contaminated materials
from the remaining properties in Montclair, West Orange and Glen Ridge
would be excavated to the criteria of the selected excavation alternative
and transported to the Barrows Field site for temporary storage. The
contaminated materials at the Barrows Field site would remain in place. It
is estimated that 22 residential properties would be purchased to create
the site required for this alternative.
The interim storage site would be constructed by placing the excavated
soils directly on the contaminated soils at the Barrows Field site. The
pile would be covered with an 80-mil-thick EPDM liner as described for the
interim storage pile in disposal option B and covered with 1 foot of seeded
topsoil to prevent erosion. Approximately 301,000 square feet would be
required to accommodate the storage pile.
The height of the storage pile would vary depending upon the excavation
alternative selected. The height of the pile for each excavation alterna-
tive is shown below.
Excavation
Alternative
Volume of
Excavation
(cu yd)
Area of
Storage Pile
(sq ft)
Height of
Interim Pile
(including topsoil
(ft)
Alternative No. 4 67,000
Alternative No. 5 69,000
301,000
301,000
7.0
7.2
3-24
-------
Drainage swales would be constructed around the storage pile to channel
storm runoff to a detention basin, which would be constructed at the
southeastern end of the site. Here the stormwater would be analyzed and
treated prior to discharge to the local stormwater system.
A conceptual design of the storage pile is shown on Figure 3-6 and the
proposed area of construction is shown on Figure 3-7. The material would
be stored at the site until such time as a permanent disposal facility is
sited within the State of New Jersey or at another appropriate location
within 400 miles. At that time the radioactively contaminated soils would
be re-excavated and transported to the final disposal facility as described
for Option B.
3.5.4 DISPOSAL OPTION D - PERMANENT DISPOSAL AT A LINED, ENCAPSULATED CELL
IN GLEN RIDGE
Under this option the contaminated materials in Montclair/West Orange and
Glen Ridge would be excavated to the criteria of the selected alternative
and transported as described for Option B to the Barrows' Field site for
permanent encapsulation.
This option would require that 62 residential properties, Barrows Field and
a portion of the Glen Ridge Municipal Yard be purchased to create a site
large enough to contain the contaminated materials. The area under con-
sideration is shown in Figure 3-8.
The encapsulated material would require an area of approximately 345,000
square feet, the thickness of which would vary depending upon the excava-
tion alternative selected. The volume, area and thickness for each excava-
tion alternative are shown below.
Excavation Volume of Excavated Area of Thickness of
Alternative Material Encapsulation Cell Encapsulation
(cu yd) (sq ft) (ft)
Alternative No. 4 119,000 345,000 16.8
Alternative No. 5 122,000 345,000 17.0
3-25
-------
345' • .
X-EDGE OF ASPHALT SLAB
\
—
/
mini
CONTAMINATED SOIL-/
~^
ill
TOP SOIL
MM
/
\
LO
r^
00
PLAN
12' HIGH FENCE
(ALL AROUND)
345'
•I1 TOP SOIL & SEEDED
^80 MIL EPDM LINER
i /
•RUNOFF DITCH
(ALL AROUND)
SCALE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-6
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
INTERIM STORAGE PILE
DISPOSAL OPTION B
3-26
-------
SITE LIMITS
STUDY AREA PERIMETER
*•$ PERIMETER ROAD
SCflLE: N.T.S.
CDM
environmental engineers, scientists.
planners & management consultants
3-27
FIGURE 3-7
MONTCLAIR / WEST ORANGE AND 6LEN RID6E
RADIUM SITES
GLEN RIDGE INTERIM STORAGE AREA
OPTION C
-------
SITE LIMITS
STUDY AREA PERIMETER
PERIMETER ROAD
fa
p
p-
p-
l_
h
T
1
1
!/
7
J
_
~
r-
D
f"
a
TOP
TO**
^^-
D
ntfl*
»0»
D
OJ
•LO
— ^
a
j
n» *
OMV
I]
ear
*1£
I
SCflLE: N.T.S.
CDftl
environmental engineers, scientists.
planners & management consultants
FIGURE 3-8
MONTCLAIR / WEST ORANGE AND 6LEN RID6E
RADIUM SITES
GLEN RIDGE PERMANENT DISPOSAL AREA
'OPTIONS G AND H
3-28
-------
The thickness of the encapsulation cell (8.5 feet) includes cap, liner and
capillary break. The height above existing ground surface will be dependent
upon depth to groundwater. It is possible that, with the existing grade of
Barrows Field a wedge-shaped cell could be constructed that would blend in
more naturally with the area.
Unlike the interim storage facility described for Option C this facility
would be designed as a permanent facility with no future excavation and
transportation of contaminated soils required.
The construction of the encapsulation cell and the placement of the con-
taminated materials is described under Option B.
3.5.5 DISPOSAL OPTION E - PERMANENT DISPOSAL AT AN UNLINED, CAPPED CELL IN
GLEN RIDGE
This option is identical to Disposal Option D with the following exceptions:
(1) The contaminated materials at the disposal site would remain in
place and the contaminated materials from the remaining properties
would be placed directly on the contaminated materials already in
place.
(2) The 1-foot-thick capillary break and the 2-foot thick soil liner
would not be constructed for this alternative.
Figure 3-9 depicts the conceptual design for this option. The area under
consideration is the same as shown in Figure 3-8.
For the purposes of this feasibility study and to satisfy the design objec-
tive, the capped cell would meet the specifications detailed in Option B,
except for the capillary break and the encapsulation cell liner.
The thickness of the capped cell would vary depending upon the excavation
alternative selected. The volume, area and thickness for each excavation
alternative are shown below.
3-29
-------
•COVER
3'-0" THICK
OJ
I
00
CD
SELECT SOIL
I'-O" THICK
RIP-RAP
l'-6" THICK
ENCAPSULATED RADIOACTIVELY
CONTAMINATED MATERIAL
RIP-RAP
2'-6" THICK
ORIGINAL
GROUND
SURFACE
FILTER BED
0'-9" THICK
DETENTION
BASIN
— RIP-RAP
l'-6" THICK
SCALE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-9
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
UNLINED ENCAPSULATION PERMANENT STORAGE CELL
DISPOSAL OPTIONS E AND G
-------
Excavation
Alternative
Alternative No. 4
Alternative No. 5
Volume of
Excavation
(cu yd)
59,000
61,000
Area of Unlined
Cell
(sq ft)
345,000
345,000
Thickness of
Capped Pile
(sq ft)
10.1
10.3
The thickness of the capped cell includes a 5.5-foot-thick cap. The height
above existing ground surface will be dependent upon depth to groundwater.
Construction of the pile would begin at one end of the site by placing and
compacting the contaminated materials to the required height.
As the placement of the material proceeds, the construction of the encapsu-
lation cell cover, the riprap layer and topsoil layer would begin, mini-
mizing the areal extent of contaminated soil exposed to the elements.
The design of the cover, as indicated, would exceed the design objectives
since the radon emanation from the encapsulation would be reduced to •
background levels and allow the site to be released for limited usage as a
park or recreational area.
3.5.6 DISPOSAL OPTION F - PERMANENT DISPOSAL AT A LINED, ENCAPSULATED CELL
AT EACH SITE
Under this option all radioactively contaminated materials from each of the
three sites would be excavated to the criteria of the selected excavation
alternative and permanently disposed of in a lined, encapsulated cell at
the three respective sites, thus creating three permanent disposal sites as
depicted by Figures 3-10, 3-11 and 3-12.
In order to construct the three disposal facilities it would be necessary
to purchase 22 residential properties in Glen Ridge, 38 residential
properties in Montclair, and 8 residential properties in West Orange.
3-31
-------
SITE LIMITS
STUDY AREA PERIMETER
PERIMETER ROAD
SCflLt N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
3-32
FIGURE 3-10
GLEN RIDGE
ONSITE PERMANENT DISPOSAL AREA
OPTIONS F AND G
-------
LEGEND:
• •• SITE LIMITS
STUDY AREA PERIMETER
ig^PERIMETER ROAD
SCflLE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
3-33
FIGURE 3-11
MONTCLAIR
ONSITE PERMANENT DISPOSAL AREA
OPTIONS F AND G
-------
STUDY AREA PERIMETER
• •• SITE LIMITS
W88& PERIMETER ROAD
SCfiLE: N.T.S.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 3-12
WEST ORANGE
ONSITE PERMANENT DISPOSAL AREA
OPTIONS F AND G
3-34
-------
The thickness of each cell would vary depending upon the excavation alter-
native selected. The amount of contaminated soil to be excavated, the size
of each site and the height of the encapsulation cell for each of the
excavation alternatives for each site are shown below.
HEIGHT OF PERMANENT LINED CELL AT EACH SITE
Site and
Excavation
Alternative
Glen
Glen
Ridge
Ridge
Montclair
Montclair
West
West
Orange
Orange
Al
Al
Al
t.
t.
t.
Alt.
Al
Al
t.
t.
4
5
4
5
4
5
Volume of
Material
(cu
63
64
48
49
9
9
yd)
,000
,000
,000
,000
,000
,000
Area of
Encapsulation
(ft)
301
301
115
115
44
44
,000
,000
,000
,000
,500
,500
Thickness of
Encapsulation
(ft)
13
13
18
19
13
13
.2
.2
.8
.0
.0
.0
The thickness of the encapsulation cell (8.5 feet) includes the cap, liner
and capillary break. While the total cell thickness at each site ranges
from 13.2 feet up to 19 feet, the profile of the pile would be lower since
a portion of the cell would be constructed below grade but above the
groundwater table.
The design of each encapsulation cell would be identical to that described
for the permanent disposal cell for Disposal Option B and as depicted in
Figure 3-5.
The design of the cover, as indicated, would exceed the design objectives
since the radon emanation from the encapsulation would be reduced to
background levels and allow the site to be released for limited use such as
a park or recreational area.
3.5.7 DISPOSAL OPTION G - PERMANENT DISPOSAL AT AN UNLINED CAPPED
CELL AT EACH SITE
Similar to Option F, this option would create a permanent disposal area at
each of the three sites. The disposal areas considered for this option are
identical to those described for Option F and as shown on figures 3-10,
3-11 and 3-12.
3-35
-------
There are two major differences between this option and Option F:
(1) The contaminated materials that exist at the disposal area would
remain in place. The remaining contaminated material from each
site would be excavated and transported to the respective disposal
area, placed on the contaminated material already on site and
capped as for Disposal Option E.
(2) The 1-foot thick capillary break and 2-foot thick soil liner used
in Option F would not be constructed for this option.
The height of the capped pile would vary depending upon the excavation al-
ternative selected. The amount of contaminated material that would be ex-
cavated under this option, the area of the disposal pile and the height
above the existing ground surface for each excavation alternative are shown
below.
HEIGHT OF PERMANENT UNLINED CELL AT EACH SITE
Site and
Excavation
Alternatives
Glen
Glen
Ridge
Ridge
Montclair
Montclair
West
West
Orange
Orange
Alt.
Al
Al
t.
t.
Alt.
Al
Al
t.
t.
Volume of
Material
(cu yd)
4
5
4
5
4
5
11
11
33
34
4
4
,000
,000
,000
,000
,000
,000
Area of
Capped Pile
(sq ft)
301
301
115
115
44
44
,000
,000
,000
,000
,500
,500
Thickness
(including
(ft)
6
6
13
13
7
7
of Pile
cap)
.5
.5
.2
.5
.9
.9
The design of the cover, as indicated, would exceed the design objectives
since the radon emanation from the capped cell would be reduced to back-
ground levels and allow the sites to be released for limited use such as a
park or recreational area.
3-36
-------
3.5.8 DISPOSAL OPTION H - OCEAN DISPOSAL
The description of the ocean disposal option assumes that an appropriate
site would be selected, an environmental impact statement (EIS) prepared,
and the necessary permits secured. It is expected that the length of the
site selection, EIS and permitting process would require that the soils be
placed at an interim storage site until such time as a disposal site is
selected and the necessary permits obtained. Because it is unclear at this
time whether containerization would be required for the relatively small
amounts of radionuclides needing disposal, the simplest case, bulk dis-
posal, will be described. Changes in the option resulting from immobiliz-
ing the soils in a cement matrix will also be treated briefly.
For the purpose of this study, the site assumed for ocean disposal is the
106-Mile Ocean Waste Disposal Site (Site 106) managed by EPA.
Dock facilities would be secured by lease from a public or private operator
within the New York Port District. The dock area would be prepared with a
large storage bin for soils, lined to allow collection of runoff, and a
decontamination pad for the trucks. Sufficient dock space woul'd be
required to moor four barges.
Reexcavated soils would be delivered to the dock at the rate of 1500
cu yd/day, 5 days a week, for an average delivery of 7500 cu yd/week.
After dumping their load into the bin, the trucks would be decontaminated
as proposed for the excavation alternatives (Section 3.4). All runoff and
other water would be collected, settled and treated to remove contaminants
and discharged to the waters near the dock. Some water would be sprayed on
the soil in the bin and barges to reduce fugitive dust emissions. Activ-
ities at the dock would be restricted to the smallest possible area to
limit the amount of decontamination needed. At the end of the contract for
the dock facility, when the disposal operation is complete, the dock and
equipment would be radiologically surveyed and decontaminated.
3-37
-------
The loading and departure of the barges would be scheduled as needed to
minimize the accumulation of soil at the dock. Four bottom-dump barges
would be secured by contract, to allow continuous waste loading at the dock
and provide contingency waste-storage capacity. The barges would each have
a capacity of 4,500 tons, equivalent to 3,000 cu yd of soil. Soils would
be loaded onto the barges with clamshell buckets operated by crawler
cranes. It is anticipated that two cranes would be able to transfer the
soil to tire barges at the rate it is delivered to the dock. Alternatively,
arrangements might be made to have the trucks delivering the soil dump
directly onto the barges.
The barges would be towed to sea by an ocean-going tug secured on contract.
Two loaded barges will be towed per trip. Dumping would occur at the site
by opening the barges' bottoms while they are in tow. After the soils are
dumped, the barges would be decontaminated by washing with ocean water
while at sea.
A round trip to Site 106 is expected to take between 2 and 3 days. With a
delivery rate of 1500 cu yd/day, the minimum time between departures"would
be 4 days. An average of 1.25 trips/week would be required to keep up with
the projected delivery rate, with some allowance for delays in barging
operations. At the projected soil delivery rate, removal of the interim
storage pile would require 4 months. At an average round-trip duration of
60 hours, and a projected need of 21 round trips, the disposal operation
could be completed within this time frame.
In the scenario for disposing of immobilized soil, the contaminated soils
would be cemented into blocks of 2 cu yd volume, each containing
approximately 1.5 cu yd of soil. The blocks may be produced at the dock or
at the interim storage site.
At the projected reexcavation rate of 1,500 cu yd/day, approximately 3
acres would be required for the batch plant to mix the soil and cement and
for setting the forms to mold the mixture into blocks. Some pilot testing
3-38
-------
would be required to determine the optimum mixture for binding the soil
particles, and the effects of clumped soil, rocks and other large soil com-
ponents on the structural properties of the blocks.
Blocks may be more readily stockpiled than bulk soil. This would allow
more flexibility in scheduling the barging operations. The blocks them-
selves would require approximately one-third more trips than bulk soil,
but would require less time to fully load two barges for each trip.
The blocks would be dumped at the site by opening the bottoms of the
barges. If the blocks would not fall freely through the bottom of the
barge, it might be possible to unload them using a barge-mounted crane.
Use of the crane would add 6 days to each trip.
The third scenario uses surplus cargo ship hulls as containers for the
excavated soil. These hulls would be loaded with soil, towed to the
disposal site and scuttled. Because of their deeper draft, the number of
suitable wharves for ship hulls is more limited than for barges, but
wharves are available. Each hull holds 20,000 tons of soil, requiring 9
ships to dispose of the 122,000 cubic yards or 165,000 tons of soil.
The ocean disposal scenarios may require periodic monitoring by manned or
unmanned submersible to determine the final location of the dumped
materials and monitor their spread and effects on the environment of the
disposal site.
(6H5/10)
3-39
-------
REFERENCES FOR CHAPTER 3
REPORTS
Baker/TSA, Construction Plans and Specifications for Montclair/Glen Ridge
Radiological Contamination Removal, March 18, 1985.
Baker/TSA, Specifications for The Disposal of Contaminated Materials,
March 18, 1985.
Baker/TSA, Specifications for The Transportation of Contaminated Materials,
March 18, 1985.
Bechtel National Inc., Advanced Technology Division, Environmental Monitor-
ing Plan for the Maywood Site, Maywood, NJ, September 1984.
Envirosphere Company, Engineering Feasibility Study and Health Physics
Evaluation of a Proposed Temporary Storage Site for Radioactive!/
Contaminated Soil, August 1984.
NLO, Inc., Project Report of Phase I Remedial Action of Properties
Associated with the Former Middlesex Sampling Plant. September 1981
(NLCO-006EV).
United States Department of Energy, Draft Environmental Impact Statement
for Long-Term Management of The Existing Radioactive Wastes and Residues at
The Niagara Falls Storage Site, August 1984.
United States Department of Energy, Engineering Evaluation of Alternatives
for the Disposition of Niagara Falls Storage Site, Its Residues and Wastes,
January 1984.
United States Department of Energy, Final Environmental Impact Statement,
Remedial Actions at the Former Vitro Rare Metals Plant Site, Canonsburo,
Washington County, Pennsylvania, Volume I, Vol. II, Appendices. July 1983
(DOE/EIS - 0096-F).
3-40
-------
United States Department of Energy, Vicinity Properties Management and
Implementation Plan, Final, June 1984 (UMTRA-DOE/AL-050601).
United States Department of Energy, Plan for Implementing EPA Standards for
UMTRA Sites - Not Dated - (UMTRA-DOE/AL-163).
United States Department of Energy, Oak Ridge Operations Office, Remedial
Action Work Plan for the Maywood Site, July 1984 (ORO-850).
United States Department of Energy, Oak Ridge Operations Office, Remedial
Action Work Plan for The Middlesex Landfill Site. August 1984.
Meetings and Telephone Conversations
December 6, 1984 Meeting between Camp Dresser & McKee Inc. and NJDEP.
January 4, 1984 Meeting between Camp Dresser & McKee Inc. and Bechtel
National Inc., Baker Engineers, Holt & Ross, USEPA and NJDEP.
January 22, 1984 Meeting between Camp Dresser & McKee Inc., and Roy F.
Weston, Inc.
March 19, 1985 Telephone Conversation between B. Germanic of Camp Dresser &
McKee Inc., and D. Adrian of U.S. Ecology.
May 15, 1985 Meeting between Camp Dresser & McKee Inc., R.F. Weston, Inc.,
Jacobs Engineering, Morrison-Knudsen, Bendix Corp., EPA and DOE.
July 26, 1985 Telphone Conversation between W. Smith of Camp Dresser &
McKee Inc., and M. Morrow of New York/New Jersey Port Authority.
July 26, 1985 Telephone Conversation between W. Smith of Camp Dresser &
McKee Inc. and dispatcher of Reinauer Towing.
3-41
-------
July 29, 1985 Telephone Conversation between W. Smith of Camp Dresser &
McKee Inc., and F. Jannuzzi of Weeks Stevedoring Company, Inc.
(6H5/10)
3-42
-------
-------
4.0 ANALYSIS OF CANDIDATE REMEDIAL ALTERNATIVES
This chapter presents detailed analyses of the candidate remedial alterna-
tives described in Chapter 3. The analyses are divided into five areas:
technical feasibility, environmental assessment (including socioeconomic
analysis), public health evaluation, institutional assessment and cost
analysis.
4.1 TECHNICAL FEASIBILITY
In this section the technical feasibility of each alternative is assessed,
with the exception of Alternative 1, the No Action alternative, which does
not involve issues of technical feasibility. Technical feasibility was
evaluated in terms of performance, reliability, implementability and
safety.
The performance of each alternative was analyzed by determining its effec-
tiveness in remediating the hazard at the site, and its useful life. Reli-
ability issues were addressed by assessing the operation and maintenance
requirements of each alternative and by assessing its previously demon-
strated performance. Implementability was evaluated in terms of the ease
of completing the remedial action and the time necessary to achieve the
specified level of response.
Safety issues are addressed in the environmental assessment (Section 4.2)
and public health evaluation (Section 4.3), leaving the first three ele-
ments to be addressed in this section.
4.1.1 ALTERNATIVE 2 - ACTIVE/PASSIVE MEASURES
This alternative consists of continuing and extending the existing removal
actions that utilize ventilation systems to reduce radon progeny to all
tier A, B and C residences. In addition, trench vents would be constructed
in the 12 residences where annual radon progeny averages are still above
4-1
-------
0.02 WL. The quarterly monitoring program would be continued to assure the
effectiveness of the systems. The 14 residences with elevated gamma
radiation would be retrofitted with lead or concrete shielding to attenuate
gamma radiation to within acceptable public health guidelines.
Performance
Quarterly monitoring results taken to date indicate that the ventilation
systems are effective in reducing the radon levels in the homes. However,
they do not bring the radon levels in every home to acceptable levels. The
effectiveness of the ventilation systems is documented in Table 4-1. It is
hoped that, with the addition of trench vents, all residences will be able
to be remediated to the 0.02 WL standard. A similar remediation in Potts-
town, Pennsylvania, has achieved a 99 percent reduction in radon progeny
levels, with concentrations going from 13-16 WL to 0.02-0.05 WL.
Laboratories and hospitals retrofitted with lead and concrete have been
demonstrated to be effective in reducing gamma radiation to within
acceptable public health limits.
Reliability
The useful life of the ventilation systems is thought to be about 10 years.
However, the ventilation systems have already been shown to be unreliable,
requiring much more maintenance than originally thought. Several systems
have had to be replaced as their efficiencies of radon reduction dropped
dramatically over time. Radiation shielding with lead or concrete is a
proven, reliable method.
Implementability
The ease of implementing the active/passive systems alternative has been
demonstrated at the three sites and at the Pottstown, Pennsylvania, resi-
dence. Replacement and maintenance, while bothersome, are also easily
implemented. It took 3 weeks to install the systems in the initial 22
4-2
-------
TABLE 4-1
RADON AND RADON PROGENY REDUCTION IN REMEDIATED RESIDENCES
Pre-Remediation
Post Remediation
% Radon Reduction
Radon Progeny
(working level)
Radon
(pCi/L)
Radon Progeny
(Working Level )
11 n
#3
Radon
(pCi/L)
151 Carteret, Glen Ridge
Basement 0.201
First Floor 0.287
Second Floor NA
37 Virginia, Montclalr
Basement 1.549
First Floor 0.170
Second Floor NA
66 Nishuane, Montclalr
Basement 0.204
First Floor 0.256
Second Floor NA
64 Nishuane, Montclair
Basement 0.505
First Floor 0.466
Second Floor NA
110.4
80.6
85.3
440.0
50.0
132.0
102.0
83.8
92.6
186
112
120
0.010
0.021
NA
0.001
0.001
NA
0.044
0.026
NA
0.014
0.042
NA
0.012
0.027
NA
0.004
0.005
NA
0.081
0.153
NA
0.004
0.005
NA
0.006
0.005
NA
0.017
0.034
0.044
14.2
10.3
9.4
0.4
0.5
0.5
36.1
26.8
25.4
10.0
17.8
14.1
87
87
89
99
99
99
65
68
73
95
84
88
NA = Not Available
Reprinted from: Czapor, John V., Kenneth Gigllello, and Jeanette Eng., Radon Contamination In Montclair and Glen Ridge. New
Jersey; Investigation and Emergency Response, November 1984.
(4H9/24)
-------
homes. The construction of the trench vents in the Pottstown residence was
completed within 3 months. Maintenance could be carried out at the time of
the quarterly radon progeny integrating sampling unit (RPISU) monitoring to
minimize disruption of the household.
Retrofitting commercial buildings with lead and concrete panels to reduce
gamma radiation has been routinely implemented, and should also be readily
applied to a residential building.
Summary of the Feasibility Analysis of Alternative 2
o Ventilation systems in combination with trench vents have been
implemented and are effective.
o These systems have extensive operation and maintenance requirements.
o Retrofitting buildings for radiation shielding has been implemented
and is effective.
4.1.2 ALTERNATIVE 3 - RELOCATION OF RECEPTORS
The technical feasibility of relocating the residences, purchasing the
properties and restricting the public from accessing the contaminated
properties was evaluated.
Relocation of the residents will entirely eliminate the elevated exposures
to radon and gamma radiation that they currently receive and thus minimize
the public health threat. The reliability of the access restrictions will
be highly dependent on such institutional controls as deed restrictions,
security and fence maintenance. While access restrictions have failed at
some of the more remote Superfund hazardous waste sites, it is believed
that location in the more controllable urban residential neighborhood will
insure performance. Similar types of access restrictions to protect aqui-
fer recharge areas or reservoirs have been proved implementable in resi-
dential areas, providing security measures and maintenance are maintained.
4-4
-------
Summary of the Feasibility Analysis of Alternative 3
o Relocation is effective in reducing public health threat.
o Access restrictions have been previously implemented.
o Access restriction entails extensive security and maintenance.
4.1.3 EXCAVATION ALTERNATIVES 4, 5 AND 6
As indicated by excavation activities at sites remediated under the Uranium
Mill Tailings Remedial Action (UMTRA) project and the Formerly Utilized
Sites Remedial Action Program (FUSRAP), excavation of the contaminated
materials to the 5/15 pCi/g standard is technically feasible.
Performance and Reliability
Data obtained from the Middlesex, New Jersey, remediation under FUSRAP
shows that excavation of the material was effective in reducing both the
outdoor radon concentrations and the radium-226 concentrations in the soil
to levels sufficient to allow the properties to be released for unre-
stricted use. Examples of these reductions are shown in Figures 4-1
through 4-4. In addition, indoor radon measurements taken before and after
remediation at Grand Junction, Colorado, indicate that removing the radium-
contaminated materials from the ground and under the homes will reduce the
indoor radon concentrations. Table 4-2 shows typical pre-remediation and
post-remediation indoor radon levels from the Grand Junction remediation
site.
Implementability
Both the Middlesex and Maywood remediations have shown the implementability
2
of excavating soil to the 5/15 pCi/g standard averaged over 100 m areas
using reasonable search and verification procedures. Implementing
Alternative 6, excavation of all radium-contaminated soil above the 5/15
4-5
-------
• 0 I
432 WILLIAM STREET RESIDENCE
Th-230 Release Level = 0.08 pCi/m3
U-Nal 1/100 Release Level = pCi/m3
Ra-226 1/100 Release Level = 0.03 pCi/m3
pCi/mv
a
i
a
o
u
o
a
p
c>
M«if. LOwei l im.l ot Oelaculmily • 0 OoJ |.Cmn'
B.'b
8.6
lO'lO 10'I6
NOTE: See Figure 6-5 For
Sampler Locations
SOURCE: Project Report of Phase 1 Remedial Action
of Properties Associated with the Former
Middlesex Sampling Plant Site.
FROM : Eberline Instrument
Corp. Report to NLO
COM
environmental engineers, scientists
planners & management consultants
FIGURE 4-1
AVERAGE GROSS ALPHA AIR
SAMPLE CONCENTRATION
-------
10;.
432 WILLIAM STREET
M..,m,,,n Po.m.SiiUlo
- }0|>Cul
BEGIN MONIIORINC
END MONITORING
\,
Mean Lowct Liimi ol DeteciaixMy a 0 20 pCI'l
SOURCE: Project Report of Phase 1 Remedial Action
of Properties Associated with the Former
Middlesex Sampling Plant Site.
FROM : Eberline Instrument
Corp. Report to NLO
COM
environmental engineers, scientists.
planners 4 management consultants
FIGURE 4-2
AVERAGE RADON CONCENTRATION
-------
432 WILLIAM STREET
10
20
30
40
50
27.5
0.8 1.1
1.3
1.0 C.8
17.5
56.2 30.3 153.1 104.4 12.7
7.5
78.7 107.4 168.0 149.3 23.3 3.7
53.5 35.0 30.2 24.5 9.1 6.8
4.0 5.1 4.0
9.0 8.7 2.1 1.J1
1.1
E.7
NOTE:
226
Ra levels expressed
as pCi/g.
SOURCE: Project Report of Phase! Remedial Action
of Properties Associated with the Former
Middlesex Sampling Plant Site.
COM
environmental engineers, scmntists.
planners & management consultants
FIGURE 4-3
PRE-CLEANUP 226Ra SURFACE
CONCENTRATIONS
-------
432 WILLIAM STREET
27.5
10
20
30
40
50
17.5
7.5
1.0
1.3 1.1 1.0 0.8 1.1 1.0
1.0 1.1 1.1
1.0
0.8 1-3 1. 1 IB OB 11 'in* 1.2
1.2 1.3 1.3 1.B 1.8
1.1 1.4
1.1 1.3 1.3 1.2 1.0
1.4 0.9 0.9
1.1 1.3 1.1 1.1 B.8 1.1 1.7 1.4
t
1.2 1.1 1.1 1.4 0.8 1.1 19
1.5 1.9
1.5 1.6
1.5 1.2 1.2
1.1 0.9
1.0 1.3 1.3 1.3
NOTE: 226
Ra levels expressed
as pCi/g.
SOURCE: Project Report of Phase 1 Remedial Action
of Properties Associated with the Former
Middlesex Sampling Plant Site.
COM
environmental engineers, scientists.
planners & management consultants
FIGURE 4-4
POST-CLEANUP 226Ra SURFACE
CONCENTRATIONS
-------
TABLE 4-2
Pre- and Post-Remedial Action Working Levels
Property No. Building Type
Pre-remedial
action WL and
(year of sample)
Post-remedial
action WL and
(year of Sample)
00001
00001*
00001*
00001*
00004
00012
00018
00020
00034
00050
00070
00080
00089
00091
00097
00098
00118
00142
00160
00194
00208
00249
00253**
00260
00269
00273
00295
00313
00315
00356
00376
00397
00399
00410
00421
00424
00456**
00473
00489
private residence
private residence
private residence
private residence
private residence
private residence
commercial building
private residence
private residence
school
private residence
private residence
private residence
college dormitory
gas station
private residence
private residence
private residence
private residence
private residence
private residence
private residence
occupational center
private residence
private residence
private residence
private residence
private residence
school
school
private residence
commercial business
commercial business
commercial business
pharmacy
commercial business
0.174 (71-72)
0.086 (72-73)
0.056 (72-72)
0.019 (72-73)
0.054 (71-72)
0.024 (70-71)
0.088 (71-71)
0.028 (76-77)
0.022 (71-72)
0.200 (70-71)
0.018 (79-80)
0.136 (74-75)
0.037 (71-72)
0.021 (71-72)
0.051 (70-71)
0.042 (72-72)
0.121 (79-80)
0.030 (77-78)
0.043 (75-76)
0.176 (81-81)
0.030 (78-79)
0.038 (75-76)
0.029 (71-73)
0.020 (71-72)
0.147 (70-71)
0.024 (76-77)
0.027 (71-72)
0.098 (71-72)
0.064 (70-72)
0.055 (70-72)
0.037 (75-76)
0.190 (71-72)
0.090 (71-72)
0.062 (71-72)
0.524 (78-78)
0.621 (71-72)
0.103 (/5-/5J
0.026 (80-81)
0.004 (82-82)
0.020 (75-76)
0.010 (75-76)
0.006 (76-76)
0.016 (76-77)
0.008 (76-77)
0.015 (80-80)
0.015 (80-81)
0.017 (76-78)
0.005 (76-76)
0.009 (82-83)
0.005 (77-78)
0.012 (74-75)
0.004 (81-82)
0.005 (82-82)
0.011 (76-77)
0.016 (81-82)
0.016 (80-80)
0.011 (78-80)
0.111 (82-82)
0.004 (80-80)
0.007 (77-78)
0.005 (76-76)
0.016 (79-80)
0.021 (74-76)
0.006 (78-79)
0.005 (76-76)
0.013 (75-76)
0.008 (82-82)
0.008 (76-76)
0.010 (78-79)
0.009 (79-79)
0.010 (77-77)
0.070 (81-81)
0.016 (81-81)
0.027 (77-78)
* Addi11onal post-remedial action working levels
**Additional remedial action being conducted
-------
pCi/g standard may necessitate technical requirements that are beyond the
capabilities of the field instruments and protocols developed to date. The
cost of verifying, with statistical reliability, that all
radium-contaminated material has been excavated will definitely be
prohibitive.
Due to the questions of implementabiity described in the previous para-
graph, Alternative 6, excavation to remove all contamination above the 5/15
pCi/g standard, will not be considered any further in this report. There-
fore, there remain only two excavation alternatives, Alternative 4 and
Alternative 5.
The implementability of excavating contaminated materials from under the
basement slabs, while supporting the structure or underpinning the founda-
tion, has been proven at both the Middlesex, and Maywood, New Jersey sites.
Remediation under the NJDEP Phase I program at Montclair/West Orange and
Glen Ridge is incorporating these techniques.
Moving homes off their foundations has not been employed at the Middlesex
and Maywood sites for remediation purposes, but it is common practice to
move homes from one site to another. It can be adapted to the remediation
at Montclair/West Orange and Glen Ridge.
Summary of the Feasibility Analysis of the Excavation Alternatives
2
o Excavation to 5/15 pCi/gm standard averaged over 100 m has been
proven to be implementable and effective.
o Excavation Alternative 6, to remove all contaminated material above
5/15 pCi/g, is not implementable.
4.1.4 DISPOSAL OPTIONS A THROUGH H
For assessment of the technical feasibility of the disposal options, the
various components--transportation, interim storage or permanent dis-
posal --were first analyzed and are then compiled to produce a comprehensive
summary of each option.
4-10
-------
Transportation
Transportation of the contaminated soils in bulk form using covered dump
trucks or in 55-gallon drums using flat-bed semitrailer trucks, is common
practice for moving radioactively contaminated soils. It has been demon-
strated by remediations at Middlesex, New Jersey, Maywood, New Jersey,
Canonsburg, Pennsylvania, and the remediation currently being conducted in
Montclair and Glen Ridge under the NJDEP Phase I program.
It should be noted that local weight restrictions of 4 tons exist on muni-
cipal streets in West Orange with the exception of specially designated
truck routes and for pickup and delivery of materials on municipal streets.
The use of 16-cubic-yard dump trucks would exceed this 4-ton weight limita-
tion. A waiver from the restriction would be required. The gross weight
of the truck would not exceed 70,000 pounds (35 tons), which is the maximum
gross weight of refuse collection vehicles. The use of smaller trucks
would impact the cost of remediation of the sites.
Rail transportation using trailer on flatcar (TOFC) is an acceptable mode
of transportation utilized in hauling contaminated materials from tailing
piles in the western states to final disposal. It would be most approp-
riate for shipment across country. For this option, existing TOFC trans-
loading facilities at each end will be utilized to transfer the trailers.
Barges or container ships would be required to transport contaminated soil
for ocean desposal. Barge transport for ocean disposal of sludge and other
wastes has proven implementable and reliable. Ocean disposal will require
more handling of waste prior to disposal. Wastes would first be trans-
ported to the interim storage site by truck and remain at the site until
the appropriate permit for ocean disposal is obtained, after which they
would be transported to an existing transloading facility at the Port of
New York.
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Disposal at Commercial -LLW Facility
The disposal of radioactively contaminated soils in 55-gall on drums is
acceptable at the Rich!and, Washington, LLW disposal site. The drums would
be disposed of according to standard procedures meeting all applicable
regulations.
