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.

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                                                           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)

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                             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)

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                             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

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                               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

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                               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)

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                             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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                                                    ~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

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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

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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

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 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

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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

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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

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                         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

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        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

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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

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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

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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

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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

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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



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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

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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
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4.51 x 10*






"•u
^8o^°5
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88
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87
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86

At

85
Po
84
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83
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82
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tlfl min /»
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a
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3.05






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mm

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s
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z"Bi
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19. 7 mm

tlOy
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mm

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««B. 'I
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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

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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

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                                  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

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                                                          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)

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                                                        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)

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 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

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                                                 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

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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

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                                  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

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 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

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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

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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

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                         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

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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

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                                  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.
                                    1-68

-------
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
                                    1-69

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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.
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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)
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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.
                                    2-9

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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.
                                    2-10

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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.
                           2-43

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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.
                                    2-44

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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
                                    2-45

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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
                                    2-46

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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.
                                    2-47

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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.

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                    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

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                                 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
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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

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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

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      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

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 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

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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

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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

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     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

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         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

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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

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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

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.. . 650'
/- EDGE OF ASPHALT SLAB
ft
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CONTAMINATED SOIL-/

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TOP SOIL
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                                              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

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    (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

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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

-------
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»


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— ^

a
j



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OMV


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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

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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

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                          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

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              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.
                                    4-11

-------
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
                                    4-12

-------
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.
                                    4-13

-------
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.
                                    4-14

-------
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.
                                    4-15

-------
     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.

                                    4-16

-------
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.
                                    4-17

-------
     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.
                                    4-18

-------
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 .
                                    4-35

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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.
                                    4-36

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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.
                                    4-38

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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.
                                    4-39

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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.
                                    4-40

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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,
                                    4-41

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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.
                                     4-44

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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.
                                     4-45

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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
                                     4-47

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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,
                                     4-48

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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.

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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)

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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
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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

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                                 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

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                               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)

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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

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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

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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

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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

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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)

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                                   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)

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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

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                                  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.

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                                   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)

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                                 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

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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

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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)

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                                 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

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                                 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

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                          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

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                    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

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                    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

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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)

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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

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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

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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

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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

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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

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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

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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

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ATTACHMENT I

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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)

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Wednesday
January 5, 1983
Part H

Environmental
Protection  Agency
Standard* for Bemedtaf Action* at"
Inactive Uranium Processing Stta*

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 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

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 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

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           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:

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         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

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                                                     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

-------
                            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.

-------
                               -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

-------
         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.

-------
                              -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

-------
        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.

-------
                              -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

-------
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.

-------
                            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.

-------
                            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)

-------
                           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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