PB99-963801
EPA541-R99-028
1999
EPA Superfund
Record of Decision:
Welsbach & General Gas Mantle
Contamination Site (Camden)
Camden & Gloucester City, NJ
7/23/1999
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RECORD OF DECISION
DECISION SUMMARY
Welsbach/General Gas Mantle Contamination Site
Gloucester City & Camden, Camden County, New Jersey
United States Environmental Protection Agency
Region 2
New York, New, York
July 1999
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Welsbach/General Gas Mantle Contamination Superfund Site
Gloucester City & Camden, Camden County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's
selection of a remedial action to address soil and building material contamination at the
Welsbach/General Gas Mantle Contamination Site (the "Site"), in accordance with the
requirements of the Comprehensive Environmental Response, Compensation and Liability Act of
1980, as amended (CERCLA), 42 U.S.C. §9601-9675, and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), as amended, 40 CFR Part 300.
This decision document explains the factual and legal basis for selecting the remedy for the first
operable unit of this Site.
The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the
planned remedial action in accordance with Section 121 of CERCLA. The NJDEP concurs with
the selected remedy (see Appendix IV). The information supporting this remedial action is
contained in the Administrative Record for the Site, the index of which can be found in
Appendix III of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Welsbach/General Gas Mantle
Contamination 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.
DESCRIPTION OF THE SELECTED REMEDY
The remedy described in this document represents the first of three planned remedial actions or
operable units for the Welsbach/General Gas Mantle Contamination Site. It will address
radiologically-contaminated soil and building materials at the former Welsbach and General Gas
Mantle facilities and properties in the vicinity of these facilities. For the second operable unit at
the site, the current owner of the former Welsbach facility is performing a remedial investigation
and feasibility study on the last remaining Welsbach era building. A third operable unit is
planned to investigate potential site impacts to groundwater, surface water, sediments, and
wetlands. The major components of the selected remedy include:
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Excavation/removal of soil and waste materials with radiological contamination above
remedial action objectives from the former Welsbach and General Gas Mantle Facilities:
Excavation/removal of soil and waste materials with radiological contamination above
remedial action objectives from the residential and commercial properties in the vicinity
of two former gas mantle facilities;
Off-site disposal of the radiologically-contaminated soil and waste materials:
Decontamination and demolition of the General Gas Mantle Building: and
Appropriate environmental monitoring to ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in Section 121 of
CERCLA, in that it: (1) is protective of human health and the environment; (2) complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
extent practicable; (3) is cost-effective, and (4) utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable. 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 remediated
properties above levels that allow for unlimited use and unrestricted exposure, a five-year review
of this action will not be required.
I certify that the remedy selected for this Site is protective of human health and the environment.
/ ->Lh<
Jeanne\f ^vT y Date
Regional Administrator I
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION I
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF RESPONSE ACTION 4
THE NATURE OF RADIONUCLIDES 5
SUMMARY OF SITE CHARACTERISTICS 6
SUMMARY OF SITE RISKS 10
REMEDIAL ACTION OBJECTIVES 13
DESCRIPTION OF REMEDIAL ALTERNATIVES 16
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21
SELECTED REMEDY 26
STATUTORY DETERMINATIONS 27
DOCUMENTATION OF SIGNIFICANT CHANGES 29
APPENDICES
APPENDIX I FIGURES
APPENDIX II TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV STATE LETTER
APPENDIX V RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
Site Background
The Welsbach/General Gas Mantle Contamination site (Welsbach/GGM or Site) is a multi-
property site located in Gloucester City and Camden. Camden County, New Jersey. EPA
initially identified the Site in 1980 during an archive search conducted as part of the investigation
of the U.S. Radium Corporation Superfund site located in Orange, New Jersey. Historical U.S.
Radium Corporation files indicated that radiological materials were purchased by U.S. Radium
from the Welsbach Corporation during the 1920s.
Between the 1890s and 1940s, the Welsbach Company (Welsbach) manufactured gas mantles at
its facility in Gloucester City, New Jersey. Welsbach was a major manufacturer and distributer
of gas mantles until gas lighting was replaced by the electric light. Welsbach extracted the
radioactive element thorium from monazite ore and used it in the gas mantle manufacturing
process. Thorium causes the mantles to glow more brightly when heated. A second gas mantle
manufacturing facility, known as the General Gas Mantle Company (GGM), was located in
Camden, New Jersey. GGM operated from 1915 to approximately 1940.
In May 1981, EPA conducted an aerial radiological survey of the Camden and Gloucester City
area to investigate for radioactive contaminants. The survey encompassed a 20 square kilometer
area surrounding the former locations of the Welsbach and GGM facilities. Five areas with
elevated gamma radiation were identified from the aerial survey; they included the locations of
the two former gas mantle manufacturing facilities and three mainly residential areas in both
Camden and Gloucester City. In 1993, EPA reanalyzed the data from the aerial survey. Based
on this revised information, EPA identified a sixth potential radiologically-contaminated area
which includes two vacant lots in Gloucester City.
In the early 1990s, NJDEP conducted detailed radiological investigations at more than 1,000
properties located throughout the original five study areas. Radiological contamination was
identified at the two former gas mantle facilities and at approximately 100 properties located near
the two facilities. In 1996, the Welsbach/GGM site was placed on National Priorities List (NPL)
because of the presence of radioactive contaminants.
EPA divided the Welsbach/GGM site into six study areas in Camden and Gloucester City, New
Jersey (Figure 1). A brief description of each study area and its current land use is presented
below:
Study Area One: includes the former GGM Facility and residential and commercial
properties which surround the facility (Figure 2.) The former GGM Facility is located in
a mixed industrial, commercial, and residential zoned section of Camden.
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Study Area Two: includes the lection of the former Welsbach Facility and nearby
residential/commercial properties. The former Welsbach Company is situated in an
industrial zoned section of Gloucester City with residential properties to the immediate
east (Figure 3.)
Study Area Three: includes residential and recrea.. jnal properties in G-louces;-.-: City.
including the Gloucester City Swim Club and the Johnson Boulevard Land Preserve.
Study Area Four: includes residential properties in the Fairview section of Camden.
Study Area Five: includes residential properties, vacant land properties, and two
municipal parks near Temple Avenue and the South Branch of Newton Creek in
Gloucester City.
Study Area Six: includes two vacant lots in a residential zoned area of Gloucester City.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Welsbach and the GGM Facilities have complex histories of changes in name, ownership,
and operation. Specific details are discuf -ed in the paragraphs below.
The United Gas Improvement Company, which formed Welsbach, purchased the patent rights to
manufacture thorium-containing gas mantles in the 1880s from Dr. Carl Auer von Welsbach.
The process for manufacturing the Welsbach gas mantle used a highly purified solution of 99
percent thorium nitrate and 1 percent cerium nitrate as a "lighting fluid" ir distilled water. A
fabric sock was then dipped into the thorium solution to create the gas manue. Thorium caused
the gas mantle, when lit, to give off a very bright white light.
The commercial source of thorium and cerium is a mineral known as monazite sand. Monazite
sand contains approximately 5-6 percent thorium oxide and 20-30 percent cerium oxide.
Thorium was typically extracted from the monazite ore by heating the ore in a sulfuric acid
solution. The thorium and other rare earth elements would go into solution, while the radium-
228 remained in the tailings of insoluble sulfates. Around 1915, Welsbach started using and
selling the radium-228 for use in luminescent paint. For a number of years, Welsbach was the
largest manufacturer of gas mantles in the world, making up to 250,000 mantles per day at its
peak.
Welsbach also made gas room heaters, gas storage water heaters, gas and electrical fixtures,
electrical refrigerators, plumbing supplies and lacquers. Manufacturing operations at the
Welsbach facility began as early as 1882 and lasted until the 1940s. The facility property
covered an area of about 21 acres, and consisted of about 20 buildings.
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In 1942, the U.S. Government acquired the Welsbach Facility and sold it to the Randall
Corporation in 1948. Randall leased the property to the Radio Corporation of America. Victor
Division. A series of intervening owners followed. In May .1976. the property was purchased by
Holt Hauling and Warehousing, Inc. (Holt), the current owner of the property. Holt operates a
cargo and overseas shipping business. None of the owners of the property after Welsbach dealt
with radioactive materials.
Only one Welsbach era-building, the Armstrong Building, is still present on the property. There
is no information available on when the other Welsbach-era buildings were demolished. The
remedy for the Armstrong Building is not part of this decision.
The former gas mantle manufacturing facility in Camden was owned and operated by the GGM
Company from 1912 to 1941. There is little information available regarding activities at GGM.
other than it used and resold radium and thorium.
Between 1941 and 1978, there was a total of seven different private owners of the property.
Based on current information, none of these operations involved radioactive materials. In
January 1978, the southern portion of the property was purchased by the Dynamic Blending
Company. In October 1988, the northern portion of the property was purchased by Ste-Lar
Textiles. In 1992, NJDEP removed radiologically-contaminated fabrics, relocated Ste-Lar, and
sealed up the GGM building on the northern property to restrict access.
During the years that Welsbach and GGM operated, ore tailings were used for fill at properties in
the vicinity of the facilities. It is also reported that building debris from the former Welsbach
Facility may have been disposed of as fill in the area. :i addition, workers from the former
Welsbach and GGM Facilities may have brought contamination home with them. These
properties associated with radiological waste from the Welsbach and GGM Facilities are
collectively termed Vicinity Properties.
In 1991, NJDEP initiated a radiological investigation at more than 1,000 properties located
throughout Study Areas 1 through 5. At properties where NJDEP determined that exposure
levels were unacceptable (or posed an immediate health risk), it performed interim remedial
measures. These measures included the installation of radon/thoron ventilation systems and
placement of concrete or lead sheeting to shield gamma radiation. In addition, NJDEP restricted
access to outdoor areas which exceeded its action levels.
In 1998, EPA identified a 100 square foot area in a Gloucester City Park, located in Study
Area 5, that had elevated levels of gamma radiation at the surface. In December 1998, EPA
performed a removal action to reduce exposure to these elevated levels. EPA excavated the top
three feet of radiologically-contaminated soil, disposed of this soil off-site at a permitted facility,
and replaced the waste material with clean fill.
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Both the Welsbach Company and the GGM Company went out of business in the early 1940s.
and EPA has been unable to identify any successor companies. In Septemrv- 1997. EPA entered
into an Administrative Order on Consent (AOC) with Holt, the current owner of the former
Welsbach Facility. Under the terms of the AOC, Holt agreed t perform a Remedial
Investigation and Feasibility Study (RJ/FS) on the Armstrong Building. Holt has also submitted
information to support its position that it is not liable for response costs at the former Welsbach
facility. EPA is currently evaluating this information.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RJ/FS report, the Proposed Plan and supporting documentation were made available to the
public in the administrative record file at the Superfund Document Center at EPA Region II. 290
Broadway, 18th Floor, New York, New York 10007 and at the following repositories: City of
Camden Main Library, 418 Federal Street, Camden, New Jersey 08103; the Hynes Center. 1855
South 4Ih Street, Camden, New Jersey 80104; and the Gloucester City Public Library, Monmouth
and Hudson Streets, Gloucester City, New Jersey 08030. Notices of availability for the
documents in the administrative record were published in the Philadelphia Inquirer on
February 1, 1999, the Courier-Post on February 2, 1999, and the Gloucester Cirv News on
February 4, 1999. The public comment period which related to these documents was held from
February 1, 1999 to March 3, 1999.
EPA conducted public meetings in both Gloucester City and Camden to inform local officials
and interested citizens about the Superfund process, to review proposed remedial activities at the
Site and receive comments on the Proposed Plan, and to respond to questions from area residents
and other interested parties. Meetings were held on February 23, 1999, at the Pine Grove Fire
Station #2 in Gloucester City, and on rebruary 24, 1999, at the Camden County Municipal
Utilities Authorities Auditorium in Camden. Responses to the comments received at the public
meeting are included in the Responsiveness Summary (see Appendix V). The City of Gloucester
City submitted a resolution supporting the proposed remedy. No other written comments were
received during the public comment period.
This Record of Decision (ROD) document presents the selected remedial action for the
Welsbach/GGM site, chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act, anc, 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 RESPONSE ACTION
This action is the first operable unit or phase taken to address the radiological contamination at
the Site. This action will address the radiologically-cr ntaminated soil and building materials at
the Vicinity Properties and the former Welsbach anc JGM Facilities. For the second operable
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unit at the site, Holt is performing an RI/FS for the Armstrong Building. A remedy for this
second operable unit will be selected in a future ROD. A third operable unit is planned to
investigate potential site impacts to groundwater. surface water, sediments, and wetlands.
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. There are
approximately 1,700 different unstable atomic species or radionuclides. These include both
naturally occurring and man-made radionuclides.
The radionuclides of concern in the wastes which originated at the former Welsbach and GGM
Facilities are members of the uranium and thorium decay series. There are 14 unique
radionuclides in the uranium decay series and 11 unique radionuclides in the thorium decay
series which precede the formation of stable lead (Pb-206 or Pb-208). Alpha, beta, and gamma
radiation are emitted from the various members of the two decay series. The primary nuclides of
concern are Thorium-232, Radium-226, and radon gas (Radon-222 and Radon-220.)
Each radionuclide has its own unique characteristic "fingerprint," consisting of three parameters:
The radioactive half-life describes the amount of time in which half of any given number
of atoms of a radionuclide will decay.
The mode of decay refers to the type(s) of particles or electromagnetic rays emitted from
the radionuclide as it decays. These types include alpha and beta particles, and gamma
rays.
The amount of energy carried away from the atom by the particles or rays is radionuclide
specific. It is the transfer of this energy to living tissue which may cause biological
effects.
When radionuclides decay, they emit energy in the form of radiation. The decaying radionuclide
is often called the "parent", and the radionuclide produced is called 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 1012 (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"12
(one trillionth) Ci. Table 1 summarizes the common units of measure for radionuclides that are
discussed below.
Radium-226 is a naturally occurring, radioactive, metallic element formed from the decay of
uranium. In its decay, Radium-226 forms Radon-222 or radon gas. Radon gas is colorless,
odorless, radioactive and inert; therefore, it can move easily through soil to the ground surface or
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into houses. Within a matter of days, the radon gas itself decays into a series of radioactive
decay products. Wr."e radon gas in the outdoor air dissipates quickly, the concer.tmion of radon
decay products in tr. .ndoor air can build up over time. Exposure to the energy re :sed by these
various decaying atoms can result in adverse health effects. For radon decay produ^.s. a special
unit called Working Level (WL) has been developed. Working Level is defined as any
combination of short-lived radon decay products in 1 liter of air that will result in the ultimate
emission of 1.3x 105 Mega-electron Volts of potential alpha energy. This value is approximately
equal to the alpha energy released from the decay of progeny in equilibrium with 100 pCi of
Radon-222.
Thorium-232 is also a naturally occurring radionuclide and is the initial radionuclide of the
thorium decay series. Its decay products include Radium-228 and Radon-220. Radon-220 is
also known as thoron. Thoron and its decay products have extremely shrr. half-lives that usually
prevent them from concentrating to any appreciable extent in indoor air. However, if a
significant source of thoron exists within, beneath, or adjacent to a structure (such as the thorium
and Radium-228 found in Welsbach/GGM site wastes;, thoron decay products can reach
concentrations which create health risks.
SUMMARY OF SITE CHARACTERISTICS
In September 1997, EPA started an RI to characterize the nature and extent of contamination at
the Welsbach Facility, GGM Facility, and 20 of the radiologically-contaminated properties
identified by NJDEP in the vicinity of Welsbach and GGM. The work was conducted by
Malcolm Pimie. Inc., under contract to EPA. In order to develop a cleanup strategy for the Site,
the RJ field investigations were divided into three property categories, as follows:
Former Welsbach Company Facility;
Former General Gas Mantle Company Facility;
Vicinity Properties
Property Investigations
EPA conducted both chemical and radiological characterizations of the former Welsbach and
GGM Facilities to define the extent of contamination. EPA also performed a radiological
investigation on 20 of the potentially contaminated Vicinity Properties identified by NJDEP.
Only 20 Vicinity Properties were investigated during the RI so that EPA could confirm the
NJDEP data and expedite the development of cleanup alternatives. Based on evaluation of the
NJDEP data, EPA segregated the properties investigated by NJDEP into the following three
categories. Table 2 summarizes the results of the property classification.
1) Properties wh-re there is no evidence of contamination related to the Welsbach/GGM site.
These are properties which have surface exposure rates less than 13 uR/h, radon progeny
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measurements less than 0.02 WL, and radon gas levels less than 4.0 pCi/l. The exposure rate
represents the upper level of the range of natural background.
2) "Suspect Properties" - are properties for which either elevated levels (i.e.. above background)
of radioactivity were detected by NJDEP or properties situated adjacent to known contaminated
properties; and
3) "Contaminated Properties" - are properties with levels of radioactivity which potentially
warrant remedial action (i.e. properties with either exposure rates greater than 30 nR/h. radon
progeny greater than 0.02 WL, radon gas levels greater than 4.0 pCi/l, or thorium or radium
concentration in the soil greater than 5 pCi/g.)
EPA will investigate the remaining Contaminated Properties which were not studied in the RI
and the Suspect Properties during the remedial design phase of this cleanup. EPA estimates that
it will study about 600 properties during the design phase to determine exactly which properties
require cleanup. This additional work may include sampling for chemical analysis, where
deemed appropriate when considering past ownership and historic information. Table 3
summarizes the volume of contaminated soil and debris at the Contaminated Properties. Field
activities conducted as part of the RI included the following:
Radon measurements
Radon decay product Working Level measurements
Gamma radiation surface and one-meter height exposure rate surveys
Surface and subsurface soil sampling
Downhole gamma radiation logging
Total surface beta surveys and removable surface alpha and beta sampling
Structural materials sampling for radionuclides (in some buildings)
Chemical sampling for metals, volatile organic compounds, and semi-volatile organic
compounds at the two former gas mantle facilities
The results of the RI can be summarized as follows.
Former Welsbach Facility Investigation
Most of the radiological contamination is located in the area of what is believed to be the
location of a former Welsbach building that was demolished in the 1970s. This area is currently
used for storage. However, there are smaller areas of contamination scattered throughout the
property. The soil in these areas is contaminated with elevated concentrations of the thorium
and uranium decay series radionuclides. These radionuclides are principal threat wastes.
Subsurface contamination on the Welsbach facility averages about 11 feet in depth. An
estimated 27,200 cubic yards of soil/buried debris have thorium and/or radium concentrations
exceeding 5 pCi/g. Radium and thorium concentrations in soil ranged from background (about 1
pCi/g for each) to as high as 455 pCi/g and 1,190 pCi/g, respectively. Surface gamma exposure
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rates associated with the contaminated soils ranged from background (less than 10 micro-
Roentgen per hour [nR/h]) to 780 uR/h. The highest readings were associated with a laree fill
areu identified in the middle of the storage area.
Low levels of chemical contaminants were also identified at the former Welsbach Facility.
Contaminants of potential concern include semi-volatile organic compounds and arsenic. These
contaminants may be indicative of "Historic Fill". If this is confirmed during the remedial
design and these contaminants are not comingled with the radiological contaminants of concern.
then there may be a need to remediate such historic contaminants.
Former General Gas Mantle Facility Investigation
Elevated concentrations of thorium and uranium decay series radionuclides were identified in
soils on the former GGM property. Contamination was generally limited to the top six to eight
feet, although contamination in some areas of South Fourth Street and the GGM Courtyard
ranged from 12 to 16 feet in depth. An estimated 900 cubic yards of soil have thorium and/or
radium concentrations which exceeded 5 pCi/g. Radium and thorium concentrations in soil
ranged from background to as high as 172 pCi/g and 149 pCi/g, respectively.
Surface gamma exposure rates associated with the contaminated soils ranged from background
(less than 10 u.R/h) to 380 nR/h. Only localized areas of surface contamination were identified
outdoors. Most of the outdoor contamination is located in the area of South Fourth Street.
However, EPA identified some smaller areas of contamination in the alleyway behind the
property. The contamination also extended onto some backyards of neighboring residential
properties.
Elevated levels of surface contamination were observed in many areas inside the former GGM
building. Levels as high as 2.33 microCi per square meter(uCi/m2) were observed. Indoor
gamma exposure rates ranged from background to 900 uR/h. An estimated 1,460 cubic yards of
contaminated structural materials in the building itself were identified, with thorium
concentrations as high as 750 pCi/g. In the basement of the former GGM building, radon decay
product concentrations measured 1.7 WL, compared to an average background level of
0.005 WL.
Certain semi-volatile organic compounds and metals were identified in the outdoor portions of
the former GGM Facility. These were, however, at such low levels that they are not of concern.
These contaminants may be indicative of "Historic Fill". If this is confirmed during the remedial
design and these contaminants are not comingled with the radiological contaminants of concern,
then there may be a need to remediate such historic contaminants.
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Vicinity Property Investigation
EPA investigated 20 properties in Camden and Gloucester City for radiological contamination as
part of the RJ. EPA compared the data from these properties to information collected from
earlier NJDEP investigations on over 1000 properties and determined that the data were
comparable. Contaminated soil averaged about two to three feet in depth on most residential
properties. On a few properties, contamination extended to 10 feet in depth. Some site
properties have indoor radon gas concentrations or soil radionuclide concentrations which pose a
long-term risk to human health.
Based on the comparison of EPA and NJDEP data, EPA identified a total of 54 properties as
having contamination above the cleanup levels. During the remedial design phase, EPA will
delineate the extent of contamination on each of these properties in order to design a cleanup
plan for each property.
During the remedial design, EPA will also investigate approximately 600 additional properties
that are either adjacent to the known contaminated properties or have gamma exposure rates
slightly above background levels. If contamination above the cleanup objectives is found on any
of these Suspect Properties, EPA will delineate the extent of this contamination and design a
cleanup plan for those properties.
Based on its review of the NJDEP data, EPA determined that 449 out of the approximately 1000
properties NJDEP investigated showed no evidence of contamination. These properties had
surface gamma exposure rates less than the upper range of natural background, radon progeny
less than 0.02 WL, and radon gas levels below 4.0 pCi/1.
Current and Future Land Use
The site properties and the surrounding areas consist of industrial, commercial, and residential
zoning districts. Study Area 1 is located in an industrial-zoned section of Camden with
residential properties east of the former GGM Facility. In Study Area 2, the former Welsbach
Facility is situated in an industrial-zoned section of Gloucester City with residential properties to
the immediate east. Study Area 3 consists of residential properties, a private swim club, and a
land preserve. Study Area 4 consists entirely of residential properties. Residential properties and
two municipal parks comprise Study Area 5. Study Area 6 consists of vacant land in a residential
area.
No significant changes in land use are anticipated, except in the area of GGM where there is a
possibility that some residential areas may be rezoned for commercial uses. The former GGM
facility is bordered by residential homes located on Arlington Street in Camden. Most of the
homes on Arlington Street are abandoned and there is debate within the community, given the
industrial nature of the area, whether to rezone this area to allow for commercial development or
leave it residential. Whether zoning changes will actually be made is uncertain at this time.
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SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for the former Welsbach Facility, the former
Facility, and the Vicinity Properties using analytical data obtained during the RI. Tne baseline
risk assessment estimates the human health risk which could result from the contamination at a
site if no remedial action were taken.
Ecological risks, that is, the risks to aquatic and terrestrial wildlife, were not evaluated for this
operable unit. However, EPA compared the levels of radioactive exposure to various species
with the cleanup criteria. Based on this comparison, EPA determined that the cleanup criteria
will be protective of ecological receptors for this operable unit. An Ecological Risk Assessment
will be conducted in a future RI to evaluate the potential for adverse effects to aquatic and
terrestrial wildlife in accordance with Ecological Risk Assessment Guidance for Superfund,
Process for designing and Conducting Ecological Risk Assessments (EPA 540-R-97-006).
To evaluate human health risks, a ; ur-step process was 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 toxiciry, 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; Toxiciry Assessment
- determined the types of adver. ? 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 expos _re and
toxiciry 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 effects (causing cancer) or
nor. carcinogenic effects (causing health effects other than cancer.) Radionuclides from the
uranium and thorium decay series (e.g., radium, thorium, radon, and radon decay products) are
known human carcinogens. Nonradiological chemical contaminants (e.g., PAHs and arsenic)
may exhibit both carcinogenic and noncarcinogenic health effects.
EPA's acceptable cancer risk range is lO^4 to 101*, which can be interpreted to mean that an
individual may have a one in i 0,000 to one in 1,000,000 increased chance of developing cancer
because of site-related exposure to a carcinogen. EPA usually initiates remedial action at a site
when the risk estimate exceeds this range.
Human health risks were estimated for both radionuclides and chemicals of concern at the former
Welsbach and GGM Facilities, and : r radionuclides o jncem at the Vicinity Properties.
Building materials and/or soil were :ne environmental ;:,vdia of concern. Following EPA
guidance, risks were estimated basec on a "reasonable maximum exposure" scenario. Risks were
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estimated as a result of exposure to site-related carcinogens based on a number of assumptions
that result in an overall exposure estimate that is conservative but within a realistic range of
exposure.
In assessing potential human health risks from exposure to the radionuclides. several scenarios
were evaluated which involve exposure to external gamma radiation, ingestion of radioactive
materials, and inhalation of radioactive materials. For the former Welsbach Facility, risk
estimates were evaluated for current and future workers, other site workers (part-time workers).
and construction workers. For the former GGM Facility, risk estimates were evaluated for
current and future trespassers, and future construction workers, adult residents, child residents.
and workers. At the Vicinity Properties, risk estimates were evaluated for adult and child
residents of the 14 residential properties investigated, and appropriate populations at the
remaining six Vicinity Properties ( Jogging Track, Swim Club, Martins Lake. Public Park. Land
Preserve, and the Popcorn Factory.) These risks were then compared to the risk from natural
background sources of radiation.
The following exposure pathways were evaluated in detail for current and future land-use
conditions:
Inhalation of radon decay products by residents, or occupants at commercial
properties;
Exposure to external gamma radiation emanating from thorium- and radium-
contaminated material, resulting in elevated exposures to residents/occupants;
Ingestion of radionuclides in soil by residents/occupants;
Ingestion of radionuclides in locally grown produce by residents; and
Inhalation of radioactive particulates by residents/occupants.
The Vicinity Properties and the former Welsbach and GGM Facilities have radiogenic risk
(radiation induced) cancer risk estimates, that is, the risks due solely to the presence of
radioactive materials above background levels, which exceed EPA's risk range. The maximum
excess lifetime radiogenic cancer risk estimates based on reasonable maximum exposures are 5.7
x 1O'2 at the former Welsbach Facility (to the current and future site worker), 1.8 x 10'1 at the
former GGM Facility (to a hypothetical future site worker), and 1.8 x 10'2 to a hypothetical
resident of a Vicinity Property (See Tables 4 and 5.) The uranium and thorium decay series
radionuclides are principal threat wastes because of these increased cancer risks.
The cancer risk from chemical exposures at the former Welsbach and GGM facilities was also
evaluated for the same populations as the radionuclides. Construction workers at both Welsbach
and GGM would be subject to the maximum risk from the chemicals of concern (See Table 6
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and 7.) However, these cancer risks do not exceed EPA's risk range and. therefore, no additional
remedial action is necessary to address chemical contaminants at these facilities.
To assess the potential for cumulative noncarcinogenic effects posed by multiple contaminants.
EPA has developed a hazard index (HI). The HI is derived by adding the noncancer risks for site
chemicals with the same target organ or mechanism of toxicity. When the HI exceeds 1.0, there
may be concern for adverse health effects due to exposure to multiple chemicals.
For the Welsbach/GGM site, non-cancer health effects were evaluated only at the former
Welsbach and GGM Facilities. The total HI for construction worker exposure to the chemicals
of concern in soil at the former Welsbach Facility from ingestion, dermal contact, and inhalation
is equal to EPA's acceptable level of 1.0 i; -.-i Table 6.) Ingestion of arsenic is the predominant
contributor to the risk estimate. The total HI for construction worker exposure to the chemicals
of concern in soil at the GGM Facility from ingestion, dermal contact, and inhalation is 0.03: this
hazard index is below EPA's acceptable level of 1.0, indicating that adverse, noncarcinogenic
health effects from such exposure are unlikely (See Table 7.)
The following are the dominant radiological exposure pathway risks for the various exposure
scenarios evaluated for the Welsbach/GGM site. At residential properties and the former
Welsbach Facility, the majority of risk is from exposure to external gamma radiation, or direct
radiation. Occupants of the former GGM Facility (current and future trespassers and future site
workers) are at risk primarily from inhalation of radon decay products. Future construction
worker risk is primarily due to direct radiation, although inhalation of particulates containing
radioactive material also contributes a significant portion of the risk.
This RI focused primarily on residential and commercial properties, and sensitive species of
plants and animals are not likely to inhabit these portions of the Site. However, sensitive species
may be present in Study Areas 3 and 5 around Newton Creek and associated areas of the
Delaware River. An ecological risk characterization will be conducted in conjunction with the
third operable unit RI to assess potential impacts to ground water, surface water, and sediment
from the Site.
Uncertainties
The procedures and estimates used to assess risks, as in all such assessments, are subject to a
wide variety of uncertainties. In general, the main sources of uncertainty include:
environmental chemistry sampling and analysis
environmental parameter measurement
fate and transport modeling
exposure parameter estimation
toxicologicaJ data
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Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry analysis error can stem from several sources including
the errors inherent in the analytical methods and characteristics of the matrix being sampled. In
addition, there is uncertainty inherent in the measurement of radioactivity.
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 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
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.
Actual or threatened releases of hazardous substances from this 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
Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and
appropriate requirements (ARARs) and risk-based levels established in the risk assessment.
EPA's remedial action objectives for the Welsbach/GGM Contamination site are to take measures
that will prevent or mitigate further release of radioactive contaminated materials to the
surrounding environment and to eliminate or minimize the risk to human health and the
environment. The sources of radiation include both contaminated soil and structural materials.
Direct radiation, inhalation, ingestion of plants and soil are potential pathways. The following
objectives were established for the Welsbach/GGM site:
Eliminate or minimize the potential for humans to ingest, come into dermal contact with,
or inhale particulates of radioactive constituents or to be exposed to external gamma
radiation in order to achieve the level of protection required by the NCP (10"* to 10"6 risk
range).
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Prevent long-term exposure to thorium- and radium-contaminated material i.g.. soil) with
concentrations greater than 5 pCi/g.
Prevent exposure to indoor concentrations of radon gas and radon decay product .-ater
than 4 pCi/1 and 0.02 WL1, respectively.
Prevent direct contact with building surfaces exhibiting total surface thorium
contamination exceeding 0.026 uCi/m2 above background.
Prevent migration of thorium-contaminated material that could result in tru .xposures
described above.
Comply with chemical-, location-, and action-specific ARARs.
EPA, in the Office of Solid Waste and Emergency Response (OSWER) Directives No. 9200.4-18
and No. 9200.4-25, developed health guidelines for limiting exposure to ionizing radiation from
radium and other sources. To further ensure protectiveness, those health guidelines can be
supplemented by selecting response actions which reduce exposures resulting from ionizing
radiation to levels t.._. are As Low As Reasonably Achievable (ALARA2) taking into
consideration technical, economic and social factors.
EPA recommends that indoor radon concentrations in homes should not exceed 4 pCi per 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 enacted standards
for limiting exposure to radon decay products and gamma radiation. While this regulation is not
directly applicable to this site because the Welsbach and GGM Facilities are not inactive uranium
processing sites. EPA considers the cleanup standards in 40 CFR 192 to be relevant and
appropriate for the Site. The relevant portions of 40 CFR 192 include limiting exposure to: radon
decay products to levels less than 0.02 WL and radium concentrations (implemented as the sum of
Ra-226 and Ra-228) to 5 pCi/g. EPA, in Directive No. 9200.4-25, states that whenever the
5 pCi/g radium soil cleanup standard is determined to be relevant and appropriate at a . "RCLA
site which contains both radium and thorium in the waste, the pCi/g cleanup standard also
applies to thorium (implemented as the sum of Th-230 and Th-232).
In achieving the remedial action objectives for the Site, EPA would rely on the ALARA
principles used at other radiologically-contaminated sites in New Jersey. Applying ALARA
1 Exposure to 4 pCi/1 of air for radon corresponds to an approximate annual average exposure of
0.02 WL for radon decay products, when assuming residential land use.
J References for ALARA principles -"Radiation Protection C. .iance to Federal Agencies for
Occupational Exposure", 1987, Federal Register 52. No. 17, 26.., and "Federal Guidance Report
No. 11". September 1988, EPA-520M-88-020.
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principles means taking additional measures during implementation of the remedial action.
beyond those required to meet a specified cleanup goal, to assure protectiveness. An ALARA
approach is being used because of the long-lived nature of radionuclides. the difficulty in
eliminating routes of exposure, and limitations of the analytical equipment to detect radionuclides.
EPA's experience at the other radiologically-contaminated sites in New Jersey has shown that the
remedial action objectives noted above can be achieved by incorporating ALARA principles.
Applying the 5 pCi/g cleanup standard with ALARA principles at these other New Jersey sites
has resulted in exposure levels that are lower than the levels that would result from using the
5 pCi/g standard alone. Therefore, by using similar remedial action objectives, the
Welsbach/GGM site would pose no unacceptable risk for residential uses after cleanup, and would
result in a cleanup that is protective under CERCLA.
The NJDEP has developed a draft proposed regulation concerning the remediation of
radiologically-contaminated soil. In reviewing this case, the NJDEP believes that the remedy
selected in this ROD will achieve the goals in the draft proposal through the incorporation of the
ALARA principles in removing the radiologically-contaminated soils and covering the excavated
areas with clean fill.
The selected remedy will meet the remedial action objectives through the excavation and off-site
disposal of the radiologically-contaminated soils and waste materials. Excavation of soils will
eliminate the threat of physical migration of contaminants, as well as potential exposure through
various pathways (ingestion, inhalation, dermal contact, external gamma radiation, etc.).
Contaminated soils will be shipped off-site to a licensed commercial facility for permanent long-
term management. For buildings, specifically at GGM, the selected remedy, decontamination,
demolition, and off-site disposal of contaminated materials, will reduce exposures to acceptable
levels for future use of the property.
Any potential ecological risks and adverse impacts from existing radiological contamination on
the properties addressed under this action will be minimized because the contaminated soils will
be removed and backfilled with clean soil. There are also limited habitats for ecological receptors
at the properties addressed under this action. Furthermore, by removing the radiologically-
contaminated waste, the surface water and sheet flow pathways will be eliminated as routes of
exposure.
Wetlands are not present at either the former Welsbach or GGM facilities. However, wetlands are
present in Areas 3 and 5, along the South Branch of Newton Creek. During the remedial design,
EPA will delineate wetland areas which are actually or potentially impacted by contamination or
remedial activities.
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DESCRIPTION OF REMEDIAL ALTERNATIVES
Section 12 l(b)(l) of CERCLA, 42 U.S.C. §9621(b)(l), mandates that a remedial action must ne
protective of human health and the environment, cost-effective, and utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. Section 121 (b)( 1) also establishes a preference for remedial actions which employ, as
a principal element, treatment which permanently and significantly reduces the volume, toxicity.
or mobility of the hazardous substances, pollutants and contaminants at a site. Section 121(d) of
CERCLA, 42 U.S.C. §962l(d), further specifies that a remedial action must attain a level or
standard of control of the hazardous substances, pollutants, and contaminants, which at least
attains ARARs under federal and state laws, unless a waiver can be justified pursuant to Section
121(d)(4) of CERCLA , 42 U.S.C. §9621(d)(4). CERCLA also requires that if a remedial action
is selected that results in hazardous substances, pollutants, or contaminants remaining at a site
above levels that allow for unlimited use and unrestricted exposure, EPA must review the action
no less than every five years after the start of the action.
In the RJ/FS Report, EPA evaluated Remedial Alternatives for addressing the radiological
contamination associated with the Site. Cleanup alternatives were equated for the Vicinity
Properties, the former Welsbach Facility and the General Gas Mantle Facility. The alternatives
include: No Action, Engineering Controls, and Excavation and Off-Site Disposal. Table 8
summarizes the costs of each alternative.
Vicinity Properties
The Vicinity Properties include residential, commercial, and public properties where radiological
contamination was identified in soils located outdoors and/or beneath buildings, and properties
with indoor air contamination.
Vicinity Properties Alternative 1 (V-l) - No Action
Estimated Capital Cost: $0
Estimated Annual Operation and Maintenance (O&M) Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period: none
A "No Action" alternative is evaluated for every Superfund site to establish a baseline for
comparison with remedial alternatives. Under this alternative, no remedial action would be
performed at the Site. Previous interim remedial actions implemented by NJDE? would not be
maintained. Current institutional controls including fencing would not be maintained. Because
hazardous substances would remain at the Vicinity Properties above acceptable levels, five-year
reviews would be required.