Operation and maintenance of the licensed low-level radioactive waste sites
are performed by the owners of the facilities. Long-term monitoring of the
facilities post-closure is guaranteed by the respective state. The costs
for both operation and maintenance and perpetual maintenance are included
in the disposal charges.
The volume of soil to be disposed is immense compared to the normal volume
of LLW accepted by this commercial facility. The maximum yearly volume
that the Richland facility presently accepts is 1.3 million cubic feet per
year. After January 1, 1985, Richland will only be able to accept 1.2
million cubic foot per year, the majority of which will be reserved for the
use of the Northwest Compact states. If half of the yearly volume were
allocated for the Montclair/Glen Ridge soils, it would take at least a 5-
year period to complete the disposal action.
Interim Storage Pile
The design of the interim storage pile on an asphalt pad, covered with an
ethylpropylenediene monomer (EPDM) liner is similar to the interim storage
pile at Middlesex, New Jersey, with the addition of a topsoil cover. The
EPDM liner was selected for the Middlesex site because of its good weather-
ing characteristics and for its ability to attenuate approximately 98 per-
cent of the radon generated by the radium-contaminated materials. Air
monitoring at the Middlesex interim storage site indicates that the EPDM
liner is effective in reducing radon emissions.
The EPDM liner is currently manufactured by Carlisle Syntec Products in
Carlisle, Pennsylvania, and is available through local distributors. The
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construction and compaction of the storage pile would follow standard prac-
tices used at existing solid waste landfills.
An offsite interim storage site does not yet exist and would have to be
sited for the offsite option. A groundwater study will need to be per-
formed at the designated interim site and an ongoing groundwater monitoring
program will have to be established.
The construction period of the storage pile would last throughout the ex-
cavation and continue for a short time afterward. The entire construction
would be completed in 2 to 2 1/2 years.
Operation and maintenance for the interim storage site would consist of
quarterly site inspections to check the security fence and repair it as
necessary, and to check the topsoil cover for signs of erosion and maintain
it as necessary. Quarterly monitoring of the air and groundwater at the
site would also be required to insure that the design objectives are being
met. Storm water runoff collected at the detention basin would be
monitored on a periodic basis to determine the integrity of the EPDM liner.
If the ocean disposal alternatives is selected, the interim storage pile
site will need to be have 3 additional acres to allow for the space needed
for concrete containerization, if that becomes a pretreatment disposal
requirement.
The interim storage pile designed for the Barrows Field site is similar to
that constructed at the Maywood, New Jersey, site, where contaminated
materials were excavated and placed directly on the contaminated materials
that existed at the storage site. The EPDM liner will serve as a barrier
for precipitation infiltrating the pile. Since the material at the site is
already contaminated and runoff from the pile will be channeled to a
detention pond for monitoring and treatment as necessary, it is not antici-
pated that interim storage of the contaminated material will have any addi-
tional impact on the groundwater.
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Interim storage would provide an opportunity to evaluate a greater number
of final disposal options, allowing for the most cost-effective, environ-
mentally sound and technologically proven option to be selected.
Permanent Encapsulation
The encapsulation cell is similar to the cell being constructed at the
Canonsburg, Pennsylvania, site. The encapsulation cell cover is predicted
to reduce the radon emissions from the encapsulated material over the cell
to less than 3.0 picocuries per square meter per second, allowing the site
to be released for limited use such as a park or recreation area.
The encapsulation cell cover is also predicted to provide excellent pro-
tection to groundwater since infiltration though the cover or liner would
be minimal. However, at this time the effectiveness of the encapsulation
cell is unproven.
As with the interim storage option, the location of an offsite disposal
site would have to be selected and approved, a groundwater study would have
to be performed at the designated site, and an ongoing groundwater
monitoring program would have to be established.
The 3-foot-thick encapsulation cell cover is the primary barrier against
groundwater contamination for the unlined cap cell option. The amount of
precipitation permeating the cover will be minimized, decreasing the
opportunity for leaching of the contaminants. The absence of the liner and
capillary break for unlined capped cell could allow the migration of water
through the contaminated material.
Operation and maintenance of the permanent encapsulation would consist of
site inspections and repairs to fences and topsoil cover. Quarterly moni-
toring of air and groundwater at the site would be conducted for the first
5 years to insure that the design objectives have been met. After this
period, monitoring could be reduced to an annual basis to insure that the
integrity of the cell is being maintained.
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Operation and maintenance (O&M) of the permanent encapsulation would be
required for a minimum period of 200 years.
Ocean Disposal
Ocean disposal is a technically feasible option; however, it will require
the issuance of an ocean disposal permit from EPA. The permit applicant
must prepare a site-specific radioactive material disposal impact assess-
ment as specified by the January 1983 amendment to the MPRSA.
Ocean disposal would also necessitate the construction of an interim
storage pile with the technical difficulties and advantages specified for
that option.
Handling difficulties may be encountered if its decided that the soils must
be containerized prior to dumping from the barge. Facilities for process-
ing the soils into cement would have to be constructed and additional space
would be needed at the interim storage facility. Decontamination facili-
ties would need to be constructed for either containerized or bulk dis-
posal. However, the construction of such facilities is not difficult and
has been previously demonstrated at other construction sites.
Summary of the Feasibility Analysis of the Disposal Options
The evaluation of each disposal option is summarized below.
Disposal Option A - Permanent Disposal at a Licensed Low-Level Waste (LLW)
Disposal Facility
o Will need a 5-year minimum time period for implementation because
of annual volume restrictions.
o An existing facility with established O&M and long-term control
procedures is in operation.
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o Transportation methods are proven and implementable. However, a
transloading facility will have to be sited.
Disposal Option B - Offsite Interim Storage Within the State of New Jersey
or Other Appropriate Locations and Reexcavation for Final Disposal Uithin
400 Miles
o No interim or final disposal site exists.
o Groundwater studies are needed at both sites.
o O&M is required at interim site and at the final site for 200
years.
o Permanent encapsulation is unproven.
o Interim storage allows opportunities for a greater number of
disposal options.
o Transportation methods are proven and implementable.
Disposal Option C - Interim Storage in Glen Ridge and Re-excavation For
Final Disposal Within 400 Miles
o No final disposal site exists.
o A groundwater study is needed at the final disposal site.
o O&M is needed at the Glen Ridge site and at final site for 200
years.
o Permanent encapsulation is unproven.
o Interim storage allows opportunities for a greater number of
disposal options.
o Transportation methods are proven and implementable.
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Disposal Options D and E - Permanent Disposal at a Lined, Encapsulated
Cell in Glen Ridge/Permanent Disposal at an Unlined, Capped Cell in Glen
Ridge
o A groundwater study is needed at Glen Ridge.
o O&M is required for 200 years.
o Permanent encapsulation is unproven.
o No siting study is needed.
o Transportation methods are proven and implementable.
Disposal Options F and G - Permanent Disposal at a Lined, Encapsulated
Cell at Each Site/Permament Disposal of an Unlined, Capped Cell at Each
Site
o Three groundwater studies are needed.
o O&M is required for 200 years at three sites.
o Permanent encapsulation is unproven.
o Siting studies are not needed.
o Transportation methods are proven and implementable
Disposal Option H - Ocean Disposal
o An interim disposal site will need to be constructed with
accompanying need for a groundwater study (if offsite) and O&M
requirements.
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o Transportation methods are proven and implementable.
o A site specific environmental impact assessment is needed.
4.2 ENVIRONMENTAL ASSESSMENT
The candidate remedial alternatives include a no action alternative, an
engineering-based alternative, a public-health-based relocation alterna-
tive, three environmentally conservative excavation alternatives, and eight
disposal options. The remedial excavations are estimated to last 2 years,
during which adverse temporary impacts will result. The final environ-
mental condition of each site will be determined by the alternative and if
applicable the disposal option selected.
4.2.1 PHYSICAL ENVIRONMENT
This section evaluates the potential impacts to soil, surface water,
groundwater, air, noise and transportation associated with each alternative
and disposal option. The long-term impacts of excavation are considered in
conjunction with the disposal option selected.
Soil, Groundwater and Surface Impacts
Radiologically contaminated soil has been identified in the three study
sites. Radium-226 values in the different stratas of fill average 107 to
867 pCi/g but can exceed 2,000 pCi/g. The depth of soil contamination
ranges from the surface to at least 16 feet. The bulk of the radioactive
material, including the most contaminated material, is located within 5
feet of the ground surface.
Alternatives 1 through 3. These alternatives would result in the continued
presence of contaminated soil. These alternatives have no additional
impact on the physical environment. The soil would continue to be a source
of elevated levels of gamma radiation and radon gas.
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Alternative 4 (Excavation). Soil excavation would result in the interim
exposure of larger soil surface areas to wind and water erosion, which can
result in excessive sedimentation and dust generation. The excavation
activities would necessitate engineering controls to minimize these adverse
effects. Soil and vegetation removal would have to be compensated by a
comparable volume of soil replacement and revegetation. Restoration of the
land to a pre-remediation condition would require an interim grounds
maintenance program.
This alternative would result in the least amount of soil disturbance but
would also leave a considerable volume of contaminated soil remaining
beneath homes.
If this excavation alternative is selected, the source of surface water
contamination, surface open lands and residential elevated gamma radiation
and radon gas levels would have been removed or, in the case of soil
beneath homes, substantially reduced to achieve gamma radiation dose and
radon progeny levels within the acceptable public health standards of at
least 20 uR/hr or 0.02 WL of radon gas.
However, this alternative would result in the continued presence of con-
taminated soil with a continued potential for groundwater contamination,
and some surface water contamination, since groundwater recharges surface
water in Wigwam Brook.
Alternative 5 (Excavation). Interim impacts due to soil excavation are the
same as for excavation alternative 4, except that a greater volume of soil
would be excavated. Less contaminated material would be left in place.
The impacts of this excavation alternative in combination with any of the
disposal options are the same as those discussed under alternative 4, ex-
cept that virtually all contaminated soil in open land would be removed. A
minimal potential for groundwater contamination still occurs because the
excavation of contaminated materials is based on achieving an average
concentration over an area, consequently some elevated levels may remain.
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Disposal Options A and B. The offsite disposal of soils excavated from
each of the sites would remove the major source of contamination from the
study area. However, the long-term impacts of these disposal options are
influenced by the specific type of excavation alternative selected.
Disposal Option C. This disposal option consists of placing the conta-
minated soils excavated from the properties directly on the contaminated
soils in Barrows Field. The interim storage site would be designed with an
Ethylpropylenediene monomer (EPDM) liner and vegetated soil surface to
minimize surface erosion and water infiltration. The design of the storage
pile would primarily reduce the impacts to air and surface water, but the
potential groundwater contamination due to fluctuations under the unlined
storage pile would remain until such time as the material is removed to its
final disposal site. Interim storage would require engineering controls
and maintenance to limit erosion and the release of elevated levels of
radon gas, and the implementation of an environmental monitoring program to
measure their effectiveness.
The overall impacts of this disposal option in combination with excavation
alternative 5 would result in the transport of the majority of the con-
taminated soils to a single location where they will be subject to engi-
neering controls and monitoring. If excavation alternative 4 is selected,
some contaminated soil may still remain in open lands, and beneath some
homes, where it would be a continued source of potential groundwater con-
tamination. However, it would no longer pose a threat to surface water or
air.
Disposal Option D and F. Disposal Option D consists of encapsulating the
contaminated materials at a permanent disposal site to be located in Glen
Ridge. In contrast, Option F consists of encapsulating the contaminated
materials from each site at the respective site. The lined and fully
encapsulated cell(s) would be designed to minimize surface erosion, surface
and lateral water infiltration, and radon gas release. The cell design for
these disposal options would result in a minimal potential for contamina-
tion of surface waters and groundwater. Appropriate engineering controls
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and grounds maintenance to minimize the release of contaminants, and the
implementation of an environmental monitoring program to measure their
effectiveness would be an integral part of these options.
Disposal options D and F, in combination with either excavation alternative
4 or 5, would result in the isolation of the majority of the contamination
at a single location. Its long-term impacts are similar to Option C in
that any unexcavated soil would continue to be a source of potential
groundwater contamination.
Disposal Option E and G. Disposal Option E is similar to Option D, and
Option G is similar to Option F, except that the soils will be placed
directly on contaminated materials and the cell(s) would be unlined.
Permanent disposal in an unlined facility would have impacts discussed for
disposal options D and F, except that this disposal design has minimal
engineering controls for groundwater protection. The 3-foot-thick encap-
sulation cover is the primary barrier against groundwater contamination
through the reduction of water infiltration. The elimination of the cell
liner and capillary break will allow for the lateral movement of ground-
water through the contaminated materials, allowing for the continued
potential for groundwater contamination. Similar mitigation and monitoring
efforts as were discussed for disposal options C and D will be required.
Similar to disposal options C, D, and F, the long-term impacts of this dis-
posal alternative, in combination with excavation alternatives 4 or 5,
would mean that any unexcavated contaminated soil would also be a continued
source of potential groundwater contamination, but would no longer pose a
risk of surface water contamination.
Disposal Option H (Ocean Disposal). The ocean disposal of contaminated
soils excavated from each of the sites would remove them as a source of
contamination. The long-term impacts of this disposal option to the study
areas are influenced by the specific type of excavation alternative
selected. A factor in the implementation of this option involves the cur-
rently lengthy permitting process, which will very likely require onsite or
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offsite interim storage prior to ocean disposal. This disposal option, in
combination with excavation alternatives 4 or 5, will result in the same
impacts discussed under disposal options A and B. Offsite and marine
impacts are discussed below.
The disposal of radioactive wastes ceased in 1970 with the availability of
land disposal and the enactment of the Marine Protection, Research, and
Sanctuaries Act (MPRSA) of 1972, which imposed rigid standards on ocean
disposal. On January 6, 1983 the MPRSA was amended so that no permits for
the disposal of low-level radioactive waste would be issued until specific
EPA requirements were met.
A specific ocean disposal site has not been selected, and a detailed
environmental impact statement is out of the scope of this report. How-
ever, this report will consider the EPA-designated 106-mile-waste-disposal
site as a potential disposal site. A preliminary discussion will be made
based on a report that discussed the impacts of the disposal of the Niagara
Falls Storage Site (NFSS) wastes into the 106 Site.
The impacts of disposing low-level radioactive wastes into the ocean will
depend on the fate of the wastes in the ocean environment. Studies of
formerly designated radioactive waste disposal sites have not demonstrated
to be detrimental to public health or the environment. Massachusetts Bay
received 2,400 curies of radioactive waste between 1946 and 1958. This
represents 2 percent of the total U.S. disposal at sea during that period.
In an EPA study conducted in 1981 and 1982 it was concluded that previous
disposals in the Bay did not impact public health or the marine environ-
ment. Other studies during that same period were initiated to determine
the possible public health impact to the cities nearest the major radio-
active waste ocean dumpsites of the past. These sites, which included the
Farallon Islands dumpsite, the Atlantic 2,800 meter and 3,800 meter dump-
sites and the Massachusetts Bay dumpsite, received 97 percent of all
radioactive waste in the U.S. from 1946 until ocean disposal ceased in
1970.
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The 106 Site, located approximately 240 kilometers northeast of Cape
Hen!open, Delaware, was previously used as an EPA ocean disposal site for
industrial wastes in slurry form until the 2-year moratorium enacted by
Congress on January 6, 1983. The 106 Site has been extensively studied to
prepare the environmental impact statement used in support of its desig-
nation as an EPA disposal site. The site was not previously used as a
radioactive waste disposal site, and studies there principally investigated
the environmental impacts resulting from chemical waste disposal. However,
there is some vicinity baseline data on radium-226 and existing biota in
sediments and the water.
In 1984 the DOE published a report in which the impacts of disposing low-
level radioactive wastes at the 106 Site were modeled. The models were
based on the disposal of 180,000 cubic yards of the Niagara Falls Storage
Site (NFSS) wastes with a total of 7.8 curies. In comparison the
Montclair/West Orange and Glen Ridge wastes consist of 122,000 cubic yards
of soil, and a total of 33.2 curies. The models only considered the
disposal of uncontainerized LLW. The International Atomic Energy Agency
proposed that radioactive wastes should be immoblized by solidification or
containerization in a chemically compatible material. However, the
environmental merits of such a disposal method will need to be further
examined since-the LLW sites are predicted to exceed the life span of these
materials.
Ocean disposal models have generally considered the impacts of ocean dis-
posal on the basis of the dilution of liquid or easily dispersed solid
wastes. Since the NFSS wastes, similar to the Montcl air/West Orange and
Glen Ridge site wastes, consist in part of wet cohesive clay soils that
disperse less easily than liquids, two models were examined. One model
considered a case where the wastes fall directly to the ocean bottom
without dilution, and a case where the wastes would be well mixed. In the
first case it was estimated, on the assumption of using the highest flux of
radium-226 known for oceans, that the radium-226 levels would be raised to
0.002 pCi/1 over the waste piles. This represents a total increase of 2
percent based on the average radium-226 concentration in seawater of 0.1
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pCi/1. The Montclair/West Orange and Glen Ridge wastes, being 4.3 times
higher in radium concentration, would be expected to increase the radium-
226 concentration in seawater. The significance in the increase is
unknown. These wastes are less in volume than the NFSS, wastes so they
would cover less area than the 17 square kilometers (less than 0.1 percent
of the total 106 Site) predicted for the NFSS wastes at a thickness of 10
cm. The area of cover represents potential loss of benthic organisms.
In the case where the wastes are fully dispersed by vertical and horizontal
mixing, waste dilutions for mixing conditions at the end of 4 days were
considered. The experimental dispersion data as adapted for this discus-
o
si on is based on a soil density of 1.4 g/cm for the Montcl air/West Orange
and Glen Ridge wastes. The LLW would be diluted under the worst low-mixing
conditions to 0.023 pCi/orr or 23 pCi/1 and, under the best mixing condi-
tions, to 3.2 x 10 pCi/cm or 0.03 pCi/1. The initial mixing period
referred to as the action period would be followed by further dilution.
The initial impacts to the planktonic organisms would result from increased
turbidity. Organisms that would not be able to swim away rapidly would be
affected. After 4 days the sediment concentrations for the Montclair/West
Orange and Glen Ridge wastes would range from 0.1 mg/1 to 100 mg/1, compar-
able to what was predicted for the NFSS wastes. Ambient suspended sediment
concentrations in the 106 Site, as in other offshore ocean conditions, is
characteristically low at less than 0.1 mg/1.
These two models are useful in providing a very preliminary estimate of the
fate of the LLW in the ocean environment. The models predicted that
ambient conditions based on two disposal methods for the NFSS wastes would
be reached within a short period. The Montclair/West Orange and Glen Ridge
wastes are similar in radium concentration and volume and as such would be
expected to have a similar fate and impact. A detailed site-specific
environmental impact assessment would be a necessary requirement to deter-
mine the impact to public health and the marine environment.
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Summary of Soil, Groundwater and Surface Impacts
Excavation Alternatives. Mature vegetation would be removed and erosion of
contaminated soil would occur. This could cause short term surface water
contamination. In the long term the potential for surface and groundwater
contamination would be reduced.because of the absence of contaminated soil.
Disposal Options A and B. Potential groundwater and surface water con-
tamination would be eliminated.
Disposal Option C. Potential for surface and groundwater contamination
during interim storage exists.
Disposal Option D and F. Potential for surface and groundwater contamina-
tion would be reduced.
Dispo'sal Option E and G. Potential for surface and groundwater con-
tamination exists.
Disposal Option H. Potential groundwater and surface water contamination
would be eliminated.
Air Impacts
Radium-contaminated soil is the source of radon gas, a radioactive air
contaminant that accumulates inside confined spaces and decays to alpha
emitting radon progeny. The outdoor above-background levels of radon gas
over the most contaminated areas of the sites are estimated to be 2.81
pCi/1 in Montclair, 0.521 pCi/1 in West Orange and 2.64 pCi/1 in Glen Ridge
(see Appendix B). Compared to the outdoor radon gas background range of
0.1 to 0.4 oCi/1, radon gas levels at each site are elevated by at least
100 percent. Indoor levels of radon progeny in several residences exceed
acceptable health standards.
Alternative 1 - No Action. This alternative would continue to adversely
impact the air quality inside homes, posing an unacceptable public health
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risk to the residents of these homes.. The outdoor air quality would
remain above background levels. Indoor and outdoor air quality may fluc-
tuate and result in elevated radon gas and radon progeny levels above
acceptable health standards in homes not presently identified as being at
risk. Without the implementation of an air-monitoring program, these
potential fluctuations would go undetected.
Alternative 2 - Active/Passive Measures. This alternative would result in
the continuation of artificial ventilation to lower radon gas and radon
progeny to acceptable health standards, and extend the remediation to all
tier A, B and C homes. The outdoor air quality would remain above back-
ground levels. The implementation of maintenance and a quarterly air
monitoring program would serve to insure the effectiveness of the program.
Alternative 3 - Relocation of Receptors. The relocation of residents in
properties where either gamma radiation levels average higher than 20 uR/hr
or radon progeny concentrations average higher than 0.02 WL will insure
that no residents on the Montclair/West Orange and Glen Ridge site are at
public health risk. However, indoor, air quality may fluctuate above
acceptable health standards in homes not presently identified as being at
risk. Without the implementation of an air monitoring program, these
potential fluctuations would go undetected. The outdoor air quality would
remain above background levels.
Alternatives 4 and 5 (Excavation). Ambient air quality is expected to be
adversely impacted during soil excavation activities. Excavation and con-
struction activities would result in a slight increase in total suspended
particulate emissions. Disturbance of radiologically contaminated soil
would increase the release of contaminated particles into the air. It
would also cause an increase in the release of radon gas because of a
decrease in attenuation resulting from soil removal and increased soil
porosity.
The impacts associated with each excavation alternative will vary depending
on the volume of soil excavation required. Increased soil excavation would
result in the increased potential for air-suspended radon progeny and con
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taminated dust particles. Interim air quality radiological controls and
monitoring would be required during the interim excavation activities to
mitigate the adverse, although temporary impacts.
Disposal Options A, B and H. Either of these two disposal options, in con-
junction with excavation alternatives 4 or 5, would result in the overall
improvement of air quality through the reduction of both outdoor and indoor
radon gas levels. Radon progeny would have been substantially reduced to
background levels or to a maximum of 0.02 WL to meet health standards.
Homes that presently require radon gas remediation by air venting would no
longer require it. The offsite disposal of excavated contaminated soil
from each of the sites would remove the source of elevated radon gas.
Disposal Options C through G. For each of these disposal options the
potential exists for the accumulation and release of elevated radon gas
levels from the proposed disposal sites. The various covers proposed under
each disposal option would be designed to retard radon gas flux by atten-
tion to cover thickness and porosity. Grounds maintenance to maintain the
integrity of the covers and an environmental monitoring program to measure
the effectiveness of the engineering controls would be implemented.
Any one of these disposal options in conjunction with one of the excavation
alternatives 4 or 5 should improve overall air quality through the re-
duction of elevated radon gas levels. Homes that presently require radon
gas remediation by air ventilation systems would no longer require it.
Consequently, the only remaining source of potential radon gas release that
could affect air quality would be at the disposal sites. All unexcavated
contaminated soil that would remain under excavation alternatives 1 or 2
should not pose an air quality problem.
Summary of Air Impacts
Alternative 1 - No Action. Elevated exposure to gamma radiation and radon
progeny would continue.
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Alternative 2 - Active/Passive Measures. Exposure to elevated gamma
radiation and radon progeny would be eliminated.
Alternative 3 - Relocation of Receptors. Exposure to elevated gamma
radiation and radon progeny would be eliminated.
Excavation Alternatives. Potential exposure to radon progeny and con-
taminated airborne particulates would increase.
Disposal Options A and B. Exposure to elevated gamma radiation and radon
progeny would be eliminated.
Disposal Options C through G. Potential of exposure to elevated gamma
radiation and radon progeny exposure would be reduced.
Disposal Option H. Exposure to elevated gamma radiation and radon progeny
would be eliminated.
Noise and Transportation Impacts
Alternative 1 - No Action. The ventilation systems that are currently a
source of noise and disturbance would be eliminated.
Alternative 2 - Active/Passive Measures. The existing ventilation systems
are noisy and cause a disturbance to the residents. More residents would
be subjected to noise and disturbance due to installation of ventilation
systems in all tier A, B and C homes. Short-term disturbances would be
incurred in homes requiring retrofitting for gamma shielding.
Alternative 3 - Relocation of Receptors. No significant impact would
exist.
Alternatives 4 and 5 (Excavation). The excavation and construction
activities resulting from these alternatives would increase noise levels
and transportation within the communities. The degree of impact will vary
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based on the volume of soil excavated. The impacts can be mitigated by
scheduling certain transportation and construction activities before and
after current peak transportation patterns. However, noise levels result-
ing from construction equipment would be within limits set by Federal,
State and local regulations.
Disposal Options A through H. Disposal options F and G will involve com-
paratively less transport distance than the other alternatives since con-
taminated soil disposal would be restricted to each site.
4.2.2 BIOLOGICAL ENVIRONMENT
The Montclair, Glen Ridge and West Orange sites are highly urbanized areas.
The biological community is representative of most local urbanized areas in
having well-established ornamental shrubs and hardwood trees, small mammals
and birds. There are no threatened or endangered species on the sites.
Barrows Field, a 4..7-acre lawn-covered field, is the only park or open
space area within the boundaries of the three sites. There is currently no
documented evidence regarding the long term effects of continued exposure
of the biological community on the sites caused by elevated gamma radiation
and radon progeny exposure.
Alternatives 1, 2 and 3. These alternatives would result in the continued
exposure of the biological community to elevated gamma radiation and radon
progeny. The impacts are considered negligible, but as yet are still
undefined.
Alternatives 4 and 5 (Excavation). Each of the excavation alternatives
would have short-term impacts resulting from the excavation activities.
The alternatives would all disrupt and result in the temporary loss and
displacement of the biological community at each of the sites because of
the mortality and disturbance caused by construction activities, stripping
of established vegetation and disturbance of groundcover, which provides
habitats, shelter and food. The major difference between the alternatives
is that an increase in excavation volume will result in an increase in the
area and the length of time that these sites are disrupted.
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Although excavation will have disrupted the biological community as des-
cribed in the discussion of the excavation alternatives, the disruption is
expected to be temporary and, following a period of site restoration and
revegetation, natural recruitment can be expected to occur from proximate
comparable biological communities and the sites restored to their pre-
existing condition.
Disposal Options A, B, and H. Any one of these disposal options in
conjunction with any of the excavation alternatives should benefit the
biological community by removing any adverse source of surface radiation
and radon gas exposure.
Disposal Options C through G. Any of these disposal options, in con-
junction with excavation alternatives 4 or 5, would result in the source of
surface gamma radiation and elevated radon gas levels to remain at the Glen
Ridge disposal site, or in the case of disposal options F or G at three
sites. Engineering controls and environmental monitoring would be required
to maintain and verify the integrity of any of the proposed covers. Any
degree of landscaping that can be incorporated into the design of the
proposed disposal sites would beneficially impact the biological community
because it would provide additional food or habitat. However, recruitment
of any burrowing animals would potentially undermine the integrity of the
disposal site covers.
4.2.3 SOCIOECONOMIC ENVIRONMENT
The proposed remediation alternatives would have minimal to significant
socioeconomic impacts to residents and the communities. The excavation
alternatives propose to lower surface gamma radiation and radon gas progeny
levels to meet public health standards. The long-term socioeconomic
impacts of the excavation alternatives must be considered in conjunction
with each of the eight disposal options. For purposes of this discussion,
the disposal options were generally grouped into offsite disposal, interim
or permanent disposal in Glen Ridge, or permanent disposal at each site.
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This section discusses the socioeconomic impacts of remediation relative to
property values, temporary or permanent relocation of residents, property
taxes and demand on community services, and local commercial services.
Some of the impacts are discussed in qualitative terms because they are
dependent on the public perception of health hazards and esthetics of the
selected remediation alternatives.
Residential Property Values
Residents within the study sites have been concerned about present and
future impacts on property values resulting from the occurence of radio-
logically contaminated soils. Some residents want the towns to acknowledge
that the contamination has had an adverse impact on property values. In
effect, Montclair and West Orange have made that acknowledgement by grant-
ing a tax relief based on each town's respective policy on the issue. Glen
Ridge has not done this (see*Table 1-2 of Chapter 1). Many residents have
not wanted to encourage the perception that property values have declined.
This is especially understandable because the benefits of a tax relief with
respect to potential loss in property values are minimal, and the owners of
properties without contamination do not want to be associated with the con-
tamination 'simply because they are adjacent to it. Communication with
local tax assessors'indicate that the real estate market in these communi-
ties is relatively slower than those of the surrounding communities. This
reflects the adverse impacts that the contamination has already had on
property values. Presently, some homeowners are relying upon NJDEP-issued
certificates (prior to the remedial investigations) stating that completed
surveys did not show radon contamination. The public has misinterpreted
the meaning of the certificates and are using them to demonstrate a "con-
tamination free" home to prospective buyers. However, the lack of radon
contamination does not preclude a property from having radium contamination
in the soil.
Alternative 1 - No Action. If the contamination from the properties in the
three communities is not remediated, then homes can be expected to diminish
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further in value. The long-term impacts after diminished publicity are
unknown.
Alternative 2 - Passive/Active Measures. Similar to Alternative 1, homes
may also be expected to diminish further in value. Homes that currently
require air-venting and those that would additionally require it in addi-
tion to gamma shielding, can be expected to be most adversely impacted
because of the more tangible knowledge of the effects of contamination.
The long-term impacts after diminished publicity are similarly unknown.
Alternative 3 - Relocation of Receptors. The remediation of the sites by
relocation of residents who are deemed to be at public health risk may have
short or long-term impacts on the community. The impacts will be in part
determined by what the public perceives to be the success of remediation
with regard to meeting public health goals and the degree to which the
aesthetic quality of the neighborhood is compromised. The final disposi-
tion of the properties that are to be purchased (e.g., demolish or* board
close) will be a variable affecting whether property values in these
neighborhoods will remain competitive. The long-term impacts after dimi-
nished publicity are also unknown.
Alternatives 4 and 5 (Excavation). The remediation by excavation of conta-
minated soils would have short- and long-term impacts on property values.
These impacts would be in part affected by the following variables: what
the public perceives to be the success of remediation with regard to meet-
ing public health goals; whether remediation is being accomplished in a
timely manner; and the degree to which the esthetic quality of the neigh-
borhood is comprised (Silbergeld, 1985). The potential short-term impacts
with respect to property values are a function of whether buyers perceive
remediation to be accomplished in a timely enough manner to overlook the
inconvenience caused by the construction activities. The long-term impacts
are a function of the public's acceptance of the excavation alternative
selected. Only if excavation alternative 5 is selected would property
values be certain to remain competitive with other comparable properties
not previously associated with the contamination.
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Disposal Options A through H. Of the various combinations of excavation
and disposal options, only the offsite disposal options (A, B or H) in
conjunction with excavation alternatives 5 or 6 would be certain to have a
beneficial impact on property values since all, or virtually all, sources
of contamination would be excavated and removed, all would be disposed off
site. All other combinations involve partial excavation of contaminated
soils and interim or permanent onsite disposal either in one or in each
community. The potential long-term impacts of any of these remediation
alternatives is based on public perception of the success of remediation as
previously discussed.
An additional factor to consider in the inclusion of disposal options C
through G lies in the public's additional need to favorably accept the
siting of an interim or permanent radiological waste storage facility in a
resident!'ally zoned area. The only close comparisons are where hazardous
waste treatment or storage facilities have been sited in a community. In
some cases, the impacts have been favorable when they are developed in con-
junction with other revenue-generating projects. However, the impacts of
siting a facility with no economic benefit in a strictly residential area
is unknown (Gimello, 1985).
The siting of an interim storage or permanent disposal facility in Glen
Ridge may be favorable or at most have no negative impact if the storage
site design maximizes functional and esthetic qualities in addition to
meeting public health standards. The proposed location in Glen Ridge is
Barrows Field. The loss of the present ball park and the siting of a waste
storage site may be mitigated by the design of a dual-function waste stor-
age and new recreational facility. Design aspects that consider public
acceptance of the land uses are in keeping with similar current trends
where landfill closure designs include plans for their conversion into
public parks or industrial parks. However, these options are mostly
untested.
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Relocation Problems
The Federal Emergency and Management Administration (FEMA) is authorized
under Superfund to manage the relocation of residents due to remedial
actions. Relocation assistance, including various degrees of food, hous-
ing and transportation compensation, would be necessary. However, the
policies have yet to be developed. The abrupt demand on local housing may
not be sufficient to allow the relocation of residents within walking
distance from their present homes; consequently, relocation to different
towns may be required. The relocation of residents would disrupt living,
working, and recreational patterns, in part because of increased travel
time between family, friends, school or work. The permanent loss of homes
may additionally result in loss of long-term planning, or emotional ties
between home and the community. Elderly residents may be especially
confused and stressed as a result of these losses.
Alternative 2 - Active/Passive Measures. The occurrence of radiologically
contaminated soils in Montclair, Glen Ridge and West Orange has not neces-
sitated the temporary or permanent relocation of residents. In homes where
radon gas levels are elevated, temporary remediation by venting has been
successfully implemented without requiring the relocation of residents.
Retrofitting a home for radiation shielding may similarly not require
temporary relocation.
Alternatives 3 through 5. Alternative 3, relocation of residents, and
excavation alternatives 4 and 5 would have a temporary and possibly a
long-term adverse impact on local residents. Excavation would temporarily
disrupt neighborhoods since construction activities would require use of
local space to accommodate construction vehicles, equipment and personnel,
increased usage of local roads, increased noise, and a general change in
the atmosphere of what is now perceived to be a quiet residential area.
Residents whose properties would require excavation would have to temp-
orarily relocate, or permanently relocate if excavation can only be accom-
plished by demolishing the house. Alternative 3 would require the per-
manent relocation of residents.
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The excavation phase of remediation would require a community support and
relocation assistance center to assist all residents. The socioeconomic
impacts of the excavation alternatives will differ in the length of the
impact and the number of properties affected because of the increasing
volumes of soil excavation required under each remediation alternative.
Disposal Options A through H. Of the various combinations of excavation
and disposal, only the offsite disposal options would not have long-term
effects on relocation at the Montclair/West Orange and Glen Ridge sites.
The relocation site would also be impacted as already discussed in the
excavation section 3.2. All other disposal options would require addi-
tional permanent relocation of residents. Disposal Option C would require
the purchase of 22 homes in Glen Ridge; disposal options D and E will re-
quire the purchase 62 homes in Glen Ridge; and disposal options F and G
would require the purchase of 22 homes in Glen Ridge, 8 homes in West
Orange and 38 homes in Montclair. The impacts and mitigation measures are
similar to those discussed for the alternatives 3 through 5.
Taxes and Community Services
Montclair and West Orange have provided limited community support to resi-
dents who are currently affected by the contamination. Montclair and West
Orange granted some homes a tax relief that resulted in an average savings
of $1,070 to Montclair residents and $774 to West Orange residents. Glen
Ridge has not granted tax relief because the Tax Assessor's Office does not
believe that property values have depreciated due to the contamination.
The tax relief has an adverse impact on the communities because of the
direct loss in property tax revenues (Table 1-2).
In addition to loss in tax revenues, the communities have had to allocate
more staff time to address resident's questions regarding such issues as
the following: (1) health impacts, (2) if and when remediation is expected
to occur, (3) potential fluctuation in property values and (4) prudence of
planning home improvement projects. The remediation investigations have
additionally required the support of public works and public health person-
nel .
