United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/103
June 1990
£EPA
Superfund
Record of Decision
Radium Chemical, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/103.
i. Recipients Accession No.
4. Title and Subtitle
«PERFUND RECORD OF DECISION
dium Chemical, NY •
rst Remedial Action - Final
5. Report Dale
06/21/90
7. Author)*)
a. Performing Orgenlatlon Rept No.
8. Performing Orgdnizrton Neme end Addreee
10. ProjecVTeek/WorkUnNNo.
11. Contrecl(O or Gnnt(G) No.
(C)
(G)
12. Spoiworlng Organization Hum end Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Typo of Report ft Pwtod Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Limit: 200 worde)
The Radium Chemical site consists of a one-story brick building in a light
industrial/residential section in Woodside, Queens County, New York. The Radium
Chemical Company (RCC) produced luminous paint beginning in 1913 and later manufactured,
leased, and sold radium226 to hospitals, medical centers and research laboratories. The
«"ium sources were stored onsite in lead containers in a poured concrete vault. In
3, the State suspended the RCC operating license due to disposal and safety
ractions and in 1987 ordered RCC to remove the radium sources and decontaminate the
building. RCC abandoned the building without complying leaving a large number of
radium-containing sealed devices, some of which were suspected of releasing radium and
radon gas. Also onsite were hundreds of containers of laboratory chemicals. From 1988
to 1989, EPA undertook a limited emergency removal action to secure the facility and
remove the radioactive sources. In 1989, a Public Health Advisory was issued for the
site based on the threatened release of radium226. This Record of Decision (ROD)
supplements the emergency removal action by addressing the remaining residual
radioactive contamination at the site including drummed hazardous waste contaminated
with radium.
(See Attached Sheet)
NY
17. Document Andyele a. Deecrfpem
Record of Decision - Radium Chemical,
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: radioactive materials (radium226, decay products)
idedTi
e. COSAT1 Hetd/Oroup
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It. Security CteeeOhie Report)
None
20. aeaittyCtaeeflNePege)
None
21. No.ofP«0M
49
22. PriM
(SM AMSt-Z38.1«)
OPDONAL 1-CmM 272 (4-77)
(FonrnrtyNTIS-JS)
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EPA/ROD/R02-90/103
Radium Chemical, NY
First Remedial Action - Final
Abstract (Continued)
The primary contaminants of concern affecting the soil and debris are radioactive
materials including radium226 and its decay products, including radon gas.
The selected remedial action for this site includes partial decontamination and complete
dismantling of the contaminated building, followed by offsite disposal of debris as
appropriate based on a contamination level; excavation and offsite disposal of
contaminated soil and subsurface piping, followed by replacement of piping and
backfilling with clean soil; and treatment of some radium-contaminated hazardous waste,
followed by offsite disposal of treated and untreated radium-contaminated hazardous
wastes in approved facilities. The estimated total cost for this remedial action is
$18,699,000. O&M costs are included in the total cost estimate.
PERFORMANCE STANDARDS OR GOALS: All soil will be excavated and disposed of offsite that
exceeds 5 pCi/g above background at the surface in the first six inches and 15 pCi/g
above background at the subsurface (i.e, subsequent 6-inch layers). Building masonry
with less than 5 pCi/g radium226 will be disposed of in a sanitary landfill, masonry
exceeding this level and other material (e.g., steel) exceeding specific surface
contamination levels will be disposed of offsite along with the soil at a radioactive
waste disposal facility. Chemical-specific goals for radium-contaminated hazardous waste
were not specified.
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ROD FACT SHEET
SITE
Name: Radium Chemical Compnay Site
Location/State: Woodside, Queens County, New York
EPA Region: II
HRS Score (date): Did not score - Added under ATSDR
NPL Rank (date): Added to NPL 11/21/89
ROD
Date Signed: June 21, 1990
Selected Remedy; Partial Decontamination of Facility Followed by
Complete Dismantling of Facility
Capital Cost: $ 18,699,000
Time to Implement: 2 years (one time remedy - no O&M)
LEAD
Remedial, EPA
Primary Contact (phone): Janet Cappelli (212-264-8679)
Secondary Contact (phone): Doug Garbarini (212-264-0109)
WASTE
Type: Radioactive (e.g. radium-226 and radon)
Medium: Building Debris/Soil
Origin: Contamination resulted from the improper storage and
handling of radium-226 sealed sources.
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DECLARATION FOB. THE RECORD OF DECISION
SITE NAME AND LOCATION
Radium Chemical Company, Woodside, Queens County., New York
STATEMENT OF BASIS AND PURPOSE '• ^',.
This decision document presents the selected remedial action for
the Radium Chemical Company Site developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended, 42 U.S.C. § 9601, et seq.. and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 C.F.R. Part 300. This decision is based on
the administrative record for the site.
The State of New York concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF SELECTED REMEDY
This final remedy addresses remediation of the residual
radioactive contamination remaining at the site by eliminating or
reducing the risks posed by the site.
The major components of the selected remedy include:
A Partial decontamination of the building followed by
complete dismantling of the building and disposal of
contaminated material in an approved radioactive waste
facility and clean material in an approved sanitary
landfill;
A Surface and subsurface soil investigation with excavation
and disposal of any contaminated material in an approved
radioactive waste facility followed by backfilling with
clean soil;
* Subsurface piping, including sewer line, investigation
with disposal of any contaminated material in an approved
radioactive waste facility followed by replacement with
clean material; and
A Treatment of some radium-contaminated hazardous waste
followed by disposal of treated and untreated radium-
contaminated hazardous wastes in approved facilities.
