PB95-963807
                               EPA/ROD/R02-95/253
                               October 1995
EPA Superfund
      Record of Decision:
       U.S. Radium Corporation
       Operable Unit 2, Essex County, NJ
       8/29/1995

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               REGION II
DATE:

JECT:  Record of Decision for the U.S. Radium Corporation Site


FROM:  Kathleen C. Callahan, Director
      Emergency and Remedial Response Division

 TO:   Jeanne M. Fox
      Regional Administrator


   Attached for your approval is the Record of Decision  (ROD) for
   the U.S. Radium Corporation site.  The site is located in Essex
   County, New Jersey.

   The selected remedial action represents the second of two planned
   operable units for the site.  The ROD for the first operable
   unit, signed September 21, 1993, selected an action to address
   all of the residential properties and most of the commercial
   properties in the Vicinity and Satellite Properties study areas.
   This second action will address the High and Alden Streets study
   area (the former U.S. Radium processing plant) and the remaining
   commercial properties not addressed in the first operable unit.
   Ground water is not addressed in either this or the earlier
   decision document.  If an action is needed for the ground water,
   it will be addressed in a future decision document.

   Under the remedy outlined in the attached ROD, radium-
   contaminated material will be excavated from the affected
   properties and transported for off-site disposal.  The remedy
   will require approximately two years to fully implement at an
   estimated cost of $22 million.

   The results of the remedial investigation and feasibility study
   and the Proposed Plan for this action were released to the public
   on May 22,  1995.  The public comment period ended on June 21,
   1995.  In addition, a public meeting was held on June l,  1995.
   The comments received from local residents and officials on the
   proposed remedial action did not necessitate a modification of
   the proposed remedy.

   The ROD was developed by the U.S.  Environmental Protection Agency
   and has been reviewed by the New Jersey Department of
   Environmental Protection,  and the appropriate offices within
   Region II and Headquarters.   Their input and comments are
   reflected in this document.

   If you have any questions concerning this ROD,  I will be happy to
   discuss them at your convenience.

   Attachment

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                       DECLARATION STATEMENT

                        RECORD OF DECISION

                      U.S.  Radium  Corporation

 Site  Name  and  Location

 U.S.  Radium  Corporation, Essex  County,  New Jersey

 Statement  of Basis and Purpose

 This  decision  document presents the  selected  remedial action for
 the former radium processing plant and  four commercial properties
 that  comprise  the second operable unit  of the U.S. Radium
 Corporation  site.  The remedial action  was chosen  in accordance
 with  the Comprehensive Environmental Response, Compensation and
 Liability  Act  of 1980, as  amended by the Superfund Amendments and
 Reauthorization Act of 1986, and, to the extent practicable, the
 National Oil and Hazardous Substances Pollution Contingency Plan.
 This  decision  is based on  the administrative  record for the site.

 The State  of New Jersey concurs with the selected  remedy.

 Assessment of  the Site

 Actual or  threatened  releases of  hazardous substances from the
 U.S.  Radium  Corporation site, if  not addressed by  implementing
 the response action selected in this Record of Decision, may
 present an imminent and substantial endangerment to public
 health, welfare or the environment.

 Description  of the Remedy

 The remedy described  in this document represents the second
 operable unit  for the  U.S. Radium Corporation site.  It addresses
 the principal threats  to human health and the environment
 associated with the properties that make up the former U.S.
Radium Corporation ore-processing plant, as well as four
nonadjacent  commercial properties, and  is the final remedial
action for those properties.

A previous Record of Decision,  signed on September 21,  1993,
selected a remedy for  contaminated residential properties and the
remaining  commercial properties that comprise the U.S.  Radium
site.   Ground water has not been addressed in either this or the
earlier Record of Decision.  If an action is needed for the
ground water, it will  be addressed in a future decision document.

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                                -2-

The  major  components of the  selected  remedy  for  the  second
operable unit  include:

      Excavation/removal of the  radium-contaminated material above
      remedial  action objectives from  the designated  properties;

      Off-site  disposal  of the radium-contaminated material; and

      Appropriate  environmental  monitoring to ensure  the
      effectiveness  of the remedy.

Declarations

The  selected remedy is  protective of  human health and the
environment, complies with federal and state requirements that
are  legally applicable  or relevant and appropriate to the
remedial action,  and is cost-effective.  This remedy utilizes.
permanent  solutions and alternative treatment technologies to the
maximum extent practicable for  this site.  However, because
treatment  of the  principal threats of the site was not found to
be practicable, this remedy  does not  satisfy the statutory
preference for treatment as  a principal element.

Because this remedy will not result in hazardous substances
remaining  on the  addressed properties above levels that allow for
unlimited use and unrestricted  exposure, a five-year review of
this action will  not be required.
Jeanne M. Jf
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Christine Todd Whitman
Governor
            Department of Environmental Protection
Robert C. Shinn, Jr.
    Commissioner
      Ms. Jean M. Fox, Regional Administrator
      USEPA - Region H
      290 Broadway
      New York, NY  10007-1866
      Dear Ms. Fox:

      Subject:
US Radium Corporation Second Operable Unit
Concurrence Letter
      The Department has reviewed the draft final Record of Decision (ROD) for the subject site
      and concurs with the following remedy for the second operable unit.

                   Excavation/removal of the radium-contaminated  material above remedial
                   action objectives from the designated properties:
                   Offsite disposal of the radium-contaminated material; and
                   Appropriate  environmental  monitoring  to ensure  the effectiveness of
                   the remedy.

      As previously stated in the attached letter dated May 22,1995 the Department concurs with
      the selected remedy; however, the Department does not support the exclusion of S-1070
      (Industrial Site Recovery Act, P.L. 1993, c.139) as State ARARs (applicable, or relevant and
      appropriate requirements) for this site.

      Thanking you for the opportunity to comment and participate in the Superfund process.
                                                        Robert C. Shinn, Jr
                                                        Commissioner
      Attachment
      AS/lmj
                                                      c
                                  New Jersey is an Equal Opportunity Employer

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                                         uf
Christine Teeid Whitman            Department of Environmental Protection                Robert C Shinn, Jr,
Governor                                                                          Commission
                                        MAY 2 21995
       KB.  Katherine Callahan
       DSEPA - Region II
       290  Broadway
       New  York, NY 10007-1SCS

       Dear Ms. Callahan:

       SUBJECT:  US Radium Corporation Superfund Site Second Operable Unit
                 Proposed Plan

       The Department has reviewed the Proposed Plan of the second operable unit for the
       U.S.  Radium  Corporation site and is in  agreement with  the proposed  remedy.
       However, the Department does not support the exclusion of S-1070 (Industrial Site
       Recovery Act, P.L. 1993, c.139) as  State  "ARARs"  (applicable, or relevant and
       appropriate requirements) for this site.  The Department has decided to support
       the  preferred alternative.    In view  of  the fact that  the selected  remedy,
       excavation and off-site disposal, would achieve the Department's objective of
       cleanup to background,  since the first two feet  thickness of soil would not
       contain above background, and that  any residually contaminated material remaining
       on the remediated properties would not be greater  than two  feet  in  thickness.
      Thank you  for the opportunity to participate in the super fund  process
                                                                  iioner
                                                        ( ^
      AS:jb
                                  New Jersey is an Equal Opportunity Employer
                                          Recycled Paper

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                         DECISION SUMMARY

                   U.S. Radium Corporation site

                       Second Operable Unit
                High and Alden Streets Properties
                      and Related Properties

 SITE  NAME,  LOCATION  AND  DESCRIPTION

 The U.S.  Radium Corporation  site consists  of  three  study  areas
 located  in  several communities of Essex  County  in northeastern
 New Jersey  about 12  miles west of New  York City.  The  study  areas
 are referred  to as the High  and Alden  Streets Properties, the
 Vicinity  Properties  and  the  Satellite  Properties.

 The High  and  Alden Streets Properties  study area covers
 approximately two acres  in the City of Orange.  The Vicinity
 Properties  study area covers approximately 25 acres and includes
 about 330 properties in  Orange and in  the  Town  of West Orange.
 The Satellite Properties study area includes  approximately 50
 noncontiguous single properties or small clusters of properties
 located primarily in Orange, with a few properties  in  the
 municipalities  of East Orange and South Orange.  Figures  1,  2 and
 3 show the  locations of  the  study areas.

 The High  and  Alden Streets Properties  and  Vicinity  Properties
 study areas are  located  in a well-established,  urban residential
 neighborhood  with single- and multi-family homes, interspersed
 with  commercial  and light-industrial establishments.   The
 Satellite Properties are located in both commercial and
 residential areas of Essex County.

 wigwam Brook, which originates in the  Watchung Mountains, passes
 through the Vicinity Properties study  area and along side the
 High  and  Alden Streets Properties study area.  Ground  water
 resources within  the study areas are an unconsolidated, glacial-
 overburden aquifer, and the  deeper,  fractured-bedrock  aquifer of
 the underlying Brunswick Formation.   The majority of the drinking
 water  supplies for the towns within the study areas are drawn
 from  surface  reservoirs in northern New Jersey, although some
 deep bedrock  aquifer wells located nearby the study areas are
 used  for water supply.

 Soil and other material at certain properties within the study
 areas  are contaminated to varying degrees with radioactive waste
materials suspected to have  originated from radium processing or
utilization by the former U.S.  Radium  Corporation.

 SITE HISTORY AND  ENFORCEMENT ACTIVITIES

The U.S.  Radium Corporation,  formerly  known as the Radium
 Luminous Materials Corporation,  operated a facility at the High
 and Alden Streets Properties study area from  1915 through 1926.

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 U.S.  Radium also operated facilities  at  various  Satellite
 Properties in the early 1900s.   A primary  activity  at  the High
 and Alden Streets Properties  was the  extraction  and purification
 of radium from carnotite ore.   Because each  ton  of  ore produced
 only  a  few milligrams of radium,  large volumes of ore  were
 required.   Large quantities of  process wastes, or "tailings",
 were  generated which contained  radioactive elements at elevated
 levels.   The tailings were temporarily discarded on unused areas
 of the  facility and ultimately  disposed  of off site.

 In addition to the production and sale of  radium itself, the U.S.
 Radium  Corporation also manufactured  a radium-based luminous
 paint.  At one time,  the company employed  over 100  workers to
 paint instruments and watch dials with this  luminous paint.
 Reports indicate that dial painting took place at the  High and
 Alden Streets Properties and at several  Satellite Properties.

 U.S. Radium Corporation discontinued  radium  processing operations
 in 1926,  while continuing its dial painting  business.  U.S.
 Radium  subsequently sold its properties  at High  and Alden Streets
 in the  1940s.   No subsequent occupants of  the properties are
 known to  have processed or used radium.

 In 1979,  the U.S.  Environmental Protection Agency (EPA) and the
 New Jersey Department of Environmental Protection (NJDEP)
 initiated  a program to identify and investigate  locations within
 New Jersey where radium processing activities had taken place.
 The former U.S.  Radium Corporation facility  was  included in this
 program.   In May 1981,  EPA conducted  an  aerial gamma radiation
 survey covering approximately 12  square  miles centered on the
 High and Alden Streets Properties.  This aerial  survey located
 about 25  acres around the High  and Alden Streets Properties where
 elevated  readings of  gamma radiation  were  detected.   This 25-acre
 area corresponds to the approximate limits of the vicinity
 Properties  study area.   This same survey identified areas of
 elevated gamma radiation in the nearby communities  of  Montclair,
West Orange and Glen  Ridge; the affected properties in these
 areas comprise two other Superfund sites,  the Montclair/West
Orange Radium site and the Glen Ridge Radium site (the "MWG
 sites").

In 1982, the  site was  proposed  for inclusion on the National
Priorities  List (NPL)  of Superfund sites.  The site was placed on
the NPL in  September  1983.

Ground level  surveys  conducted  in the early  1980s showed elevated
gamma radiation and radon gas in most of the buildings on the
High and Alden  Streets  Properties.  In 1984,  NJDEP performed
preliminary  field investigations of 31 properties near the
facility.   While  these  studies  found  elevated levels of gamma
radiation at  some  properties,  NJDEP found only small pockets of

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 radium-contaminated soil,  and detected no elevated radon gas
 levels.

 Working  from U.S.  Radium Corporation documents  and other
 historical  records,  EPA and NJDEP initially  identified  22
 Satellite Properties.   Initial investigations of  some of the
 Satellite Properties in 1983 and 1986 indicated elevated levels
 of  gamma radiation,  with a few instances  of  elevated radon  gas in
 basements.   Additional  Satellite Properties  have  been identified
 through  investigations  of properties adjacent to  the first  22
 Satellite Properties, in some cases  resulting in  small  clusters
 of  properties with similar conditions.

 In  July  1983, EPA  notified five companies and one individual that
 they had been identified as potentially responsible parties
 (PRPs) for  the  site.  EPA requested  a response  outlining the
 activities  that the  PRPs would be willing to undertake.   One PRP,
 Safety Light Corporation,  a corporate successor to the  U.S.
 Radium Corporation,  responded that it was willing to perform
 response activities  at  the site.

 In  1983, EPA and Safety Light Corporation commenced the first of
 several  unsuccessful efforts to negotiate an agreement  whereby
 Safety Light would undertake response activities  at the site,
 under EPA supervision.   The last of  these efforts ended in
 December 1988 when Safety  Light declined  to  perform any work,
 other than  a removal action to replace  the inadequate security
 fence around the High and  Alden Streets Properties.  Safety Light
 began the fence construction in 1989; however,  EPA completed the
 work because of problems which arose during  the removal  action.
 No  PRPs  have agreed to  perform any additional work.

 EPA initiated a remedial investigation  and feasibility  study
 (RI/FS)  in  October 1989  to determine the  nature and extent  of
 contamination at the U.S.  Radium site.  While preliminary field
 investigations  did not  reveal  extensive radiological
 contamination beyond the limits of the  High  and Alden Streets
 study area,   EPA elected  to perform a comprehensive  investigation
 of  what  would become about 330  vicinity and  50  Satellite
 Properties  concurrent with its  studies  of  the High  and Alden
 Streets  Properties.

 EPA's investigations of  the Vicinity and  Satellite  properties
 involved a  separate field  investigation of several  hundred mostly
 residential, private properties.   By October 1992,  over  160
 investigations  had been  performed, and  63  radium-contaminated
properties had  been identified.

As part  of a second removal action begun  in  1991,  EPA installed
radon mitigation systems and gamma radiation shielding at four
properties where elevated  radiation  levels were detected early in
the RI.

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 As with many Superfund sites,  the  problems  at  the  U.S.  Radium
 Corporation site are complex.   Consequently, EPA has  organized
 the site into separate phases  or operable units.   In  October
 1992,  with the investigations  of the  former plant  site  still
 ongoing,  EPA elected to organize the  Vicinity  and  Satellite
 Properties study areas into  a  first operable unit  (OU1) ',  and to
 propose a remedy for radium-contaminated properties within those
 study  areas.   With about 160 investigations completed,  it was
 clear  that performing studies  on the  remaining 220 properties
 would  not assist EPA in better understanding the problem, and
 would  unnecessarily delay the  process of proposing a  remedy.

 A  Proposed Plan for OU1 of the U.S. Radium  Corporation  site was
 released for public comment  in April  1993,  along with a first
 RI/FS  report,  which documented the nature and  extent  of
 contamination at the Vicinity  and Satellite Properties  and
 provided a detailed evaluation of remedial  alternatives.

 After  consideration of public  comments, which  were generally
 supportive of EPA's preferred  alternative,  EPA issued a Record of
 Decision (ROD)  for the site, signed on- September 21,  1993, which
 documented the selected remedy for OU1.  The remedy for the OU1
 properties involves excavation and off-site disposal  of the
 radium-contaminated material.

 Regarding the  OU1  selected remedy, the remedial design  associated
 with the  first group of OU1  properties is currently being
 prepared.   It  is anticipated that remedial  construction
 activities at  these properties will begin in early 1996.
 Property  investigations have continued since the 1993 ROD; over
 300 property  investigations  have now  been completed.  As a
 result, the number of properties included in OU1 has  risen to
 about  75.

 HIGHLIGHTS OP  COMMUNITY PARTICIPATION

 A Community Relations Plan was developed to ensure the public
 opportunities  for  involvement  in site-related  decisions.  In
 addition,  the  Community Relations Plan was  used by EPA  to
 determine, based on community  interviews, activities to ensure
 public  involvement and to  provide opportunities for the community
 to learn  about  the site.

 EPA held  a public  meeting, conducted  a series  of public
 availability sessions and  distributed a fact sheet in February
 1991 to explain  the RI/FS  to the public and to report on the
 progress  being made at the site.  EPA held  additional public
 availability sessions in June  and November  1992, during the RI,
when the  results from field  investigations of Vicinity and
 Satellite  Properties  were  distributed to the respective property
 owners, so that  each  individual property owner would have an
 opportunity to discuss the findings with EPA.

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 For the  second  operable unit (OU2),  the subject of this document,
 a  second RI/FS  report was released  to the public in May 1995.   A
 Proposed Plan identifying EPA's preferred remedial alternative
 was released on May 22,  1995.   These documents were made
 available to the public at the  information repositories at  the
 Orange Public Library,  located  on Main Street in Orange,  New
 Jersey,  and  at  the  West Orange  Public Library located on Mount
 Pleasant Avenue in  West Orange,  New Jersey.   in addition, the
 Proposed Plan was mailed to property owners  of affected
 properties,  and a "Superfund Update" for the site was mailed to
 certain  property owners and residents in the three study areas.
 A  copy of the administrative record file is  located at the  Orange
 Public Library  and  in the EPA Superfund Records Center in Region
 II,  290  Broadway, New York,  New York.   The notice of availability
 of the Proposed Plan and administrative record was published in
 The Star-Ledger (Essex County Edition)  on May 22,  1995 and  in The
 Orange Transcript on May 25, 1995.   The public comment period
 relating to  these documents was  held from May 22,  1995 to June
 21,  1995.

 On June  1, 1995,  EPA held a public  meeting at the Orange  City
 Hal] Council Chambers,  to present the findings of the RI/FS  and
 the Proposed Plan,  and  to respond to questions and comments  from
 area residents  and  other attendees.   Responses to the comments
 received during the public comment  period are included in the
 Responsiveness  Summary,  which is  part of this ROD.

 This decision document  presents  the  selected remedial action for
 OU2 of the U.S.  Radium  Corporation  site,  chosen in accordance
 with the Comprehensive  Environmental  Response,  Compensation  and
 Liability Act (CERCLA),  as amended  by the Superfund Amendments
 and Reauthorization Act,  and, to  the  extent  practicable,  the
 National  Oil and Hazardous Substances Pollution Contingency  Plan
 (NCP).   The selection of the remedy  for this site  is based on the
 administrative  record.

 SCOPE AND ROLE  OF OPERABLE UNIT

 As described above,   the  first operable  unit  (OU1)  included all
 the residential  properties in the Satellite  and Vicinity
 Properties study areas where radium-contaminated material was
 detected.  OU1  also  included all  but  four of the nonresidential
properties in the Vicinity and Satellite  Properties  study areas.

The second operable  unit  (OU2)  includes  all  properties within the
High and Alden  Streets study area,  including the former
processing plant  and several adjacent properties.   OU2 also
 includes the four nonresidential, nonadjacent properties not
addressed in OU1.  Two of  these four  nonadjacent OU2  properties
appear to have been watch  dial painting  facilities;  a third was a
U.S. Radium-operated laboratory.  The  fourth property appears to
have been an experimental  thorium handling operation.

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 SUMMARY OF SITE CHARACTERISTICS

 The OU2 RI/FS report presents the results  of  field investigations
 conducted at the High and Alden Streets  Properties study  area  and
 the four nonresidential,  nonadjacent  properties  that  are  included
 in OU2.  The OU2 RI/FS report also discusses  investigations  of
 Wigwam Brook and ground water;  however,  the results of  EPA's
 ground water investigation are inconclusive,  and further
 evaluation will be undertaken.

 Radionuclides,  primarily of the uranium  decay chain,  are  the
 principal contaminants of concern resulting from releases at the
 U.S.  Radium site.   These nuclides include  isotopes of radium,
 thorium,  uranium,  lead and others.  Radium-contaminated material
 resulting from radium processing and  utilization at the High and
 Alden Streets Properties was apparently  discarded on  various
 Vicinity and Satellite Properties.  Hence, the primary
 radionuclide of concern is radium-226.   As a  result of  the radio-
 active decay of radium-226 in the soil,  elevated indoor concen-
 trations of radon  gas and radon decay products are exhibited in
 most  of the buildings associated with OU2.  All  OU2 properties
 exhibit elevated levels of indoor and/or outdoor gamma  radiation.

 Table 1 summarizes the common units of measure for radionuclides
 that  are discussed below.   The  concentration  of  radium-226
 measured at the properties investigated  ranges from "background"
 levels of approximately 1 picoCurie per  gram  (pCi/g)  of soil up
 to  several thousand pCi/g.

 As  stated above, radium-226 radioactively decays into radon  gas.
 Because radium  is  found naturally in  most soils,  radon  gas is
 typically found in most buildings, and,  in fact,  radon  gas was
 detected at each of the properties where radon tests  were
 performed.   Typical indoor radon gas  levels,  measuring  about 1
 picoCurie per liter (pCi/1)  of  air, were detected at  unaffected
 properties.   Levels in excess of 4 pCi/1 are  considered elevated,
 and some  affected  properties had radon gas values as  high  as 20
 pCi/1.   The background radon-222  level of 1 pCi/1 within the
 study  areas corresponds to approximately 0.005 Working  Level
 (WL),  whereas 20 pCi/1 of radon-222 corresponds  to approximately
 0.1 WL.   Additionally,  both indoor and outdoor gamma  radiation
 levels,  reported in units of microRoentgens per  hour  (juR/hr)  ,
 have been measured at many of the study  area  properties.
 Background gamma radiation is approximately 8.3  juR/hr within the
 study  areas.