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Alternatives 1 through 3. These alternatives would continue to place a
burden on the communities because residents will be unsatisfied with the
lack of or selected remediation and will continue to request the towns to
take some action. Alternative 3 will further impact the community because
of the required purchase of homes where residents are presently at public
health risk. There are 43 homes that will need to be purchased to imple-
ment this remediation measure.
Excavation Alternatives 4 and 5. The remediation of some properties by
excavation would require that the houses be demolished. The loss of these
properties would result in a certain loss of tax revenues to the respective
towns. Presently, a policy has not been established regarding whether
residents whose homes would be demolished would be compensated by being re-
quired to, or offered a choice of, rebuilding a comparable home in the same
lot after its remediation. The lost tax revenues for the community might
be recouped if new houses are built. The excavation phase would also place
an added demand on public works, public health and other peripheral
community services.
In the long-term there is also the potential for property values to decline
because the remediation is not acceptable to the public. This could cause
further property tax revenue losses due to property depreciation.
Disposal Options A through H. Any of the excavation alternatives combined
with disposal options A, B or H would have no further impacts on taxes and
community services, other than those discussed above in the excavation
section. However, disposal options C through G would all have additional
long-term impacts because they would require the purchase of some proper-
ties to accommodate an interim or permanent disposal site in Glen Ridge, or
a permanent disposal facility in each community. The potential loss in tax
revenues to each town is given in Table 4-3.
Commercial Impacts
Alternatives 1 and 3. No impact is involved.
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TABLE 4-3
TAX REVENUE LOSSES DUE TO
DISPOSAL OPTIONS 3 - 7 (1) (2)
Glen Ridge
West Orange
Montclair
Disposal Option 3
Number of Properties
Required
22
Assessed Values
$1,524,600
Tax Revenue Loss
$ 61,136
Disposal Options 4/5
Number of Properties
Required
62
(3)
Assessed Values
$4,393,300
Tax Revenue Loss
$ 176,171
Disposal Options 6/7
Number of Properties
Required
22
38
Assessed Values
$1,524,600
$554,600
$1,284,800
Tax Revenue Loss
$ 61,136
$ 17,691
$ 113,190
( ' Based on 1984 Essex County Tax Ratables.
(2)
Not adjusted to reflect properties which received a tax relief.
Excludes assessed value of Glen Ridge municipal yard entry.
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Alternative 2, 4 and 5. The anticipated impacts to the commercial communi-
ties would be minimal. There are a sufficient number of transportation
corridors within the three communities that routes in and out of the sites
would not interfere with local businesses. The project would require a
small team of skilled construction and specialized technical personnel who
could be contracted within the New Jersey area. Consequently, the project
would be within commuting distance for most of the work force, and would
not place a demand on local living accommodations. The presence of the
construction work force overall will have no, or at best, a minimal
beneficial impact on local businesses.
Disposal Options A through H. The only impacts of the disposal options
would be for those constructed on site. The impacts caused by the actual
construction would be similar to those discussed under the excavation
alternatives above. The long-term impacts are minimal, because of the
limited and infrequent operations and maintenance requirements of the dis-
posal facilities.
Summary of Socioeconomic Impacts
Alternatives 1 and 2
o Property values would be reduced.
Alternative 3 - Relocation of Receptors
o The residents of the community would have to be permanently
relocated.
o A potential reduction of property values would result.
Excavation Alternatives 4 and 5
o Demand on community services would increase.
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o Visibility of the contamination problem would increase.
o The residents of the community would have to be temporarily
relocated.
Disposal Option A
o Property values would be restored.
o Offsite communities along transportation routes and near
transloading facilities would be impacted.
Disposal Option B
o Property values would be restored.
o Offsite communities along transportation routes and near
contaminated soil storage or disposal areas would be impacted.
Disposal Option C
o Properties in Glen Ridge could potentially be devalued.
o Offsite communities along transportation routes associated with
the final disposal would be impacted.
o A tax loss due to siting the interim storage facility in Glen
Ridge would occur.
Disposal Option D
o Properties in Glen Ridge could potentially be devalued.
o A permanent loss of taxes in Glen Ridge would occur.
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Disposal Option E
o The consequences would be the same as those for disposal Option 4.
Disposal Options F and G
o The consequences would be the same as those for disposal Option 4,
except that all communities would be affected.
Disposal Option H
o Property values would be restored.
o Offsite communities along transportation routes and near
trans!oading facilities would be impacted.
o Potential for adverse impact to the marine environment exists.
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This section has been prepared jointly by
EPA and its REM II Contractors with
guidance and input from EPA's Radiation
Program
4.3 PUBLIC HEALTH EVALUATION
The public health evaluation is a site-specific assessment of the health
risks posed by the no-action alternative with a qualitative comparison to
each of the remedial alternatives being considered at the Montclair/West
Orange and Glen Ridge Radium Sites. It is based on the combination of two
other assessments: the general hazard assessment and the site-specific
exposure assessment. The hazard assessment is an evaluation of the
radiological toxicity of the contaminants. It also includes information on
any regulatory standards or criteria applicable to the contaminants that
are present and the accepted risk models that will be used. The exposure
assessment includes an evaluation of the potential routes of exposure to
the contaminants at the sites arid ultimately estimates the doses received
by individuals or populations in the area. The last section of this public
health evaluation, the risk assessment, combines the hazard and exposure
assessments and thereby quantifies the risks posed by the contamination
present at the sites.
4.3.1 HAZARD ASSESSMENT
Elevated levels of radium-226, thorium-230 and uranium-234 and -238 are
present in soil at the Montclair, West Orange and Glen Ridge sites, causing
high levels of radon-222 and its decay products, called radon daughters or
radon progeny to be present in homes at the sites. Radium, uranium, and
thorium to be present in soil pose a health hazard due to (1) direct gamma
radiation, (2) inhalation of radon progeny or contaminated particulates,
and (3) ingestion of contaminated soil and vegetation. Radon-222 will
radiodecay to radon progeny which can become attached to dust particles in
the air. High concentrations of radon progeny can build up in indoor air,
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and subsequent inhalation poses a significant risk of lung cancer. Radio-
active materials present on soil particles can be inhaled or ingested as
particulates. Once in the body, these isotopes emit alpha and gamma radia-
tion initially in the lungs and, if absorbed, in the blood stream, in other
tissues. Absorbed thorium and radium are deposited preferentially in bone.
Radium progeny will be deposited in various tissues.
4.3.1.1 Gamma Irradiation
Hazards of Gamma Irradiation
Gamma radiation is a form of electromagnetic radiation similar to x-rays.
It is a very highly penetrating radiation, due to its low linear energy
transfer. As with all ionizing radiation, gamma rays cause injury by
breaking biological molecules into electrically charged fragments called
ions and, thereby, producing chemical rearrangements that may lead to
cellular damage. Due to the low linear energy transfer, gamma rays
disperse their'energy over a relatively long distance. The adverse
biological reactions associated with gamma rays, as well as other ionizing
indicators, are carcinogenicity (cancer), mutagencity (genetic changes),
and teratogenicity (birth defects). Further information on the effects of
exposure to low-level gamma radiation can be found in the reports of the
Committee on Biological Effects of Ionizing Radiation (BEIR II) (1980) and
EPA (1984a).
Risk Estimates
Because the effects of radiation of human health are known more quantita-
tively than the effect of most other environmental pollutants, it is
possible to make numerical estimates of risk that may occur as a result of
a particular source of radioactive emissions. Such numbers may give an
unwarranted aura of certainty to estimated radiation risks. The observa-
tional data on the effects of human exposure are subject to a number of
interpretations. This in turn leads to differing estimates of radiation
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risks by both individual radiation scientists and expert groups. Estimat-
ing radiation risks is not a mature science and methods of risk assessments
will change as additional information becomes available. EPA believes that
risk estimates for purpose of assessing radiation impacts on public health
should be based on scientifically creditable risk models that are unlikely
to understate the risk.
Dose Response Functions
A number of assumptions must be made about how observations at high doses
should be applied to low doses and low dose rates for a given type of
radiation. These assumptions include the shape of the dose response
function and possible dose rate effects. For exposure to low LET (gamma)
radiation, EPA uses the BEIR-3 linear dose response model. The linear
guadratic dose model can also be used, although it is not supported by
relevant human data. The linear quadratic estimate would be about 45% of
the simple linear estimate (EPA 1984a)
Risk Projection Model
None of the exposed groups has been observed long enough to assess the full
effects of their exposures, if, as is currently thought, most radiogenic
cancers occur throughout an exposed person's lifetime. Therefore, another
major choice that must be made in assessing the lifetime cancer risk re-
sulting from radiation is to select a risk projection model to estimate the
risk for a longer period of time than currently available observation data
will allow.
To estimate the risk of radiation exposure that is beyond the years of
observation, either a relative risk or an absolute risk projection (or
suitable variations) must be used. The National Academy of Sciences BEIR
Committee and other scientific groups have not concluded which projection
is most appropriate choice for most radiogenic cancers. However, evidence
is accumulating that favors the relative risk projection model for most
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solid cancers due to the lifetime expression period exhibited by these
cancers. Leukemia and bone cancers are exceptions to the general validity
of lifetime expression for radiation-induced cancers and appear to have a
defined limited expression period (possibly 25 years). For these diseases,
the BEIR-3 Committee believed that an absolute risk projection model is
more appropriate for estimating lifetime risk.
Although EPA feels it is likely that the relative risk model is the best
projection model for most solid cancers, it has been tested rigorously only
for lung and breast cancer. Until it has more empirical support, they
prefer to use an average risk based on both projection models.
To estimate the cancer rist from low-LET, whole-body, lifetime exposure
with the linear model, EPA and this document use the arithmetic average of
relative and absolute risk projections for solid cancers and an absolute
risk projection for leukemia and bone cancer. For dose to the whole body,
this yields an estimated 280 fatalities per million person rems (EPA
1984a).
4.3.1.2 Inhalation of Radon and Radon Progeny
Hazards of Radon Progeny
Radon, a naturally-occurring radioactive gas, is generally recognized as a
key pollutant in the indoor environment. Radon is produced from the radio-
active decay of radium-226, which occurs naturally in almost all soils and
rocks. The radioactive decay of radon (radon progeny production) produces
several alpha particle emitting radionuclides. Inhalation of these radio-
nuclides exposes lung epithelial cells to (high linear energy transfer)
alpha radiations, which are easily absorbed. High linear energy transfer
radiations have a larger biological effect per unit dose than do low linear
energy transfer radiations because they deposit more energy, and therefore
cause more damage, per unit distance traveled. The relative biological
effectiveness of alpha radiation is often many times greater than that of
gamma radiations.
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While the concentration of radon in the outdoor environment does not
usually pose a significant health hazard, indoor concentrations can be
several thousand times higher than outdoors. The rate at which radon
enters a structure and the air exchange rate influence the radon concentra-
tion inside the structure. Radon concentrates in indoor environments
because of the limited exchange rate between indoor and outdoor air. In
many buildings, the most significant pathway of radon entry is migration
from soil into the structure through the basement or foundation. The rate
/
of radon entry is affected by many factors, including radium content of the
soil near a structure, soil moisture and porosity, and structure type. The
variability of all these factors, especially radium content, contributes to
the wide distribution of radon concentrations that have been observed.
The hazards posed by increased levels of radon arise primarily from two of
its short-lived radioactive decay products, polonium-218 and polonium-214.
These decay products (progeny) adhere to dust particles or other surfaces.
If inhaled, the radioactive products deposit in the lungs, where they
undergo further radioactive decay thus exposing the surrounding tissue to
alpha radiation. Such radiation exposure can lead to lung cancer.
Risk Estimates
Although considerable progress has been made in modeling the deposition of
particulate material in the lung, it is not yet possible to adequately
characterize the bronchial dose delivered by a given exposure to radon
progeny. Current estimates of the dose actually causing the radiogenic
cancer resulting from inhaled radon-222 progeny are based on average doses
that may or may not be relevant. Until more reliable estimates of the
bronchial dose become available, EPA estimates the risk of lung cancer
resulting from radon progeny on the basis of exposure rather than dose.
Therefore, estimates of the risk associated with exposure to radon decay
products are based on several epidemiological studies of underground
miners, whose exposure to high levels of radon is known. A very high
incidence of lung cancer products has been well-documented in studies
conducted in a number of countries.
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Exposures to radon under working conditions are commonly reported in a
special unit called the working level (WL). One working level is any
concentration in air of short half-life radon-222 progeny having 1.3 x 10
MeV per liter of potential alpha energy. This unit was developed because
the concentration of specific radon progeny depends on ventilation rates
and other factors. A working level month (WLM) is the unit used to charac-
terize a miner's exposure to one working level month of radon progeny for a
working month of 173 hours (30 CFR Part 57).
Because the results of epidemiological studies are expressed in units of WL
and WLM, EPA developed a method to interpret the results for members of the
general population exposed to radon progeny based upon the amount of poten-
tial alpha energy inhaled. (See p.8-26 in ref. EPA 1984a). While a member
of the general public is exposed to a certain level of radon progeny for a
longer period of time, the amount of air inhaled per minute is less than a
working miner when such activities as sleeping and resting are taken into
account. Although it may be technically inappropriate to quantify the
amount of potential alpha particle energy inhaled by a member of the
general population in working level months, full time annual exposure to an
adult member of the general population is estimated to result in 27 WLM per
year, (as compared to the 51 WLM resulting from a straight forward applica-
tion of the exposure term). In the case, of a miner exposed only during
working hours, one WL exposure results in an annual exposure of 12 WLM.
This document will use the 27 MLM assumption for its exposure calculations.
Currently, the Mine Safety and Health Administration (MSHA) of the Depart-
ment of Labor limits the maximum permissible concentration of radon progeny
in mines to 1.0 working level (WL) and limits occupational exposure to 4.0
working level months (WLM) over a calendar year (30 CFR Part 57). These
standards are based on corresponding Federal Regulation Protection Guides
established by EPA in 1970, and are currently under review.
Risk Projections
Current estimates suggest that the risk of lung cancer is doubled by a
cumulative exposure of 20-100 working level months. (The average national
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lung cancer risk is about 3 in 100). Statistically significant, increased
risk of lung cancer in miners is observed for exposures as low as 80 WLM.
In homes, however, measured exposure rates range from 0.08 to greater than
200 WLM per year. Lifetime exposures at these rates lead to cumulative
exposures ranging from about 1 WLM to over 10,000 WLM. Thus, at the higher
levels, a person's lifetime risk of lung cancer could be increased to well
over one chance in two.
Since 1978, EPA has based risk estimates of cancer resulting from inhaled
radon-222 progeny on a linear dose response function, a relative risk
projection model, and a minimum induction period of 10 years. These
assumptions are utilized in the calculations for this report. Lifetime
risks are projected on the assumption that exposure to 1 WLM increases the
age-specific risk of lung cancer by from 1.2 to 2.8 percent over the age-
specific rate in the U.S. population as a whole. This translates to a risk
estimate of 300 to 700 deaths per million person-WLM lifetime (70 year)
exposure. (EPA 1984a)
4.3.1.3 Relevant Standards and Criteria
The criteria developed for use at these sites are based on standards
applicable to the clean-up of properties contaminated with radium-bearing
uranium mill tailings. The standards were developed under authority
assigned to EPA by the Uranium Mill Tailings Radiation Control Act (40CFR
192.12, 1983). The criteria for this site stipulate that the concentra-
tions of radium-226 averaged over a 100 square meter area shall not exceed
5 pCi/g above background levels in the first 15 cm of soil beneath the
surface and the average levels in 15 cm intervals below that shall not. be
more than 15 pCi/g above background levels. Also, in any occupied or
habitable building, the level of gamma radiation shall not exceed
background level by more than 20 microR/hr.
The guidance developed by EPA for the Indoor Radiation Exposure Due to
Radium-226 in Florida Phosphate Lands (FR, Vol. 44, July 2, 1979) stipulate
that remedial action should be taken in all residences in which the initial
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annual indoor air concentrations of radon decay products exceeds 0.02
Working Level (WL), including normal indoor background.
In addition, EPA has determined that in any occupied or habitable building,
the concentration of radon decay products (including background levels)
should not exceed an annual average radon decay product concentration of
0.02 Working Levels (WL) and should in no case exceed 0.03 WL. The
standard permits achieving 0.03 WL by removal of source material and the
balance 0.01 WL through active means when this is the only practical route
(40 CFR 192.12).
4.3.2 EXPOSURE ASSESSMENT
The potential routes of exposure for each remedial alternative and the
estimated level of exposure for the on-site residents are described below.
4.3.2.1 Exposures with the No Action Alternative
Under a no-action alternative, residents of the Montclair, West Orange, and
Glen Ridge sites would be subjected to health risks due to exposure via the
following routes:
o Inhalation of radon and radon progeny
o Direct exposure to gamma radiation from elevated indoor and
outdoor contamination levels
o Ingestion of radionuclides from eating vegetables grown in con-
taminated soil and direct ingestion of contaminated dirt.
Inhalation of radon-222 and radon progeny is almost certainly the most
important, since it greatly increases the risk of fatal lung cancer. Gamma
emissions from the contaminated soil will expose all body tissues to ioniz-
ing radiation. Finally, uranium-234 and -238, thorium-230 and 232, and
radium-226 ingested in garden vegetables or on soil consumed inadvertently,
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If absorbed, will deposit preferentially in bone and their progeny will
deposit in other tissues increasing the radiation exposure in those
tissues. In addition, if not already present in the soil, concentrations
of long half-life progeny of radon, specifically lead-210 and polonium-210,
will increase as the radium-226 decays through radon and short half-life
progeny. Both lead-210 and polonium-210 can be ingested from vegetables or
soi 1.
Inhalation of airborne radioactive soil particles will only be a problem
when the ground is disturbed and is not considered a significant route of
exposure for the no-action alternative. Based on the results of the
groundwater remedial investigation, the possibility of ingestion of
contaminated groundwater is not considered.
Inhalation of Radon and Radon Progeny
Indoor radon progeny exposure for the three sites has been measured over
the last year and a half. Houses in Montclair, West Orange and Glen Ridge
study areas have been grouped into four categories based on indoor levels
of radon progeny. Tier A houses had more than 0.5 WL of radon progeny;
Tier B houses had concentrations between 0.1 and 0.5 WL; Tier C houses had
between 0.02 and 0.1 WL; Tier D houses had less than 0.02 WL. Since the
maximum background radon progeny level was estimated to be 0.007 WL, for
the purposes of this report the Tier D homes were considered to have radon
progeny values between 0.007 WL and 0.02 WL. All houses below the 0.007 WL
cut-off were considered to be at background. The population for each com-
munity at each of these levels was estimated using population multipliers
for each town obtained from the 1980 census figures and is shown in Table
4-5.
These estimates are for current housing patterns. If we assume no increase
in population densities over the next thousand years (and beyond), this
level of impact can be expected to continue over that period. For greater
(or lower) densities the impact would be proportional to the change in
population. In addition, any energy conservation measures in the future
would intensify the problem in direct proportion to the reduction in air
exchange rates.
4-49
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TABLE 4-5
ESTIMATED NUMBERS OF PEOPLE EXPOSED
TO VARIOUS LEVELS OF RADON FOR THE NO ACTION ALTERNATIVE
Location
Radon Progeny
Concentration
Tier (WL)
Number of
Houses
Estimated
Number of
People
Monte lair
West Orange
Glen Ridge
Total for
3 sites
A
B
C
D
Background
B
C
D
Background
B
C
D+
D
2
11
13
43
121
total
not measured
190
98
2
2
9
41
total
not measured
8
8
7
35
162
total
not measured
A >0.
B 0.1
C 0.02
D 0.007
Background
0.5
0.1
0.02
0.002
total
212
41
2
21
22
87
324
not measured 147
8
41
48
159
448
704
6
6
26
119
157
20
18
88
405
531
8
67
72
273
972
1392
EPA Maximum annual indoor radon progeny limit = 0.02 WL.
1 Population estimates based on 1980 census multiplies for each town
Montclair = 3.7 persons/residence
West Orange = 2.9 persons/residence
Glen Ridge = 2.5 persons/residence
(dec 54/2)
-------
Outdoor radon progeny levels for the no-action alternative were estimated
using the RAECOM model (NRC, 1984) as described in Appendix B. The model
estimated the radon flux source term from existing data based upon radium
concentrations, depth of contamination and soil characterization such as
moisture and porosity. The outdoor radon progeny exposure was estimated
using the source terms calculated with the RAECOM model and other assump-
tions concerning site-specific meteorological conditions. The above back-
ground outdoor radon concentrations and working levels of radon progeny for
each site are as follows:
Radon Release Radon Concentration Working Levels
Source Term Above Background Above Background
(pCi/s) (pCi/1)
Montclair 6.43 x 10 6 2.81 0.0042
West Orange .4.87 x 10 5 0.521 0.0008
Glen Ridge
6.25 x 10 6 2.64 0.0040
Actual grab samples of outdoor radon progeny collected by NJDEP and EPA
from locations along streets within the study areas showed a maximum
concentration of 0.002 WL in the outdoor ambient air. This is in
relatively close agreement with the concentrations estimated with our
model.
Direct Exposure (Gamma Radiation)
Gamma radiation levels were measured both indoors and outdoors during the
remedial investigation. CDC (1984) derived a formula for estimating the
maximum annual dose of gamma radiation to an individual in the study area
using the conservation assumption that 75% of a person's time would be
spent in his or her home and 25%, in his or her yard. During the initial
field investigation indoor gamma surveys of the entire house were performed
by EPA-EERF in identified Tier A, B and C homes. Using this data, CDC and
4-51
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NJDEP estimated annual exposure using the highest reading measured in the
basement (5 hours), the first floor living area (5 hours) and the bedroom
(8 hours). Utilizing this model, no house measured exceeded the 500
mRem/year recommended maximum limit for individual exposure. During the
RI, additional residences were surveyed, however gamma surveys were
conducted in the basement only. In order to combine the data sets, all
data was reevaluated using the assumption of 75% occupancy at the average
exposure rate in the basement and 25% occupancy at the average outdoor
exposure to obtain an estimated annual dose. Table 4-6 provides the number
of houses and people in each of the study areas broken down into general
classifications of exposure.
Since the resulting exposure rate was generally less than what would have
been calculated with the CDC/NJDEP methodology, the annual exposure rates
shown on Table 4-6 should only be used as indicators for where more
thorough multilevel indoor surveys should be performed in order to get more
realistic estimates of annual dose.
Ingestion of Radionuclides
In addition to the risks associated with inhalation of radon and radon
progeny and the exposure to gamma irradiation, a significant risk to
inhabitants of the study area may be presented by ingestion of radio-
nuclides. Exposure can occur either by ingestion of vegetables grown in
contaminated soil or by ingestion of soil. The latter is the most
important means for children, but it may also contribute to the total dose
absorbed by adults. Ingestion of contaminated soil by pregnant women may
also adversely affect the fetus.
For this analysis measurements were made of uranium-234, thorium-230 and
radium-226 concentrations in soil. Concentrations of lead-210 and
polonium-210 were not measured. If they were not present originally, they
would grow in with time, attaining equilibrium and a concentration equal to
that of radium-226 about 200 years after the soil was contaminated.
However, essentially equal concentrations of lead-210 and polonium-210, 89%
of equilibrium, are reached after about 70 years.
4-52
-------
TABLE 4-6
ESTIMATED NUMBER OF PEOPLE EXPOSED
TO VARIOUS LEVELS GAMMA RADIATION
FOR THE NO ACTION ALTERNATIVE1
Location
Montclair
Estimated ,
Annual Dose
(mrem/year)
1000+
800-900
600-700
500-600
400-500
300-400
200-300
,,100-200
Above Bkgcr to 100
Number of
Homes
0
0
1
0
0
5
4
56
31
Estimated
Number of
People
0
0
4
0
0
19
15
207
115
West Orange
Glen Ridge
1000+
800-900
600-700
500-600
300-400
200-300
.100-200
Above Bkgd to 100
1000
800-900
600-700
500-600
400-500
300-400
200-300
2100-200
Above Bkgd to 100
Total
Total
Total
97
1
0
0
1
0
1
2
B
13
0
0
0
0
0
2
0
26
11
42
115
3
0
0
3
0
3
6
23
38
0
0
0
0
0
5
0
65
I5
105
Total for 3 sites
1000
600-700
500-600
3
4
3
-------
TABLE 4-6 (con't)
300-400 7 24
200-300 5 18
-100-200 84 278
Above Bkgcr to 100 53 173
Total 503
1. Recommended maximum individual dose limit = 500 mrem/year
2. Estimated background dose on site = 80 mrem/year
3. This estimate is not based on the CDC model which utilized indoor gamma
data from the basement, living area, bedroom and outside property to
calculate annual dose. This estimate utilized the assumption of 75
percent occupancy at the average reading in the basement and 25 percent
occupancy at the average outdoor exposure.
(6H5/13)
-------
To assess the possible contribution of ingested radioisotopes it is assumed
that the average annual consumption of vegetables is 112 kg and that 50% of
this amount was from a home garden (EPA 1984). Consumption of vegetables
by children less than 1 year is about 56 kg per year and by adults over age
60 is about 121 kg per year (EPA 1984).
However, the lower consumption of vegetables in children is partially
offset by direct ingestion of dirt. Kimbrough et al (1984) have estimated
that amount of soil ingested by different age groups to be as follows:
Age Group Soil Ingested
0-9 months 0 g/day
9-18 months 1 g/day
1.5 - 3.5 years 10 g/day
3.5-5 years 1 g/day
5 years 0.1 g/day
Based on these numbers, children may be at significant risk from the
ingestion of contaminated soil.
4.3.2.2 Exposure for Alternative 2; Active and Passive Measures
With alternative 2, the use of active and passive measures, to reduce the
elevated radon and gamma levels in the homes, the residents of the
Montclair, West Orange, and Glen Ridge sites would be subjected to health
risks from exposure by the same routes as for the No-Action alternative.
However, because of decreased indoor radon progeny and gamma radiation
levels, exposure due to inhalation of radon and radon progeny and gamma
irradiation would be significantly reduced for the involved residents.
To estimate the indoor radon exposure to the residents at the three sites,
it is assumed that in all Tier A, B and C level homes the radon progeny
levels will be reduced to 0.02 WL or lower. However, any reduction in the
efficiency of the ventilation systems, such as has been already observed at
4-54
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the sites, will result in exposures above this level. The levels of radon
progeny in Tier D and background residences will remain the same. Elevated
indoor gamma radiation levels would be reduced to 20 uR/hr or less above
background, however, since outdoor gamma exposures would remain the same,
some residents may still receive exposure over the 170 mrem/year above
background limit (250 mrem/year).
Exposure to outdoor radon progeny and gamma radiation and exposures due to
ingestion, gardening, excavating or other soil invasive activities will
remain the same as for the No-Action alternative as described in section
4.3.2.1.
4.3.2.3 Exposure for Alternative 3; Relocation of Receptors
For alternative 3, residents with either indoor radon progeny levels above
0.02 WL or with gamma radiation levels 20 R/h or more above background
would be relocated. This would substantially reduce the total exposure
received by residents at the sites. The maximum ijidoor radon progeny
exposure would be 0.02 WL and the maximum annual gamma radiation exposure
from indoor sources would be 250 mrem/year. Outdoor gamma exposures on
some properties are such that some residents may still receive annual doses
over the 170 mrem/year above background limit. .
Exposure to outdoor radon progeny and gamma radiation and exposures due to
ingestion, gardening, excavating or other soil invasive activities for the
remainder of the residents within the communities would be the same as for
the No-Action alternative.
4.3.2.4 Exposures for the Excavation/Disposal Alternatives
Removal of contaminated soil and replacement with uncontaminated soil is
expected to reduce the health risks to the residents of the study areas by
lowering long-term exposure to radionuclides. The exposure assessment for
the excavation/disposal alternatives is divided into two parts: (1)
exposures during remediation, and (2) exposures after remediation. For the
4-55
-------
purposes of this study, remediation includes excavation of the contaminated
soil, transportation to the disposal site and the actual disposal process
itself.
Exposures During Remediation
The major short-term exposure resulting from the excavation activities at
the sites is due to the exposure to and inhalation of outdoor radon progeny
and contaminated soil particulates. The indoor exposure to radon progeny
is expected to decrease throughout the remediation period as the source
material is removed from around the houses. Indoor radon progeny con-
centrations are directly related to radium content in the soils around the
houses and not to outdoor ambient levels of radon progeny. Therefore, the
minimal increases of radon progeny in the outdoor air will affect indoor
radon progeny concentrations.
Gamma radiation exposure will not be substantially increased above the No
Action level during the relatively short remediation period and so is not
estimated in this study. Worker exposures to radon progeny and radioactive
particulates were estimated as described in Appendix B. The dose committ-
ment from particulates was found to be negligible compared to radon progeny
and the maximum radon progeny exposure modeled for any alternative was 0.07
WLM per worker. Exposure due to ingestion is not considered to be a
problem for either workers or the general public during remediation.
The exposures during excavation are estimated by disposal option since the
magnitude of the exposure will be dependent on the design and location of
the disposal facility. For example, some of the disposal options specify
excavating the total volume of material so that the cell can be lined,
while for other options some material will be left untouched in the ground,
reducing the exposure to onsite residents caused by radon progeny and
airborne particulates.
4-56
-------
The transportation and disposal activities specified for disposal options
A, B, C and H raise the possibility that radioactive participates and radon
progeny may be released during transport and/or placement at the disposal
site, thereby increasing exposures for people along transportation routes
and at the offsite disposal facilities. Since the locations for these
offsite disposal sites are not specified at this time, these exposures were
not quantified during this study. Transportation exposures will be the
greatest for Option A where the material has to be transported across the
country. Disposal options D through G also entail transportation and
deposition exposure; however, they are far less because fewer vehicle miles
would be travelled.
Reexcavation will add an additional exposure to radon progeny and airborne
particulates for offsite resident, if Option B is used, and for Glen Ridge
residents, if Option C is implemented.
Outdoor Radon Exposure During Remediation. To estimate the changes in
outdoor radon and radon progeny for the different excavation/disposal
options, the RAECOM model was again used as described in Appendix B. The
estimates produced are based on realistic but conservative assumptions and
are best used as relative estimates to compare one option against another.
For this assessment, exposure to radon is estimated for residents living on
site, offsite within 1 km, and within the region to 80 km. The onsite and
offsite exposure are calculated in detail in the exposure assessments
presented in Appendix B. The regional exposure were estimated using the
MILDOS model as described in Appendix C. Impacts have been calculated for
excavation Alternative 5 only, since this alternative consists of
excavating a larger volume of soil than Alternative 4.
As shown in Summary Table 1 of Appendix B, the outdoor radon progeny
exposures during excavation will be about one-half the exposures for the
No-Action alternative except for Disposal Options F and G, disposal at a
lined or unlined facility at the individual sites. For these two options,
the outdoor radon exposure is at or just above the exposure for the No
Action alternative.
4-57
-------
Particulate Exposure During Remediation. The particulate release source
terms were calculated for the excavation period and were small (0.12%)
compared to the radon release source terms. Consequently, the inhalation
exposure to airborne particulates would be negligible in comparison to
radon progeny exposure.
Exposures After Remediation
After remediation the long-term exposure to the onsite residents caused by
inhalation of radon progeny, inhalation and ingestion of radioactive
particulates, and exposure to gamma radiation would be reduced to back-
ground levels for disposal options A through E, and H. For option F and G,
the indoor exposures will be reduced to background levels and the outdoor
exposures will be greatly reduced to virtually background levels.
Regional outdoor exposures were estimated using the MILDOS model and the
results are shown in Summary Tables 1 and 2 in Appendix C. MILDOS
estimates exposures from several routes, accounting for ingrowth of the
various long-lived radionuclides and uptake through the food chain.
Consequently, it is a good predictor of total impacts to be used as a final
comparison between remedial alternatives. As should be expected, the
elevated radon progeny concentrations at the Montclair/West Orange and Glen
Ridge sites have negligible impact on the surrounding area. However, it is
useful to note that the no action alternative produces the greatest offsite
impact.
4.3.3 RISK ASSESSMENT
The risks described for inhalation of radon progeny, gamma irradiation and
ingestion of contaminated materials are independent of each other and are
considered to be additive.
4-58
-------
4.3.3.1 Health Risks Associated with the No-action Alternative
Inhalation of Radon and Radon Progeny
The assumptions of 75% indoor occupancy, 70-year lifetime, and a 10-year
latency with a lifetime plateau for lung tumors used to estimate the excess
risk of lung cancer are based on figures reported by EPA (USEPA 1984a).
The assumption that the risk of lung cancer associated with exposure to WLM
over a lifetime is an increased relative risk of from 1.2% to 2.8% is based
on a review of the literature and the general agreement of this figure with
the risk estimates of other researchers (EPA 1984a). The combination of
these assumptions may overestimate the actual risk to individuals in the
area, and therefore, the risk estimates presented in Table 4-7 may provide
an upper limit on risk to the population. It should also be noted that the
risks are for lifetime exposure and that living in the contaminated area
for less than a full lifetime will decrease the risk proportionately.
Table 4-7 shows the risk "of lung cancer associated with lifetime exposure
to the levels of radon daughters present in the five tiers. Also included
for purposes of comparison is the risk associated with the average back-
ground level in New Jersey, which is estimated to be 0.002 WL.
Table 4-7, showing risks posed by lifetime exposure to different levels of
radon progeny, was combined with the population data in Table 4-5 to show
the estimated risk for the different populations at each site. This in-
formation is provided in Table 4-8. For these calculations, it was assumed
that all residents living in a particular tier were exposed for life at the
upper limit of radon working levels for that tier.
Outdoor radon progeny levels for the No-Action alternative average less
than 0.004 WL. The additional 6-hour estimated exposure to the outdoor
radon levels for the 1985 people at the three sites would add an additional
risk of from 1.5 x 10"3 to 3.4 x lo"3.
4-59
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TABLE 4-7
ESTIMATED EXCESS RISK3 OF LUNG CANCER ASSOCIATED WITH LIFETIME
INDOOR EXPOSURE TO RADON-222 AND ITS PROGENY IN
MONTCLAIR, WEST ORANGE, AND GLEN RIDGE
Risk Associated with Lifetime Residence
Indoor Radon Relative Risk Coefficient
Concentrations Progeny Tier 2.8 %T72%
(WL)
Greater than 0.5 A 4.1 x 10"1 Greater than 1.8 x 10"1
0.1-0.5 B 1.1 x 10"1 to 4.1 x 10"1 4.9 x 10"2 to 1.8 x 10"1
0.02-0.1 C 2.3 x 10"2 to 1.1 x 10"1 1.0 x 10"2 to 4.9 x 10"2
0.007-0.02 D 8.3 x 10"3 to 2.3 x 10"2 3.6 x 10"3 to 1.0 x 10"2
0.002 Average 2.4 x 10"3 1.0 x 10~3
background
Calculation based on the assumption that exposure to 1 WLM produces a relative risk for
developing lung cancer of 1.2 percent to 2.8 percent, 75 percent occupancy of the house,
residential exposure to 1 WL yields an annual exposure of 27 WLM, etc. (EPA 1984a).