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TATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate, .to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource ^
recovery) technologies to the maximum extent practicable. The
remedy does not satisfy the statutory preference for treatment,
since there is no technology to treat the principal contaminant,
radium-226, and treatment is neither feasible nor scientifically
possible. The selected remedy, however, satisfies the statutory
preference to the maximum extent practicable by requiring the
treatment of radium-contaminated hazardous waste, as well as
reducing the mobility and volume of the radium-contaminated
materials. Because this remedy will not result in hazardous
substances remaining on-site above health-based levels, the
five-year review will not apply to this action.
rohstantine Sidamon-Eristoff / tfate'
Regional Administrator
U.S. EPA - Region II
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DECISION SUMMARY
RADIUM CHEMICAL COMPANY
WOODSIDE, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
SECTION PAG
Site Location and Description 1
Site History and Enforcement Activities 1
Community Relations Activities 3
Scope and Role of Response Action 3
Summary of Site Characteristics 4
Summary of Site Risks 5
Description of Alternatives 5
Summary of the Comparative
Analysis of Alternatives 9
Selected Remedy 13
Statutory Determinations 14
Documentation of Significant Changes 17
ATTACHMENTS
Appendix I - Figures
Appendix II - Tables
Appendix III - NYSDEC Letter of Concurrence
Appendix IV - Responsiveness Summary
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SITE LOCATION AND DESCRIPTION-
The Radium chemical Company Site ("Site") is located at 60-06
27th Avenue in Woodside, Queens County, New York. Figure l
depicts the Site location. The area surrounding the Site is
classified as a light industrial/residential sector. The Site
consists of a 1-story brick building bordered on the west by 27th
Avenue and oh the east by the Brooklyn-Queens Expressway't"BQE") ,
a major roadway in New York City. The westbound lane of the BQE
is located less than 6 feet from the rear wall of the facility.
A health club is located within 100 feet of the Site and numerous
pedestrians pass the Site fence and building daily. Vehicular
traffic is very heavy along 27th Avenue, a primary access route
to the BQE.
The building is approximately 10,000 square feet in size; 7,220
square feet of which encompassed the Radium Chemical Company
("RCC"). The Solux Company, a commercial manufacturing facility,
occupies space in an adjoining building. The Radium Chemical and
Solux facilities share a common wall within the building, and
some of the Solux floor space at one time was leased to Radium
Chemical. The layout of the RCC facility and its location
relative to the Solux Company is depicted in Figure 2.
The population within a 3-mile radius of the Site obtains drink-
ing water from the New York City municipal system, which comes
from surface impoundments 10 miles from the Site. The ground
water underlying the Site is very shallow at 5 - 10 feet, but is
not used as a drinking water supply. The nearest drinking water
well is 6 miles from the Site. The nearest surface water body to
the Site is the East River, over 1.5 miles away. There are no
endangered species or critical habitats within close proximity of
the Site. The nearest residence is located 500 feet from the
Site. It is estimated that 27,000 people reside in high-rise
apartments and row houses within a 1-mile radius of the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Radium Chemical Company ("RCC") was founded in New York in
1913. The original corporate offices were located in Manhattan.
The company initially produced luminous paint for watch dials and
instruments. Later, the company manufactured, leased and sold
radium-226 in the form of radiation therapy and radiographic
sources to hospitals, medical centers, and research laboratories.
Sources were also leased or sold in limited quantities to the oil
industry for geophysical logging. In the late 1950's, RCC
transferred its operations to the present location in Woodside,
New York. The radium sources were stored on-site in lead
containers in a poured concrete vault. Eventually the demand
for radium sources lagged as they were replaced with more
advanced radiation therapy techniques using cesium-137, cobalt-
60, and iridium-192. Subsequently, many leased radium sources
were returned to RCC and were stored on-site.
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In 1983, the State of New York suspended the RCC operating
license due to various disposal and safety infractions. RCC
attempted to obtain permission to begin operations again in 1986,
but was denied. The New York State Department of Labor issued an
order against RCC on October. 17, 1987, for the removal of^the
radium sources and decontamination of the building. The owner
was unable to finance the remediation and, subsequently,
abandoned the building. This resulted in a second order, issued
on July 20, 1988, determining that the facility could not be
maintained and that it was de facto abandoned by RCC.
Remaining on-site were a large number of radium-containing sealed
devices, some of which were suspected of releasing radium and
radon gas. The amount of radium-226 at the Site was estimated,
at the time, to be 110 Curies ("Ci"). Also on-site were hundreds
of containers of laboratory chemicals, many of which were
reactive, corrosive, flammable, and/or potentially shock
sensitive.
In July 1988, at the request of the State of New York, the U.S.
Environmental Protection Agency ("EPA") undertook a limited
emergency removal action under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 ("CERCLA"), as
amended, 42 U.S.C. § 9601, et seq.. to secure the facility and
remove the radioactive sources. EPA provided 24-hour security
and initiated measures to stabilize the Site. By August 1988,
EPA had erected fencing around the perimeter and installed remote
monitoring surveillance, a foam fire suppressant system, special
vents, and other safety measures. In February 1989, EPA
developed a support agreement with the U. S. Army Armament,
Munitions and Chemical Command to use an existing contract with
Chem-Nuclear Systems, Inc. to remove the radium sources and other
hazardous materials from the Site and transport them to approved
disposal facilities. The removal action was completed in October
1989. Approximately 120 Ci of radium in the form of sources,
contaminated debris, and loose radium salts and luminous
compounds were removed from the Site. This material was disposed
of at facilities located in Richland, Washington and Beatty,
Nevada, both operated by U.S. Ecology.