 Soil and  Construction Material  Investigations

 Properties  included in OU2  were  surveyed for  radioactive
materials  to  define the limits  of contamination.   Radiological
 investigations  included the  collection of radon  gas samples  from
 inside  buildings,  and interior/exterior  surveying of  each

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 property to identify areas of elevated gamma radiation.   Wherever
 elevated gamma radiation readings were detected,  additional
 samples  were collected to characterize the extent of contaminants
 present.

 Because  of  the long and varied history of industrial use  at the
 High  and Alden Streets Properties study area,  additional  field
 investigations were performed to  augment the studies described
 above.   Surface and subsurface soil  samples were  collected  and
 analyzed for selected radionuclides  and nonradiological,  chemical
 analyses for metals,  volatile organic  compounds  (VOCs), semi-
 volatile organic compounds,  pesticides and polychlorinated
 biphenyls (PCBs).

 The following is a  summary of the RI findings.

 High  and Alden Streets Properties

      •    Soil  contaminated  with  radium and other radionuclides
          is  found  on a substantial  portion of the High and Alden
          Streets Properties study area.   Radiological
          contamination is present in  some locations to a depth
          of  15  feet.   An  estimated  18,000 cubic  yards of soil
          have  elevated radium concentrations.  In addition,
          approximately 110  cubic yards of structural material
          are  similarly contaminated.

          Gamma  radiation  exposure rates  associated  with
          contaminated soils range from background (8.3 /iR/hr) to
          700 /uR/hr.   All  buildings  on  the High and  Alden Streets
          Properties  contain elevated  levels of radon gas,  with
          levels ranging from 12.7 pCi/1  to  110 pCi/1.  Elevated
          concentrations of  both  fixed  and removable building
          surface contamination are  detected in some of the older
          on-site structures.

          Soil samples  collected  and analyzed for  chemical  (non-
          radiological) contaminants indicate the  presence  of low
          levels of metals and semi-volatiles in soils at the
          High and Alden Streets  Properties.  Chemical soil
          contamination is sporadic.

Four Nonadjacent OU2 Properties

          Studies of the four nonadjacent OU2 properties
          indicated the presence of elevated levels of
          radiological contamination.  Three properties contain
          elevated levels of radium,  found in both soil and
          structural materials, resulting  in elevated gamma
          radiation levels.  Elevated radon levels, along with
          elevated levels of both  fixed and removable building
          surface contamination, were detected at one property.

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           The fourth property  is  the  only  investigated property
           contaminated with thorium-232.   Approximately  400 cubic
           yards  of contaminated soil  and 40  cubic yards  of
           contaminated structural  material were  found at these
           four properties.

Wigwam  Brook and Ground Water  Investigations

Surface water and stream sediments were collected from Wigwam
Brook and  analyzed for radiological and chemical contaminants.
Four ground  water monitoring wells were installed at the High and
Alden Streets Properties study area.   In addition to these four
wells,  EPA also  sampled four preexisting wells  (one municipal
supply  well,  one commercial production well  and  two monitoring
wells)  for radionuclides and chemical  contaminants.  The findings
of the  RI  are summarized below.

           No elevated radiological contamination was found in
           surface water or  sediment samples  from Wigwam  Brook..

           No chemical contamination attributable to the  site was
           found  in surface  water or sediment samples from Wigwam
           Brook.

           Elevated uranium  concentrations  were detected  in EPA's
           monitoring wells  IS  and  3, and an  elevated radium
           concentration was detected in EPA  monitoring well IS.
           No other ground water sampling locations had elevated
           levels  of radionuclides.

           VOCs,  including tetrachloroethylene (PCE), trichloro-
           ethylene (TCE)  and 1,2-dichloroethylene (1,2-DCE), were
           detected in EPA monitoring wells above federal or state
           Maximum Contaminant  Levels  (MCLs)  for drinking water.

           VOCs were also detected  in the municipal and non-
           potable,  private  wells sampled over an area covering
           about  one square  mile around the site.  No definite
           pattern of VOC contamination was evident, nor  could a
           defined plume of  ground  water contamination be
           identified.   (Municipal  drinking water supply wells in
           the area have treatment  systems  to remove VOCs; there
           are no  known private drinking water wells located near
           the site.)   It is  unclear at this  time whether any
           portion of the VOC contamination found is related to
           the site.

Because EPA  monitoring wells are contaminated with site-related
as well as potentially unrelated contaminants, and information is
currently  not available to  determine the extent to which site-
related contaminants may be  migrating  into the ground water,  EPA
will further evaluate the nature and extent  of ground water

                                8

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contamination.  Not withstanding  this  further  evaluation,  site
activities do not  appear  to  be  adversely  impacting Wigwam  Brook.
In addition, local municipal water  supply wells are not
contaminated with  radionuclides.

The study areas are situated in well-established urban or
suburban communities, where  extensive  development and reworking
of soils has taken place.  Thus,  no wetlands remain at or  in
close proximity to the study areas.

SUMMARY OF SITE RISKS

During the OU2 RI/FS, EPA performed a  baseline risk assessment of
exposure to contaminants associated with  the U.S. Radium
Corporation site. This baseline risk assessment estimates  the
human health risk which could result from the  contamination at
the site if no remedial action  were taken.

To evaluate human health risks, a four-step process is used for
assessing site-related risks for  a  reasonable  maximum exposure
scenario.  These steps are:  Hazard Identification - identified
the contaminants of concern  at  the  site based  on several factors
such as toxicity, frequency  of  occurrence, and concentration;
Exposure Assessment - estimated the magnitude  of actual and/or
potential human exposures, the  frequency  and duration of these
exposures, and the pathways  (e.g.,  ingesting contaminated  soil)
by which humans are potentially exposed;  Toxicity Assessment -
determined the types of adverse health effects associated  with
exposures to site contaminants, and the relationship between
magnitude of exposure (dose) and  severity of adverse effects
(response); and Risk Characterization - summarized and combined
outputs of the exposure and toxicity assessments to provide a
quantitative (e.g., one-in-a-million excess cancer risk)
assessment of site-related risks.

For risk assessment purposes, individual  contaminants are
typically separated into two categories of health hazard
depending on whether they exhibit carcinogenic or noncarcinogenic
effects.   Radionuclides (e.g.,   radium,  thorium, radon, radon
decay products)  are known carcinogens.   Nonradiological,
"chemical" contaminants (e.g.,   polyaromatic hydrocarbons [PAHs],
barium,  vanadium, cadmium and lead)  may exhibit both carcinogenic
and noncarcinogenic health effects.

Current federal guidelines for  acceptable exposures are an
individual lifetime excess carcinogenic risk in the range  of 10^
to 10"6, representing  an  increased probability of one  in ten
thousand to one in one million  that an individual could develop
cancer resulting from exposure  to site-related contaminants, and
a maximum Hazard Index (which reflects noncarcinogenic effects
for a human receptor)  equal to  1.0.   (A Hazard Index greater than
1.0 indicates a potential for noncarcinogenic health effects.)

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 It must be noted that the risk posed by naturally occurring
 background radiation appears high when compared to the potential
 risk posed by nonradiological carcinogens.   During the RI,
 natural background radiation was  measured and used to estimate
 the risk of cancer to the general public.   The risk of cancer to
 the public was estimated to be 2  x 10'3,  representing  a
 probability of two in one thousand that an individual could
 develop cancer resulting from exposure to natural background
 radiation.   The excess risk to individuals at contaminated
 properties has been evaluated with respect to this background
 risk.

 To evaluate human health risk,  several exposure pathways  were
 selected for detailed evaluation  under current land-use
 conditions.   In addition,  potential  future land-use conditions
 were considered for the High and  Alden Streets Properties.

 All of  the current land-use conditions involved the potential
 exposure of workers or occupants  of  commercial properties,  and
 trespassers on unused properties.   Because most of the  properties
 surrounding the High and Alden Streets Properties are
 residential,  conversion from commercial  to residential  use  was
 considered to be a reasonable future scenario for the High  and
 Alden Streets Properties,  resulting  in potential  exposures  to
 residents.   The exposure pathways  were similar for current  and
 future  land-use situations:  inhalation of  radon decay products;
 exposure to external gamma radiation emanating from radium-
 contaminated material;  ingestion  of  radionuclides in  soil;  and
 inhalation  of radium-contaminated  particulates.   In addition, a
 future  residential land-use condition resulted in several added
 exposure pathways  for on-site residents:  ingestion of
 radionuclides,  cadmium and vanadium,  either from  inadvertent
 ingestion of soil  or in locally grown produce.

 In  all  current  and future  land-use situations,  inhalation
 exposure to  radon  decay products  is  consistently  the  major
 contributor  to  the total cancer risk that may  be  incurred by
 individuals  at  contaminated properties.  Exposure to  gamma
 radiation also  provides a  significant component of  the  overall
 radiogenic cancer  risk.   Ingestion of radionuclides is  several
 orders  of magnitude lower  in  risk than that of the  inhalation and
 gamma exposure  pathways.   Inhalation  exposure  to  particulate
 radium  is an  insignificant  contributor to the  total risk.

 For current  land-use conditions at the four nonadjacent OU2
 properties,  the  estimated  excess lifetime cancer  risk ranged up
 to  5 x  10"3 (five in one thousand) .  For the High and Alden
 Streets  Properties,  the estimated excess lifetime risks under
 current  and  future  land-use scenarios were  1 x  10"2  (one in one
hundred)  and  2  x 10'1  (two in ten) , respectively.
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 Tables  2  through 10  provide a  summary of the  excess  lifetime
 cancer  risk  estimates  associated  with exposure to  radionuclides
 for unremediated OU2 properties.

 Exposure  to  chemical (nonradiological)  contaminants  under  future
 land-use  conditions  contributed a marginally  elevated Hazard
 Index and cancer risk  at  the High and Alden Streets  Properties
 study area.   Table 11  summarizes  the  risks posed by  chemical
 contaminants under various  current and future use  scenarios.  The
 major contributors to  the risk are cadmium and vanadium; however,
 these risks  are  trivial compared  to those resulting  from
 radionuclide exposure.

 Unusually high concentrations  of  naturally occurring radon have
 not been  associated  with  the communities where OU2 properties are
 located.   Exposure to  elevated levels of gamma radiation, and the
 pathways  for the inhalation and ingestion of  radium, pose risks
 not typically encountered in areas of naturally occurring radon.
 The close proximity  of the  radium-contaminated soil  to the ground
 surface or radiological contamination in building construction
 material  at  contaminated  properties is  the main reason for these
 additional risks.

 The procedures and inputs used to assess risks in this
 evaluation,  as in all  such  assessments,  are subject  to a wide
 variety of uncertainties.   In  general,  the main sources of
 uncertainty  include:

           environmental sampling  and  analysis;
           environmental parameter measurement;
           fate and transport modeling;
           exposure parameter estimation;  and
           toxicological data.

 Uncertainty  in environmental sampling arises  in part from the
 potentially  uneven distribution of contaminants in the media
 sampled.   Consequently, there  is  significant uncertainty as to
 the  actual levels present.   Environmental sample-analysis error
 can  stem  from several  sources  including  the errors inherent in
 the  analytical methods and  characteristics of  the matrix being
 sampled.

Uncertainties in the exposure  assessment  are related to estimates
of how often an  individual would  actually come  in contact with
the  radionuclides of concern,  the  period  of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the contaminants of concern  at the point of
exposure.

Uncertainties in toxicological data occur in extrapolating both
 from animals to humans and  from high to  low doses of exposure,  as
well as from the difficulties  in  assessing the toxicity of a

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 mixture of contaminants.   These uncertainties  are  addressed by
 making conservative assumptions concerning  risk and  exposure
 parameters throughout the assessment.   As a result,  the  Risk
 Assessment provides upper-bound estimates of the risks to
 populations that may be exposed to  radionuclides,  and is highly
 unlikely to underestimate actual risks  related exposure.

 More  specific information concerning public health risks,
 including a quantitative  evaluation of  the  degree  of risk
 associated with various exposure pathways,  is  presented  in  the
 Risk  Assessment Report.

 An  evaluation of ecological  risk was not conducted as part  of
 OU2.   It was determined that,  because of the urban setting
 associated with the contaminated areas, the likelihood of contact
 of  contaminants with ecological receptors was  minimal.   For
 example,  Wigwam Brook serves primarily  as a stormwater drainage
 culvert in this area.   The one possible exception  would  be
 receptors down stream of  Wigwam Brook;  however,  because  of  the
 length of time since the  original deposition of  material and the
 lack  of any current releases from the High  and Alden Streets
 Properties study area into the brook, the likelihood of  exposure
 is  considered minimal.

 Actual or threatened releases  of hazardous  substances from  the
 U.S.  Radium Corporation site,  if not addressed by  implementing
 the response action selected in this ROD, may  present an imminent
 and substantial endangerment to public  health, welfare,  or  the
 environment.

 REMEDIAL ACTION OBJECTIVES

 The following remedial  action  objectives have  been established
 for this  operable unit  of the  U.S.  Radium Corporation site:

           Reduce exposure to radon  gas  levels  in excess of  4
           pCi/1 and radon decay products in  excess of 0.02  WL.

           Reduce exposure to gamma  radiation emitted from radium-
           contaminated  material  resulting from site sources with
           radium concentrations  in  excess of 5 pCi/g; employing
           As Low As Reasonably Achievable (ALARA) principles.

           Prevent ingestion  of and  general  contact with radium-
           contaminated  material  resulting from site sources with
           radium concentrations  in  excess of 5 pCi/g, employing
           ALARA principles.

These  remedial  action objectives are similar to those selected
 for the Montclair/West  Orange  and Glen Ridge Radium sites (MWG
sites) and for  OU1  of this site  and would,  at minimum,  achieve
the cleanup  criteria  in 40 CFR 192,  the federal regulations

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 governing  the  cleanup of uranium mill  tailings  from  inactive
 uranium processing  sites.   EPA has  determined that the  5 pCi/g
 standard found in 40  CFR 192  is relevant  and appropriate for
 cleanup at the U.S. Radium site,  when  combined  with  ALARA
 principles.

 EPA's  implementation  of  the remedy  at  the MWG sites  has revealed
 some of the limitations  of 40 CFR 192:  a strict  implementation
 of the regulation would  not result  in  a cleanup that would
 satisfy the more protective requirements  of CERCLA.  Therefore,
 EPA has relied upon ALARA principles at the MWG sites during
 implementation of the response action.  Applying  ALARA  principles
 means  taking additional  measures during remedial  action, beyond
 those  required to meet a specified  cleanup goal,  to  assure
 protectiveness.  In achieving the remedial action objectives for
 OU2, EPA will  rely  on the ALARA principles used at the  MWG sites
 during implementation of the  response  action.   Applying the 5
 pCi/g  standard with ALARA principles at the MWG sites has
 resulted in exposure  levels that are lower than the  levels that
 would  result from using  the 5 pCi/g standard alone.  An ALARA
 approach is being used at the MWG sites because of the  long-lived
 nature of  radionuclides,  the  difficulty in eliminating  routes of
 exposure,  limitations of the  analytical equipment to detect
 radionuclides,  and  site-specific factors  which  may make it
 necessary  to remove material  at levels below 5  pCi/g to achieve
 adequate public health protection.

 Certain structures  and above-ground debris at the affected
 properties  are contaminated with radium.  The selected  remedy is
 expected to  satisfy Nuclear Regulatory Commission guidelines for
 surface contamination or,  as  appropriate, the remedial  action
 objectives  employing  ALARA principles to  help ensure
 protectiveness.

 EPA's  experience at the  MWG sites has shown that  the remedial
 action  objectives noted  above can be achieved and, by
 incorporating  ALARA principles,  generally result  in no  elevated
 radon  or gamma radiation levels  at  the surface.   Therefore, by
using  similar  remedial action objectives, the U.S. Radium site
would pose no  unacceptable risk  for residential uses after
cleanup, and would result  in  a  cleanup that is protective under
CERCLA.

Vanadium and cadmium  at  levels that exceed background for those
metals  were detected  in  some  samples collected at the High and
Alden Streets  Properties study area; the  levels pose some
marginal risk  in several  future-use scenarios.   Risk-based
remediation goals of  517 milligrams per kilogram  (mg/kg) for
vanadium and 10 mg/kg  for  cadmium were derived  in the RI report.
The areas of radionuclide-soil contamination appear to be
contiguous with the areas  of  vanadium/cadmium contamination.  The
remedial alternatives considered below take into  account the

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 metals contamination,  in that the  limited options  available  for
 mitigating the radium-contaminated soil  would  also adequately
 address the metals contamination at the  levels detected.

 DESCRIPTION OF REMEDIAL ALTERNATIVES

 CERCLA requires that each selected site  remedy be  protective of
 human  health and the environment,  be cost effective,  and utilize
 permanent  solutions and alternative treatment  technologies or
 resource recovery technologies to  the maximum  extent  practicable.
 In  addition,  the statute includes  a preference for the use of
 treatment  as a principal element for the reduction of toxicity,
 mobility or volume of  the hazardous substances.

 Only a limited number  of options are available for the
 remediation of radioactively  contaminated sites.   No  treatment
 technologies are known that will eliminate radioactivity.  (The
 total  amount of radioactivity cannot be  altered or destroyed, as
 is  often possible with chemical contaminants.)  Thus, the
 remedial alternatives  described below focus on methods of
 satisfying the remedial action objectives by limiting contact
 with radium-contaminated material.

 The FS  evaluated in detail four alternatives for addressing  the
 contamination associated with the  U.S. Radium  Corporation site.
 The estimated capital  cost, operation and maintenance (O&M)
 costs,  and net present worth  cost  of each alternative discussed
 below  are  provided for comparison.   The  time to implement a
 remedial alternative reflects only the time required  to construct
 or  implement  the remedy and does not include the time required to
 design  the remedy,  negotiate  with  the responsible  parties,
 procure  contracts for  design  and construction,  or  conduct O&M at
 the site.   A  brief description of  each alternative  follows.

 Alternative 1:   No Action

           Estimated Capital Cost:               $ 0
           Estimated Annual O&M Costs:           $ 0
           Estimated Present Worth:              $ 0
           Estimated Implementation  Timeframe:   none

A No Action alternative is evaluated for  every  Superfund site to
 establish  a baseline for comparison  with  remedial  alternatives.
Under this  alternative,  no further  action  would be  taken to
 reduce exposure  to radioactive materials  at these properties.
The temporary  radon mitigation system already  installed at one
OU2 property during the 1991  removal  action would  remain in
place,  but  there  would be no  provision for operation  and
maintenance.   No  additional measures  would be taken to reduce
 exposures  at properties that  are not  presently being  addressed.
Even with  a long  projected life for  the radon mitigation system,
 it is assumed  that  it  would eventually fail and that  indoor

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 concentrations  of radon and  radon  decay  products would  return  to
 the  pre-mitigation conditions.

 Because  hazardous substances would remain  at  the OU2 prbperties
 above  acceptable  levels,  five-year reviews would be required.

 Alternative  2:  Engineering  and  Institutional Controls

           Estimated Capital  Cost:               $12,716,000
           Estimated Annual O&M Costs:           $   107,000
           Estimated Present  Worth:              $13,740,000
           Estimated Implementation Timeframe:   3 years

 This alternative  involves the implementation  of one or  more of
 the  following engineering controls, as determined to be
 necessary, in areas where contamination  has been identified and
 measures have yet to be taken:

           Installation  of systems  to reduce indoor concentrations
           of radon and  radon decay products;

    . •     Installation  of indoor gamma radiation shielding;

           Installation  of outdoor  gamma  radiation shielding where
           necessary; and

        .   In some cases, installation of fencing to restrict
           property access.

 During implementation of this action, temporary relocation of
 some businesses may be required.   Institutional controls (e.g.,
municipal  or health ordinances, land-use restrictions)   would also
be necessary to ensure the effectiveness of the engineering
 controls.

O&M would  also be necessary  to assure the continued
protectiveness of the engineering  controls.  Because radium,
which persists for thousands of years,  would not be removed from
the properties,  the  need for O&M would continue for many years;
however,  for cost-estimating purposes,  O&M costs for maintaining
the radon mitigation systems and gamma radiation shielding have
been assumed for  a  period of 30 years.   Because hazardous
substances would  remain at the OU2 properties above acceptable
levels, five-year  reviews of the remedy would be required.   This
alternative would  take approximately three years to implement.
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Alternative  3:   On-site containment

           Estimated Capital  Cost:               $ 10,771,000
           Estimated Annual O&M  Costs:           $    128,000
           Estimated Present  Worth:              $ 11,990,'000
           Estimated Implementation Timeframe:   2 years

Under  this alternative,  radium-contaminated buildings at the High
and Alden  Streets  Properties and one nonadjacent OU2 property
would  be dismantled.   The dismantled building debris would be
sent to an appropriate off-site disposal  facility.  Soil from the
four nonadjacent OU2  properties would be  excavated and replaced
with clean fill.   The excavated material  from these four
properties would be brought  to  the High and Alden Streets
Properties study area for long-term containment.  A containment
facility would be  constructed by installing a cap and slurry wall
around the radium-contaminated  soil at the High and Alden Streets
Properties study area.