(7H10/8)
-------
TABLE 4-8
MAXIMUM RISK OF
LUNG CANCER IN THE MONTCLAIR,
WEST ORANGE, AND GLEN RIDGE STUDY AREAS
FOR THE NO ACTION ALTERNATIVE
Tier
A
B
C
D
Background
City
Montclair
Montclair
West Orange
Glen Ridge
Total
Montclair
West Orange
Glen Ridge
Total
Montclair
West Orange
Glen Ridge
Total
Montclair
West Orange
Glen Ridge
Total
Risk Asso-
ciated with
Number of Lifetime
People Residence
8 greater than 1.8 x 10"1 to 4.1 x 10
41 1.8 x 10"1 to 4.1 x 10"1
6
20
67
48 4.9 x 10"2 to 1.1 x 10"1
6
18
72
159 1.0 x 10"2 to 2.3 x 10"2
26
88
273
448 1.0 x I0~l to 2.4 x W~l (indoor only)
119 1.5 x 10"J to 5.8 x 10"J
(outdoor + indoor)
405
972
a,,.
Risk values from Table 4-7.
(6H5/13)
-------
Gamma Irradiation
Risks associated with various lifetime exposures from 100 mrem/year
(slightly above background) to 1000 mrem/year are presented in Table 4-9.
These values are based on the BEIR III (1980) risk coefficients and on the
assumptions of linearity at low dose levels (EPA 1984a). Also included is
an assessment of the risk of cancer associated with exposure to the EP-
established indoor limit of 20 microR/hr above background levels,
approximately 170 mrem/year.
Table 4-9 showing the risks posed by lifetime exposure to different levels
of gamma radiation was combined with the data in Table 4-6 to show the
estimated excess risk for the different population at the sites for the
no-action alternative. This information is presented in Table 4-10. For
these calculations, it was assumed that all residents in a particular
exposure group were exposed at the upper level of that group.
Ingestion
In addition to the risks associated with inhalation of radon and radon
decay products and the direct exposure to gamma irradiation, a significant
risk to some inhabitants of the study are may be presented by ingestion of
radionuclides. Most people in the Montclair, West Orange, and Glen Ridge
study areas are not likely to be exposed by this route since most of the
contaminated soil is not available for direct contact and ingestion as it
is typically covered by a layer of sod. However, children and adults who
garden or landscape may come into contact with contaminated soil and may
inadvertently ingest small quantities. In addition, people with home
vegetable gardens may also come into contact with contaminated soil and may
ingest contaminated produce. Therefore, risks to potentially exposed
residents from the ingestion of radionuclides have been considered.
Ingestion of contaminated vegetables: Uptake of radionuclides from vege-
tables grown in contaminated soil can be calculated using the data in Table
4-11. The soil concentrations shown represent the average concentration of
4-62
-------
TABLE 4-9
ESTIMATED EXCESS RISK OF FATAL CANCER ASSOCIATED
WITH VARIOUS LIFETIME DOSES OF GAMMA RADIATION
Dose
(mrem/year)
1000
900
800
700
600
500
400
300
200
100
175b
Risk
1.98. x
1.78 x
1.58 x
1.39 x
1.19 x
9.90 x
7.92 x
5.94 x
3.96 x
1.98 x
3.46 x
a
ID'2
io-2
ID'2
ID'2
ID'2
-3
10
io-3
io-3
io-3
io-3
io-3
a Based on data from BEIR III (1980) and assuming linearity at low doses (EPA
1984a).
Risk at EPA regulated level of 20 uR/hr above background levels.
-------
TABLE 4-10
RISK OF CANCER DUE TO LIFETIME EXPOSURE TO GAMMA RADIATION IN THE MONTCLAIR,
WEST ORANGE AND GLEN RIDGE STUDY AREAS9
Location
Number of
People
Estimated
Dose
Risk Associated
With Lifetime
Residence
~*
Montclair
4
19
15
207
115
"350"
700
400
300
200
<100
1.78
0.79
0.59
0.40
0.20
West
Orange
3
3
3
6
23
1000+
600
300
200
<1000
1.98
1.19
0.59
0.40
0.20
Glen Ridge
5
65
35
1TJF
400
200
<100
0.79
0.40
0.20
Several conservative assumptions were used in deriving these estimates; the
actual number of cancer is almost certainly much lower. These numbers
should only be used in comparing the risks posed by the different alterna-
tives.
Risk values from Table 4-16.
The doses calculated assumed 75% occupancy in the basement and 25% outdoor
occupancy. They should only be used as indicators where more complete
multilevel indoor gamma surveys should be performed.
(6H5/13)
-------
TABLE 4-11
RADIONUCLIDE DATA FOR CALCULATING RISKS FROM INGESTION
OF HOME GROWN VEGETABLES
Nuclide Soil Cone Biv 2(a) Risk Factor(b)
(pCi/g)
U-238 20 4.2 x 10'3 8.6 x 10"10
U-234 20 4.2 x 10'3 8.3 x 10'10
Th-232 200 3.5 x 10"4 1.4 x 10"9
Th-230 200 3.5 x 10"4 1.5 x 10"9
Ra-226 200 2.0 x 10"2 5.4 x 10"9
Pb-210 200 4.8 x 10"3 2.4 x 10"8
Po-120 200 2.6 x 10"4 5.1 x 10"9
Soil - (dry weight)-to-piant (fresh weight) transfer factor (unitless)
(Appendix A of EPA 1984b)
Lifetime risk for a 1 pCi/y continuous ingestion intake (EPA 1984a).
(7H10/9)
-------
contaminated soil at the sites. The average radium-226 concentration
measured in organic soil was 104 pCi/g and these samples were taken in the
area of highest contamination. Lead-210 and polonium-210 are presumed to
be in equilibrium with the radium-226 in the soil. The concentration in
vegetables is obtained by multiplying the soil concentration by the soil-
to-plant transfer factor, (B iv2) (EPA 1984b). Although earlier estimates
of annual produce consumption have been as high as 194 kg/year (EPA 1984),
an average adult is assumed to consume 112 kg/y of produce (CDC 1984, EPA
1984). It is assumed that 50% of this (56 kg/y) to be obtained from the
individuals home garden. These assumptions provide the annual intakes. The
corresponding lifetime risks are calculated using risk factors consistent
with the models in Chapter 8 of EPA 1984a (280.5 cancer deaths per million
person rem). The lifetime risk due to ingestion of all radionuclides
considered is 2.5 x 10" .
Ingestion of Soil: Based on Kimbrough et al. (1984), the average soil
intake for an individual is 0.15 kg/y. Using the soil concentrations and
risk factors from Table 4-11, the lifetime risk from direct ingestion of
3
soil is calculated to be 1.1 x 10 .
The combined lifetime cancer risk from ingestion of both home grown
_3
vegetables and soil is estimated to be 3.6 x 10 .
Summary
In summary, exposure to existing levels of radon progeny in the houses at
the sites poses a substantial risk of lung cancer. The exposure due to
gamma irradiation and ingestion of contaminated materials poses a lower but
still significant risk to area residents.
4.3.3.2 Health Risk Associated with Alternative 2, Active/Passive Measures
The use of ventilation systems in the houses with elevated radon and pro-
geny levels will substantially reduce the overall risk posed by indoor
radon progeny over the No-Action alternative for the affected residents.
4-66
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Reducing the indoor levels to 0.02 WL will reduce the estimated risk for
people living in remediated homes by up to 91%. However, it should be
noted that such a reduction depends on continued maintenance and successful
operation of the system for the many thousands of years. The hazard will
persist if the radium is not removed.
The risks due to elevated outdoor radon progeny levels, elevated outdoor
gamma radiation, uptake of radioactive materials through gardening, and
other human interactions with contaminated soil will remain the same as for
the No-Action alternative.
4.3.3.3 Health Risk Associated with Alternative 3, Relocation of Receptors
Relocation of residents with elevated radon and progeny and/or elevated
gamma radiation levels will entirely eliminate the associated risk to those
residents. The average risk for people being relocated will be reduced
even more than in Alternative 2.
The risks due to outdoor radon and radon progeny levels, outdoor gamma
radiation, and other human interactions will remain the same as in the
No-Action alternative.
4.3.3.4 Health Risk Associated with the Excavation/Disposal Alternatives
The risk associated with the excavation/disposal alternatives are analyzed
in two manners. Risk to the residents during remediation and risk
after remediation.
Health Effects During Remedial Action
The health risks to the residents associated with remediation are primarily
due to exposure to increased radon gas and radon progeny during the exca-
vation. Risks due to exposure to radioactive particulates which could
become airborne during the excavation activities are very small in com-
parison with the radon progeny exposure described in Section 4.2.3.3.
4-67
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Since indoor radon concentrations will decrease throughout the remediation
period and since elevated indoor radon concentrations are the major reasons
for the high risk present at the sites, the overall risk due to inhalation
of radon progeny will decrease to background risk levels during the
remediation period.
The risks attributed to outdoor radon exposure levels during remediation
would be reduced proportionately to one-half the risk for the no action
alternative for all disposal options except Option F and G. For these two
options there is a slight increase in exposure which will add a slight
increase in the risk due to outdoor radon progeny. However, since the
overall risk estimates for residents were based on 75 percent indoor
exposure (which would be significantly reduced compared to the no action
alternative) and 25 percent outdoor exposure; this increase would not
affect the overall risk for the residents at the site.
The risks to off-site residents are minimal since the largest exposure
estimated, 0.02 pCi/1 in Glen Ridge for disposal Option G, would produce an
excess risk of about 9 x 10" . Therefore, the percent change in risks for
each remedial alternative was not measured for the off-site residents.
The removal of contaminated soil from the sites poses an additional risk of
deaths, injuries, the release of radon and particulates from moving trucks,
and the release of contaminated materials as a result of transportation
accidents. There will be no risk due to direct exposure to gamma radiation
emanating from the soils as the wastes are of low enough activity to pre-
clude this.
Deaths and injuries due to traffic accidents are easier to quantify then
other risks. Studies of the transport of radioactive wastes by truck re-
port an accident rate of 1.1 x 10" per vehicle kilometer (U.S. Atomic
Energy Commission, 1972, and Clarke et al., 1976, as reported by Argonne
National Laboratory, 1982). These sources also report rates of 0.03 deaths
4-68
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per accident and 0.5 injuries per accident. To estimate the risks for the
remedial alternatives, the assumption is made that trucks with 14-cubic-
yard capacities make two-way trips and haul a total of 121,000 cubic yards
of contaminated soil. Using these figures, 4.9 accidents and deaths would
be expected as a result of removing the material to a site within 160
miles. Disposal at the secure site in the West by truck would be expected
to result in about 39 accidents, about 20 injuries, and 1 death. These
figures indicate that there is an additional, possibly significant, risk
associated with final disposal of a licensed LLW facility. However, the
risks associated with rail transport are considerably less than for truck
since there will be less miles traveled, less volume of traffic along the
transport routes, and more control over the entire transport operation.
These results are based on the assumption that trucks with 14-cubic-yard
capacities make two-way trips and haul a total of 121,000 cubic yards of
contaminated soil.
Health Effects After Remedial Actions
•
Excavation and disposal of contaminated soils above the 5/15 pCi/g standard
will substantially reduce the overall risk posed by both indoor and outdoor
radon progeny, gamma radiation and ingestion of contaminated materials over
the No-Action alternative. The overall risk to people living in remediated
areas will be reduced much more than in Alternatives 2 and 3.
Excavation and disposal of contaminated soils would result in a permanent
remediation of indoor radon progeny and gamma radiation levels to below the
prescribed standards and in most cases to background levels. It will also
reduce almost to background the risk associated with outdoor radon, outdoor
gamma radiation, uptake of radioactive materials through gardening, and
other human interactions with contaminated soils.
The long term risk of the disposal options after remediation are also
calculated in Appendix B. Since the radon flux through the encapsulation
cell was similar for all disposal sceneries, the options specifying one
cell show less risk than three cells due to the increased surface area that
4-69
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the three sites would encompass. While the risk associated with radon
progeny exposure from a single cell on-site would be similar to the risk
for off-site disposal, the increased population density surrounding the
Montclair, West Orange and Glen Ridge sites could result in more potential
negative effects. With offsite disposal, transportation risks may have to
be considered as risks increase with the amount of vehicle-miles traveled.
Ocean disposal may present the lowest exposures to humans but the amount of
unknowns associated with this option serve to increase the risks.
4.3.4. SUMMARY
In summary, exposure to existing levels of radon progeny in the houses at
these three sites poses a substantial risk of lung cancer. The exposure
due to gamma radiation and ingestion of contaminated materials poses a
lower but still significant risk to area residents. If corrective action
is not taken, many generations of people will be exposed to similar risks
over thousands of years.
The risks posed by Alternative 3 would be less than Alternative 2 since the
affected residents would be entirely removed from their exposures.
However, both alternatives leave the contaminated soil within the
communities so that the risks due to outdoor gamma irradiation, ingestion
and other human interactions will remain the same as for the No Action
alternative. Among the excavation/disposal options, one disposal site
would present less risk than three disposal sites and an offsite disposal
location in a less densely populated area would present less overall risk
than onsite disposal.
(7H14/2)
4-70
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4.4 INSTITUTIONAL ISSUES
This section discusses how institutional issues will facilitate, guide, or
impede the implementation of the excavation and disposal alternatives.
4.4.1 INTERAGENCY COORDINATION
The proposed remediation alternatives will involve coordination with exist-
ing Federal, State and local institutions. The agencies above the local
level which will be involved in the implementation coordination of the
selected alternative will inlcude EPA, NJDEP, FEMA, OSHA, NIOSH, CDC and
DOT.
Center for Disease Control Advisory
On December 6, 1983 the Centers for Disease Control (CDC) issued a health
advisory regarding the Montclair, West Orange and Glen Ridge radiological
«
contamination. The advisory stated that although the evacuation of resi-
dents at a defined health risk was not necessary, immediate and prompt
action was felt to be necessary. This advisory was issued by CDC and was
established under consultation with the New Jersey Department of Health and
the EPA. The CDC established a three-tier plan for remedial action, based
on exposure level and a time limit for completion of action. Tier A homes
(radon level over 0.5 WL) and Tier B homes (radon level 0.1-0.5 WL) have
been temporarily remediated by air ventilation systems. However, tier A, B
and C homes (0.02-0.1 WL) were to have been permanently remediated by
December 1985. The directive specifically states: "If, for any residence,
the plan cannot be completed within the outlined time frame, then an imme-
diate alternative must be developed and implemented." The no action alter-
native would be in direct conflict with the CDC advisory. It does not
appear at this time that the CDC deadline can be met by the required date.
4-71
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Relocation
The Federal Emergency and Management Administration (FEMA) is authorized
under Superfund to manage the relocation of residents caused by remediation
actions. The implementation of any of the action alternatives will require
their notification to assist in the temporary or permanent relocation of
some residents owing to excavation activities on or at adjacent properties.
The temporary or permanent relocation of residents may be complicated by
their resistance to relocation and possibly impeded further through court
actions.
Temporary relocation policies have not been specifically defined. A tem-
porary relocation plan was established in December 1984 by FEMA for the
NJDEP Phase I Study. The relocation plan involves interagency coordina-
tion, primarily between FEMA and the New Jersey Division of Housing and
Development. The plan includes provision for "subsistence and miscel-
laneous allowances" as well "as moving and storage of personal property.
The relocation arrangements for full remediation will be significantly
different than the NJDEP project. It will involve a larger number of
residents, require permanent as well as temporary relocation, and it will
be financed under EPA funding. Consequently, it will necessitate a
central coordinating office that will handle relocation as well as other
public issues. This may include assistance from local public housing or
health agencies in addition to FEMA.
4.4.2 REGULATORY ISSUES
The action alternatives will require compliance with currently existing
Federal, State and local regulations. The regulations are addressed under
health and safety, transportation and disposal categories.
4-72
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Health and Safety
The US Department of Health and Human Services through NIOSH will be re-
sponsible for monitoring the health of workers and citizens. Worker safety
at Superfund sites are the responsibility of the employers, but OSHA has
the authority to inspect and issue citations. The general and occupational
public health regulations relevant to radiation protection that must be
implemented are 10 CFR 20 or Department of Energy Order DOE 5480-1A Chapter
IX. External gamma radiation must be maintained within the maximum per-
missible dose and internal radiation must be limited by limiting radio-
nuclides in air and water within the maximum permissible concentration. In
addition to compliance with Federal regulations, excavation and construc-
tion activities should be performed under the philosophy that is committed
to reducing personnel exposures to levels as low as reasonably achievable
(ALARA). ALARA is achieved through proper training, responsible work prac-
tices, adequate housekeeping practices and use of protective equipment when
necessary.
Transportation
The offsite transport of radiologically contaminated soils from the
Montclair, West Orange and Glen Ridge sites must comply with 49 CFR
174.403. A single truck shipment must not exceed 2,000 pCi/gm. Gross
vehicle shipments must not exceed 80,000 pounds as promulgated under P.L.
97-424, Highway Improvement Act of 1982. State and local laws are pre-
empted by Federal P.L. 93-633. The major bulk of radiologically contami-
nated soils from the sites would be sufficiently low in radioactivity that
it would be classified as nonradioactive and transported as such. Appli-
cable packaging and shipping requirements are given in 49 CFR 173.393 -
173.395. Marking and labelling requirements are covered by 49 CFR 172.300.
Although the offsite transport of radiologically contaminated soils is not
subject to state or local regulations, EPA will attempt to comply with
their requirements.
4-73
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Disposal
The permanent offsite or onsite disposal facility design must conform with
the performance and safety guidelines given in 40 CFR 192, Subpart A. The
interim offsite or onsite disposal facility design must conform with sound
engineering practices consistent with OOE's ALARA policy as covered under
DOE Order 5480.1A. Use of commercial LLW facilities for disposal is
dependent upon receiving a bid from the facility for the bulk disposal of
the soils and receiving a permit from the state in which the facility is
located.
Operations and Maintenance Requirements °
The proposed no action alternatives will require that the EPA continue the
indefinite maintenance on all homes that currently have remediation by
ventilation systems to reduce radon gas to acceptable health risks.
If the selected alternative is one of the interim offsite, or interim or
permanent onsite disposal options, then it will require that the EPA and
NJDEP implement the operations and maintenance controls of the disposal
facility as discussed in Chapter 4.1.3.
Disposal options 6 and 7 would require that these responsibilities be ex-
tended over three sites rather than just one. The O&M for the interim
disposal facilities would have to follow the DOE guidelines, whereas the
O&M for the permanent facility would follow the EPA guidelines.
Regulatory I nee n t i v e s_f o i'_Ij iterim to Final Disposal
T'oe siting of a permanent disposal facility would be an irreversible and
irretrievable commitment of resources because of current and pending
regulations, or future technological advancements in treatment technology.
The Low-Laval Parlioactive Waste Policy Act of 1980 encouraged states to
enter into compacts to develop regional facilities for low-level waste
disposal. The operation of new disposal facilities is at least 4 to 5
4-74
-------
years away and existing disposal sites may restrict access to those sites
until new sites are available. New Jersey recently missed an opportunity
to enter into the Appalachian Compact, which has Pennsylvania as the host
state. New Jersey will need to independently establish a LLW disposal
facility or enter into a compact that May not be as locally convenient. Up
to the present there have been no identified candidate sites for a LLW
facility in New Jersey. However, New Jersey must soon either select a site
within the State or enter into a compact. The need to dispose of the
large volumes of soils from the three sites should serve as an impetus to
site a facility in New Jersey. However, it may be inappropriate to dispose
of the soils in a LLW facility. Co-location may be a viable option. Dis-
posal in one of the currently existing LLW disposal sites is presently an
unknown disposal option. South Carolina and the State of Washington are
firmly committed to limiting site access severely if other states have not
reached an agreement on disposal in 1985.
Although the Beatty, Nevada, site is not a technically feasible option, it
provides an example of the present potential institutional constraints.
The current political status of Nevada on limiting site access is clear.
Nevada Governor Bryan and the City Council of Las Vegas have already dis-
approved and tried to stop the proposed disposal of Phase 1 soils at the
Beatty, Nevada, disposal site. The City Council has twice tried to use
legal action to stop the shipment, but they have not ruled out litigation.
A further option is to file a lawsuit with the U.S. Circuit Court of
Appeals. .Siting a disposal facility within the State of New Jersey will
allow offsite disposal at a considerable cost savings.
In August 31, 1983, the EPA published an Advance Notice of Proposed Rule-
making to indicate their intent to develop generally applicable standards
for the land disposal of LLW. The LLW Standard would cover all Atomic
Energy Act materials not covered by other standards.
The Nuclear Regulatory Commission has recently endorsed the identification
of wastes that can be safely disposed through less restrictive disposal
practices. The NRC seeks to identify the class of radionuclide concentra-
4--7 5
-------
tions that would be classified as below regulatory concern. EPA will
address "de minimi's" standards, which are scheduled for public review in
early 1986. Some of the the Montclair, West Orange and Glen Ridge wastes
can be reasonably expected to fall within the anticipated concentration
levels of wastes that would be covered under the de minimis standards. The
fact that the standards are scheduled to be released soon is significant
because it would be most cost-effective to segregate the wastes within the
levels of the de minimis standards for disposal as defined under those
standards. Consequently, the decision to implement the offsite or onsite
interim storage alternatives would be most practical if the de minimi's
standards were already defined.
Ocean dumping of low-level radioactive wastes is presently not an easily
attainable option. However, if an interim offsite or onsite disposal
option is selected, then the opportunity will rut be lost to apply for an
ocean dumping permit at a time when the legislature appears to be more
amenable to that option.
Another incentive to the selection of the interim onsite or offsite dis-
posal options is the opportunity to take advantage of future advancements
in treatment technologies which could cost-effectively reduce waste
volumes.
Ocean Disposal
The ocean disposal option will require the permit applicant to prepare a
si i/2-specific radioactive material disposal impact assessment that includes
11 requirements specified by the January 1983 amendment to the ocean dump-
ing act of 1982. If EPA determines a permit is warranted, then EPA must
request authority from Congress to issue the permit. This request must be
approved by a joint resolution of Congress acting within 90 days of receipt
of EPA's recommendation. To date, no permits have been issued because the
political climate to approve them has not been favorable.
4-75
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4.4.3 RESIDENTIAL USAGE RESTRICTIONS
The selection of alternatives 2 or 4 would require a restriction on prop-
erty deeds to reflect the fact that there may be, or there is, conta-
mination beneath the house, and as such any construction or repairs b-sneat'n
the house would be dons under specific radiological safety guidelines.
Furthermore, properties that would require ventilation and shielding may
also be restricted in regard to repairs or renovations to the property.
The implementation of such restrictions has occurred under other
applications. Although they could be implemented under the authority of
eminent domain, they would be impeded because of legal and public health
issues. An issue to address is whether to compensate property loss value
or consider buyouts for those residents who would be unwilling to accept
such restrictions.
4.4.4 FACILITY SITING CONSTRAINTS
The siting of an interim offsite disposal facility will be impeded beoiusis
of the inherent difficulty in siting any radioactive or hazardous wast?
disposal facility. As discussed under a previous section, New Jersey is in
need of a permanent disposal facility and, as such, has a difficult task.
The siting of an interim disposal facility, although comparatively-less
difficult, is nonetheless a formidable >
-------
the facility through purchase of residential properties. Constructing a
disposal facility at each site would be more politically equitable since
each town would receive its proportionate share of the wastes. However, it
would also be proportionately more difficult because it would involve nego-
tiations with three towns rather than just one. Acquiring the residential
properties needed to site the disposal facility will be hampered by public
resistance and legal actions.
4.5 COST ANALYSIS
This section presents the costs of the various alternatives. Tables 4-18
through 4-26 show the costs of the various alternatives. Appendix E gives
detailed backup information on the costs presented in this section. All
costs (except for the No Action Alternative) are rounded to the nearest
$100,000.
Ution
Under this alternative 16 ventilation systems installed during the removal
action would be removed. The total cost of removal plus legal and admini-
strative fees is estimated at $100,000, as shown on Table 4713.
Alternative 2 - Active fiM3!.
This alternative requires the installation of 21 additional ventilation
systems, shielding for excess indoor gamma at 14 homes and the construction
of trench vents around 12 homes to aid in radon gas reduction. Capital
costs are estimated at $1.1 million.
Legal and administrative fees plus operation and maintenance of the systems
for a 200-year period are estimated to add $3.1 million, as described in
Table 4-18.
4-78
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Alternative 3 - Relocation of Receptors
Under this alternative a total of 73 properties would be purchased, the
residents relocated, the structures demolished and disposed of, and the
properties secured from the public. The total cost of this alternative is
estimated at $7.1 million, as shown in Table 4-18.
Alternatives 4 and 5 - Excavation and Disposal
The estimated costs of these two alternatives vary with respect to the
amount of soil excavated as well as the method of disposal. The costs for
these alternatives are presented in Tables 4-19 through 4-26.
The costs used in preparing these alternatives were developed from the bid
proposals received from the NJDEP Phase 1 remediation, cost estimates from
the Canonsburg, Pennsyvlania, Final Environmental Impact Statement, Volume
II, the Envirosphere Report on the temporary storage of radioactively
contaminated soils at the West Orange Armory, meetings with DOE and DOE
contractors for the UMTRA and FUSRAP projects, R.S. Means Construction Cost
Data, and conversations with contractors, vendors, and trucking companies.
The estimates for the two excavation alternatives vary within any disposal
option because of the variation in the volume of material to be removed,
and the number of homes requiring removal of material from beneath the
basement slab as well as structural restoration.
Variation in estimated costs between disposal options is due to the vari-
ation in the volume of material to be removed, the number of homes to be
purchased for onsite interim storage or onsite final disposal, the volume
of material under homes requiring excavation, with structural support and
restoration, the method of excavation and backfill, and the variation in
transportation costs.
Eighty percent of the volumes used in preparing the estimated costs have
been confirmed by downhole borehole logging. The remaining 20 percent were
4-79
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estimated based on similarity to anomalies where borehole logging was per-
formed .
A large number of homes within the study areas have either not yet been in-
vestigated or have not fully been investigated as shown in Table 1-15.
Based on the projected number of properties still requiring investigation
and the volume of material that remains to be confirmed by downhole bore-
hole logging, it is estimated that the volumes and the prices as presented
for each of the alternatives could increase by as much as 50 percent.
(6H12/2)
4-80
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TABLE 4-18
ESTIMATED COST ($1,000)
Alternative No. 1
Remove Existing Ventilation Systems 50
Legal and Administrative j>0
TOTAL $100
Alternative No. 2
Capital Cost
Install Ventilation Systems $ 300
Gamma Shielding 100
Construct Trench Vents 700
Subtotal 1,100
Operation and Maintenance Cost (Annual Cost)
Ventilation Systems $100
Sampling and Monitoring 100
Total Annual Cost 200
Present Worth of O&M Costs P 8% per year for 200 years 2,500
Legal and Administrative Costs • . 600
Total 4,200
Alternative No. 3
Purchase 43 properties 5,400
Relocate 48 families 200
Demolition and Disposal 300
Restoration (grading & seeding) 200
Secure properties 100
Legal and Administrative 900
TOTAL 7.TDTJ
NOTES:
1. The cost of Gamma Shielding is based on placing 2 inches of concrete
over existing concrete basement slab. If lead shielding is used the
cost will increase by $135,000.
2. The cost of constructing trench vents includes the cost of container-
izing, shipping and disposing of contaminated soil excavated during the
construction of the trench vents.
(6H5/13)
4-81
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.TABLE 4-19
ESTIMATED COST
DISPOSAL OPTION A
($1,000)
Alternative
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11
12
13
Item
Excavation
Soil Erosion/Sediment Control
Structural Restoration
Dust Proofing
Mobilization
Police/Traffic Control
Containerize Waste
Transloading Facility
Transportation
. Storage Charges
. Engineering for Excavation
. Legal /Administrative
. Relocation
TOTAL
No. 4
10,600
500
1,500
400
400
600
37,400
200
35,400
71 ,800
7,500
7,800
500
174,600
No. 5
11,500
500
2,900
400
400
600
38,000
200
36,400
73,000
8,500
7,800
800
181 ,000
NOTE: Pending Federal Legislation may place a surcharge of $10 per cubic
foot on the storage charges. Should this legislation be passed, the
estimate for Alternative No. 4 will increase by $32,200,000 and the
estimate for Alternative 5 will increase by $32,800,000.
(6H5/13)
4-82
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TABLE 4-20
ESTIMATED COST
DISPOSAL OPTION B
($1,000)
Alternative
Item
1. Excavation
2. Soil Erosion/Sediment Control
3. Structural Restoration
4. Dust Proofing
5. Mobilization
6. Police/Traffic Control
7. Engineer Excavation
8. Relocation of Residents
Subtotal Excavation Costs
9. Transportation to Interim Storage
10. 'interim Storage Site Selection
11. Interim Storage Site Acquisition
12. Interim Storage Site Preparation
13. Interim Storage Site Construction
14. Engineer Interim Storage
15. Mobilization
Subtotal Interim Storage Site
Construction
16. Final Disposal Site Selection
17. Final Disposal Site Purchase
18. Engineer Final Disposal Site
19. Final Disposal Site Preparation
20. Encapsulate Radioactive Waste
21. Re-Excavate Contaminated Material
22. Mobilization
23. Transport to Final Disposal
24. Operation and Maintenance
Subtotal Final Disposal
25. Legal and Administrative
TOTAL
No. 4
10,600
500
1,500
400
400
600
7,500
500
22,000
3,400
800
400
600
2,100
500
100
7,900
800
500
500
600
6,100
1,800
- 300
7,700
400
18,700
7,800
56,400
No. 5
11,500
500
2,900
400
400
600
8,500
800
25,600
3,500
800
400
600
2,100
500
100
8,000
800
500
500
600
6,100
1,800
300
7,800
400
18,800
7,800
60,200
(6H5/13)
4-83
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TABLE 4-21
ESTIMATED COST
DISPOSAL OPTION C
($1000)
Alternative
Item
1. Excavation
2. Soil Erosion/Sediment Control
3. Structural Restoration
4. Dust Proofing
5. Mobilization
6. Police/Traffic Control
7. Engineer Excavation
8. Relocation of Residents
Subtotal Excavation Costs
9. Transportation to Interim Storage
10. Interim Storage Site Acquisition
11. Interim Storage Site Preparation
12. Interim Storage Site Construction
13. Engineer Interim Storage
14. Mobilization
Subtotal Interim Storage Site
Construction
15. Final Disposal 'Site Selection
16. Final Disposal Site Purchase
17. Final Disposal Site Engineering
18. Final Disposal Site Preparation
19. Encapsulate Radioactive Waste
20. Re-Excavate Contaminated Material
21. Mobilization
22. Transport to Final Disposal
23. Operation and Maintenance
Subtotal Final Disposal
24. Legal and Administrative
TOTAL
No. 4
7,500
500
1,300
400
400
600
6,800
500
18,000
400
3,800
500
1,100
500
100
6,400
800
500
500
600
6,100
3,900
300
7,700
400
20,800
7,800
53,000
No. 5
8,400
500
2,700
400
400
600
7,800
800
21,600
400
3,800
500
1,100
500
100
6,400
800
500
500
600
6,100
3,900
300
7,800
400
20,900
7,800
56,700
(6H5/13)
-------
TABLE 4-22
ESTIMATED COST
DISPOSAL OPTION D
($1,000)
Alternative
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Item
Excavation
Soil Erosion/Sediment Control
Structural Restoration
Dust Proofing
Police/Traffic Protection
Engineer Excavations
Disposal Site Acquisition
Engineer Disposal Site
Disposal Site Preparation
Encapsulation Construction
Transport Contaminated Materials
Mobilization
Operation and Maintenance
Legal and Administrative
Relocation of Residents
TOTAL
No. 4
10,200
500
1,200
400
600
7,300
8,800
500
900
4,000
700
600
400
7,800
500
44,400
No. 5
11,000
500
2,500
400
600
8,500
8,800
500
900
4,000
700
600
400
7,800
800
48,000
(6H5/13)
4-85
-------
TABLE 4-23
ESTIMATED COST
DISPOSAL OPTION E
($1,000)
Alternative
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Item
Excavation
Soil Erosion/Sediment Control
Structural Restoration
Dust Proofing
Police/Traffic Protection
Engineer Excavations
Disposal Site Acquisition
Engineer Disposal Site
Disposal Site Preparation
Encapsulation Construction
Transport Contaminated Materials
Mobilization
Operation and Maintenance
Legal and Administrative
Relocation of Residents
TOTAL
No. 4
6,600
500
1,200
400
600
6,300
8,800
500
900
2,400
300
600
400
7,800
500
37,800
No. 5
7,500
500
2,500
400
600
7,300
8,800
500
900
2,400
300
600
400
7,800
800
41,300
(6H5/13)
4-86
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TABLE 4-24
ESTIMATED COST
DISPOSAL OPTION F
($1,000)
Alternative
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Item
Excavation
Soil Erosion/Sediment Control
Structural Restoration
Dust Proofing
Police/Traffic Protection
Engineer Excavations
Disposal Site Acquisition
Engineer Disposal Site
Disposal Site Preparation
Encapsulation Construction
Transport Contaminated Materials
Mobilization
Operation and Maintenance
Legal and Administrative
Relocation of Residents
TOTAL
No. 4
9,600
500
600
300
600
7,500
9,500
1,500
1,300
5,900
700
700
900
7,800
500
47,900
No. 5
10,300
500
1,700
300
600
8,500
9,500
1,50*0
1,300
5,900
'700
700
900
7,800
800
51,000
(6H5/13)
4-87
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TABLE 4-25
ESTIMATED COST
DISPOSAL OPTION G
($1,000)
Alternative
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Item
Excavation
Soil Erosion/Sediment Control
Structural Restoration
Dust Proofing
Police/Traffic Protection
Engineer Excavations
Disposal Site Acquisition
Engineer Disposal Site
Disposal Site Preparation
Encapsulation Construction
Transport Contaminated Materials
Mobilization
Operation and Maintenance
Legal and Administrative
Relocation of Residents
TOTAL
No. 4
5,300
500
600
300
600
5,200
9,500
1,500
1,700
3,500
300
700
900
7,800
500
38,900
No. 5
5,900
500
1,700
300
600
6,000
9,500
1,500
1,700
3,500
300
700
900
7,800
800
41,700
(6H5/13)
4-88
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TABLE 4-26
ESTIMATED COST
DISPOSAL OPTION H
OCEAN DISPOSAL
($1000)
Alternative
Item
1. Excavation
2. Soil Erosion/Sediment Control
3. Structural Restoration
4. Dust Proofing
5. Mobilization
6. Police/Traffic Control
7. Engineer Excavation
8. Relocation of Residents
Subtotal Excavation Costs
9. Transportation to Interim Storage
10. Interim Storage Site Selection
11. Interim Storage Site Acquisition
12. Interim Storage Site Preparation
13. Interim Storage Site Construction
14. Engineer Interim Storage
15. Mobilization
16. Operation & Maintenance
Subtotal Interim Storage Site
Construction
17. Prepare EIS on Disposal Site
18. Re-excavate Contaminated Material
19. Transport to Dock
20. Dock Fees
21. Loading Cost
22. Barging Cost
23. Mobilization
24. Monitoring
Subtotal
25. Legal and Administrative
No. 4
10,600
400
1,500
400
400
600
7,500
500
21,900
3,400
800
400
600
2,100
500
100
300
8,200
2,000
1,800
3,400
200
700
1,500
300
900
10,800
7,800
No. 5
11,500
400
2,900
400
400
600
8,500
800
25,500
3,500
800
400
600
2,100
500
100
300
8,300
2,000
1,800
3,500
200
700
1,600
300
900
11,000
7 ,800
TOTAL 48,700 52,600
(6H5/13)
4-89
-------
REFERENCES FOR CHAPTER 4
Technical Feasibility and Cost
United States Department, Oak Ridge Operations Office, Remedial Action Work
Plan for the Middlesex Landfill Site. August 1984
NLO, Inc. Project Report of Phase I Remedial Action of Properties Asso-
ciated with the Former Middlesex Sampling Plant, September 1981 (NLCO
-006EV)
United States Department of Energy, Oak Ridge Operations Office, Remedial
Action Work Plan for the Maywood Site, July 1984 (ORO-850)
»
Bechtel National Inc., Advanced Technology Division, Environmental
Monitoring Plan for the Maywood Site, Maywood, NJ, September 1984
United States Department of Energy, Final Environmental Impact Statement,
Remedial Actions at the former Vitro Rare Metals Plant Site, Canonsburg,
Washington County, Pennsylvania, Volume I, July 1983 (DOE/EIS - 0096-F Vol.