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Vicinity Properties Alternative 2 (V-2) - Engineering Controls
Estimated Capital Cost: $900.000
Estimated Annual O&M Cost: $99.000
Estimated Present Worth: $1.810.000
Estimated Implementation Period: 3-5 years
Under this alternative, outdoor gamma shielding would be placed at each property which has
contaminated soil. The gamma shield would consist of a geotextile liner, fill material. 6 inches of
topsoil, and vegetation (seeding or sod). The thickness of the fill material will vary from 6 inches
to 42 inches, based on the shielding requirements of each property. A total of approximately
75,000 square feet of coverage would be installed.
In addition, indoor gamma shielding would be placed inside buildings exhibiting unacceptable
exposure levels. The shielding would consist of concrete or steel as needed. The concrete would
range from 4 inches to 7 inches thick, and about 1.5 inches of steel sheeting would be placed on
wall surfaces. A total of approximately 2,000 square feet of concrete and 60 square feet of steel
coverage would be installed. Finally, if any property buildings exhibit elevated radon/thoron
levels, a sub-slab ventilation radon mitigation system would be installed.
Institutional controls, such as deed restrictions, would be required to ensure the protectiveness of
the remedy. Because hazardous substances would remain at the Vicinity Properties above
acceptable levels, five-year reviews would be required. The estimated time to design and
construct the remedy is from three to five years.
Vicinity Properties Alternative 3 (V-3) - Excavation and Off-Site Disposal
Estimated Capital Cost: $ 13,408,560
Estimated Annual O&M Cost: $0
Estimated Present Worth: $ 13,408,560
Estimated Implementation Period: 3-5 years
Under this alternative, soil on the Vicinity Properties contaminated above 5 pCi/g greater than
background would be excavated and disposed of at a licensed off-site facility. Radiologically-
contaminated building demolition debris would also be excavated and disposed of off-site. EPA
will replace these areas with clean fill. The total volume of soils requiring disposal at the Vicinity
Properties is estimated to be 11,000 cubic yards. The total volume of buried demolition debris at
the Vicinity Properties is estimated to be 2,250 cubic yards.
Where contamination is suspected underneath buildings, this alternative includes removing
concrete flooring and underpinning the buildings. After the removal of contaminated soil, a new
concrete floor would be constructed. Approximately 21 properties would require concrete floor
removal and replacement. Underpinning may be required at one property.
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The estimated time to design and construct the remedy is three to five years. Provisions would
need to be made for the temporary relocation of residents and businesses during construction of
this alternative. ! ring excavation, short-term provisions to pvent dust generation and protect
workers would be required. EPA will develop a wetland miti. m plan if it disturbs wetland
areas by remedial activities.
Welsbach Facility
The former Welsbach Facility is presently owned and operated by Holt as a cargo storage and
oversea shipping operation. Radiological contamination on fv oroperty is present in the outdoor
portion of the storage area. Most of the contamination is located in a single contiguous area, with
smaller contaminated areas scattered across the property. The Armstrong Building is not included
in the remediation alternatives. Holt is preparing an RI/FS that will address the remedial
alternatives for that building.
Welsbach Alternative 1 (W-l) - No Action
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period: none
Under this alternative, no remedial action would be performed at the Site. Current institutional
controls, including fencing, would not be maintained. Because hazardous substances would
remain on the property above acceptable levels, five-year reviews would be required.
Welsbach Alternative 2 (W-2) - Engineering Controls
Estimated Capital Cost: $5,686,000
Esv.-uted Annual O&M Cost: $44,000
Estimated Present Worth: $6,182,000
Estimated Implementation Period: 3-5 years
Under this alternative, outdoor gamma shielding would be placed in the areas of the former
Welsbach property that have soil contamination. The gamma shield would consist of sreel
covered by asphalt. The steel would range in thickness from 1 to 5 inches, with a 4-incn asphalt
cover. Approximately 53,000 square feet of area would be. covered by the steel shielding.
Institutional controls, such as deed restrictions, would be required to ensure the protectiveness of
the remedy. Because hazardous substances would remain on the property above acceptable levels,
five-year reviews would be required. The estimated time to design and construct the remedy is
three to five years.
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Welsbach Alternative 3 (\V-3) - Excavation and Off-Site Disposal
Estimated Capital Cost: $18.503.560
Estimated Annual O&M Cost: SO
Estimated Present Worth: SI8.503.560
Estimated Implementation Period: 3-5 years
Under this alternative, all soil contamination at the Welsbach site above 5 pCi/g greater than
background would be excavated and disposed of at a licensed off-site facility. EPA will also
excavate contaminated building debris from past demolition activities, which is currently buried
on-site, and dispose of this material at an appropriate off-site facility. EPA will backfill these
areas with clean fill. The volume of soils above the cleanup standard is estimated to be 19.400
cubic yards. The volume of buried demolition debris requiring disposal is estimated to be 4.400
cubic yards. During excavation, short-term provisions to prevent dust generation and protect
workers would be required.
Subsurface contamination on the Welsbach Facility averages about 11 feet in depth. In the area of
the deepest contamination, underground tunnels dating from around the turn of the century are
present. These tunnels extend down to about 10 to 12 feet in depth. These tunnels can act as
conduits to cany radon gas to nearby residential properties. As a result, the remedy includes
excavation of the contamination to the tunnel depths to prevent any future radon migration
problems and to protect future workers from elevated gamma radiation levels. The estimated time
to design and construct the remedy is three to five years.
General Gas Mantle Facility
The GGM building is presently inactive and in a dilapidated state. The building has been boarded
shut and fenced in by NJDEP. Radiological contamination on the property exists both inside and
outside the building. Inside the building, contamination is present in building materials and in
ambient air. Outside the GGM Facility, soil contamination is primarily located to the immediate
southwest of the GGM building extending into South Fourth Street. Two smaller areas of
contaminated soils are situated to the northeast of the building and in the alleyway adjacent to the
eastern side of the building.
General Gas Mantle Alternative 1 (G-l) - No Action
Estimated Capital Cost: SO
Estimated Annual O&M Cost: $0
Estimated Present Worth: $0
Estimated Implementation Period: none
Under this alternative, no remedial action would be performed at the Site. Previous interim
remedial actions would not be maintained. Current institutional controls including fencing would
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not be maintained. Because hazardous substances would remain on the property above
acceptable levels, five-year reviews would be required.
General Gas Mantle Alternative 2 « 2) - Engineering Controls
Estimated Capital Cost: $ 122.000
Estimated Annual O&M Cost: S23.000
Estimated Present Worth: $381.000
Estimated Implementation Period: 2-3 years
Under this alternative, outdoor gamma shielding would be placed at the former General Gas
Mantle property. The gamma shield would consist of either a soil shield or a concrete shield. The
soil shield would include a geotextile liner, fill material, 6 inches of tonsoil, and vegetation
(seeding or sod). The thickness of the fill material will range from t 24 inches. The thi. ness
of the concrete will range from 6 to 8 inches. Approximately 5,000 icoare feet of coverage would
be required. Areas of contamination extending into .- .>uth Fourth Street would be covered with an
additional 4 inches of asphalt.
Also under this alternative, significant institutional controls, including permanently boarding shut
the building and restricting access to the building forever, would be required. Because hazardous
substances would remain on the property above acceptable levels, five-year reviews would be
required. The estimated time to design and construct the remedy is two to three years.
General Gas Mantle Alternative 3 - Excavation and Off-Site Disposal
of Soil and Building/Demolition Debris
Option A: Demolition and Disposal
Estimated Capital Cost: $2,309,560
Estimated Annual O&M Cost: $0
Estimated Present Worth: $2.309,560
Estimated Implementation Period: 1-2 years
Under this alternative for the GGM property, EPA will excavate contaminated soil above 5 pCi/g
greater than background and dispose of this waste in a licensed off-site facility. Contaminated
building demolition debris which is currently buried on-site because of former demolition
activities would also be excavated and disposed of off-site. EPA will backfill these areas with
clean fill. The volume of soil and buried demolition debris at GGM is estimated to be 650 cubic
yards and 60 cubic yards, respectively.
Under this alternative, the former General Gas Mantle building would be demolished, and the
demolition debris would be disposed of with the contaminated soil. The volume of building
materials to be demolished is estimated to be 1,400 cubic yards. During excavation and
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demolition, short-term provisions to prevent dust generation and protect workers would be
required. The estimated time to design and construct the remedy is one to two years.
Option B: Decontamination, Demolition and Disposal
Estimated Capital Cost: $ i .979.560
Estimated Annual O&M Cost: SO
Estimated Present Worth: S1.979.560
Estimated Implementation Period: 1 -2 years
This alternative essentially would be the same as 3A above, except that the demolition of the
building would proceed in steps. First, the wood structural materials and roofing would be
removed. This debris (approximately 450 cubic yards) would be disposed of with the
contaminated soil. The remainder of the building (approximately 950 cubic yards of primarily
masonry and concrete) would then be decontaminated using pressure washing before demolition.
The contaminated waste water would be disposed of at an approved off-site facility. The building
would then be demolished and the debris would be crushed and sent off-site for disposal. The
estimated time to design and construct the remedy is one to two years.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in Section 121 of CERCLA, 42
U.S.C. §9621, by conducting a detailed analysis of the viable remedial alternatives pursuant to the
NCP, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consisted
of an assessment of the individual alternatives against each of nine evaluation criteria and a
comparative analysis focusing upon the relative performance of each alternative against those
criteria.
The following "threshold" criteria are the most important and must be satisfied by any alternative
in order to be eligible for selection:
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 of federal and state environmental
statutes and requirements, or provides grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify the
major trade-offs between alternatives:
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3. Long-term effectiveness and permanenr? refers to the ability of a remedial alternative to
maintain reliable protection of human th and the er. :ronment over time, once cleanup-
goals have been met. It also addresses ...-: magnitude uid effectiveness of the measures
that may be required to manage the risk -;ed by treatment residuals and/or untreated
wastes.
4. Reduction oftoxicity. 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 availability of materials and services needed to implement the
alternative.
7. Cost includes the estimated capital and operation and maintenance costs, and the present-
worth costs.
The following "modifying" criteria are considereu iully after the formal public comment period
on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS reports 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 ir.e RI/FS report. Responses to public comments are addressed
in the Responsiveness Summary section of this Record of Decision.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above
follows:
Overall Protection to Human Health and the Environment
The No Action Alternatives (W-l, V-l, G-l) would not be protective of human health and the
environment because the Site would remain in its current contaminated condition. Therefore, the
No Action Alternatives have been eliminated from consice-ation and will not be discussed
further.
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Under the Engineering Controls Alternatives (W-2, V-2. G-2), potential exposure routes of
gamma radiation would be shielded by soil, concrete and/or steel sheeting. The shielding would
have to be maintained, and institutional controls, such as deed restrictions, would be required to
ensure that these alternatives are protective.
For the Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3). all radiological
contamination above cleanup standards would be excavated and disposed of off-site in a licensed
disposal facility. Institutional controls would not be necessary. All unacceptable risks to human
health and the environment would be eliminated by the excavation and off-site disposal of the
radiologically-contaminated waste.
Compliance with Applicable or Relevant, and Appropriate Requirements
Actions taken at any Superfiind site must meet all ARARs of federal and state law. or provide
grounds for invoking a waiver of these requirements. There are three types of ARARs: action-
specific, chemical-specific, and location-specific. Action-specific ARARs are technology or
activity-specific requirements or limitations related to various activities. Chemical-specific
ARARs are usually numerical values which establish the amount or concentration of a chemical
that may be found in, or discharged to, the ambient environment. Location-specific requirements
are restrictions placed on the concentrations of hazardous substances or the conduct of activities
solely because they occur in a special location.
For the Welsbach/GGM site, no requirements are applicable for the cleanup of the radiological
contamination. However, as discussed earlier, portions of the federal regulations governing the
cleanup of uranium mill tailings from inactive uranium processing sites, at 40 CFR 192, have
been determined to be relevant and appropriate. These provide the radon decay products standard
of 0.02 WL and soil cleanup criteria of 5 pCi/g above background.
The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) would comply with all
ARARs. All contamination above the 40 CFR 192 cleanup standards would be excavated and
sent off-site for disposal. The Engineering Controls Alternatives (W-2, V-2, G-2) would comply
with all ARARs that limit exposure to gamma radiation and radon. However, the Engineering
Controls Alternatives would not comply with 40 CFR 192, because the contaminated material
would remain at the Site.
Long-Term Effectiveness and Permanence
The Excavation and Off-Site Disposal Alternatives (W-3, V-3, G-3) are all effective and
permanent. They are considered a final remedial action. The contaminated material would be
removed from the Site and stored in a controlled, licensed off-site facility.
The long-term effectiveness of the Engineering Controls Alternatives W-2 and V-2 would be
uncertain. Contaminated material would remain in place, and the engineering controls would
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require deed restrictions and long-term monitoring. In addition, the engineering controls would
have to be maintained forever because the half-life of thorium is 14 billion years.
Alternative G-2 (Engineering Controls for General Gas Mantle) would not be effective in the
long-term because of the dilapidated nature of the building, even if the building were completely
sealed.
Reduction of Toxicitv. Mobility, or Volume Through Treatment
No treatment technology is known today that can substantially reduce the toxicity. mobility, or
volume of radioactive materials found at the Site, and meet the 40 CFR 192 cleanup standards.
The total amount of radioactivity cannot be altered or destroyed, as is often possible with
chemical contaminants. Therefore, none of the remedial alternatives fill;., satisfy this evaluation
criteria.
However, Alternative G-3 with Option B (the General Gas Mantle Decontamination and
Demolition Alternative) would reduce the volume of contaminated building debris to be disposed
of off-site by pressure washing the radioactive contamination off the floors and walls before
demolition. The contaminants would be concentrated in the filtrate after pressure washing. Only
this filtrate would have to be disposed of in a licensed off-site facility.
Short-Term Effectiveness
Both the Engineering Control Alternatives (W-2, V-2, G-2) and the Excavation and Off-Site
Disposal Alternatives (W-3, V-3, G-3) provide effective short-term protection, and become
effective as they are implemented at individual properties. The estimated time to design and
construct the remedial alternatives for the former Welsbach Facility (Alternatives W-2 and W-3)
and the Vicinity Properties (Alternatives V-2 and V-3) is from three to five years. For the former
GGM Facility, the estimated time to design and construct the Engineering Control Alternative
G-2 is from two to three years, and for the Excavation and Off-Site Disposal Alternative G-3 from
one to two years.
The Engineering Control Alternatives involve less intrusive activities, and pose less of a threat to
workers and the surrounding community than the Excavation and Off-Site Disposal Alternatives.
However, both the Engineering Control Alternatives and the Excavation and Off-Site Disposal
Alternatives involve intrusive activities, including, in some cases, temporary relocation of
residents.
The Excavation and Off-Site Disposal Alternatives have a greater potential adverse impact in the
short term because of the excavation of radiologically-contaminated soil. For future workers, this
could lead to increased short-term exposure to radon, gamma radiation, and soil radionuclides.
Dust suppression techniques and/or other measures would be required to minimize the impacts of
this alternative. However, under Alternative V-2 (Engineering Controls for the Vicinity
24
-------
Properties), there would be some increased short-term risk to workers during the installation of
the radon mitigation systems. This is due to the need to excavate under the foundation of homes
that require radon mitigation.
Implementabilirv
The Excavation and Off-Site Disposal Alternatives (W-3, V-3 and G-3) are readily
implementable. Similar activities have been utilized at other radiologically-contaminated sites
around the country. There is an available off-site disposal facility, which is accessible by both
truck and rail. However, the continued availability of this off-site disposal facility is required for
implementation of these alternatives.
Implementation of the Engineering Controls Alternatives V-2 and G-2 may pose some
difficulties. Under Alternative V-2 (for the Vicinity Properties), there may be some difficulty in
getting the consent of all of the property owners to restrict future work on their properties. EPA
would have to reach agreement with individual property owners to file Declarations of
Environmental Restrictions (i.e., deed restrictions) on their properties. For Alternative G-2 (for
General Gas Mantle), it would be difficult to keep the building permanently sealed from
trespassers.
Cost
Alternative V-2 includes construction costs of $900,000 to implement engineering control
measures at the Vicinity Properties. Annual O&M costs are estimated to be $99,000. The present
worth cost of Alternative V-2 is $1,810,000, with O&M costs assumed for 30 years. Alternative
W-2 includes construction costs of $5,686,000 to implement engineering control measures at the
former Welsbach Facility. Annual O&M costs are estimated to be $44,000. The present worth
cost of Alternative W-2 is $6,182,000, with O&M costs assumed for 30 years. Alternative G-2
includes construction costs of $122,000 to implement engineering controls at the General Gas
Mantle Facility. Annual O&M costs are estimated to be $23,000. The present worth cost of
Alternative G-2 is $381,000, with O&M costs assumed for 30 years. The radionuclides in
question have half-lives far greater than 30 years, so any of the Engineering Controls remedies
must be maintained effectively forever.
Alternative V-3 includes construction costs of $13,408,560 to excavate the radiologically-
contaminated soil at the Vicinity Properties and dispose of the waste at an off-site disposal
facility. Alternative W-3 includes construction costs of $18,503,560 to excavate the
radiologically-contaminated soil at the former Welsbach Facility and dispose of the waste at an
off-site disposal facility. Alternative G-3 - Option A involves construction costs of $2,309,560,
and includes demolishing the General Gas Mantle building and disposal of all the building debris
at an off-site disposal facility Alternative G-3 - Option B involves construction costs of
$1,979,560, and includes decontaminating the General Gas Mantle building before its demolition.
25
-------
There are no O&M costs associated with the Excavation and Off-Site Disposal Alternatives (\V-5i
V-3 and G-3 Options A and B).
State Acceptance
The State concurs with the selected remedial action.
Community Acceptance
EPA solicited input from the community on the remedial alternatives proposed for the
Welsbach/General Gas Mantle Contamination Site. The community was supportive of EPA's
preferred remedy which caHed for the excavation and off-site disposal of the radiologically-
contaminated soils at the Site. The No Action and Engineering Controls Alternatives received no
community support. The attached Responsiveness Summary addresses the comments received
during the public comment period.
SELECTED REMEDY
Based upon consideration of the results of the RI/FS, the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, EPA and NJDEP have determined that the
Excavation and Off-Site Disposal Alternatives (V-3, W-3, and G-3 with Option B) are the
appropriate remedies for the Site.
The selected remedial action will provide a final remedy and achieve the remedial action
objectives at the Vicinity Properties and the Welsbach and General Gas Mantle Facilities by:
eliminating or minimizing the potential for humans to ingest, come in dermal contact with.
or inhale particulates of radioactive constituents, or be exposed to external gamma
radiation, thereby achieving the level of protection required by the NCP;
preventing exposure to radon gas and radon decay products in excess of 4 pCi/L and 0.02
WL, respectively;
preventing direct contact with building surfaces exhibiting total surface thorium
contamination exceeding 0.026uCi/m2 above background;
preventing long-term exposure to thorium- and radium-contaminated materials with
concentrations greater than 5 pCi/g above background; and
preventing migration of radiologically-contaminated materials that could result in
exposures described above.
26
-------
Radiologically-contaminated soil found on the Vicinity Properties and the former Welsbach and
GGM Facilities in excess of 5 pCi/g above background will be excavated consistent with 40 CFR
192. Subparts B and E. The remedy will attain a risk level similar to risk levels associated with
exposure to natural background radiation. This will be confirmed via post-excavation property
surveys. The Multi-Agency Radiation Survey and Site Investigation Manual (MARISSM) may
be used where appropriate to conduct such property surveys. MARISSM provides a methodology
to confirm that a particular soil concentration level has been achieved after the remedial action is
completed. An appropriate survey methodology to be used will be determined during remedial
design.
EPA estimates that the following volumes of contaminated soil and debris will be removed from
the Site: Vicinity Properties - 13,000 cubic yards, General Gas Mantle - 2.500 cubic yards;
Welsbach Facility - 27,000 cubic yards. EPA will dispose of the radiologically-contaminated
material at a licensed, off-site facility. Areas that have been excavated will be restored with clean
fill. No significant changes in land use are anticipated. Because all contamination above the
cleanup criteria will be excavated and sent off-site for disposal, all remediated properties will be
available for unrestricted future use.
EPA will make every effort to minimize any long-term disruption to individual residents or the
community. During excavation, EPA may need to temporarily relocate some residents at
government expense.
As previously stated, EPA will investigate approximately 600 Suspect Properties during the
remedial design phase. When these properties are tested, it is likely that some will be found to
contain radiologically-contaminated material and will require remediation. The selected remedy
also includes such remediation. EPA believes that cleanup of additional contaminated properties
will not affect the overall scope of the remedial action.
STATUTORY DETERMINATIONS
t
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 Supertund 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 statute 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 first operable
unit of the Welsbach/GGM site.
27
-------
Protection of Human Health and the Environment
This remedy is fully protective of human health and the environment for all properties with
radiological contamination above the cleanup standards. It is estimated that no radiological ly-
contaminated soil above the cleanup standards will remain on the affected properties. 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, .-.halation
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.
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 radiologically-
contaminated dust. In addition, no adverse cross-media impacts are expected from the remedy.
Compliance with 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 applicable, they are relevant and appropriate to the
situation at the Welsbach/GGM site. Table 9 lists and summarizes these and other standards that
may be pertinent during the implementation of this remedial action.
When implemented, the cleanup of the affected properties within the study areas will comply with
all public health and soil cleanup ARARs, and will allow for unrestricted use of these properties.
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.
The radioactive half-life of thorium-232, the primary contaminant of concern, is 14 billion years.
Remedies that would isolate wastes containing thorium and the uranium series radionuclides
permanently from the public and the environment are preferable.
Utilization of Permanent Solutions and Alternative Treatment 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
28
-------
be utilized in a cost-effective manner for this phase of the remedial action at the
Welsbach/General Gas Mantle Contamination 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. cost, the statutory
preference for treatment as a principal element and State and community acceptance.
Alternatives V-3, W-3, and G-3 result in a permanent solution to the radioactive contamination.
The longevity of these contaminants of concern (thousands to billions of years) favors excavation
which permanently removes them from their current uncontrolled locations. Commercial disposal
at a licensed facility with an appropriate closure plan will ensure that these radiological wastes are
permanently isolated from human and ecological receptors. The Excavation and Off-Site
Disposal Alternatives are considered implementable and will result in a remedy that is highly
effective in the long-term. These remedies are also consistent with the remedial approach taken at
all other radiologically-contaminated sites in New Jersey.
Preference for Treatment as a Principal Element
The principal threat at the Site is from exposure to excess levels of indoor and/or outdoor gamma
radiation, and ingestion and/or inhalation of radiologically-contaminated soil. In addition, there
are threats from the generation of excess concentrations of radon gas and radon decay products
indoors which migrate from the underlying soils, and are subsequently inhaled by the residents of
those houses. 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 levels of indoor and/or outdoor
gamma radiation. 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.
29
-------
APPENDIX I
FIGURES
30
-------
WELS8ACH/GENERAL GAS MANTLE
CONTAMINATION
SITE STUDY AREAS
FIGURE 1
31
-------
STE-LAR
TEXTILES
FORMER
GENERAL.
GAS MANTLE
FACIUTY --
DYNAMIC /
BLENDING"^
H S
TH
/
RESIDENTIAL
BUILDINGS
JEFFERSON AVENUE /^-ALLEYWAY
-/ /«
MIXWG
ROOM
r
WAREHOUSE
J_
WAREHOUSE
WAREHOUSE
OPEN
SPACE 7
JDADING
CHELTON AVENUE
STREE
ARLING
NDTTDflCALE
was MCH loom stn
STUDY AREA ONE
FORMER GENERAL GAS MANTLE FACILITY LOCATIONS
FIGURE 2
32
-------
Figure 3 - Former Welsbach Facility
ELLIS STREET
-WALT VMTMAN
BRIDGE
-------
APPENDIX II
TABLES
34
-------
TABLE -i
RADIATION UNITS
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
liR/h
rad
rem
International
Unit
Becquerel
Becquerel per
kilogram
~-
Becquerel per
cu. meter
Gray
Sievert
Abbrev.
Bq
Bq/kg
...
Bq/m3
Gy
Sv
35
-------
TABLE-2
PROPERTY C! 1ARAC THR1ZATION
WELSBACII/GGMSITE
STUDY AREA
PROPERTIES SURVEYED BY THE
NJDEP
PROPERTIES WITH NO EVIDENCE OF
CONTAMINATION
0.02 WL RADON DECAY PRODUCTS
> 4.0 pCi/L RADON
AREA 1
359
103
239
17
AREA 2
174
40
113
21
AREA 3
48
18
23
7
AREA 4
474
272
199
3
AREAS
32
16
II
5
ARK A 6
NA1
0
0
1
TOTAL
1088
449
585
54
Nole:
1 - Study Area 6 was not part of the NJDEP investigation.
NA - Not Applicable
36
-------
TABLE 3
ESTIMATED VOLUME OF CONTAMINATED MATERIALS
WELSBACH/GGM SITE
FORMER WELSBACH
FACILITY
FORMER GGM FACILITY
VICINITY PROPERTIES
TOTAL
SOIL
(CUBIC YARDS)
22,200
885
11,010
34,100
STRUCTURAL/DEBRIS
MATERIALS
(CUBIC YARDS)
5,000
1,460
2,255
8,720
37
-------
TABLE 4
RADIOLOGICAL RISK ESTIMATES BASED OIS REASONABLE MAXIMl'M EXPOSURES
AT
FORMER CAS MANTLE MANUFACTURING FACILITIES
POPULATION
PATHWAY
EXPOSURE
MEDIUM
GROSS
RISK
FORMER WELSBACH FACILITY
WORKER
OTHER WORKER
CONSTRUCTION WORKER
EXTERNAL
EXTERNAL
EXTERNAL
INGESTION
INHALATION
SOIL
SOIL
SOIL
SOIL
PARTICULATES
5.70e-02
1 400-02
7.50e-04
3.100-05
1 106-03
BACKGROUND
RISK
NET
RISK
TOTAL
RISK
7.30e-05
1.800-05
8.700-07
5.600-08
8400-07
5700-02
140042
7500-04
3.100-05
1.100-03
5.70*-02
l.40e-02
I.90e-OJ
FORMER C.ENERAL GAS MANTLE FACILITY-
TRESPASSER
CONSTRUCTION WORKER
ADULT RESIDENT
CHILD RESIDENT
WORKER
EXTERNAL
INGESTION
INHALATION
EXTERNAL
INGESTION
INHALATION
EXTERNAL
INGESTION
INHALATION
EXTERNAL
INGESTION
INHALATION
EXTERNAL
INHALATION
SOIL
BUILDING MATERIALS
SOIL
PARTICULATES
RADON DECAY PRODUCTS
SOIL
SOIL
PARTICULATES
SOIL
SOIL
HOME GROWN PRODUCE
RADON DECAY PRODUCTS
SOIL
SOIL
HOME GROWN PRODUCE
RADON DECAY PRODUCTS
BUILDING MATERIALS
PARTICULATES
RADON DECAY PRODUCTS
3 10e-05
2.00e-05
1.900-06
0.00*+00
2.50C-03
2.10e-05
7.500-07
2.800-05
8.90e-03
2.70e-05
2.300-05
4.900-03
1.800-03
1.100-05
1.90046
5600-04
1.400-03
0.000*00
1.800-01
1.300-06
3400-06
1400-07
0.000*00
7400-06
8700-07
5.600-08
8400-07
3.800-04
2.00e-06
3.200X16
8.0004)4
7.800-05
8.100-07
2.700-07
9.200-05
2.400-04
0.000*00
5.100-04
3.000-06
1.700-05
1800-06
0.000*00
2.500-03
2.000-05
6.900-07
2.700-05
8.500-03
2.500-05
2.000-05
4 100-03
1.70043
1.000-05
1.600-06
4.700-04
1.20043
0.000*00
1.800-01
2.50e-OJ
4.80e-OS
IJOe-02
2.20«-03
1.80*-01
38
-------
VICINITY
PROPERTY
PUBLIC PARK
POPCORN
FACTORY
PUBLIC PARK
POPCORN
FACTORY
PUBLIC PARK
LAND
PRESERVE
LAND
PRESERVE
TABLE 5
VICINITY PROPERTIES
SUMMARY OF RADIOLOGICAL RISK ESTIMATES
BASED ON REASONABLE MAXIMUM EXPOSURES*
POPULATION
SITE WORKER
CONSTRUCTION
WORKER
ADULT
RECREATIONALIST
RESIDENT ADULT
CHILD
RECREATIONALIST
RESIDENT CHILD
TRESPASSER
PATHWAY
External
Inhalation of Participates
Inhalation of Radon
Ingestion of Soil
Total:
External
Inhalation of Particulates
Ingestion of Soil
Total:
External
Inhalation of Particulates
Ingestion of Soil
Total:
External
Inhalation of Radon
Ingestion of Soil
Total:
External
Inhalation of Particulates
Ingestion of Soil
Total:
External
Inhalation of Radon
Ingestion of Home Grown
Produce
Ingestion of Soil
Total:
External
Inhalation of Particulates
Ingeauon of Soil
Total:
RISK
GROSS
7.36-01
2.3e-02
1.7e-03
3.0e-03
7.66-01
3.3e-04
l.le-05
1 le-06
3.46-04
2.2e-01
6.9e-03
4.5e-O4
2.3e-01
470-02
1.2e-01
1.2e-04
1.7e-01
44e-02
1.2e-03
1.8e-04
4.5e-02
7.00-02
2.50-02
2.56-03
4.6e-04
9.86-02
2.44-03
1.26-04
2.36-06
2.56-03
BACKGROUND
86*-05
1.8e-06
5.26-04
5.56-07
6 16-04
8.3e-07
3.16-08
3.16-09
8.66-07
2.66-05
5.56-07
83e-08
2.76-05
3.56-04
7.9e-04
206-06
1 16-03
5.16-06
9.46-08
3.3e-08
5.2e-06
6.86-05
9.06X35
3.86-06
786-07
166-04
2.5e-06
9.46-08
3.86-09
2.66-06
NET
T.36-01
2.3e-02
1 2e-03
3 Oe-03
7.6e-01
3.36-04
1.16-05
1.16-06
346-04
2.26-01
6.9e-03
4.5e-O4
2.3e-01
47e-02
126-01
1.26-04
1.76-01
446-02
1.26-03
LBe-04
4.5e-02
7.06-02
2.56-02
256-03
466-04
9.86-02
2.4e-03
126-04
2.3e-06
2.50-03
The exposure duration varies for each population considered in the Risk Assessment Only the maximum risk
estimates for each population evaluated are provided.
39
-------
TABLE 6
RISK ASSESSMENT SUMMARY
FORMER WEI.SBAUI I ACIUI Y
Sccurio TiaefrMM: Foam
Kntpux Faptttatm Ci
RjctplmAgc:
Water
Medium
Soil
Eiposurc
Soil
Paniculate;
Cbenkal
Benzo(a)Anthracene
Benzo(b)Fluoranthene
Benzo(a)Pyrene
Aroclor-1248
Aroclor-1254
Antimony
Arsenic
Selenium
(Total)
Benzo(a)Anthraceiir
Bcnzo(b)Fluoranlhene
Benzo(a)Pyrene
Aroclor-1248
Aroclor-1254
Antimony
Arsenic
Selenium
(Total)
Carcinogenic Risk
Ingestion
6e-08
le-07
6e-07
le-08
le-08
No Tox Data
7e-06
-
7e-06
-
-
-
-
--
-
-
~
--
Inhalation
«
-
*
-
-
-
-
-
No Tox Data
No Tox Data
No Tox Data
2e-09
2e-09
No Tox Data
le-05
--
le-05
Dermal
No Tox Data
No Tox Data
No Tox Data
7e-09
8e-09
No Tox Data
le-06
--
le-06
--
-
--
--
--
-
--
-
--
Total Risk Across Soil
Total Risk Across All Media Hid All Exposure Routes
Exposure
Routes Total
6c-08
le-07
6e-07
2e-08
2c-08
-
8e-06
-
8e-06
--
--
-
2e-09
2e-09
--
le-05
--
le-05
2e-05
2c-05
Chemical
Arsenic
(Total)
(Total)
Non-Carcinogenic Hazard Quotient
Primary
Target
Organ
Skin
Ingestion
le+00
le+00
-
-
--
-
-
-
-
-
-
Inhalation
..
--
--
-
--
--
-
-
-
--
--
Dermal
2e-OI
2e-(ll
--
-
--
--
-
-
-
-
Tola! Hazard Index Across All Media and All l{«posure Kouics
liiul Skin III -
Exposure
Routes Total
le+00
l< "HI
--
-
--
--
-
-
--
--
lr»00
Iff (10
-------
TAI1LE 7
RISK ASSI-SSMI-NT SUMMARY
(il-NI-RAI. GAS MANTLE
Scctuno Tuncftim: fnomt
Rttcptaf PofMhM: CouncbM Water
RcttptmAgt AJull
Medium
Soil
Eipoinrc
Soil
Paniculate;
Chemical
Benzo(a)Anihracene
Benzo(a)Pyrene
Aroclor-1248
Selenium
Thallium
(Total)
Benzo(a)Anthracene
Benzo(a)Pyrene
Aroclor-1248
Selenium
Thallium
(Total)
Carcinogenic Risk
Ingestion
2e-09
2e-08
9e-IO
2e-08
--
--
~
-
-
-
Inhalation
--
--
-
-
--
No Tox Data
No Tox Dala
2e-IO
2e-IO
Dermal
No Tox Dala
No Tox Dala
7e-IO
7e-IO
--
--
--
-
--
--
Toul Risk Across Soil
Toul Risk Across All Media and All Exposure Routes
Exposure
Routes Total
2e-09
2e-08
2e-09
--
-
2e-08
-
--
2e-IO
--
--
2e-IO
2e-08
2e-08
Chemical
Aroclor-1248
Selenium
(Total)
(Total)
Non-Carcinogenic Hazard Quotient
Primary
Target
Organ
N/A
Liver
Ingestion
2e-OJ
2e-04
2e-03
-
-
-
--
--
--
Inhalation
..
-
-
«
-
~
-
-
--
Dermal
le-03
No Tox Data
le-03
«
--
-
-
--
--
Toul lluwd Index Across All Media and All Exposure Routes
Tola! l.iver III -
Rxposure
Routes Total
3e-03
2e-04
3e-03
--
-
-
--
--
-
3e-OJ
2e-04
-------
TABLE 8 1
li
SUMMARY OF ALTERNATIVE COSTS
WELSBACH/GENERAL GAS MANTLE SITE
ALTERNATIVE
NO ACTION
ENGINEERING CONTROLS
EXCAVATION AND
OFF-SITE DISPOSAL
1
PROPERTY
WELSBACH(W-I)
VICINITY PROPERTIES (V-l)
GENERAL GAS MANTLE (G-l)
WELSBACH (W-2)
VICINITY PROPERTIES (V-2)
GENERAL GAS MANTLE (G-2)
WELSBACH (W-3)
VICINITY PROPERTIES (V-3)
GENERAL GAS MANTLE
OPTION A (G-3)1
GENERAL GAS MANTLE
OPTION B (G-3)J
CAPITAL
$0
SO
SO
$5,686,000
$900.000
$122.000
$18,503.560
$13,408,560
$2,309.560
$1,979,560
O& M*
(30 Years)
SO
SO
$0
$496,000
$910.000
$259.000
SO
$0
$0
SO
TOTAL
$0
$0
$0
$6,182.000
SI. 8 10.000
$381.000
$18.503.560
$13,408,560
$2,309.560
$1,979.560
* O&M costs calculated using an 8 percent discount rate
1. Option A: Demolition and Disposal of GGM building
2. Option B: Decontamination and Demolition of GGM building
-------
TABLE 9
SITE SPECIFIC CLEANUP STANDARDS
TYPE
PERTINENT
STANDARD OR
GUIDELINE
SOURCES
Radon and Thoron
Indoor Concentration
4pCi/L
Citizen Guide to
Radon (EPA 1992)
Radon and Thoron
Decay Progeny:
Average
Maximum
0.02 WL
0.03 WL
40CFR192
40CFR192
Soil:
Radium and
Other Radionuclides
5 pCi/g - Sum of 226Ra and 228Ra
5 pCi/g - Sum of "°Th and 232Th
40CFR192
Subsurface Soil:
Radium and
Other Radionuclides
5 pCi/g - Sum of 226Ra and 228Ra
5 pCi/g - Sum of 230Th and 232Th
OSWER Directive
9200.4-25
Wetlands
Protection of Wetlands
Clean Water Act
40 CFR 230.1 etseq.
Executive Order 11990
Endangered Species
Protection of Endangered and
Threatened Species
Endangered Species Act
16 U.S.C. 1536 (a)(2)
Historic Buildings
Protection of Archaeological
Significant Items
National Historic
Preservation Act
16 U.S.C. 470(f)
43
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APPENDIX III
ADMINISTRATIVE RECORD INDEX
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WELSBACH & GENERAL GAS MANTLE CONTAMINATION
ADMINISTRATIVE RECORD
INDEX OF DOCUMENTS
1.0 SITS IDENTIFICATION
1.2 Notification/Sit* Inspection Report!
100001-
100308
100309-
100551
100552-
101016
101017-
101428
Report: Final Hazard Ranking System Documentation.