On February 10, 1989, at EPA's request, the U.S. Agency for Toxic
Substances and Disease Registry ("ATSDR") issued a Public Health
Advisory to alert the public, EPA, and the State of New York of
a serious threat to human health, based on the threatened release
of radium-226 from the RCC site. EPA had requested ATSDR to
perform an assessment on the Site to evaluate the priority for
complete remediation. In an August 1989 special National
Priorities List ("NPL") update, EPA proposed the RCC site for the
NPL based on the ATSDR advisory. On November 21, 1989, the RCC
Site was added to the NPL.
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EPA completed a Focused Feasibility Study ("FFS") of the Site in
April 1990. The FFS report characterizes the nature and extent
of the contamination at the Site, and describes..various remedial
alternatives for addressing the contamination. In April 1990,
the FFS. report was released;.to the public along with the ^Proposed
Remedial Action Plan ("Proposed Plan") , developed by EPA. ..A 30-
day public comment period was provided, ending on May 13, 1990.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Radium Chemical Company Site
was finalized in early 1989, prior to the removal action. This
document lists contacts and interested parties throughout
government and the local community. It also establishes
communication pathways to ensure timely dissemination of
pertinent information. Numerous fact sheets, outlining the
progress of the removal action, were distributed during 1989.
The FFS and Proposed Plan were released to the public in April
1990. These last two documents were made available through two
information repositories maintained at the Woodside Branch
Library and the Sunnyside Branch Library. A public comment
period was held from April 12, 1990 to May 13, 1990. In
addition, a public meeting was held on May 1, 1990 to present the
results of the FFS and the preferred alternative as presented in
the Proposed Plan for the Site. All substantive comments which
were received by EPA prior to the end of the public comment
period, including those expressed verbally at the public meeting,
are addressed in the Responsiveness Summary which is attached, as
Appendix IV, to this Record of Decision.
SCOPE AND ROLE OF RESPONSE ACTION
The scope of this response action is to address the remaining
residual radioactive contamination at the Site. As discussed, a
previous emergency removal action addressed the principal threat
at the Site, namely the radium-226 sources.
The purpose of this response is to remove or reduce radium-226
and its daughters, or decay products, and to prevent radon
concentrations from exceeding acceptable levels. Also, this
response will prevent both the release of radioactivity to the
air and the possible spreading of contamination into the soil and
groundwater beneath the facility and restore the Site property to
a condition allowing unrestricted use.
The selected alternative for this final phase of the project will
address all remaining concerns at the Site.
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SUMMARY OF SITE CHARACTERISTICS
The site is presently inactive and secure. All windows are
covered with steel grates and all doors are equipped with locked
steel rqil-up covers. Permanent caps have been placed on....all
roof vents and stacks, except for the four high efficiency
particulate air ("HEPA") vent lines. Fencing with razor ribbon
on top surrounds the Site as well as the roof around the entire
facility. EPA has posted signs warning that the site contains
radioactive materials and entry to the property is prohibited.
Residual radioactive contamination by radium-226 ("Ra-226") and
radon gas still exists within the facility. The source area, as
depicted in Figure 2, has widespread contamination including
nineteen areas of elevated radiation levels, or hot spots. A hot
spot is defined as an area that measures more than 10.0 mR/hr at
a distance of one centimeter from the floor or wall surface, more
than 100,000 disintegrations per minute ("dpm")/100 cm2 removable
alpha contamination, or more than 250,000 dpm/100 cm2 removable
beta contamination. The highest radiation exposure rate
identified in the source vault area was 200.0 mR/hr at one
centimeter from the interior of a safe in the source vault area.
The highest contamination level identified in the source vault
area was 847,000 dpm/100 cm2 removable beta in a 55-gallon drum
filled with lead containers, or pigs, that were used to shield
radium sources for storage. Four hot spots were found in areas
outside the source vault. The highest radiation exposure rate
found in this area, outside of the source vault, was 50.0 mR/hr
one centimeter from the surface of the concrete pedestal in the
tritium room. The highest contamination level, outside of the
source vault area, was 483,000 dpm/100 cm2 removable beta found
inside of a safe in the pump room. Approximately 75% of all
survey points in the lease area and 25% of all survey points in
the administrative office area exceeded acceptable radiation
levels for surface contamination (see Tables 2 and 3 which
reference these acceptable levels). None of the soil samples,
outside of the RCC building, collected below six inches was found
to exceed the standards.
A 30-gallon metal pail containing radium-contaminated mercury is
stored in a safe located in the source vault room within the RCC
building. An additional two 55-gallon drums containing radium-
contaminated hazardous wastes (i.e. various hazardous chemicals
as indicated in Table 1) are also being stored in the source
vault room within the RCC building. Please note that the
Proposed Plan referred to the hazardous waste contaminated by
radium-226 as "mixed waste". The correct term is radium-
contaminated hazardous waste. "Mixed waste" applies only to
hazardous waste contaminated by radionuclides governed under the
Atomic Energy Act, which does not have authority over radium-226.
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SUMMARY OF SITE RISKS
Although the emergency removal action addressed., the immediate
danger at the Site by removing approximately 120 Ci of Ra-226,
the RCC,.facility still poses, a potential risk due to residual
levels of contamination within the building and fenced area. The
remaining concerns are the levels of radioactivity, the amount of
exposure the maximally exposed individual could receive, and the
potential for exposure to the public.