United States Department of Energy, Final Environmental Impact Statement,
Remedial Actions at the Former Vitro Rare Metals Plant, Canonsburg,
Washington County, Pennsylvania, Volume II Appendices, July 1983
(DOE/EIS-0096-F Vol. II).
United States Department of Energy, Vicinity Properties Management and
Implementation Plan, Final, June 1984 (UMTRA-DOE/AL-050601)
United States Department of Energy, Plan for Implementing EPA Standards for
UMTRA Sites - Not Dated - (UMTRA-DOE/AL-163)
4-90
-------
REFERENCES FOR CHAPTER 4 (continued)
Envirosphere Company, Engineering Feasibility Study and Health Physics
Evaluation of a Proposed Temporary Storage Site for Radioactiviy
Contaminated Soil, August 1984
United States Department of Energy, Draft Environmental Impact Statement
for Long-term Management of the Existing Radioactive Wastes and Residues at
the Niagara Falls Storage Site, August 1984
Baker/TSA, Construction Plans and Specifications for Montclair/Glen Ridge
Radiological Contamination Removal, March 18, 1985
Baker/TSA, Specifications for The Disposal of Contaminated Materials, March
18, 1985
Baker/TSA, Specifications for The Transportation of Contaminated Materials,
March 18, 1985
Meeting between Camp Dress & McKee Inc. and NJDEP December 6, 1984
Meeting between Camp Dresser & McKee, Inc. Bechtel National Inc., BAKER
Engineers, Holt & Ross, USEPA AND NJDEP
Meeting between Camp Dresser & McKee Inc. and Roy F. Weston, Inc., January
22, 1985
Telephone Conversation between B. Germanio of Camp Dresser & McKee, Inc.
and D. Adrian of U.S. Ecology, March 19, 1985
Meeting between Camp Dresser & McKee, Inc., R.F. Weston, Inc, Jacobs
Engineering, Morrison-Knudsen, Bendix Corp., USEPA, and USDOE May 15, 1985
4-91
-------
REFERENCES FOR CHAPTER 4 (continued)
Environmental
N.J. Dept. of Enviromental Protection. 1980. Investigation of a Former
Radium Processing Site. Jeanette Eng.
U.S. Department of Energy. Draft Environmental Impact Statement, Long-Term
Management of the Existing Radioactive Wastes and Residues of at the
Niagara Falls Storage Site. (DIE/EIS-01091), August 1984.
U.S. Environmental Protection Agency. Final Environmental Impact Statement
(EIS) for 106-Mile Ocean Waste Disposal Site Designation, February 1980.
.U.S. Environmental Protection Agency. Report to Congress January 1981 -
December 1983, On Administration of the Marine Protection, Research, and
Sanctuaries Act of 1972, as amended (P.L. 92-532)' and Implementing the
International London Dumping Convention, 1983.
Sandia National Laboratories, Feasibility of Ocean Disposal of Materials
from the Formerly Utilized Sites Remedial Action Program (FUSRAP),
(SAND-82-0459C), 1982.
Kathy Bronnander, Helen de Seal a Realty, Telephone Conversation between
Emily Pimentell of Camp Dresser & McKee Inc., June 21, 1985
Jean Carradona, Township of Montclair Tax Assessor, Telephone Conversation
between Emily Pimentell of Camp Dresser & McKee Inc., June 20, 1985
Robert Ebert, Township of Glen Ridge Tax Assessor, Telephone Conversation
between Emily Pimentell of Camp Dresser & McKee Inc., June 21, 1985.
Richard J. Gimello, New Jersey Hazardous Waste Facilities Siting
Commission, Telephone Conversation between Emily Pimentell of Camp Dresser
& McKee Inc., June 20, 1985.
4-92
-------
REFERENCES FOR CHAPTER 4 (continued)
Joseph Scatturo, Township of West Orange Tax Assessor, Telephone
Conversation between Emily Pimentell of Camp Dresser & McKee Inc., June 21,
1985.
Ellen K. Silbergeld, Environmental Defense Fund, Telephone Conversation
between Emily Pimentell of Camp Dresser & McKee Inc., June 24, 1985.
Public Health
Argonne National Laboratory 1982. Methods for Assessing Environmental
Impacts of a FUSRAP Property-Cleanup/Interim Storage Remedial Action.
U.S. Department of Energy, pp. 3-49
Camp Dresser & McKee Control (COM). 1985 Interim Report on Morkplan
Development-Montclair/West Orange, New Jersey: Low Level Radiation
Sites. January 8, 1985
Centers For Disease Control (CDC). Letter from C. Eheman to Richard Spear,
Ph.D., USEPA. July 6, 1984. Letter from C. Eheman to Jeanette Eng, New
Jersey Department of Environmental Health. July 12, 1984
Evans, R., Harley, J., Jacobi, W., McLean, A., Mills, W., and Stewart, C.
Estimate of Risk From Environmental Exposure to Radon-222 and Its Decay
Products. Nature 290:98-100
Gilbert, T., Cree, P., Knight, M., Peterson, J., Roberts, C., Robinson, J.,
Tsai, S. and Yuan, Y.C. 1983. Pathways Analysis and Radiation Dose
Estimates For Radioactive Residues at Formerly Utilized MED/MED/AEC
Sites. Argonne National Laboratory. March 1983. NTIS Publication No.
CE83-011018
4-93
-------
REFERENCES FOR CHAPTER 4 (continued)
Hobbs, C.H., and McClellan, R.O. 1980. Radiation and Radioactive
Materials. In: Doull, J., Klaassen, C., Amdur, M., eds. Casarett and
Doull's Toxicology--The Basic Science of Poisons. 2nd ed. Macmillan
Publishing Co., New York
Kimbrough, R., Falk, H., Stehr, P., and Fries, G. 1984. Health
Implications of 2,3,7,8-Tetrachlorodibenzodioxin (TCDD) Contamination
of Residential Soil. In; Lowrance, W.W., ed. Public Health Risks of
Diosins. William Kaufmann, Los Altos, California
Thomas, D.C., and McNeil 1, K.G. 1982. Risk Estimates for the Health
Effects of Alpha Radiation. Prepared for the Atomic Emergency Control
Board
U.S. Environmental Protection Agency (USEPA). 1976. Potential
Radiological Impact of Airborne Releases and Direct Gamma Radiation to
Individuals Living Near Inactive Uranium Mill Tailing Piles. U.S.
Office of Radiation Programs, Washington, D.C. January 1976 EPA
520/1-75-001
U.S. Environmental Protection Agency (USEPA). 1979. Indoor Radiation
Exposure Due to Radium-226 in Florida Phosphate Lands. U.S. Office of
Radiation Programs, Washington, D.C. July 1979. EPA 520/4-78-013
U.S. Environmental Protection Agency (USEPA). 1983. Background
Information Document—Proposed Standards for Radionuclides. U.S.
Office of Radiation Programs, Washington, D.C. March 1983. EPA
520/1-83-001
U.S. Department Of Energy (USDOE). 1983. Radiological Guidelines For
Application of DOE's Formerly Utilized Sites. Remedial Action Program.
NTIS Publication No. DE83-011013
4-94
-------
REFERENCES FOR CHAPTER 4 (continued)
U.S. Department of Transportation, Bureau of Motor Carrier Safety,
Accidents of Motor Carriers of Property, 1980-91 August 27,1982), pp.
35-40, 51-52; National Highway Traffic Safety Administration,
Large-Truck Accident Causation (July 1982), pp. III-4 and III-5
Whittemore, A., and McMillan, A. 1983. Lung Cancer Mortality Among U.S.
Uranium Miners: A Reappraisal. UnCI 71:489-499
Institutional
Center for Energy and Environmental Management, and Nuclear Waste News,
1985. The 1985 Washington Conference on Low Level Nuclear Waste
Disposal and Cleanup, May 16-19, 1985, Arlington, Virginia.
(6H10/14)
EPA 1984a EPA 520/1-84-015 An Estimation of the Daily Food Intkae Based
On Data from the!977-1978 USDA Nationwide Food Consumption Survey
EPA 1984a EPA 520/1-84-022-1 Radionuclides. Background Information
Document for Final Rules, Volume 1.
EPA 1984b EPA 520/1-82-022-1 Radionuclides. Background Information
Document for Final Rules, Volume 2.
4-95
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-------
5.0 SUMMARY OF ALTERNATIVES
The remedial action alternatives were assessed for technical feasibility,
environmental, socioeconomic, institutional, and public health impacts and
cost criteria. This chapter summarizes the information in Chapter 4, high-
lighting the trade-offs among the criteria assessed to facilitate the
selection of a remedial alternative.
5.1 NON-COST EVALUATION OF ALTERNATIVES
Table 5-1 presents the Non-Cost Evaluation of the five remaining candidate
remedial alternatives and the eight disposal options summarizing, the
assessment of alternatives as described below.
5.1.1 ALTERNATIVE NO. 1, NO ACTION
Under Alternative No. 1, No Action, the existing ventilation systems
installed during the removal action would be removed and quarterly
monitoring would be discontinued.
This alternative, while readily implementable, does not attain public
health objectives or meet environmental standards. It also does not meet
the December 6, 1983 CDC advisory and is in conflict with the large public
response demand for action at these sites.
5.1.2 ALTERNATIVE NO. 2, ACTIVE/PASSIVE MEASURES
Under Alternative No. 2, Active/Passive Measures, the existing ventilation
systems would be continued and 21 additional ventilation systems installed.
Trench vents would be required to help reduce radon levels in 12 homes
where the existing ventilation systems do not achieve removal of radon to
0.02 WL. In addition, 14 homes would require installation of shielding to
reduce exposure to gamma radiation.
5-1
-------
U1
I
TABLE 5-1
NON-COST EVALUATION OF ALTERNATIVES
No. 1
No
Criteria Action
Reliability
Previous
Implementation 0
Time to
Implement +
Air Impact
Groundwater
Impact
Public Health
Impact
Community
Acceptance
Deed
Restrictions
Siting
Problems +
No. 2 Disposal Disposal Disposal
Active/ Alt 3 Alt 4 Alt 5 Option Option Option
Positive Relocation Excavation Excavation A B C
+ + +00
+ + + + + -
+ + 0 0 - - 0
00++ +
0 + + +
+ + 0 0 + + +
+ + + 0
0 + + +
+ + 0 0 + -
Disposal Disposal Disposal Disposal Disposal
Option Option Option Option Option
D E F G H
0 - 0
.
0 0000
+ + +
+ 0. + 0 +
+ + + + +
-
+ + + + +
+
+ Denotes positive or beneficial impact
0 Denotes no significant impact
Denotes negative or adverse impact
(RW11/12)
-------
This alternative is easily implemented and assures the elimination of the
major adverse health impacts, but does not meet the relevant environmental
standards. Contaminated soil will still remain within the communities
posing exposure and ingestion hazards. The potential for future migration
of radon gas and radium in the soil would necessitate continued radon,
groundwater, and surface water monitoring. It also is in violation of the
CDC advisory and unacceptable to the public. Restrictions would be re-
quired to be placed in deeds to all properties on which contaminated soils
exist, requiring that any excavation activities on the property be regu-
lated so that worker and public safety are addressed and proper disposal of
the contaminated soil is assured.
5.1.3 ALTERNATIVE NO. 3 RELOCATION OF RECEPTORS
Under Alternative No. 3, relocation of receptors, 43 properties with radon
progeny concentrations in excess of 0.02 WL or average indoor gamma
exposure rates in excess of 20 uR/hr would be purchased; the residents
relocated; the structures demolished and disposed off; and security fences
placed around the property or group of contiguous propreties to prohibit
access.
This alternative would assure the immediate elimination of the major
adverse health impacts by removing the receptors from the source, but would
not attain relevant environmental standards. Contaminated soil will still
remain within the communities posing exposure and ingestion hazards. While
the CDC advisory would be met, the public would still find this alternative
unacceptable. The potential for future migration of radon gas and radium
in the soil would necessitate continued radon, groundwater and surface
water monitoring. It would require that restrictions be placed in deeds
requiring that any excavation on contaminated properties not purchased, be
regulated so that worker and public safety are addressed and the proper
disposal of contaminated soil is assured.
5-3
-------
5.1.4 ALTERNATIVE NO. 4, EXCAVATION TO ELIMINATE ADVERSE HEALTH EFFECTS
Under Alternative No. 4, excavation to eliminate adverse health effects,
contaminated soils would be removed from all open lands to the 5 or 15
pCi/gm standard averaged over 100 square meter area, as described in 40 CFR
192, and from under or around residences only if the radon progeny concen-
trations exceed 0.02 WL or if the average indoor gamma exposure rates
exceed 20 uR/hr above background.
This alternative would attain the goal of eliminating adverse health
impacts but would not meet the relevant environmental standards.
Restrictions would be required to be placed in deeds requiring that
excavation activities be regulated on those properties where contamination
exists under the basement slab or adjacent to the foundation so that worker
and public safety are addressed and to insure that contaminated soils are
properly disposed. Such restrictions are certain to be found unacceptable
by the public.
5.1.5 ALTERNATIVE NO. 5,-EXCAVATION TO MEET RELEVANT ENVIRONMENTAL
STANDARDS
Under Alternative No. 5, excavation to meet relevant environmental
standards, contaminated soils would be removed from all open lands and from
around and beneath structures to 5 or 15 pC/g average over any 100 square
meters as describe in 40 CFR 192. This alternative attains all public
health objectives, meets relevant environmetal standards and would allow
all properties remediated to be released for unrestricted use.
5.1.6 ALTERNATIVE NO. 6, EXCAVATION TO ELIMINATE ALL CONTAMINATION
Under Alternative No. 6 excavation to eliminate all contamination, any soil
within 6 inches of the ground surface exceeding 5 pCi/g and any soil at
depths greater than 6 inches from the ground surface exceeding 15 pCi/g
would be removed from open lands and from around or under structures. This
alternative exceeds both public health and environmental standards and
would allow all properties remediated to be released for unrestricted use.
5-4
-------
It may not be technically feasible to implement this alternative due to
problems with verification. The cost of the search and verification
procedures would be more than an order of magnitude greater than those for
the other two excavation alternatives. For these two reasons, this alter-
native was eliminated from further consideration.
5.1.7 DISPOSAL OPTIONS
For each of the two remaining excavation alternatives there are eight
disposal options, allowing for a total of 16 remedial alternatives involv-
ing excavation.
Disposal Option A, Disposal at a licensed Low Level Radioactivity Waste
Facility, is a reliable and previously implemented disposal option. It is
similar to the NJDEP Phase I Remediation at Montclair and Glen Ridge and is
a proven method of containment for contaminated materials. However,
because of the large volume of soil that must be disposed of, use of an
existing LLW facility may not be feasible in light of the future demands on
the Richland facility (the only available LLW facility) by the State of
Washington and other States within the Northwest compact. In addition, the
large distance the soils must be transported raises the potential for
increased public health risks due to transportation accidents.
Disposal Options B & C; Offsite Interim Storage and Reexcavation for Final
Disposal, and Interim Storage in Glen Ridge with Reexcavation for Final
Disposal, would meet environmental and public health standards but could
take some time to implement since the offsite storage or disposal sites
would have to undergo environmental study and meet with public acceptance.
While interim storage, as it is specified in Chapter 3, has been previously
implemented and found effective, the encapsulation cell specified for final
disposal is still in the construction phase at the Cannonsburg, Pennsyl-
vania site and its effectiveness is unproven.
5-5
-------
Disposal Option C, with an on-site interim storage facility is probably
more efficient than Option B since it could take place immediately without
having to wait for an acceptable interim storage site to be located off-
site. It would allow for a detailed site selection to take place so that
an environmentally suitable site could be selected for permanent disposal.
The use of an interim storage facility would also allow for the development
of existing, yet environmentally unproven disposal technologies or for the
implementation of any new, more environmentally-sound technologies for
treatment or final disposal.
Disposal Option D through G, Permanent Disposal in Lined or Unlined Cells
in Glen Ridge, or at Each Site are similar to the permanent disposal
sceneries for Options B and C since they have not been previously imple-
mented and are, therefore, not proven effective. However, Options D
through G would entail no special siting studies and so could probably be
implemented in a shorter time period.
Local disposal would probably net be accepted by the community for any of
the four options. Disposal Options E and G would probably elicit the most
objections since the unlined cells may be less reliable than the encapsula-
tion cells specified for options D and F.
Option H. Ocean disposal, will necessitate the construction of an interim
storage site with all of its requirements and a site specific environmental
impact assessment. While it is not felt that there would be any adverse
environmental impacts associated with ocean disposal, and studies of past
ocean disposal sites seems to bear this out, there is a large unknown
element to any ocean disposal scenerio such that this option may be thought
as less reliable than land disposal alternatives. While the local commu-
nity may accept this option since it is "offsite", there will undoubtedly
be a large adverse public response to any ocean disposal proposal.
5-6
-------
5.2 NON-COST COMPARISON OF ALTERNATIVES
Technical
All of the remaining remedial alternatives are technically feasible, how-
ever, excavation and disposal at a licensed LLW facility (Option A) is
probably the most technically reliable option for the following reasons:
(1) other disposal options have not been previously demonstrated; and (2)
Alternatives 2 and 3 would leave contaminated material within the community
and therefore should not be considered completely reliable remedial alter-
natives. However, because of the large volume of soil that must be dis-
posed of, and the current regulatory restrictions on existing LLW facili-
tes, implementation of option A may not be possible after January 1, 1986.
Environmental and Public Health
Ocean disposal would probably offer the least problems as far as potential
for concentrated release to the environment and resulting affects on the
biological community and, eventually, man. However, ocean disposal is
perceived by the public to adversely affect the environment, no matter what
the situation. This perception, coupled with the issue that opening the
door for ocean disposal would set a precedent for disposal of more highly
reactive or toxic wastes, may preclude the use of the ocean for disposal of
the Montclair/West Orange and Glen Ridge soils. Of the other disposal
options, while all are subject to the documented problems of land disposal,
complete encapsulation would be more environmentally desireable than the
unlined capped cell versions offered in Options E and G. In terms of
exposure, one disposal cell offers less risk than three and disposal sites
located in less densely populated areas offer less risk than any onsite
disposal option .
Institutional
Alternatives 1, 2, 3 and 4 do not meet relevant environmental and public
health standards and are not acceptable solutions from the public view-
point.
5-7
-------
Every disposal option poses institutional problems in implementation. The
existing LLW facility may not be able to accept the wastes due to the new
LLW disposal policy. The offsite disposal sites will need to be sited and
accepted by the public. The onsite disposal options are unacceptable to
the local communities and could cause major socioeconomic impacts to these
communities.
5.3 COST COMPARISON OF ALTERNATIVES
Table 5-2 presents the cost summaries for the candidate remedial alterna-
tives. For the excavation/disposal alternatives, the disposal option is
costed using the volumes and figures for Excavation Alternative 5.
The No Action alternative is obviously the least costly, followed by
Alternative 2 and 3, the source control alternatives. All of the excava-
tion/disposal alternatives are more costly than the source control alter-
natives by at least an order of magnitude.
Of the eight disposal options, the least costly are Option E, onsite
disposal in an unlined, capped cell in Glen Ridge, estimated to cost $41.3
million, and Option G, onsite disposal at an unlined, capped cell at each
site, estimated to cost $41.7 million.
(7H9/5)
5-8
-------
Alt. 1 Alt. 2
No Action Active Meas.
Table 5-2
MONTCLAIR/WEST ORANGE AND GLEN RIDGE
REMEDIAL ALTERNATIVE COST SUMMARY
($1000)
Alt. 3 Alt. 5
Relocation of Disposal Disposal Disposal Disposal Disposal Disposal Disposal Disposal
Receptors Option A Option B Option C Option D Option E Option F Option G Option H
Excavation & Restoration
Engineering of Excavation
Transport to Interim
Interim Site Selection & Design
Interim Acquisition
Interim Site Construction
Final Site Selection & Design
Final Site Acquistion
Reexcavation
Containerize waste
Transloading Facility
Transport to Final Disposal
Construct Final Disposal
Storage Charges
Relocation of Residents
Demolition and Disposal
Secure Properties
EIS for Ocean Disposal
Port Fees
Load Barges
Ocean Transport
Monitoring
Install /Remove Vent
and Shielding 50 1,100
Operation and Maintenance 2,500
Legal and Administrative 50 600
Total 100 4,200
200 . 16,300 16,300 13,000 15,500 11,900 14,100 9,700 16,200
8,500 8,500 7,800 8,500 7,300 8,500 6,000 8,500
3,500 400 3,500
1 , 300 500 1 , 300
5,400 400 3,800 400
2,800 1,700 2,800
1,300 1,300 500 500 1,500 1,500
500 500 8,800 8,800 9,500 9,500
1,800 3,900
38,000
200
36,400 7,800 7,800 700 300 700 300 3,500
7,000 7,000 5,000 3,500 7,200 5,200
73,000
200 800 800 800 800 800 800 800 800
300
100
2,000
200
700
1,900
900
400 400 400 400 900 900 300
900 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800
7,100 181,000 60,200 56,700 48,000 41,300 51,000 41,700 52,6(10
-------
ATTACHMENT I
-------
SUBJECT
FROM
TO
^ i r> i i
UNITEL ,TATES ENVIRONMENTAL PROTECT,.A AGENCY «"^
SEP171984
Cleanup Criteria for Radium-Contaminated Soils in Glen Ridge, Montclair,
and West Orange, New Jersey
Sheldon Meyers, Acting Director
Office of Radiation Programs (ANR-458)
William J. Librizzi, Director
Emergency and Remedial Response Division, Region II
This memorandum transmits criteria recommended for use in the cleanup
of properties contaminated with radium-226 at aites in Glen Ridge,
Montclair end Vest Orange, New Jersey. Recommended limits for indoor
concentrations of radon decay products were previously provided in the
"Public Health Advisory for Glen Ridge and Montclair, New Jersey" prepared
by the Centers for Disease Control. Limits on the concentration of
radium-226 in toil and on gamma exposure rates are now provided to
complete the basic criteria needed for the remedial action program. These
'criteria are consistent with the objectives for the indoor radon limits,
and are identical to the standards promulgated by the Agency for remedial
action on lands contaminated with radium-bearing tailings from inactive
uranium mill sites (40 CFR 192.12; Sections a(l), a(2) and b(2)). The
guidance for implementation of those standards will also be useful in the
application of criteria to the remedial activities in New Jersey.
Attachment 1 is the Federal Register notice containing the standards and
implementation guidance.
Some comments on the application of the criterion for subsurface soil
may be helpful. For the New Jersey sites, preliminary data indicate that
the locations of contaminated soil may be noncontiguous, with
concentrations ranging from values near the criterion to two thousand
pCi/g. The cost and difficulties of removing small, noncontiguous volumes
of marginally contaminated soil nay hamper the overall remedial actions.
Thus, decisions for or against removal in a particular location may be
facilitated by the averaging technique for the areal extent of soil
concentrations provided for in Section 192.12(a) of the standards.
Bawever, we encourage that removal decisions based on such an averaging
technique or on findings of extensive quantities of moderately elevated
concentrations (e.g., 5-15 pCi/g) of radium-226 be made with good
statistical assurance that the criteria for soil contamination will be met.
The preliminary data also indicate that soil contamination may not be
vertically contiguous (i.e., stratification of radium wastes may exist).
Such observations illustrate the need for radioactivity measurements to
properly represent the 15 cm layer stipulated in the criteria. For
example, the results from analyses of soil samples should reflect an
average concentration for the entire 15 cm layer and gamma logging
instruments should incorporate adequate collimation so that contributions
from a greater than 15 cm layer are minimized.
ee 'i
12
-
: 13^333' j-D
-------
The numerical values in the recommended criteria are intended as
upper limits for soil radium concentration, exposure rate, and indoor
radon decay product levels for use in the management of remedial
activities. The criteria also suggest that consideration should be
given to opportunities to cost-effectively further reduce exposures or
concentrations to levels below the numerical values. Conversely,
decisions to discontinue remedial action may be appropriate when there
is reasonable assurance that radium wastes are not the cause of any
elevated radiation exposure.
On-site personnel in New Jersey have thus far demonstrated good
capability in managing the remedial actions. We are confident that the
tasks of applying these criteria will also be capably performed. Although
our limited resources will permit us to provide assistance (e.g., quality
assurance for soil analyses) with these activities during the pilot removal
program, the lack of the Office of Radiation Programs' resources currently
identified for Superfund activities precludes long term commitments of
staff or equipment. Please continue to direct any questions concerning
the application of these criteria to Allan C.B. Richardson (FTS 557-8927)
ia the Office of Radiation Programs.
Attachment
cc: Christopher J. Daggett (Region II)
Richard J. Guimond (ANR-460)
Paul A. Giardina, Region II
Allan C.B. Richardson (AHR-460)
-------
Wednesday
January 5, 1983
Part H
Environmental
Protection Agency
Standard* for Bemedtaf Action* at"
Inactive Uranium Processing Stta*
-------
690 Federal Register / Vol. 46, No. 3 / Wednesday. January 5,1983 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Partita
tA-FRL22l1-«ai
Standards for Remedial Actions at
Inactive Uranium Processing Sites
AGENCY: U.S. Environmental Protection
Agency.
ACTION; Final rule.
•UMMAftr: We are i»uing final health
and environmental standards to govern
stabilization, control, and cleanup of
residual radioactive materials (primarily
mill tailings] at inactive uranium
processing sites: These standards were
developed pursuant to Section 275 of the
Atomic Energy Act (42 U.S.C. 2022), as
added by Section 206 of the Uranium
Mill Tailings Radiation Control Act of
1978 (Pub. L 65-604). and were proposed
in April 1980 and January 1981.
The standards apply to tailings at
locations that qualify for remedial
action under Title I of Pub. L 05-604.
Hie standards for control provide that
die tailings be stabilized in a way that
gives reasonable assurance that the
health hazards associated with the
tailings will be controlled and limited
for a long period of time. They also
establish a requirement to control
releases of radon from tailings piles. The
standards for cleanup set limits on the
radon decay-product concentration and
gamma radiation levels in buildings
affected by tailings and on the radium-
226 concentration in contaminated land.
la response to comments on the
proposed standards for disposal and* for
.cleanup, we have evaluated a number of
alternatives in terms of their costs sad •
the reductions achievable in potential
health effects. A number of changes
have been made, including raising some
of the numerical limit* and eliminating
some requirements. The purpose of most
of these changes it to make
implementation easier and less costly.
The changes should not result in any
substantial loss of health or
environmental protection over that
which would have been provided by the
proposed standards.
EFFECTIVE DATE: The final standards
take effect on March 7,1063.
ADOAEMES: Final Environmental
Impact Statement. Background
information is given in the Final
Environmental Impact Statement for
Remedial Action Standards for Inactive
Uranium Processing Sifes. (FES). EPA
Report 520/4-82-013-1. Single copies of
the FEIS, as available, may be obtained
from the Program Management Office
(ANR-456). Office of Radiation
Programs, U.S. Environmental Protection
Agency. Washington. D.C 20460;
telephone number 703-657-4351. .
Docket. Docket Number A-70-25
contains the rulemaking record. The
docket is available for public inspection
between 6:00 a.m. and 4:00 p.m.. Monday
through Friday, at EPA's Central Docket
Section (A-I30). West Tower Lobby. 401
M Street S.W.. Washington. D.C 20460.
A reasonable fee may be charged for
copying.
POM. PUKTHEN INFORMATION CONTACT
Dr. Stanley Lichtman. Guides and
Criteria Branch (ANR-460), Office of
Radiation Programs. U.S. Environmental
Protection Agency. Washington, D.C
20460; telephone number 703-557-8927.
•UPPLEMEMTAftY SMFOMSATIOSC
L Introduction
On November 8.1078, Congress
enacted the Uranium Mill Tailings
Radiation Control Act of 1978, Pub. L
05-604 (henceforth designated "the
Act"). In the Act. Congress stated its
finding that uranium mill tailings ". . •
may pose a potential and significant
radiation health hazard to the public,
. . . and. . . that every reasonable
effort should be made to provide for
stabilization, disposal, and control in a
safe and environmentally sound mBP"«r
of such tailings in order to prevent or
minimize radon diffusion into the
environment and to prevent or mfnim
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Federal Register / Vol. 46. No. 3 / Wednesday. January 5. 1983 / Rules and Regulations 591
considered are given In the FEJS.
Selected results of our analysis that ar»
pertinent to our choices for each part of
the final standard are gtven tn Section
ID of this Notice. The following table
contains a summary of the alternative
standard* we considered for control of
tailing! pile*.
ALTERNATIVE STANDARDS ra* CONTROL OP URAMUM Mu. TAJUNGB PILES
TV alternative cleanup and control
standards can be generally categorized
as:
(I) Least cost alternatives which
provide minimum acceptable health
protection, and depend upon the use of
institutional methods of control:
(2) Optimized cost-benefit alternative*
which provide longer term health
protection, without reliance on
institutional controls, but at somewhat
higher costr. and
(3) Nondegndation alternatives which
attempt to achieve dose to the same
environmental consequences as might
occur if the ore had not been mined:
these entail much higher costs, and
could result in some undesirable
environmental consequences.
Our analysis was based on assuming
that remedial actions to satisfy "least
coat" tailings pile control standards
would entail applying a thin earthen
cover and little or so reinforcement of
relatively steep side slopes. Integrity of
the cover would be assured through
active maintenance for 100 years. Only
minimal flood protection measures
would be applied, and ai few as one pile
would be moved to a more stable
location. Covers would be progressively
thicker and lesi dependent upon care
under the more stringent alternatives,
with more gradual slopes and greater
use of rock for reinforcement. Under the
"nondegradation" alternatives, up to
half of the piles would be moved to
jatlafy either water protection or
longevity requirements.
* The alternative cleanup standards
would require progressively more
'complete removal of tailing* from more
buildings. Remedial methods that do not
involve tailings removal may be used on
a limited basis under all but
"nondegradation" alternatives.
The more stringent land cleanup
alternatives require more complete
removal of contaminated material.
implying that larger areas may be
cleaned up at each contaminated '
location and somewhat greater numbers
of sites qualify for cleanup.
We concluded that the standards we
originally proposed approach a
"nondegradation" alternative that
would, in at least some cases, be
difficult to implement, since they specify
cleanup and control limits close to
background levels. More importantly.
the small incremental health benefits,
when compared to the benefits for lets
stringent alternative*, do not appear to
Justify the large additional costs.
We selected an "optimized cowl-
benefit" rather than a "least cost"
alternative for the final standards, in
part because It provides much greater
1A ante to th» (Mm of rw&Mcthw mitoriii
thai pimtMJO V bilbo* a»eiMr trwufornuttoBt
(14. d*c«y* of radium mu> ndoa) pn Mooad. A
picocune (pd) It * tritftonth of t curt*. On*
ptcocuric of maltha! produce! |u»t over two
mnHaruttara p«r minuu. pQ/B'i It t aalt for
(to !•!•••• rat* at radioactivity froa i rerfto*
(m-m*u*. t-mcood). pO/f • t «a« far Om
protection of health at only a small
increase above the least cost
aJtaraauvea. and in part becauae it does
not place primary reliance on
institutional methods of control The
final standards provide for
(1) Control tyrtemt for tailings piL
Control and stabilization which will
ensure, to the extent reasonably
achievable, an effective life of 1000
years, and in any case, for at least 200
years. This control and stabilization will
be designed to provide a barrier which
will effectively minimize the po;r*»:al
for misuse and spread of the tailings,
limit the average radon emission from
the surface of tailings piles to no more
than 20pCi/m't,'protect against
flooding, and protect from wind and
water erosion. We have also provided
an alternative equivalent to the radon
emission limit that is stated in terms of
the maximum radon concentration in air
at locations off the pile.
(2) Flood control—Diking or other
flood protection controls jjiven first
consideration, rather than moving piles,
when there is a risk from floods.
(3) Control of waterborne pollutant*—
DOE should assess each site and
establish any corrective or preventive
programs found necessary to meet
relevant State and Federal Water
Quality Standards and to be consistent
to the maximum extent practicable, with
the Solid Waste Disposal Act aa
amended.
(4) Cleanup of buildings—fin
objective for reduction of radon deca>
products of 0.02 WU'with a maximum
limit of 0.03 WL
(5) Cleanup of dispersed tailings
Limitations of soil radium content to S
pCi/g (above background) averaged
ovar the top 15 centimeters of soil and
to 15 pCi/g averaged over any 15
centimeters of soil below this.
(6) Cleanup of off-lite land-—Remedial
actions applied only to situations that
constitute a hazard; in those case*,
cleanup equivalent to the above
standard for dispersed tailings.
Tha Table below provides a summary
comparison of the proposed and final
standard*. The following sections
provide a more detailed discussion of
the basis for the final standard*.
radioactivity aancnmttaa In • i
.
•A -worUm IrraT fWIJ b any oo«bu)«tioo of
«bol-H*»d radon deny producti bi on* liter of »tr
(fell wUJ iMuJl lo UK ultimate emiuioo of *lpba
|wrtid« with • lauJ «MffT of 130 bOi io (he «L- ool of how
Buck rnliitor i ftrm* «cni»Uy
-------
692
Federal Register / Vol. 48. No. 3 / Wednesday, January 5. 1983 / Rules and Regulations
SUMMARY COMPARISON Of PROPOSED AMD FMAL STANDARDS
ConwaoiT.
. 1. Una*
OM^C o uma
1.1
t Bral...
I 1000
sun
Specific imu for • runtw of tow *nd
0rBdUon <*
OJ1IWI
S pO/B In * <
tooiaiMlM*
t pCt/g *< mi IS em h*v Mat <
UC e 1800 yum to f» «rtmi rmnn.
«* •«•<•». tu • IM 100
»w»
10 pO/m •«. «r OJ fO/1 ki •> ouvd*
•n dvoowi ••. lonnurt ID
(ex isoucian
UM nmncj Suit «nO fumtl
Sntf not mate 0.01 WU to in atM
»tie»c««. KtMd 0.08 WU
Unoivna
It I* tl an
16 pO/fl m «nr IS an to* MB* M
It should be noted that these
standard* in DO way are intended to
establish precedents for other situations
or regulations involving similar
environmental objectives, but with
different economic and/or technological'
circumstances. For example, our
'orthcoming proposed standards for
live uranium mills will be based on an
.idependent analysis of operating and
future mills, which may result in -
different standards. Similarly, our
remedial action standard for
contaminated buildings should not be
taken as an appropriate design goal for
indoor radon decay product
concentration in new housing, or as a
remedial action goal appropriate for all
circumstances.
IL Summary of Background Information
Beginning in the 1940's. the VS.
Government purchased uranium for
defense purposes. As a result large
quantities of tailings were created by
the uranium milling industry. These
tailings are a sand-like material, and are
attractive for use in construction and
soil conditioning. Most of these mills are
'now inactive, and the ultimate disposal
of their tailings has not yet talcen place.