Welsbaeh and General Gas Mantle Contamination
Sites. Camden and Gloucester Cicv. New Jersey.
Volume I of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking System Documentation.
Welsbaeh and General Gas Mantle Contamination
Sites. Camden and Gloucester Citv. New Jersey.
Volume II of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking System Documentation.
We-lsbach and General Gas Mantle Contamination
Sitea. Camden and Gloucester Citv. New Jersey.
Volume III of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking Svatem Documentation.
Welab*eh and General Gaa Mantle Contamination
Sites. Camden and Gloucester Citv. Mew Jersey.
Volume iv.of VIII. prepared for the Environmental
Service* Division, U.S. EPA, Region II, prepared
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101429-
101707
101708-
102024
102025-
102600
102601-
102920
by Mr. Steven T. McNulty, Project Manager, Kr.
Todd G. Teryek, Task Leader. Mr. Jchr. 1.
Splendore, P.E., Work Assignment Manager, 'J.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking System Document a tirr..
Helsbaeh and General Gas Mantle Cor.tatr.ir.aticr.
Sitea. Camden and Gloucester Citv. New Jersey.
Volume V of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking System Documentation.
Welabaeh and General Gas Mantle Contamination
Sites. Camden and Gloucester Citv, New Jersey.
Volume VI of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 1995.
Report: Final Hazard Ranking System Documentation.
Helsbaeh and General Gas Mantle Contamination
Sites. Camden and qioueeater Citv. New Jersey.
Volume VII of VIII. prepared for the Environmental
Services Division, U.S. EPA, Region II, prepared
by Mr. Steven T. McNulty, Project Manager, Mr.
Todd G. Teryek, Task Leader, Mr. John L.
Splendore, P.E., Work Assignment Manager, U.S.
EPA, Region II, March 27, 199S. (Note: The
Gloucester City/Camden Survey of Affected
Properties for Senior Citizens and Children, pages
102298-102305, is confidential due to the Privacy
Act. It is located at the U.S. EPA Superfund
Records Center, 290 Broadway. 18th Fl., N.Y., N.Y.
10007-1866.)
Report: Final Hazard Ranking System Documentation.
Welabaeh and General Gas Mantle Contamination
Sites. Camden and Gloucester Citv. New Jersey.
Volume vili of v;;i. prepared for the
Environmental Services Division, U.S. EPA, Region
XI, prepared by Mr. Steven T. McNulty, Project
Manager, Mr. Todd 0. Teryek, Task Leader, Mr. John
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L. Splendors. P.ET. , Work Assignment Manager, V.S.
EPA, Region II, March 27, 1995. (Note: The Quality
Control Internal Controls and Audits Manual, paces
102763-102822, and The Quality Assurance Manual,
pages 102823-102876, are confidential business
information. They are located at the U.S. EPA
Superfund Records Center, 290 Broadway, 18th ri . ,
N.Y., N.Y. 10007-1866.)
1.4 Sit* Investigation Report*
102921- Report: An Aerial Survey yf Gloucester. New Jg^-s
102947 and Surrounding Area, prepared for the U.S. EPA,
Region II, prepared by Mr. Joel E. Jobst, Mr.
Harvey W. Clark, Project Scientists, May 1981.
3.0 RBOEDXAX. INVESTIGATION
3.3 Work Plans
P. 300001- Plan: Welsbach/General Gas Mantle Contamination
300192 Site, Camden, New Jersey, Work Assignment No.050-
28UC, Draft Final Work Plan, Remedial
Investigation/ Feasibility Study, Volume I,
prepared for the U.S. EPA, Region II, prepared by
Malcolm Pirnie, Inc., June 1997.
3.4 Remedial Investigation Reports
P. 300193- Report: Helsbaeh/General Gas Mantle Contamination
300347 Sice. Camden. New Jersey. Work Assignment No. 050-
2flUC. Stage la Archaeological Investigation.
prepared for the U.S. EPA, Region II, prepared by
Malcolm Pirnie, Inc., June 1998.
P. 300348- Report: Welflbaeh/General Gas Mantle
300694 Contamination Site. Camden. Mew Jersey. Work
Assignment No. QSO-2BUC. Draft Final Remedial
Investigation/Feasibility Study Report. Volume I.
prepared for the U.S. EPA, Region II, prepared by
Malcolm Pirnie, Inc., June 1998.
P. 300695* Report: Welsbaeh/General Saa Kanrl*
301035 Contamination Site. Camden. New Jersey. Work
Assignment No. Q50-2BUC. Draft Final Remedial
Investigation/Feasibility Study Report. Volume II.
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prepared for the U.S. EPA, Region II, prepared by
Malcolm Pirnie, Inc.. June 1996.
3.5 Correspondence
P. 301036- Report: Welabaeh/ General Gas Mantle Concamir.aricr.
301134 Sice. Camden. New Jersey. Werk Assignment Ne. 050-
2SUC Response ;a Comments, prepared for the U.S.
EPA, Region II, prepared by Malcolm Pirnie, Inc.
November 1997.
P. 301135- Memorandum to Addressees, from Stephen 0. Lufcig,
301145 Director, of Office of Emergency and Remedial
Response, and Mr. Larry Weinstock, Acting
Director, Office of Radiation and Indoor Air, re:
Establishment of Cleanup Levels for CERCLA Sites
with Radioactive Contamination, August 22, 1997.
P. 301146- Memorandum to Addressees, from Mr. Stephen D.
301151 Luftig, Director, of Office of Emergency and
Remedial Response, and Mr. Larry Weinstock, Acting
Director, Office of Radiation and indoor Air, re:
Use of Soil Cleanup Criteria in 40 CFR Part 192 as
Remediation Goal for CERCLA sites, February 12,
1998.
7.0 XHFORCZKXHT
7.3 Administrative Orders
P. 700001- Administrative Orders on Consent for Remedial
700059 Investigation/Feasibility Study Armstrong
Building, In the Matter of Welsbach Gas Mantle
Contamination Site (BU), Holt Hauling and
warehouse System, Inc., Respondent, undated.
8.0 HEALTH ASSESSMENTS
1.1 ATSD* Health Asseeaaaat*
P. 800001- Memorandum to Mr. John Prince, ERRD/NJSB1-N, from
800037 Mr. Arthur Block. Senior. Regional Representative,
re: Final Health Consultation for Welsbach and
General Gas Mantle Contamination Sites (WGGMCS),
March 12, 1997.
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10.0 PUBLIC PARTICIPATION
10.2 Coanunity Relations Plaaa
P. 10.00001- Plan: Welsbach/General Gas Mantle Contamination
10.00038 Sice, Camden, New Jersey, Work Assignment No. C5:-
28UC, Draft Final Community Relations Plan,
Remedial Investigation/Feasibility Study, prepare:
for the U.S. EPA. Region II, prepared by Maicclm
Pirnie, June 1997.
10.9 Proposed Plan
P. 10.00039- Plan: Superfund Proposed Plan, Welsbach/General
10.00059 Gaa Mantle Contamination, Superfund Site, Camden
and Gloucester City, Camden County, New Jersey,
prepared by U.S. EPA Region II. February 1999.
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APPENDIX IV
STATE LETTER
-------
SBVT BY'SITE REMEDIATION : 7-21-93 :12:4SPM : FAX * 609 633 2360- 212 637 4429:* 2/ 3
Tedd Whihncn . D«partm«nt of Knviron»ivnl«l Pruteiliuii Rnburt C. Sninn. Jr
Governor irftn iflti "i»»l«dmr Coj»ffi'««jan«r
r.O. B*i 402
TIMIM. NOT* Jtiwjr
-1114
July 21. 1999
Ms. Jeanne M. Fox
Regional Administrator
U.S. EPA - Region II
290 Broadway
New York, NY 10007-1866
Subject: Webbaca/Gencral Gas Mantle Contamination Superfund Site
Record of Decision (ROD)
Door Ma. POM:
The New Jersey Department of Environmental Protection (NJDEP) has evaluated and concurs
with the components of the selected remedy as described below for the WeJsbscLCcac.-3>! CM
Mantle Superfund Site. The selected remedy corresponds to the first of three planned operable
units for the Site which includes properties located in Gloucester City and Camden, Camden
County, New Jersey.
The major components of the (elected remedy include:
Bxeavatkn/removal of soil and waste materials with radiological contamination above remedial
acooo objectives from the former Welsbacb and General Gas Mantle Facilities;
Excavation/removal of soil and waste materials with radiological uunuuninalion aliuve laindiai
action objectives from the residential and commercial properties in the vicinity of two former
M« m»t^t^» ftfilltTfj'
Off*ite disposal of the radiologically-contaminated soil and waste materials;
Decontamination and demolition of the General Gas Mantle Building; and
Appropriate environmental monitoring to ensure the effectiveness of the remedy.
NJDEP concurs that the selected remedy is protective of human health and the environment,
complies with requirements that are legally applicable or relevant and appropriate for the
remedial action, and is cost effective.
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oioiic
^*orm TAA » ouo ooo ^ooir* ^i^ 60 ' f*^o-* o/ o
The State of New /cracy appreciated du. e>ppcituj\it; *IToidcd u> |«*<'bw«p«u. i» (Ji>.
process.
C. Shinn. Jr.
Commissioner
New Jersey Department of Environmental
Protection
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APPENDIX V
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
WELSBACH/GENERAL GAS MANTLE CONTAMINATION SITE
GLOUCESTER CITY & CAMDEN, CAMDEN COUNTY, NEW JERSEY
I. INTRODUCTION
This Responsiveness Summon- provides a summary of pubjic comments and concerns regarding
the remedial investigation and feasibility study (RJ/FS) report and the Proposed Plan for the
Welsbach/General Gas Mantle Contamination site. It also provides the U.S. Environmental
Protection Agency's (EPA's) responses to those comments. After reviewing and considering all
public comments received during the public comment period. EPA has selected a remedy tor the
former Welsbach Facility, the former General Gas Mantle (GGM) Facility, and the Vicinity
Properties at the Welsbach/General Gas Mantle Contamination site.
The RJ/FS report, the Proposed Plan and supporting documentation were made available to the
public in the administrative record file at the Superfund Document Center in EPA Region II. 290
Broadway. 18'h Floor, New York, New York 10007and at the following repositories: City of
Camden Main Library, 418 Federal Street, Camden, New Jersey 08103; the Hynes Center, 1855
South 4lh Street, Camden, New Jersey 80104; and the Gloucester City Public Library. Monmouth
and Hudson Streets, Gloucester City, New Jersey 08030. The notice of availability for the above-
referenced documents was published in the Philadelphia Inquirer on February 1. 1999. the
Courier-Post on February 2, 1999, and the Gloucester Citv News on February 4. 1999. The
public comment period which related to these documents was held from February 1, 1999 to
March 3. 1999.
EPA conducted public meetings in both Gloucester City and Camden to inform local officials
and interested citizens about the Superfund process, to review proposed remedial activities at the
Site and receive comments on the Proposed Plan, and to respond to questions from area residents
and other interested parties. Meetings were held on February 23, 1999, at the Pine Grove Fire
Station #2 in Gloucester City, and on February 24, 1999, at the Camden County Municipal
Utilities Authorities Auditorium in Camden. Responses to the comments received at the public
meeting are included in this Responsiveness Summary. The City of Gloucester City submitted a
resolution supporting the proposed remedy. No other written comments were received during the
public comment period.
In general, the community responded positively to EPA's Proposed Plan. A majority of the
residents recognized the importance of remediating the contamination at the Welsbach/General
Gas Mantle Contamination site.
The next section of this Responsiveness Summary provides a comprehensive summary of major
questions, comments, concerns, and responses, by summarizing oral comments made at the
public meetings and EPA's responses.
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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, and a Proposed Plan Summary that was provided to interested parties with the
Proposed Plan;
Appendix B contains the public notices which appeared in the Philadelphia Inquirer, the
Courier-Post, and the Gloucester Citv News:
Appendix C contains the transcripts of the public meetings: and
Appendix D contains the \vritten comments received by EPA during the public comment
period.
II COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
CONCERNS. AND RESPONSES
Oral Comments Received During the Public Meetings
This section summarizes oral comments raised at the public meetings and EPA's responses. The
comments and corresponding responses are presented in the following categories:
1.0 Remedial Investigation and Feasibility Study
2.0 EPA's Proposed Plan
3.0 Health and Safety
4.0 Cleanup Schedule
5.0 Public Participation Process
6.0 Real Estate Issues
7.0 Other
1.0 Remedial Investigation and Feasibility Study
1.1 Comment: An interested resident noted that the maps prepared for the project showed that
properties north of the General Gas Mantle Building were not investigated. EPA was asked
whether these properties would be included in future investigations.
Response: During the remedial design, EPA will investigate these properties and other
properties that are adjacent to known contaminated properties.
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2.0 EPA's Proposed Plan
2.1 Comment: An interested citizen asked what will happen to the residents while the remedial
work is going on.
Response: EPA will work with the property owner(s) so that there is as little inconvenience to
residents as possible. If there is a need for temporary relocation, the property owner will not be
responsible for any costs. All costs associated with the temporary relocation will be paid by
EPA.
2.2 Comment: An interested citizen asked if the decision on whether to proceed with the
demolition of the GGM building and excavation of the contaminated material from the site has
been made.
Response: EPA will not make a final decision until all public comments have been received:
however, the preferred remedy calls for the demolition of the GGM building and the excavation
and off-site disposal of the radiologically-contaminated soils and waste materials. At that time.
EPA will issue the Record of Decision (ROD) which formally selects a remedy for the cleanup of
the site.
2.3 Comment: An interested resident inquired as to how the contaminated material would be
shipped from the site.
Response: The material will be shipped off-site via rail transport. The material will be
excavated from any given contaminated property and loaded onto a truck for transport to a rail
loading site in or near Gloucester City or Camden. Measures will be taken to secure the
containers holding the contaminated material to ensure the public's safety.
2.4 Comment: An interested resident asked how deep the excavations are going to be in the
backyards of the homes on Arlington Street in Camden.
Response: At this time, EPA does not know the exact depths and volumes of soil that would
need to be removed from the Arlington Street properties. The exact volumes will be determined
during the remedial design phase. For the purpose of the RI/FS, volume estimates were based on
the investigation of other properties with similar conditions. Based on this information, EPA
estimates that contamination is generally limited to the top one to two feet of soil.
2.5 Comment: An interested citizen asked if there is a work plan for the demolition of the GGM
building and excavation and off-site disposal of the radiologically-contaminated materials.
Response: A work plan for the construction activities will be prepared after the Remedial Design
is completed. Prior to beginning construction activities, EPA will hold public meetings
-------
describing the construction activities that would take place. At that time, a work plan woulJ be
available for review at the public repositories.
2.6 Comment: An interested citizen complimented EPA on selecting the most thorough remed>
and asked whether the cleanup will allow for future unrestricted use of the properties.
Response: The cleanup criteria are protective of both human health and the environment.
Consequently, once the material has been removed, there would be no restriction on ruture uses
of these properties.
2.7 Comment: An interested resident asked if residents would be relocated during the cleanup
and for how long.
Response: Based on EPA's current findings, only a limited number of individuals may need to
be temporarily relocated during remediation. EPA would assure that relocated residents would
be provided with comparable accommodations. EPA would pay for temporary relocation
expenses. On similar sites that required relocation, EPA has found that the length of time a
resident would be relocated ranges from three to six months.
2.8 Comment: An interested party asked if EPA is going to check for radon in the basements.
Response: Part of EPA's investigation protocol is to perform a radon test on any potential
radiologically-contaminated property.
2.9 Comment: A interested party asked whether EPA would reconsider the cleanup plan if it
discovered much more contamination that expected.
Response: EPA does not anticipate finding such a substantial additional amount of
contamination that it would require changing the proposed remedy. The communities of both
Camden and Gloucester City support the remedy. Where EPA finds radiological contamination,
it will take it away. Once the ROD has been issued, EPA would be required to hold additional
public meetings and receive public comment before it modified the selected remedy.
3.0 Public Health Concerns
3.1 Comment: An interested resident questioned whether there were any long-term health
effects associated with the site. In particular, the resident mentioned the recent cancer study
prepared by the New Jersey Department of Health which indicated a higher than normal
occurrence of lung cancer throughout the area surrounding the site.
Response: The only long-term health effect from radiation is an increase in the risk of
developing cancer. Although the study indicated that there was an increase in the incidence of
-------
lung cancer in the area, the results of the cancer study indicate that the Superfund sites were no;
the probable cause for this increase.
3.2 Comment: An interested citizen inquired about whether a health .study would be performed
on the residents of contaminated properties both prior to and following any remedial actions.
Response: EPA does not plan to perform focused health studies on residential property owners
in the future.
3.3 Comment: An interested resident asked what would be done for the residents while the soil
was being removed and will this pose any problems for people. How is EPA going to protect
them?
Response: The problems are more logistical than health based. The work will be performed in a
controlled manner to reduce dust and to ensure there is no spread of contamination. If there is a
potential health risk or significant inconvenience to the property owner, the homeowner may be
temporarily relocated until the work is complete.
3.4 Comment: A resident found some material from Welsbach in his home and was concerned
about possible health affects.
Response: At the public meeting. EPA informed the resident that it would scan his property to
see if there was any radiological contamination. A few days after the public meeting, EPA
investigated the property and found no radiological contamination.
4.0 Cleanup Schedule
4.1 Comment: An interested resident asked how soon the former GGM building would be
demolished.
Response: EPA anticipates that the GGM building will be demolished within one to two years.
5.0 Public Participation Process
5.1 Comment:An interested resident asked whether EPA was in contact with Camden city
officials.
Response: Yes, EPA has discussed the proposed remedial actions with the City of Camden's
mayor's office.
5.2 Comment: An interested resident asked what the next steps would be regarding informing
the residents of upcoming activities.
-------
Response: Following the public comment period. EPA will prepare a ROD which selects the
cleanup remedy for the site. The ROD will include all of the public comments and EPA's
responses. After the ROD is signed. EPA will place it in the local public repositories. The nex:
public meeting will be held prior to the start of any construction activities. EPA will also
provide periodic updates during the cleanup process.
6.0 Real Estate Issues
6.1 Comment: An interested citizen asked what could or should be done if an owner of a
contaminated property wishes to sell the property.
Response: The owner should provide a prospective buyer with all data about contamination on
the property. The participants in the transaction would need to obtain the advice of an Attorney
regarding their obligations under State law. If necessary. EPA can enter into an prospective
purchaser agreement with a potential purchaser of a contaminated property. The agreement
would provide that the purchaser would not be held liable for any cleanup costs associated with
the property. EPA's policy is not to pursue innocent landowners for cost recovery.
6.2 Comment: An interested resident asked whether the owner of a contaminated property who
became the owner through inheritance from a relative would be responsible for cleanup costs.
Response: Persons who inherit contaminated property will not be held responsible for cleanup
costs if they can demonstrate that they had nothing to do with the contamination and can meet
the other requirements set forth in Sections 107(b) and 101 (35(A)(iii.) of CERCLA. There are
similar provisions in State law and an Attorney should be consulted on these matters.
Furthermore, under EPA's existing policy, residential owners of contaminated property will not
be asked to demonstrate that they have defenses to liability or asked to reimburse EPA for the
costs of cleaning up that property so long as the owners did not cause or exacerbate the
contamination and they cooperate with EPA's cleanup efforts.
7.0 Other
7.1 Comment: An interested resident asked if the NJDEP had performed property surveys in the
neighborhood of the Jogging Track, where a removal of contaminated material occurred.
Response: With few exceptions, the properties surveyed by the NJDEP were within the areas
identified in the Aerial Radiological Survey performed by EPA in 1981. Certain areas were
excluded based upon records which indicated that homes were constructed prior to the dates of
dumping/filling activities. Because the area in question was outside the areas identified in the
aerial survey. NJDEP did not survey this area.
7.2 Comment: An interested citizen asked if money has been approved for this project.
-------
Response: EPA has allocated money for the design of the project. The design phase of the
project must be completed before EPA can allocate money for construction. When the design
phase is complete, EPA's regional office will request EPA Headquarters in Washington. DC. to
allocate funding for this project. At this time, we do not anticipate any problems.
7.3 Comment: A number of residents expressed concern over security issues associated with the
radiological contamination at the Popcorn Factor.- pan of the site in Gloucester City.
Response: The former Popcorn Factory property is surrounded by a fence to keep people away
from the contamination. Gloucester City also placed gravel over the contaminated areas to
protect the residents. There are no signs posted because a majority of the residents in the area
informed city officials that they preferred no signs around the property. The contaminated
materials from EPA's removal action which are presently being stored in roll-offs on the
property are securely covered. (Since the public meeting, the roll-off containers have been
removed and disposed off-site.)
7.4 Comment: A number of citizens questioned whether contamination was found in the area
designated for a playground near the Jogging Track in Gloucester City.
Response: At the public meeting EPA indicated that it would investigate the area designated for
the playground prior to its construction. In March 1999, EPA investigated this area and found no
radiological contamination.
Written Comments Received During the Public Comment Period
Comment: The City of Gloucester City submitted a resolution endorsing EPA's plans for
cleaning up the radiologically contaminated properties in Gloucester City.
Response: No response necessary.
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Appendix A
Proposed Plan
-------
Superfund Proposed Plan
Welsbach/General Gas Mantle Contamination
Superfund Site
Cam den and Gloucester City
Camden County, New Jersey
Region 2
Februarv 199
Mark Your Calendar
Public Comment Period
February 1.1999 to March 3,1999
Public Meetings:
Gloucester City
Tuesday. February U, 1999 at
7:00 p.m. at Pine Grove Fire Station #2
Camdeo
Wednesday. February 24,1999 at
7:00 p-m. at Camden County Municipal
Utilities Authority Auditorium
Availability Sessions -
informal question and answer sessions:
Gloucester Cliy
Tuesday, February 23,1999, from
1:00 p.m. to 4:00 p.m. at Pine Grov?
Fire Station *2
Camden
Wednesday, February 24,1999, from
1:00 to 4:00 pun. at Camden County
Municipal Utilities Authority Audiioriun:
PCRPOSE OF THE PROPOSED PLAN
This Proposed Plan describes the remedial alternatives that the L'.S Environment
Protection Agency (EPA) considered in addressing soil and building maim
contamination at the Welsbach/General Gas Mantle Contamination Sue (Sue). T)
plan also identifies EPA's preferred remedial alternatives and the rationale for th
preference. This document was developed by EPA, in consultation with the New Jerv
Department of Environmental Protection (NJDEP). The alternatives summarized he
are described in greater detail in the Remedial Investigation and Feasibility Stud
which is now available at the City of Camdec Main Library. Camden. New Jersey: d
Hynes Center. Camden. New Jersey, the Gloucester City Public Library, G loucesrer C it
New Jersey; and at EPA's offices at 290 Broadway. 18th Floor. New York. New Yor
EPA's preferred remedial alternatives address soil and building contamination at d
Site. The preferred alternatives are the excavation and off-site disposal alternatives f
the Vicinity Properties. Welsbach Facility and General Gas Mantle Facility I Aliematr
V-3.W-3. and G-3 with Option B).
EPA encourages the public to review and comment on all of die alternatives considen
by EPA in this Proposed Plan. The remedies described in mis Proposed Plan are EPA
preferred remedy for the She. Changes to the preferred reaedy or a change from tl
preferred remedy to another remedy may be made if public comments or additional da
indicate that such a change will result in a more appropriate remedy EPA, i
consultation with NJDEP. will select the remedy after considering all pool.
comments.*
COMMUNITY ROLE IN SELECTION PROCESS =
EPA relies on public input to ensure that the concerns
of the community are considered in selecting an
effective remedy for each Superfund site. To this
end. EPA has made the Remedial Investigation and
Feasibility Study (RJ/r S) report. Proposed Plan, and
supporting documentation available to the public for a
public comment period from February 1,1999, to
March 3,1999.
During the public comment period. EPA will hold a
public meeting at the Pine Grove Fire Station *2 in
Gloucester City on Tuesday, February 23,1999 at
7:00 p.m., and at the Camden County Municipal
Utilities Authority Auditorium, in Camdzn on
Wednesday, February 24,1999 at 7:00 p.m. At
these meetings, EPA will present the conclusions of
the RI/FS. discuss the reasons for recommending the
preferred remedial alternatives, and receive public
comments.
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EPA will also be available on an informal basis to
answer any questions at the Pine Grove Fire Station
*2 on Tuesday, February 23, 1999, from 1:00 p.m.
to 4:00 p.m.. and at the Camden County Municipal
Utilities Authority Auditorium on Wednesday,
February 24. 1999, from 1:00 to 4:00 p.m.
Comments received at the public meeting, and all
written ccruner/^, will be documented in the
Responsiveness Summary Section of the Record of
Decision (ROD), the document which formalizes the
selection of the remedy. All written comments
should be addressed to:
Richard J. Robinson
Project Manager
L'.S. Environmental Protection Agency
290 Broadway. 19th Floor
York. AT 10007-1866
Copies of the Rl/FS report. Proposed Plan, and
supporting documentation are available at EPA's
office at 290 Broadway. 18th Floor, New York, NY
10007-1866. (212) 637-4308, and at the following
repositories:
City of Camden Main Library
41 8 Federal Street
Camden, NJ 08 103
(609) 757-7650
Hynes Center
1855 South 4* Street
Camden, NJ 80 1 04
(609)966-9617
Gloucester City Public Library
Monmouth and Hudson Streets
Gloucester City. NJ 08030
(609)45^4181
EPA, after consultation with NJDEP, will select a
remedy for the Site only after the public comment
period has ended, and the information submitted
during that time has been reviewed and considered.
EPA is issuing this Proposed Plan as pan of its public
participation responsibilities under Section 1 !~.ai of
the Comprehensive Environmental Response.
Compensation and Liability Ac: iCERCLA.-. 25
amended, and Section 300.430(f) of the Natior.^; L'I!
and Hazardous Substances Pollution Cor.uncer.j>
Plan (NCP).
'SITE BACKGROUND
Between the 1890s and 1940s, the Welsbach
Company (Welsbach) manufactured gas mantles a: its
facility in Gloucester City, New Jersey. Welsbach
was a major manufacturer and distributer of gas
mantles until gas lighting was replaced by*the electric
light Welsbach extracted the radioactive element
thorium from ore ?.nd used it in the gas mantle
manufacturing process. Thorium causes the mantles
to glow more brightly when heated. A second gas
mantle manufacturing facility, known as the General
Gas Mantle Company (GGM). was located in
Camden. New Jersey. GGM was operated from 1915
to approximately 1940.
EPA initially identified the Site in 1980. during an
archive search conducted as pan of the investigation
of the U.S. Radium Corporation Superfund site
located in Orange, New Jersey. Historical U.S.
Radium Corporation files indicated that radiological
materials were purchased by U.S. Radium from the
Welsbach Corporation during the 1920s.
In May 1981. EPA conducted an aerial radiological
survey of the Camden and Gloucester City area to
investigate for radioactive contaminants. The survey
encompassed a 20 square kilometer area surrounding
the former locations of Ac Welsbach and General Gas
Mantle Facilities. Five areas with elevated gamma
radiation were identified from the aerial survey; they
included the locations of the two former gas mantle
manufacturing facilities and three mainly residential
areas in both Camden and Gloucester City. In 1993,
the data from the aerial survey were reanalyzed.
Based or. this revised information, EPA identified z
sixth potential radiologically contaminated area which
includes rwo vacant lots in Gloucester City.
EPA Region 2 - February 1999
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In the early 1990s. NJDEP conducted more detailed
radiological investigations at more than 1.000
properties located throughou: the original five study
areas. Radiological contamination was found at the
iwo former gas mantle faciliues. NJDEP data also
indicated that approximately 100 properties near the
rxvo former gas mantle facilities might be
contaminated. In 1996. the "-Velsbach/GGM site was
placed r- National Priorities List (NPL) because of
the presence of radioactive contaminants.
Based on their geographic proximity. EPA divided
the Welsbach'GGM site into six study areas in
Camden and Gloucester City. New Jersey (Figure 1).
A brief description of each study area and its current
land use is presented below:
Study Area One: includes the former General
Gas Mantle Facility and residential and
commercial properties which surround the facility.
The former GGM Facility is located in a mixed
industrial, commercial, and residential zoned
section of Camden.
Study Area Two: includes the location of the
former Welsbach Facility and nearby
residential/commercial properties. The former
Welsbach Company is situated in an industrial
zoned section of Gloucester City with residential
properties to the immediate east.
Study Area Three: includes residential and
recreational properties in Gloucester City.
including the Gloucester City Swim Club and the
Johnson Boulevard Land Preserve.
Study \rea Four includes residential properties in
the Fair-view section of Camden.
Study Area Five: includes residential properties.
vacant land properties, and two municipal parks
near Temple Avenue and the South Branch of
Newton Creek in Gloucester City.
Study Area Six: includes two vacant lots in a
residential zoned area of Gloucester City. This
area was initially identified when the aerial survey
data were revised in 1993. This area was
ider.tified during site assessments performed b> th«
Ci:y of Gloucester City.
No significant changes in land use are 2ntic:p2'.Svi.
except in the Study Area I where there is 2. poss:bf.::>
that some residential areas may be rezoned for
commercial uses. Whether zoning chances w-11
actually be made is uncertain at this time.
'SITE HISTORY
The Welsbach and the GGM Facilities have complex
histories of name and ownership changes. Specific
details are discussed in the paragraphs below.
The United Gas Improvement Company, which
formed Welsbach. purchased the patent rights to
manufacture thorium-containing gas mantles in the
1880s from Dr. Carl Auer von Welsbach. The
process for manufacturing the Welsbach gas mantle
used a highly purified solution of 99 percent thorium
nitrate and 1 percent cerium nitrate 25 a "lighting
fluid" in distilled water. A fabric sock was then
dipped into the thorium solution to create the gas
mantle. Thorium caused thr _-as mantle to give off a
very bright white light when lit
The commercial source of thorium and cerium is a
mineral known as monazitc sand. Monazite sand
contains approximately 5-6 percent thorium oxide
and 20-30 percent cerium oxide. Thorium was
typically extracted from the monazite ore by heating
the ore in a sulfuric acid solution. The thorium and
other rare earth elemen's would go into solution,
while Lie radium-228 remained in the tailings of
insoluble sulfates. Around 1915. Welsbach started
using and selling the radium-228 for its use in
luminescent paint For a number of years. Welsbach
was the largest manufacturer of gas mantles in the
world making up to 250.000 mantles per day at its
peak.
Welsbach also made gas room heaters, gas storage
water heaters, gas and electrical fixtures, electrical
refrigerators, plumbing supplies and lacquers.
Manufacturing operations at the Welsbach facility
EPA Region 2 - February 1999
Page 3
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*«* 1.**
w.CS.* ' ++ i»
'*";<,
\ A'ifcSJ
SOURCE: CAMOCN. NJ - USGS QUAOMNACLI
WELSBACH/GENERAL GAS MANTLE
CONTAMINATION SITE STUDY AREAS
Page 4
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began as early as 1882 and tasted until the 1940s.
The facility property covered an area of about 21
acres, and consisted of about 20 buildings.
In 1948. the former Welsbach Facility in Gloucester
City was sold to the Randall Corporation, and leased
to the Radio Corporation of America, Victor
Division. In May 1976, the property was purchased
by Holt Hauling and Warehousing, Inc. (Holt), the
current owner of the property. Holt operates a cargo
and overseas shipping business.
Only one Welsbach era building, the Armstrong
Building, is still present on the property. There is no
information available on when the other Welsbach-era
buildings were demolished. The Armstrong Building
is not pan of this Operable Unit. Holt is performing
an RI/FS of the Armstrong Building under an
Administrative Consent Order with EPA.
The former gas mantle manufacturing facility in
Camden was owned and operated by the GGM
Company from 1912 to 1941. There is little
information available regarding activities at GGM,
other than it used and resold radium and thorium.
Between 1941 and 1978. there had been a total of
seven different private owners of the property. Based
on current information, none of these operations
involved radioactive materials. In January 1978, the
southern portion of the property was occupied by the
Dynamic Blending Company. In October 1988, the
northern portion of the property was purchased by
Ste-Lar Textiles. In 1992, NJDEP removed
radiologically contaminated fabrics from the facility,
relocated Ste-Lar, and sealed up the GGM building to
restrict access.
During the years that Welsbach and GGM operated,
ore tailings were used for fill at properties in the
vicinity of the facilities. It is also reported that
building debris from the former Welsbach Facility
may have been disposed of as fill in the area. In
addition, workers from the former Welsbach and
GGM Facilities may have brought contamination
home with them. These properties associated with
radiological waste from the Welsbach and GGM
Facilities are collectively termed Vicimn Properv.es
In 1991. NJDEP initiated a radiological investigation
at more than 1.000 properties located throughout
Study Areas 1 through 5. At properties where
NJDEP determined that exposure levels were
unacceptable (or posed an immediate health risk*.
they performed interim remedial measures. These
measures included the installation of radon thoron
ventilation systems and placement of concrete or lead
sheeting to shield gamma radiation. In addition.
NJDEP restricted access to outdoor areas which
exceeded its action levels.
In 1998. EPA identified a 100 square foot area in a
Gloucester City Park, located in Study Area 5. that
had high levels of gamm- radiation at the surface. In
December 1998. EPA performed a removal action to
reduce exposure to the high levels of gamma
radiation at the surface. EPA excavated the top three
feet of radiologically contaminated soil and replaced
the waste material with clean fill.
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. There are approximately 1,700 different
unstable atomic species, or radionuclides. These
include both naturally occurring and man-made
radionuclides.
The radionuclides of concern in the wastes whun
originated at the former Welsbach and GGM
Facilities are members of the uranium and thorium
decay series. There are 14 unique radionuclides in
the uranium decay series and 11 unique radionuclides
in the thorium decay series which precede the
formation of stable lead (Pb-206 or Pb-208). Alpha,
beta, and gamma radiation are emitted from the
various members of the two decay series. The
primary nuclides of concern are Thorium-232,
EPA Region 2 - February 1999
PageS
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Radium-226. and radon gas (Radon-222 and Radon-
Each radionuciide has its own unique characteristic
"fingerprint." consisting of three parameters:
I . The radioactive half-life describes the amount
of time in which half of any given number of
atoms of a radionuciide will decay.
2. The mode of decay refers to the rype(s) of
panicles or electromagnetic rays emitted from
the radionuciide as it decays. These types
include alpha and beta panicles, and gamma
rays.
3. The amount of energy carried away from the
atom by the panicles or rays is radionuciide
specific. It is the transfer of this energy to
living tissue uhich may cause biological
effects.
\Vhen radionuclides decay, they emit energy in the
form of radiation. The decaying radionuciide is often
called the "parent", and the radionuciide produced is
called 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 10i:
(2.22 trillion) disintegrating atoms per minute. A
more convenient unit for expressing environmental
radioactivity- is the picoCurie (pCi). which is equal to
I x 10"': (one trillionth) Ci.
Radium-226 is a naturally occurring, radioactive,
me:ollic element formed from the decay of uranium.
In its decay. Radium-226 forms Radon-222 or 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, the concentration of
radon decay products in the indoor air can build up
over time. Exposure to the energy released by these
various decaying atoms can result in adverse health
effects. For radon decay products, a spec:a! unit
called Working Level (WL) has been dexeieped.
Working Level is defined as zny combination 01
short-lived radon decay products in 1 lnrr c:'a:r tr.2:
will result in the ultimate emission of 1.5x10-" Miga-
electron Volts of potential alpha energy This - a!us t:
approximately equal to the alpha energy released
from the decay of progeny in equilibrium with 100
pCi of Radon-222.
Thorium-232 is also a naturally occurring
radionuciide and is the initial radionuciide of the
thorium decay series. Its decay products include
radium-228 and Radon-220. Radcn-220 is* also
known as thoron. Thoron and its decay products
have extremely shon half-lives that usually prevent
them from concentrating to any appreciable extent in
indoor air. However, if a significant source of thoron
exists within, beneath, or adjacent to a structure (such
as the thorium and radium-228 found in
Wclsbach/GGM site wastes), thoron decay products
can reach concentrations which create health risks.