Radium decays to form radon gas and other decay products. Within
tightly enclosed buildings, the danger exists for the potential
build-up of radon gas above the standards set to protect human
health, representing a long-term exposure hazard to people who
live or work in the buildings.
The radiation and contamination levels in the facility exceed
both State regulations and Federal guidance for exposure to the
public. The levels of removable alpha radiation and removable
beta radiation within the RCC facility clearly exceed the Federal
standards (see the discussion in the "Summary of Site
Characteristics" section on page 5 and Tables 2 and 3). It is
believed the beta radiation is from the decay products of Ra-226.
The alpha radiation most likely results from residual Ra-226
remaining in the building, but may also result from polonium-210,
a radon daughter or decay product, which is an alpha emitter.
This material still is a potential health hazard to members of
the neighboring area. There still is a possibility of either
inhalation or ingestion of radioactive materials as a result of
either fire or vehicular collision with the building from the
BQE, although this has been greatly lessened due to the emergency
removal action. The facility as it presently exists is primarily
a hazard from a direct contact and entry point. The prime
concern involving a fire in the facility now will be the toxic
components of the smoke and the mercury which may be airborne.
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.
DESCRIPTION OF ALTERNATIVES
This section describes the remedial alternatives which were
developed to meet the objectives of the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"), 40 CFR
Part 300, and CERCLA, 42 U.S.C. § 9601, et. sea. These
alternatives were developed and screened for the applicability tc
site-specific conditions and were evaluated for their
effectiveness, implementability, and cost.
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The alternatives developed for the Radium Chemical Company Site
are detailed below.
ALTERNATIVE 1 - NO ACTION
Total Cdsts: $515,000 "
Time to Implement: 1 month
Under this alternative, no further actions would be taken to
prevent radon generation or to remove any of the contamination.
The building and Site perimeter would be secured against
intrusion and the contamination would be left in place.
Additional fencing would be installed between the building and
the BQE. All windows, as well as all but one door, would be
sealed with brick. The four HEPA vent lines would also be
sealed. Surveillance cameras would be installed and an
electronic system would be used to provide 24-hour monitoring to
ensure that building security is not broken. A sampling program
would be instituted to ensure that no releases are occurring. A
public awareness program would be maintained to keep the
neighboring community and businesses informed. All radium-
contaminated hazardous waste would be secured and left on-site.
ALTERNATIVE 2 - TOTAL DECONTAMINATION OF FACILITY
Total Costs: $ 21,211,000
Time to Implement: 2 years
Under this alternative, the RCC facility would undergo a total
decontamination and decommissioning of the contaminated interior
and exterior areas. This work would involve the partial or
complete removal of interior walls and floors. A site
characterization survey would be performed to further quantify
the extent of contamination in surface and subsurface soils as
well as underground piping, including sewer lines, in the
immediate vicinity of the Site. Certain constituents of the
radium-contaminated hazardous waste would be treated for their
hazardous nature and disposed of as radioactive waste. An
attempt would be made to temporarily store the remaining radium-
contaminated hazardous waste at an off-site location until such
time as a facility becomes permitted to accept it for disposal.
If that attempt fails, the remaining radium-contaminated
hazardous waste would have to be securely stored on-site until a
disposal facility could accept it. This radium-contaminated
hazardous waste would be stored in the lease area portion of the
facility while decontamination efforts would take place in other
areas of the facility.
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As much of the building as possible would be left in place after
the contamination was removed. Precautions would be necessary to
minimize the spread of contamination, releases to the
environment, and potential exposures to workers. Contaminated
material.-would be packaged in accordance with Department of
Transportation regulations and shipped to an approved radioactive
waste disposal facility. It is not possible to estimate the
extent of contamination in floor/foundation materials at this
time. Floor structures, and possibly soils below the floor, may
be contaminated and would require decontamination/removal.
Decontamination and removal of the floor/foundation would require
additional structural support of the building.
It is also not possible to determine the extent, if any, of drain
line or sewer contamination. It is highly likely that floor
drains originating from the source area are contaminated.
Contaminated materials were regularly disposed of via the
sanitary sewer system. Other drains from the restricted area of
the facility (source repair room, toilets, janitor's closet, and
tritium room) have known contamination. This remedy would
include an investigation to further determine the extent of that
contamination. Decontamination of drains or sewers would involve
complete removal of the pipes, conduits, and replacement of sewer
lines and/or catch basins.
ALTERNATIVE 3 - COMPLETE DISMANTLING AND REMOVAL OF FACILITY
Total Costs: $ 19,776,000
Time to Implement: 2 years
The entire RCC facility would be dismantled as is and shipped to
a radioactive waste repository. This would involve the complete
removal of the building and contaminated soil. Precautions would
be necessary to minimize the spread of contamination to the
environment and potential exposures to workers. All material
would be packaged and shipped in accordance with Department of
Transportation regulations.
It is not possible, at the present time, to determine the extent
of contamination in the soils or structures below the foundation.
As with Alternative 2, a site characterization survey would be
conducted to further quantify the extent of contamination in
surface and subsurface soils as well as underground piping,
including sewer lines, in the immediate vicinity of the Site. If
soil contamination is discovered below grade, the materials would
have to be removed and replaced with "clean" soils. If sewers or
drain lines are found to be contaminated, they would require
removal and replacement.