During implementation of this action, temporary or permanent
relocation of businesses would  be required at some properties.
Chemical (nonradiological) soil contamination found at the High
and Alden  Streets  Properties would also be contained under the
cap.   Engineering  and institutional controls similar to those
described  under  Alternative  2 would be required for the High and
Alden  Streets Properties; however, the four nonadjacent OU2
properties would be available for unrestricted use.  Because
hazardous  substances  would remain at the  High and Alden Streets
Properties study area,  five-year reviews  of .the remedy would be
required to assure the  continued effectiveness of the remedy.
This alternative would  take  approximately two years to implement.

Alternative 4:   Excavation and  Off-site Disposal

           Estimated Capital  Cost:              $ 22,030,000
           Estimated Annual O&M  Costs:          $          0
           Estimated Present  Worth:             $ 22,030,000
           Estimated Implementation Timeframe:  2 years

Under  this alternative,  radium-contaminated material would be
excavated  or otherwise  removed  from contaminated properties,  and
replaced with clean fill or  otherwise restored.  It is estimated
that approximately 18,400 cubic yards of  soil and 150 cubic yards
of construction material are  contaminated with radionuclides.
Contaminated material would  be  transported for final disposal at
an appropriate, off-site facility.

Based  on experience at this  site and the MWG sites, material
contaminated above  background levels would not remain within the
first  two  feet of  a remediated  property.   In addition,  based on
data available for  the  site  and EPA's experience,  residually


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 contaminated material  remaining on remediated  properties  would
 not  be  greater than two feet in thickness.

 During  implementation  of this action,  relocation  of businesses
 would be  required at some properties.   In addition, demolition of
 certain OU2  property buildings may be  required because  of the
 unique  contaminant distributions at those properties.   Excavation
 and  off-site disposal  of radium-contaminated soil from  the High
 and  Alden Streets Properties would also remove nonradiological,
 chemical  contamination found in the soil.   Because this
 alternative  would not  result in elevated levels of radionuclides
 remaining on any  property,  a five-year review  of  the
 effectiveness of  the remedy would not  be required.  This
 alternative  would take approximately two years to implement.

 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

 In accordance with the NCP,  a detailed analysis of each remedial
 alternative  was performed with respect to each of the nine
 evaluation criteria.   This section discusses and  compares  the
 performance  of the remedial  alternatives under consideration
 anainst these criteria.   These criteria were developed  to  address
 the  requirements  of  Section  121 of CERCLA to ensure that all
 important  considerations  are factored  into  remedy selection
 decisions.   All selected  remedies  must at least satisfy the
 Threshold  Criteria.  The  selected  remedy should provide the best
 trade-offs among  the Primary Balancing Criteria.   The Modifying
 Criteria  are  evaluated following the public comment period.

 Threshold Criteria

 1.   Overall  protection of human health and the environment
     considers whether or  not  a remedial alternative provides
     adequate  protection  and describes how risks posed  through
     each exposure pathway are  eliminated,  reduced, or  controlled
     through treatment, engineering controls, or  institutional
     controls.

 2.   Compliance with ARARs addresses whether or not a remedial
     alternative meets all of  the  applicable or relevant and
     appropriate requirements  (ARARs)  of federal and state
     environmental statutes  and requirements, or provides grounds
     for invoking  a waiver.

Primary Balancing Criteria

3.   Long-term effectiveness and permanence refers to the ability
     of a remedial alternative to maintain  reliable protection of
     human health and the environment over  time,  once cleanup
     goals have been met.  It also addresses the magnitude and
     effectiveness of the measures that may be required to manage
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      the risk posed by treatment  residuals  and/or  untreated
      wastes.

 4.    Reduction of toxicitv.  mobility,  or  volume  through-treatment
      addresses the statutory preference for selecting  remedial
      actions  that employ treatment  technologies  that permanently
      and significantly reduce toxicity, mobility or volume of
      hazardous substances as a principal  element.

 5.    Short-term effectiveness considers the period of  time needed
      to  achieve protection and any  adverse  impacts on  human
      health and the environment that may  be posed  during the
      construction and implementation period, until cleanup goals
      are achieved.

 6.    Implementability refers to the technical and  administrative
      feasibility of a remedial alternative,  including  the avail-
      ability  of materials and services needed to implement the
      alternative.

 7.    Cost  includes  the estimated capital  and O&M costs, and the
      present-worth  costs.

 Modifying  Criteria

 8.    State acceptance indicates whether,  based on  its  review of
      the RI/FS  and  the Proposed Plan, the State  supports,
      opposes,  and/or has identified any reservations with the
      preferred  alternative.

 9.    Community  acceptance refers to the public's general response
      to the alternatives described  in the Proposed Plan and the
      RI/FS report.   Responses  to public comments are addressed in
      the Responsiveness  Summary section of  this Record of
      Decision.

 comparisons

 A comparative analysis of the  remedial alternatives based upon
 the evaluation  criteria  noted  above follows.

 Protection of Human  Health and the  Environment

Alternative 1  (No Action)  is not protective of human health and
the environment because  the  risks associated with contaminated
OU2 properties would  persist  for the foreseeable future.   Under
Alternative 1,  radon  and radon decay product levels would be
 reduced in only the  one  building which currently has a mitigation
 system.  However, as  the temporary mitigation system fails,
 indoor concentrations  of radon and  radon  decay products would
 return to pre-mitigation conditions.  Under Alternative 1,  the
security fence currently in place around  the abandoned portion of

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 the  former  plant site would  not  be  maintained.  There would be no
 reduction in  gamma  radiation exposure  indoors or  outdoors, and no
 reduction in  the threat  of direct contact  with radium-
 contaminated  material.

 Alternatives  2  (Engineering  and  Institutional Controls) and 3
 (On-site Containment)  reduce the possibility of exposure to
 contaminated  material and, therefore,  reduce human health risks
 associated  with  the site.  However, with either alternative, the
 radium-contaminated material would  remain  on certain properties.

 Alternative 4 (Excavation and Off-site Disposal)  is fully
 protective  of human health and the  environment because  it removes
 the  contamination from the site.  As a result, Alternative 4
 allows unrestricted future use of contaminated properties.

 Compliance  with  Applicable or Relevant and Appropriate
 Requirements

 No requirements  have been determined to be applicable to the
 remediation of the  OU2 properties.  However, as discussed
 earlier, portions of the federal regulations governing  the
 cleanup of  uranium  mill tailings from  inactive uranium  processing
 sites, 40 CFR 192,  have been determined to be relevant  and
 appropriate.

 Health- or  risk-based  standards  include an annual average
 exposure guideline  of  no more than  4 pCi/1 of air for radon,
 which corresponds to an approximate annual average exposure of
 0.02 WL for radon decay products.  Additionally, the standards
 for the cleanup  of  radium-contaminated material require that the
 concentration of radium-226, averaged  over an area of 100 square
 meters (120 square  yards) of surface soil,  be no greater than 5
 pCi/g.  For this site, the 5 pCi/g cleanup standard also applies
 to subsurface soils.

 Alternative 1 does  not satisfy any of  the human health standards.
Alternatives  2 and  3 satisfy human health standards by reducing
 exposures to radiation in excess of natural background levels;
however,  continued  O&M is required to  assure continued attainment
 of these standards.   Alternative 4 satisfies human health
 standards by removing the source of exposures to radiation in
excess of natural background levels.  Alternatives 2,  3 and 4
would satisfy the threshold  requirements of overall protection of
human health and the environment with  regard to chemical
 (nonradiological) contaminants.

Because Alternative  1, No Action, does not meet the threshold
requirements of overall protection of human health and the
environment or compliance with ARARs,   it will not be considered
 further in the evaluation of alternatives.
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 Long-Term Effectiveness and Permanence

 Alternative 2 provides little long-term  effectiveness  or
 permanence,  since it relies on the  use of  engineering  and
 institutional controls at radium-contaminated properties.
 Alternative 3 provides a slightly more effective  long-term
 solution;  however,  it would be difficult to maintain a facility
 containing radioactive wastes with  long  half-lives  (about 1,622
 years  for Radium-226)  in a densely  populated area.  Alternative 3
 would  allow for unrestricted future use  of the  four nonadjacent
 OU2 properties,  but not the High and Alden Streets  Properties.
 Alternative 4 is fully effective in the  community for  the long
 term,  would allow for unrestricted  use of  all the OU2  properties,
 and is considered a final remedial  solution.

 Reduction of Toxicity.  Mobility, or Volume through  Treatment

 As radioactivity is an intrinsic property  of the  nuclides in the
 contaminated material,  its toxicity cannot be altered  by
 treatment.   Mobility and/or volume  may be  addressed by treatment,
 but as toxicity is  not altered, such treatment  does not provide a
 sufficient reduction in health risk or environmental threat.  No
 treatment  technology is currently available that  can effectively
 reduce the toxicity,  mobility or volume  of the  radioactive
 contamination to the site-specific  cleanup criteria specified
 given  the  soil  matrix found at the  OU2 properties.  Therefore,
 none of the  remedial alternatives that were considered satisfy
 this evaluation factor.   Although none of  the alternatives
 considered use  treatment as a principal  element,  Alternatives 3
 and 4  provide some  reduction in the mobility of radiologically
 contaminated material,  through placement in a secure containment
 facility.

 Short-Term Effectiveness

 Alternatives  2,  3 and  4  provide effective  short-term protection,
 and become effective as  they are implemented at individual
 properties.   Any adverse short-term impacts during  implementation
 (such  as the  creation  of dust)  can  be controlled  through the use
 of measures  such as  dust suppression techniques.

Alternative  2  involves  less  intrusive activities  and poses less
of a threat  to workers  and  the  surrounding community during
 implementation than  Alternatives 3  or 4.   Alternatives  3 and 4
require a  comparable period  of  time to implement,  two  years.
However, Alternatives  2,  3  and  4 involve intrusive activities,
 including, in some cases, temporary or permanent  relocation of
businesses.  Alternatives  3  and 4 have a greater  potential
adverse impact in the  short  term because of the removal of
radium-contaminated  material,  including  the excavation of soil.
Engineering controls would be required to minimize the  impacts of
these alternatives.

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 Implementability

 The indoor remedial activities associated with Alternative 2  are
 generally straightforward to implement and have been successfully
 implemented at other sites.   Extensive outdoor gamma radiation
 shielding techniques have not been attempted or fully
 demonstrated and,  therefore,  may create some difficulties.
 Property owners along with state,  county and municipal
 authorities would  need to be involved in the process of
 implementing the necessary institutional controls  for
 Alternatives 2 and 3.

 Alternatives 3 and 4 involve the use  of standard construction
 practices.   Implementation would be expected to be
 straightforward and,  in the  case of Alternative 4,  has  been
 successfully performed at the Montclair/West Orange and Glen
 Ridge  Radium sites.

 The continued availability of an off-site disposal  facility is
 required for implementation  of Alternative 4.

 Cost

 Alternative 2  includes construction costs of  $12.7  million  to
 implement  remedial measures  at OU2  properties,  and  an annual  O&M
 cost of  $107,000 for all  properties for an assumed  period of  30
 years.   This results in an estimated  present  worth  cost of  $13.7
 million  for the alternative.   Alternative 3 has  an  estimated
 present  worth  cost of  $12  million,  with $128,000 in annual  O&M
 costs  assumed  for a  period of  30 years.   Alternative 4  involves
 construction costs of  $22  million,  but  no O&M costs.

 State  Acceptance

 The  State of New Jersey concurs with  the  remedial actions called
 for  by the  selected  remedy.

 Community Acceptance

 The  community  response to  EPA's Proposed  Plan was supportive.
 There  is a  consensus of support for the proposal in that it calls
 for  full remediation of the properties where radium-contaminated
 material is  discovered.

Alternative  4 has received consistent community support, as it is
 a final remedy which complies with ARARs.  Even though  short-term
disruption to the community during  implementation of Alternative
 4 would be the highest of the active  remedial alternatives, the
public fully supports this alternative.

Alternatives 1, 2 and 3 have received little or no community
 support.

                                21

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 SELECTED  REMEDY

 The  following describes the remedial  action plan which EPA  is
 selecting to  implement at  the OU2  properties.  EPA selects
 Alternative 4,  as  presented in the Proposed Plan.

 The  selected  remedial  action will  achieve the remedial action
 objectives at affected OU2  properties,  (i.e., reduce exposure to
 gamma  radiation resulting  from material with radium
 concentrations in  excess of 5 pCi/g,  reduce exposure to radon
 decay  products in  excess of 0.02 WL,  and prevent ingestion  of and
 general contact with material with radium concentrations in
 excess of 5 pCi/g).  Radium-contaminated soil found on affected
 properties in excess of 5  pCi/g will  be excavated consistent with
 40 CFR 192, Subpart B.   The remedy will attain a risk level
 similar to risk levels associated  with exposure to natural
 background radiation.   Based on sampling efforts to date, EPA
 estimates that approximately 18,400 cubic yards of contaminated
 soil will be  excavated from these  properties.  Other nonsoil
 contamination,  estimated to total  approximately 150 cubic yards,
 will also be  removed.   All  of the  radium-contaminated material
 will be disposed of at a licenser',  off-sjte facility.  Areas that
 have been excavated will be restored  with clean fill.

 Concentrations  of  vanadium  and cadmium are present at this  site
 in excess of  the risk-based remediation goals for those metals
 (517 mg/kg for  vanadium, 10 mg/kg  for cadmium).  However, the
 areas  where nonradiological contaminants have been found
 generally coincide with areas of radionuclide contamination.
 Therefore, the  selected remedy will provide for excavation and
 disposal  of these  contaminants as  well.

 During implementation  of this action, some businesses may need to
 relocate.

Though it is  unlikely,  should circumstances arise which prevent
the continuation of off-site  disposal (e.g., loss of the disposal
 facility), excavation  activities will cease.  At that point, the
OU2 properties  will receive appropriate engineering controls
designed  to protect human health and  the environment to the
maximum extent  practicable.

The selected  remedy will be a final remedy for the OU2 properties
addressed in  the second operable unit.  As stated earlier,
because elevated levels of  radon decay products could be present
after completion of the remedy as  a result of naturally occurring
sources,   it may be necessary  for some property owners to maintain
radon mitigation systems after implementation of the action.

A Stage 2  Cultural Resources  Survey is currently being performed
as part of the  second operable  unit studies.  It has been
determined that  mitigation  actions under the National Historic

                                22

-------
 Preservation Act  (NHPA)  may  be  necessary  as  a  result  of  the
 remedial  action selected here.  The  nature and extent of those
 mitigation  activities  will be assessed  as part of  the Cultural
 Resources Survey.   The selected remedy  will  be performed in
 compliance  with the requirements  of  the NHPA.

 STATUTORY DETERMINATIONS

 Superfund remedy selection is based  on  CERCLA  and  the regulations
 contained in the NCP.   Under its  legal  authorities, EPA's primary
 responsibility  in selecting  remedies at Superfund  sites  is to
 undertake actions that are protective of  human health and the
 environment.  In addition, Section 121  of CERCLA establishes
 several other statutory requirements and  preferences.  These
 specify that, when  complete, the  selected remedial action for
 this site must  comply  with applicable or  relevant  and appropriate
 environmental standards established  under federal  and state
 environmental laws  unless a  statutory waiver is justified.  The
 selected  remedy also must be cost-effective and utilize  permanent
 solutions and alternative treatment  technologies or resource
 recovery  technologies  to the maximum extent practicable.
 Finally,  the statue includes a  preference for  remedies that
 employ treatment that  permanently and significantly reduce the
 volume, toxicity, or mobility of the hazardous wastes, as their
 principal element.  The  following sections discuss how the
 selected  remedy meets  these  statutory requirements for the second
 operable  unit of the U.S. Radium Corporation site.

 Protection of Human Health and  the Environment

 For the OU2  properties,  this remedy  fully protects human health
 and the environment.   It is  estimated that .no  radium-contaminated
 soil above the  cleanup standards will remain on the affected
 properties.   In addition, based on experience  at this site and
 the Montclair/West  Orange and Glen Ridge  Radium sites, material
 contaminated  above  background levels would not remain within the
 first two feet  of a remediated property.  In addition, based on
 data available  for  the site  and EPA's experience, residually
 contaminated  material  remaining on remediated properties would
 not be greater  than two  feet in thickness.  The remedy will
 attain a  risk level similar  to risk  levels associated with
 exposure to natural background radiation.   Implementation of this
 remedy will eliminate  additional risks attributable to exposures
 to indoor or  outdoor gamma radiation, indoor radon gas or radon
decay products,  inhalation and/or ingestion of contaminated soil,
 and ingestion of contaminated vegetables  grown in contaminated
 soil.

This remedy will comply with the ARARs for exposure to indoor
gamma radiation and the  inhalation of radon gas or radon decay
products,  and attainment of soil cleanup  standards.


                                23

-------
 There are few short-term risks  associated with the  implementation
 of  this  remedy.   Where excavation  occurs, dust suppression
 measures can reduce the risk  of inhalation of radium-contaminated
 dust.  In addition,  no adverse  cross-media impacts  are expected
 from the remedy.

 Attainment of ARARs

 As  presented earlier,  the  primary  ARARs for this site are
 contained in 40 CFR 192, Subpart B.  This regulation deals with
 the cleanup of inactive uranium processing facilities.  EPA has
 determined that while  these standards are not legally applicable,
 they are relevant and  appropriate  to the situation  at the U.S.
 Radium Corporation site.

 When implemented,  the  cleanup of the affected properties within
 the study areas will comply with all public health  and soil
 cleanup  ARARs.

 Cost Effectiveness

 The selected remedy  is cost-effective because it provides the
 highest  degree of overall  effectiveness relative to its cost.
 The remedy provides  for complete protection of public health and
 the environment at the affected properties.  It has been examined
 closely  to ensure that it  is the least costly means of achieving
 the required level of  protection.

 Utilization of Permanent solutions and Alternate Treatment or
 Resource  Recovery Technologies  to  the Maximum Extent Practicable

 EPA and  the State of New Jersey have determined that the selected
 remedy represents the  maximum extent to which permanent solutions
 and currently  available treatment technologies can  be utilized in
 a cost-effective  manner for this phase of the remedial action at
 the U.S.   Radium Corporation site.  Of those alternatives that are
 protective of  human health and  the environment and  comply with
 ARARs, EPA and the State of New Jersey have determined that the
 selected  remedy provides the best balance of trade-offs in terms
 of  long-term effectiveness and  permanence,  short-term
 effectiveness, implementability, and cost,  and considering the
 statutory preference for treatment as a principal element and
 State and community acceptance.

 Preference  for Treatment as a Principal Element

The  principal  threat at the site is the generation  of excess
concentrations of  radon gas and radon decay products indoors,
which are  subsequently inhaled  by the occupants of  structures on
OU2  properties.   In addition,  there are threats from exposure to
excess levels  of  indoor and/or  outdoor gamma radiation,  ingestion
and/or inhalation  of radium-contaminated soil,  and  ingestion of

                                24

-------
vegetables grown in contaminated soil.  Because there is no
treatment available that destroys the radioactive source of these
threats, the selected remedy does not satisfy the statutory
preference for treatment as the principal element.  The remedy
does reduce the exposure to all excess indoor concentrations of
radon and radon decay products.  It also provides for complete
remediation at the affected properties, thereby reducing the
exposure risk from all pathways.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative
presented in the Proposed Plan.
                               25

-------
             VICINITY

  PROPERTIES STUDY AREA

   t* SuR/hr ISOPLETH)
          STREET PROPERTIES
                                             NOTE: SATELLITE PROPERTIES ARE CIRCLED
     U.S. RADIUM SITE

   ORAMQC. NEW  JERSEY
MA1DX
  PIRNIE
SITE LOCATION MAP

-------
                     U.S. RADIUM  CORPORATION SITE
                       VteWty  Properties Study Area
                                 U&KAOUM
                                CORPORATION
                                  FACUTY
Note: The Satellite Propertlee study ana IndudM dteerata propcrtle* located In tevard
     communltlftt, and cannot be elmtarly represented.
                               FIGURE 2

-------
a:
m
o
     GATE
                                             GATE
                      r
•SECURITY

FENCE
                   VACANT

                    (G)
                    GATE !
                        , i
                    VACANT -  2 FLOORS
                         r
                              •TRANSFORMER
                                          GATE:
(C)

(B)
                        GAS PUMP-
                 GATE
               HIGH STREET
      UNDERGROUND—
MALCOLM
RRNIE
EPA US RADIUM SITE
FIELD INVESTIGATIONS
SITE PLAN SHOWING EXISTING BUILDINGS
• JkLCOlB •••« «C
FIGURE 3

-------
   TABLE  1
RADIATION UNITS




 US RADIUM SITE
Parameter
Quantity
Radionuclide
Concentration in
Soil or other
Solid Material
Radionuclide
Concentration in
Water
Radon gas cone.
Radon progeny
cone.
Exposure rate
Dose


Dose equivalent
Historical
Unit
Curie

picoCurie per
gram of Solid


picoCurie per
liter of Water
picoCurie per
liter of Air
Working Level

micro-Roentgen
per hour
Radiation
Absorbed
Dose
Radiation
Equivalent Man
Abbrev.
Ci

pCi/g


pCi/L
pCi/L
WL

uR/h
rad


rem
International
Unit
Becquerel

Becquerel per
kilogram


"
Becquerel per
cu. meter


	
Gray


Sievert
Abbrev.
Bq

Bq/kg


	
Bq/m3


	
Gy


Sv

-------


TABLE 2


HAZARD ASSESSMENT
U.S. RADIUM SITE
RADIONUCLIDE
Radium-226
Uranium-238
Thorium-230
Lcad-210
Thorium-232
Radon-222
MEDIUM
Soil;
Structural
Materials
Soil
Soil
Soil
Soil
Air
RANGE OF
DETECTED
CONCENTRATION
(pCi/g)
<1-3300
<1-220
<1-2300
Not Measured
<1-159

-------
                                         TABLE  3

                    SUMMARY OF COMPLETE EXPOSURE PATHWAYS

                                    U.S. RADIUM SITE
Potentially Exposed   Exposure Route, Medina
    Population          and Exposure Point
                           Pathway Selected
                            for Evaluation?
                Reason for Selection
                   or Exclusion
    Residents;
    Occupants1-1
External gamma radiation
emanating from soil
and/or structural
materials.
Yes
Contamination is in
occupied and potentially
occupied areas.
    Residents;       Inhalation of radon decay
    Occupants'       products.
     Residents        Inhalation of radioactive
                     particulates.