^REMEDIAL INVESTIGATION SUMMARY
In September 1997. EPA started an Rl to
characterize the nature and extent of contamination at
the Welsbach Facility. General Gas Mantle Facility.
and 20 of the radiologically contaminated properties
identified by NJDEP in the vicinity of Welsbach and
GGM. In order to develop a cleanup strategy for the
Site, the RJ field investigations were divided into
three property categories, as follows:
Former Welsbach Company Facility;
Former General Gas Mantle Company
Facility;
Vicinity Properties.
The RI/FS report presents the results of field
investigations conducted to date at both Welsbach
and GGM Facilities and the 20 Vicinity Properties.
In future phases of the remediation, called operabie
units, EPA will investigate potentially impacted
ground water, surface water, and sediments.
EPA Region 2 - February . -*
Page 6
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Property Investigations
EPA conducted both chemical and radiological
characterizations of the former Welsbach and GGM
Facilities to define the extent of contamination. EPA
also performed a radiological investigation on 20 of
the potentially contaminated Vicinity Properties
identified by NJDEP; Only 20 Vicinity Properties
were investigated during the RI so that EPA could
confirm the NJDEP data and expedite the
development of cleanup alternatives. EPA will
investigate the remaining potentially contaminated
properties identified by NJDEP. and other properties
suspected of being possibly contaminated during the
remedial design phase of this cleanup. EPA estimates
that about 600 properties will be studied in the design
phase to ^.'.ermine exactly which properties require
cleanup. This additional work may include sampling
for chemical analysis, where deemed appropriate
when considering past ownership and historic
information. Field activities conducted as part of the
RI included the following:
Radon measurements
Radon decay product Working Level
measurements
Gamma radiation surface and one-meter
height exposure rate surveys
Surface and subsurface soil sampling
Downhole gamma radiation logging
Total surface beta surveys and removable
surface alpha and beta sampling
Structural materials sampling (in some
buildings)
Results of Field InvesuCations
.Areas with elevated levels of radioactivity that
exceeded the radiological standards for human health
were identified during the remedial investigations.
The RI data support the following conclusions:
Former Welsbach Facility
Most of the radiological contamination is
located in the area of a former Welsbach
building that was demolished in the i9~0s
This area is currently used for storage
However, there are smaller areas of
contamination scattered throughout the
property. The soil in these areas is
contaminated with elevated concentrations of
the thorium and uranium decay series
radionuclides. Subsurface contamination on
the Welsbach facility averages about 11 feet in
depth. An estimated 27.200 cubic yards of
soil/buried debris have thorium and or radium
concentrations exceeding 5 pCi g. Radium
and thorium concentrations in soil ranged
from background (about 1 pCi g fcft each) to
as high as 455 pCi/g and 1.190pCi g.
respectively.
Surface gamma exposure rates associated
with the contaminated soils ranged from
background (less than 10 micro-Roentgen per
hour [uR1i]) to 780 uRTi. The highest
readings were associated with a large fill area
identified in the middle of the storage area.
Low levels of chemical contaminants were
identified at the former Welsbach Facility.
Contaminants of potential concern include
semi-volatile organic compounds and arsenic.
These contaminants may be indicative of
"Historic Fill". If this is conf.-med in the
remedial design, then there may be no need to
excavate this soil. Instead, it may be more
appropriate to cap these soils in place.
Former General Gas Mantle Facility
Elevated concentrations of thorium and
uranium decay series radionuclides were
identified in soils on the former GGM
property. Contamination was generally
limited to the top six to eight feet, although
contamination in some areas of South Fourth
Street and the GGM Courtyard ranged from
12 to 16 feet in depth. An estimated 900
cubic yards of soil had thorium and/or radium
concentrations which exceeded 5 pCi/g.
EPA Region 2 - February 1999
Page 7
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Radium and thorium concentrations in soil
ranged from background to as high as 172
pCi r and 149 pCi/g. respectively.
Surface gamma exposure rates associated
with Lie contaminated soils ranged from
background (less than 10 uR/h) to 380 uR/h.
Only localized areas of surface contamination
were identified outdoors.
Most of the outdoor contamination is located
in the area of South Fourth Street. However,
some smaller areas of contamination were
identified in the alleyway behind the property
that extended onto some backyards of
neighboring residential properties.
Elevated levels of surface contamination were
observed in many areas inside the former
GGM building. Levels as high as 2.33
microCi per meter square (uCi/nv ) area were
observed.
Indoor gamma exposure rates ranged from
background to 900 uR/h.
An estimated 1.460 cubic yards of
contaminated structural materials in the
building itself were identified, with thorium
concentrations as high as 750 pCi/g.
In the basement of the former GGM building.
radon decay product concentrations measured
1.7 WL, compared to an average background
level of 0.005 WL.
Certain semi-volatile organic compounds and
metals were identified. These were; however,
at such low levels that they are not chemicals
of concern. These contaminants may be
indicative of "Historic Fill". If this is
confirmed in the remedial design, then there
may be no need to excavate this soil. Instead,
it may be more appropriate to cap these soils
in place.
I 'icinity Properties
EPA investigate:: 20 properties in Ci~csn and
Gloucester City for radiological contamination as p-ir.
of the RJ. EPA compared these data to information
collected from earlier NJDE? investigations and
determined that the data were comparable. These
data support the following conclusions.
Some site properties have indoor radon gas
concentrations or soil radionuclide
concentrations which pose a long-tsrrr. risk to
human health.
«
Contaminated soil averaged about mo to
three fee: in depth on most residential
properties. On a fr« aropenies.
contamination extended to 10 feet in depth.
Based on the comparison of EPA and NJDEP
data, approximately 50 propenies were
identified as having contamination above the
cleanup levels. During the remedial design
phase. EPA will delineate the extent of
contamination on these propenies in order to
design a cleanup plan for each property.
£PA identified approximately 600 properties
that are either adjacent to the known
contaminated properties or have gamma
exposure rates above background levels. In
the RJ report, these properties are termed
"suspect propenies." During the remedial
design phase. EPA will investigate and sample
these propenies to see if there is any
radiological contamination present. If
contamination above the cleanup objectives is
found, EPA will delineate the extent of this
contamination and design a cleanup plan for
these properties.
SUMMARY OF SITE RISK
A baseline risk assessment was conducted for the
former Welsbach Facility, the former GGM Facility.
and the Vicinity Properties utilizing analytical data
EPA Region 2 - February 1999
PageS
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obtained during the RJ. The baseline risk assessment
estimates the human health risk which could result
from the contamination at a site if no remedial action
were taken.
Ecological risks, that is, the risk to aquatic and
terrestrial wildlife (plants and animals), were not
evaluated for this operable unit because the study
areas consisted primarily of residential and
commercial properties. An Ecological Risk
Assessment will be conducted in a future RI to
evaluate the potential for adverse effects to aquatic
and terrestrial wildlife (plants and animals) in
accordance with Ecological Risk Assessment
Guidance for Superfund, Process for Designing and
Conducting Ecological Risk Assessments (EPA 540-
R-97-006).
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
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 A tsessment - 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 effects (causing cancer) or
noncarcinogenic effects (causing health effects other
than cancer.) Radionuclides (e.g., radium, thorium,
radon, thoron, and radon/thoron decay products) are
known carcinogens. Nonradiological chemical
contaminants (e.g.. PAHs and arsenic) rm> exhibr.
both carcinogenic and noncarcinogenic health et":ej:i
EPA's acceptable cancer risk range is 10*4 to 10-0
which can be interpreted to mean that an individual
may have a one in 10.000 to one in 1.000.000
increased chance of developing cancer because ot"
site-related exposure to a carcinogen.
Human health risks were estimated for both
radionuclides and chemicals of concern at the former
Welsbach and GGM Facilities, and for radionuclides
of concern at the Vicinity Properties. Budding
materials and/or soil were the environmental media ot"
concern. Risks (that is, the probability of developing
a cancer because of exposure to radioactive
materials) were calculated based on "reasonable
maximum exposure" according to EPA guidance.
This means that risks are estimated as a result of
exposure to site-related carcinogens over a 30-year
lifetime under the specific exposure conditions at a
site and other exposure assumptions that result in an
overall exposure estimate that is conservative but
within a realistic range of exposure.
In assessing potential human health risks from
exposure to the radionuclides. several exposure
scenarios involving exposure to external gamma
radiation, ingestion of radioactive materials, and
inhalation of radioactive materials were evaluated.
Risks were estimated for several current and future
scenarios, and were compared to the risk from natural
background sources of radiation.
The maximum excess lifetime radiogenic (radiation
induced cell damage) cancer risks, that is, the risks
due solely to the presence of radioactive materials
above background levels, are 5.7 x 10'2 at the former
Welsbach Facility (to the current and future site
worker), 1.8 x 10"' at the former GGM Facility (to a
hypothetical future site worker), and 1.8 x 10': to a
resident of a vicinity property. These radiogenic risks
exceed EPA's acceptable risk range. The cancer risk
from chemical exposures to the same populations at
the former Welsbach and GGM Facilities was also
EPA Region 2 - February 1999
Page 9
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evaluated. The cancer risk did not exceed EPA's risk
ranee and: therefore, no additional remedial action is
necessary because of chemical contaminants.
To assess the potential for cumulative
noncarcinezsnic effects posed by multiple
contaminants. EPA has developed a hazard index
(HI). The HI is derived by adding the noncancer
risks for sue chemicals with the same target organ or
mechanism of toxicity. When the HI exceeds 1.0.
there may be concern for adverse health effects due to
exposure to multiple chemicals.
For the Welsbach/GGM site, non-cancer health
effects were evaluated only 21 the former Welsbach
and GGM Facilities. The total HI for construction
worker exposure to the chemicals of concern in soil
at the former Welsbach Facility' from ingestion.
dermal contact, and inhalation is equal to EPA's
acceptable level of 1.0. Ingestion of arsenic is the
predominant contributor to the risk estimate. The
total HI for construction worker exposure to the
chemicals of concern in soil at the GGM Facility from
ingestion. dermal contact, and inhalation is 3 x 10":.
this hazard index :s below EPA's acceptable level of
' -°. indicating that adverse, noncarcinogenic health
c.iects from such exposure are unlikely.
The following are the dominant radiological exposure
pathway risks for the various exposure scenarios
e\2:uated for the Welsbach/GGM site. At residential
properties and the former Welsbach Facility, the
major.ry of risk is from exposure to external gamma
radiation, or direct radiation. Occupants of the
former GGM Facility' (current and future trespassers
and future site workers) are at risk primarily from
inhalation of thoron decay products. Future
construction worker risk is primarily due to direct
radiation, although inhalation of participates
containing radioactive material also contributes a
significant portion of the risk.
This Rl focused primarily on residential and
commercial properties, and sensitive species of plants
anc animals are not likely to inhabit these portions of
the Site. However, sensitive specie* may be present
in Study Areas 3 and 5 around Newton Crsrek AJK
ecological risk characterization for '.hese x-e^s wtil i»e
conducted :n a future operable unit.
Actual or threatened releases of hazardous s-bs:^.-;?>
from the Site, if not addressed by the preferred
alternatives, or one of the other active measures
considered, may present a current cr potential thrsat
to public health, welfare, or the environment
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to
protect human health and the environment. These
objectives are based on available information and
standards such as applicable or relevant and
appropriate requirements (ARARs) and risk based-
based levels established in the risk assessment. EPA's
remedy! action objectives for the Welsbach. General
Gas Mar.:ie Contamination site are to ;ake measures
that will prevent or mitigate further release of
radioactive contaminated materials :o the surroundinc
environment and to eliminate or minimize the nsk tc
human health and the environment. The sources of
radiation include both contaminated soil and
structural materials. Direct radiation, inhalation.
ingestion of plants and soil are potential pathways.
EPA proposes the following remedial action
objectives for the Site:
Eliminate or minimize the potential for
humans to ingest, come into dermal contact
with, or inhale paniculates of radioactive
constituents or to be exposed to external
gamma radiation in order to achieve the level
of protection required by the NCP (10~* to
10~6 risk range).
Prevent long-term exposure to thorium- and
radium-contaminated material (e.g.. soil) with
concentrations greater than 5 pCi/g.
EPA Region : - FeDrutry 1999
Page 10
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Prevent exposure 10 indoor concentrations of
radon gas and radon decay products greater
than » pCLl and 0.02 WL1. respectively.
« Prevent direct contact with building surfaces
exhibiting total surface thorium contamination
exceeding 0.026 uCi/nv above background.
' Prevent migration of thorium-contaminated
material that could result in the exposures
described above.
Comply with chemical-, location-, and action-
specific ARARs.
EPA. in the Office of Solid Waste and Emergency
Response ; OSWER) Directives No. 9200.4-18. and
No. 9200.4-15. developed health guidelines for
limiting exposure to ionizing radiation from radium
and other sources. 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
Lou AS Reasonably Achievable (ALARA:) taking
into consideration technical, economic and social
factors.
EPA recommends that indoor radon concentrations in
homes should not txceed 4 pCi per 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 enacted standards for limiting exposure to radon
decay products and gamma radiation. While this
regulation is not directly applicable to this site
because the Welsbach and GGM Facilities are not
1 Exposure to 4 pCi/'l of air for radon corresponds to an
approximate annual average exposure of 0.02 WL for
radon decay products.
References for ALARA principles - "Radiation
Protection Guidance to Federal Agencies for
Occupational Exposure ". 196". Federal Register 52.
Vo. /" 2822: and "Federal Guidance Report So. 11".
September 1988. EPA-S20\i-88-020.
inactive uranium processing sites. EPA considers :r.s
cleanup standards in 40 CFR 192 to be relevant .ir.d'
appropriate for the Site. The relevant portions c: -"
CFR 191 include limiting exposure to radon dica>
products to levels less than 0.02 U"L and radium
concentrations (implemented as the sum of Rs-22?
and Ra-228) to 5 pCi/gram. EPA. in Directive So
9200.4-25. states that whenever the 5 pCi g radium
soil cleanup standard is determined to be rsicvar.t and
appropriate at a CERCLA site which contains both
radium and thorium in the waste, the 5 pCi c cleanup
standard also applies to thorium ^implemented ^ the
sum of Th-230 and Th-232).
«
In achieving the remedial action objectives tor the
Site. EPA would rely on the ALARA principles used
at other radiological contaminated sites in New
Jersey. Applying ALARA principles means taking
additional measures during implementation of the
remedial acuon, beyond those required to meet a
specified cleanup goal, to assure protectiveness. An
ALARA approach is being used 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 ..-.ay make it necessary to
remove material at levels below 5 pCi g to achieve
adequate public health protection.
EPA's experience at the other radiological
contaminated sites in New Jersey has shown that the
remedial action objectives noted above can be
achieved by incorporating ALARA principles.
Therefore, by using similar remedial action objective;
the Welsbach/GGM Site would pose no unacceptable
risk for residential uses after cleanup, and would
result in a cleanup that is protective under CERCLA.
To meet the remedial action objectives outlined
above. EPA plans to excavate radiologically
contaminated soils and waste materials, and dispose
of them off-site. Excavation of soils will eliminate tl
threat of physical migration of contaminants, as well
as potential exposure through various pathways
(ingestion. inhalation, dermal contact, external
gamma radiation, etc.). Contaminated soils will be
EPA Region : - February 1999
Pace 11
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shipped off-site to a licensed commercial facility for
permanent long-term management.
The planned response action for buildings, specifically
at GGM. is decontamination, demolition, and off-site
disposal of contaminated materials to reduce
exposures within acceptable levels for future use of
the property.
Any potential ecological risks and adverse impacts
from existing radiological contamination on the
properties addressed under this action will be
minimized because the contaminated soils will be
removed and backfilled with clean soil. There are
also limited habitats for ecological receptors at the
properties addressed under this action. Furthermore,
by removing the radiologically contaminated waste,
the surface water and sheet flow pathways will be
eliminated as routes of exposure.
Wetlands are not present at both the former Welsbach
anJ GGM facilities. However, wetlands are present
in Areas 3 and 5, along the South Branch of Newton
Creek. During the remedial design. EPA will
delineate wetland areas whi.h are actually or
potentially impacted by contamination or remedial
activities.
SCOPE AND ROLE OF ACTION
The goal of the proposed remedial action is to
minimize or eliminate the potential health hazard
posed by all radiologically contaminated soils and
structural materials at the Site. Because of the large
geographical area associated with this project, not all
potentially contaminated areas were evaluated during
the Rl. EPA will investigate additional areas as pan
of the remedial design to delineate the full extent of
contami" tion. The Armstrong Building, ground
water, Su. .ace water, and sediments, will be
addressed in future Operable Units.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each remedv be protects ^ .-:
human health and the environrrsn:. oe cos: e:Tec:;\t.
comply with other starutor laws, and utilize
permanent solutions and alternative treatment
technologies and resource recovery alternatives to :he
maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a
principal element for the reduction of toxicit>.
mobility, or volume of hazardous substances.
CERCLA also requires that if a remedial action :s
selected that results in hazardous substances.
pollutants, or contaminants remaining at a sue above
levels that allow for unlimited use znd unrestricted
exposure. EPA must review the action no less than
every five years after the start of the action.
This Proposed Plan evaluates the Remedial
Alternatives for addressing the contamination
associated with the Site. Cleanup alternatives were
evaluated for the Vicinity Properties, the former
Welsbach Facility and the General Gas Mantle
Facility. The alternatives include: No Action,
Engineering Controls, and Excavation and Off-Site
Disposal.
Vicinity Properties
The Vicinity Properties include residential,
commercial, and public properties where radiological
contamination was identified in soils situated
outdoors and/or beneath buildings, and properties
with indoor air contamination.
Vicinity Properties Alternative 1 (V'-l)
No Action
Estimated Capital Cost: SO
Estimated Annual Operation and Maintenance
(O&M) Cost: $0
Estimated Present Worth: SO
Estimated Implementation Period none
EPA - rgion 2 . February 1999
Page 12
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A "No Acucr." alternative is evaluated for every
Superfund sr.e :o establish a baseline for comparison
with remedial alternatives. Under this alternative, no
remedy; action would be performed at 'jjt Site.
Previous interim remedial actions implemented by
NJDEP would not be maintained. Current
institutional controls including fencing would not be
maintained. Because hazardous substances would
remain at the Vicinity Properties above acceptable
levels, five-year reviews would be required.
Vicinity Properties Alternative 2 (V-2) -
Engineering Controls
Estimated Capital Cost: $900.000
Estimated Annual O&M Cost: S99.000
Estimated Present Worth: $1.810.000
Estimated Implementation Period 3-5 years
Under this alternative, outdoor gamma shielding
would be placed at each property which has
contaminated soil. The gamma shield would consist
of a geotextiie liner, fill material. 6-inches topsoil. and
vegetation (seeding or sod). The thickness of the fill
material will vary from 6 inches to 42 inches, based
on the shielding requirements of each property. A
total of approximately 75.000 square feet of coverage
would be installed.
In addition, indoor gamma shielding would be placed
inside buildings exhibiting unacceptable exposure
levels. The shielding would consist of concrete or
steel as needed. The concrete would range from 4
inches to 7 inches thick, and about 1.5 inches of steel
sheeting would be placed on wall surfaces.
Approximately 2.000 square feet of concrete and 60
square feet of steel coverage would be installed.
Finally, if any property buildings exhibit elevated
radon/thoron levels, a sub-slab ventilation radon
mitigation system would be installed.
Institutional controls, such as deed restrictions, would
be required to ensure the protect! veness of the
remedy. Because hazardous substances would remain
at the Vicinity Properties above acceptable levels.
five-year reviews would be required. The estimated
time to design and construct the rsrr.
to five years.
Vicinity Properties Alternative 3 (V-3) -
Eicavatiot and Off-Site Disposal
Estimated Capital Cost: S }.-OS.ro'
Estimated Annual O&M Cost: SC<
Estimated Present Worth: S'.3.408.560
Estimated Implementation Period 3-5 years
Under this alternative, soil on the Vicinity Properties
contaminated above 5 pCi/g greater than background
would be excavated and disposed of a: a licensed
off-site facility. Radiologically contaminated b-:ldim
demolition debris would also be excavated and
disposed of off-site. EPA will replace these areas
with clean fill. The total volume of soils requiring
disposal at the Vicinity Properties is estimated to be
11.000 cubic yards. The total volume of bur.ed
demolition debris at the Vicinity Properties is
estimated to be 2.250 cubic yards.
Where contamination is suspected underneath
buildings, this alternative includes removing concrete
flooring and underpinning the buildings. After the
removal of contaminated soil, a new concrete floor
would be constructed. Approximately 2! properties
would require concrete floor removal and
replacement. Underpinning is estimated to be
required n one property.
The estimated time to design and construct the
remedy is from three to five years. Provisions would
need to be made for the temporary relocation of
residents and businesses during construction of this
alternative. During excavation, short-term provisions
to prevent dust generation and protect workers would
be required.
Welsbacb Facility
The former Welsbach Facility is presently owned anc
operated by Holt, as a cargo storage and oversea
shipping operation. Radiological contamination on
the property is present in the outdoor portion of the
EPA Region : - February 1999
Page 13
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storage area. Most of the contamination is located in
a single contiguous area, with smaller elevated areas
scattered across the property. The .Armstrong
Building is not included in the remediation
alternatives. Holt is preparing ar. RJ/PS that will
address the remedial alternatives for that building.
Welsbach Alternative 1 (W-l) - No Action
I
Estimated Capital Cost: SO
Estimated Annual O&M Cost: SO
Estimated Present Worth: SO
Estimated Implementation Pehod none
Under this alternative, no remedial action would be
performed at the Site. Current institutional controls
including fencing would not be maintained. Because
hazardous substances would remain on the property
above acceptable levels, five-year reviews would be
required.
Welsbach Alternative 2 (W-2) - Engineering
Controls
Estimated Capital Cost: S5.690.000
Estimated Annual O&M Cost: $44,000
Estimated Present Worth: S6.180.000
Estimated Implementation Period 3-5 years
Under this alternative outdoor gamma shielding
would be placed in the areas of the former Welsbach
property that have soil contamination. The gamma
shield would consist of steel covered by asphalt The
steel would range in thickness from I to 5 inches,
with a 4-inch asphalt cover. Approximately 53,000
square feet of area would be covered by the steel
shielding.
Institutional controls, such as deed restrictions, would
be required to ensure the protectiveness of the
remedy. Because hazardous substances would remain
on the property above acceptable levels, five-year
reviews would be required. The estimated time to
design and construct the remedy is from three to five
years.
Webbacb Alternative 3fW-3) . Excavation and
Off-Site Disposal
Estimated Capital Cost: S! S.503.fc";
Estimated .Annual O&M Cost: $-.'
Estimated Present Worth: S18.50." .5eO
Estimated Implementation Period 3-5 >si-s
Under this alternative, a: .-oil contamination at the
Welsbach sits above 5 pCi, g greater than background
would be excavated and disposed of at a licensed
off-site facility Contaminated building demolition
debris which is currently buried on-site because oi
former demolition activities would also be*e.\ca% ated
and disposed of at an appropriate off-site facility.
EPA will replace these areas with clean fill. The
volume of so::s above the cleanup standard is
estimated to be 19.400 cubic yards. The volume of
buried demolition debris requiring disposal is
estimated to be 4,400 cubic yards. During
excavation, short-term provisions to prevent dust
generation and protect workers would be required.
Subsurface contamination on the Welsbach Facility
averages about 11 feet in depth. In the area of the
deepest contamination, underground runnels dating
from around the rum of the century are present.
These tunnels extend down to about 10 to 12 feet in
depth. These tunnels can act as conduits to carry
radon gas to nearby residential properties. As a
result, the remedy includes excavation of the
contamination to these depths to prevent any future
radon migration problems and to protect furure
workers from elevated gamma radiation levels. The
estimated time to design and construct the remedy is
from three to five years.
General Gas Mantle Facility
The GGM building is presently inactive and in a
dilapidated state. The building has been boarded shut
and fenced in by NJDEP Radiological contamination
on the property exists both inside and outside the
buil Jing. Inside the building, contamination is present
in raiding materials and in ambient air. Outside the
GCM Facility, soil contamination is primarily located
EPA Region 2 - February 1999
Page 14
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to the immediate southwest of the GGM building
extending into South Fourth Street. Two smaller
areas of contaminated soils are situated to the
northeast of the building and in the alleyway adjacent
to the eastern side of the building.
General Gas Mantle Alternative 1 (G-l) - No
Action
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Implementation Period
$0
$0
$0
none
Under this alternative, no remedial action would be
performed at the Site. Previous interim remedial
actions would not be maintained. Current
institutional controls including fencing would not be
maintained. Because hazardous substances would
remain on the property above acceptable levels.
five-year reviews would be required.
General Gas Mantle Alternative 2 (G-2) -
Engineering Controls
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Implementation Period
$122.000
$23.000
$381.000
2-3 years
Under this alternative, outdoor gamma shielding
would be placed at the former General Gas Mantle
property. The gamma shield would consist of either a
soil shield or a concrete shield. The soil shield would
include a geotextile liner, fill material, six-inches
topsoil. and vegetation (seeding or sod). The
thickness of the fill material will range from six to 24
inches. The thickness of the concrete will range from
six to eight inches. Approximately 5,000 square feet
of coverage would be required. Areas of
contamination extending into South Fourth Street
would be covered with an additional 4 inches of
asphalt.
Also under this alternative, significant institutional
controls, including permanently boarding shut the
building and restricting access to the building tbre\e:
would be required. Because hazardous substances
would remain on the property above acceptable
levels, five-year reviews would be required. The
estimated time to design and construct the remed> :s
from two to three years.
General Gas Mantle Alternative 3 - Excavation
and Off-Site Disposal of Soil and
Building/Demolition Debris
G-3A: Demolition and Disposal
Estimated Capital Cost: 'S2.309.56C
Estimated Annual O&M Cost: S(
Estimated Present Worth: S2.309.56(
Estimated Implementation Period 1 -2 year:
Under this alternative for the GGM property, soil
contaminated above 5 pCi/g greater than background
would be excavated and disposed of at a licensed
off-site facility. Contaminated building demolition
debris which is currently buried on-site because of
former demolition activities would also be excavated
and disposed of off-site. EPA will replace these area
with clean fill. The volume of soil and buried
demolition debris at GGM is estimated to be 650
cubic yards and 60 cubic yards, respectively.
Under this alternative, the former General Gas Mantl
building would be demolished, and the demolition
debris would be disposed of with the contaminated
soil. The volume of building materials to be
demolished is estimated to be 1,400 cubic yards.
During excavation and demolition, short-term
provisions to prevent dust generation and protect
workers would be required. The estimated time to
design and construct the remedy is from one to two
years.
G-3B: Decontamination, Demolition and Disposa
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Implementation Period
$1,736.56'
$<
$1,736.56-
1 -2 year
EPA Region 2 - February 1999
Page 15
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This alternative essentially would be the same as 3A
above, except that the demolition of the building
would proceed in steps. First the wooa structural
materials and roofing would be removed. This debris
would be disposed of with the contaminated soil and
is estimated to be approximately 450 cubic yards.
The remainder of the building (approximately 950
cubic yards of primarih masonry and concrete) would
then be decontaminated using pressure washing
before demolition. The building would then be
demolished and the debris would be crushed and sent
off-site for disposal. The estimated time to design
and construct the remedy is from one to two years.
.EVALUATION OF REMEDIAL ALTERNATIVES
Each of the above alternatives was evaluated against
specific criteria on the basis of the statutory
requirements of CERCLA Section 121. Nine criteria
are used in evaluating the alternatives. The first two
criteria are threshold criteria which must be met by
each alternative. The next five criteria z.. the
primary balancing criteria upon which the analysis is
based. The final two criteria are referred to as
modifying criteria and are applied, following the
public comment period, to evaluate state and
community acceptance.
A comparative analysis of these alternatives, based
upon these criteria, is presented below.
Overall Protection to Human Health and the
Environment
The No Action Alternatives (W-I, V-l, G-l) would
not be protective of human health and the
environment because the Site would remain in its
current contaminated condition. Therefore, the No
Action Alternatives have been eliminated from
consideration and will not be discussed further.
Under the Engineering Controls Alternatives (W-2,
V-2, G-2), potential ex- sure routes of gamma
radiation would be sh: ^ by concrete and/or steel
sheeting. The shieldir.. juld have to be maintained,
and institutional controls, such as deed restrictions.
GLOSSARY OF EVALUATION CRITERIA
Threshold Criteria
Overall Protfction of Human Heahh and tfif Em ironrr;r.: 7h:»
criterion addresses whether or not a remed> provioes aaecuait
protection and describes how HSKJ air eliminated, reaucra or
controlled through treatment, engineering controls or
insrirutionaJ controls.
Compliance with Applicable or Relevant and Arrrccriatt
Requirements (ARARsl: This criterion addresses u hetner or r.c:
a remedy will meet all of the applicable or relevant and
appropriate requirements of other environmental statutes or
provide grounds for invoking a waiver.
«
Primary Balancing Criteria
Lone-Tertn Effectiveness and Permanence: This criterion refers
to the ability of the remedy to maintain reliable protection of
human health and me environment over time once cleanup goals
have been met
Reduction of Toxicitv. Mobility and Volmr. -->ueh
Treatment: This criterion addresses the antic:raied performance
of the treatment technologies that a remedy m;-. emplov.
Short-Term Effectiveness: This criterion im. .- the period of
time needed to achieve protection and any ac* -. r impacts on
human health and the environment that ma\ :. r j$ed during the
construction and implementation period unn. : sanup goals are
achieved.
Implernentabilirv: This criterion examines the technical and
administrative feasibility of a remed>. includ_-. availability of
raateriiis and services needed to implement a particular option.
Cost: This criterion includes capital, operation and maintenance
costs, and net present worth.
Modifying Criteria
State Acceptance: This criterion indicates whether, based on its
review of me Rl/FS reports and the Proposed Plac, the State
concurs with, opposes, or has no comment on the preferred
alternative.
Community Acceptance: This criterion will be addressed in the
Record of Decision following a review of the public comments
received on the JU/FS reports and the Proposed Plan.
EPA Region 2 - February
Page 16
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would be required to ensure that these alternatives
are protective.
For the Excavation and Off-Site Disposal Alternatives
(W-3. V-3, G-3), all radiological contamination above
cleanup standards would be removed and disposed of
off-site in a licensed disposal facility. Institutional
controls would not be necessary. All unacceptable
risks to human health and the environment would be
eliminated by the excavation and off-site disposal of
the radiologically contaminated waste.
Compliance with Applicable or Relevant, and
Appropriate Requirements
Actions taken at any Superfund site must meet all
ARARs of federal and state law, or provide grounds
for invoking a waiver of these requirements. There
are three types of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific
ARARs are technology or activity-specific
requirements or limitations related to various
activities. Chemical-specific ARARs are usually
numerical values which establish the amount or
concentration of a chemical that may be found in, or
discharged to, the ambient environment. Location-
specific requirements are restrictions placed on the
concentrations of hazardous substances or the
conduct of activities solely because they occur in a
special location.
For the Welsbach/GGM site, no requirements are
applicable for the cleanup of the radiological
contamination. However, as discussed earlier,
portions of the federal regulations governing the
cleanup of uranium mill tailings from inactive uranium
processing sites, at 40 CFR 192, have been
determined to be relevant and appropriate. These
provide the radon decay products standard of 0.02
WL and soil cleanup criteria of 5 pCi/g. In addition,
waste materials produced at the former Welsbach
Facility would be considered "by-product" material as
defined by Section 1 l(e)(2) of the U.S. Atomic
Energy Act (AEA).3 Since Welsbach processed
monazite ores to extract thorium. EPA has
determined Section I l(e)(2) of the AEA to be
relevant and appropriate. Because the waste
materials from the Welsbach Facility and its
operations are an AEA Section 1 l(e)(2) waste
material, they must be disposed of at a licensed
facility in accordance with AEA requirements.
The Excavation and Off-Site Disposal Alternatives
(W-3, V-3, G-3) would comply with all ARARs All
contamination above the 40 CFR 192 cleanup
standards would be excavated and sent off-site for
disposal. The Engineering Controls Alternatives (W-
2, V-2, G-2) would comply with all ARARs that limi
exposure to gamma radiation and radon. However.
the Engineering Controls Alternatives would not
comply with 40 CFR 192, because the contaminated
material would remain at the Site.
Long-Term Effectiveness and Permanence
The Excavation and Off-Site Disposal Alternatives
(W-3, V-3, G-3) are all effective and permanent.
They are considered a final remedial action. The
contaminated material would be removed from the
Site and stored in a controlled, licensed facility.
The long-term effectiveness of the Engineering
Controls Alternatives W-2 and V-2 would be
uncertain. Contaminated material would remain in
place, and the engineering controls would require
deed restrictions and long-term monitoring. In
addition, the engineering controls would have to be
maintained forever because the half-life of thorium is
14 billion years.
Alternative G-2 (Engineering Controls for General
Gas Mantle) would not be effective in the long-term
3*By-product" material means (1) any radioactive material
(except special nuclear material) yielded in or made radioactivi
by exposure to the radiation incident to the process of
producing or utilizing special nuclear material, and (2) the
tailings or wastes produced by the extraction or concentration
of uranium or thorium from any ore processed primarily for its
source material content.
EPA Region 2 - February 1999
Page 17
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because of the dilapidated nature of the building, even
if the building were completely sealed.
Reduction of Toxicitv. Mobility, or Volume Through
Treatment
No treatment technology is known today that can
substantially reduce the toxiciry, mobility, or volume
of radioactive materials found at the Site, and meet
the 40 CFR 192 cleanup standards. The total amount
of radioactivity- cannot be altered or destroyed, as is
often possible with chemical contaminants.
Therefore, none of the remedial alternatives fully
satisfy this evaluation criteria.
However, the Excavation and Off-Site Disposal
Alternatives (W-3, V-3. G-3) would lead to some
reduction in the mobility of the material because
radioactive contaminated materials would be
contained in a secure landfill cell. Alternative G-3
with Option B (the General Gas Mantle
Decontamination and Demolition Alternative) would
reduce the volume of contaminated building debris to
be disposed of off-site by pressure washing the
radioactive contamination off the floors and walls
before demolition. The contaminants would be
concentrated in the filtrate after pressure washing.
Only this filtrate would have to be disposed of in a
licensed facility.
Short-Term Effectiveness
Both the Engineering Control Alternatives (W-2. V-
2. O-2) and the Excavation and Off-Site Disposal
Alternatives (W-3. V-3, G-3) provide effective short-
term protection, and become effective as they are
implemented at individual properties. The estimated
time to design and construct the remedial alternatives
for the former Welsbach Facility (Alternatives W-2
and W-3) and the Vicinity Properties (Alternatives
V-2 and V-3) is from three to five years. For the
former GGM Facility, the estimated time to design
and construct the Engineering Control Alternative
G-2 is from two to three years, and for the Off-Site
Disposal Alternative G-3 from one to two years.
The Engineering Control Alternatives involve less
intrusive activities, and pose less of a threat to
workers and the surrounding community thar. the
Excavation and Off-Site Disposal Alternates
However, both the Engineering Control Alternative*
and the Excavation and Off-Site Disposal Aitensam ;>
involve intrusive activities, including, in some cases.
temporary relocation of residents.
The Excavation and Off-Site Disposal Alternatives
have a greater potential aaverse impact in the short
term because of the excavation of radiological 1> -
contaminated soil. For future workers, this could
lead to increased short-term exposure to radon.
gamma radiation, and soil radionuclides Dust
suppression techniques and. or other measures would
be required to minimize the impacts of this
alternative. However, under Alternative V-2
(Engineering Controls for the Vicinity Properties).
there would be some increased short-term risk to
workers during the installation of the radon mitigation
systems. This is due to the need to excavate under
the foundation of homes that require radon
mitigation.
Implememabilitv
The Excavation and Disposal Alternatives (W-3. V-3.
G-3) art readily implementable. Similar activities
have been utilized at other radiologically-
contaminated sites around the country. There is an
available off-site disposal facility, which is accessible
by both truck and rail. However, the continued
availability of this off-site disposal facility is required
for implementation of these alternatives.
Implementation of the Engineering Controls
Alternatives V-2 and G-2 may pose some difficulties.
Under Alternative V-2 (for the Vicinity Properties).
there may be some difficulty in getting the consent of
ail of the property owners to restrict future work on
their properties. EPA would have to reach
agreements with individual property owners to file
Dec:.-rations of Em :-3nmental Restrictions (i.e., deed
resr . ;.ons) on their properties. For Alternative G-2
(for ueneral Gas Mantle), it would be difficult to
EPA Region 2 - February I"9
Page 18
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keep the building permanently sealed from
trespassers.