Again, as with Alternative 2, certain constituents of the radium-
contaminated hazardous waste would be treated for their hazardous
nature and disposed of as radioactive waste. An attempt would be
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' 8
made to : :mporarily store the remaining radium-contaminated
hazardous v;aste at an off-site location until such time as a
facility becomes permitted to accept it for disposal. If that
attempt fails, the remaining radium-contaminated hazardous waste
would have to be stored on-site until a disposal facilityvcould
accept it. This radium-contaminated hazardous waste would be
stored in the lease area portion of the facility while
dismantling efforts would take place in other areas of the
facility.
ALTERNATIVE 4 - PARTIAL DECONTAMINATION AND DISMANTLING OF
FACILITY
/
Total Costs: $ 18,699,000
Time to Implement: 2 years
The RCC facility would be decontaminated and then dismantled.
Essentially this option is a combination of Alternatives 2 and 3.
The work would involve the partial or complete removal of
contaminated interior walls and floors, as well as the removal of
any radioactively contaminated sewer lines and soil beneath the
building. The remaining areas would be dismantled and disposed
of as either contaminated or uncontaminated waste, depending on
whether or not decontamination operations were undertaken in the
area. Decontamination efforts will result in a reduction of the
amount of radioactive material requiring disposal. Precautions
would be necessary to minimize the spread of contamination,
releases to the environment, and potential exposures to workers.
Contaminated material would be packaged in accordance with
Department of Transportation regulations and shipped to an
approved disposal facility.
It is not possible to determine the extent of contamination in
floor or foundation materials at this time. As with Alternatives
2 and 3, a site characterization survey would be conducted to
further quantify the extent of contamination in surface and
subsurface soils as well as underground piping, including sewer
lines, in the immediate vicinity of the Site. Structures and
possibly soils below the floor may be contaminated and would
require excavation and disposal. 1f contamination is discovered
below the foundation, the time required for excavation, as well
as disposal costs, would increase.
It is also not possible to determine the extent, if any, of drain
line or sewer contamination. It is highly likely that floor
drains originating from the source area are contaminated.
Contaminated materials were regularly disposed of via the
sanitary sewer system. Other drains from the restricted area of
the facility (source repair room, toilets, janitor's closet, and
tritium room) have known contamination. This remedy would
include an investigation to further determine the extent of that
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contamination. Decontamination of drain lines or severs would
involve complete removal and replacement.
As with Alternatives 2 and 3, certain constituents of the radium-
contaminated hazardous waste would be treated for their hazardous
nature and disposed of as radioactive waste. An attempt would be
made to temporarily store the remaining radium-contaminated
hazardous waste at an off-site location until such time as a
facility becomes permitted to accept it for disposal. If that
attempt fails, the remaining radium-contaminated hazardous waste
would have to be stored on-site until a disposal facility could
accept it. This radium-contaminated hazardous waste would be
stored in the lease area portion of the facility while
decontamination and dismantling efforts would take place in other
areas of the facility.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
All remedial alternatives were evaluated in detail utilizing nine
criteria as set forth in the NCP, 40 C.F.R. § 300. 430 (e)(9).
These criteria were developed to address the requirements of
Section 121 of CERCLA to ensure all important considerations are
factored into remedy selection decisions.
The following "threshold" criteria are the most important and
must be satisfied by any alternative in order to be eligible for
selection:
Threshold Criteria A overall protection of human health and
the environment; and
A Compliance with applicable or relevant
and appropriate requirements.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
alternatives:
Primary Balancing A Long-term effectiveness and
permanence;
Criteria A Reduction in toxicity, mobility, or
volume through treatment;
A Short-term effectiveness;
A Implementability; and
A Cost.
The following "modifying" criteria are considered fully after the
formal public comment period on the Proposed Plan is complete:
Modifying Criteria A state/support agency acceptance; and
A Community acceptance.
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The discussion which follows provides a summary of the relative
performance of each alternative with respect to the nine criteria.
Overall Protection of Human Health and the Environment
This criterion addresses whether or not a remedy provides adequate
protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls, or institutional
controls.
Protection of human health is the central mandate of CERCLA.
Protection is achieved primarily by taking appropriate action to
ensure that there will be no unacceptable risks to human health or
the environment through any exposure pathways.
Alternatives 2, 3, and 4 are all designed to remove any source of
contamination. Therefore, the potential for public exposure would
be eliminated and any potential spread of contamination into the
surroundings would be halted. Alternatives 2, 3, and 4 all provide
protection of both human health and the environment. Since
Alternative 1 does not remove the source of radon generation, but
merely secures the Site, the potential for the spread of
contamination into the community would continue. Therefore, it
would not be as protective of human health and the environment.
Compliance with ARARs
This criterion addresses whether or not a remedy will meet all
applicable or relevant and appropriate requirements and/or provide
grounds for invoking a waiver. ARARs can be chemical-specific,
location-specific, or action-specific.
After implementation of Alternatives 2, 3, and 4, all ARARs
providing standards for radiation protection within buildings and
allowable surface and soil contamination would be met since all
radioactive contamination would be removed from the Site. All ARARs
governing the transportation of radioactive material would be met
with Alternatives 2, 3, and 4. Tables 2 and 3 identify the major
ARARs for the Site. Since no removal of contaminated material would
occur with Alternative 1, ARARs would not be achieved.
Long-term Effectiveness and Permanence
This criterion refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time,
once clean-up levels have been met. It also addresses the magnitude
and effectiveness of the measures that may be required to manage t.*-.--
risk posed by treatment residuals and/or untreated wastes.