    Occupants1       Inhalation of radioactive
                     particulates.

     Residents        Digestion of radionudides
                     in soil

    Occupants1       Ingestion of radionudides
                     in soil

     Residents        Ingestion of radionudides
                     in locally grown produce.
                                 Yes
                                 Yes


                                 No


                                 Yes


                                 No


                                 Yes
             Major contributor to
             radiation dose at some
             occupied and potentially
             occupied properties.

             Contamination is in
             potentially occupied areas.

             Contamination is in
             inaccessible areas.

             Contamination is in
             potentially occupied areas.

             Contamination is in
             inaccessible areas.

             Produce is grown at several
             Vicinity Properties and
             may be grown in potentially
             occupied areas.
     'Commercial properties
     Trespasser is also considered an occupant

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TABLE 4
EXPOSURE CONDITIONS - COMMERCIAL AND TRESPASSER SCENARIOS
US RADIUM SITE
PROPERTY
SATELLITE I
SATELLITE:
SATELLITE 3
VICINITY!
High and Alden Streets
Background
SCENARIO
Commercial
Commercial
Commercial
Commercial
Current commercial


TWMI^^MV
—
ftpOMre Point Gamma
D&rli«tLr« P»m»^i.» It mtm
(ufUb\
8
12
80
10
22
44
89
8
Eiponrc Point Indoor
Radon Coneentr*tion
roCi/L) I
<1.7
<1.7
43
<1.7
11.0
24.4
18JS
1.7

-------
i TABLE 5
EXPOSURE CONDITIONS:
HIGH AND ALDEN STREETS PROPERTIES - FUTURE RESIDENTIAL SCENARIO
• US RADIUM SITE
•
EXPOSURE POINT
VALUES
SOBL(pCi/g):
Ra-226
Pb-210
U-234,238
Th-230
PRODUCE (pCi/g):
Ra-226
Pb-210
U-234, 238
Th-230
INHALATION:
Gaseous (pCi/L):
Rn-222
Paniculate (pCi/cujn):
Ra-226
Pb-210
U-234,238
Th-230
BACKGROUND
1
1
14
1
0.02
0.01
0.0036
0.0005

1.7
1E-04
1E-04
1.8E-04
1E-04
HIGH AND ALDEN
STREETS PROPERTIES
456
456
10
182
9.1
4.6
0.02
0.09

253
4.6E-02
4.6E-02
l.OE-03
1.8E-02

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                                                                  TABLE 6

                                      SUMMARY OP UPBTIMB GAMMA RADIATION DOSB AND RADON INTAKE
                                                 FOR COMMERCIAL AND TRBSPASSBR SCENARIOS
                                                                 US RADIUM SITE
       PATHWAY
BacfcgroMil
SATELLITE 1
SATBLUTB 2
                                                                                        PROPERTY
SATELLITE 3
VICINITY I
                                                                                                                     Ililk ud Aides Slfecit
                                                                    C«t«al    R«4a*«tepa4
 EXTBRNALOAMMA
 RADIATION DOSB(nMl)
   0.35
    aas
    0.52
     3.5
                                                                                      1.0
                               1.9
                                                                                                             0023
 RADON -222
 INHALATION (pCi)
  2.1E+M
  K2.IB+06
  <2.IB+08
   5.4B+M
  <2.IE+M
I.4E+09
4611 + 06
• Trcipauer wuke it tewd oo • OK yew cipowire period and m*y be co«pved to backgrouad valuei of 2.IB-03 rad eatcraal (••>•• dow aad 4.3E*05 pCi Rn-222 inukc vit inhaUtioo.

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                               TABLE?

      LIFETIME RADIONUCUDE INTAKE FOR HIGH AND AJLDEN STREETS
              PROPERTIES - FUTURE RESIDENTIAL SCENARIO
                             US RADIUM SITE
   Exposure Pathway            Background                High and Alden
   ^	Street! Properties
INGESTION (pCi)

 Ra-226
  Sofl                           UE+03                    5.7E+05
  Produce                        2.6E+04                    1.2E+07

 Pb-210
  Soil                           UE+03
  Produce                        1.3E+04

 U-234.238
  Sofl                           2JE+03                    UE+04
  produce                        4.6E+03                    2U5E+04

 Th-230
  Sofl                           1.3E+03                    2JE+05
  Produce                        6.4E+02                    UE-t-05
INHALATION (pQ)

 Rn-222                         2.7E+08                    4.0E+09

 Ra-226                           53                      2.4E+Q3

 Pb-210                           53                      14E+03

 U-234,238                         9J                      5JE+01

 Th-230                           5J

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TABLE 8
SUMMARY OP BXCBSS UPBT1MB CANCER RISK ESTIMATE; - COMMERCIAL SCENARIOS
US RADIUM SITE
PATHWAY
EXTERNAL GAMMA
RADIATION
INHALATION
TOTAL RISK
TOTAL EXCESS
UFETIMB RISK •
~+—
2.26-04
I.6E-03
1.96-03
--
PROPERTY
SATBLUTB 1
2.2B-04
I.6E-03
I.9B-03
OB+00
SATBLUTB 2
3.26-04
I.6E-03
2.06-03
1.16-04
SATBLUTB 3
2.2E-03
4.2B-03
6.4E-03
4.5E-03
VICINITY 1
2.7E-04
I.6E-03
I.9B-03
5.4E-03
Ilillli ««d Aldca Slfccii
CMICB!
Coaacfciil
5.9E-04
I.IB-02
I.1B-02
9.3E-03
Cammtittt
1.2E-OJ
2.4K-02
25U-02
2.3E-02
Tout CIOCM lifclime riik - Toul Riik - Riik from uo«void»bte nMural bMk|rouad ckdialioo.

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TABLE 9
SUMMARY OF EXCESS ANNUAL RISK ESTIMATES - TRESPASSER SCENARIO
US RADIUM SITE
PATHWAY
EXTERNAL GAMMA
RADIATION
INHALATION
ANNUAL RISK
TOTAL EXCESS
ANNUAL RISK*
Background
1.3E-06
3.3E-06
4.6E-06
--
Treapaaaw
1.4E-03
3.0E-03
5.0E-Q5
4.6E-03
' Total ezceta annual riik - Annual Riik - Riik Cram unavoidable naionl background radiation.

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TABLE 10
SUMMARY OF EXCESS LIFETIME CANCER RISK ESTIMATES FOR
HIGH AND ALDEN STREETS PROPERTIES - FUTURE RESIDENTIAL SCENARIO
US RADIUM SITE
PATHWAY
EXTERNAL GAMMA
RADIATION
INGESTION
Soil
Produce
INHALATION
Radon
Paniculate
TOTAL RISK
TOTAL EXCESS
LIFETIME RISK •
BackfroMd
1.4E-M
1.1E-06
1.2E-05
2.1E-03
9.3E-07
12E-03
--
Resident
&3E-02
4.JE-04
3.3E-03
3. IE -02
4.9E-05
l.OE-01
9.8E-02
• Total excen lifetime risk * Total Riik - Risk from aaavokkMe natural background radiation.

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TABLE 11
SUMMARY OF HAZARD INDICES AND
U.S. RADIUM SITE
EXPOSURE POPULATION
AND PATHWAY
CURRENT SCENARIO
COMMERCIAL WORKER
Inadvertent ingestion of surface soils
Dermal contact with surface soils
Inhalation of volatilized chemicals from surface soils
Inhalation of paniculate matter
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
TRESPASSER
Inadvertent ingestion of surface soils
Dermal contact with surface soils
Inhalation of volatilized chemicals from surface soils
Inhalation of paniculate matter
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
FUTURE SCENARIO
RESIDENT ADULT
Inadvertent ingestion of soils
Dermal contact with soils
Inhalation of volatilized chemicals from soils
Inhalation of paniculate matter
Ingestion of homegrown produce
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RESIDENT CHILD
Inadvertent ingestion of soils
Dermal contact with soils
Inhalation of volatilized chemicals from soils
Inhalation of paniculate matter
Ingestion of homegrown produce
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
COMMERCIAL WORKER
Inadvertent ingestion of soils
Dermal contact with soils
Inhalation of volatilized chemicals from soils
Inhalation of paniculate matter
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
CANCER RISKS
HAZARD INDEX


5E-01
3E-01
N/A
1E-04
8E-01

6E-02
3E-02
N/A
2E-05
1E-01


6E-01
3E-01
3E-04
5E-04
9E-01
2E-HK)

5E-HX)
6E-01
IE-03
3E-03
2E+00
8E-HOO

4E-01
2E-01
6E-05
1E-04
6E-01

CANCER RISK


4E-05
N/A
4E-10
8E-09
4E-05

2E-07
N/A
2E-12
5E-11
2E-07


3E-05
N/A
5E-09
4E-09
3E-04
3E-04

5E-05
N/A
5E-09
4E-09
1E-04
2E-04

1E-05
N/A
9E-10
7E-10
1E-05
N/A - Not Applicable

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                      RESPONSIVENESS SUMMARY
                              FOR THE
                   U.S. RADIUM CORPORATION SITE
                     ESSEX COUNTY, NEW JERSEY

                       SECOND OPERABLE UNIT
I.   INTRODUCTION

This Responsiveness Summary  provides  a  summary  of public comments
and concerns  regarding  the remedial investigation and  feasibility
study  (RI/FS)  report  and  the Proposed Plan  for  the U.S. Radium
Corporation Superfund site.   It also  provides the U.S.
Environmental  Protection  Agency's  (EPA's) responses to those
comments.  EPA has selected  a remedy  for the second operable unit
(OU2)  of the U.S. Radium  Corporation  site after reviewing and
considering all public  comments received during the public
comment period.  OU2  includes the  High  and  Alden Streets
Properties study areas  and four other commercial properties.

A previous Record of  Decision (ROD),  signed September  21, 1993,
selected a remedy for contaminated residential  properties and the
remaining commercial  properties that  comprise the U.S. Radium
site.  These properties are  referred  to as  the  first operable
unit (OU1).

EPA held a public comment period from May 22, 1995 through June
21, 1995 to provide interested parties  with the opportunity to
comment on the OU2 RI/FS  report and the Proposed Plan.  In
addition, EPA held a  public  information meeting to discuss the
remedial alternatives described in the  RI/FS report and to
present EPA's preferred remedy for cleaning up  the site.  The
meeting was held on June  1,  1995 at the Orange  City Hall Council
Chambers located at 29 North Day Street, Orange, New Jersey.

In general, the community responded positively  to EPA's Proposed
Plan.  Residents recognized  the importance  of remediating the
contamination at the  U.S. Radium Corporation site.

The next section of this Responsiveness Summary provides a
comprehensive summary of major questions, comments, concerns, and
responses/ by summarizing oral comments raised  at the public
meeting, written comments submitted during  the  public comment
period, and EPA's responses.

-------
 The  last  section of this  Responsiveness  Summary  includes
 appendices  which document public participation in  the  remedy
 selection process for this site.  There  are  four appendices
 attached  to this Responsiveness Summary." They are as  follows.

          Appendix A contains  the Proposed Plan  that was
          distributed to  the public  for  review and comment.

          Appendix B contains  public notices which appeared in
          The  Orange Transcript and  The  Star-Ledger.

          Appendix C contains  the public meeting transcript.

          Appendix D contains  the index  to the administrative
          record for the  site.

 II.  COMPREHENSIVE SUMMARY OF  MAJOR  QUESTIONS. COMMENTS.
     CONCERNS. AND RESPONSES

 ORAL COMMENTS  RECEIVED DURING  THE PUBLIC MEETING

 This section summarizes oral comments raised at  the public
 meeting and EPA's  responses.   Most of the individuals  at the
 public meeting were homeowners or residents  of properties
 included  in OU1; thus, it is not surprising  that most  of the
 comments  were  directed toward  EPA's  ongoing work to clean up
 affected  OU1 properties.   What follows is a brief  discussion of
 the types of questions and concerns  raised about OU1,  followed by
 a response to  the  questions directed at  EPA's OU2  Proposed Plan.

 First Operable Unit

 Because of the complexity of the U.S. Radium site, with its many
 affected  properties located in several municipalities, a number
 of questions were  directed at  trying to  understand which
properties were  included  in OU1 and which in OU2.  All the
 residential properties have been included in OU1,  along with most
 of the commercial  properties.  OU2 contains only commercial
properties.  The OU2 properties also have in common the fact that
the U.S.  Radium  Corporation appears to have directly operated
 facilities on  each, whereas none of the  OU1 properties appear to
have been used directly by the company.

Other questions were directed  at real estate issues, EPA's
cleanup schedule and general health concerns.  Written responses
to these  types of  questions appear in the Responsiveness Summary
 for the OU1 ROD, which is  available at the Orange and West Orange
Public Libraries,  or from  EPA.

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 Second Operable unit

 Comment:   One interested citizen asked about the  extent of EPA's
 community relations efforts since the start of EPA's  RI/FS.

 Response:  Since the start of the RI/FS in 1990,  EPA  has tried  to
 provide as much information as possible to the community,  and to
 be  responsive to community concerns  about  the site.   Public
 meetings  were held in January 1991,  May 1993 and  June 1995.  Ten
 public availability sessions were also held,  on various dates,
 where  property owners were provided  an opportunity to talk
 individually  with EPA about their property or the project in
 general.   In  addition,  Superfund Updates providing project status
 information were periodically distributed  to hundreds of property
 owners,  residents and interested parties in the study area.  Most
 recently,  the Proposed Plan and a Superfund Update were
 distributed to interested parties.   Notices of the availability
 of  these  documents and of the public meeting were placed in The
 Orange Transcript and The Star-Ledger.   Contact was also made
 with property owners during the property surveys.  Over the past
 four years, EPA has contacted over 350  property owners
 individually  to request access for property investigations.
 These  community relations efforts will  continue throughout the
 remedial  design and remedial  action.

 Comment:   One concerned citizen asked whether anyone  could be
 held liable for future  health problems  resulting  from exposure  to
 site contaminants,  and  what those health problems  might be.

 Response:   Several  successor  corporations  to  the U.S. Radium
 Corporation have  been  identified  as  potentially responsible
 parties for the site; however,  determining whether any  party
 could  be  held liable  for  future health  problems is beyond  the
 scope  of  EPA's  authority.

 Studies have  shown  that long-term exposure  to even low  levels of
 radiation  increases the incidence  of  cancer in  a population.
 However,  it is  important  to recognize that  risk estimates  are
 statistical probabilities of  the  likelihood of  a given  event
 (e.g., an  incidence of cancer resulting  from exposure to site
 contaminants)  taking place within  a population  in  the future.
The translation of these  risk estimates  to  practical,  real-world
 circumstances  is  difficult, and depends  substantially on what
 individuals perceive as an acceptable risk  for themselves  and
their  families.

The primary health threat posed by radium-contaminated material
 from the U.S.  Radium site is  exposure to elevated  levels of radon
gas and radon decay products.  The dominant health concern posed
by the inhalation of radon decay products  is an increased risk of
getting lung cancer.  Gamma radiation emitted by the radium-
contaminated material is also a contributing factor.

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Comment:  One interested citizen asked why EPA hadn't identified
the specific addresses  for the four nonadjacent properties in its
description of OU2.

Response:  Information  about the four properties is available in
the administrative record for the site and, specifically, in the
RI/FS report.  To provide property owners with some degree of
privacy, EPA tries to avoid publicly discussing specific property
addresses when possible.

WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD

EPA received no written comments during the public comment
period.

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         U.S.  Radium Corporation Site
            Responsiveness  Summary
             Second operable  Unit
Appendix A:    Proposed Plan dated May 22, 1995

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 Superfund Proposed Plan-
 EPA
 Region 2-
                                                        U.S.  Radium Corporation Site
                                                                          Second Operable Unit
                                                            High And Alden Streets Properties
                                                                         And Related Properties
                                                                      Essex County, New Jersey
                                -May 22, 1995
PURPOSE OF PROPOSED PLAN

This Proposed Plan describes the remedial
alternatives considered for a discrete group of
properties associated with the U.S. Radium
Corporation Superfund site, and identifies the
preferred remedial alternative with the rationale for
this preference. The properties include (1) the
former radium processing facility at the corner of
High and Alden Streets and several adjacent
properties, and (2) four nonadjacent, nonresidential
properties.  The U.S. Environmental Protection
Agency (EPA) developed this Proposed Plan with
support from the New Jersey  Department of
Environmental Protection (NJDEP). EPA is issuing
the Proposed Plan as part of its public participation
responsibilities under Section 117(a) of the Compre-
hensive Environmental Response, Compensation and
Liability Act of 1980, as amended by the Superfund
Amendments and Reauthorization Act (CERCLA),
and Section 300.430(f) of the National Oil and
Hazardous Substances Pollution Contingency Plan.
EPA is simultaneously issuing a remedial
investigation and feasibility study (RI/FS) report,
which describes the nature and extent of contam-
ination and the remedial  alternatives summarized
here.  The RI/FS report  should be consulted for a
more detailed description of all the alternatives.

EPA has placed the RI/FS report at two information
repositories: the Orange Public Library,  located at
348 East Main Street in Orange, New Jersey; and the
West Orange Public Library located at 46 Mount
Pleasant Avenue in West Orange, New Jersey.
Additional documentation regarding the proposed
remedy is available in the administrative record for
the site.  Copies of the administrative record, as
assembled to date, are located at the Orange Public
Library and at EPA's offices at 290 Broadway, New
York, New York.
The remedy described in this Proposed Plan is the
preferred remedy for the site.  Changes to the
preferred remedy, or a change from the preferred
remedy to another remedy, may be made if public
comments or additional data indicate that such a
change will result in a more appropriate remedial
action.  Because EPA may select a remedy other
than the preferred remedy, EPA is soliciting public
comment on all of the alternatives considered in the
detailed analysis of the RI/FS. The final decision
regarding the selected remedy will be made after
EPA has taken into consideration all public
comments.

COMMUNITY ROLE IN SELECTION PROCESS

EPA and NJDEP rely on public input to ensure that
the remedy selected for  each Superfund site is fully
understood by the public and that the agencies have
considered the concerns of the local  community, as
well as to ensure  that the selected remedy provides
an effective solution.

This Proposed Plan and the RI/FS report are being
made available to the public during the public
comment period.  Written comments on the
Proposed Plan or the RI/FS report will be welcomed
through June 21,  1995, and, if received by that date,
will be considered in a Record of Decision (ROD)
which will formally document the selected remedy.
All written comments should be addressed to:

    Mr. John Prince, Remedial Project Manager
          New Jersey Superfund Branch I
 U.S. Environmental Protection Agency - Region II
                 290 Broadway
         New York, New York 10007-1866

The final remedy selected will be documented in a
ROD  only after consideration of all comments on

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 any of the remedial alternatives addressed in the
 Proposed Plan and RI/FS report. A public meeting
 has been scheduled for June 1, 1995, at 7:00 p.m. at
 the Orange City Hall Council Chambers, located at
 29 North Day Street in Orange, to present both the
 findings of the RI/FS report and the Proposed Plan.
    MARK YOUR CALENDAR:

         May 22, 1995 through June 21,1995

    Public Comment Period - written and oral
    comments solicited on RI/FS report and this
    Proposed Plan

                    June 1, 1995

    Public meeting at the Orange City Hall
    Council Chambers, 29 North Day Street, at
    7:00 pm.
   Copies of the RI/FS report, Proposed Plan, and
   supporting documentation  are available at the
   following locations:

   Orange Public Library
   348 Main Street

   West Orange Public Library
   46 Mount Pleasant Avenue
DESCRIPTION OF STUDY AREAS

The U.S. Radium Corporation site comprises
radium-contaminated properties within three study
areas, located primarily in the City of Orange, Essex
County, New Jersey. EPA refers to the three study
areas as the "High and Alden Streets Properties", the
"Vicinity Properties" and the "Satellite Properties".
The three study areas are described below:

High and Alden Streets Properties

     These properties are the location of the former
     U.S.  Radium Corporation radium-processing
     facility, which operated from approximately
     1915 to 1926, and several  adjacent properties
      contaminated as a result of activities at the
      processing facility.  The study area occupies
      approximately two acres at the southwest corner
      of High and Alden  Streets in Orange. Wigwam
      Brook runs in a concrete channel along the
      south side of the study area.

 Vicinity Properties

      These are properties in the vicinity of the High
      and Alden Streets Properties, some of which
      contain radium-contaminated material. This
      study area includes  over 300 properties on
      about 25 acres in Orange and West Orange.