Cost
Alternative V-2 includes construction costs of
$900,000 to implement engineering control measures
at the Vicinity Properties. Annual O&M costs are
estimated to be $99,000. The present worth cost of
Alternative V-2 is $1,810,000, with O&M costs
assumed for 3' \ ears. Alternative W-2 includes
construction coais of $5,690,000 to implement
engineering control measures at the former Welsbach
Facility. Annual O&M costs are estimated to be
$44.000. The present worth cost of Alternative \\ -_
is $6.180,000. with O&M costs assumed for 30 years.
Alternative G-2 includes construction costs of
$ 122.000 to implement engineering controls at the
General Gas Mantle Facility. Annual O&M costs are
estimated to be $23.000. The present worth cost of
Alternative G-2 is $381.000, with O&M costs
assumed for 30 years. The radionuclides in question
have half-lives far greater than 30 years, so any of the
Engineering Controls remedies must be maintained
effectively forever.
Alternative V-3 includes construction costs of
$ 13.408.560 to excavate the radiologically-
contaminated soil at the Vicinity Properties and
dispose of the waste at an off-site disposal facility.
Alternative W-3 includes construction costs of
$18.503,560 to excavate the radiologically-
contaminated soil at the former Welsbach Facility and
dispose of the waste at an off-site disposal facility.
Alternative G-3 - Option A involves construction
costs of $2.309,560, and includes demolishing the
General Gas Mantle building and disposal of all the
building debris at an off-site disposal facility
Alternative G-3 Option B involves construction
costs of $ 1,736,560, and includes decontaminating
the General Gas Mantle building before its
demolition. There are no O&M costs associated with
the Excavation and Off-Site Disposal Alternatives
(W-3, V-3, G-3 Options A and B).
State Acceptance
The State of New Jersey is currently evaluating the
Proposed Plan.
Community Acceptance
Community acceptance of the preferred alternatives
will be evaluated after the public comment period
ends and will be described in the Record of Decision
for the Site.
PREFERRED ALTERNATIVE _
Based on the information available to evaluate the
remedial alternatives against the nine criteria. EPA
recommends the Excavation and Off-Site Disposal
Alternatives (V-3, W-3. and G-3 with Option B) as
the preferred alternatives for the cleanup of the
contaminated soil and building materials at the Site.
Rationale for the Preferred Alternatives
For each of the three property types, EPA's preferred
alternative is the excavation and off-site disposal
alternative. Alternatives V-3. W-3, and G-3 with
Option B are the most protective alternatives.
The radioactive half-life of thorium-232. the primary
contaminant of concern, is 14 billion years. Remedie:
that would isolate wastes containing thorium and the
uranium series radionuclides permanently from the
public and the environment are preferable.
Alternatives V-3, W-3, and G-3 result in a permanent
solution to the radioactive contamination. The
longevity of these chemicals of concern (thousands tc
billions of years) favors excavation which
permanently removes the contaminants from their
current uncontrolled locations. Commercial disposal
at a licensed facility with an appropriate closure plan
will ensure that these radiological wastes are
permanently isolated from human and ecological
receptors. The Excavation and Off-Site Disposal
Alternatives are considered implementable and will
EPA Region 2 - February 1999
Page 19
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result in a remedy that is highly effective in the long-
term. These remedies are also consistent with the
remedial approach taken at all other radiologically-
contaminated sites in New Jersey.
Alternatives V-3, W-3, and G-3 provide greater long-
term effectiveness because all soils with radioactivity
greater than 5 pCi/g are disposed of in a licensed
radiological waste disposal facility. The technology
and equipment to perform the remedial action are
readily available. Implementation of Alternatives V-
3, W-3, and G-3 would allow for unrestricted future
use of all affected properties. The Engineering
Controls Alternatives (V-2, W-2, and G-2) would
require deed restrictions and long-term monitoring
essentially forever because of the extremely long half-
lives of the radiological contaminants. Thus, EPA
believes excavation and off-site disposal of the
radiological contamination represents the most viable
cleanup alternative.
The preferred alternatives will provide the best
balance of tradeoffs among alternatives with respect
to the evaluating criteria. EPA believes that the
preferred alternatives will be protective of human
health and the environment, will be cost effective, and
will utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent practicable.
NEXT STEPS .; .
After EPA has presented the preferred alternative at
the public meeting and has received any comments
and questions during the public comment period,
EPA will summarize the comments and provide its
responses in a document called the "Responsiveness
Summary." The Responsiveness Summary will be
appended to the Record of Decision, which will
describe the final alternative selected by EPA and
provide EPA's rationale for that selection.
EPA Region 2 - February 1999 Page 20
-------
MAILING UST
ADDITIONS
If you know of someone who is not receiving
information and would like to be placed on the
mailing list for the Welsbach/General Gas Mantle Contamination
Site, call Ms. Natalie Loney at (212) 637-3639. e-mail her at
loney.natalie@epamail.epa.gov. or fill out and mail this
form to:
Ms. Natalie Loney
Community Relations Coordinator
U.S. Environmental Protection Agency
290 Broadway. 26th Floor
New York, NY 10007-1866
Name
Address
Telephone
Affiliation_
EPA Region 2 February 1999 Page 21
-------
Suserfund Fact Sheet
Welsbach/General Gas Mantle Contamination Site
Gloucester City/Camden, New Jersey
February 1999
INTRODUCTION
This 'summary highlights tne U.S. Environmental
Protection Agency s (EPA s) Proposed Plan for tne
cleanup of contaminated soils and ouilding materials at
the Welsoacn/ General Gas Mantle (Welsbacn/GGM)
Supertund site in Camden County. New Jersey.
' Investigations at the Welsbach/GGM site have shown
that some commercial, residential, and public
properties located in the Camae- and Gloucester City
area contain soil contaminated to varying degrees with
thorium, radium, and uranium.
These contaminants are radioactive and associated
with -vaste matenals generated in the manufactunng
activities that took place at the former Welsbach and
General Gas Mantle facilities. Both facilities used
radioactive elements, specifically thorium, in the
production of gas mantles, were used for lighting
purposes in the late 19th and early 20th centuries.
Radium, uranium anc thorium are associated with
mantle proouction process.
Radioactive elements such as thorium, radium or
uranium are unstable and as a result release energy.
Thonum releases energy in the form of alpha pa/tides.
beta particles or gamma radiation. This radioactive
decay also forms radon gas.
Radon gas is odorless, colorless and tasteless and can
be harmful if people are exposed to it over many years.
Gamma radiation also may pose health problems to
people who come in contact with the wastes over long
periods of time.
WELSBACM/ GENERAL GAS MANTLE SITE
The Welsbach/GGM site is comprised of properties
within the following six study areas:
Study Area One: a rnixed industrial, commercial, and
residential zoned section of Camden which includes
the former GGM facility and residential and commercial
properties which surround the facility.
Study Area Two: an industrial zoned property in
Gloucester City along the Delaware River, formerly
occupied by the Welsbach Corporation and a
residential area to the immediate east
Study Area Four: residential properties ;:-. tne r air.iew
section of Camden.
Study Area Five: residential properties -acart :and
properties. anC two municipal parKs near Ter-^ie Avenue
and the South Brancn of Newton C.-ee* m Gloucester
City.
Study Area Six: vacant lots in a residential coned area
of Gloucester City.
Study Area
procerties in
Boulevard Lana Preserve
Three: residential and recreational
Gloucester City, including the Johnson
Mark Your Calendar
Public Meetings:
Gloucester City
Pine Grove Fire Station *2
on
Tuesday, February 23,1999 at 7:00 p.m.
Camden
Camden County Municipal Utilities Authority
Auditorium
on
Wednesday, February 24,1999 at 7:00 p.m.
Availability Sessions informal question and
answer sessions:
Gloucester City
Pine Grove Fire Station #2 on
Tuesday, February 23,1999
1:00-4:00 r in-:
Camden
Camden County Municipal Utilities Authority
Auditorium on
Wednesday February, 24,1999
1:00 -
!HF
The pufaUceamroent pertorfoo the proposed plan
mn» FefcnMCtt "L MM^tfvu to March 3,139ft
-------
REMEDIAL INVESTIGATION AND FEASIBILITY
STUDY
in '9S7 E3A oegan a remedial investigation and
feasibility stuay (Rl/FS) to aetemvne the source and
extent of raaioiogical contammanon m the Camoen and
Gloucester City area and to evaluate cleanup
alternatives "he areas investigated during tne Rl/FS
mciudec tne former Wetsbacn facility, tne former GGM
facility, and 20 of the radiologically contaminated
properties identified during earlier investigations
conducted by tne New Jersey Department of
Environmental Protection (NJDEP). The findings of
the remeeal investigation were then used to prepare a
feasibility stuay. whicn evaluates cleanup alternatives.
THE PROPOSED PLAN
In addition to the fll/FS. EPA has prepared a Proposed
Plan for the Weisbach/GGM site which identifies EPA's
preferred cleanup alternatives for the radiologically
contaminated properties. The alternatives which were
evaluated include: No Action; Installation of
Engineering Controls: and Excavation and Off-Site
Disposal of Contaminated Materials.
EPA's preferred alternative is Excavation and Off-site
Disposal of Contaminated Materials. This alternative
calls for the removal and off-site disposal of
radioactively-contaminated soil. The excavated areas
will be backfilled with dean soil. Where necessary.
contaminated building material will be removed and
replaced with dean material. Removal of contaminated
of soils and building matenals will eliminate potential
gamma rac'iation and radon exposure through vanous
pathways (ingestion. inhalation, dermal contact, etc.).
The planned response action for the former GGM
building, is decontamination, demolition, and off-site
dispose' of contaminated materials. All contaminated
material will be taken to an approved off-site disposal
facility.
The estimated volumes cf contaminated material from
the site properties are:
Vicinity Properties:
soil -11.000 cubic yards:
demolition debris - 2.250 cubic yards:
Former Weisbach Facility:
soil -19.400 cubic yards;
demolition debris - 4.400 cubic yards:
Former GGM Facility
soil - 550 cubic yards:
demolition debns - 60 cubic yards;
building materials - 450 cubic yards.
The cost of the proposed remedial action :s estimated
to be $13,408.560. $18.503.560. and $1,379,560 for
the Vicinity Properties, former Weisbach facility, and
former GGM facility, respectively.
While some of :ne activities prcoosec !sr -:te c:eanup
may be disruptive to individual ~!omeow-e;s or me
community. EPA will worn witr aftecrec esice'-ts ar-c :ne
community to ensure a safe ano SUICK cieanuc 3' :n»
site.
EPA relies on public input to ensure that :^e rcrce^s c'
the community are consioered in seiec::nc an ehec:!ve
remedy for eacr. Superfund sue. TO triis enc E3- -as
made the RI/rS report. Proposed Plan, anc suocc.Tmg
documentation available to the public for a public
comment penod from February 1. 1999. to March 3.
1999. EPA considers all public comments before
se acting a final cleanup plan. For more information
p ease contact Natalie Loney. Community Delations
Coordinator at (212) 637-3639 or RICK Soomson. Project
Manager at (212) 637-4371.
The RI/FS report which presents the results of field
investigations conducted to date at these properties has
been completed. Copies of the Rl/FS report. Proposed
Plan, and supporting documentation are available at
EPA's offices at:
290 Broadway. 18r ROOT
New York. NY
10007-1866
(212)637-4308
and at the following repositories:
City of Camden Main Library
418 Federal Street
Camden. NJ 08103
(609) 757-7650
Hynes Center
1855 South 4" Street
Camden. NJ 80104
(609) 966-9617
Glcucaster City Public Library
Monmoutn and Hudson Streets
Gloucester City. NJ 08030
(609)456-4181
SUMMARY
The Proposed Plan presents EPA's preferred remedy for
the cleanup of contaminated properties which are part of
the Weisbach/GGM site. EPA proposes to excavate
contaminated soil and waste materials: decontaminate
(as appropriate), demolish, and remove contaminated
debris and building material: dispose of the
contaminated soils and waste materials in a licensed off-
site disposal facility; and restore the affected properties
with dean fill. The proposed remedy would provide z
permanent cleanup response and would be protective o:
human health and the environment.
-------
Appendix B
Public Notices
-------
.Term, If
Proof of Publication of Notice ii Ite niadelplu ta|ur*
Undw Act N«. 1*0, F J- S77, J-*y 9, 197*
Commonwealth of Pennsylvania
County of Philadelphia
}
55.:
L.....Cipr^an araa and to ovaiuato cMonup
Itarnattvaa, Thai flm puouc moating to dlacuaa tno nna-
.' a) engineering and Institutional Control* '?*"
'*) Excavation and Ofl'SlteOlepoMi
EPA'a propoaad cleanup remedy la Alternative «3. mo
excavation end Off-ana Olapciai Alternative. Under tma
alternative! tne radiological contaminated malarial
would oe removed and traneportad on ma site tor dla-
pnaal. All of ma wove aiterativoa are outlined and dle-
oueeod in ma Prop aaia Plan. .-..; . 4. -- ': '".*.'.' ,*,--'
>8*A reHeWcin puoMo'lnpul to eneure linet ma~eoneorne of
._tne community are cenaidered in ««l«cimn an effective
rremedy tor eeon Supertund ana. To true end. CPA naa
meflar ma RI/FS reoon. >»Tcoo«ao Plan, and »uciporting
fdecumenietion avauaote to me pueuc tor a puPlic com-
<««M «.nnn trout ft* nil i. t«aja _»e ajeiex ». lee*.
on O** OVtocvMaWft <
. _ .
Tno Onaj mrnlnn documont wW Mcuido a aummary of
pueiie eommantB and BPA raapenin, Copni of mo
RI/FS moon. PiuiiuaaJ Plan, and Mipporting doeumon-
wtionaroavaiiaDiaatePA-BamcaatMO roadway, lain
floor. Now Yom. NT lOOOT-IMe. (212) B3T-«3Oa. and at
"
Written ccwnm«nu en tn« OfOpu««d Ptan .tfseuld b«
RIcnarBJ. Aobinaon-orcali
U.S. Environmoma*
protection Aoancy .' -.
MQBrowaway. IfHti Floor .
Natalia uonoy ^ :
U.S. Environmontai ..,..
Protoetlon Agancy '
20O Broadway. Mm Floor
-------
'legal Holiest " '10 ! Un'ilMotlcet > 10
u* ( ..~« I
' PUBLIC MBBTINO ' » IroniperUd oil Ih* tilt l»f«
Propoted Plan U be Oil-* dlipeial. AllelrheoMveal- 1-
,/tuiitd lor Weliboch/acn-k lornallvei or* outlined and
«ji eiolGatMonlle < > dlecuteod In lit* Pr*p***d|
Centtiinlnoilon tuverhtftdfc Plan. EPA i*lln »n public (
611* - ....... I Input le enlur* thai In* co«v
.G*>md*n'Glouc*il*r.CliYil. cern» ollh*e*inmunltvar*,|
c*ntld*r*d In Ml*cllna on(
*ll*cllv* rem»dr IM *och
Super lund tilt. T* Ihlt *nd..|
Th« united State* Cnvlrm-:
menial Pfolicllan Ag«ncv
IEPAI will held lw» Inter-
i 'muiiuciaiv
I djjcuit ni«
' iXtnlir iain
'
EPArm»mod«m*HI/F»r»-
perl. Prepeied Plan, and
-i
d]
tiicmMiinmlti lueperllm decumenlallan
luidinat el a rt- avaliaM* le Hi* public l»r a |
0i*l*d r*m*dlol public commtnl »*rled«
**l'Pa"*nandlMil6lllrV< IramPEIRUANY 1. 1t»tl* ,
dr IRI/FS). and an- -MARCH J. Iff*. C*mm*nl* '
r*m*<; mud b« r*c*lv*4 an «r b«.1
ler Ih* Cloonvp el reilV lore MARCH 1 Ittf. Tit* II-1
dMillol and ether properliei' no) declilon document will I
'which comprlt* Ih* Weli-1 IncludeaeummorrelPublleJ
' fcoch/Otneral Ooi Manll* comment* and HP* ro-l
Cenlamlnallon Iup*r|un4* M*nM*.C*pl*i*flh*NI/Fl!
»>l«. Th* HI/PI yrai MIK i» orl, Propaied Plan, and|
dueled U determine (h* lupporlln* decurnerttollen I
iource *nd e«lenl el rddlo-.' are available al BPA'» ( J
Mloncontainlitollenlnlhear-. lie* al 1*0 Br*odwar..tllh ;
a and lo evaluate cleanup.. Floori New Verk, NV»
blleinallvei. The tlitl pub-. ttODIUM. (Ill) *1I-41II,?
lie mtelln* le dlecute ttlt and at Ih* tollawln* Inter-1|
Indlnm will IM held *£*.* mollen r*Mill*rl**: .'. :
'I 1 '
t'--~",~'-"f (£'«' "i;;T+iijSY»Sff4ihii:7i"i?7.r»r.f
'^il Hie (aiiMlen County OMll'/ Camdwi. MJ *«1*4>7..TV |,V-
(uoied el Ie4l P*rry Av*J 'written c*mm*nd« *n Ih*'
itu« iii camden. New Jereey^f Pr*p*t*4 Plan- *h*u|d b« t
>he Ri/PS*valual*drhrM'i*ntt*: . . . »,.-....?
allernallvei lor oxtdreiilnf { Rlchetd J. NoblnMn ',' it
.
. Enalneerlnaand
^Ollek i^iiw* iv* wmwBinv i mtnvtw «. fivwnvvn ', i
,i dlqiualcallv ccnlamlnol'.'.U.i.CnvlrwunonMPrthKoi
-«d eell and tlrucfural mat*-; ll*n A«y. ..,. nd
tale. Theyar*:^. ->-r }«* Broadway. Ittti Fl ,j---
I.Noocllon "**' «J<"f'» N*wV*rk. NY IMtMtM .;
OR CALL: NATALIH LO- _
NBY ,9
Environmental Protec-
tion Agy. , ,
1*0 Broadway. Mm PI. V
New York. NY lOMMIe* .
llll)41Me)«
(I71.M)
ihllllutlonol Conlreli ' J «' NBY
:>. Cicavollon and -1 .' ,'' ' U.S.I
'OH SlleOltpoiol ' ' lion*
t^HA'e vrepoted cleanup'
remedy li AlKrnatlve *1,
.*t>e Cxavutlonai>dOII-)IIO
DltMiiiul Aim native. Under
"Mill oiler native. Hie ladle-
logically cerilainliMileil ma-
' Urlal weuldb* removed and'
44
CftStT*
.Voun
STATE OF NEW JERSEY
CAMDEN COUNTY
ss
S. Butler
of lull age. being duly sworn, according to law, says that he/aha Is
bookkeeper of (he
COURIER-POST
and thai a Notice, of which the annexed Is a true copy, was
published dally in the COURIER-POST, newspaper printed
and published dally In the county ol Camdan. Slate of New
Jersey.
once on the 2nd dayol F.Rtt..9.9.
281239 001021 #31827 1
MALCOLM PIRHIE I NC
INTERNATIONAL E:
ATTN: BOB KERTX
MAHUAH NJ 071
1 S \ ^&*~-^
MM/MO
-------
' NEWS
All
Girls...
< ....... TC m
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roor from Mootpomrrv tc
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cur or. DCAUI ot t :rmi>r
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DIUC: anc :o utc DOC.:
.nor: :-\e .".. : Rjcn.<
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As a teen, sne net navut never ios: a games ir prune nrne i & (X:
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HAMBLFTON-STEWART REALTORS
It S lmiu»ir>. fiioucumr City
496-1144
Saxnng TM trm» tmc* IBM
Y«i I HC U«M «f
CLOl CESTtR CTH 3 bcorooim. beautiful mxe-ia COOOIDOO aomr nnnoorko
ta*th » fioerruu u»«er »'ilidmj doors, pmtry of natunJ «oo4 cabioru. L-coumcr »
v tuuiu. u imk. oevm «"w in linos room tain A hall :" floor lauadn. mum
broroom dual clown 1)9.900
CLOl CESTER Cm 3 bedrooms. I , bath. brumfuJ hartvoorf Boon & chnnn
vim. 3 ccuiaf tans moOem kncbra »»ave. paoo.
feaced viri iiorate bare, move-m coodnoa. Onry S74.90C
CLOl CESTER CITY .' utdiuuua. grcn oppornmrrv' Huft dencbrd borne only m
neeo of coimeoc TLC. 2 pouibte tnUiumiB OB 3 floor New beater, remodeled bub
plunouf ibr a 1" floor oattL p»c >r»cr lac. 3yn IHUB roof A lyr iiictaen rooi entrance
tow. pouioie 203k Only 157.900
DCPTFOKD NEW LJSTINC I buliuuui new «ondo»>. araer carpeu. u unk. or*
mife. nrrrjcmate condmoo. oe*er central air con^rcuer. oor piece fiberftail cub
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floor uain 4 hall «ny. I piece fifacijlai* aibHtafct. «»uido»» wai at aacnea. pn»ac>
fenced rear vard. tioeife ibcdi. floored anx ceiaBBcule ioycr. 20>14 coorreirpat 10.
r\cellefii condition, wboie house un. 17O.400
CLOl CESTER CITY : becrooiiB. modem knchce oak cabuco and newer aagt.
nrui cnndinoa 7 ceilnf ram. newer beam and CKW heacer. tenant pan all ann-
ie» iiviuuing >ewcr Addmoaal appltaacei Deiooafatc. 157! pti umiath. call for more
details'
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.ajweuij: *orlc o: inr CL'.
luiif Tf j-. A-Tienca
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coaches mu> al«a^) r«
memoei au- me court*
cuit aueaot Aiuwerec
airnoti ans otn^it a
Kaooi or
j: '_ir . -i i-.r
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p: tflr ^urTffme . -'ur.
DC!C .»: rr: ot: .- .Hi..-
at ao inoi%iauai
athlete ot team. Ai»a» oe
civii and try to aetotutc
in tbe ichaol or tcbooi
board fint
"Get a conwnRiec or a
pennon lotettter aad be
relpectfut yet firm
FnnUy. meres oo oeed
tor anger became your
side a boldzgf tear aces
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Dent. pvu| paretm the
run around bu ben the
normal roumx He»t»er.
wbeo scnool adouni-
tuauuui inevitably rod
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and (he Office of Civil
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happen and profms is
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itnou: jursnor.
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has arrived «
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pater Cloucerarr area.
irmair spon; c^enc.
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celebrate j Uxa. remai'
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week or Jan Z'.H. In me
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Pat Cummuujs bucket
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Soer Dane s Liar."
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Co
ST.MAItrSSCHOO
UCISnATION
Si Mary Sebool
r
-------
Appendix C
Transcripts of Public Meetings
-------
1
2
3
4
7
e
9
U.S. Environmental Protection Agency's (EPA's)
Proposed Plan for Cleanup of Superfund Sites
5
Public Hearing
6
February 23, 1998
10 ----- .............
11 Public Meeting of the U.S. Environmental
12 protection Agency (EPA) held at the Pine Grove Fire
iJ station #2, Gloucester City, New Jersey, before
!» Linda A. Burns, Shorthand Reporter and Notary Public
10 of the State of New Jersey, on the above date,
ib commencing at 7:00 p.m.
18
19
20
21
22
23
24
DBGNAN & BATEMAN, INC.
(609) 547-2565
-------
1 EPA MEMBERS IN ATTENDANCE:
2 Richard J. Robinson, Project Manager
Pat Evangelista, Team Leader
3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch
4 MALCOLM PIRNIE REPRESENTATIVES IN ATTENDANCE:
5 Robert Kerbel, Associate
Alan Fellman
6
ATSDR REPRESENTATIVES IN ATTENDANCE:
7
Arthur Block, Sr. Regional Representative
8
ALSO PRESENT:
9
Bob Saunders, Emergency Management Coordinator
10
I- N D E X
II Witness Pa.ge.
John Becks(ph) 50
12 Sue Marks(ph) 56,79
Mike Grabowski 74,85
13 Unidentified Speaker 76
Unidentified Speaker 88
14 Theresa Graham 91
Ed Gorman 92
15
EXHIB ITS
16
(There were no exhibits marked at this time.)
17
18
19
20
21
22
23
24
DEGNAN & BATBMAN, INC.
(609) 547-2565
-------
EPA Public Meeting - 2/23/99
1 MS. CERVANTES-GROSS: I just wanted
2 to start by thanking all of you for coming
3 here tonight to talk with us about the
4 Welsbach/General Gas Mantle Superfund site
5 and post cleanup. We will be talking with
6 you about all of the cleanup here and will
7 be giving you different information about
8 the study that was done and the
9 alternatives that we have looked at as far
10 as what we are proposing.
11 Just to introduce people who are here
12 tonight from EPA and who are involved in
13 the cleanup, we have Rick Robinson who is
14 the project manager for EPA for this site.
15 Pat Evangelista is the team leader for us
16 at EPA and oversees all of the Superfund
17 sites in our region, New Jersey, and all
18 the sites that deal with radioactive
19 contamination.
20 Alan Pellman is with Malcolm Pirnie,
21 a contractor that works with BPA to
22 actually do the investigation and cleanup,
23 as well as Bob Kerbel who is also with
24 Malcolm Pirnie.
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l And obviously, everyone here knows
2 Bob Saunders who has been doing so much
3 work with us and will be here long after
4 we're gone. And Artie Block is also here
5 from ATSDR, the Agency for Toxic Substances
6 and Disease Registry, part of the Federal
7 Department of Health and Human Services.
8 And ATSDR works with us on a consultation
9 basis and works with us closely to look at
10 these Superfund investigations that we do
11 and gives us information on potential
12 health impacts.
13 As well, I also wanted to introduce
14 Linda Burns who is the stenographer who
15 will be taking down all of the comments
16 that you make tonight. And that's why we
17 are here tonight, to hear from you, your
18 thoughts, your comments, your concerns.
19 And to take any questions you have about
20 what we will be discussing tonight and what
21 our proposed cleanup will be for the
22 contamination for the site.
23 And just to point out, my name is
14 Mary Helen Cervantes, I'm with EPA as
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1 well. And I work in the area of Superfund
2 Community Relations. The Superfund program
3 stresses, as we do throughout all of the
4 programs, community involvement and
5 community participation. We feel we can do
6 a much better job by having you involved
7 and telling us what you hear, see and know
8 about the community, your community, in
9 which you live. You know what's happening
10 here a lot better than we do most of the
11 time. So again, that's why we are here
12 tonight, to hear your comments and
13 concerns.
14 In order for us to do that and to
15 make sure that we get everything down, if
16 you could, after we go through our
17 presentations, if you could hold your
18 questions until the end. He will try to
19 move through it as quickly as possible to
20 make time for questions.
21 When you have questions or want to
22 make a statement, state your name clearly
23 so that Linda can get that down and speak
24 up so we can get it all down. So at the
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1 end of the comment period, which ends on
2 March 3, which is next Wednesday, we'll
3 take comments on what we're proposing up
4 until next Wednesday. Afterwards we will
5 do a responsiveness summary, which we'll go
6 through all the comments and all of your
7 concerns and we'11 write a summary
8 responsive to that. But what you say
9 tonight and whatever comments you have,
10 that will actually go into the official
11 record. So you don't have to write it down
12 afterwards. We'll take it down right here
13 as you say it.
14 I also just wanted to point out that
15 Natalie Loney, whom you may have met, works
16 with EPA and is the assigned Community
17 Involvement Coordinator for the site. So
18 I'm just sitting in for her today. She
19 just had a baby on Valentine's Day, but you
20 will see here throughout all of the other
21 meetings throughout the year. She is the
22 one who is assigned just to work with you
23 and to handle your questions and concerns
24 and to make sure you're involved as much as
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l possible and we want you to be involved in
2 the process here.
3 Just a couple of things very
4 quickly. We have various project
5 initiatives that will help you understand
6 -- you'll see there's a lot of technical
7 information, but there are programs that
8 are available to help you understand the
9 technical information. And if anyone is
10 interested in those programs, I will talk
11 to you about those afterwards. They are
12 numerous. But just talk to me afterwards
13 if you'd like.
14 I'll now turn it over to Pat and Pat
15 is going to go through the Superfund
16 program in general.
17 MR. EVANGELISTA: Good evening,
18 ladies and gentlemen. Thanks for coming
19 out tonight and participating in our
20 meeting.
21 Just to reiterate a little bit of
22 what Mary Helen said, we highly encourage
23 all of you to come forward and identify any
24 comments, concerns or questions that you'd
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i like to have answered, if not tonight, you
2 know, anytime in the near future. We'll
3 hand out business cards if you'd like and
4 feel free to call us at any time.
5 What I'm going to do now for you is
6 give you a little briefing on what
7 Superfund is about so that you maybe
8 understand better why we're here and what
9 kind of process we've been following and
10 are going to follow until we're done with
11 this particular site.
12 Back in 1980, Congress gave SPA the
13 authority under a law that's known to us as
14 the Comprehensive Environmental Response
15 and Liability Act. And then five or six
16 years later they amended that law to give
17 us what we currently have today. Our
18 process always beings with somehow an
19 identification to the agency that there's a
20 problem in a certain area. And that's what
21 you see up on the screen as the discovery
22 or CERCLIS. The CERCLIS is simply a
23 program or process we use to track site
24 progress.
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l Then we move into what's known as the
2 preliminary assessment or site inspection.
3 we go out and we try to ascertain, on a
4 preliminary basis, what kind of a problem
5 we're dealing with so that we can funnel
6 all of that information into a hazard
7 ranking system. Based on the hazard
8 ranking system we are able to rate that
9 problem or that site, if you will, and .if
10 the score, based on the ranking, exceeds or
11 is higher than 28.5, which was somehow
12 selected very arbitrarily, the site ends up
13 on what's known as the National Priorities
14 List. This is a prioritization list that
15 the agency uses to deal with the sites that
16 are on it.
17 From the National Priorities List we
18 are then able to authorize federal money to
19 proceed into what is known as the Remedial
20 Investigation/Feasibility Study. The
21 Remedial Investigation/Feasibility Study is
22 a very detailed study of the problem or the
23 site or the properties, if you will.
24 Perhaps you've seen us out there taking
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1 soil samples. You may have seen our
2 contractors. You may be -ware of our field
3 office.
4 So we've been gathering data on this
5 site for the past year or so. That data is
6 then analyzed to formulate alternatives
7 that we can further evaluate to identify
8 the preferred cleanup option to address the
9 contamination that's out there. Those
10 cleanup options are identified in the
11 Feasibility Study and the Feasibility Study
12 is used to generate the proposed plan.
13 The proposed plan -- I guess we went
14 public with it back on February l -- "went
15 public with it," meaning we identified it
16 in public notice, in the newspapers, for
17 your knowledge. It's available for your
18 review. We have copies of it here tonight
19 if you'd like a copy. And in that proposed
20 plan we proposed to you what we'd like to
21 do to clean up this site.. And Rick will
22 get into a lot of that detail.
23 After the public comment period ends
24 we'll proceed into a Record of Decision,
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1 after having considering all of your
2 comments and concerns. That Record of
3 Decision will formally identify the
4 cleanup. The cleanup will then be designed
5 under what's known as a remedial design.
6 That design will identify all of the
7 specifications that the contractor will
8 need to follow in order to clean up your
9 properties. That, in effect, is the
10 cleanup.
11 Once the agency has determined that
12 the cleanup has occurred pursuant to all of
13 the specifications, we give it a clean bill
14 of health, if you will, and we remove it
15 from the National Priorities List or delist
16 it from the NPL.
17 That essentially describes our
18 process. If you have any questions I'd be
19 happy to answer them for you later. At
20 this point I'll pass it onto Rick Robinson,
21 the Project Manager for the site.
22 MR. ROBINSON: Thanks again, Pat.
23 Just for background, the site is
24 located both in Camden and Gloucester
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1 City. It comprises two former Gas Mantle
2 manufacturing facilitie some residential
3 properties, commercial properties,
4 municipal park lands and vacant land.
5 As part of the Stare's investigation
6 early on, in the early 1990s they divided
7 the site into a number of study areas. And
8 as we were going on with our investigation,
9 we followed along with their study areas.
10 The first one, Study Area 1, is the
11 General Gas Mantle Facility in Camden and
12 the surrounding properties.
13 Study Area 2 is the former Welsbach
14 Facility here in Gloucester City and the
15 surrounding properties.
16 Study Area 3 is the residential area
17 in Gloucester City, including the Johnson
18 Boulevard Land Preserve.
19 Study Area 4 is the residential area
20 in the Fair-view section of Camden.
21 Study Area 5, the residential
22 properties and also some municipal parks in
23 Gloucester City.
24 And Study Area 6, some --scant
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1 properties in the residential area in
2 Gloucester City.
3 Study Area 1, again, the General Gas
4 Mantle facility in Camden. And there is a
5 photograph of the area with the General Gas
6 Mantle building highlighted (indicating).
7 There's a photograph of the General Gas
8 Mantle building on the corner of Jefferson
9 Street.
10 Study Area 2 is the former Welsbach
ll facility. It's now owned by Holt with the
12 Gloucester terminal. The Armstrong
13 building is the last remaining building
14 from Welsbach's operation. And the area in
15 pink right in here (indicating) is the
16 location of the former Welsbach building
17 that was demolished around 1975, 1976. And
18 that is the main contamination area on that
19 property. There's a photograph of the
20 Armstrong building as it is today. There's
21 the Walt Whitman Bridge in the background.
22 Study Area 3 is Gloucester City.
23 Gloucester City Swim Club is highlighted
24 and the Johnson Boulevard Land Preserve.
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1 Study Area 4, again, is the Fairview
2 section of Camden. And we only found a few
3 properties in this part of the site that
4 were identified as having elevated levels
5 of gamma radiation.
6 Study Area 5 is in Gloucester City
7 and includes the former Welsbach dump area
8 on Temple Avenue and contamination in the
9 park areas along Johnson Boulevard there.
10 And Study Area 6 is a newly
11 identified area and we call it the Popcorn
12 Factory. You can ask Bob Saunders as to
13 how that name came about. And there' s a
14 photograph of the Popcorn Factory and
15 vacant lot. And the area in red is the
16 small area of contamination that we found
17 with radiological components.
18 Going to the site history now. In
19 about 1885 a Dr. von Welsbach invented a
20 process using thorium to manufacture gas
21 mantles. For those of you who don't know
22 what a gas mantle is, you know in a camping
23 lantern, you can see over on the left
24 (indicating), and in a street light right
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l here (indicating), that is the gas mantle.
2 And what they did is take a sock-like
3 material and they dipped it in the thorium
4 solution. And when it dried, it was lit.
5 And it produced a very brilliant white
6 light.
7 And in about 1890 Welsbach started
8 manufacturing the gas mantles here in
9 Gloucester city. And at the turn of the
10 century they were the world's largest
11 manufacturer of gas mantles. And by the
12 1940s they finally went out of business
13 when the electric light put the gas light
14 industry out of business.
15 In Camden, General Gas Mantle
16 manufactured gas mantles from about 1912 to
17 1941. They were a much smaller company
18 than Welsbach. They were a small
19 competitor. There is very little
20 information that we know about the Gas
21 Mantle's activities other than it used and
22 resold radium and thorium in the production
23 of gas mantles.
24 What we've termed vicinity properties
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1 are all the other properties that we found
2 at the site, excluding the General Gas
3 Mantle facility and the Welsbach facility.
4 And they were contaminated as a result of
5 either disposal of the ore tailings from
6 the Welsbach operation or building debris
7 when buildings were demolished. Like when
8 they built the Walt Whitman Bridge, some of
9 the buildings were knocked down. Or from
10 former workers bringing contamination home
11 with them.
12 Previously the site was identified in
13 1980 during an archive search of the U.S.
14 Radium Site in Orange, New Jersey. And in
15 May 1981 EPA sponsored an aerial fly-over
16 where a helicopter flew over the area with
17 gamma detectors and was searching for gamma
18 radiation. And as a result of that the
19 State then conducted preliminary screening
20 surveys in the mid 1980s and in the early
21 1990s they investigated over a thousand
22 properties in both Caraden and Gloucester
23 City.
24 And as a result of that they
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l identified about 20 properties that needed
2 -- that they felt needed some more
3 immediate measures taken. And as a result
4 they installed some radon/thoron
5 ventilation systems in a number of homes.
6 They installed concrete or steel sheeting
7 on properties, in people's basements. And
8 they also purchased one property and
9 relocated the residents.
10 In 1992 the State also removed
11 radioactive material in the General Gas
12 Mantle building and relocated the current
13 occupant at the time, Ste-Lar Textiles, and
14 they sealed up the building to restrict
15 access.