Alternatives 2, 3, and 4 present no long-term threat to public
health because these alternatives are designed to remove any source
of radon generation. After implementation of Alternatives 2, 3, or
-------
4, there would no longer be any unacceptable risks posed by
radioactive or hazardous contaminants associated with the site.
Since Alternative 1, no further action, does not involve any actions
to prevent further radon generation or to remove any radioactive
materials,,..it would present a long-term risk due to the resulting
continual presence of contamination at the Site.
Reduction of Toxicitv, Mobility, or Volume
This evaluation criterion relates to the anticipated performance of
a remedial technology, with respect to these parameters, that a
remedy may employ.
Alternatives 2, 3, and 4 are designed to remove the source of
radiation from the Site and, thereby, eliminate any potential
mobility of radiation into the Site surroundings. In turn, the
volume of radioactive material and its associated toxicity would be
removed from the Site. Alternative 2 would result in the smallest
volume of radioactive material requiring disposal followed by
Alternatives 4 and 3. However, Alternative 1, no further action,
does not employ any removal or treatment technologies and,
therefore, would not achieve any level of reduction of toxicity,
mobility, or volume of contaminants.
Short-term Effectiveness
This criterion involves the period of time necessary for each
alternative to achieve protection, and any adverse impacts on human
health and the environment that may be posed during construction and
implementation of the alternative.
Alternatives 2, 3, and 4 present some minimal short term risks to
workers during the remediation. With Alternatives 3 and 4,
involving dismantling, there is typically less control over possible
releases of contamination to workers than where remediation involves
only decontamination, as with Alternative 2. Measures, such as
strict adherence to the "as low as is reasonably achievable"
("ALARA") operating philosophy, would be taken to ensure that
exposures to the workers are reduced as far below specified limits
as is reasonably achievable. Any adverse short-term impacts during
implementation of Alternatives 3 and 4, involving dismantling (such
as the creation of dust), could be controlled by instituting dust
suppression measures. Since Alternative 1, no further action, does
not involve any substantial construction, there would be no short-
term risks associated with it.
Iroplementability
This criterion involves the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
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Alternative 1, no further action, does not require any substantial
construction and would be easily and promptly implemented.
Alternatives 2, 3, and 4 would all require approval of detailed
plans before field work is started. After Alternative 2 is
implemented, a. verification survey must be performed to ensure that
decontamination efforts have succeeded. If not, the decontamination
must be performed again, possibly resulting in reinforcement or
dismantling of the building. Alternative 3 assumes the entire
volume of the facility to be contaminated since segregation of clean
debris after dismantling is impossible. Locating a radioactive
disposal facility capable of accepting such a great volume of
material may prove difficult, thus creating a barrier to
implementation. Alternative 4, using partial decontamination, would
result in a reduction of contaminated material requiring disposal.
This would help in locating a radioactive disposal facility which
could accept all the material.
Cost
This criterion includes both estimated capital and operation and
maintenance ("O&M") costs.
Alternative 2 would be the most costly to implement followed by
Alternatives 3 and 4. Alternative 1, no further action, would be
the least costly to implement. The overall cost estimates for each
alternative are as follows:
Alternative 1: $ 515,000
Alternative 2: 21,211,000
Alternative 3: 19,776,000
Alternative 4: 18,699,000
State/Support Agency Acceptance
This criterion assesses the technical and administrative issues and
concerns the state may have regarding each of the alternatives. The
factors to be evaluated are those features of the alternatives that
the state supports or opposes, and any reservations the state may
identify.
The State of New York, through the New York State Department of
Environmental Conservation ("NYSDEC"), has concurred with EPA's
selected remedy. The NYSDEC letter of concurrence is attached as
Appendix III.
Community Acceptance
This criterion provides an assessment of any public concerns
regarding any of the alternatives. Factors of community acceptance
o be discussed include support, reservation, and opposition by the
ommunity.
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• . -• " il
No strong objections from the community were raised regarding
the selected remedy. The only concerns regarding implementation
centered mainly on the issue of rerouting traffic through the
area. The community has expressed a strong preference for a
permanent solution and off-site disposal. A responsiveness summary
which addresses all substantive comments received during the public
comment period, including the May 1, 1990 public meeting, is
attached as Appendix IV.
SELECTED REMEDY
Based upon all available data and analyses conducted to date, EPA
has selected Alternative 4 - Partial Decontamination and Complete
Dismantling as the most appropriate solution for meeting the goals
of this study. This alternative provides the best balance among the
nine criteria used as a means of evaluation. Alternative 4 provides
protection of human health and the environment, while minimizing
future costs and problems, and offers the best balance in time
spent, volume of radioactive waste generated, and overall costs.
The volume of waste generated, although greater than that of the
decontamination option, is less than that of the total dismantling
option. This is an important consideration as the availability of
disposal space for radium contaminated material is expected to
continue to decrease in the future. After implementation of
Alternative 4, the source of radon generation will be removed and
the Site property will be restored to a condition allowing
unrestricted use.
The partial decontamination will be performed in order to remove hot
spots and reduce the risk of worker exposure and the risk of
spreading contamination outside the Site boundary during
dismantling. The decontamination will also prepare parts of the
building masonry (with less than 5 pCi/g radium-226) for disposal in
a sanitary landfill, thereby reducing the volume of material
requiring costly disposal in a radioactive waste facility.