 Satellite Properties

      These properties include noncontiguous
      residential and commercial properties at which
      radium-containing materials may have been
      handled or disposed of, in addition to former
      residences of employees of the U.S. Radium
      Corporation. This group includes about 50
      properties located mostly in Orange, with a few
      properties in the municipalities of East Orange
      and South Orange.

DESCRIPTION OF OPERABLE UNITS

As with many Superfund  sites, the problems at the
U.S. Radium Corporation site are complex. As a
result, EPA has organized the site into separate
phases or operable units.  This Proposed Plan
addresses the second operable unit (OU2) for this
site.

The first operable unit (OU1) included all the
residential properties in the Satellite and Vicinity
Properties study areas where radium-contaminated
material was detected. OU1 also included all but
four of the nonresidential properties in the Vicinity
and Satellite Properties study areas.

The second operable unit (OU2) includes the all of
the High and Alden Streets study area, including the
former processing plant and several adjacent
properties. OU2 also includes the four non-
residential, nonadjacent properties not addressed in
OU1.  Two of these four nonadjacent OU2
properties appear to have been dial painting
facilities; a third was a U.S. Radium-operated
laboratory. The fourth property appears to have
been an experimental thorium handling operation.

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 SITE BACKGROUND

 The U.S Radium Corporation, formerly known as the
 Radium Luminous Materials Corporation, operated
 a facility at High and Alden Streets in Orange from
 1915 through  1926. Its primary activity at this
 location was the extraction and purification of
 radium from carnotite ore.  Each ton of ore
 produced only 5 to 7 milligrams of radium; thus,
 large volumes of ore were required.  Large quantities
 of process wastes, or "tailings", were generated,
 containing radioactive elements at elevated levels.
 The tailings were temporarily discarded on unused
 areas of the facility and ultimately disposed of off the
 site.

 In addition to the production and sale of radium
 itself, the  U.S. Radium Corporation also
 manufactured a radium-based luminous paint.  At
 one time,  the  company employed over 100 workers
 to paint instruments and watch dials with this
 luminous paint.  Reports indicate that dial painting
 took place at the High and Alden Streets Properties
 and at several Satellite Properties.

 U.S. Radium Corporation discontinued radium
 processing operations in 1926, while continuing its
 dial painting business. U.S. Radium subsequently
 sold its properties at High and Alden Streets in the
 1940s.  No subsequent occupants of the properties
 are known to have processed or used radium.

 EPA and NJDEP began investigating former radium
 processing facilities, including the High and Alden
 Streets facility, in the early 1980s. The investigations
 of U.S. Radium lead to the identification  of several
 large areas in  the nearby communities of  Montclair,
 West Orange and Glen Ridge where radium-
contaminated soil had been deposited; the affected
properties in these areas comprise two other
Superfund sites, the Montclair/West Orange Radium
site and the Glen Ridge Radium  site (MWG sites).

In 1982, the U.S. Radium site was proposed for
inclusion on the National Priorities List (NPL) of
Superfund sites.  The site was placed on the NPL in
September 1983.

In July 1983, EPA notified five companies and one
individual  that they had been identified as potentially
responsible parties (PRPs) for the site.  EPA
requested  a response outlining the activities that the
PRPs would be willing to undertake.  One PRP,
 Safety Light Corporation, a corporate successor to
 U.S. Radium, responded that it was willing to
 perform response activities at the site.

 In 1983, EPA and Safety Light Corporation
 commenced the first of several unsuccessful efforts to
 negotiate an agreement whereby Safety Light would
 undertake response activities at the site, under EPA
 supervision. The last of these efforts ended in
 December 1988 when Safety Light declined to
 perform any work, other than to replace the
 inadequate security fence around the High and
 Alden Streets Properties.  Safety Light began the
 fence construction in 1989; however, EPA completed
 the work because of problems with health and safety
 procedures. The PRPs have not agreed to perform
 any additional work.

 The chronology of EPA and NJDEP site
 investigations and activities have been described in
 two RI/FS reports, available at the information
 repositories identified on page 2 of this Proposed
 Plan, or from EPA. The information repositories
 also include reports describing two removal actions
 performed at site properties:  the 1989 fence
 replacement described above; and in 1991, the
 installation of radon mitigation systems and gamma
 shielding at four OU1 properties and a radon
 mitigation system in one OU2 property.

 For further information on the selected remedy for
 the OU1 properties, please refer to a first Record of
 Decision (ROD) for the site, signed on September
 21, 1993, also available at the information
 repositories or from EPA. The selected remedy for
 the OU1 properties involves excavation and off-site
 disposal of the radium-contaminated material.

 Regarding the OU1 selected remedy, the remedial
 design associated with the first group of OU1
 properties is currently being prepared. It  is
 anticipated that remedial construction activities at
these properties will begin in 1995. Further
 information on the OU1 remedy is available from
EPA.

For further background information about the site,
please  refer to the documents mentioned here and
available at the information repositories.

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             U.S. RADIUM CORPORATION SITE
               Vicinity Properties Study Aiea
T/ie Satellite Properties study area includes discrete properties located in several
communities, and cannot be similarly represented.

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 THE NATURE OF RADIONUCLIDES

 A radionuclide is an element that spontaneously
 changes, or "decays" into another element through
 natural processes. Radionuclides are present in trace
 amounts in all rocks and soils, and consist primarily
 of elements of the uranium-238 and thorium-232
 decay series.  When radionuclides decay, they emit
 energy in the form of radiation. The decaying
 radionuclide is often called the "parent", and the
 radionuclide that is produced is referred to as the
 "decay product".  A quantity of radioactive material
 is measured by its rate of decay, expressed by the
 unit Curie (Ci), which is equal to 2.22 x 10U (2.22
 trillion) disintegrating atoms per minute. A more
 convenient unit for expressing environmental
 radioactivity is the picoCurie (pCi), which is equal to
 1 x 10'u (one trillionth) Ci.

 Radium-226 is a naturally occurring, radioactive,
 metallic element formed from the decay of uranium.
 Radium, in turn, decays, with the formation  of radon
 gas.  Radon gas is colorless, odorless, radioactive and
 inert; therefore, it can move easily through soil  to
 the ground surface or into houses. Within a matter
 of days, the radon gas itself decays into  a series of
 radioactive decay products.  While radon gas in the
 outdoor air dissipates quickly, inside a house, the
 concentration of radon decay products in the indoor
 air can build up over time. Adverse health affects
 have been shown to result from  the exposure to the
 energy released by these various decays, referred to
 collectively as "ionizing radiation".

 EPA has developed health guidelines for limiting
 exposure to ionizing radiation from radium and other
 sources.  In order to further ensure protectiveness,
 those health guidelines can be supplemented by
 selecting response actions which reduce  exposures
 resulting from ionizing radiation to levels that are As
 Low As Reasonably Achievable (ALARA) taking
 into consideration technical, economic and social
 factors.

 EPA recommends that indoor radon concentrations
 should not exceed 4 picoCuries/liter of air (pCi/1).
 In 40  CFR 192, "Standards for Cleanup of Land and
 Buildings Contaminated with Residual Radioactive
 Materials From Inactive Uranium Processing Sites",
 EPA promulgated standards for  limiting exposure to
 radon decay products, gamma radiation, and radium.
 While this regulation is not applicable to this site
because it is not an inactive uranium processing site,
 EPA promulgated standards for, parts of 40 CFR 192
 are considered relevant and appropriate.  The
 relevant portions include the limiting of exposure to:
 (1) radon decay products to levels less than 0.02
 Working Levels (WL) (exposure to 4 pCi/1 of air for
 radon corresponds to an approximate annual average
 exposure of 0.02 WL for radon decay products); (2)
 gamma radiation to  20 micro-Roentgens/hour
 (|iR/hr) above the background rate; and (3) radium
 concentration to 5 picoCuries/gram (pCi/g) above
 background averaged over  100 square meters (120
 square yards) of surface soil.  As noted in the initial
 ROD for the site, the 40 CFR 192 standard of 15
 pCi/g in sub-surface soil (below 15 centimeters) is
 not considered relevant and appropriate for this site;
 the 5 pCi/g standard is considered relevant and
 appropriate for both surface and subsurface soil.

 The U.S. Nuclear Regulatory Commission (NRC)
 has set guidelines for decontamination of building
 surfaces and equipment prior to tlieir release for
 unrestricted use from facilities that process
 radioactive materials.  The limits for radium
 contained within these guidelines are To-Be-
 Considered guidelines with regard  to this site and,
 therefore, provide a  set of criteria to determine
 which structures and above-ground debris pose an
 unacceptable risk of radiation exposure.

 REMEDIAL INVESTIGATION SUMMARY

 In 1990, EPA initiated an RI to characterize the
 nature and extent of contamination at the High  and
 Alden Streets, Vicinity and Satellite Properties study
 areas.  Field studies for all  study areas began  in
 August 1991. In April 1993, EPA released the OUl
 RI/FS report, presenting the results of field
 investigations conducted at Vicinity and Satellite
 Properties. The OU2 RI/FS report released
 concurrently with this Proposed Plan presents the
 results of field investigations conducted at the High
 and Alden Streets Properties study area and  four
 non-residential nonadjacent properties not included
 in OUl.  The OU2 RI/FS report also discusses
 investigation of ground water to date; however, the
 results of EPA's ground water investigation are
inconclusive, and further evaluation will be
undertaken.

 Soil and Construction Material Investigations

Properties included in OU2 were surveyed for
radioactive materials to define the limits of

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contamination.  Radiological investigations included
the collection of radon gas samples from inside
buildings, and interior/exterior surveying of each
property to identify areas of elevated gamma
radiation.  Wherever elevated gamma radiation
readings were detected, additional samples were
collected to characterize the extent of contaminants
present.

Because of the long and varied history of industrial
use at the High and Alden Streets Properties study
area, additional field investigations were performed
to augment the studies described above. Surface and
subsurface soil  samples were collected and analyzed
for selected radionuclides and nonradiological,
chemical analyses for metals, volatile organic
compounds (VOCs), semi-volatile organic
compounds, pesticides and polychlorinated biphenyls
(PCBs).

The  following is a summary of the RI findings.

High and Alden Streets Properties

     •    Soil contaminated with radium and other
          radionuclides is found on a substantial
          portion of the High and Alden Streets
          Properties study area. Radiological
          contamination is present in some locations
          to a depth of 15 feet.  An estimated  18,000
          cubic yards of soil have elevated radium
          concentrations. In addition, approximately
          110 cubic yards of structural material are
          similarly contaminated.

     •    Gamma radiation exposure rates
          associated with contaminated soils range
          from background (less than 10 |iR/hr) to
          700 uR/hr. All buildings on the High and
          Alden Streets Properties contain elevated
          levels of radon gas, with levels ranging
          from 12.7 pCi/1 to  110 pCi/1.  Elevated
          concentrations of both fixed and
          removable building surface contamination
          are detected in some of the older on-site
          structures.

     •    Soil samples collected and analyzed for
          chemical (non-radiological) contaminants
          indicate the presence of low levels of some
          contaminants  (metals and semi-volatiles)
          in soils at the High and Alden Streets
          Properties. Chemical soil contamination is
          sporadic.

 Four Nonadiacent OU2 Properties

      •    Studies of the four nonadjacent OU2
          properties indicated the presence of
          elevated levels of radiological
          contamination.  Three properties contain
          elevated levels of radium, found in both
          soil and structural materials, resulting in
          elevated gamma radiation levels.  Elevated
          radon levels, along with elevated levels of
          both fixed and removable building surface
          contamination, were detected at one
          property.  The fourth property is the only
          property investigated as part of the site
          contaminated with thorium-232 (Th-232).
          Approximately 400 cubic yards of
          contaminated soil and 40 cubic yards of
          contaminated structural material were
          found at these four properties.

Wigwam Brook and Ground Water Investigations

Surface water and stream sediments were collected
from Wigwam Brook and analyzed for radiological
and chemical contaminants.  Four ground water
monitoring wells were installed at the High and
Alden Streets Properties study area. These four
wells and four existing wells (one municipal supply
well, one commercial production well and two private
monitoring wells) were sampled and analyzed for
radionuclides and chemical contaminants. The
findings of the RI are summarized below.

     •    No elevated radiological contamination
          was found in surface water or sediment
          samples from Wigwam Brook.

     •    No chemical contamination attributable to
          the site was found in surface water or
          sediment samples from Wigwam Brook.

     •    Elevated uranium concentrations were
          detected in EPA's monitoring wells IS and
          3, and an elevated radium concentration
          was detected in EPA monitoring well IS.
          No other ground water sampling locations
          had elevated levels of radionuclides.

     •    VOCs, including tetrachloroethylene
          (PCE), trichloro-ethylene  (TCE) and 1,2-

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           dichloroethylene (1,2-DCE), were detected
           in EPA monitoring wells above federal or
           state Maximum Contaminant Levels
           (MCLs) for drinking water.

      •    VOCs were also detected in the municipal
           and non-potable, private wells sampled
           over an area covering about one square
           mile around the site. No definite pattern
           of VOC contamination was evident, nor
           could a defined plume of ground water
           contamination be identified. (Municipal
           drinking water  supply wells in the area
           have treatment systems  to remove VOCs;
           there are no known private drinking water
           wells located near the site.)

 Because EPA monitoring  wells are contaminated
 with site-related and potentially unrelated
 contaminants, and information is currently not
 available to determine the extent to which site-
 related contaminants may be migrating into the
 ground water,  EPA will further investigate the
 nature and extent of ground water  contamination. In
 summary, site activities do not appear to be
 adversely impacting Wigwam Brook. Local
 municipal water supply wells are not contaminated
 with radionuclides.

 SUMMARY OF SITE RISKS

 During the OU2 RJ/FS, EPA performed a baseline
 risk assessment of exposure to contaminants at the
 U.S. Radium Corporation site. This baseline risk
 assessment estimates the human health risk which
 could result from the contamination at the site if no
 remedial action were taken.

 To evaluate human health risks, a four-step process
was used for assessing site-related risks for a
 reasonable maximum exposure scenario. These steps
are: Hazard Identification - identified the contami-
 nants of concern at the site based on several factors
such as toxicity, frequency of occurrence, and
concentration;  Exposure Assessment - estimated the
 magnitude of actual and/or potential human
exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting
contaminated soil) by which humans are potentially
exposed; Toxicitv Assessment - determined the types
 of adverse health effects associated with exposures to
site contaminants, and the relationship between
magnitude of exposure (dose) and severity of adverse
 effects (response); and Risk Characterization -
 summarized and combined outputs of the exposure
 and toxicity assessments to provide a quantitative
 (e.g., one-in-a-million excess cancer risk) assessment
 of site-related risks.

 For risk assessment purposes, individual
 contaminants are typically separated into two
 categories of health hazard depending on whether
 they exhibit carcinogenic or noncarcinogenic effects.
 Radionuclides (e.g., radium, thorium, radon, radon
 decay products) are known carcinogens.
 Nonradiological, "chemical" contaminants (e.g.,
 polyaromatic hydrocarbons [PAHs], barium,
 vanadium, cadmium and lead) may exhibit both
 carcinogenic and noncarcinogenic health effects.

 Current federal guidelines for acceptable exposures
 are an individual lifetime excess carcinogenic risk in
 the range of 10"* to 10"6, representing an increased
 probability of one in ten thousand  to one in one
 million that an individual could develop cancer
 resulting from exposure to site-related contaminants,
 and a maximum health Hazard Index (which reflects
 noncarcinogenic effects for a human receptor) equal
 to 1.0. (A Hazard Index greater than 1.0 indicates a
 potential for noncarcinogenic health effects.)  It must
 be noted, however, that the risk posed by naturally
 occurring background radiation appears high when
 compared to the potential risk posed by
 nonradiological carcinogens. During the RI, natural
 background radiation was measured and used to
 estimate the risk of cancer to the general public.
 The risk of cancer to the public was estimated to be
 2 x 10'3, representing a probability of two in one
 thousand that an individual could develop cancer
 resulting from exposure to natural background
 radiation. The excess risk to individuals at
 contaminated properties has been evaluated with
 respect to this background risk.

To evaluate human health risk, several exposure
pathways were selected for detailed evaluation under
current land-use conditions.  In addition, potential
future land-use conditions were considered for the
High and Alden Streets Properties.

All of the current land-use conditions involved the
potential exposure of workers or occupants of
commercial  properties, and trespassers on unused
properties.  Conversion from commercial to
residential use was considered as a future scenario
for the High and Alden Streets Properties, resulting

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 in potential exposures to residents.  The exposure
 pathways were similar for current and future land-
 use situations: inhalation of radon decay products;
 exposure to external gamma radiation emanating
 from radium-contaminated material; ingestion of
 radionuclides in soil; and inhalation of radium-
 contaminated particulates. In addition, a future
 residential land-use condition resulted in several
 added exposure pathways for on-site residents:
 ingestion of radionuclides, cadmium and vanadium,
 either from inadvertent ingestion of soil or in locally
 grown produce.

 In all current and future land-use situations,
 inhalation exposure to radon decay products is
 consistently the major contributor to the total cancer
 risk that may be incurred by individuals at
 contaminated properties. Exposure  to gamma
 radiation also provides a significant component of
 the overall radiogenic cancer risk.  Ingestion of
 radium, cadmium  and vanadium is several orders of
 magnitude lower in risk than that of the other two
 pathways. Inhalation exposure to paniculate radium
 is an insignificant contributor to the  total risk.

 For  the four nonadjacent OU2 properties, the
 estimated excess lifetime cancer risk ranged up  to 5 x
 10'3 (five in one thousand).  For the  High and Alden
 Streets Properties, the estimated excess lifetime risks
 under current and future land-use conditions were 1
 x 10"2 (one in one hundred) and 2 x 10"1 (two  in ten),
 respectively.

 Exposure to chemical (nonradiological) contaminants
 under future land-use conditions contributed a
 marginally elevated Hazard Index and cancer risk at
the High and Alden Streets Properties study area;
 however, these risks are trivial relative to those
 resulting from radionuclide exposure.

 Unusually high concentrations of naturally occurring
radon have  not been associated with the
communities where OU2 properties are located.
 Exposure to elevated levels of gamma radiation, and
the pathways for the inhalation and ingestion of
radium, pose risks not typically encountered in areas
of naturally occurring radon.  The close proximity of
the radium-contaminated soil to the ground surface
or radiological contamination in building construction
material at contaminated properties is the main
reason for these additional risks.
 An evaluation of ecological risk was not conducted as
 part of OU2.  It was determined in OU1 that,
 because of the urban setting associated with the
 contaminated areas, the likelihood of contact of
 contaminants with ecological receptors was minimal.
 For example, Wigwam Brook serves primarily as a
 stormwater drainage culvert in this area.  The one
 possible exception would be receptors down stream
 of Wigwam Brook; however, because of the length of
 time since the original deposition of material and the
 lack of any current releases from the High and Alden
 Streets Properties study area into the brook, the
 likelihood of exposure  is considered minimal.

Actual or threatened releases of hazardous
 substances from this site, if not addressed by the
preferred alternative or one of the other active
measures considered, may present a current or
potential threat to public health, welfare, or the
environment.

SCOPE AND ROLE OF ACTION FOR OU2
PROPERTIES

As described above, this Proposed Plan addresses the
second operable unit for the site and identifies the
preferred remedy for the High and Alden Streets
Properties study area and four nonadjacent
properties not addressed in the first operable unit.

Remedial Action Objectives

EPA proposes the following remedial action
objectives for this second operable unit of the U.S.
Radium Corporation site:

     •    Reduce exposure to radon gas levels in
          excess of 4 pCi/1 and radon decay
          products in excess of 0.02 WL.

     •    Reduce exposure to gamma radiation
          emitted from radium-contaminated
          material resulting from site sources with
          radium concentrations in excess of 5
          pCi/g, employing ALARA principles.

     •    Prevent ingestion of and general contact
         with radium-contaminated material
          resulting from site sources with radium
          concentrations in excess of 5 pCi/g,
          employing ALARA principles.

-------
 These remedial action objectives are similar to those
 selected for the Montclair/West Orange and Glen
 Ridge Radium (MWG) sites and for OU1 of this site
 and would, at minimum, achieve the cleanup criteria
 in 40 CFR 192. Region II has determined that the 5
 pCi/g standard found in 40 CFR 192 is relevant  and
 appropriate for cleanup at the U.S. Radium  site.

 In achieving the remedial action objectives for OU2,
 EPA would rely on the ALARA principles used at
 the MWG sites during implementation of the
 response action. Applying ALARA principles means
 taking additional measures during remedial action,
 beyond those required to meet a specified cleanup
 goal, to assure protectiveness. Applying the  5 pCi/g
 standard with ALARA principles at the MWG sites
 has resulted in exposure levels that are lower than
 the levels that would result from using the 5  pCi/g
 standard alone. An ALARA approach is being used
 at the  MWG sites  because of the long-lived nature of
 radionuclides,  the difficulty in eliminating routes  of
 exposure, limitations of the analytical equipment  to
 detect  radionuclides, and site-specific factors which
 may make it necessary to remove material at levels
 below 5 pCi/g to achieve adequate public health
 protection.

 Certain structures and above-ground debris at the
 affected properties are contaminated with radium.
 Any remedial alternative considered for these
 properties would be expected to satisfy the NCR
 guidelines for surface contamination or, as
 appropriate, the remedial action objectives employing
 ALARA principles to help ensure protectiveness.