16 The State's investigation -- they
17 base their surveys on just surface exposure
18 rates, indoor radon sampling and they
19 performed very limited surface soil
20 samples. However, they did not really look
21 in the subsurface at all. They made no
22 estimates on the amount or extent of
23 contamination and were just looking to
24 address the more immediate potential health
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l time. BPA's involvement at the site became
2 official when it was placed on the National
3 Priorities List in June of 1996. And then
4 that's when I was given the site and
5 started the investigation process.
6 Currently the General Gas Mantle
7 building is inactive and boarded shut.
8 Welsbach is currently owned by Holt and is
9 an active facility. And with the vicinity
10 properties, the immediate health concerns
11 were addressed either by the State's
12 remedial actions or by the EPA removal
13 action. Like what we did in the park in
14 December around the Ponytail(ph) Field.
15 And here's a photograph of the excavation
16 where we removed the top three feet of
17 surface contamination. We're hoping to
18 ship that material. It's being temporarily
19 staged around the Popcorn Factory and we're
20 going to ship that off in about three
21 weeks. Today we had somebody out there
22 sampling that material in preparation for
23 shipment.
24 Right now I'd like -o turn this
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l Right now I'd like to turn this
2 portion of the talk over to Alan Fellman.
3 And Dr. Fellman will talk to you a little
4 bit about the radiation issues. Thank
5 you.
6 MR. FELLMAN: My background is in
7 health physics and radiation sciences. So
8 I'm going to spend just a few minutes to
9 give you a few points about some of the
10 terminology and some of the components
11 regarding radioactivity that hopefully will
12 help you follow along with the materials
13 that you have been given to read and some
14 of the things that you're hearing tonight.
15 And then later on I'11 come back and have a
16 few words about the risk assessment that we
17 did, which is a component of the Superfund
18 remedial investigation.
19 You've already heard some terms
20 related to radioactivity. And I just want
21 to hit on some of the key ones. When we
22 measure radioactivity, when we want to
23 identify a quantity of radioactive
24 material, we need different units than what
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1 we're more traditionally used to because
2 we're not talking about a mass. We can't
3 describe the weight of the material. What
4 we're concerned about is the rate that
5 these atoms are decaying, undergoing
6 radioactive decay.
7 The term we use, the unit, is called
8 pico Curies. When we're talking about how
9 much is in dirt or how much is in water, we
10 express it as a concentration, pico Curies
11 per gram or pico Curies per liter of
12 water. Now this term is indicative of how
13 much. It does not really address what kind
14 of dose one received or what the risk is
15 from that material. The point being that,
16 ten pico Curies per gram of one type of
17 radioactivity might give someone a
18 different dose and have a different risk
19 associated with it than ten pico Curies per
20 gram of a different radioactivity.
21 When we talk about dose of radiation,
22 and that's really related to the risk, we
23 use a unit called millirem. And that's a
24 measure of the potential for biological
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1 effect as a result of that radiation.
2 Basically what we're measuring is energy
3 that is coming from the radioactivity that
4 is emitted from that radioactive material
5 and is absorbed in the biological tissues.
6 And that energy that's transferred from the
7 radioactivity to the tissues is the subject
8 of what could then ultimately lead to a
9 biological effect or a health effect.
10 Obviously, the greater the dose the
11 greater the risk. There are several
12 different types of radioactivity and you've
13 heard some of previous speakers say the
14 words thorium, radon, radium. All of these
15 are different elements that have
16 radioactivity associated with them. They
17 emit different types of radioactivity.
18 Alpha particles and beta particles
19 and gamma rays are the three more common
20 types of radioactivity and they're really
21 the ones that we're concerned about here.
22 They have different properties. Alpha
23 particles are relatively heavy. They
24 travel slowly and they are not penetrating,
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1 which means that they will not travel very
2 far. if they're emitted from surface soil
3 they will be stopped within one to two
4 inches of air. They cannot get through a
5 sheet of paper.
6 Beta particles on the other hand have
7 an intermediate amount of penetrating
8 ability. They're smaller than alpha
9 particles but they do have some mass
10 associated with them. So while they can
11 get through a sheet of paper, they will be
12 stopped by something like a piece of wood.
13 Gamma rays on the other hand are very
14 similar to X-rays. They have no mass
15 simply. It's simply packets of energy.
16 It's sometimes referred to as penetrating
17 radiation because it can travel fairly
18 significant distances through air, paper,
19 wood. And it takes a more dense media to
20 absorb that energy and stop the gamma rays
21 such as concrete or lead.
22 The problem here, by and large what
23 we're dealing with are what's known as ore
24 residues. The by-product of the thorium
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l extraction processes that were implemented
2 by the Welsbach company who left them with
3 large piles of dirt which contained these
4 ore residues with elevated concentration of
5 radioactivity.
6 In this schematic here, the area
7 that's shaded in blue tends to show
8 potential areas with these elevated levels
9 of thorium. And if that were the case,
10 what you can get, radon gas which is
11 mobile, which can emanate from this dirt
12 into the indoor atmosphere. Fortunately
13 we've seen very little of that at the
14 Welsbach General Gas Mantle sites. Much
15 more frequently would be the case where
l there would be some of this material in an
17 outdoor area where the influx of the gas
18 into an indoor environment isn't likely to
19 happen. But there the potential exposure
20 would be from the gamma radiation that's
21 emitted to an occupant who would be
22 occupying, that would get a dose of that
23 gamma radiation.
24 At this point I'm going to let
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1 Bob Kerbel speak for a few minutes. He's
2 been our Project Manager from Malcolm
3 Pirnie throughout the investigation and
4 he'll take you through some of the key
5 points in that investigation.
6 MR. KERBEL: I just want to give you
7 a little insight of the type of
8 investigation we did in the community so
9 you can kind of see everything in the
10 nutshell and see the type of work we've
11 been doing.
12 There are three areas we looked
13 into. Two of the industrial facilities,
14 the former Welsbach facility and the
15 General Gas Mantle facility. And then
16 there was the vicinity problem, basically
17 everything else. I assume most people here
18 are homeowners and your home would come
19 under that vicinity property category.
20 If there's anything good about this
21 type of work from our standpoint as
22 investigators it's that it's easy for us to
23 detect this type of contamination. It
24 gives off gamma radiation. So we basically
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1 walk over the property with meters similar
2 to this. And we might have come to your
3 property and walked over the property in
4 search for elevated levels of radiation. I
5 have a little meter here. And we'd take
6 those readings and walk over your entire
7 property.
8 Then if we find something we take
9 soil samples and test for radiological and
10 chemical contaminants. We only test for
11 chemical contaminants at industrial
12 properties because there's always a chance
13 that there could be some chemical
14 contamination just given the industrial
15 nature of those areas.
16 Once we find an area, we have to come
17 up with a volume, how much is there. So we
IB put a boring into the ground and these can
19 be either shallow or deep. The only reason
20 there's not a deep check mark under
21 vicinity properties is because we really
22 didn't have deep contamination on
23 residential properties. That was really at
24 the industrial sites that we needed to go a
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l little deeper. And as Alan alluded to, if
2 there's soil contamination in the area,
3 that gives off radon gas that could get
4 into the household, so we test for that as
5 well.
6 On the industrial properties we also
7 do something called alpha/beta measurements
8 where we would actually sample structural
9 materials. Because sometimes we might run
10 into a question, whether it's the soil
11 under the building or the building material
12 itself that might be contaminated. So we
13 might test that.
14 This isn't too easy to see, but I
15 want you to use your imagination a little
16 bit. Let me try to get your eyes to focus
17 here. This is the former Welsbach facility
18 that was located along the Delaware River.
19 The Delaware River is up there on top, you
20 can see a smoke stack. And King Street
21 would be at the lower end of the picture.
22 But if you could imagine, this is the early
23 part of the century. There's no DEP;
24 there's no environmental protection
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l agency. The hazards associated with
2 radiation really aren't known yet. Things
3 like nuclear power are decades in the
4 future yet to come. And as Rick said they
5 made gas mantles here. Things like X-rays
6 that the doctor does now were still being
7 discovered at that time.
8 But at this facility, they brought
9 ore in. So basically on this facility
10 there was a pile of dirt that they would
11 extract the thorium from to use in these
12 gas mantles. So at the time it was really
13 a prosperous business until the electric
14 light bulb came into play and put them out
15 of business. But at that time the hazards
16 weren't really known.
17 In future years, in the last couple
18 of decades, we're more aware of the hazards
19 associated with radiation. So now someone
20 said, you know what, we should go back to
21 all these facilities that did this in the
22 early part of the century. Because the
23 sand that contained thorium, that could
24 . potentially be radioactive. So we should
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l go back to these facilities to see if,
2 indeed, there is radioactive material on
3 these sites.
4 So years later they come back to the
5 site but now there's no building here. The
6 circle is basically where the facility
7 would have been. So what we do is just
8 what I told you earlier, we walk over the
9 entire site and it takes a number of weeks
10 to do it because it's so large, and we look
11 for elevated levels of radiation. Because
12 at the beginning the thought is, if the
13 building is gone, it's conceivable that
14 they had these huge basements and they
15 knocked the building down and filled the
16 basement and then paved over it.
17 So we go over the entire site, we
18 look for the elevated levels and then we
19 bring them back to our office and we have
20 special programs that help us see what the
21 radiation levels are. Now this is a bird's
22 eye view looking down at this site now.
23 And wherever you see a colored area, those
24 are elevated radiation levels. That's a
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l clear signal for us that there is
2 contamination on the site. And then we go
3 back and take soil samples to see that it
4 is thorium. And we do borings to see how
5 deep it is. Ballpark approximately ten
6 feet deep in locations.
7 Alan is going to come back and talk
8 more about risk, but I just.want to give a
9 little perspective to it. When we do this
10 work it's not like we dress up in suits or
11 anything. We just wear our regular work
12 cloths and work in these areas and get our
13 measurements and so on. For the people
14 that work for Malcolm Pirnie, I'm
15 responsible for their health and safety.
16 And for me, the real risk is that they
17 don't get killed by a truck going through
18 the yards rather than the radiation wells.
19 Another thing to keep in mind, this
20 is not like an oil spill that's spreading
21 out there. It's been there for 50 years.
22 It really doesn't move around unless you
23 mechanically move it to another location.
24 When I mentioned that soil pile from 50 to
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l 100 years ago, what if you had a
2 residential property, they removed a tree,
3 there's a hole in the ground and they took
4 that soil to fill the hole. That's the
5 type of thing we're looking for now.
6 The General Gas Mantle building, let
7 me just tell you a little bit about what we
8 have here. It's all closed up now. Again,
9 as Alan was telling you, the radon levels
10 coming from the ground underneath the
11 building, that is indeed what's happening
12 here. Since it's all boarded up, there's
13 no ventilation so there is a high radon
14 level. There is some soil contamination,
15 nowhere near as extensive as at the
16 (INAUDIBLE) facility.
17 And it is a longer building and it
18 does come out into the street at South
19 Fourth Street. And there are some building
20 materials. The building is vacant.
21 There's nothing in there. There's wood
22 floors and some of those wood floors are
23 contaminated. They would have to be
24 decontaminated before the building is
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1 demolished. But Rick Robinson will come
2 back and talk a little about that.
3 I assume most people here are
4 property owners. So the last category is
5 . the vicinity properties. So let me touch
6 base a little more on this one. The goal
7 here is to get to the cleanup as soon as
8 possible. And we were fortunate in this
9 case that the State went to a thousand
10 properties. So we didn't want to go to a
11 thousand properties all over again and
12 investigate those properties. But what we
13 had to do is see that we could use the
14 State's data. So we went to 20 properties
15 and we compared our data to the State
16 data. And we agreed with their data.
17 So then we took their data and
18 categorized it. The State went to
19 approximately 1,000 properties. Here it's
20 1,088. When we looked at the State data,
21 we said approximately half, 449 properties
22 are clean. We can't find any indication of
23 contamination on those properties.
24 Then there's another category we put
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l on that we call suspect properties. That's
2 585 properties. Now suspect properties are
3 our grey area, if a property was adjacent
4 to a contaminated property, we
5 automatically called it suspect because we
6 want to check it out because it's adjacent
7 to that contaminated property.
8 Throughout the State people test
9 their homes for radon and get elevated
10 levels of radon in certain locations. That
11 might have happened here and it would be
12 perfectly normal. But we question is that
13 because of the normal radium in the soil,
14 or is it a sign that there might be some
15 soil contamination from the Welsbach
16 facility.
17 We use the term natural background
18 radiation because there's radiation all
19 over but there's an average. And these
20 properties might have had levels on the
21 high end of that. If you live in a brick
22 home, that may be a reason that it's high.
23 But we want to go back to those properties
24 to really break them either way, if it's
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1 the contaminated category or the clean
2 property category.
3 And then the bottom line is we have
4 54 contaminated properties. Properties
5 that clearly had some contamination on them
6 from our results and the State's. And we
7 came up with a volume for this for our
8 estimate in the future.
9 Before I let Alan come back and talk
10 again about risk, I just want to mention on
11 suspect properties, again it's our grey
12 area. The contamination on all these
13 properties might be a small spot that we
14 can take away and put in a pail. We might
15 have to bring a backhoe in there to dig it
16 out. But the suspect properties, we would
17 think that most of those properties can be
18 moved to the clean category eventually.
19 But we don't know that for sure and we
20 won't know until we actually do the testing
21 on that property.
22 So I'll let Alan come back and talk a
23 little bit about health risks.
24 MR. FELLMAN: Whenever I talk to
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l people about the risk of radiation, it's
2 always a good frame of reference to say a
3 few words first about natural background
4 radioactivity. it's very helpful when you
5 realize that we live on a radioactive
6 planet. And as a result of that, we're
7 constantly being bombarded by
8 radioactivity, no matter where we are,
9 having nothing to do with the Superfund
10 site.
11 There are several different sources
12 of natural radioactivity and they're listed
13 in this table. Cosmic and cosraogenic refer
14 to things coming from the atmosphere, the
15 upper atmosphere.
16 Terrestrial radioactivity is the
17 natural thorium, radium, uranium that's in
18 the ground, in the soil, in the rocks. And
19 we get most of that 28 millirem per year
20 from terrestrial sources which comes from
21 gamma radiation.
22 Inhaled radiation, we*re talking
23 mostly there about radon gas. On average,
24 in the average house, anytime you put four
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l walls and a ceiling together you're going
2 to get some level of radon gas. And on
3 average we get a dose of about 200 millirem
4 per year.
5 And then the internal emitters,
6 referring to the radioactivity that we
7 carry around in our bodies from natural
8 sources such as potassium 40, which is a
9 small but significant component of all the
10 potassium on the planet. There's a little
11 bit of these in soil, in the plants,
12 vegetables and fruit and so forth. And so
13 we're constantly ingesting and excreting
14 some of this radioactivity. And as a
15 result of it being in our bodies we receive
16 a dose on average of 40 millirem per year.
17 There's also a host of consumer
18 products that have one or another type of
19 radioactivity associated with it. And you
20 can see it's a pretty diverse list. And
21 the last one that we show there are gas
22 mantles, we know a little bit more about
23 them than we'd like to.
24 Adding a few more things to those
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1 that you see here on this slide, I have a
2 little show and tell here. Most everybody
3 who works in my field has one of these.
4 This is a piece of Fiestaware(ph) which
5 you'll find in almost any antique show.
6 And this orange color -- I don't know why
7 they call it yellow cake -- but the glaze
8 that they apply to give it this orange
9 color is called yellow cake. And it has a
10 fair amount of natural uranium in it.
11 This meter here is called a Geiger
12 viewer detector, the common name is a
13 pancake probe because of the shape. It has
14 very low background. When you turn it on,
15 from regular background radiation, this is
16 what you'll hear, the sporadic beep. Each
17 time a photon or a gamma ray is interacting
18 inside the detector, it makes a click. And
19 then, as you can tell when I get close to
20 the Fiestaware, there's quite a
21 difference. If I move one to two feet
22 away, you can hear how rapidly that level
23 of radioactivity decreases. As we remove
24 ourselves from the source, the level drops
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l off fairly rapidly. So again, a very high
2 level right out of the source, but by the
3 time I get within three feet apart, there's
4 very little, if any, impact right here.
5 Now, another thing that's kind of
6 interesting is that for those of us who
7 have been told by our doctors that we have
8 to reduce our salt intake because of
9 hypertension or heart problems, they say,
10 go get some salt substitute from the
ll grocery store. What you're getting is not
12 a salt substitute, it's potassium chloride
13 instead of sodium chloride.
14 And as I said earlier, of all the
15 potassium on the planet, a very small
16 zraction is radioactive. And there's no
17 difference from the potassium that's in
18 here than the potassium that's in a banana
19 or potato or any other potassium-rich
20 food. And the difference is not quite what
21 you'd hear with the Piestaware, but you do
22 hear a difference. And again, that's
23 natural potassium 40 emitting beta
24 particles and gamma rays. And this is what
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1 we need to eat to protect us from
2 hypertension. Again, it doesn't cause a
3 big dose. I just want to illustrate the
4 fact that there's radioactivity all around
5 us, even in the things that we eat.
6 when we talk about dose effect
7 relationship, about being exposed to
8 radiation, there's one point --if you get
9 nothing else -- there's one point that I
10 think is very important for you to
11 understand. And that is that what we know
12 about radiation is that, yes, it is most
13 definitely a human carcinogen. But we know
14 that because of studies that have been done
15 on populations of people that have been
16 exposed to very, very high doses of
17 radiation, compared to background, compared
18 to the levels that we have at some of the,
19 quote, unquote, contaminated properties
2 0 here. These would be groups such as the
21 Japanese who survived the atomic weapons
22 blast at the end of World War II. Several
23 groups of patients, who back in the '20s
24 and '30s and '40s were treated for various
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1 ailments with radiation. Whereas now, the
2 medical community uses radioactivity to try
3 to help destroy cancer cells. Back then it
4 used to be a treatment for certain
5 diseases. So 20, 30, 40 years later there
6 are these populations treated with these
7 high doses of radioactivity who were
8 followed and were found to suffer from high
9 or increased levels of cancer.
10 So what do we do as public health
11 scientists? We know that when the dose is
12 very high we see excess cancer. Now we've
13 got the lower dose and you can see in this
14 curve, what I'm talking about earlier with
15 the Japanese and some of these other
16 groups, they're up here in the dose
17 response curve. We know the dose is very
18 high and we see the health effect or the
19 risk of cancer is easy to measure. What we
20 have down here is what I call an area of
21 great uncertainty. There are no data that
22 we can point to that will show that at the
23 levels that we're exposed to from
24 background radiation and from levels that
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l are slightly greater than background such
2 as some of the properties that have these
3 thorium residues on them. There are no
4 data that show that people exposed at those
5 levels are actually suffering from
6 increased incidents of any type of cancer.
7 But the fact that I can say that
8 doesn't mean that we can then dismiss or
9 would want to say there'a no problem, let's
10 forget about it. We make an assumption.
11 He assume that there's a linear risk. We
12 assume what's called no threshold, that as
13 soon as you get any dose of radiation, we
14 assume there's some risk. It might be very
15 small. We certainly can't measure it and
16 the truth of the matter is, there may be no
17 risk at all.
18 But we assume that there is a risk.
19 And when we end up at a risk level, when we
20 do our risk assessment part of this
21 investigation, we come up with a number and
22 compare that to what EPA has determined to
23 be the acceptable risk range. And if our
24 models project a risk greater -- that is
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1 greater than the risk range that EPA is
2 looking to obtain, that becomes the basis
3 for a cleanup. The way the Superfund law
4 is written, EPA needs to demonstrate a risk
5 greater than what they found to be
6 acceptable and to use that then as a reason
7 to go forward with an action.
8 At this point I'11 stop and Rick will
9 pick back up and discuss the alternatives
10 for the sites.
11 MR. ROBINSON: Thanks, Alan. Now
12 what we're going to talk about is, based on
13 the results of the remedial investigation
14 we evaluated a number of alternatives for
15 the cleanup. And we evaluated alternatives
16 for the three property types we discussed
17 earlier, the vicinity properties, the
18 Welsbach facility and for the General Gas
19 Mantle facility. And for each of the three
20 property types we evaluated, we evaluated a
21 No Action Alternative; an Engineering
22 Controls Alternative; and an Excavation and
23 Off-site Disposal Alternative.
24 The No Action Alternative is an
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1 alternative that we have to do on each
2 Superfund site. And we have to compare the
3 other alternatives versus what if we did
4 nothing. If we left it alone, what are the
5 risks. So the No Action Alternative is
6 something that we have to do. In this case
7 here, it was determined that there is a
8 risk above EPA's criteria, as Alan just
9 told you. And as a result we're not going
10 to talk about the No Action Alternative
11 anymore. And we're not even going to
12 consider it right now.
13 For the vicinity properties, for the
14 Engineering Controls Alternative, it's
15 Alternative v-2. Outdoor gamma shields
16 would be required on approximately 50
17 properties; indoor gamma shields on
18 approximately 20 properties,- and radon
19 mitigation systems would be needed on
20 approximately 4 properties. As a result we
21 would need to have deed restrictions on the
22 property/ limiting future work on that
23 property. And we would have to negotiate
24 tiiat with each property owner. The State
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l of New Jersey would be responsible for
2 enforcing those restrictions. And we would
3 have to go back every five years to make
4 sure that it was protected and the shields
5 were still effective.
6 For the Alternative v-3, the
7 Excavation and Off-site Disposal
8 Alternative, all the soil and debris above
9 our cleanup standards would be excavated
10 and disposed of off-site. And under this
11 alternative, the contaminated materials
12 would all be removed. The mobility of the
13 contaminants would be eliminated and there
14 would be no significant institutional
15 controls remaining on the properties. The
16 properties would be safe for future reuse
17 and the remedy would be protective of human
18 health and environment.
19 For the Welsbach facility,
20 Engineering Controls, again we would need
21 outdoor gamma shields. We would need deed
22 restrictions limiting future site work.
23 And we would have to go back every five
24 years to make sure that it was protected
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l and that the shields were still effective.
2 Alternative W-3 for the Welsbach
3 facility, all the soil and debris above our
4 cleanup standards would be removed and
5 excavated and sent off-site for disposal.
6 All of the materials, again, would be
7 removed from the property, mobility of the
8 contaminants would then be eliminated, and
9 there would be no controls remaining.
10 For General Gas Mantle, again for the
11 Engineering Controls Alternative, G-2,
12 again outdoor gamma shields. For the Gas
13 Mantle building, we would have them
14 permanently board the building shut. He
15 would have to restrict access against the
16 building, and we would have to go back
17 every five years to make sure that it was
18 still effective controls.
19 For the Excavation and Off-site
20 Disposal Alternative G-3, we evaluated two
21 options for the buildings. For the General
22 Gas Mantle facility under Option A, the
23 building would just be demolished and the
24 building materials would be sent off-site
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l as contaminated materials.
2 For Option B, we would first go in
3 and try to decontaminate the building and
4 then this would reduce the volume of
5 material that needed to go to off-site
6 disposal. For both options all materials
7 would be moved from the site and there
8 would be no significant institutional
9 controls.
10 And now we'll just go into some
11 summaries. The summary of the cost for the
12 vicinity properties. The engineering
13 controls would cost about $2 million
14 dollars to implement. And the Excavation
15 and Off-site Disposal would cost
16 approximately a little over $13 million
17 dollars.
18 For the Welsbach facility, the
19 engineering controls, almost $6 million
20 dollars. And the Excavation and Off-site
21 Disposal, $18.5 million dollars.
22 For the General Gas Mantle facility,
23 the Engineering Controls Alternative just
24 under $400,000. And the Excavation and
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1 Off-site Disposal for Option A which was
2 the straight demolition of the building is
3 just over $2 million dollars. And for the
4 decontamination and demolition of the
5 building, just under $2 million dollars.
6 As a result, BPA's preferred
7 alternative is the Excavation and Off-site
8 Disposal Alternative, v-3, w-3 and G-3.
9 And with the General Gas Mantle facility it
10 would be Option B, decontamination prior to
11 the demolition.
12 In summary, the total cost of the
13 selected remedies combined is almost $34
14 million dollars. Where do we go to next
15 now? The next steps, right now we're at
16 the process soliciting public comment. And
17 as Mary Helen told you earlier, we're here
18 to respond to your verbal comments tonight
19 and we're also encouraging you to submit
20 written comments, if necessary. And after
21 we receive public comments, we select a
22 remedy in a document that's called a Record
23 of Decision (ROD). And once we sign the
24 Record of Decision, EPA can then start the
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l design process.
2 Our focus will be on the residential
3 properties first. And then followed by
4 that the commercial and industrial property
5 cleanups. We plan on starting the field
6 investigations on the suspect properties in
7 the fall of this year. And we'll hopefully
8 start the design and investigation on the
9 potential contaminated properties also in
10 the fall. And we're also going to try to
11 start the demolition process of the General
12 Gas Mantle building sometime this year and
13 hopefully finish in one to two years. The
14 General Gas Mantle building is in a very
is sad state of disrepair. Vandalized a
16 number of times. The wood floor is a fire
17 hazard. We'd like to get the building down
18 as soon as possible.
19 The plan right now is to start the
20 cleanup activities on the individual
21 properties in about three to five years.
22 One of the processes with the design is
23 that because it's an individual nature of
24 the property -- because the contamination
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1 is on an individual property, we have to do
2 a specific design on each individual
3 property. And it takes time to generate
4 the design activities on all these
5 different properties and put it together in
6 a package so that we can have a contractor
7 go in and do the cleanup all at once.
8 We're also in the process of
9 conducting a ground water investigation.
10 And that's underway right now to make sure
11 there is no radiological contamination from
12 the site in the ground water, we don't
13 believe we'll find that much, but thorium
14 itself does not like water. It doesn't go
15 into water, into solution. But we're
16 testing the ground water anyway just to
17 confirm that there is no radiological
18 contamination there.
19 We're also going to investigate the
20 wetland areas around Newton Creek, around
21 the Johnson Boulevard Land Preserve and
22 along Temple Avenue where there's two
23 former dumps as well as the welsbach
24 operation.
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l And that's the end of our
2 presentation. We'd like to invite you to
3 ask any questions. We're all here to
4 answer them.
5
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1 MR. EVANGELISTA: Before we get
2 involved in the questions and answers, I
3 just wanted to point out that we have some
4 handouts up front. One provides you with
5 factual information, sort of a summary fact
6 sheet. Hopefully it kind of reiterates
7 what I opened up with at the initial part
8 of the meeting. If you have any questions
9 now is a good time to raise them.
10 MS. CERVANTES-GROSS: Or if you just
11 have a comment. If you could just state
12 your name again before you give us your
13 question.
14 MR. BECKS: My name is John Becks(ph)
15 (INAUDIBLE). I live on the 900 block of
16 Somerset Street. I'm about eight houses
17 from where you were doing the cleanup
is earlier.
19 Did they come around -- did you or
20 the State come around to individual homes
21 in that area to test our homes? And what
22 steps are being taken for that?
23 MR. ROBINSON: You might have to show
24 us on one of the maps where Somerset Street
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1 is.
2 MR. SAUNDERS: Johnson Boulevard, the
3 ponytail, almost catty-corner, right in
4 those blocks.
5 MR. ROBINSON: I would have to look
6 at the State information on whether or not
7 that part of Somerset Street was included
8 in the investigation. We could let you
9 know if there is any information on your
10 property --if the State did survey it or
11 not. If you don't believe they did --
12 MR. BECKS: No, I don't.
13 MR. SAUNDERS: That area -- actually
14 the whole town --we get a lot of false
15 positives, which is what we want. They go
16 back through that area to see if it's
17 construction of the home material. And in
18 that area the only thing they saw was along
19 the Johnson Boulevard area of houses in
20 Gloucester, (INAUDIBLE), in that immediate
21 area.
22 MR. BECKS: Why wouldn't they be?
23 MR. SAUNDERS: we went out. I can
24 show you on one of the colored pictures
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l where it was done.
2 MR. BECKS: And was it?
3 MR. SAUNDERS: Yes, it was done. Was
4 the house done? No. Plus the construction
5 date of those homes -- that was called the
6 homes, like, that (INAUDIBLE) and a lot of
7 the construction predated the site. The
8 homes were built -- that whole section on
9 Somerset Street predated a lot of the dump
10 area. The wetland area that was all
11 wei.ands in the '50s. So that's some of
12 the ones where we didn't see anything.
13 When I say "we," EPA. There was nothing to
14 indicate that there was any concern
15 whatsoever in that area (INAUDIBLE) quite a
16 few feet to make sure.
17 Some of the pictures -- here some
18 people made mention of (indicating).
19 People want to make sure again and again
20 and again, to make sure. So that's why it
21 may be contaminated here. We are going to
22 look here and here and here and here again
23 (indicating). The last thing anybody wants
24 to do is do this wrong.
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l I live around the block. I have --
2 was my house tested? No. Because I know
3 the age of when they were built, how it was
4 built. Where Dr. Kelly lives, that area,
5 that predated the dump. So the homes built
6 before the dump (INAUDIBLE) they weren't
7 (INAUDIBLE). However, as part of this
8 randomly (INAUDIBLE). They did go out.
9 MR. ROBINSON: If you'd like and you
10 are concerned, we can just go over and do a
11 quick walkover while one of our contractors
12 is out here.
13 MR. BECKS: I'm concerned too, in
14 talking with various neighbors, it was a
15 common practice at the time when they were
16 filling the wetlands, that people go home
17 and pick up building materials, bring them
18 home to your site, wood and such. And
19 that's a concern.
20 MR. FELLMAN: Part of the answer is
21 that this fly-over data kind of laid out
22 the boundaries of the different study
23 areas, as starting points. And not looking
24 at a map, you know, I suspect that your
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1 home is probably outside of the boundaries
2 that the fly-over gave us to start with.
3 MR. BECKS: I was doing some work in
4 my basement about a week and a half ago. I
5 tore out the closet and there was building
6 material from Welsbach.
7 MR. ROBINSON: Really. If you could
8 please leave your name. I have a
9 contractor who's here with me today doing
10 some fieldwork and we can make an
11 appointment and scan your property. We'll
12 need to do that this week.
13 MR. BECKS: I have two very small
14 children that my wife and I love dearly.
15 MR. SAUNDERS: That's the kind of
16 information -- some people think they're
17 going to get in trouble.
18 MR. BECKS: Well, that's why I came
19 here. That's not the only reason. I was
20 planning on coming when I first read it in
21 the Gloucester City News. The only way
22 that I knew about this meeting was from
23 that article in the Gloucester City News.
24 I can see by the amount cf people that
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l apparently nobody cares or everyone wasn't
2 informed.
3 MR. SAUNDERS: This is what we did.
4 Gloucester City News was given the same
5 data as the Courier and as the Inquirer.
6 And all those areas of people who live in a
7 house (INAUDIBLE) there was suspect
8 condition. So now you're looking at quite
9 a few hundred people and this is generally
10 the response.
ll MR. BECKS: I only really get the
12 Gloucester City News. I don't read the
13 Courier or the Inquirer.
14 MR. SAUNDERS: In fairness to EPA, a
15 lot of these residents who had questions, a
16 lot of them have called to complain. And
17 we'll give them the information -- plus the
18 residents we've sat down with. And I'll
19 show you what we have here, a demarcation.
20 MR. BECKS: There was a lot of people
21 filling in tree holes from dirt piles down
22 at the end of the street.
23 MR. SAUNDERS: But the fly-over would
24 have shown that.
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1 MR. ROBINSON: We can schedule a time
2 tomorrow morning. We'll still be here in
3 town. We can make an appointment with you
4 or anytime at your convenience when we' re
5 down here. If you know of anybody else who
6 are not in these areas who have other
7 Welsbach materials, we're very, very
8 interested in trying to find those homes.
9 Like a former worker who used to work there
10 may have brought some stuff home with him.
11 It's very, very hard to do the entire
12 town. And we need help from the public on
13 that.
14 MR. SAUNDERS: As always, if you get
15 the word out, they can call us 24 hours a
16 day and we'll take a quick sample. That's
17 the beauty. We can meter it and say, yes,
18 it's there/ no, it's not. We want to do
19 that with a whole host of the materials.
20 MR. BECKS: Thank you.
21 MS. CERVANTES-GROSS: Anyone else
22 have a comment or a question?
23 MS. MARKS(ph): My name is Sue
24 Marks. I live in Bellmawr. I was a
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1 resident of Fairview for many years. I
2 have a couple of questions and I spoke to a
3 couple of gentlemen earlier.
4 I have a cancer study here that I
5 sent to the EPA (INAUDIBLE) a couple of
6 weeks ago. I received a copy of this and
7 in here, one of things that stood out for
8 me was, it says higher cancer incidents
9 from the Welsbach General Gas Mantle site
10 appear to be due to significantly higher
11 lung cancer incidents in the population,
12 especially in males.
13 Do you -- and maybe you're not the
14 right people to ask -- but to me I'm
15 concerned about the health aspect of what
16 has seemed to be a long-term problem here.
17 As I said, I used to live in Fairview and
18 my house -- I just saw on one of the poster
19 boards there -- was basically right
20 directly behind one of your highly
21 contaminated homes. I'm concerned about
22 the residents' health. And I guess what I
23 need to know is, the people that are living
24 in these homes that are the 54 contaminated
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1 homes, what will be done with them, to
2 them, for them, while this remedial work is
3 going on? In other words, A, will they be
4 moved out of their home; B, will they be
5 monitored for any sort of health problems
6 as the remedial work is going on? To me
7 that's one of my greatest concerns.
8 I think, Bob, you and I had spoken
9 about this earlier. I don't know where
10 this came from. I don't know how it's in
11 reference to this Welsbach site. But I
12 have to know that it must be connected
13 somewhere.
14 MR. ROBINSON: For the answer to the
15 health study, we have Artie Block here from
16 ATSDR. And his agency is the one who
17 sponsored the State investigation.
18 MR. BLOCK: Let me just take a
19 moment. Again, my name is Arthur Block.
20 I'm a Senior Regional Representative for
21 ATSDR.
22 As was mentioned by Mary Helen, ATSDR
23 is the Agency for Toxic Substances and
24 Disease Registry and is part of the
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l Department of Health and Human Services.
2 We are primarily, and our main mandate and
3 responsibility, is environmental health.
4 We work very closely with the Federal EPA,
5 the State, the community, whatever it is to
6 identify if there are any health needs or
7 health concerns associated with
8 environmental exposure. And that's
9 basically our main role.
10 One other thing I'll tell you about
11 our agency, my agency, is that it is an
12 independent environmental health agency.
13 In other words, we look at situations that
14 affect you, the community, on an
15 independent basis. We look at all the data
16 that was put in front of us and we evaluate
17 that data independently of other agencies.
18 And we give you our health call as to what
19 is up or what's going on in your
20 community. I'm not going to spend too much
21 more time on this. Here's the information
22 and certainly if after the meeting you want
23 to speak more to me about our agency, you
24 can have this information about ATSDR. And
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1 there's a lovely young lady over here who
2 says she's a computer geek, so I'm going to
3 pass this onto you, which is our web page.
4 And we also have some more of that if
5 you're into computer information. And
6 actually you can get a lot of information,
7 more than I could ever tell you tonight,
8 about contaminants, about how they impact
9 on human health. So if you want that
10 information I can certainly pass that along
11 to you too. And I'll certainly give you my
12 card and, as Pat indicated, if you have any
13 follow-up questions.
14 I'm not a scientist. I'm just like
15 you guys. But I work in public health so
16 there may be some specific questions, if
17 you do come up with any, that refer to a
18 specific science or physic radiation. I'll
19 refer those to Alan. He is a health
20 physicist and the person who can give you
21 the scientific readouts. I'll give you the
22 readout from the point of view of just
23 common people like ourselves.
24 If you look at the houses that, as
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l they existed 50, 60 years ago or the area
2 around there 50, 60 years ago -- I wish we
3 were able to take one of these machines and
4 read what people were exposed to back then
5 and at what level. we don't know. We
6 don't know. That is the bottom line.
7 Nobody knows. It takes time for cancer to
8 develop. It doesn't happen overnight. And
9 it takes a lot of dosage, constantly being
10 exposed to these high doses. These are
11 things that just come out. And that's how
12 I understand it.
13 To get exposed on a normal basis, as
14 indicated, we do commonly get exposed to
15 radiation in different levels. Most of
16 that is not of public health concern.
17 People who generally worked in these
18 situations and got a constant exposure to
19 them, these are the people who developed --
20 or in the case, you know, of the Japanese,
21 where you have a huge, huge amount of
22 dosage coming at you at one time. So these
23 things we know about.