In addition, tailings have been dispersed
from the piles at most of the sites by
natural forces, or have been removed by
man for use in or around buildings, or on
land. The Act provides for the cleanup
of these offsite tailings as well as for the
long-term control of the tailings piles.
Congress designated twenty-two
•tive sites, and the Department of
gy has added two more. The sites
«_c located in the West, predominantly
in arid areas, except for a single site at
Canonsburg. Pa. Tailings piles at these
sites range in area from 5 to 150 acres
and in height from a few feet to as much
as 230 feet. The amount of tailings at
each jite ranges from only residual
contamination to 2.7 million tons. The
twenty-four designated sites combined
contain about 26 million tons of tailings
covering a total of about 1,000 acres.
The most important hazardous
constituent of uranium mill tailings Is
radium, which is radioactive. We
estimate that these tailings contain a
total of about 15,000 curies of radium.
Radium, in addition to being hazardous
itself, produces radon, a radioactive gas
whose decay products can cause lung
cancer. The amount of radium in
tailings, and. therefore, the rate at which
radon is produced, will decay to about
10% of the current amount in several
hundred thousand years. Other
potentially hazardous constituents of
tailings include arsenic, molybdenum.
selenium, uranium, and. usually in lesser
amounts, a variety of other toxic
substances. The concentrations of these
materials vary from pile to pile.
Radiation and toxic materials may
cause a variety of cancers, and other
diseases, as well as genetic damage and
teratogenic effects. Tailings are
hazardous to man because: (1) decay
products of radon may be inhaled and
increase the risk of lung cancer, (2)
individuals may be exposed to gamma
radiation from the radioactivity in
tailings: and (3) radioactive and toxic
materials from tailings may be ingested
with.food or water. We believe the first
of these hazards is clearly the most
important.
The radiation hazard from tailings
lasts for many hundreds of thousands of
years, and some nonradioactive toxic
chemicals persist indefinitely. The
hazard from uranium tailings therefore
must be viewed in two ways. In
themselves, the tailings pose a present
hazard to human health. Beyond this
immediate, but generally limited health
threat the tailings are vulnerable to
human misuse and to dispersal by
na rural forces for an essentially
indefinite period. In the long run. this
threat of expanded, indefinite _»
contamination overshadows the present
dangers to public health. The
Congressional report accompanying the
Act expressed the view that the
methods used for remedial actions .
should not be effective for only a short
period of time. It stated "The committee
believes that uranium mill tailings
should be treated... in accordance
with the substantial hazard they will
present until long after existing
Institutions can be expected to last in
their present forms," and that 'The
Committee does not want to visit this
problem again with additional aid. The
remedial action must be done right the
first time." (H.R. Rep. No. 1480. 95th
Cong.. 2nd Sess.. Pi I p. 17, and PL IL p.
40 (1976).)
For the purpose of establishing
standards for the protection of health.
we assume a linear, nonthreshold dose-
effect relationship as a reasonable basis
for estimating risks to the general public
from radiation. This means we assume
that any radiation dose poses some risk
and that the risk of low doses is directly
proportional to the risk that has been
demonstrated at higher doses. We
recognize that the data available
preclude neither a threshold for some
types of damage below which there are
DO harmful effects, nor the possibility
that low doses of gamma radiation may
be less harmful to people than the linear
model implies. However, the major
radiation hazard from tailings arises
from alpha radiation, and the National
Academy of Sciences' Advisory
Committee on the Biological Effects of
Ionizing Radiation (the BEIR Committee)
stated in their 1980 report that for ". . .
radiation, such as from internally
deposited alpha-emitting radionuclides.
the application of the linear hypothesis
is less likely to lead to overestimates of
risk, and may. in fact lead to
underestimates."
Our quantitative estimates of
radiation risk are based on our review
of epidemioiogical studies, conducted in
the United Stales and in other countries.
of underground miners of uranjum and
other metals who have-been exposed to
-------
Federal Register / Voi, 48, No. 3 / Wednesday, January 5, 1963 / Rule* and Regulations'
593
radon decay products, and on three
reporU: The Effects on Population* of
Exposure to Law Levels of ionizing
Radiation (1972) and Health Effect* of
Alpha Emitting Particles in the
Respiratory Tract (1976) by the BQR
Committee, and the report of the United
Nstiont Scientific Committee on the
Effect* of Atomic Radiation entitled
Source* and Effects of Ionizing
Radiation (1877). Detnili of our risk
estimate* are provided in Indoor
Radiation Exposure Due to Rodium-228
in Florida Phosphate Land* (EPA 520/4-
78-013) and in the FEIS.
Although the studies of underground
miners show that there is a significant
risk of lung cancer from exposure to
radun decay product*, there is some
uncertainty about its magnitude.
Exposure* of miner* are estimated from
the time spent in each location in a mine
and the measured radon decay product
levels at those locations. However.
radon decay product measurements
were infrequent and often nonexistent
for exposures of miners prior to the
1960's. The uncertainty increases when
data for miners are used to estimate risk
to the general population because there
are differences in age. physiology.
exposure conditions, and other (acton
between the two populations.
Nevertheless, we believe the
information available provides an
estimate of risk which is probably
reliable within a factor of two or three,
and that this constitutes an adequate .
basis for these standards.
It is not possible to reduce the risk to
zero for people exposed to radiation or.
for that matter, to many other hazardous
material*. In order to decide on an
appropriate level of a small residual
risk, we evaluated the costs and benefits
of different levels of control We also
considered technical difficulties
associated with Implementing different
levels of control
The legislative record shows that
Congress intended that EPA set general
standards and not specify any particular
method of control. Therefore, our
analyses of control methods, costs.
risks, and other pertinent factors
emphasize the general characteristics of
uranium mill tailings and the designated
sites. The Act gives other agencies of the
Feder •-Government the responsibility
to decide how to satisfy these standards
at specific sites. They will issue site-
specific Environmental Impact
Statements or Environmental
Assessments, as appropriate, covering
such matters.
The information upon which we based
these health and environmental
standards for control and cleanup of
tailings from inactive uranlusB
processing site* is summarized below.
Additional background information and
more complete presentations are givea
in era notices of proposed rulemaJdng
(45 PR 27370. April 22.1980, sod 40 PR
2556. January 9.1981] and in the PHIS.
A The Risks from Tailings
Uranium mill tailings can affect man
throogh four principal environmental
pathway*:
• Diffusion ofmdon-232. the decaj
product of radfum-220. from tailings into
indoor air. Breathing radon-222. an inert
gas. and Its short half-life decay
products, which attach to tiny dual
particles, exposes the tangs to alpha
radiation (principally from polonium-210
and polonium-214). The exposures
involved may be large for persons who
have tailings In or around their houses.
or who live very dose to tailings .pile*.
Additional, but smaller, exposures to
alpha radiation may result from long'
lived radon-222 decay product!
(principally lead-210 and poIonrom-210).
Exposure doe to radon from tailings to
or around buildings is best estimated
from direct measurements of its decay
products in indoor air.
• Direct exposure to gamma
radiation. Many of the radioactive
decay products in tailings produce
gamma radiation. The most important
are lead-214. biarotith-214. and thallium-
210. Hazards from gamma radiation an
limited to persons In the immediate
vicinity of piles or removed tailings.
Exposure due to gamma radiation from
tailings is readily estimated from direct
measurements.
• DispertoJ of taioJl partJcJet of
tailings material in the air. Wind
erosion of unstabilized tailings piles
creates airborne tailings material The
predominant dose is to the bones from .
eating foods contaminated by thorium-
230. radium-228, and lead-210. and is
small. Exposure doe to airborne
transport of radon and paxticulata* from
• pile usually cannot be directly
measured, but may be estimated using
meteorological transport m/wUU.
• Waterbome transport of
radioactive and toxic material
Dispersal of unstabilized tailings by
wind or water, or leaching, can carry
radioactive and other toxic materials to
surface or ground water. Current levels
of contamination appear to be low or
nonexistent However, some long-term
future contamination of surface and
ground water and consequent intake by
man and animals is possible. Potential
exposures due to the transport of
waterborne contaminants are highly
site-specific and can generally only b»
determined by a careful survey program.
The following discussion of risks
focuses largely oa current biological
effects: however, these current effects
could be expanded by future misuse of
tailings by man and by uncontrolled
effects of natural forces. Our standards
reflect consideration of both current and
future Impacts of tailings.
1. Air Pathways. We estimated the
hazards posed by radon emissions to air
from uranium mill tailings piles and
from tailing* used hi and around houses.
For the first case we used
meteorological models and considered
people in the neighborhood of the pile.
the population in the local region, and
the remainder of the national
popolatton. For the second, we drew
largely upon experience from
contaminated houses in Grand Junction.
Colorado. Pour sources of exposure
were considered; inhaled short-lived
radon decay products, gamma radiation,
the long-lived radon decay products.
and airborne tailings.
From our analysis we conclude:
(a) Lung cancer caused by the short-
lived decay products of radon is the
dominant radiation hazard from tailings.
Effects of gamma radiation, of long-lived
radon decay products, and of airborne
tailings from the piles are generally
much less significant, although high
gamma radiation doses may sometime*
occur.
(b) Individual* who have tailings in or
around their houses often have large
exposures to indoor radon and hence
high risks of lung cancer. For example,
in 50% of a sample of 190 houses with
tailing* in Grand Junction. Colorado, we
estimate that the lifetime exoew risk
due to exposure to short-lived radon
decay products prior to remediation may
have been greater than 4 chances in 100.
(c) Individuals living near an
uncontrolled tailings pile are also
subjected to high risks from short-lived
radon decay product*. For example, we
estimate that people living continuously
next to some of the piles may have
lifetime excess lung cancer risks a* high
as 4 chance* in 100.
(d) Based on models for the
cumulative risk to all exposed
populations, we estimate that, without
remedial action, the radon from all the
inactive sites considered together could
cause about 170 to 240 potential excess
lung cancer death* per century. Of
these, 55% to 80% are projected to occur
among person* living less than 50 miles
from a pile.
There I* a substantial uncertainty in
these estimate* because of uncertainties
in the rale of release of radon from
tailing* piles, the exposure people will
receive from its decay products, and
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594 Federal Register / Vol. 48, No. 3 / Wednesday, January 5, 1983 / Rules and Regulations
from our incomplete knowledge of the
effects on people of these exposures. In
addition, our estimates are based upon
current sizes and geographical
distributions of populations. If
populations increase in the future, the
estimated impact would be larger.
We concluded that a primary
objective of standards for cleanup of
tailings should be to remove or reduce
existing and potential risks due to radon
decay products indoors. Such risks from
indoor radon decay products arise in
two ways—in existing buildings where
tailings were used in construction and
cause elevated levels, and from land
contaminated sufficiently to cause
deviled levels in new construction. A
secondary objective should be to reduce
high exposures to gamma radiation due
to tailings in buildings or on land away
from the tailings piles.
We concluded that a primary
objective of standards for control ol
tailings should be isolation and
stabilization to prevent their misuse by
man and dispersal by natural forces.
such as wind, rain, and flood waters. A •
second objective should be to reduce
radon emissions from tailings piles. A
third objective should be the elimination
of significant exposure to gamma
radiation from tailings piles.
2. Wa'.er Pathways. Although water
contamination does not now appear to
be a significant source of immediate
radiation exposure at the piles, both
radionuclides and nonradioactive toxic
substances, such as arsenic,
molybdenum, and selenium, could be
leached or otherwise removed from
tailings and contaminate water
resources. If this occurred, it could then
affect crops, animals, and people. Such
contamination could, in principle, be
caused by either past or future releases
from the tailings. Tailings piles at
inactive sites have already lost most of
the water deposited in them during mill
operations through evaporation and
seepage. However, elevated
concentrations of radioactive or toxic
substances m ground water have been
observed at only a few of the designated
sites (four are identified in the FEIS),
and in some standing water ponds (but
not in running water). Any future water
contamination would arise from the
effects of rain or through flooding of a
pile, from penetration of a pile from
below by ground water, or from leaching
of tailings transported off a pile.
A theoretical analysis performed for
the Nuclear Regulatory Commission
(NRC) of a larger model pile showed
that contamination of ground water by
selenium, sulfate, manganese, and iron
might exceed current drinking water
standards over an area 2 kilometers
wide and S to 30 kilometers long.
However, more than 95% of this
projected contamination was
attributable to initial seepage of process
water discharged to the pile during mill
operations. The movement of
contaminants through a pile and subsoil
to ground water depends on a
combination of complex chemical and
physical properties, as well as on local
precipitation and evaporation rates.
Chemical and physical processes can
effectively remove or retard the flow of
many toxic substances passing through
subsoil. However, some contaminants
such as arsenic, molybdenum, and
selenium, can occur in forms that are not
removed. Typically, ground water can
move as slowly as a few feet per year.
and only in coarse or cracked materials
does the speed exceed one mile per
year. For these reasons, contaminants
from tailings may not affect the quality
of nearby water supply wells for
decades or longer after they are
released. However, once contaminated,
the quality of water supplies cannot
usually be easily restored simply by
eliminating the source (although, in
some cases removing or isolating the
tailings may contribute to improving
water quality).
Based on results from the NRC generic
model for mill tailings piles, it is likely
that the few observed cases of ground
water contamination resulted from
seepage of the original liquid waste
discharges from the mill. Additional
future contamination of ground water
should be much smaller, and in most
cases would be expected to be
minimized by measures required to
control misuse of tailings by man and
dispersal by wind, rain, and flood
waters. These measures should also
effectively eliminate the threat of
contamination of surface water by
runoff or from leaching of tailings
transported off piles, and provide
reasonable protection of surface and
ground water from contamination by
flooding. However, at a few specific
sites, especially in areas of high rainfall
or where ground water tables intersect
the piles, special consideration of
possible future contamination of ground
water may be needed.
Though a few sites appear to have
some existing contamination due to the
presence of tailings, we believe it will
usually not be feasible or practical to
remove the contaminants from subsoil
or ground water. Whether or not it is
feasible or practical to restore an
aquifer and to what degree will depend
on site-specific factors, such as the
ability to restore the aquifer in its
hydrogeologic setting, the cost, the
present and future value of the aquifer
as a water resource, the availability of
alternative supplies, and the degree to
which human exposure is likely to
occur.
We concluded that potential
contamination of surface and ground
water at the inactive sites must be
considered on a site-specific basis. The
remedial program should provide for
adequate hydrological and geochemical
surveys of each site as a basis for
determining whether specific water
protection or cleanup measures should
be applied. In many cases, the control
measures needed for other purposes
should reduce any potential for
contamination. .«
In addition to the available
information upon which we based our
conclusion, hydrological and
geochemical studies are presently being
conducted or planned at a number of
sites. The purpose of these studies is to
gather additional information so as to
more fully assess any actual or potential
ground water contamination and to
better understand the mechanism of
contaminant movement. The studies will
identify the extent and character of
contaminants remaining in the piles, as
well as the direction, rale of movement
and degree of attenuation of any
contaminants already released. In
particular, attention is being given to
identifying the likelihood of
contaminants reaching an actual or
potential water supply source. We are
currently reviewing current studies and
will review future studies assessing the
site-specific factors related to potential
ground water contamination.
As stated previously in this Section II.
site-specific Environmental
Assessments (EAs) or Environmental
Impact Analyses (ElAs) will be prepared
for each site. We will review the
information generated as part of those.
The EAs or ElAs would gather data on a
site-specific basis which would either
characterize the site completely or
confirm the use of general models in
determining potential mechanisms for
impact or lack of impact on ground
water.
We believe that it is important to
conclude these studies as quickly as
possible. These studies will provide a
more complete data and analytical base
to allow us to reevaluate the decision
not to set ground water protection
standards. Information to be obtained as
a part of the studies will include the
response of the tailings and interstitial
fluids to water table and precipitation
stimuli: distribution of radionuclides and
other contaminants within the tailings
pile; identification of mobile
constituents within the tailings and
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Federal Register / Vol. 48. No. 3 / Wednesday. January 5, 1983 / Rules and Regulations 595
ground water system: and analyses of
the mechanisms for the release and
transport of the contaminants both to
the surface and downward to ground
water.
To date, the results of more recent
studies than those we described in our
FE1S strongly support our decision not to
issue general numerical water protection
standards. We intend to continue to
review additional information as it
becomes available, and will reconsider
our decision if the need to do so
becomes apparent.
B. Cleanup and Contra] of Tailings
L.Cjntrolof Tailings Piles. The
objectives of tailings control and
stabilization efforts are to prevent their
misuse by man. to reduce radon
emissions (and gamma radiation
exposure), and to avoid the
contamination of land and water by
preventing erosion by natural processes.
The longevity (i.e.. long-term integrity)
of control is particularly important. This
is affected by the potential for
disruption by man: by the probability of
occurrence of such natural phenomena
as earthquakes, floods, windstorms, and
glaciers; and by chemical and
mechanical processes in the piles.
Prediction of the long-term integrity of
control methods becomes less certain as
the period of concern increases. Beyond
several thousand years, long-term
geological processes and climatic
change become the dominant factors.
Methods to prevent misuse by man
and disruption by natural phenomena
maybe divided into those whose
integrity depends upon man and his
institutions ("active" controls) and those
that do not ("passive" controls).
Examples of active controls are fences,
warning signs, restrictions on land use,
and inspection and repair of semi-
permanent tailings covers, temporary
dikes, and'drainage courses. Examples
of passive controls are thick earthen
covers, rock covers, massive earth and
rock dies, burial below grade, and
moving piles out of locations highly
subject '^rosion. such as unstable river
banks.
Erosion of tailings by wind, rain, and
flooding can be inhibited by contouring
the pile and its cover, by stabilizing the
surface (with rock, for example) to make
it resistant to erosion, and by
constructing dikes. If necessary, erosion
can be inhibited by burying tailings in a
shallow pit or moving them away from a
particularly flood-prone or otherwise
geologically unstable site.
Methods to control release of radon
range from applying a simple barrier
(such as an earthen cover) to such
ambitious treatments as embedding
tailings^in cement or processing them to
remove radium, the precursor of radon.
Covering tailings with a permeable
(porous) barrier, such as earth, delays
radon diffusion so that most of it decavs
and is effectively retained in the cover.
In addition to simple earthen covers,
other less permeable materials such as
asphalt, clay, or soil cement usually in
combination with earthen covers, may
be used. The more permeable the
covering material, the thicker it must be
to achieve a given reduction in radon
release. However, maintaining the
integrity of very thin impermeable
covers, such as plastic sheets, even over
a period as short as several decades is
unlikely given the chemical and physical
stresses present at piles.
The most likely constituents of covers
for use to control tailings are locally
available earthen materials. The
effectiveness of an earthen cover as a
barrier to radon depends most strongly
on its moisture content. Typical clay
soils in the uranium milling regions of
the west exhibit ambient moisture
contents of 9% to 12%. For nonclay soils
ambient moisture contents range from
6% to 10%. The following table provides.
as an example, the cover thicknesses
•that would be required to reduce the
radon emission to 20 pCi/m2s for the
above ranges of soil moisture. Three
examples of tailings are shown that
cover the probable extreme values of
radon emission from bare tailings at the
designated sites (100 to 1000 pCi/m's);
the most common value is probably
somewhat less than 500 pCi/m's.
ESTIMATED COVER THICKNESS (METERS) TO
ACHIEVE 20 PG/M«S
HaOO** 9***S3W* froffl
tailings lpoi/m*a
'<» , . ,
"° , .,
1QOD
•
17
3.4
4.1
•
1.3
2.6
12
contont of cowv
10
1.0
2.0
24
12
o.r
1.5
1.S
These values are for simple
homogeneous covers. In practice, multi-
layer covers using clay next to the"
tailings can be used to significantly
reduce the total thickness required.
Methods that control radon emissions
will also prevent transport of
participates from the tailings pile to air
or to surface water.'Similarity,
permeable covers sufficiently thick for
effective radon control will also absorb
gamma radiation effectively (although
thin impermeable covers will not).
'However, recent studjea suggest the possibility
that some chemical processes in tailings piles could
carry dissolved contaminant! upward, perhaps even
through earthen covering! Control system designer*
must carefully consider this possibility.
Control of possible contamination of
ground water is difficult In the few
cases where this is a potentially
significant problem, clay liners and/or
clay caps may provide a good degree of
protection for at least many decades.
However, more permanent protection
may require removal to a site with more
favorable hydrological, geochemical, or
meteorological characteristics.
Very effective long-term inhibition of
misuse by man. as well as of releases to
air and surface water, could be achieved
by burying tailings in deep mined
cavities. In this case, however, direct
contact with ground water would ??
difficult to avoid. The potential hazards
of tailings could also be reduced by
chemically processing them to remove
contaminants. Such processes have
limited efficiencies, however, so the
residual tailings would still require
control. Furthermore, the extracted
substances (e.g., radium and thorium]
would be concentrated, and would
require further control.
We analyzed the costs of a number of
possible control methods. The total cost
is affected most strongly by the type of
material used to stabilize the surface
against erosion and inhibit misuse by
man. by the water protection features
required, and by the number of piles that
must be moved to new sites. In general
costs of covers using man-made
materials (e.g., asphalt) are somewhat
higher than costs for earthera covers.
Active control measures are usually less
costly in the short term than are passive
measures. The costs for burial of tailings
piles or for using chemical processing to
extract radium (and perhaps other
substances) are much higher than those
for disposal using covers. We find that
given a decision to carry out any
significant stabilization, the total cost of
control using earthen covers does not
depend strongly on the degree of
reduction of radon emissions, for
reductions by up to about a factor of 50
(the maximum that would probably be
required at any site under these
standards).
2. Cleanup of Tailings. The objective
of cleanup of tailings from buildings is to
reduce elevated indoor levels of radon
decay products and gamma radiation.
The objective of cleanup of tailings from
land is to remove the potential for
elevated levels of radon decay products
in future buildings, and exposure of
people to gamma radiation.
A variety of methods for cleanup of
buildings are available. The most
commonly used, and the most reliable
and permanent measure, is to dig out the
tailings and return them to the pile. This
is sometimes relatively easy, such as
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596 Federal Register / Vol. 48, No. 3 / Wednesday. January 5, 1983 / Rules and Regulations
removing tailings from outside footings.
but may be very difficult, as in removing
tailings from under a concrete slab floor
in a finished room. Other methods
include air filtration, improved
ventilation, and the use of sealants to
•keep out radon.
Windblown tailings on lands around a
tailings pile are usually removed by
scraping off the top few inches of earth
with earth-moving equipment and
adding it to the pile. Land cleaned up in
this way is relatively easily restored to
close to background levels of
radioactivity because windblown
tailings are usually on the surface and
easy to remove. Generally the cost is
determined by the amount of land
sc.-'ip'''''. < . '. '. Thick covers
offer greatly increased benefits from
inhibiting misuse. ccr.tru.'Iing radon
emissions, and increased longevity of
the covers' effectiveness. For example.
we estimate that the final control
standard provides about ten times
greater overall benefits than the lowest
cost alternative standard, for only about
25 percent greater cost. Therefore, given
that tailings piles will be stabilized
under any of the alternatives we
considered, we find it cost-effective to
stabilize them well This observation
strongly influenced our choice of a
radon release standard, as discussed in
Section L1J.B.2. below.
Cost and benefit estimates for the
alternative standards we considered are
reported in detail in the FEJS: we briefly
summarize here only our estimates for
the final standards we selected.
Costs: We estimate the remedial
action costs for mill sites and for off-site
cleanup will be 156 and 38 million (1981)
dollars, respectively. DOE has estimated
its program development and
management ("overhead") costs as 118
million (1981) dollars. These estimated
total expenditures of 314 million (1981)
dollars will occur over a period of seven
yean or more.
Benefits: We estimate benefits under
the assumption, when appropriate, that
tailings pile control systems wilt be
partially effective longer than the
Standard requires. Control systems are
required to be effective for as long as
reasonably achievable up to 1000 years,
but for not less than ZOO years. Under
this standard most of the 24 tailings pile
will be stable against erosion and casual
intrusion for misuse for much longer
than inofl years. Those few piles that are
susceptible to flood damage will be
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Federal Register / Vol. 48. No. 3 / Wednesday. January 5. 1983 / Rules and Regulations
597
{.'.'ot?i::ed for at least 200 years, and
might not suffer real damage for much
longer. During the period of full control.
the maximum risk for individuals living
very near a tailings pile from exposure
to its radon emissions will be reduced
b> about 97*6. from about 3 chances in
100 to about 1 chance in luOO. An
estimated 200 potential premature
deaths per century will be avoided
initially, for a total of many thousands
over the life of the cover. The potential
fur or existence of water contamination
from tailings piles will be evaluated and
av.v :wfltti\e or remfdi?! actions that
the implementing agencies determine
are warranted will be taken. We further
f .-•:." jte that dbout 60 premature deaths
•A-'!l OP Avoided bv cleaning up
• • . . .-Vs-ii bu:;d;njs :\r.
u:iue:c m-innble additional number of
d^.-iths and the institutional burden of
applying land-use controls may be
c\ vjvj by cleaning up 1900 acres of
land containing windblown tailings and
about 3200-6500 additional locations
where tailings have been brought for
inappropriate uses.
•;. S.-ope of:he Stc.idards and the EIS.
Commenters expressed the view that
«crre important impacts cf mi!! tailings
were not adequately considered in the
DEIS and that we had not considered all
cf :b.c available pertinent data. They
cited inadequate consideration of (a) the
health impacts of toxic elements, (b)
r:.r!;..t;rn doses to man from tho food
pathway, and (c) 1.1 e effects of
radior.uclides and toxic elements on
plants and animals.
We have reviewed the available data
on tcxic elerr.er.ts in tailings and
improved the FEIS in this respect
(Appendix C). We have concluded that
it is reasonable to expect that hazards
frorr. tovc eluments will be adequately
limited if control and cleanup are
carried out according to these final
starda.-ds. We have also reviewed the
rad:ation doses from ingestion of food
and confirmed our earlier conclusion
thdt :he risks from this pathway are
small. We have not specifically required
r.e^sures to protect animals and plants
from thft hazards of radioactivity, since
we have concluded that the impacts are
sma!!.
S.-.T-e comments expressed the view
that the proposed standards were too
narrow in scope to adequately protect '
public health. For example, it was
proposed that the standards should
include: Limits for radionuclide
concentrations in air participates and in
vegetation: limits for toxic elements in
?c'!, guidance for the interim period
prior to remedial actions: jnd radiation
protection criteria for workers who
perform remedial actions.
We have considered these comments
and believe that no changes are needed.
If control and cleanup are carried out
according to these final standards, the
health impact from radionuclides in air
and from food pathways, and from toxic
elements in soil, which are already low,
would be .fuj .her n-.::ig iiivJ. Workers are
already protected under existing Federal
Guidance for occupational radiation
exposures. Finally, the impacts that will
occur prior to completion of remedial
actions are sufficiency srr;,ll thst we do
not believe special interim standards are
justified.
B. The Standards for Control of Tailings
Piles
1. Lcr.gev::-/ of the Control. Some
commenters expressed the view that the
proposed requirement that stabilization
and cor.tro! last for at least 1000 years is
unreasonable because events cannot be
predicted over this period of time with
sufficient certainty. They recommended
a period of no more than 100 £0 200
years, and that active institutional care.
such as access control and periodic
maintenance, be permitted. Other
commenters recommended that the
. longevity required should be greater
«an 1000 years, and expressed the view
at a requirement for longevity of up to
10.000 years is practical.
We consider the single most important
goal cf control to be effective isolation
and stabilization of tailings for as long a
period of time as is reasonably feasible.
because tailings will remain hazardous
for hundreds of thousands of years. The
longevity of tailings control is governed
chiefly by the possibilty of intrusion by
man and erosion by natural forces.
Reasonable assurance of avoiding
casual intrusion by man can be provided
through (he use of relatively thick and/
or dilficult-to-penetrate covers (such as
soil. rock, or soil-cement). No standard
can guarantee absolute protection
againsHhe purposeful works of man.
and these standards do not require such
protection. Protection against natural
forces requires consideration of wind
and surface water erosion, and of the
possibility of flood damage. Wind and
surface water erosion are relatively
well-understood and predictable, and
are easily inhibited through the use of
rock or. in some cases, vegetative
surface stabilization. Similarly, a body
of scientific and engineering knowledge
exists to predict the frequency and
magnitude of floods for periods of many
hundreds of years, and to provide the
engirtppring controls to pro'.eU against
such floods (including the possibility of
moving a pile if this is more
economical). We considered longevity
requirements ranging from 100 to 10.000
years and have concluded that existing
knowledge permits the design of control
systems for these tailings that have a
good expectation of lasting at least for
periods of 1000 years. We recognize that
it may not always be practical, however.
to project such performance with a high
degree of certainty, because of limited
engineering experience with such long
time periods.
We know no historical examples of
societies successfully maintaining active
cars of decentralized materials through
public institutions for periods ex;«*cmg
to many hundreds or thousands of years.
We have concluded that primary
reliance on passive rr.sa?;;:es is
preferable, since their long-term
performance can be projected with more
assurance thjn that of measures which
rely on institutions and continued
expenditures for active maintenance.
Section 104 of the Act requires the
Federal Government to acquire and
retain control of these tailings disposal
sites under licenses issued by the
Nuclear Regulatory Commission (NRC).
The NRC is authorized to require
performance of any maintenance.
monitoring, and emergency measures
that are needed to protect public health
•and safety. As long as the Federal
Government exercises its ownership
rights and other authorities regarding
these sites, they should not he
systematically exploited by people or
severely degraded by natural forces.
We believe that these institutional
provisions are essential to support any
project whose objectives is as long term
as are these disposal operations, and for
which we have as little experience. This
does not mean that we believe primary
reliance should be placed on
institutional controls: rather, that
institutional oversight is an essential
backup to passive control. We note, in
this regard, that the remedial actions
required by these standards would not
make it safe to build habitable
structures on the disposal sites. Federal
ownership of the sites is assumed to
preclude such inappropriate uses.
In the final standards we hava
modified the requirement for longevity
of control so as to assure that it is
practical for agencies to certify that the
standards are implemented in all cases.
We recognize that this is a remedial
action program, that these sites were not
chosen with long-term drsposal in mind
and that our ability to predict the
longevity of engineered designs is not
always ciiic^udit to the task at hand.
The proposed standard required a
longevity of control of at least 1000
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598
Federal Register / Vol 48. No. 3 / Wednesday. January 5, 1963 / Rules and Regulations
year*. The finaJ standard require* that
control measures be carried out in a
manner that provides reasonable
assurance that they will last, to the
extent reasonably achievable, op to 1600
yean and. In any case, for a minimum of
200 years. The widely varying
characteristica of the inactive sites, the
uncertainties involved in projecting
performance of control measures over
long periods of time, and the large costs
involved in moving some tailings piles to
provide a very high degree of assurance
of longevity make this change
appropriate. (We estimate op to SO
million dollars might be unnecessarily
spent to move piles under the proposed
requirement for a longevity of at least
1000 years.) The change does not signify
ihflt thp^e 'ifi; circumstance* under
•which the term of protection
contemplated by the proposed
standards is not appropriate. The
change merely acknowledges that
implementing agencies may in some
cases have difficulty certifying that
control measures that are appropriate
can reasonably be expected to endure
without degradation for 1000 yean.
Man's ability to predict the future is
notoriously limited. That fact which on
the one hand warrants our "P^ing
responsible societal efforts to limit risk
to future generations, also warrants our
refraining from actions undertaken
merely in the name of necessarily
artificial levels of statistical certainty.
We selected this period of period of'
performance because we believe there is
a reasonable expectation that readily
achievable controls will remain effective
for at least this period. However, we
recognize that uncertainties increase
significantly beyond a thousand years.
and we conclude it would be
unreasonable to require that assurance
be provided that the controls will be
effective for periods of up to 10.000
yean.
2. The Radon Release Limit Some
commenters expressed the view that the
proposed radon emission standard of 2
pCi/mH from the surface of a tailings
pile was either unreasonably low or
unnecessary'. Others suggested that
proper consideration of cosU and
benefits would lead to a higher
standard, in the range of 40-100
pCi/mV Some urged that the standards
for radon be expressed as a limit on
ambient air concentration at the site
boundary, rather than as an emission
limit. Others were concerned that the
proposed level could not be reliably
implemented, since H i» dose to
background levels. Finally, many argued
thai radon emitted from tailings piles
does not constitute a significant health
hazard because it cannot be
distinguished from background radon
levels a short distance from a tailings
pile (i.e., k-fc mile), and that, therefore.
there is no need for • radon emission
standard.
We believe that limiting radon
emissions from tailings piles serves
several necessary functions: reducing
the risk to nearby individuals and
individuals at greater distances: and
furthering the goals of reliable long-term
deterrence of misuse of tailings by man
and control of erosion of piles by natural
processes. The degree of reduction of
radon emissions achieved by a disposal
system is more or less directly related lo
the degree of abatement of each of these
hazards.
Our analysis predicts significant risk
to people living next to tailings piles.
and field measurements confirm
elevated levels of radon in air close to
the piles. If radon emissions are not
.reduced, we estimate that individuals
residing permanently near some of the
piles could incur as much as three to
four chances in a hundred of a fatal lung
cancer in addition to normal
expectations. The fact that increases in
radon levels due to the piles cannot be
distinguished relative to background
levels furthnr away from a pile does not
mean that radon is not present or that
there is no increased risk from this
radon—it merely means that
measurements are not capable of
unambiguously detecting such levels.
Limiting radon release, therefore, not
only benefits the nearby individual, but
also reduces the adverse affects of
radon well beyond the immediate
vicinity of the site.
Radon emission was selected as the
preferred quantity to be specified by the
standard because, unlike ambient air
concentration at the site boundary, it is'
directly related to the degree of radon
control achieved. A site boundary
standard would not necessarily require
any cpntrol of radon emissions (since
the boundary might be moved arbitrarily
far from the pile), and. in any case,
compliance would depend on
indefinitely excluding public access
across the boundary.
We have concluded that a limit on a
radon emission is the most direct and
appropriate means for furthering the
Congressional objective of adequate and
reliable long-term control of tailings.
Such a limit assures a sufficient earthen
cover (or its equivalent) to provide an
acceptable degree of stabilization and
isolation of the tailings over a long
period of time. Congress did not intend
that EPA set standards {or one
generation only, or that rt set standards
without consideration of the long-term
reliability of whatever means are
available for implementing them.
(Similarly. Congress anticipated that
short-term institutional controls would
not provide the primary basis for
protection.) Although the implementing
agencies will decide which specific
controls to employ, this does not
preclude our considering, in accordance
with Congress' directive, the effect of a
particular choice of a numerical limit on
the maintenance of future control.
Therefore, in selecting the value for
radon emissions, an important
consideration was that the standee**
promote the objectives of adequate
isolation and stabilization to control
both intrusion by man and erosion by
natural forces.
We have reevaluated the costs and
benefits of alternative standards and
have revised the radon emission
standard to 20 pCi/raS. in part because
we concluded that the incremental
benefits of the proposed standards are
not justified by the increased costs, and
in part because recent results of teats of
coven indicate that a 2 pG/m*s
standard may be more difficult to
achieve than we originally believed. The
specific alternatives we analyzed are
described in detail in the FEIS. They
ranged from controlling emissions to 2
pCi/m's to providing only a minimal
cover that we estimate would, on the
average, reduce total radon emissions
by half (to final values ranging from 40
pCi/raJ» to 500 pCi/m*s, depending upon
the site.) Estimated disposal costs for
these options (excluding DOE overhead
and the cost of moving piles) range from
50 to 195 million dollars. The costs for
the revised standard of 20 pCi/m's were
• estimated as 95 million dollars; this is
approximately 45 million dollar* less
than for the proposed standard.