 EPA's  experience at the MWG sites has shown that
 the remedial action objectives noted above can be
 achieved and, by incorporating ALARA principles,
 result in no elevated radon or gamma radiation levels
 at the surface.  Therefore, by using similar remedial
 action objectives, the U.S. Radium site would pose
 no unacceptable risk for residential uses after
 cleanup, and would result in a cleanup that is
 protective under CERCLA.

 Vanadium and  cadmium were detected in some
 samples collected at the High and Alden Streets
 Properties study area at levels that exceed
 background for those metals; the levels pose some
 marginal risk in several future-use scenarios.  The
 areas of radionuclide-soil contamination appear to be
contiguous with the areas of vanadium/cadmium
contamination.  The remedial alternatives considered
 below take into account the metals contamination, in
 that the limited options available for mitigating the
 radium-contaminated soil would also adequately
 address the metals contamination at the levels
 detected.

 FEASIBILITY STUDY

 The information obtained from the RI was used to
 conduct the FS. The FS report provides a detailed
 evaluation of various options, referred to as remedial
 alternatives, to address the site.

 Summary of Remedial Alternatives

 CERCLA requires that each selected  site remedy be
 protective of human health and the environment,
 comply with applicable or relevant and appropriate
 requirements (ARARs), utilize permanent solutions
 and alternative treatment technologies or resource
 recovery technologies to the maximum extent
 practicable, and be cost-effective. In addition, the
 statute includes a preference for the use of treatment
 as a principal element for the reduction of toxiciry,
 mobility, or volume of hazardous substances.

 Alternative 1: No Action

 Estimated Capital Cost:                    $ 0
 Estimated Annual Operation &
  Maintenance (O&M) Costs:               $ 0
 Estimated Present Worth:                  $ 0
 Estimated Implementation Timeframe:    none

A No Action alternative is evaluated for every
Superfund site to establish a baseline for comparison
with remedial alternatives.  Under this alternative,  no
further action would be taken to reduce exposure to
 radioactive materials at these properties.  The
temporary radon mitigation system already installed
at one OU2 property during the  1991  removal action
would remain in place, but there would be no
provision for operation and maintenance.  No
additional measures would be taken to reduce
exposures at properties that are not presently  being
addressed.  Even with a long projected life for the
radon mitigation system, it is assumed that it would
eventually fail and that indoor concentrations  of
radon and radon decay products would return to the
pre-mitigation conditions.

-------
                                                   10
 Because hazardous substances would remain at the
 OU2 properties above acceptable levels, five-year
 reviews would be required.
Alternative 2:  Institutional and Engineering Controls

Estimated Capital Cost:               $12,716,000
Estimated Annual O&M Costs:       $   107,000
Estimated Present Worth:             $13,740,000
Estimated Implementation Timeframe:     3 years

This alternative involves the implementation of one
or more of the following engineering controls, as
determined to be necessary, in areas where
contamination has been identified and measures have
yet to be taken:

      •    Installation of systems to reduce indoor
          concentrations of radon and radon decay
          products;

      *    Installation of indoor gamma radiation
          shielding;

     •    Outdoor gamma radiation shielding where
          necessary; and

     •    In some cases, installation of fencing to
          restrict property access.

During  implementation of this action, temporary
relocation of some businesses may be required.
Institutional controls (e.g., municipal or health
ordinances, land-use restrictions) would also be
necessary to ensure the effectiveness of the
engineering controls.

Operation and maintenance of the action would also
be necessary, to assure the continued protectiveness
of the engineering controls. Because radium, which
persists for thousands of years, would not be
removed from the properties, the need for O&M
would continue for many years; however, for cost-
estimating purposes, O&M costs for maintaining the
radon mitigation systems and gamma radiation
shielding have been assumed for a period of 30
years. Because hazardous substances would remain
at the OU2 properties above acceptable levels, five-
year reviews of the remedy would be required.  This
alternative would take approximately three years to
implement.
Alternative 3: On-site Containment

Estimated Capital Cost:              $ 10,771,000
Estimated Annual O&M Costs:       $   128,000
Estimated Present Worth:            $ 11,990,000
Estimated Implementation Timeframe:    2 years

Under this alternative, radium-contaminated
buildings at the High and Alden Streets Properties
and one nonadjacent OU2 property would be
dismantled.  The dismantled building debris would be
sent to an appropriate off-site disposal facility. Soil
from the four nonadjacent OU2 properties would be
excavated and replaced with clean fill.  The excavated
material from these four properties would be brought
to the High and Alden Streets Properties study area
for long-term containment. A containment facility
would be constructed by installing a cap and slurry
wall over the radium-contaminated soil at the High
and Alden Streets Properties study area.

During implementation of this action, temporary or
permanent  relocation  of businesses would be
required at some properties.  Chemical
(nonradiological) soil contamination found at the
High and Alden Streets Properties would also be
enclosed under a cap.   Engineering and institutional
controls similar to those described under Alternative
2 would be required for the High and Alden Streets
Properties; however, the four nonadjacent OU2
properties would be available for unrestricted use.
Because hazardous substances would  remain at the
High and Alden Streets Properties study area above
acceptable levels, five-year reviews of the remedy
would be required to assure the continued
effectiveness of the remedy.  This alternative would
take approximately two years to implement.

Alternative 4:  Excavation and Off-site Disposal

Estimated Capital Cost:              $ 22,030,000
Estimated Annual O&M Costs:        $        0
Estimated Present Worth:            $ 22,030,000
Estimated Implementation Timeframe:    2 years

Under this alternative, radium-contaminated material
would be excavated or otherwise removed from
contaminated properties, and replaced with clean fill
or otherwise restored.   It is estimated that
approximately 18,400 cubic yards of soil and 150
cubic yards of construction material are
contaminated with radionuclides.  Contaminated

-------
                                                    11
 material would be transported for final disposal at an
 appropriate, off-site facility.

 Based on experience at this site and the MWG sites,
 material contaminated above background  levels
 would not remain within the first two feet of a
 remediated property. In addition, based on data
 available for the site and EPA's experience,
 residually contaminated material remaining on
 remediated properties would not be greater than two
 feet in thickness.

 During implementation of this action, relocation of
 businesses would be required at some properties.  In
 addition, demolition of certain OU2 property
 buildings may be required because of the  unique
 contaminant distributions at those properties.
 Excavation and off-site disposal of radium-
 contaminated soil from the High and Alden Streets
 Properties would also remove  nonradiological,
 chemical contamination found in the soil.  Because
 this alternative would not result in elevated levels of
 radionuclides remaining on any property, a five-year
 review of the effectiveness of the remedy would not
 be required.  This alternative would take
 approximately two years to implement.

 EVALUATION OF ALTERNATIVES

 During the detailed evaluation of alternatives,  each
 alternative is assessed against nine evaluation
 criteria. The nine criteria are  described below.

 Overall Protection of Human Health and the
 Environment

     This criterion addresses whether or not a
     remedy provides adequate protection and
     describes how risks are eliminated, reduced or
     controlled through treatment, engineering
     controls or institutional controls.

Compliance with Applicable or Relevant and
Appropriate Requirements of Federal or State of
New Jersey Regulations

     This criterion addresses whether or not a
     remedy  will meet all of the applicable or
     relevant and appropriate requirements of other
     environmental statutes and/or provide grounds
     for invoking a waiver.
 Long-Term Effectiveness and Permanence

      This criterion refers to the ability of the remedy
      to maintain reliable protection of human health
      and the environment over time once cleanup
      goals have been met.

 Reduction of Toxicity, Mobility and Volume Through
 Treatment

      This criterion addresses the anticipated
      performance of the treatment technologies that
      a remedy may employ.

 Short-Term Effectiveness

      This criterion involves the period of time
      needed to achieve protection and any adverse
      impacts on human health and the environment
      that may be posed during the construction and
      implementation period until cleanup goals are
      achieved.

 Implementability

      This criterion examines the technical and
      administrative feasibility of a remedy, including
      availability of materials and services needed to
      implement a particular option.

 Cost

     This criterion includes capital operation and
      maintenance costs, and net present worth.

 State Acceptance
     This criterion indicates whether, based on its
     review of the RI/FS reports and the Proposed
     Plan, the State concurs with, opposes, or has no
     comment on the preferred alternative at the
     present time.

Community Acceptance

     This criterion will be addressed in the Record
     of Decision following a review of the public
     comments received on the RI/FS reports and
     the Proposed Plan.

The remedial alternatives are evaluated utilizing the
above criteria. A discussion of these evaluations is
presented below.

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                                                    12
 PREFERRED ALTERNATIVE

 The preferred alternative for the remediation of the
 U.S.  Radium Corporation site  OU2 properties is
 Alternative 4, Excavation and Off-site Disposal. A
 comparison of the remediation alternatives follows.

 Overall Protection of Human Health and the
 Environment

 Alternative 1, No Action, is not protective of human
 health and the environment because the risks
 associated with contaminated properties would
 persist for the foreseeable future.  Alternatives 2 and
 3 reduce the possibility of exposure to contaminated
 material and, therefore, reduce human health risks
 associated with the site.

 Alternative 4 is protective of human health and the
 environment because it removes contamination from
 the site.

 Compliance with ARARs

 No requirements have been determined to be
 applicable to the remediation of the OU2 properties.
 However, as  discussed earlier, portions of the federal
 regulations governing the cleanup of uranium mill
 tailings from inactive uranium processing sites, 40
 CFR  192, have been determined to be relevant and
 appropriate.

 Health- or risk-based standards include an annual
 average exposure guideline of no more than 4 pCi/1
 of air for radon, which corresponds to an
 approximate  annual average exposure of 0.02 WL for
 radon decay products. Additionally, the standards
 for  the cleanup of radium-contaminated material
 require that the concentration of radium-226,
 averaged over an area of 100 square meters (120
 square yards) of surface soil, be no greater than 5
 pCi/g. For this site, the 5 pCi/g cleanup standard
 also applies to subsurface soils.

Alternative 1 does not satisfy any of the human
 health standards. Alternatives 2 and 3 satisfy human
health standards by reducing exposures to radiation
in excess of natural background levels; however,
continued operation and maintanence are required
 to assure continued attainment  of these standards.
Alternative 4 satisfies human health standards by
removing the source of exposures to radiation in
excess of natural background levels.
 Alternatives 2, 3 and 4 would satisfy the threshold
 requirements of overall protection of human health
 and the environment with regard to chemical
 (nonradiological) contaminants.

 Because Alternative 1, No Action, does not meet the
 threshold requirements of overall protection of
 human health and the environment or compliance
 with ARARs, it will not be considered further  in the
 evaluation of alternatives.

 Long-Term Effectiveness And Permanence

 Alternative 2 provides essentially no long-term
 effectiveness or permanence. Alternative  3 provides
 a marginally more effective long-term solution.  It
 would be difficult, however, to maintain a  waste
 disposal facility containing radioactive wastes with
 long half-lives (about 1,600 years for Ra-226) in a
 densely populated area. Alternative 3 would allow
 for unrestricted future use of the four nonadjacent
 OU2 properties, but not the High and Ald^n Streets
 Properties.  Alternative 4  is fully effective  in the
 community for the long term, would allow  for
 unrestricted use of all the OU2 properties, and is
 considered a final remedial solution.

 Reduction of Toxiciry, Mobility and Volume Through
 Treatment

 No treatment technology is known today that can
 effectively reduce the toxicity, mobility or volume of
 the radioactive contamination to the site-specific
 cleanup criteria specified given the soil  matrix found
 at the OU2 properties.  The total amount  of
 radioactivity cannot be altered or destroyed, as is
 often possible with chemical contaminants.
 Therefore, none of the remedial alternatives
 considered fully satisfy this evaluation criterion.

 Short-Term Effectiveness

Alternatives 2, 3 and 4 provide effective short-term
protection, and become  effective as they are
 implemented at individual properties. Any adverse
 short-term impacts during implementation  (such as
the creation of dust) can be controlled through the
 use of measures such as dust suppression techniques.

Alternative 2 involves less intrusive activities and
poses less of a threat to workers and the surrounding
community than Alternative 3 or 4. Alternatives 3
 and 4 require a comparable period of time to

-------
                                                    13
 implement, two years.  However, Alternatives 2, 3
 and 4 involve intrusive activities, including, in some
 cases, temporary or permanent relocation of
 businesses. Alternatives 3 and 4 have a greater
 potential adverse impact in the short term because of
 the removal of radium-contaminated material,
 including the excavation of soil. Engineering controls
 would be required to minimize the impacts of these
 alternatives.

 Implementability

 The indoor remedial activities associated with
 Alternative 2 are generally straightforward to
 implement and have been successfully implemented
 at other sites. Extensive outdoor gamma radiation
 shielding techniques have not been attempted or fully
 demonstrated and, therefore, may create some
 difficulties.  State, County and Municipal authorities
 would need to be involved in the process of
 implementing the necessary institutional controls for
 Alternatives 2 and 3.

 Alternatives 3 and 4 involve the use of standard
 construction practices.  Implementation would be
 expected to be straightforward and, in the case of
 Alternative 4, has been successfully performed at the
 MWG sites.

 The continued availability of an off-site disposal
 facility is required for implementation of Alterna-
 tive 4.

 Cost

 Alternative 2 includes construction costs of $12.7
 million to implement remedial measures at OU2
 properties, and an annual O&M cost of $107,000 for
 all properties for an assumed period of 30 years.
 This results in an estimated present worth cost of
 $ 13.7 million for the alternative. Alternative 3 has
 an estimated present worth cost of $12 million, with
 $ 128,000 in annual O&M costs assumed for a period
 of 30  years. Alternative 4 involves construction costs
 of $22 million, but no O&M costs.

 State Acceptance
 Community Acceptance

 Community acceptance of the preferred alternative
 will be evaluated after the pubb'c comment period
 ends and will be described in the Record of Decision
 for the site.

 SUMMARY OF PREFERRED ALTERNATIVE

 Based on the information available to evaluate the
 remedial alternatives against the nine criteria, EPA
 has concluded that the preferred solution for OU2
 properties at the U.S. Radium Corporation site is
 Alternative 4, excavation of the radium-contaminated
 soil and restoration of the affected properties with
 clean fill, removal of radium-contaminated concrete
 and other construction material and restoration to
 the extent required, and disposal of all excavated or
 removed radium-contaminated materials, at a
 licensed, off-site disposal facility. The alternative
 would also remediate the elevated concentrations of
vanadium and cadmium found at the High and Alden
 Streets Properties study area.

 Based on current information, Alternative 4 appears
 to provide the best balance of trade-offs among the
 alternatives with respect to the nine criteria. The
preferred alternative is protective of human health
and the environment, complies with ARARs, and is
cost-effective. This action would utilize permanent
solutions and alternative treatment technologies to
the maximum extent practicable.
The State of New Jersey supports the preferred
alternative.

-------
         U.S.  Radium Corporation site
            Responsiveness  Summary
            Second Operable Unit
Appendix B:    Public Notices

-------
 Superfund Update-

 SEPA
 Region 2	
     U.S. Radium Corporation Site
                    Essex County, New Jersey
                                    -May 1995
 This Superfund Update provides the latest information on the United States Environmental Protection Agency's
 {EPA's) field activities to residents and local officials living and working in the vicinity of the U.S. Radium
 Corporation Superfund site. The Update focuses on two activites:

       •      progress on the first operable unit (OU1) selected remedy, involving about 75 residential and
              commercial properties; and

       •      the Proposed Plan for remedial action for the second operable unit (OU2), which includes the
              former U.S. Radium plant site at High andAlden Streets, and four other, non-adjacent properties.
PROGRESS ON THE FIRST OPERABLE UNIT
(OU1) PROPERTIES

OU1 Selected Remedy

A Record of Decision (ROD) for the first operable
unit (OU1) properties was signed on September 21,
1993.  The ROD details the selected remedy for the
OU1 properties, which will involve excavation of the
radium-contaminated material at each property, with
off-site disposal of the excavated material. After the
radium-contaminated material has been removed,
confirmatory testing will be performed and the
property will be restored as necessary.

OU1 Remedial Design - Phase I

The remedial design associated with the first group
of OU1  properties is currently being prepared. It
will involve approximately 18 residential properties,
located throughout the U.S. Radium study area. It is
anticipated that remedial construction activities at
these Phase I properties will begin in late 1995.

Ongoing OU1 Property Surveys

Approximately 380 properties will be investigated as
part of OU1, with over 300 property surveys
completed thus far. The remaining 80 or  so
properties are either awaiting a property survey or
EPA has yet to obtain access to the property.
Difficulty in obtaining access has led to delays in
completing this aspect of the site investigation. EPA
continues to try to gain access to these remaining
homes to complete this stage of the process.

Of the 300 property surveys performed to date, about
75 properties have been found to contain radium-
contaminated material requiring remedial action.
The first 18 properties are included in Phase I. In
June 1995,  EPA will initiate remedial design surveys
on the next group of properties, which will become
Phase H.

SECOND OPERABLE UNIT (OU2) PROPOSED
PLAN

Concurrent with the release of this Superfund
Update, EPA is releasing a Proposed Plan  for the
second operable unit (OU2) of the U.S. Radium
Corporation site, with support from the New Jersey
Department of Environmental Protection.  OU2
includes the properties that once made up  the U.S.
Radium Corporation radium-ore processing plant
along High and Alden Streets in Orange.  OU2 also
includes four U.S. Radium-operated commercial
properties that are not adjacent to the original High
and Alden Streets plant, called the "non-adjacent
OU2 properties".

The OU2 Proposed Plan describes the remedial
alternatives considered for the OU2 properties, and
identifies EPA's preferred remedy.  EPA conducted
a remedial investigation and feasibility study (RI/FS)

-------
 for OU2 to define the extent of contamination at the
 OL'2 properties, and develop and evaluate measures
 to protect public health. The alternatives considered
 in the Proposed Plan consist of the following:

       - No Action
       - Institutional and Engineering Controls
       - On-site  Containment
       - Excavation and Off-site Disposal

 The Proposed Plan

 EPA's preferred alternative for OU2 is Alternative 4,
 Excavation and Off-site Disposal. The Proposed
 Plan details the rationale for EPA's preference of
 Alternative 4. As part of its public participation
 responsibilities under Superfund, EPA is soliciting
 comment on the Proposed Plan and the RI/FS
 report.  Written comments should be sent to:
       John Prince
       Remedial Project Manager
       New Jersey Superfund Branch I
       U.S. Environmental Protection Agency
       290 Broadway
       New York,  New York 10007-1866
The final remedy will be documented in a ROD after
consideration of comments on the Proposed Plan and
RI/FS report. Comments will be accepted through
June 21, 1995. Also, a public meeting has been
scheduled for June 1, 1995, at 7:00 p.m. at the
Orange City Hall Council Chambers, located at 29
North Day Street in Orange, to present the findings
of the RI/FS report and the Proposed Plan.
For Further Information

If you would like more information about the U.S.
Radium Corporation site, EPA has placed important
site documents at the following locations:

Orange Public Library
348 Main Street
Orange, New Jersey

West Orange Public Library
46 Mount Pleasant Avenue
West Orange, New Jersey

If you have any questions about the site or your
property, please contact EPA at (201) 676-3331. If
you hear a recorded message, please leave your
name, address and telephone number, and an EPA
representative will get back to you shortly. If you
would like to speak to EPA's project manager
directly, please call John Prince at (212) 637-4382.
  Dates to remember:
  MARK YOUR CALENDAR

        May 22,1995 through June 21,1995

  Public comment period on RI/FS report, Proposed
  Plan, and remedies considered

                   June 1, 1995

  Public meeting  at the Orange City Halt  Council
  Chambers, 29 North Day Street at 7:00 pm.

-------
   United States
   Environmental Protection Agency
 } Region 2: NJ, NY, PR, VI
 * 290 Broadway
   New York, New York 10007-1866
NEWS
                         95(44) Rich Cahill  (212) 637-3665

FOR RELEASE:  Tuesday, May 23, 1995

EPA TO HOLD PUBLIC MEETING IN ORANGE ON CLEAN-UP PLAN FOR D.S.
RADIUM SUPERFUND SITE IN ESSEX COUNTY, NEW JERSEY

NEW YORK,  N.Y.  —  The U.S. Environmental Protection Agency

(EPA) is holding a public meeting in the City of Orange, New

Jersey on June  1st to discuss its plan to clean up radium-

contaminated materials at the U.S. Radium Corporation Superfund

site at High and Alden Streets.  The plan also calls for the

cleanup of similar materials at four commercial properties in the

area.  The contaminated material would be disposed of at a

licensed,  out-of-state disposal facility under the plan.  The

radium-contaminated materials at the site,  which covers about 2

acres,  originated from radium processing and utilization by the

former U.S.  Radium Corporation from 1917 to 1926.



The meeting on  Thursday, June 1st will start at 7 P.M. in the

Council Chambers of the City of Orange Municipal Building. Copies

of the plan and other site-related documents are available for

public review at the Orange Public Library and the West Orange

Public Library.   The public comment period on EPA's plan started

on May 22nd and ends on June 21st.  Written comments on the plan

should be  addressed to John Prince, Remedial Project Manager,

USEPA,  Emergency and Remedial Response Division, 19th Floor, 290

Broadway,  New York, New York 10007-1866.

                        - more -

-------
                            - 2 -

In September 1993, EPA selected a cleanup plan that will remove

soil that contains radium-226 and other radioactive materials

from about 120 scattered residential and commercial properties

located primarily in the City of Orange, with the rest in South,

East and West Orange, Essex County, New Jersey.  The contaminated

material will be disposed of at a licensed, out-of-state disposal

facility.  This action will be carried out over the next four

years at a cost of $14.1 million.