24 Now, let me also make some other
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1 statements about the study. And that
2 hopefully will get to your question. Is
3 lung cancer -- can it be associated or is
4 it biologically causable that radiation can
5 cause lung cancer? The answer is yes. But
6 looking at the numbers and what was given
7 to ATSDR and the New Jersey Department of
8 Health who did the evaluation of the
9 sampling that was done, these dosages were
10 not high enough or should not have been
11 high enough to give you lung cancer.
12 That's the short and long of it.
13 But nonetheless, ATSDR, my agency,
14 along with the New Jersey Department of
15 Health and the Department of Health and
16 Human Services decided to take a look. And
17 you won't be surprised to hear that in New
18 Jersey there are other sites like this. So
19 you have Maywood in Maywood, New Jersey.
20 You have the West Orange, Montclair area,
21 all similar radon exposures. New Jersey
22 and ATSDR decided, well, let's take a look
23 because communities generally are concerned
24 about cancer and understandably so,
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1 radiation issues around these type of
2 Superfund sites.
3 So we pick these three areas here,
4 this whole bottom area (indicating), and
5 those other two that I just mentioned. If
6 you read the study, you'll find out that
7 with an examining of the cancer risks
B around a one- or two-mile area of those
9 Superfund sites, there was no elevated
10 cancer of any type found associated with
11 the exposure to radon or radiation. Didn't
12 find it. Didn't find it in Montclair.
13 Didn't find it in Maywood.
14 What we did find, what you're
15 bringing up is, yes, there was elevated
16 lung cancer found here in this area.
17 What's kind of interesting is, you have the
IB same type of contaminant.
19 If you look at the history of all of
20 these sites, they're very similar. And yet
21 you have just one elevation of one type of
22 cancer, lung cancer, in this area. What
23 you would want -- what you might expect to
9
24 find is that if this is all similar
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1 contamination, all similar exposures to
2 people, that you'd find lung cancer here
3 and find lung cancer in Maywood and you'd
4 find lung cancer also in the Montclair,
5 West Orange area.
. 6 Is radiation the cause for the
7 increased lung cancer? In all honesty, I
8 cannot say to you standing in front of you,
9 and I wouldn't say that, that it isn't
10 possible. It is possible. The probability
11 of it is probably much less than that.
12 Okay. Beyond that, it would take a very --
13 you'd have to study the individual people
14 themselves to find out --to rule out
15 other, what are called, confounders.
16 What are these confounders? These
17 confounders are things like occupational
18 exposure that causes lung contamination.
19 Smoking, that we know has a direct
20 association with lung cancer. These are
21 the confounders that, if you pursued this
22 further, you may find, yes, there was a lot
23 of smokers out there. Or, yeah, they were,
24 in fact, occupationally exposed. And that
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l elevated number that was found from that
2 study will start to decrease or it should.
3 Unless we rule out all other
4 confounders and you're stuck with, yeah,
5 it's the radiation. That's what that study
6 was trying to find out. Is there any
7 similarities in the occurrence of cancers
8 within those three -- around those three
9 given Superfund sites and there wasn't any
10 found. Other than the one elevation of
11 lung cancer here. And that was the purpose
12 of the study. It wasn't necessarily to
13 associate Superfund sites and cancer. That
14 was not the purpose. The purpose was to
15 see if there was any commonality of the
16 exposures and things like that from the
17 Superfund sites.
18 Let me stop there. Having heard what
19 Alan said, having heard what I said, are
20 there more concerns than that? Did I
21 somewhat, kind of, sort of, answer your
22 question?
23 MS. MARKS: Yes. It'8 just my
24 concern that we live in the area that's
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l very polluted.
2 MR. BLOCK: It's a very real
3 concern.
4 MS. MARKS: Exactly. And the
5 Welsbach problems coupled with this study
6 just alarmed me more than I thought.
7 I do have a couple other questions.
8 MR. BVANGELISTA: At this point I'd
9 like to address the other part of your
10 question regarding how the EPA will deal
11 with affected residents whose property will
12 require cleanup.
13 As Rick and I touched upon a little
14 earlier, we talked about the remedial
15 design phase of the project. At that point
16 EPA will look at each of these individual
17 properties that will require cleanup and
18 design an approach for cleaning up that
19 property. And each property will be
20 different. You may have a property that
21 has several bricks in the backyard that we
22 will essentially pick up and take away. We
23 may have another property where we may have
24 to excavate a certain volume of soil that's
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1 elevated in levels of radioactivity which
2 we'll also move away.
3 Whatever you may have as far as a
4 cleanup that's required, the agency will
5 and hopes to work very cooperatively with
6 the property owner. Our intent or our
7 approach will be as we've applied it in
8 other sites like Montclair where we'11 work
9 as closely as we can with the property
10 owner to impose as little inconvenience as
11 possible.
12 You touched a little bit upon
13 relocation. If there's a need for
14 relocation, which we hope there won't be,
15 but if there is a need then EPA will work
16 as closely with the property owner as
17 possible to provide as temporary relocation
18 as possible. And, of course, that will be
19 at our expense or the Superfund's expense.
20 But we hope that that will not be the case
21 for any of the properties. But I'm not out
22 here to tell you tonight that that's not
23 ever going to be the case on any of these
24 projects. That may very well be the case
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i on some of the projects. So we'll just
2 have to wait and see and we'll do our best
3 to keep you as informed as possible in as
4 timely a fashion as possible.
5 MR. SAUNDERS: Say I live in a house
6 that there's known contamination there, I
7 understand remedial measures have already
8 been taken (INAUDIBLE) shields as discussed
9 earlier. So right now, if you're in the
10 house (INAUDIBLE) we know we're going to
11 protect yo\:. There's a lot of (INAUDIBLE)
12 that don't care about the health issues,
13 they just care about the trees and birds.
14 That's the farthest thing from the truth.
15 (INAUDIBLE) and then we go from there. And
16 we have been somewhat criticized in
17 (INAUDIBLE) and using overkill. And yes,
18 we do take overkill and we wear it as a
19 badge of honor. (INAUDIBLE) some of the
20 people over at the Popcorn Factory, I'd
21 much rather be brought before my governing
22 body -- there are quite a few Council
23 people here -- I'd much rather be brought
24 on the carpet for overkill than not doing
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l enough. And the direction is always
2 overkill. It's never not enough. So here
3 that's what we've taken. EPA, they have
4 gone above and beyond in many, many
5 situations.
6 MS. MARKS: Would there be any sort
7 of follow-up, I mean, like a health study
8 done on the residents after your remedial
9 work takes place? will you be tracking
10 them for a period of time to see if they
11 develop any sort of problems or any
12 long-term problems due to -- maybe before
13 your remedial work started and before these
14 temporary structures were put into place?
15 MR. SAUNDERS: Would you be able to
16 speak for the purpose of contamination?
17 MR. BLOCK: Your question is more, as
18 I understood it, they're going to begin the
19 remedial and then -- did I sense that you
20 think you're going to be exposed to
21 something during that time period and
22 then --
23 MS. MARKS: NO; no.
24 MR. BLOCK: Okay. I did
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1 misunderstand then.
2 MS. MARKS: I understand the way it's
3 going to occur. What I'm saying is, these
4 people, evidently, I assume some of them
5 have been living in these contaminated
6 homes for some time. Will there be some
7 sort of a health study done on them before
6 the remedial work starts and then would
9 there be a follow-up study just to track
10 the situation to see if anything they
11 have incurred any sort of medical problems?
12 MR. FELLMAN: In a sense that first
13 health study is what ATSDR funded to the
14 State. Because the only health effects
15 that we associate with exposure to
16 radiation is cancer. There aren't other
17 illnesses that we look at as indices of
18 radiation exposure. So it's either
19 elevated cancer or not. And so that first
20 look, in effect, is the study that you've
21 looked at. Now whether there's going to be
22 an additional study done or another study
23 done down the road -- I think --
24 MR. BLOCK: The bottom line, is there
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i a health plan?
2 MR. ROBINSON: It's not planned.
3 MR. FELLMAN: It's not part of this
4 process.
5 MR. BLOCK: It doesn't require it
6 from the viewpoint of looking at the site
7 and how the impact on health would be. So
8 the short answer is no. But I know Bob
9 wanted me to just discuss the Cancer
10 Registry.
11 Are all of you familiar with the
12 State Cancer Registry? Is there anyone who
13 needs information on that and how it works
14 and what it's there for? Are you okay with
15 that? Because I' 11 spend a moment on that
16 if you'd like.
17 New Jersey, like all 50 states
18 throughout the nation, maintains what is
19 called a Cancer Registry. Some states do
20 it better than others. And, in fact,
21 they're funded very well to maintain a good
22 Cancer Registry. And within the states
23 there are mandated laws that hold --
24 hospitals and physicians who diagnose
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l cancer must report that cancer incident to
2 the State. And once it's reported, then it
3 comes into the registry system.
4 And the reason for that is,
5 obviously, all of us are concerned about
6 cancer. Not only for research reasons, but
7 certainly we want to know how much cancer
8 is out there and specifically within our
9 own areas. Are there more elevated cancers
10 overall? Why? Because that then may
11 prompt further investigations. A perfect
12 example of that is just north and east of
13 here, Toms River. And I'm sure a lot of
14 you have heard about that. And our agency,
15 ATSDR, along with the New Jersey Department
16 of Health is very, very much into that
17 childhood cancer investigation at this
18 point.
19 So this Cancer Registry maintains all
20 of the reported incidents. And actually
21 this is kind of interesting. Prior to Toms
22 River, the New Jersey Cancer Registry was
23 probably four to five years behind in terms
24 of keeping up with the data that was
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1 entering in. After Toms River, all of a
2 sudden money came into the Cancer
3 Registry. And now it's probably -- and I'm
4 not kidding you about this -- New Jersey's
5 Registry is a gold mark standard registry.
6 But something like that had to happen. And
7 there are other states in the union who are
8 not very good with keeping their data. But
9 New Jersey is exemplary with its program.
10 Now what that does is -- and when you
11 get into the issue of statisticians and
12 numbers and how big populations are in
13 terms of how do you measure what's
14 happening in one community as opposed to
15 another community, what they do is -- I'm
16 simplifying it, really -- I have to. I
17 really don't understand all of it. I'm not
16 a statistician.
19 What they do is take comparable
20 populations in numbers and size and their
21 socioeconomic background. And they compare
22 these two populations which are similar and
23 look at the cancer rates or incidents
24 within those populations, they should be
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1 similar. Everything else being equal, they
2 should be similar. But if something pops
3 out, whether it be bladder cancer or lung
4 cancer or brain cancer, that just doesn't
5 gel, that pushes the investigative health
6 system to go further, what's in this
7 neighborhood that may be causing it, to do
8 further investigation.
9 MR. SAUNDERS: In an indirect way,
10 yes, there is a follow-up indirectly.
11 MR. GRABOWSKI: Mike Grabowski. I'm
12 just wondering if your house is found
13 contaminated and you don't want to live
14 there, you want to sell, there's a problem
15 there. But the State of New Jersey has a
16 disclosure on it. You have to tell the
17 Realtor. What happens with that?
18 MR. ROBINSON: Well, I guess that's
19 one of the grey areas of the process with
20 an individual property that has
21 contamination on it and the property owner
22 wants to sell it.
23 For EPA, what we can do to a
24 potential purchaser --we can enter into an
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1 agreement with the purchaser to give them a
2 prospective purchaser agreement to not be
3 held liable for any cleanup costs associated.
4 That way it may be helpful with the
5 transfer. So that he wouldn't be taking on
6 liability. However, with respect --
7 MR. EVANGELISTA: And assurance that
8 it will be cleaned up.
9 MR. ROBINSON: Right.
10 MR. GRABOWSKI: Do I have to put down
11 the limit of contamination in the area?
12 MR. EVANGELISTA: We would be able to
13 inform them at an appropriate time when
14 we've properly investigated your property
15 -- if it's your property that we're
16 talking about -- yes, we'll have cut lines
17 as we call them, where the contamination
18 is, an estimate of the volume, etc., etc.
19 If someone's interested in your property,
20 we can provide them with a document that
21 says EPA is going to clean up this property
22 and is not going to hold you accountable
23 for it in any way, shape or form.
24 MR. GRABOWSKI: It will be pretty
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1 tough to sell the property.
2 MR. EVANGELISTA: I understand that,
3 sir.
4 MR. GRABOWSKI: Nobody would want to
5 buy it, I don't think.
6 MR. EVANGELISTA: I understand. And
7 I guess the other part that may give you
8 comfort, we've been moving along in this
9 project extremely quickly. You may look at
10 other Superfund projects where an RI/FS has
11 gone on for three, four, five years. We've
12 completed this process in what some would
13 say is record time. We did it in a year.
14 And we hope to continue moving that quickly
15 so that we can restore your property and
16 others to a form where it may be attractive
17 for selling or you may be comfortable with
18 it again.
19 UNIDENTIFIED SPEAKER: I own a
20 property on Temple Avenue that goes right
21 into Newton Creek, concreted over. My son
22 was told recently by a lawyer from Malcolm
23 Pirnie that -- I had wanted to either give
24 him the property or sell it, get it out of
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l my hair, so to speak. And the lawyer told
2 him that he would be responsible for the
3 cost of the cleanup.
4 MR. KERBEL: Just to be clear, it
5 wasn't a Malcolm Pirnie lawyer. I don't
6 know if --
7 UNIDENTIFIED SPEAKER: He had spoken
8 to Steve McNally(ph).
9 MR. KERBEL: Steve is right here.
10 UNIDENTIFIED SPEAKER: And he was
11 referred to a lawyer.
12 MR. ROBINSON: I think Steve referred
13 your son to me.
14 UNIDENTIFIED SPEAKER: Oh, was that
15 you?
16 MR. ROBINSON: Yes, I'm Rick
17 Robinson.
18 MR. KERBEL: We don't have the
19 authority.
20 MR. ROBINSON: Your son spoke to me
21 and I basically told your son it's in his
22 best interest to talk to an attorney to
23 find out from an attorney himself, his own
24 attorney. I didn't give him any legal
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l advice. I jusc told him it would be in his
2 best interest to talk to an attorney prior
3 to any transfer. Because he doesn't want
4 to take on any liability knowing that he's
5 buying a contaminated property. I'm just
6 giving him advice, you know. I would
7 contact an attorney. And I was just --
8 UNIDENTIFIED SPEAKER: And if I died
9 tomorrow and he inherited the property, he
10 would not have to pay for the cleanup?
11 MR. ROBINSON: He would not.
12 MR. EVANGELISTA: And neither would
13 you.
14 MR. ROBINSON: It's a different story
15 when someone purchased the property not at
16 full-market value and they try to buy a
17 property for, you know -- they know it's
18 contaminated and they're getting it for,
19 like, three cents on the dollar or ten
20 cents on the dollar. That's where EPA
21 would then go back to that person who's
22 buying it cheaply and say, hey, you're
23 buying it not at the fair-market value and
24 we may want to get some of that money
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i back. That's where the issue is.
2 MR. BLOCK: May I say one more thing
3 about the Cancer Registry? I just want to
4 point out the fact that the local County
5 and City here are trying to get information
6 frsm the New Jersey Cancer Registry to do
7 some type of follow-up also. So they're
B attempting to get that information.
9 The Cancer Registry information is
10 extremely confidential and private. And
11 it's designed under law to be that way. So
12 to get that information, sometimes you have
13 to jump through hoops to try to get that
14 information. But I know your City and
15 County are attempting to get that
16 information to do some additional follow-up
17 work. Is that correct?
18 MR. SAUNDERS: Yes.
19 MS. CERVANTES-GROSS: Any other
20 questions or comments?
21 MS. MARKS: Just two more. I wanted
22 to address the issue of the alternatives.
23 One, obviously, was a No Action Alternative
24 which, for obvious reasons, would never
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1 work. The second, the Engineering Controls
2 Alternative. And the third, the excavation
3 and demolition of the various properties.
4 Is it my understanding that the EPA
5 is suggesting that the demolition and
6 excavation go forward? Has a decision been
7 made on that?
8 MR. ROBINSON: The decision won't be
9 made until EPA hears all the public
10 comments. And we're patiently waiting to
11 hear your responses today, your verbal
12 comments, and any written comments that are
13 submitted. As Mary Helen said earlier, our
14 public comment period ends on March 3, next
15 Wednesday. So after next Wednesday, then
16 EPA sits back and writes responses to all
17 of the questions and will formally select a
18 remedy in a document called the Record of
19 Decision. And attached to the Record of
20 Decision is another document that we call
21 the responsiveness summary, which
22 summarizes the verbal responses today that
23 we're given and the written responses
24 also.
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l So that's why we have a court
2 reporter here today and she's taking down
3 your questions and ray answers. So all that
4 will be part of the record.
5 MR. SAUNDERS: At the local level,
6 our (INAUDIBLE) is March 3. And on that
7 document would be a resolution (INAUDIBLE)
8 in our City that supports that. I asked
9 for a telephone campaign and that would be
10 such (INAUDIBLE). That is something they
11 need to make (INAUDIBLE) what is the
12 interest here. And we support them
13 totally. It's part of what has to occur
14 and we do have (INAUDIBLE) in that office
15 and our governing body (INAUDIBLE).
16 MS. MARKS: And I would hope that the
17 City of Camden would do likewise. Although
18 I would have to say in my years -- you
19 think you got 25 people here tonight --
20 you'll probably be lucky if you get ten
21 . tomorrow night. Unfortunately, a lot of
22 City residents aren't real anxious to go
23 into the CCMUA at night. So that may not
24 give you a real indication. Has anyone
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1 there been in touch with the mayor over the
2 situation?
3 MR. ROBINSON: I've been in contact
4 with the City of Camden, the mayor's
5 assistant.
6 MS. MARKS: Okay. I would like to
7 see the City of Camden put forth the same
8 kind of resolution to remove and excavate
9 the sites.
10 MR. EVANGELISTA: I guess based on
11 what we've seen and heard thus far, it's
12 our anticipation that the decision will be,
13 in fact, to excavate both Camden and
14 Gloucester City.
15 MR. FELLMAN: In the proposed plan,
16 that's what EPA is indicating is EPA's
17 preference. So they need to have reasons
18 why not to go forward with that, as opposed
19 to having to be convinced to do it.
20 MS. MARKS: Okay. One more
21 question. When you excavate these sites
22 and remove the contaminated material, it
23 will be put onto a truck and trucked out of
24 the area to wherever your hazardous waste
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1 facility is?
2 MR. ROBINSON: Most likely we will
3 probably ship it by rail.
4 MS. MARKS: Okay. If you ship it by
5 rail it's obviously not going to be put on
6 the train right here in Gloucester City --
7 MR. ROBINSON: We would hope to find
8 a site here in Gloucester City to ship it
9 out.
10 MS. MARKS: On rail?
11 MR. ROBINSON: On rail.
12 MS. MARKS: You're going to have it
13 come right from the contaminated site in
14 Gloucester City to the rail?
15 MR. ROBINSON: Or the nearest rail
16 transfer --
17 MR. SAUNDERS: We have two staging
18 areas. If you're getting to or worrying
19 about spilling something, if you have an
20 opportunity I can take you to the tankers
21 they go in. They are totally encapsulated.
22 MS. MARKS: You're not going to bring
23 it in from Camden? Incinerator ash has --
24 MR. SAUNDERS: We have sites here in
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1 Camden and Gloucester City (INAUDIBLE) put
2 on a truck. Just like you had (INAUDIBLE)
3 that stuff.
4 MS. MARKS: What is your estimate --
5 MR. SAUNDERS: Now you said three
6 weeks. That's beyond anybody's control
7 here.
8 MS. MARKS: The problem is low
9 (INAUDIBLE) .
10 UNIDENTIFIED SPEAKER: But your
11 earlier statement that the stuff was
12 falling out the top and containers were
13 open and totally (INAUDIBLE) totally sealed
14 at the top. I wasn't --
15 MR. SAUNDERS: They were just --if
16 your concern is about falling out --
17 MS. MARKS: That is my concern that
18 some of it will be falling out as you put
19 it in and maybe it isn't all carried away.
20 MR. ROBINSON: We have a lot of
21 experience in dealing with contamination,
22 removing radiological contamination waste.
23 we just completed a very large excavation
24 in an Essex County site and a number of
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l homes in Orange, New Jersey and Montclair.
2 That material is transported by truck and
3 sent out to Utah. Trucks moving it every
4 day, moving it for four or five years now.
5 MS. MARKS: I wasn't insinuating that
6 there was --
7 MR. ROBINSON: The material is not
8 hazardous waste; it's radioactive waste.
9 MR. GRABOWSKI: Something should be
10 on those trailers. In my neighborhood
11 where I have a store, kids are jumping that
12 fence and playing in that area. Now why
13 shouldn't that be marked off as hazardous
14 waste?
15 MR. SAUNDERS: Well, as I said
16 before, I hope you're calling the police
17 when children are there. The (INAUDIBLE)
18 site you saw with contamination is under
19 gravel and dirt. There's a fence. In
20 order to get into those trailers
21 (INAUDIBLE) to get into that property.
22 MR. GRABOWSKI: Why don't you have
23 signs up?
24 MR. SAUNDERS: The other issue is,
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i depending on the type of radiation you
2 have, it depends on how you placard it. At
3 that level there isn't an appropriate
4 placard. It's too low.
5 MR. FELLMAN: The labeling on the
6 container for this type of waste is
7 outlined in the Department of
8 Transportation regulations. And the levels
9 are such, or this type of waste is such,
10 that it doesn't warrant the type of label,
11 I guess, that you're looking for.
12 MR. GRABOWSKI: How high is that
13 rating on that site?
14 MR. FELLMAN: The rating?
15 MR. GRABOWSKI: Reading; reading.
16 The reading that you're getting.
17 MR. FELLMAN: I haven't scanned those
18 containers so I couldn't answer that other
19 than to say it's clearly elevated because
20 if it wasn't, it would not have been
21 removed from the park. So there's
22 something there. How high? I don't know.
23 MR. EVANGELISTA: You're not talking
24 about placards that should be on them for
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1 shipment, you essentially just want some
2 warning signs for kids.
3 MR. GRABOWSKI: You know, like Bob
4 said, call the police. I work too and my
5 wife can't constantly sit by the window and
6 watch.
7 MR. ROBINSON: What we'll do is,
8 we'll arrange for signs to be placed on the
9 fence.
10 MR. SAUNDERS: This is the problem we
11 have. If we speak to X amount of neighbors
12 and try to accommodate the wishes of most
13 neighbors in this township, that's the
14 problem. We're never going to make
15 everybody happy. Some people want signs.
16 The vast majority of people indicate to me,
17 if we don't have to have signs, they really
18 appreciate it.
19 MR. FKLLMAN: They want it to be
20 invisible. They don't want signs right
21 next to their homes.
22 MR. GRABOWSKI: I think it's Stupid.
23 MR. FELLMAN: And you're entitled to
24 that opinion. But this is what people are
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1 telling Bob and. other folks.
2 MR. GRABOWSKI: They're afraid
3 because if they want to sell their house,
4 nobody is going to buy it.
5 MR. SAUNDERS: It's going to be
6 remediated as soon as possible. It's also
7 going to be certified clean. And nothing
8 will be done on there until that's done.
9 We can say confidently for the neighbors of
10 the Popcorn Factory, that site is safe for
11 you and everyone else. And we say that
12 with full confidence. The items that are
13 staged there will be removed. Those types
14 of things are there to make sure that the
15 residents, children and everyone else are
16 safe. We're not going to tell you things
17 that we don't know as exist today.
18 UNIDENTIFIED SPEAKER: Mike sees
19 these people in the suits, but they're
20 dealing with the removal every day. But if
21 you go and you walk, you're not going to
22 get that type of exposure. Is that what
23 you're concerned about, Mike?
24 MR. GRABOWSKI: No. The children in
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l the neighborhood. I live catty-corner from
2 that. I don't know if my property is
3 contaminated or not.
4 MR. SAUNDERS: In order for the kids
5 to get into the containers --
6 MR. GRABOWSKI: They're not getting
7 into the containers. They're covered. But
8 they're getting into the property
9 (INAUDIBLE) before the fence (INAUDIBLE).
10 MR. SAUNDERS: I think even if you
11 patrolled it (INAUDIBLE). It's an example
12 of overkill. The City has done more to
13 protect our residents than (INAUDIBLE).
14 Required us to put more gravel at the site,
15 to be more protective of our residents. So
16 even if a child is standing (INAUDIBLE),
17 it's somewhat misleading that the
18 contamination is underneath.
19 So again, as Alan said, (INAUDIBLE)
20 it's, like, months and months and months of
21 not moving it. We used overkill and are
22 protective of that site. And I appreciate
23 your concerns. And they're valid. And
24 we've taken --if they tell us this is good
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i enough, we go a few more steps.
2 UNIDENTIFIED SPEAKER: As far as
3 getting from point A to point B, I live in
4 the (INAUDIBLE) hundred block of Somerset
5 Street. And as a truck would back in, they
6 would put a tarp down. The truck would
7 back over top of this tarp, seal it, and
8 actually broom the truck off and everything
9 around those tires was broomed off. I
10 thought it was total overkill protection
11 for us, the residents of the City, and I
12 loved it. Before that truck moved, three
13 or four guys would walk around it and sweep
14 every tire, every little nook and cranny.
15 It was amazing how they did it.
16 MR. EVANGELISTA: In addition to
17 that, getting back to the containers on the
18 Popcorn property, not only are they covered
19 with the locked covers, but inside the
20 material is covered with clean fill. So
21 even if someone opens the cover and gets in
22 there, they're jumping onto --
23 MR. GRABOWSKI: I didn't know you had
24 clean fill on top of that.
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1 MR. BVANGELISTA: So there's that
2 additional protective measure that's been
3 taken. Like the gentleman said, everything
4 is done with overkill.
5 MR. SAUNDERS: They are metal too.
The tops are sealed shut metal units, not
7 open containers. There are several things
8 they would have to do to get to the
9 problem.
10 MS. CERVANTES-GROSS: Any other
11 comments or questions? Thank you for
12 coming and, again, you have until next
13 Wednesday if you have any other questions
14 or comments. And you may have seen on the
15 board outside here, there is additional
16 information on the individual properties in
17 the areas. Thank you.
j_g ********
19 MS. CERVANTES-GROSS: Can we go back
20 on the record for some additional comments,
21 please?
22 MS. GRAHAM: Theresa Graham and Ed
23 Gorman, Chairman of the Community
24 Playground, Port Nassau, that will be
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l placed at Johnson Boulevard right in the
2 middle of the jogging track. And our
3 concerns are the safety of any contaminants
4 on there. We were told that an overall was
5 done of the top of it and there doesn't
6 appear to be any right there.
7 And our concern is that we'll put
8 $110,000 into the building of this
9 playground and then come April 7th or nth
10 we'll have it finished, and then what
11 happens to it if later on you find
12 something there. We want to be assured
13 that our property, if anything has to be
14 done, will be taken care of by DEP, I
15 guess.
16 MR. GORMAN: By somebody.
17 MR. GRAHAM: By somebody. Because a
18 lot of time and effort on the part of this
19 community as a whole has gone into this
20 project. And we want to safeguard the
21 children of the community above all.
22 MR. GORMAN: Is there any fast
23 tracking or something they could test
24 before we actually build it on April 7?
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1 MS. GRAHAM: Is there any kind of a
2 boring that they could come down and do to
3 totally assure us? Because we're already
4 contracted in for the beginning of this
5 project on the 7th. Thank you.
g ********
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7
1 CERTIFICATE
2 STATE OF NEW JERSEY
3 I. LINDA A. BURNS, Shorthand Reporter and Notary
4 Public of the state of New Jersey, do hereby certify
5 that I reported the public hearing in the
6 above-captioned matter and that the foregoing is a
true and correct transcript of the stenographic notes
8 of testimony taken by me in the above-captioned
9 matter.
10 I fu*ther certify that I am not an
11 attorney or counsel for any of the parties, nor a
12
13
14 in the action.
relative or employee of any attorney or counsel
connected with the action, nor financially interested
15
16
17
IS
19
20
21
22
Linda A. Burns
23
24 Dated: March 4, 1999
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Linda A. Burns
Notary Public
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Appendix D
Written Comments
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3-33-1999 3 t 43PM
t-WUM UOJUL
iex
t r r IKS.
RESOLUTION
#R-OS« -99
I
A RESOLUTION ENDORSING THE)ENVIRONMENTAL
PROTECTION AGENCY'S PLAN FOR CLEANUP OF RAD1OLOG1CALLY
CONTAMINATED PROPERTIES
WHEREAS, the United Stales Environmcnto
Protcaion Agency has investigated
various sites in Gloucester City and Camden in relationship to the Wclsbach/Oencnl Mantle
Supcrfund Contamination She, including the four areas ir'Glouecstcr Chy listed below:
a) Study Area Two - an industrial zoncJ property along the Delaware Rjver.
formerly occupied by the Wdsbach Corporation and a residential area to the
immediate east: I
b) Study Area Three - residential and recreational properties, including the Johnson
Boulevard Land Preserve; I
c) Study Area Five - residential properees, vacant land properties, and two
municipal parks near Temple Avenue and the South Branch of Newton Creek,
d) Study Area Six - vacant lots in a residential zoned area of Gloucester City, and
WHEREAS, the E.P.A. s investigations have
locations to contain soil contaminated to van ing degrees
which are associated with waste materials generated in
place at former Welsbach Gas Mantle facilities; and
shoun properties in the above stated
with thorium, radium and uranium.
the manufacturing activities that took
WHEREAS, the E.P.A. has proposed the follov
ing alternatives to address the findings
stated above:
a) No action;
b) Installation of engineering controls;
c) Excavation and off-site disposal of contaminated materials; and
WHEREAS, the locations of this contamination
and recreational areas, and the COST of excavation
$31,912.120.00, shall be bom entirely by the United State
re almost entirely located in residential
4id off-site disposal, estimated to be
Environmental Protection Agency.
NOW, THEREFORE, BE IT RESOLVED th*! the Mayor and Common Council of
Gloucester City do hereby endorse the excavation and oflVsite disposal of contaminated materials
from the Welsbach/General Mantle Superfund Contanination Sites which are located in
Gloucester City
Robert T. Gorman. Mayor ,
Passed by die Mayor and Common Council of Gloucester
y of Map*, 1999
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3
U.S. Environmental Protection Agency's (EPA's)
4
Proposed Plan for Cleanup of Superfund Sites
5
Public Hearing
6
7
February 24, 1998
8 -
9 Public Meeting of the U.S. Environmental
10 Protection Agency (EPA) held at the Camden County
11 Municipal Utilities Authority Auditorium, Camden,
12 New Jersey, before Linda A. Burns, Shorthand Reporter
13 and Notary Public of the State of New Jersey, on the
14 above date, commencing at 7:00 p.m.
15
16
17
18
19
20
21
22
23
24
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1 EPA MEMBERS IN ATTENDANCE:
2 Richard J. Robinson, Project Manager
Pac Evangelista, Team Leader
3 Mary Helen Cervantes-Gross, Chief, Public Outreach Branch
4 MALCOLM PIRNIE REPRESENTATIVES IN ATTENDANCE:
5 Robert Kerbel, Associate
Alan Pellman
6
ATSDR REPRESENTATIVES IN ATTENDANCE:
7
Arthur Block, Sr. Regional Representative
8
ALSO PRESENT:
9
Fred Mumford, NJDEP
10
11 INDEX
Witness Page
12
Donna Maggio(ph) (INAUDIBLE) 41,47
13 Olga Pullman(ph) 44
14
EXHIBITS
15
(There were no exhibits marked at this time.)
16
17
18
19
20
21
22
23
24
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l MS. CERVANTES-GROSS: We're going to
2 go ahead and start. I just wanted to thank
3 everyone one coming here tonight and we'11
4 be giving you several presentations
5 tonight. My name is Mary Helen
6 Cervantes-Gross. I'm with the EPA and I'm
7 here actually, standing in temporarily, for
8 Natalie Loney whom most of you know, she
9 just had a baby boy on February 14 and she
10 will be back out here in the future to work
11 with you again.
12 But with us here tonight is
13 Rick Robinson, Project Manager for the
14 Welsbach General Gas Mantle Superfund site;
15 Pat Evangelista, who is the team leader
16 with the EPA overseeing various types of
17 radiation sites and other types of sites
18 throughout the region. Here as well is
19 Arthur Block with ATSDR. He works with the
20 EPA1s Agency for Toxic Substances and
21 Disease Registry, as well as a consultation
22 business on health-related issues. Here
23 tonight also is Alan Fellman as well as
24 Bob Kerbel, both with Malcolm Pirnie who
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l are contractors for EPA working on both
2 investigation of the sites and put together
3 much of the information that you will hear
4 tonight.
5 And I just wanted to remind everyone
6 that what you say tonight, whatever
7 questions you have, what comments you have
8 --we have Linda Burns here who is a
9 stenographer and who is officially taking
10 down all of your questions and comments and
11 they will go into the official record. And
12 at the end of the public comment period,
13 which ends next Wednesday, March the 3rd,
14 we will review all of the comments chat we
15 have received both here tonight and at the
16 meeting that we had last night in
17 Gloucester City, we will also review any
18 written comments that we have, and we will
19 prepare a responsiveness document answering
20 or responding to any comments that you
21 have. As well, all of these comments will
22 be looked at before we make a final
23 decision, because that's what we do with a
24 Superfund program. Throughout the program
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l we come out to the community before we make
2 final decisions in an attempt to answer any
3 questions or concerns you have, so that we
4 are sure to address those in its final
5 decision.
6 So with that I will turn it over to
7 Pat who will talk to you a little bit about
8 the Superfund program in general.
9 MR. EVANGELISTA: Welcome. Before I
10 get started in my part of the meeting this
11 evening, I'd like to introduce to you, as
12 well, Fred Mumford who is here representing
13 the New Jersey Department of Environmental
14 Protection. What I'd like to do in getting
15 the meeting started is to just talk to you
16 a little bit about the Superfund process
17 and how it works and just to familiarize
18 you or remind you of how it works.
19 Back in 1980 Congress handed the EPA
20 a law known as the Comprehensive
21 Environmental Response and Liability Act
22 and amended it five or six years later. So
23 it's what we're working with at this site
24 today.
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l It starts out with what's known as
2 discovery. Discover is the part of the
3 process where we are actually made known of
4 the site and it warrants us to follow up
5 and perform what's known as a preliminary
6 assessment or site inspection where we
7 gather information that we need to do
8 what's known as a hazard ranking. In
9 performing the ranking we generate what's
10 known as a hazard ranking score. And if
11 that score is or exceeds 28.5, the site
12 ends up on what's known as the National
13 Priorities List.
14 This allows us as EPA to perform
15 what's next in the process and this is
16 known as a remedy investigation feasibility
17 study. That's what we would call the more
18 detailed investigation of the site to
19 gather all of the information that we need
20 about that site to generate alternatives
21 that we would look into for remediating the
22 problem or cleaning up the problem. And
23 those alternatives are evaluated in the
24 feasibility study part of that remedial
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1 investigation.
2 The alternatives are then evaluated
3 according to certain criteria and, you
4 know, at the end of that process we would
5 recommend a cleanup alternative that we
6 would put before you, the public, and
7 concerned citizens. And that part of the
8 process is what's known as the proposed
9 plan.
10 The proposed plan is what we
11 presented as of February l and is subject
12 to your review and comment. And that's
13 part of the reason why we're here tonight.
14 As a result of the public comment
15 period, we generate what's known as a
16 transcript, hence our stenographer here.
17 And that transcript is added to the record
18 of decision which formalizes the agency's
19 decision, your comments inclusive, of
20 course.
21 After that we enter into what's known
22 as remedial design. We actually design the
23 nuts and bolts of the remedy that the
24 agency has selected.
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i From there we enter into the cleanup
2 phase and ultimately we certify it as clean
3 and acceptable for future use. And we
4 delete the site from the National
#
5 Priorities List.
6 That's basically the process. If you
7 have any questions I'd be happy to answer
8 them for you later. Thank you.
9 MR. ROBINSON: I'll just go into a
10 little bit of background on the site. As
11 most of you know the site is located both
12 in Camden ~nd in Gloucester City. And it
13 comprises the two former gas mantle
14 manufacturing facilities. It also includes
15 residential properties, commercial
16 properties, municipal park lands in
17 Gloucester City and vacant land.
18 As part of the State's investigation
19 early on, they divided the sites into study
20 areas. And for the purposes of our
21 investigation we followed those study
22 areas. And the first study area is where
23 we are right now in Camden around the
24 General G=.= Mantle facility and the
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1 surrounding properties. Study Area Two is
2 Gloucester City, the former Welsbach
3 facility. Study Area Three is also in
4 Gloucester City. It comprises residential
5 properties and land preserve. Study Area
6 Four, some residential properties in the
7 Fairview section of Camden. And Study Area
8 Five, residential properties including
9 municipal parks in Gloucester City. And
10 Study Area Six is also some vacant land
11 properties in Gloucester City.