We have concluded that this revised
standard will provide excellent
protection of public health, safety, and
the environment. Control measures
designed to meet this standard will
prevent misuse and protect piles from
erosion by providing adequate isolation
of tailings. The standard provides more
than 96% of the reduction of the
potential for lung cancer from radon
emissions provided by the proposed
standard. Under the revised emission
limit, the excess risk to the most
exposed individual would be reduced to
a few chances in a thousand. In •
addition, it provides this protection at a
substantial cost reduction compared to
the originally proposed standard
(including the modification of the
longevity requirement, the combined
saving is approximately 95 million
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Federal Register / Vol. 48, No. 3 / Wednesday. January 5. 1983 / Rules and Regulations
599
dollars). The revised emission limit
should also be high enough to remove
any concern associated with confusing
radon from tailings with radon emitted
from normal toils (typically up to 1
pCi/mS), and can be readily achieved
through the use of a wider variety of
earthen materials than the proposed
standards.
We conclude from our analysis that a
higher emission standard, such as 100
pCi/m's, would not achieve the above
objectives to an acceptable degree. It
would result in a five times greater risk
to individuals living near a tailings pile
and a similar increase in the impact
from radon emissions on local regional
and national populations (to 20% of the
total risk from uncontrolled piles). The
control measures required to meet such
a less restrictive standard would
provide significantly less isolation
against intrusion and protection against
erosion. The further cost reduction
compared to the final standard would be
relatively small (approximately 20
million dollars).
The Department of Energy, in the
course of the consultations that Section
206 of the Act requires before we
promulgate final standards, expressed
its strong preference for an ambient air
concentration standard rather than an
emission standard. Therefore, through
calculations described in the FE1S. we
determined an alternative standard
expressed as a radon concentration at
the edge of the tailings that we believe
would require basically the same level
of control as the 20pCi/mJs emission
standard Applying a concentration
standard .at the edge of the tailings
resolves our concerns about applying it
at a site boundary. A limit applied at a
site boundary would permit varying
effectiveness of cover, depending on the
choice of location of the boundary, and
compliance would depend on indefinite
maintenance of the boundary. However.
a radon concentration standard at any
position that is defined in terms of its
relation to ',. tailings has a fixed
relationship .o radon releases and
compliance does not depend on
institutional maintenance of a fence.
Calculations can be used to estimate
the values of the annual average radon
concentrations at various distances from
tailings piles with a given emission rate.
Considering the uncertainties in such
calculations, we are confident that
designing control systems to keep tb»
maximum annual average radon
concentration at the edges of the tailings
below 0.5 pCi/1 will provide
approximately the same overall health
protection as designing them for an
average emission rate of 20 pCi/m's.
Under either form of the radon limit the
radon concentration due to a pile will be
well below the background level at any
residence near the disposal site. The
final standard contains both forms of
radon limit, as approximately equivalent
alternatives.
3. Avoiding Contamination of Water.
Commenters expressed concern that the
proposed requirements for protection of
water are unnecessarily restrictive, are
impractical or too costly to implement
or incorporate numerical values that had
not been adequately justified. Some
argued that water protection should be
handled on a site-specific basis, that
genera] standards were not necessary.
and that water quality standards were
not an appropriate basis for these
regulations. Other comments expressed
the opposite view that the proposed
standards did not provide sufficient
protection, that already degraded
ground water should be cleaned up. or
that numerical values should be
included for additional toxic elements.
We have carefully reviewed available
data on contamination of ground water
at the designated sites. Studies of these
sites are not yet conclusive, but they
provide little evidence of recent
movement of contaminants into ground
water, and there is some evidence that
the geochemica) setting may inhibit
contaminants from entering usable
ground water at two sites where there
might otherwise be a problem (Salt Lake
City and Canonsburg). The proposed
standards might be difficult to
implement at certain sites because our
ability to perform definitive hydrological
assessments is limited. That is. .they
could lead to decisions to use very
expensive control methods, such as
moving piles to new sites and installing
liners, even though no substantial threat
to ground water is demonstrated We
also believe that minor degradation of
ground water may be acceptable, such
as for water of already inadequate
quality for existing or probable uses, or
for very small aquifers.
Finally, we agree that there is
uncertainty associated with the
appropriateness of both the toxic
elements selected and the numerical
values specified in the proposed
standards, which were drawn mainly
from existing national water quality
standards for surface water and public
drinking water supplies.
In summary, although a few sites
appear to have some existing ground
water contamination, probably due to
dewatering of process liquids from the
tailings, we believe there is a low
probability of additional contamination
at most of the sites. The remedial
program should provide for adequate
hydrological and geochemical surveys of
each site as a basis for determining
whether specific water protection or
cleanup measures should be applied
Whether or not it is feasible or practical
to restore an aquifer and to what degree
will depend on site-specific factors.
including the aquifer's hydrogeologic
setting, the cost, the present and future
value of the aquifer as a water resource.
the availability of alternative supplies.
and the degree to which human
exposure is likely to occur.
We do not believe that the existing
evidence indicates that ground water
contamination from inactive mill tailings
is or will be a matter of regulatory
concern. We have decided, therefore,
not to establish general substantive
standards on this subject. Should
evidence be found that shows that this
judgment is in error, we will consider
the need for further rulemaking
procedures.
A possible alternative to the above
course of action is for us to establish a
general regulatory mechanism for others
to use in deciding, on a site-specific
basis, whether a ground water problem
exists and if so. what remedial action is
appropriate. Such a nonsubstantive, or
procedural mechanism would resemble
that established by our regulations
implementing the Solid Waste Disposal
Act. as amended (47 FR 32274. July 26.
1982). in this connection, the Uranium
Mill Tailings Radiation Control Act
reflects the desire of Congress (in
Section 206) that CPA's standards be
consistent to the maximum extent
practicable, with the Solid Waste
Disposal Act It also requires NRC to
concur in DOE's remedial actions at
each site (in Section 106) and to issue
licenses for these sites (in Section 104)
that may encompass any ". . .
monitoring, maintenance, or emergency
measures necessary to protect public
health and safety." These functions are
consistent with those embodied in EPA's
above-referenced regulations. We have
decided not to adopt this alternative.
because we believe,that the devising of
any necessary such mechanisms for
application under this Act can more
appropriately be left to the NRC and
DOE.
If any existing contamination or
potential for future ground water
contamination is present we have
provided therefore, in the
implementation section of these
standards, that judgments on the
possible need for monitoring or remedial
actions should be guided by relevant
considerations described in EPA's
hazardous waste management system.
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600 Federal Register / Vol. 46. No. 3 / Wednesday, January 5, 1983 / Rules and Regulations
and by relevant State and Federal
Water Quality Criteria for existing and
anticipated uses of the aquifer.
Decisions to undertake remediation
should consider the costs and benefits of
possible remedial and control measures,
including the extent and usefulness of
the aquifer. We have also concluded
that the same approach is appropriate to
surface water, which should be
adequately protected in any case by any
control measures meeting the standards
for longevity and radon emission.
C. The Standards for Cleanup of
Tailings
1. Radium-226 in Soil. Comments
•bout the cleanup standard for radium-
226 in soil dealt primarily with the
proposed numerical value of the
standard and perceived difficulty of
measurement to show confonnance.
Many comments expressed the view
that there was no justification for a
standard as low as 5 pCi/g and that a
higher value would be most cost-
effective. Recommended values ranged
from 10-30 pCi/g.
The purpose of this standard is to
limit the risk from inhalation of radon
decay products in houses built on land
-.ontaminated with tailings, and to limit
^amma radiation exposure of people
using contaminated land. We estimate
that each increase of 0.01 WL inside a
bouse increases the risk of lung cancer
to each of its inhabitants by something
like one-half to one in a hundred, for an
assumed lifetime of residency. The
infiltration of radon in soil gas directly
into a house is by far the largest
contributor to indoor radon, and we
estimate that soil extensively
contaminated at a level of 5 pCi/g
radium can readily lead to indoor levels
of radon decay products of 0.02 WL
Because the risks from soils
contaminated with radium-226 are
potentially so great, the proposed
standard was set at a level as close to
background as we believed reasonable.
taking into consideration the difficulties
in measuring this level and
distinguishing it from natural
backgound. N
We have examined the costs and
benefits of alternative standards ranging
from S to 30 pCi/g. These are described
in detail in the FE1S. Total cleanup costs
are less than 10* to 20^ of the total
costs of disposal of tailings piles for all
the alternatives consid'-'ed. Costs for
cleanup of Mir>dbiown to:i;r.gj f:orr. land
•rfaces are sensitive to the standard.
cause the area to be cleaned up varies
app:u\irr.:-.:e]y inversely with the limit
selected. Costs for removal of buried
tailings are not sensitive to the standard.
since the amount to be removed vanes
only slightly with the limit selected
That is. we concluded most buried
tailings would be removed under any of
the alternatives considered. We also
considered the difficulty of measuring
various thicknesses of surface
contamination, and in identifying and
measuring contamination due to buried
tailings. Detection of buried tailings
could be difficult. However, buried
tailings, as opposed to surface
contaimination (usually windblown and
diluted with soil), can be effectively
located using a higher detection limit
than the proposed standard of 5 pCi/g.
Based on these analyses, we have
modified the standard for surface
contamination of soil (5 pCi/g) from an
average over the top 5 cm of soil to an
average over the top 15 cm of soil; and
revised the standard for subsurface
contamination from 5 pCi/g to 15 pCi/g
(still averaged over any 15 on layer of
•oil). We believe these standards will
result in essentially the same degree of
cleanup, and will be simpler to
implement.
For tailings transported by man to off-
lite properties, the hazard varies with
the amount of tailings involved and their
location. The proposed standard did not
provide for exemption of locations
posing a low hazard. The final standard
requires cleanup of contamination only
when the amount and location of
tailings poses a clear present or future
hazard, and provides criteria to assist
this determination. We estimate that
perhaps more than half of the identified
locations of such contamination do not
present a hazard sufficient to warrant
cleanup, at an estimated saving of 24
million dollars.
Some comments expressed the view
that measuring radium-226 and •
distinguishing residual radioactive
materials from natural background at
the levels proposed would be difficult
and costly, and that many samples
would have to be collected and
analyzed to show compliance with the
standards. The changes we have made
make determination of compliance with
the standard easier and less costly. In
addition, we have provided guidance in
this Notice and the FEUS on
implementation of the standards, to
clarify our intent that unnecessarily
stringent (and costly) verification that
the standards have been achieved
should be avoided.
2. Radon Decay Products in Buildings.
Some comments expressed the view that
the proposed indoor radon decay
product standard of 0.015 WL would be
difficult and costly to implement,
because it is within the upper range of
levels that commonly occur in houses
due to natural causes. For example, it
might be necessary to distinguish'
whether the standard is exceeded
because of the presence of tailings or
because of anomalies in the natural
background. This could result in costly
and unnecessary remedial actions, or in
the frequent use of an exceptions
procedure. These comments
recommended that we raise this
standard to a more cost-effective value
that can be more pssily dis'.inc'ji'bp^
from natural!) -or -.urring ler • !•.
We have considered these arguments
and re-examined the costs and benefits
of alternative standards. We used the
data from the Grand Junction, Colorado,
remedial program for contaminated
buildings to assist this evaluation.
Reduction of radon decay products in
existing buildings is probably the most
cost-effective of all types of remedial
actions for tailings, because the high risk
associated with indoor radon decay
products. Based on these evaluations.
the standard has been revised upward
only slightly so as to facilitate
implementation and to more closely
conform to other related standards.
Under the final standard the objective of
remedial actions is to achieve an rncoor
radon decay product concentration of
0.02 WL. For circumstances where
remedial action has been performed and
it would be unreasonably di.T.cu!: ar.d
costly to reduce the level below 0.03
WL, the remedial action may be
terminated at this level without a
specific finding of the need for an
exception. However, we have also
•ought to avoid excessive costs by
encouraging the use of active meaborrs,
(such as heat exchangers, air cleaners.
and sealants) to meet the objective of
0.02 WL when further removal of tailings
to achieve levels below 0.03 WL is
impractical. We believe the final
standard deals adequately with
complications introduced by the
presence of any high concentration of
naturally-occurring radinnuclides. and
avoids unnecessary and costly remedial
actions that produce only marginal
improvements.
D. Reducing Regulatory Burdens.
Some commenters suggested that the
proposed standards should be flexible to
take account of unusual circumstances.
site-specific factors, and any
complications due to high natural
background levels. These corr.mer.'.ers
recommended that this be accomplished
by raising the numerical limits.
establishing different standards for
unusual circumstances, or by expressing
the standards as a range of values
We agree that it is appf-r>r..- .«• and
de«irable to take into account, ee far as
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Federal Register / Vol. 4& No. 3 / Wednesday, January 5. 1983 / Rule* and Regulations 601
practical, different circumstance*. In
addition, we believe that regulation*
should be easy to carry out and not
contain unnecessary procedural
requirements. We have encouraged the
implementing agencies to do this in our
"Guidance for Implementation" as
described below. We have also changed
the procedures for situation* in which It
' would be unreasonable to satisfy th»
standards from an "exceptions" process
to one in which the implementing
agencies apply "Supplemental
Standards." This is also described
below. Finally, the numerical limits of
some of the standards have been raised:
this will assure that they ore more
readily distinguishable from background
levels.
IV. Implementation.
The Act requires the Secretary of.
Energy to select and perform the
remedial action* needed to implement
these standards, with the full
participation of any State that share*
the cost with the concurrence of the
Nuclear Regulatory Commission, and in
consultation, when appropriate, with
affected Indian tribes and the Secretary
of the Interior.
The cost of remedial action will b«
borne by the Federal Government and
the States a* prescribed by the Act
Control and stabilization remedial
activities are large scale undertaking*
for which there it relatively littla
experience. Although preliminary
engineering assessment* have been
performed, specific engineering
requirements and costs to meet the
standards at each site have yet to be
determined. We believe control and
stabilization costs (including DOE
overhead) averaging about 10-12 million
(1981] dollars per tailings pile are most
likely. For some sites, this cost may.be
partly offset by recovered land values or
through provisions of the Act for
recovery of uranium or other mineral*
through reprocessing the tailings prior to
performing remedial action*.
A. Guidance for Implementation
Conditions at the Inactive processing
sites vary greatly, and engineering
experience with some of the required
remedial actions Is limited. It is our
objective that implementation of these
standards be consistent with the
assumptions we haw made in deriving
them. We are therefore providing
"Guidance for Implementation" to avoid
needless expense which may result from
uncertainty or confusion as to what
level of protection the standards are
intended to achieve.
The standard for control and
stabilization of tailings piles is primarily
intended as a design standard.
Implementation will require • Judgment
that tha method chosen provides a
reasonable expectation that the
provisions of the standard will be met
to the extent reasonably achievable, for
op to 1000 yean. and. in any case, for at
least 200 yean. This judgment will
necessarily be based on site-specific
analyses of the properties of die site*.
candidate control systems, and the
potential effect* of natural processes
over time, and. therefore, the measure*
required to satisfy the standard will
vary from site to site. We expect that
computational models, theories, and
expert judgment will be the major tools
in deciding that a proposed control
system will adequately satisfy the
standard. Pout-remediation monitoring
will not be required to show compliance.
but may serve a useful role in
determining whether the anticipated
performance of the control system ia
achieved.
The purpose of our cleanup standard*
is to provide the main'mnm reasonable
protection of public health and the
environment Costa incurred by remedial
action* should-be directed toward this
• purpose. We intend the standards to be
implemented using search and
verification procedures whose cost and
technical requirement* are reasonable.
For example, since we intend the
cleanup standards for building* to
protect people, measurements in such
locations as small crawl spaces and
furnace rooms may often be
inappropriate. Remedial action
decisions should be based oo radiation
level* in the part* of buildings where
people spend substantial amounts of
time. The standards for cleanup of land
are designed to limit the exposure of
people to gamma radiation, and to limit
the level of radon decay product* in
buildings that might later be built on the
land. In most circumstances, no
significant barm would be caused by not
cleaning up small areas of land
contaminated by tailings. Similarly, it
would be unreasonable to require
expensive detailed proof that all the
tailings below the surface of open land*
had been removed. Procedures that
provide a reasonable assurance of
compliance with the standard* will be
adequate. Where measurements ere
necessary to determine compliance with
the cleanup standards, they should be
performed within the accuracy of
presently available field and laboratory
measurement capabilities and in
conjunction with reasonable survey and
sampling procedures designed to
mmtmm the cost of verification. We are
confident that DOE and NRC, tat
consultation with EPA and the States,
will adopt implementation procedure*
consistent with our intent in establishing
these standards.
B. Supplemental Standards
The varied condition* at the
designated cites and limited experience
with remedial actions make it
appropriate that EPA allow adjustment
of the standards where circumstance*
require. We believe that in moat esses,
our final standards an adequately
protective and can be implemented at
reasonable cost However, the
standard* could be too strict in some
applications. We anticipate that Tudi
circumstances might occur. We
originally proposed to deal with this
through an "exceptions" procedure
which would relax standards when
certain criteria were satisfied. We agree
with the comments, however, that the
proposed procedure was unnecessarily
burdensome to apply.
In the final regulations we have
eliminated this procedure and replaced
it with a simplified procedure for
applying "supplemental standards."
This is a more effective mean* of
accomplishing our original purpose. An
additional significant change in the
proposed criteria for exceptions is the
addition of criterion 192.21(c). which
relaxes the requirement for cleanup of
land at off-site locations when residual
radioactive materials are not clearly
hazardous and cleanup costs are
unreasonably high. This category of
contamination was not adequately
addressed in the proposal*.
Regulatory Impact Analysis
Under Executive Order 12291. EPA
must judge whether a regulation is
"Major" and therefore subject to the
requirement of a Regulatory Impact
Analysis. That order requires such an
analysis if the regulations would result
in (1) an annual effect on the economy
of $100 million or more: (2) a major
increase in costs or prices for
consumer*, individual industries.
Federal. State, or local government
agencies or geographic regions; or (3)
significant adverse effects on
competition, employment investment,
productivity, innovation, or oo the
ability of United States-based •
enterprises to compete with foreign-
based enterprises in domestic or export
markets.
This regulation is not Major, because
we expect the costs of the remedial
action program in any calendar year to
be lew than 9100 million: States bear
only 10% of the*e costs and there are no
anticipated major effects on costs or
prices for other* and we anticipate no
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602 Federal Register / Vol. 4& No. 8 /Wednesday. January S. 1983 / Rules and Regulations
significant advene effect! oa domestic
or foreign competition, employment.
Investment productivity, or innovation.
The cost* of these standards an
discussed in the FEIS.
This regulation was submitted to the
Office of Management and Budget for
review as required by Executive Order
12291.
This regulation will not have a
significant effect on a substantial
number of small entities, as specified
under Section 60S of the Regulatory
Flexibility Act, because there are no
small entities subject to this regulation.
D«te± December IS. 1M2.
Ana* M. Crornidt
Admir.ittrator.
List of Subjects ia 40 CFB Part 192
Environmental protection; Radiation
protection: Uranium.
In 40 CFR Chapter L Part 182 is
revised to read as follows:
PART 192— HEALTH AND
ENVIRONMENTAL PROTECTION
STANDARDS FOR URANIUM MILL
TAIUNGS
Subpart A— Standards for the Control of
RttJduaf Radtoectrve MatertaH from
Inactive Uranium Processing SitM
be.
1Q2JO Applicability.
192.01 Definition*.
1?7 Vt Standard*.
Subpart B— Standards for Cteanup of Land
and Buildings Contaminated wttn Residual
•tadloactrve Usterlal* from Inactive
Uranium Processing Sttn
192.10 Applicability. "
192.11 Definition*.
1BZ.12 Standards. ' *
Subpart C— Implementation
IB? 70 Guidance for implementation,
182-21 Criteria for applying supplemental
standard*.
192-22 Supplement*] standard*.
lK.tt Effective date.
Authority. Section 275 of the Atomic
Energy Act of 1954. 42 U.S.C 2022. ai added
by the Uranium Mill Tailing! lUdiation
Control Act of 1978. Pub. L B&-004.
Subpart A— Standards for the Control
of Residual Radioactive Materials from
Inactive Uranium Processing Sites
Appficabany
This subpart appUes to the control of
residual radioactive material at
designated processing or depository
sites under Section 106 of the Uranium
Mill Tailings Radiation Control Act of
1978 (henceforth designated "the Act").
and to restoration of such sites following
any use of subsurface minerals under
Section 104(h) of the Act
Dtflnmona •
(a) Unless otherwise indicated in this
subpart. all terms shall have the same
meaning as in Title I of the Act
(b) Remedial action means any action
performed under Section 108 of the Act
(c) Control means any remedial action
intended to stabilize, inhib.it future
misuse of. or reduce emissions or
effluents from residual radioactive
materials.
(d) Disposal lite means the region
within the smallest perimeter of residual
radioactive material (excluding cover
materials] following completion of
control activities.
(e) Depository site means a disposal
site (other than a processing site)
selected under Section 104(bj or lOSfbJ
of the Act
(f) Curie (G) means the amount of
radioactive material that produces 37
billion nuclear transformation per
second. One picocurie (pCI) • 10 ~"CA.
|10Z03 Standards
Control shall be designed4 UK
(a) Be effective for up to one thousand
years, to the extent reasonably
achievable, and, in any case, for at least
200 years, and,
(b] Provide reasonable assurance that
releases of radon-222 from residual
radioactive material to the atmosphere
will not
(1) Exceed an average 'release rate of
20 picocuries per square meter per
second, or
(2) Increase the annual average
concentration of radon-222 in air at or
above any location outside the disposal
site by more than one-half pioocurie per
liter. •
Subpart B—Standards for Cleanup of
Land and Buildings Contaminated wrth
Residual Radioactive Materials from
Inactive Uranium Processing Sites
{192.10 AppflcaMlrty
This subpart applies to land and
buildings that are part of any processing
site designated by the Secretary of
Energy under Section 102 of the Act
Section 101 of the Act states, in part
that "processing site" means—
(a) Any site, including the mill
containing residual radioactive
•Baciuit tht (UacUrd tpplin to deiigo.
Bo&iionoi tflir diipouJ » not required to
ojcnoiutnl* compliuio*.
'Thii iver*gr •hill ipply over the entire lurfic*
at utt ditpoMj lilt and ovv «t Utd • oacvw
p*hod lUdoo will ooot (TOO both mldual
ndkxcbvt nitenali and from mtltndi covering
Uir-?< Radon •nuutont from the covering matcnaJj
•hould b* Httmiitd »• p*n of developing i
rcmvdit! »etion p!in for etch me The ittnderd.
however. tppliM only to •auuioni from r*udu*l
ndjot.cn** utsrUii to tht •Bnacphcr*.
materials at which all or substantially
all of the uranium was produced for sale
to any Federal agency prior to January 1.
1071. under a contract with any Federal
agency, except in the case of a site at or
near Slide Rock, Colorado, unless—
(1) Such site was owned or controlled
as of Januray 1,1078, or is thereafter
owned or controlled, by any Federal
agency, or
(2) A license (issued by the (Nuclear
Regulatory) Commission or its
predecessor agency under the Atomic
Energy Act of 195-1 c: by a Sidle as
permitted under Section 274 of such Act)
for the production at site of any uranium
or thorium product derived from ores is
in effect on January 1,197ft. or is issued
or rer.ewed after »ucb date; and
(b) Any other real property or
improvement thereon which—
(1) Is in the vicinity of such site, and
(2) Is determined by the Secretary, in
consultation with the Commission, to be
contaminated with residual radioactive
materials derived from such site.
1102.11 OetVDttona
(a) Unless otherwise indicated in this
subpart all terms shall have the same
meaning as defined in Title I of the Act
or in Subpart A.
(b) "Land" means any surface or
subsurface land that is not part of a
disposal site and is not covered by an
occupiable building.
(c) "Working Level" fWL) means any
combination of short-lived radon decay
products in one liter of air that will
result in the ultimate emission of alpha
particles with a total energy of 130
billion electron volts.
(d) "Soil" means all unconsob'dated
materials normally found on or near the
surface of the earth including, but not
limited to, silts, clays, sands, gravel, and
small rocks.
{192.12 Standards
Remedial actions shall be conducted
•o as to provide reasonable assurance
that as a result of residual radioactive
materials from any designated •
processing site:
(a) The concentration of radium-226 in
land averaged over any area of 100
square meters shall not exceed the
background level by more than—
(1) 5 pCi/g. averaged over the first 15
cm of soil below the surface, and
(2) 15 pCi/g. averaged over 15 cm
thick layers of soil more than 15 cm
.below the surface.
(b) In any occupied or habitable
building—
(1) The ob|ective of remedial action
shall be. and reasonable effort shall be
made to achieve, an annual average (or
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Federal Register / Vol. 48. No. 3 / Wednesday. January 5. 1933 / Rules and Regulations
603
equivalent) radon decay product
concentration (including background)
not to exceed 0.02 WL in any case, the
radon decay product concentration
(including background) shall not exceed
0.03 WL. and
(2) The level of gamma radiation shall
not exceed the background level by
more than 20 microroentgens per hour.
Subpart C—Implementation
$ 192.20 Guidance for Implementation
Section 108 of the Act requires the
Secretary of Energy to select and
perform remedial actions with the
concurrence of the Nuclear Regulatory
Commission and the full participation of
any State that pays part of the cost, and
in r.rnsnltation. as appropriate, with
o/fnclud /r.dian Tribes and the Secretary
of the Interior. These parlies, in their
respective roles under Section 108, are
referred to hereafter as "the
implementing agencies." The
implementing agencies shall establish
methods and procedures to provide
"reasonable assurance" that the
provisions of Subparts A and B are
satisfied. This should be done as
appropriate through use of analytic
models and site-specific analyses, in the
case of Subpart A. and for Subpart B
through measurements performed within
the accuracy of currently available
types of field and laboratory
instruments in conjunction with
reasonable survey and sampling
procedures. These methods and
procedures may be varied to suit
conditions at specific sites. In particular:
(a)(l) The purpose of Subpart A is to
provide for long-term stabilization and
isolation in order to inhibit misuse and .
spreading of residual radioactive
materials, control releases of radon to
air, and protect water. Subpart A may
be implemented through analysis of the
physical properties of the site and the
control system and projection of the
effects of natural processes over time.
Events and processes that could
significantly effect the average radon
release rate from the entire disposal site
should be considered. Phenomena that
are localized or temporary, such as local
cracking or burrowing of rodents, need
to be taken into account only if their .
cumulative effect would be significant in
determining compliance with the -.... • . \
standard. Computational models. • -~ :> '
theories, and prevalent expert judgment.
- may be used to decide that a control
system design will satisfy the standard.
The numerical range provided in the
standard for the longevity of the "'•'•'
effectiveness of the control of residual
radioactive materials allows for
consideration of the various factors
affecting the longevity of control and
stabilization methods and their costs.
These factors have different levels of
predictability and may vary for the
different sites.
(2) Protection of water should be
considered in the analysis for
reasonable assurance of compliance
with the provisions of $ 192.02.
Protection of water should be
considered on a case-specific basis,
drawing on hydro'ogical and
geochemical surveys and all other
relevant data. The hydrologic and
geologic assessment to be conducted at
each site should include a monitoring
program sufficient to establish
background ground water quality
through one or more uppradient wells,
and identify the presence and movement
of plumes associated with the tailings
piles. «
(3) If contaminants have been
released from a tailings pile, an
assessment of the location of the
contaminants and the rate and direction
of movement of contaminated ground
water, as well as its relative
contamination, should be made. In
addition, the assessment should identify
the attenuative capacity of the
unsaturated and saturated zone to
determine the extent of plume
movement Judgments on the possible
need for remedial or protective actions
for groundwater aquifers should be
guided by relevant considerations -
described in EPA's hazardous waste
management system (47 FR 32274, July
26.1982) and by relevant State and
Federal Water Quality Criteria for
anticipated or existing uses of water
over the term of the stabilization. The
decision on whether to institute
remedial action, what specific action to
take, and to what levels an aquifer
should be protected or restored should
be made on a case-by-case basis taking
into account such factors as technical
feasibility of improving the aquifer in its
- hydrogeologic setting, the cost of
applicable restorative or protective
programs, the present and future value
of the aquifer as a water resource, the
availability of alternative water
supplies, and the degree to which human
exposure is likely to occur. .
(b)(l) Compliance with Subpart B, to
the extent practical, should be -
demonstrated through radiation surveys.
Such surveys may, if appropriate, be ,....
restricted to locations likely to contain
residual radioactive materials. These
surveys should be designed to provide
for compliance averaged over limited
areas rather than point-by-point
compliance with the standards. In most
cases, measurement of gamma radiation
exposure rates above and below the'
land surface can be used to show
compliance with fi 192.12(a). Protocols
for making such measurements should
be based on realistic radium
distributions near the surface rather'
than extremes rarely encountered.
(2) In 5 192.12(a). "background level"
refers to the native radium •
concentration in soil. Since this may not
be determinable in the presence of
contamination by residual radioactive
materials, a surrogate "background
level" may be established by simple
direct or indirect (e.g.. garr.^-; radiation)
measurements performed nearby but
outside of the contaminated location.
(3) Compliance with J I92.12(b) may
be demonstrated by methods that the
Department of Energy has approved for
use under Pub. L 92-314 (10 CFR 712). or
by other methods that the implementing
agencies determine are adequate.
Residual radioactive materials should
be removed from buildings exceeding
0.03 WL so that future replacement
buildings will not pose a hazard [unless
removal is not practical—see
§ 192.21(c)]. However, sealants,
filtration, and ventilation devices may
provide reasonable assurance of
reductions from 0.03 WL to below 0.02
WL In unusual cases, indoor radiation
may exceed the levels specified in
$ 192.12(b) due to sources other than
residual radioactive materials. Remedial
actions are not required in order to
comply with the standard when there is
reasonable assurance that residual
radioactive materials are not the cause
of such an excess.
§ 192.21 Criteria for applying
supplemental standards
The implementing agencies may (and
in the case of Subsection (f) shall) apply
standards under § 192.22 in lieu of the
standards of Subparts A or B if they
determine that any of the following
circumstances exists:
(a) Remedial actions required to
satisfy Subparts A or B would pose a
clear and present risk of injury to
workers or to members of the public,
notwithstanding reasonable measures to
avoid or reduce risk. ~
(b) Remedial actions to satisfy the
cleanup standards for land. § 192.12(a)."
or the acquisition of minimum materials '•
required for control to satisfy •
. $ 192.02(b). would, notwithstanding ..'..'.
reasonable measures to limit damage,
directly produce environmental harm
that is clearly excessive compared to the
health benefits to persons living on or
near the site, now or in the future. A
clear excess of environmental harm is
harm that is long-term, manifest, and
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604 Federal Register / Vol. 46. No. 3 / Wednesday. January 5. 1983 / Rules and Regulations
groasly diiproportionate to health
benefit* that may reasonably be
anticipated.
(c) The estimated cost of remedial
action to satisfy { 192.12(a) at •
"vicinity" tite (described under Sec.
101(6)(B) of the Act) is unreasonably
high relative to the long-term benefits.
and the residual radioactive materials
do not pose a clear present or future
hazard. The likelihood that buildings
will be erected or that people will spend
long periods of time at such a vicinity -
lite should be considered in evaluating
this hazard. Kemedial action will
generally not be necessary where
residual radioactive materials have been
placed semi-permanently in a location
where site-specific factors limit their
hazard and from which (hey are costly
or difficult to remove, or where onJy
minor quantities of residual radioactive
materials are involved. Examples are
residual radioactive materials under
bard surface public roads and
. sidewalks, around public sewer lines, or
in fence post foundations. Supplemental
standards should not be applied at such
aites. however, if individuals are likely
to be exposed for long periods of time to
radiation from such materials at level*
above those that would prevail under
1192.12(a),
(d) The cost of a remedial action for
cleanup of • building under | 192.12{b)
it clearly unreasonably high relative to
the benefits. Factors that should b«
included in this judgment are the
anticipated period of occupancy, the-
incremental radiation level that would
be affected by the remedial action, the
residual useful lifetime of the building.
the potential for future construction at
the site, and the applicability of lew
costly remedial methods than removal
of residual radioactive materials.
(e) There is nc known remedial action.
(f) Radionuclides other than radium-
226 and its decay products are present
in sufficient quantity and concentration
to constitute a significant radiation
hazard from residual radioactive
materials.
1192.22 Supplemental standards
Federal agencies implementing
Subparts A and B may in lieu thereof
proceed pursuant to this section with
respect to generic or individual
situation! meeting the eligibility
requirements of f 19Z21.
(a) When one or more of the criteria of
{ I92.21(a) through (e) applies, the
implementing agencies shall select and
perform remedial actions that come as
dose to meeting the otherwise
applicable standard as is reasonable
under the circumstance*.
(b) When 1102.21 (f) applies, remedial
actions shall, in addition to satisfying
the standards of Subpart* A and B,
reduce other residual radioactivity to
levels that are as low as is reasonably
achievable.
(c) The implementing agencies may
maJce general determinations concerning
remedial actions under this Section that
will apply to all locations with specified
characteristics, or they may make a
determination for a specific location.
When remedial actions are proposed
under this Section for a apecfwlocation.
the Department of Energy snail inform
any private owners and occupants of the
affected location and solicit their
comments. The Department of Energy
shall provide any such comments to the
other implementing agencies. The
Department of Energy shall also
periodically inform the Environmental
Protection Agency of both general and
individual determinations under the
provisions of this section.
I19&23 Effective date
Subparts A, B. and C shall be effective
March 7.1963.
IF* Doc S3-4SU& IM«d U-JD-C. 1OM «a)
SMJJMG COOC Um Si •
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
T Applicability of Secondary Standards to the Nontclair/West Orange and
Glen Ridge Radon Sites r\ . \i/~"
scv Allan C.B. Richardson, Chief Mtt-A'V1'0
Guides and Criteria Branch (AJiR-460)
TC William J. Librizzi, Director
Emergency and Remedial Response Divisiy
THRU: Richard J. Guimond, Director
Criteria and Standards Divisi
This is in response to Johfc Czapor's request for clarification of the
intent of the secondary standards in EPA's regulations under DMTRCA. In
general, these provisions are not anticipated to be uaed often, and were
provided for remote unpopulated areas, for situations in which safety was
involved (such as steep cliffs and ravines), or for situations in which
the materials do not pose a clear present or future hazard and improve-
ments could be achieved only at unreasonably high coat.
Your memorandum statea that "It is clear to us that [leaving
contaminated material in the community] must be included in the
feasibility study." If this conclusion is based upon the secondary
standards, it is not a correct interpretation and we do not believe such
alternatives should be included in the study. In the residential area
involved, it is difficult to envision that any of the qualifying criteria
under 192.21(a-e) would apply. Criteria (a) and (b) clearly do not apply,
since safety or excessive long term environmental harm from the cleanup is
not at issue. Criterion (c) does not apply since the residual materials
would pose a future hazard, since the area will clearly be occupied. Even
in the case of material "...under hard aurface public roads and sidewalks,
around public sewer lines, or in fence post foundations," in the wet
climate of New Jersey and the residential setting involved the danger to
groundwater would appear to preclude leaving any aubstantial quantity of
radium-bearing materials in excess of the standards of 192.12(a).