People may suffer adverse health effects from long-term exposure
to gamma re^Jiation and inhalation of radioactive dust particles,
or inadvertent ingestion of radioactive particles.

Past actions by EPA resulted in the restriction of public access
to hot spots, thereby making the site safer while the
investigations leading to the selection of cleanup methods for
the site were underway.  Interim measures were also taken to
reduce the levels of radon at other residential and commercial
properties, which further minimized potential radiation
exposures.

                             ###

-------
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                                                          PUBLIC MEETING

                                                PROPOSED PLAN TO BE DISCUSSED FOR

                                            U.S. Radium Corporation Supertund Site, Operable Unit 2

                                                               Orange, New Jersey


                                         The United State* Environmental Protection Agency (EPA) will how an informational
                                         public mMtlng on Thursday. Jura 1,1995. at 7:00 pm. In the Omnga City Hall Council
                                         Chamber*, located at 29 North Day Street trf Orange. New Jersey. EPA will discuss me
                                         findings of a recently completed remedial Investigation and feasibility study and
                                         announce the proposed remedy (or the cleanup of the former U.S. Radium Corporation
                                         plant site on Alden Street riear die comer of High Street, and (our other non-adjacent but
                                         related commercial properties located In Orange. These properties comprise Operable
                                         Unit 2 of tne U.S. Radium Corporation Supertund site.

                                         The study evaluated four alternatives for  addressing radium-contaminated soil and
                                         structural materials (e.g., concrete, wood, gravel, etc.). These are:

                                               1) No Action;
                                               2) Engineering and Institutional Controls;
                                               3) On-site Containment; and
                                               4) Excavation and Off-site disposal.

                                         EPA's proposed remedial alternative la Alternative 4, under wnkti radium-contaminated
                                         material would be removed and transported oft site for disposal. All of these alternatives
                                         are discussed in the Proposed Plan for Operable Unit 2.

                                         Before selecting a final remedy. EPA will consider written and oral comments on tne
                                         proposed alternative, aa well as tne other alternatives mat were considered. Comments
                                         must be received on or before June 21.1995. The final dectston document will include a
                                         em finery of pubttc comments and EPA responses.

                                         The remedial Investigation and leasttlty study  report. Proposed Plan, and other site-
                                         «attted documents have been placed in the information repositories I

                                         Orange PuMc Ubrary
                                         348 Mam Street
                                         Orange, New Jen0y
                                                                                                  West Orange Ubrary
                                                                                                  46 Mount Pleasant Avenue
                                                                                                  West Orange. New Jersey
                                                 Written comments on the proposed alternative, aa well as any other alternatives
                                                 considered, should be sent to:

                                                 John Prince, Remedial Project Manager
                                                 U.S. Environmental Protection Agency
                                                 290 Broadway
                                                 New York. New York 10007-1866

-------
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         • GALL BLADDER

   STEVEN I. BECKER* M.D.,
    Board Certified General Surgeon
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                             l>
 	0-....1 iui anon uao shoved a l
percent drop.
   Every region reported a decline to
reported crime: 5 percent in the North-
can, 2 percent in the South, and l pet-
cent in the Midwwt and ia the Weft.
violent crtanc declined In all reflona
and property crtme abowed a wJuctton
in all but the West, where tt remained
attheimtertL
   Among cWea, the largest decline
m overall reported crtme TOI 6 percent
in those with more Uum 1 ndfllon ret-
dent*. AH others showed smaUer de-
dines except titin of 10,000 to 04,999,
where reported crtme mnainedtewl,
   In subfurbs, overall crime chewed
no change-, tt Incretsed tr/1 percent in
rural area.
   In  New  Jersey,  serious crime
dropped a Uttte leas then 3 percent m
Sttiabeth and Mew«rt; renamed about
the same in Jersey C3£y tart dropped al-
most 12 percent In Pateison.
                    «« »> u« r 01. in other sencus
                    categohes lor urban New Jersey, re-
                    ported rapes fen H percent, robbery
                    ten 4 percent and aggravated assault
                    was unchanged.
                       The FBI's total of seven major
                    dimes reported to law enforcement na-
                    tionwide decnned 2 percent m 1993 and
                    3 percent m 1991
                       violent cilme-mistier, rape, rob-
                    bery and aggravated assault-was un-
                    changed in 1993 from the 1992 figures.
                    Property crime declined 2 percent ia
                    1993 and 4 percent u 1992.
                       "WeTe now in the tuB before the
                    crime storm,1'Fox saw. AS the children
                    of baby boomers age, "by the year 2005,
                    we wffl have 23 percent more teenagers
                    than now."
                       Tte problem is confined to boys
                    with guns. The bomickte rate among
                    teenage gtts has not risen.
                       "Once 1914, the number of teen-
                    agers committing murder with a gon
                    has quadrupled. The number of teen-
 Public  Meeting
 VepoMd Plan to be Olt cuM«d fo
                                             for
  U.S. Radium Corporation Sopodund Stto, OB*raM« UnH 1
                  Orange), New Jeney
8tdM envtronmantal Protection Agancy (EPA) *SJ Notd an
l public m««ttna on Thuraday, Jun« i, 1896, at 7:00 pm, In uw
 Hal Counc* Chambara. located  It 29 North Day 8tro«t in
 The Unnad 8tdM envtronmantal
 Informational
 Oranga City Hal Counc* Chambara. located It 29 North Day
 Oraiig*, Naw Jarwy. SPA wtt dlacuaa tr» flndtoga ol • rteantly compfetad
 remedial invwatfaaUon and faaalbtUty study and announoa me propoaad
 remedy for the aeanup of the termer U.8. Radium Corporation plant ttta on
 AMen Street new trie corner of High Street, end tour other non-ed|eoem
 but reteted commercial propefttea located In Orange, Theee propenlee
 comprtee Operable UnK 2 of the u.3. Radtum Corporation Superfund ttte.

 Tht study evmhteted tour eRemaUvee tor eddrwebtg radkjnv«entemlneted
 •ott end •truetum miterutto (•.$., concrete, wood, gravel, etc.)- Thee* ve:

      DNoAqUon;
      Z) Enotneertng and tnatttuttooil Controla;
      3) On-eKe Contammeou and
      4) Excavettan and Otl.ttte Olapoeal.

 EPA'a propoeed remedial ettemettve i» Anemettve 4, under whtoh radhim
 contamuwted matertal would be  removed and tranaported art *n« to
 dlepoaai. Al of theea attematrMe are dlecuaeed In the Propoaed Plan to
 OperaMeUnlta.

 Wore a»ecuno a rtnet remedy, EPA wlU conaWer written  and on
 comment! on the propoeed alternative, aa weH aa the other alternative* thi
 were considered. Commenta mutt  be received on or before June 21,196
 The final declatan document win include a eummary of puMto eommerr
 and EPA reaponeee.

 The remedial inveettBatlon and teaafbiHty atudy report. Propoeed Plan, at
 other «ite-reiated  dooumema  have  been  placed  in the  mtormatl
 report ortea UeiAd batovr
                                               Orange Public Ubrary
                                               S4S Main Street -
                                               Orange. New Jerety
                                Weat Oranae Ubrary
                                46 Mount Ptoeaant Avenue
                                Wait Orange. New Jersey
  Written  commenta  on  the propoaad alternative,  ai well u any  ot
  aftamativea cortaWered. atwutd be eent to:

  John Prince, Remedial Protect Manager
  U.S. Envtronmantal ft oteetlon Agency
  2M Broadway
  New York. New York 10007-1866                            «
JUT.
me:
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         U.S.  Radium Corporation Site
            Responsiveness  Summary
             Second Operable Unit
Appendix C:    Public Meeting Transcript

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           U.S.  ENVIRONMENTAL PROTECTION AGENCY
           NEW JERSEY SUPERFUND BRANCH I
      IN  THE  MATTER  OF:             :   PUBLIC HEARING
      EPA SUPERFUND                 :
      U.S.  RADIUM CORPORATION SITE :
      ESSEX COUNTY,  NEW  JERSEY     :
                           June  1,  1995
 8                         Council  Chambers
                           City  Hall
 9                         29  N.  Day  Street
                           Orange,  New Jersey
10                         Commencing at  7:07 p.m.

11   PRESENT:

12        JOHN  PRINCE
          EPA REMEDIAL  PROJECT  MANAGER
13
          PAT SEPPI
14        EPA COMMUNITY RELATIONS  COORDINATOR

15        ROBERT MC  KNIGHT
          EPA SECTION CHIEF
16
          ALAN  FELLMAN,  Ph D
17        MALCOLM PIRNIE,  INC.

18        ROBERT KERBEL
          MALCOLM PIRNIE,  INC.
19
          THOMAS J.  MORRISON  III
20        BUSINESS ADMINISTRATOR,  CITY OF ORANGE

21

22

23                ROBERTS, WALSH & ASSOCIATES
                 Certified Shorthand Reporters
24                   425  Eagle Rock Avenue
                  Roseland, New Jersey 07068
25                       201-228-9280

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                     TRANSCRIPT  of  proceedings  taken by



     and  before  JOANNE  M.  OPPERMANN,  a Notary  Public and



     Certified Shorthand  Reporter  of  the  State of New



     Jersey,  at  City Hall, 29 N. Day  Street, Orange, New



     Jersey,  on  June 1, 1995, commencing  at  7:07 p.m.







                 MR.  MORRISON:  I'm Thomas Morrison, your



     Business Administrator, City  of  Orange. This is the



     next  in  a series of  EPA Public Hearings on the



10.  North Ward  and  surrounding ward  radon situations in



11   people's homes.



12               Many of  you have  come to other



13   meetings--  I wouldn't say many,  there may be a



14   few-- and there  have been a lot  of people that the



15   federal  government has contacted in  this  last year,



16   year and a  half, period of time, to  try and resolve



17   the situations  that  we have that revolve around a



18   radon plant in  the North Ward.



19               I certainly want  to  thanJc the EPA for



20   these series of meetings and  their efforts in



21   cleaning up a problem that has existed  for a long



22   time, 40, 50 years,  and at least 10  to  15 years of



23   abandonment of  some  properties that would be



24   important to us on Alden Street.



25               So, they are certainly going to go

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      through  a  presentation  this  evening. They will tell
      you  who  to be  in  contact with, but at any point in
      time,  if we  as  a  city can be  helpful in this
      inner - relationship, we  would  be happy to, and I
      certainly  will  give you cards later on as to how to
      contact  me here in City Hall.
                  Without further adieu, I'd like to
 8    bring  forth  those from  EPA who are kind enough to
 9    be here  this evening and give their presentation.
10                MS. SEPPI: My name is Pat Seppi and I'm
11    with tne U.S. Environmental Protection Agency and I
12    want to  thank you for coming  out to this meeting
13    this evening. I know it's a nice night outside. I'm
14    sure you would rather be home.
15                The purpose of this meeting tonight is
16    twofold. We  want to tell you about the cleanup plan
17    that EPA has come up with for the U.S.  Radium site
18    that's located here in Orange, and, secondly,  we
19   want to open the floor to questions and answers
20   when we're done. Hopefully,  we'll have the answers
21   to your questions. If not,  we'll get them for you
22   and get back to you at a later date.
23                I wanted to introduce the other people
24   that are here this evening.  From EPA,  John Prince,
25   who is the project manager for EPA; and Bob Me

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      Knight  who  is  also  section  chief  for  EPA;  also  we
      have  two  gentlemen  from  Malcolm,  Pirnie, Bob  Kerbel
      who  is  the  manager,  actually,  of  all  the in-field
      investigations that  are  going  on  right  now, and
      Alan  Fellman who  is  an expert  in  health physics.
      If anybody  has any  questions related  to risks,  as
      far as  radium-contaminated  soil is  concerned, Alan
 8    will  be here to answer your questions.
 9               So, we  do have  a brief  presentation.
10    John  has  assured  me  it's .only  about 10  or  15
11    minutes.  Then,  as I  said, we'll open  up the meetin9
12    to questions and  answers.
13               There is a sign-in sheet  up front.  If
14    you would be so kind as  to  sign it, I would
15    appreciate  it.  We have a mailing  list.  If  you are
16    not on the  mailing list, this  will  assure  that  you
17    do get on it.
18               Secondly, you will notice that this is
19    being recorded by a  stenographer. So  when  we get to
20    the question and  answer portion,  if you would state
21    your  name before  you ask your  question, because we
22    want  to have a record of these comments this
23    evening.
24               Part  of  the  Proposed  Plan is a comment
25   period. Tonight we'll be taking oral  comments from

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      anyone  who  has  questions.  If  anyone  has  a  written
      question  that may come  up,  or a  question that  may
      come  up that you  want to  write to  us  after this
      meeting,  come up  to  me  afterwards.  If you  don't
      know  the  address,  I'll  give that to  you. That
      comment period  ends  June  21st. There  is  about  three
      more-weeks  to get  your  written comments  in.
                 The Proposed  Plan itself  is  in your
      library if  anyone  would like  to  go and read  it. The
10    Proposed  Plan, which some  of  you may  have  gotten in
11    the mail  or some  of  you may have gotten  a  Superfund
12    Update--  the Proposed Plan  sort  of summarizes  EPA1s
13    alternatives for  cleaning  up  the U.S. Radium
14    Corporation site.  There is  a  few different
15    alternatives in there and  then the final
16    alternative that the EPA has  chosen as their
17    preferred one.
18               What happens after this,  we  take all
19    the comments into  consideration,  we go back  and
20    write the final decision document that's called a
21    "Record of Decision."
22               That's all  I have  to say. I'd  like to
23    turn this  over to  John  Prince  for his presentation.
24               (Whereupon,  there  is an off- the - record
25   discussion.)

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                  MR.  PRINCE:  Thank  you.
                  To  some  of you,  this  presentation might
      sound  quite  familiar because in May  of  1993 we were
      here,  making a  very  similar  presentation about the
      U.S. Radium  site  and about making a  proposal for
      cleaning  up  a portion of  the site.
                  The  result of that proposal was that
      EPA signed what's  called  a "Record of Decision," in
      September of 1993, for those properties, and EPA is
10    now proceeding  with  implementing  that remedy at
11    those  properties.
12                This  meeting, and  the proposal that is
13    the subject  of  this  meeting, is about a different
14    group  of properties  also  associated  with the U.S.
15    Radium Corporation site.
16                The  first group of properties we call
17    "Operable Unit  l." It's sort of our  shorthand for
18    that group of properties. This group of properties
19   .we call "Operable Unit 2" (indicating), and I'm
20    going  to describe the site in general terms and
21    then I'll explain what's  in Operable Unit l and
22   what's in Operable Unit 2.
23                This  is  a map (indicating.) You all
24   have-- if you grabbed the handout, you have a copy
25   of this map  also.

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                  So,  if  you  look  at  High  and Alden
      Streets  here  in  Orange, you'll  notice  at  the center
      is a  former  U.S.  Radium Corporation- operated
      facility.  It's about  two acres  on Alden Street near
      the corner of High  Street.   That's the first study
      area  and we  call  that the  "High and  Alden Street
      Study Area."
 8                Surrounding that is the  "Vicinity
 9    Properties Study  Area" because  it's  in the vicinity
10    of the original plant. It  involves about  330
11    residential and commercial properties. Some of
12    those properties  have been identified  to  contain
13    some of the material  from  the U.S. Radium site.
14               And then  there is a third  study area,
15    which is called the "Satellite  Properties," and it
16    is not depicted on  the map because it's located
17    further away. It  totals about 50 properties. They
18    are single properties and  then  small clusters,
19    small groups of properties. They were  identified by
20    going back and looking at  some  of the U.S. Radium
21    corporate records and identifying where some of the
22    off-site operations of the corporation took place
23   and where some of the residences of some of the
24    executives of the U.S. Radium Corporation were.
25               So,  those are  the three study areas,

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      the  Plant  Site,  the  Vicinity  Properties  and  then
      the  Satellite  Properties.
                  The  first  operable unit  includes about
      75 residential and commercial properties away  from
      the  original plant site. So,  of  these many,  many
      properties,  we have  done studies and identified
      about  75 so  far,  that  have some  level of this
 8    material that will require action to satisfy our
 9    selected remedy,  and we're in the design stage of
10    that work. We expect that first  excavations  on the
11    first  properties  will  take place early next  year,
12    the  spring of 1996.  So, there will be several
13    groups, but  the  first  group of about 18 we expect
14    to be  getting to  early next year.
15                So,  the  second operable unit, the
16    subject of this  evening's meeting, really includes
17    what's left, which is  the Plant Site and then  four
18    other  properties, four commercial properties that
19    were also places  where U.S. Radium worked,  places
20    where  they were  actually doing their various
21    activities.
22               Let  me get to describing those
23    activities.
24               U.S.  Radium started work at this plant
25    in about 1915,  1916.  The business was bringing an

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      ore,  which  was  high  in  radium  content,  to  this
      facility, extracting  the  radium,  and  then  they used
      that  product  for  various  purposes.
                 The ore,  after  it  had been  processed,
      still  contained some  radium, and  that material was
      deposited,  some on the  property,  some away from  the
      property, and the resulting disposition we see at
 8    some  of  these Vicinity  Properties that  are
 9    associated  with the first operable unit.
10               We also believe that  they are
11    associated  with the Montclair, West Orange and Glen
12    Ridge  radium sites. We  believe that most of the
13    radium material from  this plant actually created
14    those properties.
15               I should  tell you a little  bit  about
16    radium itself. Radium is a rare radioactive metal
17    which, like all radioactive substances,  goes
18    through a process of  radioactive decay,  releasing a
19    certain amount of energy and forming actually
20    another element.  In  the case of radium it  decays
21    in forms of radon gas.
22               Radium is naturally occurring;  it's
23    found in soil, it's found throughout the surface of
24    the earth, and it's found in certain ores  to a
25   greater degree,  like  the ore that U.S.  Radium was

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      processing  at  this  plant.  Radon  is  also  naturally
      occurring,  and it  tends  to  be  present  at  higher
      concentrations when one  has  higher  concentrations
      of  radon.
                  There  are  health effects that  are
      associated  with exposure to  radionuclides  like
      radium  and  radon,  and  those  health  effects are
      generally put  into  two categories,  acute  health
      effects and long-term  or chronic health effects.
10    Acute health defects would be  associated  with
11    generally short-term exposures to very high levels
12    of  radiation,  and  radiation  sickness is the result
13    of  those acute health  effects.
14                In all  of  the studies we have done at
15    the U.S. Radium sites, we haven't seen any levels
16    that would  result in acute health effects. There
17    are levels  of  material at the plant site  that,
18    under certain  circumstances, could  present a
19    long-term health effect,  which would result from
20    long-term exposure  to even low levels of
21    radionuclides.
22           .    One  thing I do need to  mention is that
23    radionuclides  are part of the crust of the earth
24   and natural radiation is sort of something that we
25    live with and  there is a certain sort of a natural

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      background  radiation  tnat's  associated  with  living


      on  this  planet.  The levels associated with this


      plant  site  are  elevated  above  that  natural

      background  level,  and exposure  to,  say,  a worker at

      that plant  site,  who  worked  there over  a number of    :


      years, could  result in an  increased risk of  cancer.   ',


                 An.-her example  would be exposure to      :


      radon  gas and radon decay products  over  a long        :
                                                           i
                                                           !
      period of time,  resulting  in an  increased risk of     j


10    lung cancer.             .                             •


11               I'll  talk a  little bit  about the plant


12    site itself and  what  we  have found.


13               We  investigated all  the properties that


14    are associated  with this second  operable unit. The


15    main problems that we found-- this  figure is also


16    in your handout--  the  main problems that we found


17    are associated with the  soils and associated with


18    some of the older  buildings that remain  on this


19    facility.

20               What this  map represents, this is High


21    Street and Alden Street,  and these darker areas


22    represent deeper levels  of contamination


23    (indicating.)  So,  this sort of is a quantification


24   of the extent of contamination.


25               We also found elevated  levels of radon

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                                                     12
      in  the  buildings  located on this facility, and, as
      I say,  some  of  the  older portions of  the buildings
      that  were  there,  at  the time U.S. Radium was
      operating, have some building surface contaminants
      as  a  result.
 6                The four commercial properties that are
 7    away  from  this  facility are-- it's mainly building
 8    surface  contamination as a result of  activities
 9    that  were  going on  at the'plant site  at that time--
10    at  those various  facilities at the time, rather.
11                We  also  found some low-level chemical
12    contamination,  nonradiological contamination, at
13    this  facility,  and  it may be related  to U.S. Radium
14    activities and  it may be related to some activities
15    that  took  place after U.S.  Radium sold the
16    property.  But the primary concern-- EPA's primary
17    concern are  these levels of radium contamination.
IS                We also took some samples in Wigwam
19    Brook, which runs alongside of the site here
20    (indicating), and did not find any problems
21    associated with Wigwam Brook.
22                We  installed some monitoring wells to
23    examine the  groundwater immediately below the site,
24    to  try and assess whether there is a possibility
25    that  groundwater might be affected from the site.