The dismantling will be accomplished in three phases: (1) removal of
material (except masonry) from the building interior; (2) removal of
the building roof, windows, and doors; and (3) dismantling of the
residual masonry. All clean material (i.e., steel) with surfaces
that meet the limits of Table 3, or bulk material (i.e., masonry,
soil) with less than 5 pCi/g Ra-226 will not require disposal in a
radioactive waste facility. Soil on the Site will be considered
contaminated if it contains more than 5 pCi (above background) of
Ra-226 per gram of soil averaged over the first 6 inches and greater
than 15 pCi (above background) of Ra-226 per gram of soil for subse-
quent 6 inch layers. Although New York State Department of Labor
("NYSDOL") regulations require no more than 0.1 pCi/g of Ra-226 for
disposal of material in a sanitary landfill and for soil
remediation, due to the technical difficulty in achieving this
level, NYSDOL has agreed to waive their soil/disposal limits in
favor of the EPA 5/15 pCi/g Ra-226 regulation. The NYSDOL letter,
-------
-14
waiving the regulation requiring 0.1 pCi/g of Ra-226 for soil
remediation and disposal, shall be placed in the administrative
record for the Site. All contaminated material is expected to be
disposed of in the radioactive waste disposal facility operated by
Envirocare of Utah, Incorporated, located in Clive, Utah, since, at
the present time, this is the only facility capable of accepting
this type of naturally occurring radioactive material.
Certain constituents of the radium-contaminated hazardous waste
would be treated for their hazardous nature and disposed of as
radioactive waste. Utilizing present technology, it appears that
the mercury, potassium chromate, and galena may be treated for their
characteristic toxicity hazard and then disposed of in a radioactive
waste facility. An attempt would be made to temporarily store the
remaining radium-contaminated hazardous waste at an off-site
location until such time as a facility becomes permitted to accept
it for disposal. If that attempt fails, the remaining radium-
contaminated hazardous waste would have to be stored on-site until a
disposal facility could accept it. This radium-contaminated
hazardous waste would be stored in the lease area portion of the
facility while decontamination and dismantling efforts would take
place in other areas of the facility. The remediation will not be
completed until the radium-contaminated hazardous waste is disposed
of off-site.
Once complete, the remedial action will have removed all radioactive
and hazardous materials, above acceptable levels, from the Site,
rendering the Site property allowable for unrestricted use.
STATUTORY DETERMINATIONS
EPA believes that the selected remedy will satisfy the statutory
requirements of providing protection of human health and the
environment, being cost-effective, utilizing permanent solutions and
alternative treatment technologies or resource recovery technologies
to the maximum extent practicable, and satisfying the preference for
treatment as a principal element.
Protection of Human Health and the Environment
The selected remedy will eliminate all remaining threats posed by
the Site. All sources of radioactive and hazardous materials will
be removed from the Site. The Site property will be returned to a
condition allowing unrestricted use once the remedial action is
complete. There are no unacceptable short-term risks caused by
implementation of the remedy.
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Compliance with ARARs
Few applicable standards exist for the cleanup of..radioactively
contaminated sites and buildings. This section discusses the
applicability or relevance arid appropriateness ("ARARs") of-....
standards for the remediation of sites containing radioactive
contamination. Several agencies have authority over the cleanup of
sites contaminated with radioactive materials. Each agency has a
variety of general regulations that could be applicable or relevant
and appropriate to CERCLA sites with similar radioactive
contamination. In addition, there are a variety of radiation
advisories and guidance, referred to as "to be considered" ("TBCs"),
that, while not ARARs, may be considered when developing protective
remedies at CERCLA sites. The primary agencies that have regulatory
programs for the cleanup of such sites and buildings are EPA, the
Nuclear Regulatory Commission ("NRC"), the Department of Energy
("DOE"), and States. The Department of Transportation ("DOT") also
has regulations governing the transporting of radioactive wastes.
The selected remedy will comply with all of the following ARARS.
EPA regulations governing the cleanup of uranium mill tailings, 40
C.F.R. 192, have been determined to be relevant and appropriate for
soil remediation and disposal of materials for the Site. Again, as
stated on page 13, although NYSDOL regulations for soil/disposal are
more stringent, NYSDOL has agreed to waive those levels in favor of
the levels found in 40 C.F.R. 192. Table 2 highlights the uranium
tailings cleanup standards and summarizes additional ARARs for the
Site. Table 3 highlights the allowable surface levels for Ra-226 as
found in NRC Regulatory Guide 1.86. These NRC limits for allowable
surface contamination are more stringent than NYSDOL limits for
allowable surface contamination and are relevant and appropriate for
remediation of the Site. The selected remedy will comply with the
more stringent regulations. The regulations discussed above and
additional regulations found to be relevant and appropriate for
remediation of the Site are listed below.
EPA ARARs
A 40 CFR Part 61: "National Emissions Standards for Hazardous Air
Pollutants: Standards for Radionuclides"
A 40 CFR Part 192: "Health and Environmental Protection Standards
for Uranium and Thorium Mill Tailings"
* 40 CFR Part 261: "Identification and Listing of Hazardous Waste"
NRC ARARs
A 10 CFR Part 20: "Standards for Protection Against Radiation"
A 10 CFR Part 61: "Licensing Requirements for Land Disposal of
Radioactive Waste"
-------
•• 16
A Regulatory Guide 1.86: "Termination of Operating Licenses for
Nuclear Reactors"
A 16 CFR Part 71: "Packaging of Radioactive Material for Transport
and Transportation of Radioactive Material Under Certain^.