12 Again, Study Area One is around the
13 General Gas Mantle facility here in
14 Camden. And this is a photograph of the
15 area and the General Gas Mantle building is
16 highlighted. There's a photograph of the
17 famous General Gas Mantle building.
18 Study Area Two is the former Welsbach
19 facility, it's now owned by Holt. The
20 Gloucester terminal is there on Kings
21 Street. And the Armstrong building is the
22 last remaining building from Welsbach's
23 operation.
24 Study Area Three is Gloucester City
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1 and it comprises the swim club area and
2 ohnson B .evard Land Preserve.
3 Study Area Four is in the Fair-view
4 section of Catnden. And we only had a few
5 properties in that area that had some
6 elevated gamma radiation levels.
7 Study Area Five is Gloucester City
8 and comprises a dump area off of Temple
9 Avenue and municipal park lands.
10 Study Area Six is a newer identified
11 area in Gloucester City. We call it the
12 Popcorn Factory.
13 Site history: In about 1885 a
14 Dr. Carl Auer von Welsbach invented the
15 process of using thorium to manufacture gas
16 mantles. And just to let you know, gas
17 mantles are the material that's used for
18 camping lanterns or in the street lights.
19 Right there is a gas mantle (indicating).
20 And what they did is they took a sock of
21 material and dipped it in a solution of
22 thorium. And when the sock dried and they
23 lit it, it produced a very brilliant white
24 light. And as a result the thorium is
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1 radioactive. And that's what we're here to
2 clean up.
3 In the 1890s Welsbach started
4 manufacturing the gas mantle and by the
5 turn of the century they were the world's
6 largest manufacturer of them. And in the
7 early '40s they went out of business when
8 the electric light put gas lighting out of
9 business basically.
10 Very little is known about General
11 Gas Mantle. We know they operated from
12 around 1912 to 1941. We just know that
13 they probably used radium and thorium.
14 They didn't manufacture -- they didn't
15 process any ores. They just bought the
16 ores -- bought the refined radium and
17 thorium. And they manufactured gas
18 mantles.
19 What we've termed all of the other
20 properties that are associated with the
21 radiological contamination here, besides
22 the Welsbach facility and the General Gas
23 Mantle facility, we call them vicinity
24 properties. And they were contaminated
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1 either from disposal of ore tailings from
2 Welsbach, or building debris from when they
3 knocked some building down, or when they
4 built the bridge back in the early '50s, or
5 from workers bringing contamination home
6 with them.
7 Previous investigations: The site
8 was initially identified in 1980 as a
9 potential radiation site during search of
10 the U.S. Radium site in Orange, New
11 Jersey. And in 1981 EPA sponsored an area
12 fly-over to search for gamma radiation.
13 And a helicopter came over the area looking
14 for excess gamma radiation levels.
15 In the mid-1980s the State went out
16 conducting preliminary screenings in the
17 area. And in the early 1990s they
18 investigated over a thousand properties
19 throughout Camden and the Gloucester City
20 area. Based on those results they
21 identified about 20 properties that they
22 felt that needed more immediate action.
23 And as a result they installed some
24 radon/thoron ventilation systems in some
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l homes. They put concrete or steel sheeting
2 down to shield for gamma radiation. And
3 they purchased one property in Gloucester
4 City and relocated the resident.
5 Also, in 1992 they removed
6 radioactive materials from the old General
7 Gas Mantle building. They relocated the
8 occupant at the time, Ste-Lar Textiles.
9 And they sealed up the building to restrict
10 access.
ll The State investigation: They base
12 their contamination levels on surface
13 exposure rates, indoor radon sampling and
14 limited surface soil samples. However,
15 they didn't perform any subsurface
16 sampling. They made no estimate on the
17 amount or extent of contamination. And
18 they were just looking to address any of
19 the immediate potential health concerns at
20 the time.
21 BPA's involvement at the site, again,
22 when the site was placed or took the lead
23 --we took the lead on the site when the
24 site was placed on the Superfund list back
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1 in June of 1996. Currently, the General
2 Gas Mantle facility is inactive and boarded
3 shut. Welsbach is an active facility, now
4 owned by Holt. And the vicinity
5 properties, any immediate health treats
6 were either addressed through interim
7 measures performed by the State or by EPA
8 removal action last December in the park in
9 Gloucester City.
10 I'll now turn it over to Alan Fellman
11 from Malcolm Pirnie and he will give you a
12 real brief overview on radiation.
13 MR. FELLMAN: I just want to spend a
14 few minutes going over a couple of the
15 terms regarding radioactivity that will
16 hopefully make it a little easier for you
17 to understand.
18 Some of the things we're saying about
19 the conditions of these properties, when we
20 talk about radioactivity we're not talking
21 about a typical product that we measure in
22 pounds or address in terms of mass. We're
23 more concerned with the amount or the rate
24 at which the radioactive atoms are
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1 decaying. And the unit that we use to
2 describe that is called pico Curies, which
3 we abbreviate pCi.
4 Now when we have radioactivity in
5 soil, we express the amount as
6 concentration in pico Curies per gram of
7 soil. And if we're talking about
8 radioactivity in water or liquid, then we
9 would express it as pico Curies per liter,
10 pCi/1.
11 Again, now this is only indicative of
12 how much there is. It doesn't really
13 address the dose or the risk. To do that
14 we need some other terms. The dose of
15 radiation is expressed in the unit known as
16 millirems. And what we are expressing when
17 we quantify millirems, that's a measure of
18 how much energy, which is released from the
19 radioactive emissions, is transferred from
20 those atoms into an absorbing media such as
21 the human body. The amount of energy
22 that's deposited is used to determine what
23 the dose is and, of course, the higher the
24 dose the higher the risk.
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l There are several different types of
2 radioactivity that are emitted from
3 thorium, uranium, radium, radionuclides
4 that are associated with this waste
5 material. Alpha particles are the heaviest
6 of these. They have mass. They travel
7 very slowly. And they can be shielded by
8 something as thin as a piece of paper.
9 Beta particles are intermediate in
10 penetrating ability. They can be
11 transferred through a piece of paper but
12 are more likely to be stopped by a piece of
13 wood.
14 On the other hand, gamma radiation,
15 also known as photons, have no mass.
16 They're simply packets of energy. And they
17 are also sometimes referred to as
16 penetrating radiation. These are things
19 that are more likely to get through paper
20 or wood. And it takes something denser or
21 thicker to shield them, such as concrete or
22 . lead.
2:- The problem that we have here for the
24 most part has to do with the radioactive
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1 residue being present in dirt. And when
2 the dirt gets moved from the Welsbach or
3 General Gas Mantle facility onto an
4 adjacent or vicinity property, it can be
5 put in the ground either adjacent to a
6 structure or in some cases beneath a
7 structure. When the radioactivity decays
8 several of the -- most of the radionuclides
9 are solid. They don't travel; they don't
10 really go anywhere. They stay where they
11 are placed. But at one point in the
12 process the resultant atom that's formed is
13 a gas, radon. And if the radon gas is
14 formed in soil that's either up against the
15 side of a building or beneath the building,
16 now you've got something that's mobile and
17 can emanate from the soil into the building
18 resulting in a potential medical threat.
19 For people who don't have that
20 problem but where there's this type of
21 radioactivity associated with the soils
22 some distance from a structure, in that
23 case the potential exposure to the gamma
24 radiation that's emitted from the ground is
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l part of the radiation dose to a person
2 occupying that area.
3 Also, the next few minutes will be
4 spent going over the field investigations
5 that Malcolm Pirnie has performed for EPA
6 over the last couple of years and
7 Bob Kerbel will be talking about that.
8 MR. KERBEL: I know some of you were
9 here at the meeting we had a year ago, but
10 I'll just go over in the nutshell again the
11 type of work we've been doing in the two
12 communities. We did investigations at the
13 former Welsbach facility and the General
14 Gas Mantle facility, they are industrial
15 facilities. Now anything beyond the border
16 of those two facilities we term vicinity
17 properties. The term residential property,
18 that's categorized into the vicinity
19 property category.
20 Now, if there's anything good from
21 our standpoint as investigators, it's that
22 this material is easy to detect. We have
23 meters that we walk over the property and
24 it's easy to detect if there's an elevated
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l radiation level. So we did that on all of
2 the properties. And then if we found an
3 elevated radiation level we would go back
4 and take a radiological sample and send it
5 to the laboratory to confirm that it was
6 indeed due to thorium or radium.
7 On the industrial sites, given the
8 industrial nature of the property, we also
9 checked for chemical contaminants. One of
10 the focuses of our RI/FS report that we're
11 putting together is to come up with a cost
12 of how much it would cost to clean this
13 up. So we need a volume. So if there was
14 contamination, we had to know how deep the
15 contamination was. So we put in shallow or
16 deep borings, depending where we were. If
17 you notice, there's not a deep check mark
18 on the soil borings for the vicinity
19 properties. That's only because, in
20 general, the contamination was really on
21 the surface of the property. As Alan was
22 telling you, radon gas can get in a home so
23 we check for radon in any structure that
24 might have been on a property. And we also
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1 did air .-.a/beta measurements for structural
2 materia^ sampling. Because in some cases,
3 especially on the industrial properties,
4 the contamination wasn't always associated
5 with soil but the building material
6 itself.
7 Let me work you through this so you
8 can kind of understand the process. This
9 is an old picture of the Welsbach facility
10 which existed about, you know, the early
11 part of the century. Just to give you some
12 bearings here because I know it's not a
13 good picture. The Delaware River is on
14 top. You can see the smoke stack of that
15 facility. Kings Street is on the bottom.
16 This is Gloucester City. But if you can
17 imagine, they made these gas mantles at the
18 beginning of the century. The hazards
19 associated with any materials having
20 radioactivity associated with it really
21 weren't known at that time. Things like
22 X-rays were just being discovered and
23 nuclear power -- things like that were
24 decades in the future yet to come.
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l But as years went by and in the past
2 couple of decades, we became aware of the
3 hazards that could be associated with any
4 radioactive materials. And someone
5 prudently said we should go back to all of
6 these facilities that operated in the early
7 part of the century and check to see if
8 there were, indeed, some radioactive
9 materials associated with those
10 properties.
11 So if you could imagine, you had a
12 facility like this (indicating) and you had
13 this mound, basically, of sandy-like dirt
14 that was there and they processed the
15 thorium out of that sand. So what happened
16 is years later we go back to that property
17 to see if we can find anything. Of course,
18 the facility is gone by now. But the
19 circle showing where the facility used to
20 be, it's actually a large 52-acre sprawl at
21 this cargo area.
22 But if you could imagine, let's say,
23 if you had these large buildings, they
24 probably had large basements associated
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l with them. And they knocked down the
2 building, you would assume, and maybe put
3 them in those large basements and paved
4 tover it. So the first thing we would do is
5 go over this entire property doing the
6 surface exposure rate we talked about to
7 look for elevated levels of gamma
8 radiation. And we did that over the course
9 of several weeks. And then we take that
10 information back with us to our office and
ll we have computer programs where we can look
12 at the data.
13 And we go back now, this is a bird's
14 eye view looking down at the facility, and
15 all the different colors are where we do
16 have elevated levels of radiation. So
17 clearly there was something and is
18 something on that property. We go back to
19 locations xike this and take soil samples
20 to see that it is thorium causing the
21 elevated levels, and it is. And we do the
22 borings to see how deep it is to come up
23 with a volume. So that's really what goes
24 on at the Welsbach facility.
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1 To jump a little closer to home here
2 in Camden, to tell you a little bit about
3 what we've done. This is the General Gas
4 Mantle facility. And as Rick told you,
5 it's boarded up now. And as Alan alluded
6 to, this material gives off radon gas. But
7 there's no ventilation in this building
8 because the windows are all boarded up. So
9 when we go in there to work in that
10 building, there are elevated levels of
11 radon levels. There is soil that is
12 contaminated under the building and
13 adjacent to the building. And it does come
14 out somewhat onto South Fourth Street,
15 along with the sidewalk and into the street
16 somewhat.
17 So that will eventually need to be
18 removed or remedied as Rick will talk
19 about. The building is vacant. There are
20 wood floors. Those woods floors as well
21 have some contamination associated with
22 it. So if this building were to be
23 demolished there may be a need to remove
24 those floors before any demolition takes
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l place.
2 I just wanted to touch on this now
3 but Alan will come back and talk a little
4 bit more about risk. But when we do work
5 on properties like this, it's not like
6 we're all dressed up in special equipment.
7 We wear our regular work clothes and we
8 walk throughout the building with the
9 meters. A real hazard that's associated
10 with it, from our standpoint, is if we have
11 somebody fall through a floor while we're
12 in the building rather than the radiation
13 problem itself. But Alan will talk a
14 little bit more about risk.
15 We'll talk about the vicinity
16 properties now. One of the problems is
17 there is such a large geographical area
18 associated with this site where
19 contamination could end up. If we were to
20 have gone throughout the whole community
21 and start from scratch, it would have taken
22 us years to do this. But fortunately the
23 State and Fred's group, they were here
24 previously and they went through over a
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1 thousand properties and investigated those
2 properties.
3 Now, when we started this project we
4 didn't want to go out and reinvestigate all
5 of these properties. We wanted to use the
6 State's data. But we had to be sure we
7 could use that data. So we went to 20
8 properties and we compared our data to the
9 State's data. And we agreed that we can
10 use the State's data to somewhat categorize
11 these properties.
12 We went through all of the State's
13 data and we categorized the properties
14 something like this. Ballpark thousand
15 properties that the State went to,
16 approximately half, 449, we don't see any
17 evidence that there's contamination
18 associated with those properties. Then we
19 have the category we call suspect
20 properties. It's a pretty large grey area
21 for us. What that category means is that
22 we're not 100 percent sure that they're
23 clean. We're not 100 percent sure that
24 they may be contaminated either. But we do
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l want to go back and test those properties.
2 If a property was simply adjacent to
3 contaminated property, we call that a
4 suspect property and we put it in this
5 category. If it had an elevated radon
6 level -- many homes in New Jersey have
7 elevated radon. But in this case we tend
8 to ask ourselves, is that due to normal
9 radiation associated with the soil or is it
10 due to the Welsbach facility. We're not
11 sure right now so we want to go back and
12 check.
13 There's radiation all over. It's a
14 natural thing and it ranges. There's an
15 average. It's high in locations and low in
16 others. In some cases you could live in a
17 brick home and the levels could be higher
18 than you normally expect. But we would put
19 it in this category. So there are 585
20 properties that we would want to go back to
21 now and kind of do additional testing
22 eventually and either move them over to the
23 clean category or if we needed to move them
24 to the contaminated properties category.
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l And chen finally there's a category
2 where we have potentially contaminated --
3 they are properties that, based on the data
4 we have available, the evidence suggests
5 that there is contamination on those
6 properties. And we used our investigation
7 from the 20 we went to to come up with a
8 volume of materials to estimate a cleanup
9 cost associated with the project. And Rick
10 will come back and talk a little bit more
11 about that in a couple of minutes, right
12 after Alan talks a little bit more about
13 health risks.
14 MR. FELLMAN: Before you can really
15 get a handle on the risk from exposure to
16 radiation, it's helpful, I think, to
17 understand that we live on a radioactive
18 planet. And as a result we're constantly
19 being exposed to natural sources of
20 background radiation. The items that are
21 listed on this table break down the
22 components of background radiation.
23 we are radiated from the atmosphere.
24 We receive radiation from natural levels of
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1 radionuclide in soil and rock, many of the
2 same radionuclide that we have _n the waste
3 stream at the Welsbach and General Gas
4 Mantle facilities; uranium, thorium,
5 radium.
6 Inhaled radioactivity, that 200
7 milligrams per year, is the average dose in
8 North America from radon gas. Any time you
9 put four walls and a ceiling together,
10 you're going to get some level of indoor
11 radon that's going to deliver a dose. And
12 the average radon level is about one to one
13 and a half pico Curies per liter there, and
14 that's going to give you your 200
15 milligrams.
16 Internal emitters is referring to the
17 various radionuclide that we store in our
18 body tissues. As a reflection of the fact
19 that there's radioactivity naturally in
20 soil, then when we grow fruit and
21 vegetables and all sorts of products, some
22 of that radioactivity is taken up and some
23 of it is ingested. There's natural
24 potassium which is an essential
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1 micronutrient. We ingest potassium in lots
2 of different products. A small fraction of
3 that potassium is radioactive.
4 So we carry around these
5 radionuclide. We ingest them every day.
6 We excrete them every day. And as a result
7 of their being in our bodies, we're exposed
8 to a dose of about 40 millirem per year.
9 There's also a whole lot of
10 radioactivity in lots of different types of
11 consumer products. And as you read through
12 some of these, you can see that there's
13 quite a range. And I brought a couple of
14 items that add to those.
15 This is Morton salt substitute. If
16 you need to keep your sodium intake to a
17 minimum because of high blood pressure or a
18 cardiac problem, your doctor may suggest
19 that you use potassium chloride instead of
20 sodium chloride. And as I just said, some
21 potassium is radioactive. And there's no
22 way to separate out the radioactive
23 potassium from the nonradioactive
24 potassium.
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1 This instrument is known as a pancake
2 detector. And as you can hear, from
3 natural sources it has a very low
4 efficiency, you'll get sporadic clicks.
5 When I hold the salt substitute up, you get
6 a slightly positive response and it's easy
7 to hear the difference. Again, that's
8 natural potassium in the salt substitute
9 that the detector can see.
10 Here is a smoke detector. Everybody
11 should have these in their home. And one
12 of the components of the smoke detector is
13 one micro Curies of Americium 241, a
14 man-made radionuclide. And when I hold
15 this meter up to the source, again you can
16 hear the instrument respond.
17 This is a piece of Piestawear(ph).
18 It's made in the Southwest, covered with a
19 glaze known as yellow cake. And that glaze
20 has a lot of natural uranium in it.
21 There's a lot of radioactivity here. There
22 are people who eat off of these and you'll
23 find these in antique shops, at antique
24 shows all around the country. So I can
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l either leave that here and radiate my
2 colleagues or move it back out of range a
3 little bit.
4 We're concerned about radiation dose
5 because radiation is a known carcinogen.
6 That is the only health affect that we need
7 concern ourselves with. There are no acute
8 short-term health p-rblems associated with
9 exposure to radiation with the exception of
10 very, very high doses which are not
11 possible from environmental issues such as
12 what we have here.
13 So we're worried about cancer, we
14 know that people who have been exposed to
15 very high levels of radioactivity in those
16 populations, there is most definitely an
17 increase in the incidence of cancer. When
18 we set public health policy in this
19 country, we assume that there is a risk of
20 cancer when we're exposed to any dose of a
21 carcinogen, no matter how small. Now, the
22 fact of the matter is, when we look at the
23 scientific data, we don't really know if
24 that's true or not.
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l Because what we have here is, again,
2 what's known as a dose response curve or
3 dose response line. As the dose increases
4 -- so up here in this range (indicating)
5 we're looking at high doses such as the
6 Japanese who survived the atomic weapons
7 blast, groups of patients who were radiated
8 for various ailments in the '30s or '40s
9 before medical science realized that that
10 wasn't the way to go. The radium dial
11 painters who were basically ingesting
12 radium while they painted watch dials
13 during the 1920s. Several of them died
14 from acute illnesses but most of them
15 survived and went on to live 20, 30, 40, 50
16 years. And in that group there was
17 elevated cancers. So these are groups who
18 got very high doses and we know that the
19 incidence or cancer or the health effect or
20 risk was elevated.
21 Now we get down to the lower end of
22 the curve where I showed you, just a few
23 minutes ago, background radiation, that we
24 all get a couple hundred millirems per
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1 year. So now we're down in this area of
2 the curve (indicating). And now we've got
3 this type of a waste stream where there may
4 be additional exposure on the magnitude
5 similar to what we're getting from
6 background. And what do we know about
7 that?
8 Well, we don't have any scientific
9 data that would show that people who are
10 exposed to these levels are actually going
ll to suffer increased numbers of cancer. We
12 don't know that. The scientific studies or
13 physical tests are not powerful enough to
14 discern that when we're talking about a
15 disease or group of disease that is
16 afflicting one out of every four Americans
17 to begin with. So you just can't measure
18 it at these low levels. This is what we
19 call an area of great uncertainty.
20 However, EPA's policy is to assume
21 that there is some risk at these low
22 levels. And when the risk that we
23 calculate based on the data that we
24 generate during our studies, when that is
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l placed in a risk assessment: model and it
2 shows us a risk chat's unacceptable
3 relative to the acceptable risk range that
4 EPA has established, EPA can then use that
5 information as the basis to go forward with
6 the cleanup.
7 And now I'11 let Rick talk about
8 cleanup alternatives.
9 MR. ROBINSON: For the Welsbach/
10 General Gas Mantle site we evaluated
11 cleanup alternatives for the three property
12 types we just discussed: The Welsbach
13 facility, the General Gas Mantle facility,
14 and for the vicinity properties. The three
15 alternatives that we looked at were the No
16 Action Alternative; an Engineering Controls
17 Alternative; and Excavation and Off-site
18 Disposal Alternative.
19 As part of the Superfund process, EPA
20 has to look at a cleanup based on a No
21 Action Alternative. What if we did
22 nothing, what would be the result? And
23 based on the risk assessment that Alan just
24 explained a little bit, we found that there
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l was a risk and, therefore, we were going to
2 take an action. And as a result, we're not
3 going to talk about no action anymore.
4 For the vicinity properties, the
5 Engineering Controls Alternative, it would
6 require outdoor gamma shields on 50
7 properties; indoor gamma shields on about
6 20 properties; and radon mitigation systems
9 on about 4 properties. And the excavation
10 and off-site disposal alternative, if any
11 property was found to have contamination
12 above our cleanup levels, we would take the
13 material off site for disposal, dig it up
14 and take it off site.
15 The Welsbach facility, again, the
16 Engineering Controls Alternative, we would
17 put outdoor gamma shields on the property.
18 We would have to have deed restrictions
19 limiting future site work. And we would
20 have to go back every five years to make
21 sure that the remedy would still be
22 effective.
23 For the excavation and off-site
24 disposal alternative for the Welsbach
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1 facility, again, we find the contamination
2 above our cleanup level so we would dig
3 that material up and send it off-site for
4 disposal.
5 For the General Gas Mantle facility,
6 Engineering Controls Alternative would
7 require outdoor gamma shields around the
8 outside of the building. We would have to
9 permanently board-shut the building. He
10 would have to have deed restrictions
11 limiting future access to the site. And we
12 would have to go back every five years to
13 make sure the remedy would still be
14 effective.
15 Then for the General Gas Mantle, the
16 excavation and off-site disposal
17 alternative, we have two operations. The
18 first option is we would take the building
19 down and dispose of the whole building as
20 contaminated material. The second option,
21 Option B is we would first try to
22 decontaminate the building, take the
23 radioactive material out of the building.
24 And that would reduce the volume of
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l materials chat would have to be sent
2 off-site for disposal.
3 The alternatives of the engineering
4 controls, again, just to summarize, we
5 would have to have deed restrictions on the
6 property limiting future site work. The
7 State would have to be responsible for
8 enforcing those restrictions. And we would
9 have to go back every five years to make
10 sure it would still be effective.
11 For the excavation and off-site
12 disposal alternative, all of the
13 contamination above our cleanup standards
14 would be excavated and sent off-site for
15 disposal. And that would result in, again,
16 the contaminated materials being removed
17 from the site. Mobility of the
16 contaminants would be eliminated. And
19 there would be no significant institutional
20 controls remaining on the properties at
21 all. The properties would be safe for
22 future reuse and protective of human health
23 and environment.
24 Just to go over the summary of the
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i costs, for the engineering controls for the
2 vicinity properties would be about a little
3 over $2 million. And for the excavation
4 and off-site disposal on the vicinity
5 properties, just over $13 million dollars.
6 For the former Welsbach facility, the
7 engineering controls just under $6 million
8 dollars. And for the excavation and
9 off-site disposal alternative, eighteen and
10 a half million dollars.
11 For the General Gas Mantle facility,
12 the engineering controls is just under
13 $400,000. And the excavation and just the
14 demolition and disposal alternative option,
15 just over $2 million dollars. And for the
16 decontamination and demolition, just under
17 $2 million dollars.
18 EPA'B preferred remedy action is the
19 excavation and off-site disposal
20 alternative for both the vicinity
21 properties, Welsbach and General Gas Mantle
22 facility. For the General Gas Mantle we
23 have Option B, which is the decontamination
24 of the building prior to demolition. The
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1 total cost of the remedy is just under $34
2 million dollars.
3 Now we go to what do we next, the
4 next steps. The first thing that we're
5 doing right now is respond to public
6 comment. We're here today to take your
7 verbal comments. And also, again we have a
8 public comment period for written comments
9 which ends next Wednesday, March 3. And we
10 invite the public to send in written
11 comments as well as your comments today.
12 Once we receive all of the comments,
13 we select a remedy in a document called a
14 Record of Decision (ROD). And once we sign
15 that ROD, EPA can start the design of the
16 cleanup.
17 Our focus will be first on the
18 residential properties and then we'll go to
19 the commercial and industrial properties.
20 We hope to start the investigations on the
21 suspect properties in the fall, later this
22 year, and also start the design
23 investigations on the potentially
24 contaminated properties this year also.
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1 And we also plan to demolish the General
2 Gas Mantle building as soon as we can,
3 hopefully in one to two years.
4 This actual cleanup on these
5 individual properties we estimate about
6 three to five years from today. We're also
7 in the process right now of conducting a
8 ground water investigation to make sure
9 that none of the contamination from the
10 site is getting into the ground water. And
ll we also have to investigate some wetland
12 areas in Gloucester City around Newton
13 Creek that are next to some of the known
14 contaminated areas.
15
16
17
18
19
20
21
22
23
24
**
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1 MR. ROBINSON: Now we'd like to open
2 the meeting up for some comments and
3 questions.
4 MS. CERVANTES-GROSS: If you have any
5 questions about what we discussed tonight.
6 MR. ROBINSON: Please state your name
7 for the record.
8 DONNA MAGGIO(PH) (INAUDIBLE): I have
9 a question with the houses on Arlington
10 Street. When you say you're going to
11 excavate the back yard, how deep is it
12 going to go and what's going to be done for
13 the people while you're doing this? Hill
14 this pose any problems for people? What
15 are you going to do to protect them?
16 MR. ROBINSON: Right now on Arlington
17 Street we have not done any volume samples
18 or estimate of the depth of contamination
19 on Arlington Street. That will be done in
20 the design phase. We estimate right now,
21 by what we've seen on other properties that
22 are similar to contamination there, the
23 contamination is about one to two feet.
24 Generally we try to work around the
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i residents and make sure that they're not
2 severely impacted by the work.
3 DONNA MAGGIO: This doesn't pose any
4 sort of a problem, digging up?
5 MR. ROBINSON: We're going to try to
6 minimize any potential impacts through
7 controls during our construction phase.
8 MR. FELLMAN: The impacts are
9 (INAUDIBLE). They are not health related.
10 DONNA MAGGIO: That's what I'm
11 wondering.
12 MR. FELLMAN: When these things are
13 removed, it's done in a controlled way so
14 that dust is minimized. If necessary, soil
15 is wet before taking it off. Before things
16 are sent out, say, in a truck to travel
17 over public roads, the trucks are scanned
18 and the wheels. This is all done in a very
19 prescribed manner so that contamination is
20 not spread.
21 DONNA MAGGIO: Is there a work plan,
22 a document, yet?
23 MR. ROBINSON: When we go to
24 construction, after we've completed the
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BPA Public Hearing - 2/24/99
1 remedial design, we'll have another meeting
2 prior to the actual demolition or the
3 construction activities. We'll present to
4 you our plan on how we're going to proceed
5 with that phase, the action.
6 MR. BVANGELISTA: We'll intend to
7 make these plans available in repositories
8 for review.
9 DONNA MAGGIO: I have a question as
10 far as the radon in the basements. Are you
11 going to check for radon in the basements?
12 MR. FELLMAN: Well, that's part of
13 the study protocol when we go to any of the
14 suspect properties. The properties that
15 we've been to through the remedial
16 investigation, we scan for gamma radiation
17 indoors and outdoors. We take soil
18 samples, put holes in the ground and take
19 down hole measures, and put radon detectors
20 in the basements and measure for radon.
21 That's typically part of the protocol.
22 The reason why there have been so few
23 properties or structures with elevated
24 radon out of the many properties
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1 investigated here is because most of the
2 contamination, where it exists, is out in
3 the yard somewhere as opposed to being
4 adjacent to or underneath the house. If
5 you have -- like on Arlington Street where
6 that kind of strip of contamination is
7 toward the rear of the property, closer to
8 the alleyway, the radon gas that was formed
9 in that material is emanating up into the
10 outdoor atmosphere as opposed to if that
11 material was underneath the homes emanating
12 up and would be intercepted by a house and
13 get into the basement. That's when you get
14 the higher level or volume of this stuff.
15 MS. PULLMAN(ph): My name is Olga Pullman.
16 I'd like to first of all say, great, BPA
17 has selected the most thorough cleanup
18 alternative of the three products. I think
19 that's very important for the health and
20 safety of the residents and also the future
21 of this neighborhood.
22 I was just wondering, to make it
23 clear in my own mind what you're saying,
24 the level of cleanup is going to be to
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l remove anything contaminated and bring in
2 fresh fill for any empty areas? And it's
3 your position that after that, that land
4 could be used for anything, residential,
5 playgrounds, parks, vegetable gardens, that
6 level of cleanup?
7 MR. ROBINSON: Yes.
8 MS. PULLMAN: Is that definite? The
9 money has been approved for that project?
10 MR. ROBINSON: Before we can actually
11 get any money for a cleanup we have to go
12 through a design. Once we get the design
13 altogether, we'll be going out to request
14 money from EPA headquarters for the
15 project. Until we complete the -- we're
16 still three to five years away from that.
17 As you see from our presentation, there's a
18 lot of things we have to look at to gather
19 information together.
20 MR. EVANGELISTA: I just wanted to
21 add that behind the scenes that's what's
22 known as Record Review Board. And what we
23 did before we identified our preferred
24 alternative and the projected cost estimate
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l is we took the site and all of the
2 information before this Board within EPA
3 which consists of representation throughout
4 the country. And they gave us a nod of
5 approval that they're okay with the costs
6 associated with it. We don't anticipate
7 any problems in funding the project in the
8 anticipated time frame.
9 MS. PULLMAN: In terms of checking
10 property, I happen to notice where the
11 Arlington Street property is located, the
12 General Gas Mantle, you haven't yet checked
13 the properties on the other side that's not
14 shown on the map, kind of adjacent to it
15 heading north. Is that something you're
16 going to include in this investigation?
17 MR. KSRBEL: That sounds like data
18 the State collected, but we didn't in the
19 last year go into these properties.
20 MR. ROBINSON: Those maps were
21 generated or based on information that the
22 State provided to EPA. As part of our
23 investigation and our next phase in the
24 design, we're going to look at the
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EPA Public Hearing - 2/24/99
1 properties adjacent to known contaminated
2 or potentially contaminated properties.
3 And we'11 look at those properties and add
4 them on. In future maps they'll include
5 other properties that the State has not
6 (INAUDIBLE) .
7 DONNA MAGGIO: I just had a question
8 with the time frame. So you think you
9 could demolish the General Gas Mantle
10 within one to three years?
11 MR. ROBINSON: One to two years.
12 DONNA MAGGIO: Prom now?
13 MR. ROBINSON: Yes. We're hoping
14 sooner. As soon as we get the remedy
15 approved the sooner we'll start the process
16 of taking the building down.
17 MS. PULLMAN: What's going to be your
18 next series of steps when you're going to
19 inform the community about what's going
20 on?
21 MR. ROBINSON: Once we select the
22 remedy and the Record of Decision -- and in
23 the Record of Decision will be all your
24 verbal responses today, that's why we have
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1 the court reporter here, and any written
2 comments submitted -- that will be in the
3 responsiveness summary attached to the
4 Record of Decision. Once we sign the
5 Record of Decision we'll place that
6 document in the local repositories: One in
7 Camden's main library, one in Gloucester
8 City's public library, and in the Hynes
9 Center of Camden. The next public meeting
10 we'll have is when we're ready to start the
11 construction, most likely the General Gas
12 Mantle demolition, hopefully later this
13 year. If we could move the people along.
14 MR. EVANGELISTA: "People" meaning
15 EPA management.
16 MS. PULLMAN: So, of course, you'd
17 let us know if something were to happen.
18 If you discover that the scope of work was
19 greater than you thought and you had to
20 reconsider your plans, at what point would
21 you let the community know that, before you
22 make the final Record of Decision?
23 MR. EVANGELISTA: At this point we
24 don't anticipate reconsidering anything as
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EPA Public Hearing - 2/24/99
l far as what we've proposed in the proposed
2 plan or discussed this evening. The only
3 way that we would reconsider anything would
4 be based on public comment. And based on
5 what we've seen and heard thus far, both
6 here and in Gloucester City, there's
7 nothing indicative of our changing our
8 minds.
9 MR. ROBINSON: Everyone is in favor
10 of us digging the material up and taking it
11 off-site.
12 MS. PULLMAN: Good.
13 MS. CERVANTES-GROSS: In addition, as
14 we pointed out, there are still 500-some
15 properties that we consider as suspect
16 properties. So in the design -- as we go
17 through the design phase, there will be
18 additional investigation of those
19 properties, to include those properties in
20 what we're proposing. Once we go out there
21 to confirm if they have elevated levels
22 above our cleanup levels, those properties
23 would be included in -- most of the
24 vicinity properties.
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l MR. FELLMAN: Fed into the design
2 process that will be ongoing and current.
3 MR. KERBEL: There's a lot of
4 variability when we say contaminated
5 properties. It could range from just a
6 small spot where somebody might have to
7 almost come in with a shovel and put it in
8 a barrel and get it off; to maybe a backhoe
9 might have to come in and scrape the top
10 off. So there's a lot of variability.
11 MS. PULLMAN: I just realized at this
12 point you can't say exactly how many
13 properties you're going to have to do
14 cleanup and what level it will be. I'm
15 just being paranoid here. At any point you
16 could reconsider the plan if you rediscover
17 it's a greater scope of work or whatever.
18 MR. ROBINSON: No. If we find
19 contamination it will be taken away.
20 MS. PULLMAN: All right.
21 MS. CERVANTES-GROSS: Any other
22 questions or comments?
23 Okay. I that's it.
24 MR. ROBINSON: Thank you very much
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i for attending and hopefully we'll see you
2 soon with the progress of taking the
3 building down.
4 MR. BVANGELISTA: There are some
5 handouts that are on the table and you're
6 welcomed to take a copy.
7 ********
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52
1 CERTIFICATE
2 STATE OF NEW JERSEY
3 I, LINDA A. BURNS, Shorthand Reporter and Notary
4 Public of the State of New Jersey, do hereby certify
5 that I reported the public hearing in the
6 above-captioned matter and that the foregoing is a
7 true and correct transcript of the stenographic notes
8 of testimony taken by me in the above-captioned
9 matter.
10 I further certify that I am not an
11 attorney or counsel for any of the parties, nor a
12 relative or employee of any attorney or counsel
13 connected with the action, nor financially interested
14 in the action.
15
16
17
IB
19
20
X
21 Linda A. Burns
22
23
24 Dated: March 4, 1998
DBGNAN & B A T E M A N, INC.
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Notary Public ^
ssior. 1:.'-:.
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Welsbach/General Gas Mantle Contamination, Inc. Site
Site location: Gloucester City & Camden, Camden County, New Jersey
Listed on the NPL: June 16, 1996
Record of Decision:
Date signed: July 23, 1999
Selected remedy:
Alternative (V-3) - Excavation and off-site disposal of contaminated soil.
Alternative (W-3) - Excavation and off-site disposal of contaminated soil.
Alternative (G-3) - Decontamination and Demolition of the General Gas
Mantle Building
Operable Unit: OU-1
Capital cost: $33,892,120
Anticipated Construction Completion: September 2004
O & M cost: $0
Present-worth cost: $33,892,120
Lead:
Site is currently fund lead - EPA is the lead agency
Primary Contact: Rick Robinson, Remedial Project Manager, (212) 637-4371
Secondary Contact: Pat Evangelista, Chief, New Jersey Projects/State Coordination Team,
(212)637-4403
Waste:
Waste type: thorium, radium, uranium
Waste origin: gas mantle manufacturing, extracting thorium from ore
Contaminated medium: Soil and building materials
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