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                                                      13
                  While  we  did  get  some  information,  we
      really  don't  have  a complete  handle  on  the  extent
      of  what  might  be a problem. There  were  some  low
      levels  of  groundwater contaminants.   Some of  them
      may be  associated  with the  site, but  there  is  some
      additional studies that need  to  take  place  and
      that's  not actually part  of the  proposal in  the
 8    Proposed Plan.
 9               EPA has been  doing some  sampling,
10    periodically,  of the  drinking water  supplies  in
11    this area, just as an extra "heck  to  make sure  that
12    there isn't any effect  from the  site  that might be
13    getting to the municipal  supplies, and  we have  not
14    found any problems. The municipalities  do a very
15    good job of testing and treating the  water  to make
16    sure that it's safe to drink.
17               That's a  real quick  summary of  the
18    investigations that we have done.  I'm now going to
19    describe the alternatives that we  considered  in
20    considering how to address this  second  operable
21    unit,  and I'll say that I'm going  to go through
22    these very quickly. There is a lot of additional
23    information that is sort  of the backup  for
24   describing these alternatives, and it's available,
25   and we can explain after  the meeting how you can

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                                                      14
      find  additional  information  if  you are  interested
      in  it,  and  then  these  alternatives are  described
      also  in greater  detail  in the Proposed  Plan itself.
                  So,  there  are four  alternatives that we
      came  up with.  One  thing you  need  to know, as
      regards to  radionuclide contamination,  is that
      there  is no  way  to destroy it and there  is no way
 8    to  reduce the  level of  radioactivity. It's
 9    impervious  to  that sort of treatment.
10                So,  what we're left with  is  figuring
11    out ways that  you  can  separate  people from the
12    material so  that they  don't  come  in contact with
13    it.
14                So,  these  are the four alternatives
15    that were considered:  "No Action"; "Engineering
16    Controls and Institutional Controls"  is  the second
17    alternative; Alternative 3 is "On-site
18    Containment";  and Alternative 4 is "Excavation and
19    Off-site Disposal."
20               Alternative l, "No  Action,"  EPA is
21    obliged to consider no action as a baseline so that
22   we can  compare active  options and have  some
23   baseline:  Well, if there were  no action taken,
24   what would be  the effect?
25               Alternative 2, "Engineering  and

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                                                     15





      Institutional  Controls,"  involve  a  number of



      different  things.  For  example,  shielding of



      material,  that's  in  the ground  or below a



      structure, with either lead or  concrete or soil;



      fencings could be  an institutional  control, just



      preventing people  from getting  access  to an area;



      radon mitigation  systems, because radon tends to



      concentrate inside structures,  so that you can



      prevent or minimize exposure  to radon.



10               Alternative 3, "On-site Containment,"



11    woula involve bringing material from the f^ur



12    commercial properties  not at  this plant, to the



13    High and Alden Street  facility, probably bringing



14    it down and then building a cap over the top of



15    this two-acre property and fencing  it, then



16    providing some security.  That would be the extent



17    of the action.



18               Then the fourth alternative, which is



19    "Excavation and Off-site Disposal," is actually



20    EPA's preferred alternative and I'll describe that



21    in a little more detail.



22               EPA expects it will cost approximately



23    $22 million to implement that action,  "Excavation



24   and Off-site Disposal," and that it will take



25   approximately-- it would take approximately two

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                                                     16
      years.  It  would  involve digging up material,
      contaminated  material, transporting it off-site to
      a  landfill  licensed  to dispose of that material
      appropriately, confirmatory testing in the
      excavation  area  to assure that we have gotten all
      the material  out, and then filling the hole back
      in, and  restoration  would follow.  Again that's
 8    EPA's preferred  option.
 9               That is  pretty much the end of our
10    presentation. Again  I'11.remind you that there is a
11    public comments  period that's open until June 21&t.
12    Written  comments will be accepted on the Proposed
13    Plan until  then. Before EPA takes an action, we'll
14    consider those comments and there have been cases
15    where comments have  been submitted that have
16    resulted in EPA  changing remedies, changing
17    proposals.  So we take those comments very
18    seriously.
19               I guess  that's about it. I'm going to
20    reintroduce the  people who will probably be
21    responding  to questions along with myself; Bob Me
22    Knight with EPA, Pat Seppi with EPA, and then Bob
23    Kerbel,  who's really responsible for our
24    investigations,  and  Dr. Alan Fellman whose
25   background  is in health physics and has a lot of

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      experience  with  the  effects  of  radiation.
                  Please state  your name  and  if  it's a
      complicated name, we  may  ask you  to spell  it.
      That's about  it.
                  Are  there any questions?
                  MS.  CATALFAMO:   Orange,  New Jersey.
                  That diagram,  does  that refer  to
 8    Watchung Avenue  at all?
 9                MR.  PRINCE: Watchung  is-- let  me put up
10    this  one because it may make a  little bit  more
11    sense.
12                {Pause.)
13                This is Watchung here  (indicating) and
14    that  other  figure is  a blowup of--
15               MS.  CATALFAMO: We're  right  behind Alden
16    Street.
17               MR.  PRINCE: You're  up near  this corner
18    { indicating)?
19               MS.  CATALFAMO: Yes,  we're in more where
20    Spanky's is.
21               MR.  PRINCE: That's  right on  the corner,
22    right. The  facility is actually at  the  corner of
23    High and Alden Streets. It's about  two  acres.
24               DR. FELLMAN:  Point  out  what  the back
25    figure is showing.

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                                                      18





                  MR.  PRINCE:  Yes,  it's  this  right  here



      (indicating . )



                  MS.  CATALFAMO:  I'm  talking  about  the



      other  diagram  you  have  there.



                  MR.  PRINCE:  This  is  a  blowup  of this



      area right here  (indicating.)



                  MS.  CATALFAMO:  Okay. That's what  I



 8    wanted  to know.



 9                Also,  I  think you're wrong  about  the



10    date of  the  first  meeting.  I don't  think  it  was in



11     '93.  I  think  it was before that.  It was  before



12    because, I remember, when we  came  to the  first



13    meeting, you told  us that it  would be in  a few



14    years,  the cleanup,  in  '95, and  here it is '95 and



15    nothing  has  been done.



16                MR.  PRINCE:  EPA's studies of all  of



17    these properties-- we have done  over 300 properties



18    investigations so  far--  began in 1991. We had some



19   meetings back  in 1991 to tell people who we were



20    going to be  in the community  and the sort of  work



21    that we  were going to be doing.



22               MS.  CATALFAMO: You said within a



23    four-year period this would have been resolved.



24               MS.  JANICE CHAM:  Orange, New Jersey.



25                I would  like to know a little bit about

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                                                      19





      Operable  Unit  2  because  you're  noc  talking  about



      that  and  I  think that  I'm in  that area  and  that



      area  is  from Alden  to  probably  Washington.



                 MR.  PRINCE:  This  is Washington  over



      here  (indicating),  that's actually  Operable Unit  1.



                 MS.  CHAM:  You don't have  it depicted  on



      either one  of  those--  on that blowup  really.  I'd



      like  to know why.



                 MR.  PRINCE:  I may not have  been clear.



10    There is  two separates pieces.  For  the  first  piece,



11    which is  Operable Unit 1 and  includes a number of



12    residential properties in this  area,  not  the  plant,



13    we have already  selected a  remedy,  we already have



14    the design process  going on, and those  properties--



15    the work  on those properties, which will  involve



16    excavation, off-site disposal of that material,



17    excavation of  the property, are  in  the  process, and



18    the first group  of  those properties is  what we



19    expect to actually  start  working on,  the



20    construction work,  next  spring.  That  group  is



21   actually  18 properties.



22               MS.  CHAM: That  includes this  area that



23    I'm talking about?



24               MR.  PRINCE:  It  includes particular



25   properties in  that  area.

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                                                      20





                  MS.  DENICE  JONES:  Orange,  New  Jersey.



                  I  live  right  in back  of  the  radiation



     plant.  I  want  to know,  who is  going  to be  held



     responsible  for  long-term or acute health  problems



     of my  family and for  how  long  in  the  future  is  this



     person  or  whatever  going  to be responsible?



                  DR.  FELLMAN:  I think  the  first part  of



 8   the question is,  who's  responsible? The  responsible



 9   party  is  the U.S. Radium Corporation  who ceased



10   activities here  in  1926.



11                So,  unfortunately  there  is no  person



12   responsible  who  you can interact  with in 1995. A



13   lot of  the Superfund  problems  are inactive sites.



14   The person or  company that is  responsible  for



15   creating  the hazardous  condition  is no longer with



16   us and  in many cases  such as this one, it's been 70



17   or so years  since they have been  here.



18                As far as health effects, what we're



19   talking about, as John touched on, is an increased



20   risk of cancer when one is exposed to a  carcinogen.



21   It would be  similar to the risk to a  cigarette



22   smoker, in that,  number one,  not  everyone  who



23   smokes  cigarettes gets cancer or  any  other



24   tobacco-related  illness.. The more one smokes, the



25   greater the  risk. Then again you may  have  a

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                                                      21

      three-pack  smoker  who  lives  to  be  a  hundred  and
      never  gets  cancer.
                  It's not something  that  you  can  point a
      finger at and  say,  if  this individual  is  exposed to
      this amount  of  radiation  for this  period,  then we
      can say with any degree of certainty that  there  is
      going  to be  a  radiation-caused  cancer  down the
 8    road,  10, 20,  30 years later, for  that individual.
 9          •      All we  can say is,  in  a  broad  sense,
10    looking at a population,  as  opposed  to an
11    individual,  that if a group  of  people  are  exposed
12    to elevated  levels  of radiation for  a  long period
13    of time, then  in that group  we  may expect  to see a
14    greater number  of cancers than  we  would have had
15    they not been exposed to  radiation.
16                Just like in  a group of  cigarette
17    smokers, over a long period  of  time  we would expect
18    to see greater  numbers of tobacco-related  illness,
19    such as lung cancer and heart disease, than we
20    would  have had  that group not been exposed to that
21    hazardous agent.
22               So, having said  that, what we're left
23    with here is levels of radiation that are elevated
24    above background,  natural background. We know what
25    natural background levels are and we see definite

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                                                     22
      increases  when  we  are  studying  over  the U.S. Radium
      waste  piles.
                  On  the  other hand,  the fact that these
      elevated levels  exist  does not  necessarily mean
      that the people  who are either  living near them, as
      you are, or  working in and around them, as we have
      for the past  several years, are not  getting such an
 8    enormous radiation  exposure that we're necessarily
 9    going  to see  any health effects.
10                What this  is all about is being
11    prudent. It's about an increased risk, albeit a
12    small  risk.  You  are still talking risk estimates
13    that would predict a handful of cases to thousands
14    of people.
15                So,  certainly no real certainty that
16    there  would be any cancers caused by this,  but a
17   possibility based on our knowledge of how radiation
18   works  and what the carcinogenic-- the magnitude of
19   the carcinogenic effects based on studies of people
20   like the survivors from Japan who were exposed to
21   radiation when the atomic bomb went  off, and other
22   groups that have been  studied over the years.
23               So, again  it's more of a low risk,  but
24   it's a-- we know it's  there,  we know this is a
25   carcinogen, and so the prudent thing to do is to

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                                                      23





      find  it  and  remove  it.




                  MS.  JONES:  With  all  due  respect,  that's



      not an acceptable answer  to  me.  I  appreciate  the



      information  that you're offering.  The  reason  it's



      not acceptable  to me,  in  your  line of  work  you



      choose to  do your line  of  work.



                  DR.  FELLMAN:  That's  true.



 8                MS.  JONES:  If  a  person chooses  to smoke



 9    cigarettes,  that's  their  choice.



10                DR.  FELLMAN:  That's  true.



11                M
-------
                                                      24





      what  I  was  moving  into  and  I  have my  family



      smack-dab in  the middle  of  something  that was not



      my  choice.



                 If  I had  been informed of  the situation



      beforehand, someone had  given me the  choice, I



      would not have  moved  there. I feel very angry



      because  the choice was  taken away from me. My



 8    family-- I  feel horrible that my family is in this



 9    situation.  I  have very  small children  and I j.ust



10    feel that someone has to.be responsible for that.



11    I'm not  saying  that you  are, but someone has to  be



12    responsible.  Someone  should have informed me before



13    I moved  to where I'm  living.



14               DR. FELLMAN: I  take it you're a tenant.



15               MS. JONES:  I'm  a tenant. Someone should



16    have informed me, before I moved to this area right



17    smack in the backyard of this, of what the



18    situation was.



19               This is where my anger comes in:  I'm



20    the last person in the world who would have put



21   myself in that  situation. I've always  been very



22    careful with my family and  their health. I'm not



23   blaming anyone  here. But I have to vent how I feel.



24               DR. FELLMAN: Understood.



25               MR. PRINCE: Other questions, please?

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                                                      25

                  MR.  CAREY  GAGE,  Orange,  New  Jersey.
                  What  properties  exactly  are_in Operable
      Unit  2?  You  have  the plan  site  and you said  four or
      f ive- -
                  MR.  PRINCE:  Four other properties.
                  MR.  GAGE:  What are  the addresses?
                  MR.  PRINCE:  I  have  the addresses with
 8    me and actually  I didn't have your telephone number
 9    so I  couldn't call you back.  I can  provide you the
10    information  that  you requested.
11                The  reason we  don't generally make
12   public the addresses that  are associated with
13   particular properties  is that,  while the
14    information  is public  information, because the EPA,
15   the government,  is paying  for this work and
16   therefore it's the work of the people and it's
17   public information, we try and keep  a level of
18   privacy to the degree  that we can.
19                So, we don't talk about  individual
20   properties,   we don't refer to so and so's house.  We
21   just try and have that level of separation.
22                So, I know the information you would
23   like and I have it. I  can provide it for you.
24                MS. CHAM: What's going to happen to the
25   people who have to have on-site excavation, or

-------
                                                      2S
      whatever,  and  the  people  around  them?  Are  you
      telling  those  neighbors--  I mean should  they not
      know  about  this? If  it's  one  individual  house, what
      about  the  people around them?  They  should  not know
      about  it?
                 MR. PRINCE: Well,  we'll need to speak
      to  them, depending on  the  level  of  work  that has to
 8    take  place  at  their  particular property.
 9               This is  a  question about the first
10    operable unit  again. It's  generally a  question
il    about  one or a group of these  residences that is
12    not the subject of this particular  meeting, but
13    that  doesn't mean  it's not a  legitimate  question.
14               In general we're  finding that  we don't
15    find  clusters  of properties.  We  are often  finding
16    just  one property out  here somewhere (indicating),
17    where  this  material, sometime back  in  the  '20s, was
18    brought. We don't know how. It's  clearly material
19    that  is associated with this  plant, but  how it got
20    there, we don't know.
21               Be that  as it may, it's part of the
22    cleanup work. We speak with the  individual
23   homeowner.   In some cases,  depending on the extent
24   of the contamination,  and more the  type  of work
25    that has to take place, we do need  to  relocate

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                                                      27





      certain  homeowners,  which  is  also  part  of  the



      restoration  program.



                  It's  paid  for  through  the cleanup work



      and, depending  on the  nature  of  the  work,  we may be



      working  in front  of  that house or  around that



      particular house  for several  days, several  weeks,



      possibly-- generally several  weeks.  And, in that



 8    case, obviously we need to make  everyone in the



 9    area understand why we're  in  and what we're doing



10    and contact  them  and explain  our concerns.



11                MR. MORRISON:  You have said you have



12    gone house-to-house and anybody  who  lets you, you



13    went in  and  examined for radon.



14                MR. PRINCE: Radium,  yes.



15                MR. MORRISON: Radium.  People who



16    wouldn't let you  in, you could not examine,



17    correct?



18                MR. PRINCE: That  is  true.



19                MR. MORRISON: So, anybody who  is there,



20    you would have  contacted.



21                MR. PRINCE: Right.



22                MR. MORRISON: So, if someone has a



23    particular problem, you've already contacted the



24    neighbors in the  ways  that you can already.



25                MR. PRINCE: Well, we don't stop there.

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                                                     23
                  MR. MORRISON: At  least you are going
     through  that  initial situation.
                  MR. PRINCE: Sure. You actually bring up
     a point  that  is worth my mentioning. There are 330
     properties here and then there are about 50
 6   properties that are sort of scattered about. That's
 7   380 properties. We have been  to 300 or so, a little
 8   more than 300 or so of those. There are about 80
 9   that, for one reason or another, we haven't been to
10   yet. In  some  case it's because people have said,
11   no, no,  *e can't be bothered.
12               DR. FELLMAN: In most cases. There are
13   some properties that are abandoned and we can't
14   find the owner. In general it's because people
15   don't understand or we maybe  haven't done our job
16   of communicating what we're doing yet.
17               So, that work is  ongoing. We're still
18   trying to get into those remaining 80 homes to find
19   out, well, is there a problem? The good news is, if
20   we do find something for these 380 properties,  not
21   associated with this plant and not those four
22   commercial properties,  we have a remedy at home for
23   that so we can start that work relatively quickly.
24               MS. SEPPI:  Any other questions? If
25   anyone has a question about their own property, if

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                                                     29





 1   they would prefer to stay after to talk to us more,




 2   that's fine and we would be glad to stay and answer




 3   your questions.



 4               If that's all the questions for now,



 5   thank you very much for coming. If anyone didn't




 6   get the handout, there are some up here




 7               Thank you.



 8              (Whereupon, the hearing is concluded at




 9   7:47 p.m.)




10




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25
           CERTIFICATE
           I, JOANNE M. OPPERMANN, a Certified



Shorthand Reporter and Notary Public of the



State of New Jersey, do hereby state that the



foregoing is a true and accurate transcript of



my stenographic notes of the within



proceedings, to the best of my ability.
                       JOANNE M. OPPERMANN




                         LICENSE NO. X1435

-------
         U.S.  Radium Corporation site
            Responsiveness Summary
             Second Operable Unit
Appendix D:    Administrative Record Index

-------
                   U.S. RADIUM CORPORATION SITE
                         OPERABLE UNIT TWO
                    ADMINISTRATIVE RECORD FILE
                        INDEX OF DOCUMENTS


 1.0   SITE  IDENTIFICATION

 1.5   Previous Operable Unit Information

 P.    100001  -  Memo to administrative record  file,  from Mr. John
      100028    Prince,  Remedial  Project Manager, U.S. EPA, Region
               II, re:   Incorporation by  reference  of documents
               that are included in the administrative  record  for
               the first operable unit (OU1)  of the site and are
               also part of the  OU2 administrative  record, May
               12, 1995.   (Attached:   QU2 Administrative Record
               Documents (In OUl Administrative Record), Index
               Chronological Order, U.S. Radium Corporation
               Documents, October 18,  1993.)


3.0  REMEDIAL INVESTIGATION

3.4  Remedial investigation Reports

P.   300001 -  Report:  Draft Final Remedial
     300361    Investigation/Feasibility Study Report.  Volume  I.
               Operable Unit Two. U.S.  Radium Corporation.
               prepared by  Malcolm Pirnie Inc., prepared for U.S.
               EPA, May 1995.

P.   300362 -  Report:  Draft Final Remedial
     300455    Investigation/Feasibility Study Report.  Volume  II.
               Appendices.   Operable Unit Two. U.S. Radium
               Corporation,  prepared by Malcolm Pirnie  Inc.,
               prepared for U.S. EPA, May 1995.

p.   300456 -  "Abstract of Offers - Construction, Montclair/West
     300463    Orange & Glen Ridge Radium Sites, Property
               Remediation  & Restoration; Phase IIA, Essex
               County, New  Jersey", prepared  by Ms. Susan Meites,
               Bid Opening  Officer, U.S. EPA, September 14, 1992.

-------
 6.0   STATE COORDINATION

 6.2   State Certification of Applicable  or .Relevant  and
      Appropriate Requirements

 P.    600001 -   Memo to administrative record  file,  from Mr. John
      600025    Prince,  Remedial  Project Manager, U.S. EPA, Region
                II,  re:   U.S.  Radium Corporation Superfund Site  -
                Second Operable Unit - Administrative Record
                Confidential Document, May 12,  1995.   (Attached:
                "Objective:   To Establish  Statewide  Cleanup
                Standards for Radioactive  Materials  Consistent
                with the Direction  in S-1070 and the Radiation
                Protection Act",  prepared  by the Bureau of
                Environmental  Radiation, undated.  Note:  This
                document is  CONFIDENTIAL.  It  is located in the
                U.S.  EPA Superfund  Records Center, 18th floor, 290
                Broadway,  New York,  New  York,  10007-1866.)


10.0 PUBLIC  PARTICIPATION

10.6 Fact Sheets  and Press  Releases

P.   1000001 -  "A Citizen's Guide  to Radon  (Second  Edition), The
     1000016    Guide to Protecting Yourself and Your Family from
                Radon11,  prepared  by U.S. EPA,  U.S. Department of
                Health and Human  Services, and Centers for Disease
                Control,  May 1992.

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                          ROD FACT SHEET
SITE
Name            :
Location/State  :
EPA Region      :
HRS Score  (date):
Site ID #

ROD	
Date Signed:
Remedy:
Operable Unit Number:
Capital Cost:
Construction Completion:
O & M:
Present Worth:

LEAD	

Primary contact:
Secondary contact:
Main PRP:
PRP Contact:

WASTE	
Type:
Medium:
Origin:
Est. quantity:
U.S. Radium Corporation
Essex County, New Jersey
II
37.79 (8/12/83)
NJD980654172
     August 29,  1995
     Excavation and off-site disposal of
     radium-contaminated material
     OU-2
     $ 22 Million in 1995 dollars
     Two years
     None
     $ 22 Million
     Remedial/EPA
     John Prince  (212)-637-4382
     Robert McKnight  (212)-637-4378
     Safety Light Corporation
     N/A
     Radium and other  radionuclides
     Soil,  miscellaneous
     Radium-ore tailings
     18,000 cu.yd.

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