Criterion (d) applies only to cleanup of buildings to meet the standards
for indoor air in 192.12(b), and not to cleanup of contaminated land to
aatisfy the soil standards in 192.12(a). Finally, criterion (e) does not
apply, since removal is clearly possible.
Regarding the suggestion involving use of deed restrictions, the
discussion of the proper role of institutional controls in the attached
Federal Register notice of similar standards for uranium tailings at
NRC-licensed sites best characterizes Agency policy (pp. 45935-6). Note
that the timeframe contemplated by these standards is thousands of years,
and primary reliance on institutional controls, such as deed restrictions,
is not provided for by these standards.
.. J-7«>
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Thus, at a maximum, use of the secondary standard might be examined
for cases of small quantities of material under public roads or sidewalks
(and associated sewer lines).
Your related question regarding such sites as Barrows Field should be
covered by the above discussion. In short, the 5/15 criteria do need to
be implemented, since there is no basis for an exemption.
I hope the above clarifies the meaning of the secondary standard. If
not, please contact me at (703) 557-8927.
Attachment
cc: I/John V. Ctapor, Region II
Paul Ciardina, legion II
Mike Hard is (ANR-461)
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Federal Register / Vol. 48.-No. 196 / Friday. October 7. 1983 / Rules and Regulations 4593S
atmosphere." (H.R. Rep. No. 1480.95th
Cong.. 2nd Sess.. RII. p. 25.) We have
concluded that maximum individual
lifetime risk (estimated as 2 in 100) and
the long-term cumulative impact on
populations (potentially many tens of
thousands of deaths over the long term)
due to radon emissions from tailings an
dearly significant enough to justify
controls. As discussed in the FEIS, R1A.
and a later section of this Preamble, our
analysis shows that tailings can. at •
reasonable cost, be disposed of in a
manner that provides, among other
benefits, greatly reduced radon
emission*.
S. Standards Based on Current
Population* .
During the review of the standards for
the inactive sites by certain Federal
agencies, questions were raised
regarding the appropriatenes* of the -
control standards for.general
application to all 24 inactive sites. Some
reviewer* suggested that leu restrictive
standards might be appropriate for sites
that are in currently sparsely-populated
areas. Other reviewers suggested that
we consider a radon standard that
applies at and beyond the fenced
boundary of such a site. le.. a standard
that relies in part on dispersion and
institutional maintenance of control over
access. EPA requested public comments
on these issues for the inactive sites (48
FR 605. January 5.1983). These issues
are moat simply stated as: (1) Should the
degree of radon control after disposal
depend in part on the size of the current
local population, and (2) Should
implementation of the disposal
standards be permitted to depend
primarily or in part on maintenance of
institutional control of access (e.g.. by
fences)? We also specifically requested
comment* on these issue* in the April
29.1983 notice of proposed rulemaking
for active mill«.
Most commenters who addressed the
first of these issues opposed different
standards at remote sites (although most
industry comments favored less
restrictive standards for all sites). Many
raised the "equity" consideration, i.e.,
the fairness of protecting a few people
less just because of where they live.
Others commented that many of these
sites are locations where people are
unlikely to live. or. conversely, that the
sizes of populations in the future are not
predictable and cited examples of recent
changes. Finally, commenten who
addressed the issue of whether EPA I*
authorized to set different standards
based on "remoteness" denied that the
Agency has such authority.
In 1983 EPA counted the number of
people living close to all the active and
Inactive mill sites. Of the 52 site*
surveyed, only 7 had no people living
within 5 kilometer* (3 miles). Another 0
•ites had 10 or fewer people living
within 5 kilometer*. Collectively,
, however, the mill sites have • normally .
distributed continuous range of local
population*, and it I* not possible to
distinguish a special set of sites. The
definition of a remote site is therefore
difficult to achieve, unless it i* done
arbitrarily. In addition, demographer*
have concluded that it is not possible to
determine that a population at • specific
location will remain low in the future, if
it i* low now. Therefore, • choice of two
different standards implies • need for
institutional oversight of future
population shift* and for having to
upgrade the disposal at those sites that
exceed some criterion of "remotene**."
Presumably, the State or Federal,
custodian would be responsible, not the
original owner.
The motivation for considering
relaxed standards at "remote" «ites is to
reduce the cost of disposal. Our analysis
•hows that any potential cost saving
from less restrictive standards at such
sites i* not commensurate with the loss
of benefit*. In a later section we report
the costs for several relaxed radon
standards. These results show, for the
case of no radon emission limit (case .
Cl) and with no provision for the added
cost* of institutional control through
fencing, land-use control, and land
acquisition (to avoid unacceptably high
Individual doses 10 nearby residents),
and with no provision for increased
costs to meet closure requirement*
under SWDA (discussed below), that 46
percent of the cost of disposal at the
level required by these standards (case
C3] would be potentially recoverable.
We have examined the added costs
required for institutional control and
conclude that they may vary from about
10 to 50 percent of these potentially
recoverable costs, depending mostly on
the cost of land acquisition at specific
•ites. Costs for conformanca to RCRA
closure requirements for a cap under
I 284.228(a)(2)(iii)(E) range from about
50 to 140 percent of these potentially
recoverable costs, depending upon
whether or not the pile has an
impermeable liner under it or not. (This
SVVDA requirement was excepted under
the proposed standards, on the basis
that it would interfere with the moisture
required for radon control. This basis
would no longer exist in the absence of
a radon limit.) Any savings through
deletion of radon control would be
achieved by forgoing approximately
one-half of the annual benefit (the entire
impact on nooregional national
populations), a considerable degree of
protection against misuse, and a
significant fart of the anticipated total
term of effective protection from all
hazards, due to the greatly reduced
thickness of the cover. We have
concluded, therefore, independent of
other considerations, that when coat* for
Institutional control and compliance
with SWDA closure are added and the
net saving is applied to only those site*
that might be defined as "remote", the
potential total cost saved is not
significant enough in comparison to the
benefits foregone to justify separate
standards.
Finally, with regard to the Agency's
legal authorization to establish a
separate level of protection at remote
sites by issuing two sets of standards,
UMTRCA clearly contemplates that
these standards be adequate for the long
term and that they achieve the benefits
of radon control. Regarding those
objectives, we are aware of no site that
is uninhabited and can also reasonably
be assumed will remain uninhabited.
nor are we aware of any scientific basis
for concluding that there is no impact on
national populations due to radon
emissions from remote sites. We '
conclude, therefore, that relaxed
standards for "remote'.' sites are not
feasible on demographic grounds, are
not defensible on legal grounds, and are
not attractive, in any case, on the basis
of cost-effectively achieving the various
public health and environmental goals
of this rulemaking.
4. Passive vs. Institutional Controls
A* noted above, EPA also requested
comments on whether a radon limit
applied at the boundary ("fenceline") of
the Government-owned property around
• tailings pilej.e, a "dispersion"
standard, would be an appropriate form
of standard for the sites with low nearby
population*. (Such consideration could
also apply to some more populated
•ites.) Such a dispersion standard could
be satisfied largely by institutional
method*. Le.. by acquiring and
maintaining control over land. The
proposed disposal standard, by
comparison, would require generally
more costly physical methods (such as
applying thick earthen covers) that
directly control the tailings and their
emissions with minimal reliance on
institutional methods (i.e.. it i* a
"control" standard). EPA also requested
comments on the adequacy of such a
radon "fenceline" standard to meet the
objectives of the UMTRCA.
Comments on this issue ranged from
strong support of primary reliance on
passive stabilization for periods greater
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ATTACHMENT 2
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Auguat 24. 1981
NUMBER 6050.8
Department of Defense Directive
SUBJECT: Storage and Disposal of Non-DoD-Ovned Hazardous or Toxic
Materials on DoD Installations
References:
(a) Deputy Secretary of Defence memorandum, "Storage
•ad Disposal of Hazardous and Toxic Materials on
Department of Defense Installation," January 10,
1980 (hereby canceled)
(b) Public Law 96-510, "Comprehensive Environmental
Responses, Compensation and Liability Act of 1980"
(c) Federal Standard 313A, "Material Safety Data
Sheets," June 4, 1976, as amended
(d) DoD Directive 9025.1, "Use of Military Resource*
During Peacetime Civil Emergencies Within the
United States, its Territories, and Possessions,."
Hay 23, 1980
A. PURPOSE
Thir Directive establishes DOD policy, enunciated by reference
(a), for the storage or disposal of non-DoD-ovned toxic or hazardous
materials on DoD installations.
B. APPLICABILITY
N
The provisions of this Directive apply to the Office of the
Secretary of Defense, the Military Departments, the Organization of
the Joint Chiefs of Staffs, «nd the Defense Agencies (hereafter
referred to as "DoD Components").
C. DEFIMITIOHS
Hazardous or To«ic Materials. Those materials defined in sec-
tion 101 of reference (b), (reference (c)), or that are of an explo-
sive, flammable, or pyrotechnic nature.
D. POLICY
1. It is the policy of the Department of Defense not to permit
the use of DoD installations for the storage or the disposal of
aon-DoD-ovned toxic or hazardous materials. The storage, disposal,
transportation, and rendering safe of non-DoD-ovned hazardous or
toxic material reported or discovered in areas outside of DoD instal-
lations are primarily the responsibilities of civil authorities.
2. This policy, however, does not apply to:
-------
a. Agreements with the General Services Administration for the storage
of strategic and critical materials in the National Stockpile Program.
b. Agreements or arrangements between DoD Components and other federal
agencies on the temporary storage of disposal of explosives, except fireworks,
as necessary, to protect the public, or to assist those responsible for federal
law enforcement in storing or disposing of explosives when 00 alternative
solutions are available.
c. Emergency lifesaving assistance to civil authorities on the tempo;
rary storage or disposal of explosives, except fireworks. ~*
d. Those excess explosives generated under an existing DoD contract
yfaefi ibs head of the DoD Component concerned determines, on a case-by-case
basis, that no alternative, feasible disposal means are available to the
contractor. Beads of DoD Components shall consider public safety, available
contractor resources, and national defense production requirements when weighing
rJ»is option.
e. Arrangements with the Department of Energy for the temporary
storage of nuclear materials or nonnuclear classified materials.
f. Military resources used during peacetime civil emergencies, in
•accordance with DoD Directive 3025.1 (reference (d)).
g. Assistance and refuge'for commercial carriers with material of
other federal agencies during the transportation emergencies.
3. The Assistant Secretary of Defense (Manpower, Reserve Affairs, and
Logistics) (ASD(MKML)) may grant exceptions to the policy stated in subsection
D.2. when such action is essential to protect the health and safety of the
public from imminent danger, when the ASD(MRA&L) otherwise determines it to
be essential, and when such assistance does not compete with private enterprise.
Such support generally shall be on reimbursable cost basis. In the case of
imminent danger, the use of DoD facilities for the storage of non-DoD-owned
toxic or hazardous materials shall be temporary and shall cease once the
emergency situation no longer exists. In all other cases, the assistance
•hall be terminated as determined by the ASDCMRA&L).
E. RESPONSIBILITIES
Heads of DoD Components shall;
2. Ordinarily deny requests for use of DoD installations to store or
dispose of non-DoD-owned toxic or hazardous materials, except as described in
subsection D.2., above. Support under subsection D.2. shall be on a reim-
bursable cost basis, unless expressly authorized to the contrary.
2. Forward requests for exceptions to the ASD(MRA&L) for decision. Excep-
tion requests shall include, as a minimum, a discussion of alternative solu-
tions, an explanation of essentiality, any appropriate environmental documeft-
tation, and an estimate of the impact of the planned action upon DoD resources.
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Aug 24, 81
6050.8
3. Ensure that safe and environmentally sound procedures are followed to
protect DoD personnel and property when a decision has been made to store or
dispose of non-DoD-owned toxic or hazardous materials on DoD installations.
4. Make certain that any non-DoD authority that uses DoD property for the
storage or disposal of toxic or hazardous material obtains all necessary
permits and meets appropriate financial requirements.
.5. Ensure that the non-DoD storer or disposer prepares any required
environmental documentation prior to using DoD property, and returns the
facility to its original condition.
F. EFFECTIVE DATE AND IMPLEMENTATION
This Directive is effective immediately. Forward two copies of' imple-
menting documents to the Assistant Secretary of Defense (Manpower, Reserve
Affairs, and Logistics) within 120 days.
Deputy Secretary of Defense
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ATTACHMENT 3
-------
U.S. DEPARTMENT OF ENERGY
*;i*a. HMO • •
SUBJECT Policy c-. "anagc'e-rt of TRU and Low-Level Waste Gf'C
TO H. E. Roser,.Marker, Albuquerque Operations Office
R. H. Ba-er, Mar.-Ter, Chicago Operations Office
C. E. Ui'liams, "=rager, Idaho Operations Office
M, E. Gates, Mani:er, Nevada Operations Office
R. J. Hart, r:an::-:-r. Oak Ridge Operations Office
fc. G. Fre-.ling, ."sncser, Richland Operations Office
J. B. L^-'c.ne, Vs.-.cger, San Francisco Operations Office
R. L. Nortan, f'a.-sgsr. Savannah River Operations Office
Admiral r. 3. Ric-:over, Deputy Assistant Secretary
for :iav*l Reactors, NE-40
Eased on recent ir;uiries to this office, I believe that a statement of
policy or. the acccrtance of DOE and commercial TRU and LLW may be helpful
to you. Tne'foll:.vino guidance does not apply-to nuclear material-desig-
nated as scrap ir, accordance with procedures established by the Division
of Materials Premising. However, any waste arising from activities with
this material wcu's be managed as DOE waste in accordance with the
followinr guidance:
SCE Waste- (SOCC ar.o GOGO Facilities)
o All CCE TRU v.dr.'.c and LLW should te managed on-site unless such action
is inc^-patibli <.ith long-range site plans.
o All DOE LLW generated on a site which does not have an approved LLW dis-
posal facility should be sent to a DOE site which has such a facility.
Specific directions were issued in the ASNE TWX's to Field Office
Managers, date: October 26, 1979 and November 19, 1979 (copies attached).
o All DOE TRU waste generated on a site which does not have an approved
retrievable st:-aae facility should be sent to a DOE site which has such
a facility, nrra'igesents should be rrade between the appropriate fi^d
officei. The --:-ceiving office should provide waste acceptance critefic
and psckaginc rerjirerr.ents. Field offices called upon to provide t.iis
service shoula r.ork closely with the waste generators to expedite
completion of arrangements.
Csrrercial V.'aste
o Oorr-.erc-ial LL'..' irould not be accepted at DOE sites. There are three
active licensee disposal sites for corr?ercial wastes (Beatty, Nevaaa;
Richlend, Washington; and Barnwell, South Carolina).
o Cowrercial TRU waste should not be accepted at DOE sites. Due to the
recent change ir the operating license for the Richland, Wasnington
LLW disposal site, waste with greater than 10 nCi/ctn of TRJ
-------
material is no longer accepted. NRC is working, with comnercial TRL1 waste
generators and the States to provide for licensed interim storage to
resolve the immediate issue for the waste generators. When-a Federal
repository becomes operational, we expect to have authority to accept
for disposal all TRU waste NRC may identify as requiring such isolation.
General Ccr-ents
o In sone cases it may be unclear whether certain waste should be con-
sidered "DOE Waste" or "Commercial Waste", and managed as described atove.
For LL!/, the appropriate field office may make this determination; for
TRU waste, however, DOE's response to a request to accept it will be
coordinated by the Division of Waste Products. This latter action is
being taken because of the significant policy issues involved.
- The continuation of an R&D activity may require assurance of a safe
•storage or disposal site. In such cases DOE may have authority under
Section 3! of the Atomic Energy Act to accept the waste for storage
and disposal.
•
- If the waste is generated in connection with a DOE contract, DOE nay
have the legal authority and financial responsibility for its storage
or disposal. The contract terms shojld be helpful in answering these
questions.
o Retrievable storage facilities for TRU v/aste are located at Hanford, NTS,
INEL, LASL, ORNL, SRP, and the Pantex Plant. We know cf no plans for
establishing additional DOE TRU storage facilities, and do not encourage
such actions.
o The draft report entitled "Executive Summary of an Analysis of a Nuclear
Regulatory'Commission Suggestion on Use of DOE Sites for Commercial
Low-Level Wastes" is a reply to a specific request from the NRC and does
not change our policy. (A copy of the 4/10/80 draft is included as
Attachment 3.)
o You are encouraged to continue to work with DOE waste generators to
' assure efficient and safe management of DOE waste.
o You are also 'encouraged to continue keeping the appropriate State
agencies fully informed so that any misunderstandings^re avoided.
3 Attachments
cc: J. Vreeland, GC-32
- •/(
el don Meyers
Deputy Assistant Secretary
for Nuclear Waste Management
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Department of Energy EPA-RECe II
Richland Operat.ons CW.ce OFFICE D" EKIHG.'!^/ C-.
P.O. BOX 550 REMZ5.::.L :::::';;"<*
Richland. Washington 99352
EKOCT 12 PK 3--kS
OCT 5 J984 ^.lr.C:u, 5C;.-,-!:.
Mr. William J. Librizri, Director
Emegency & Remedial Response Division
Environmental Protection Agency
Region 11
26 redt?ral Plaza
New York, New York 10278
Dear Mr. Librizzi:
DISPOSAL OF RADIUM CONTAMINATED SOILS'AT HANFORD
In response to your September 21, 1984, letter to me on the above subject,
we have reviewed the Department of Energy (DOE) policy with regard to the
management of such wastes, the current policy clearly states that commercial
low level waste "(LLW) should not be accepted at DOE sites and that only DOE
LLW generated on a DOE site which does not have an approved LLW disposal
facility should be sent to a DOE site which has a facility. The policy further
lists the three active licensed disposal sites for commercial wastes (Beatty,
Nevada; Richland, Washington; and Barnwell, South Carolina).
In view of this policy, we are not able to consider your request to dispose
of the radium contaminated soils at Hanford.
"Any further questions may be directed to Mr. G. T. Orton, FTS 444-6622.
Very truly yours,
f
Gfad
/r /
frOerry D. White, Director
WMD:GTO Waste Management Division
cc: J. E. Dieckhoner, DOE-HQ/DP-122
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ATTACHMENT 4
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
HEW YORK. NEW YORK 1O27S
John B. Baublitx, Director
Division of Remedial Action
Programs (NE-24)
O.S, Department of Energy
Washington, D.C. 20585
Dear Mr. Baublitz:
This is to confirm the substance of a conversation on September 17
with a member of my staff, Joyce Feldman, In which you discussed
the possibility of using a site owned by the Department of Energy
(DOB) for the disposal of soils from properties in three Hew Jersey
communities. The soils are believed to be the residues of a
local radium extraction Industry which operated during the early*
part of this century. The residues are contributing to unacceptably
high indoor radon levels in about eighty residences in those
communities.
The O.S. Environmental Protection Agency (EPA) is funding an emer-
gency response action under the authority of the Comprehensive
Environmental Response, Compensation and Liability Act (CBRCLA,
or 'Superfund'). Part of that response Involves removal of the
residues from around the properties in an effort to reduce the
radon levels. The BPA is attempting to locate a suitable repository
for these radium-contaminated materials.
»
The specific site discussed was in Canonsburg, Pennsylvania, a
property which was itself contaminated by a uranian extraction
operation. Even though the Canonsburg site is now a permanent
repository for those residues, an agreement between DOB and the
State and local authorities precludes addition of any other
materials to those present from the actual operations of the
original company. As discussed, an environmental impact statement
developed for activity at this site did not address the possibility
of co-location of other materials: The local community had required
a defined scope and a limit to the extent of the project. Any
attempt to add materials to those already there would delay remedial
activities now underway and would undermine the relationship of
trust which DOB has developed with the local community.
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-2-
Zn a separate conversation with E. L. Keller of the DOB'a Oak Ridge
Operations Office, Ms. Peldman also discussed DOE properties in
Middlesex, New Jersey and Oak Ridge, Tennessee. .Bach of these
locations, according to Mr. Keller, is'not available for disposal
or storage of materials:
• In the case of the Middlesex property, there is an existing
agreement between the DOB and the State and local authorities
under which no additional soils froa other locations may be
added to those froa the Middlesex sites. (If a copy of this
agreement is available, please forward it for our records.)
BPA appreciates the need to honor existing agreements and,
therefore, would not request the use of a property with those
restrictions.
- In the case of the Oak Ridge Reservation, the DOB is committed
to the management of the property to meet its own mission needs.
Disposal of waste on the reservation must meet those mission
needs.
If there are.any DOE sites which may possibly be available for
the use I have described, I would appreciate that information as
soon an possible, since the operation is considered an emergency
removal action.
Tour cooperation in this effort is appreciated.
Sincerely yours,
William J. Librizzi, Director
Baergency ft Remedial Response Division
cc: B. L. Keller
Oak Ridge Operations Office
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O27B
David LaClaire, Director
Defense Nuclear Waste and By-Product
Management Group
U.S. Department of Energy
Washington, DC 20545
Dear Mr. LaClaire:
This is to confirm oar telephone conversation on October 3,
1984 in which we discussed the rationale for a Departaent of
Energy (DOB) policy limiting acceptance of radioactive ore
processing residues, planned to be removed by the U.S. Environ-
mental Protection Agency (BPA), at DOB facilities.
Radioactive .soils in three New Jersey communities are believed
to be the residues of a local radium extraction industry which
operated during the early part of this century. The residues
are contributing to unacceptably high indoor radon levels in
about eighty residences in those communities. BPA is funding
an emergency response action under the authority of the Compre-
hensive Environmental Response, Compensation and Liability Act
(CBRCLA, or *6uperfund*). Part of that response involves removal
of the residues from around the properties in an effort to reduce
• the radon levels. • The Agency must now locate a suitable repository
for these radium-contaminated materials.
The substance of our discussion involved the following points:
DOB cannot accept waste materials not generated by DOB
facilities. This would present unfair competition to commercial
waste disposal facilities.
The Low-Level Radioactive Waste Disposal Act of 1980
mandated that States form compacts to locate and developx«aste
disposal facilities within each region. It was intended that
these facilities would accept wastes such as the residues
described here. By allowing the use of a Federal facility for
disposal of the residues, the DOE would be providing a tacit
approval of any delay in the siting of an appropriate facility
by a regional compact.
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-2-
There are sites for the storage of no similar materials
from DOE remedial actions in New Jersey which are awaiting
disposal. Hie Middlesex, MJ facility slight be considered as a
possible site for locating these Materials. The site is owned
by the Federal government; however, a DOB/State/ local agreement
presently precludes addition of materials to those stored there
now. A new agreement would need to be negotiated.
Finally, it is DOB policy that no non-DOB or -DOD
generated wastes will be accommodated at any DOB facility.
While this policy could conceivably be altered, that change in
stance is not now viewed as a likely possibility.
Z wish to thank you for your time and for sharing your views
with me. Please let me know as soon as possible if there is
any change in the policies outlined above.
Sincerely yo'urs,
William J. Libritri, Director
Emergency ft Remedial Response Division
cc: S. Ruhrtz, NJDBP
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK NEW YORK 1OZ7B
James E. Dieckhoner
Defense Nuclear Haste and By-product
Management Group
OS Department of Energy
Washington, DC 20S45
Dear Mr. Dieckhoner:
This is to confirm our telephone conversation on October 3,
1984 in which we discussed the rationale for • Department of
Energy (DOB) policy limiting acceptance of radioactive ore
processing residues, planned to be removed by the O.S. Environ-
mental Protection Agency (EPA), at DOE facilities.
Radioactive soils in three New Jersey communities are believed
to be the residues of a local radium extraction industry which
operated during the early part of this century. The residues
•re contributing to unacceptably high Indoor radon levels in
•bout eighty residences in those communities. EPA is funding
•n emergency response action under the authority of the Compre-
hensive Environmental Response, Compensation and Liability Act
(CERCLA, or "Superfund"). Part of that response involves removal
of the residues from around the properties in an effort to reduce
the radon levels. The Agency must now locate • suitable repository
for these radium-contaminated materials.
The substance of our discussion involved the following points:
It is the DOE interpretation of the Atomic Energy Act
that-the Department has authority to dispose of only DDE-
generated waste under that law; other Federal government agencies
must ship any regulated wastes to commercial disposal facilities.
Under an agreement with the Department of Defense (DOD), on an
emergency basis, certain wastes may by transferred to a DOE
facility for disposal.
DOE policy now avoids the situation in which commercial
waste disposal facilities are pre-empted in their business oppor-
tunities by the activities of a segment of the Federal government.
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-2-
DOE is concerned that by accepting too much watte from
other Federal organizations, the Nuclear Regulatory Commission
(NRG), which develops and enforces regulations for handling of
radioactive materials under the Atomic Energy Act, may be forced
into a position of developing new regulations covering DOE
facilities. This would lead to an extensive revision of other
DOE policies and procedures.
Zn order for DOE to accept quantities of BPA-generated
waste, it would be necessary for DOE to develop a Federal
Register Notice to establish a fee for the service"! This would
require a considerable effort and resource commitment.
A State in which DOE has repository space may well object
to the accommodation of BPA-generated wastes on the basis of .
the fact that it is losing the fees which would be received by
use of a co-located commercial facility; further, the State
would lose control over the manner of'disposal of the soils.
I wish to thank you for your time and responsiveness on this matter,
If there is any change in DOE policy on this question, I would
appreciate your notifying me promptly.
Sincerely yours.
William J. Librixzi, Director
Emergency t Remedial Response Division
cc: S. Kuhrtz, HJDBP
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G LOSS ARY
ACRO NVMS
-------
GLOSSARY
Alpha Particle: A positively charged particle consisting of two protons
and two neutrons, identical with the nucleus of the helium atom; emitted
by several radioactive substances.
Ambient: The enviroment surrounding a flying aircraft or other body but
undisturbed or unaffected by it, as in ambient temperature or ambient
air.
Anomaly: A local derivation from the general geological properties of a
region.
Attenuate: To weaken a signal by reducing its level.
Beta Particle: An electron or positron emitted from a nucleus during beta
decay.
Capping: The process of sealing or covering one type of material by
another type of material.
Catalyst: Substance that alters the velocity of a chemical reaction and
may be recovered essentially unaltered in form and amount at the end of
the reaction.
Conglomerate: A sedimentary rock a significant fraction of which is
composed of rounded pebbles and boulders; the lithified equivalent of
gravel.
Culvert: A covered channel or a large-diameter pipe that takes a
watercourse below ground level.
De minimis: A standard setting the minimum value to be regulated.
Density: The mass of a given substance per unit volume.
Dip: The angle between the unit of interest (e.g., sedimentary layer) and
a horizontal plane, as measured perpendicular to the strike.
Downhold Gamma Log: Vertical record of gamma activities along depth of
borehole.
Electrode: One of the terminals used in dielectric heating for applying
the electric field to the material being heated.
Emanation: A radioactive gas given off by certain radioactive elements;
all of these gases are isotopes of the element radon. Also known as
radioactive emanation.
-------
GLOSSARY (continued)
Embarkation: The loading of materials into ships or aircraft.
Encapsulate: To surround, encase, or enclose as if in a capsule.
Fault: A fracture in rock along which there has been an observable amount
of displacement.
Flocculating Agent: A reagent added to a dispersion of solids in a liquid
to bring together the fine particles to form floes. Also known as
flocculant.
French Drain: An underground passage of water, consisting of loose stones
covered with earth.
Gamma Radiation: Radiation of gamma rays.
Gamma Ray: A high-energy photon, especially as emitted by a nucleus in a
transition between two energy levels.
Glacial Drift: All rock material in transport by glacial ice, and all
deposits predominantly of glacial origin made in the sea or in bodies of
glacial meltwater, including rocks rafted by'icebergs.
Gl aciofluvial : Pertaining to streams fed by melting glaciers, or to the
deposits and landforms produced by such streams.
Graben : A block of the earth's crust, generally with a length much greater
than its width, that has dropped relative to the blocks on either side.
Groundtruth : As used in the study, confirmation of areas of elevated gamma
activity identified from aerial survey by ground level gamma survey using
a radiation meter.
Heap Leaching: A process used for the recovery of copper from weathered
ore and material from mine dumps; material is laid to a thickness of 20
feet in alternately fine and coarse beds and treated with water at inter-
vals during which oxidation occurs; liquor that runs off is treated with
scrap iron to precipiate copper.
Horst: A block of the earth's crust uplifted along faults relative to the
rocks on either side.
Infiltration: Movement of water through the soil surfaces into the ground.
In-situ: In the original location.
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GLOSSARY (continued)
Intermontane Basin: A sedimentary basin commonly in a graben, bounded by
horsts.
lonization: A process by which a neutral atom or molecule loses or gains
electrons, thereby acquiring a net charge and becoming an ion; occurs as
the result of the dissociation of the atoms of a molecule in solution
(NaClNa+ + C1-) or of a gas in an electric field (H2-2H+).
Irradiation: The exposure of a material, object, or patient to x-rays,
gamma rays, ultraviolet rays, or other ionizing radiation.
Isopleth : A line drawn through points on a graph at which a given quantity
has the same numerical value (or occurs with the same frequency) as a
function of the two coordinate variables.
Kiln: A heated enclosure used for drying, burning or firing materials.
Leaching: The separation of dissolving out of soluble constituents from a
rock or ore body by percolation of water.
Lens : A geologic deposit that is thick in the middle and converges toward
the edges, resembling a convex lens.
Liner: Subsurface barrier across sides and bottom of disposal cell.
Moraine: Till deposited under, along, or at the terminus of a glacier.
Overburden: Loose soil, sand, or gravel that lies above the bedrock.
Palletize: To package material for convenient handling on a pallet or lift
truck.
Passive Collection System: A collection system that intercepts material in
its natural flow.
Permeability: The capacity of a porous rock, soil or sediment for
transmitting a fluid without damage to the structure of the medium.
Polymerization : The bonding of two or more monomrs to produce a polymer.
Progeny: Offspring; descendants.
Quench: The rapid cooling of a solution's temperature which is caused by
the removal of the heat source.
Radioactive Decay: The spontaneous transformation of a nuclide into one or
more different nuclides, accompanied by either the emission of particles
from the nucleus, nuclear capture or ejection of orbital electrons, or
fission. Also known as decay; nuclear spontaneous reaction; radioactive
disintegration; radioactive transformation; radioactivity.
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GLOSSARY (continued)
Radioactive Emanation: A radioactive gas given off by certain radioactive
elements; all of these gases are isotopes of the element radon. Also
known as emanation.
Radiochemistry: That area of chemistry concerned with the study of
radioactive substances.
Radioisotope : An isotope which exhibits radioactivity.
radioactive isotope; unstable isotope.
Also known as
86; all isotopes are
for mass number 222;
produced as, a gaseous
conventional name for
Radionuclide : A nuclide that exhibits radioactivity.
Radon: A chemical element, symbol Rn, atomic number
radioactive, the longest half-life being 3.82 days
it is the heaviest element of the noble-gas group,
emanation from the radioactive decay of radium. The
radon-222.
Recharge: The addition of water to an aquifer.
Rem: A unit of ionizing radiation, equal to the amount that produces the
same damage to humans as 1 roentgen of high-voltage x-rays. Derived from
roentgen equivalent man.
Roentgen: An exposure dose of gamma radiation or x-radiation such that the
electrons and positrons liberated by this radiation produce, in air, when
stopped completely; ions carrying positive and negative charges of
2.58 x 10-4 coulombs per kilogram of air. Abbreviated R (formerly r).
Also spelled rontgen.
Sarcoma: A malignant tumor arising in connective tissue and composed
principally of anaplastic cells that resemble those.of supportive
tissues.
Scintillometer : A device in which the scintillations produced in a
flourescent material by an ionizing radiation are detected and counted by
a multiplier phototube and associated circuits; used in medical and
nuclear research and in prospecting for radioactive ores. Also known as
scintillation detector: scintillation counter.
Secular Equilibrium: Radioactive equilibrium in which the parent has such
a small decay constant that there has been no appreciable change in the
quantity of parent present by the time the decay products have reached
radioactive equilibrium.
Sensitive Receptor: Members of a population considered most susceptible to
pollutants, such as nursing homes, hospitals, schools etc.
-------
GLOSSARY (continued)
Shine: Elevated radiation measured at a distance away from the source.
Sinter: To form a coherent bonded mass by heating mineral powders without
melting, similar to use in powder metallurgy.
Sludge: Any semisolid waste from a chemical process.
Slurry: A free flowing, pumpable suspension of fine solid material in
liquid.
Split Spoon: A sampling device consisting of a hollow tube which open
longitudinally to expose the sampled core.
Split Spoon Samples: Samples collected at specific depths during a
borehole installation intended to characterize the soil types present in
the strata penetrated by the borehole.
Strike: The compass direction of a horizontal linear feature or a
horizontal line in any planar feature. Used, with dip, to define the
attitude of strata, etc.
Swale: A depression created for drainage purposes.
Topographic Map: A large-scale map showing relief and man-made features of
a portion of a land surface distinguished by portrayal of position,
relation, size, shape, and elevation of the features.
Toxicology: The study of poisons, including their nature, effects,
detection and methods of treatment.
Transuranic Elements : Elements that have atomic numbers greater than 92;
all are radioactive, are products of artificial nuclear changes, and are
members of the actinide group. Also known as transuranium elements.
Unsaturated Zone: A subsurface zone containing water below atmospheric
pressure and air or gases at atmospheric pressure. Also known as vadose
zone; zone of suspended water; zone of aeration.
Vitrification: The formation of a glassy or noncrystalline material.
Working Levels : The unit of measure used to identify the concentration of
radon progeny in the air.
Working Level Months: The unit of measure used to identify a cumulative
exposure to radon per month.
(DEC45/8)
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List of Acronyms
ALARA
ANL
BEIR
CDC
CERCLA
CPM
dis/s
DOD
DOE
DOT
EIS
EPA
EPDM
FEMA
FIT
FS
FUSRAP
LLW
LSA
MEV
MPRSA
MSHA
MWH
NFSS
uR/hr
As low as reasonably achievable
Argonne National Laboratory
Biological Effects of Ionizing Radiation
Center for Disease Control
Comprehensive Environmental, Response,
Compensation and Liability Act
Counts per minute
Disintegrations per second
Department of Defense
Department of Energy
Department of Transportation
Environmental Impact Statement
Environmental Protection Agency
Ethylpropylenediene monomer
Federal Emergency Management
Administration
Field Investigation Team
Feasibility Study
Formerly Utilized Sites Remedial Action
Program
Low level waste
Low specific activity
Million electron volt
Marine Protection Research and
Sanctuaries Act
Mine Safety and Health Administration
Megawatt hours
Niagara Falls Storage Site
Microrem per hour
-------
List of Acronyms (continued)
mR/hr
NCRP
NEPA
NIOSH
NJDEP
NPL
NRC
NURE
NORM
O&M
OSHA
PH
pCi/gm
pCi/1
RCRA
RDC
RI
RPISU
TOFC
UMTRA
USGS
WL
WLM
WPA
Milirem per hour
National Council on Radiation Protection
National Environmental Protection Act
National Institute of Safety and Health
New Jersey Department of Environmental
Protection
Superfund National Priorities List
Nuclear Regulatory Commission
National Uranium Resource Evaluation
Naturally occuring radioactive material
Operation and Maintenance
Occupational Safety & Health Act
Public Health
Picocurie per gram
Picocurie per liter
Resource Conservation Recovery Act
Radon Progeny Concentration
Remedial Investigation
Radon Progeny Integrating Sampling Unit
Transfer onto flat car
Uranium Mill Tailings Remedial Action
United States Geological Survey
Working Level
Working Level Months
Works Projects Administration
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