Conditions"
DOT
A 49 CFR 173: "Transportation and Packaging of Radioactive
Materials"
STATE
A 12NYCRR38: "Ionizing Radiation Protection"
A 6NYCRR Part 380: "Rules and Regulations for Prevention and Control
of Environmental Pollution by Radioactive Materials"
TBCs
A "Technological Approaches to Cleanup of Radiologically
Contaminated Superfund Sites" - EPA - May 23, 1988.
A "Guidelines for Decontamination of Facilities and Equipment Prior
to Release for Unrestricted Use or Termination of Licenses for
Byproduct, Source, or Special Nuclear Material"- NRC - July, 1982.
Cost—Effectiveness
The preferred alternative, Alternative 4, provides overall
effectiveness proportionate to its cost. It is estimated to be the
least expensive alternative to implement, other than the no action
alternative, and saves substantial costs on the disposal of
contaminated material by reducing the amount of contaminated
material requiring disposal through the partial decontamination
effort.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
Practicable
EPA has determined that the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can
be utilized in a cost-effective manner for the Radium Chemical
Company Site. The selected remedy represents the best balance of
the nine evaluation criteria used to judge all alternatives.
No treatment exists for radioactively contaminated material.
Therefore, the selected remedy must involve disposal in an approved
radioactive waste disposal facility. Treatment technologies will be
used for certain portions of the radium-contaminated hazardous waste
-------
. .. - 11
to render them non-hazardous prior to their disposal as radioactive
material.
After dismantling and removal of the building and. any contaminated
soils or subsurface piping is complete, the Site will no longer be
contributing any contamination and will be restored to a condition
allowing unrestricted use.
Preference for Treatment as a Principal Element
The statutory preference for treatment is not satisfied by the
selected remedy, since no treatment exists for addressing the
principal threat, namely radioactive material. Again, treatment
methods will be employed for certain constituents of the radium-
contaminated hazardous waste prior to its disposal.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Radium Chemical Company Site was released
to the public in April 1990. The Proposed Plan identified
Alternative 4, Partial Decontamination and Complete Dismantling, as
the preferred alternative. EPA reviewed all comments submitted
during the public comment period. Upon review, it was determined
that no significant changes to the selected alternative, as it was
orig-inally identified in the Proposed Plan, were necessary.
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APPENDIX I
FIGURES
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• . .FIGURE' 2
RADIUM CHEMICAL COMPANY
60-06 27th AYE.
WOODSIDE, NY 11377
/ DOOR
( IN TOT )
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APPENDIX II
TABLES
-------
TABLE 1 '
RADIUM-CONTAMINATED HAZARDOUS WASTE CONSTITUENTS REMAINING ON-SITE
Chemical
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Varnish
Zinc Powder
Adhesive
Acetone
Ferric Chloride
Platinum Plating Solution
Dupont Phosphine gg
Para Rosaniline Base
Flourcin
Dupont Auramine
Granylurea Phosphate
Formaldehyde
Galena (Lead Sulfide)
5-Chlor-2-Hydroxy Benophene
Potassium Chromate
Unknown
Unknown
Unknown
Unknown
Radium Content (pCi/g or pCi/11
(6.09 c/s gross)
1.32 (32.35 c/s gross)
(9.59 c/s gross)
(105.91 c/s gross)
(6.88 c/s gross)
(68.86 c/s gross)
0.61
(5.45 c/s gross)
(7.44 c/s gross)
(10.85 c/s gross)
(18.01 c/s gross)
(14.89 c/s gross)
(10.76 c/s gross)
(10.75 c/s gross)
(27.34 c/s gross)
(7.12 c/s gross)
(5.39 c/s gross)
3.3
4.9
0.55 pCi/ml Cs-137
1.1 pCi/ml Cs-137
2.9
23.7
805
22.0 Th-232
19
67.5
17.5
9.2
3795
6.2
4.2
316
11.2
4.7
416
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TABLE 2
MAJOR ARARs
Type of Requirement
ARAR
Source of ARAR
Public Health
* Radon Decay Products
* Gamma radiation
* Radon
0.02 WL
(as an annual average)
20 micro R/hr
above background
4 pCi/l
40 CFR 192;
EPA guidance
40 CFR 192
EPA guidance
EPA guidance
Cleanup of Land
A Radium concentration
in soil
5 pCi/g above back-
ground at surface2
in first six inches
15 pCi/g above back-
ground at subsurface2
in successive 6 inches
40 CFR 192
40 CFR 192
Cleanup of Surfaces
(See Table 3)
NRC Reg. 1.86
Land Disposal
* Longevity
* Radon Emission rate
At least 200 yrs.
20 pCi/m2/sec
40 CFR 192
40 CFR 192
Transportation
(See discussion in Appendix IV)
49 CFR 173
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TABLES
ACCEPTABLE SURFACE CONTAMINATION LEVELS
NUCLIDE*
U-nat.U.235,U.238.and
associated decay products
Traruurania, Ra-226. Ra-228.
Th-230.Th-228,Pa.231.
Ac-227. 1-125. 1-129
Th-nat.Th-232.Sr-90,
Ra.223.Ra-224.ll.232.
1-126.M31.M33
Beta-gsmma emitters (nuclides
with decay modes other than alpha
emission or spontaneous fission)
except Sr-90 and others noted above.
AVER AC Eb c
5. 000 dpm a/ 100 cm2
lOOdpm/lOOcm2
1000 dpm/ 100 cm2
5000 dpm fal 100 cm2
MAXIMUMb d
1 5, 000 dpm a/ 100 cm2
300dpm/100cm2
3000dpm/100cm2
15, 000 dpm ^y/1 00 cm2
REMOVABLE0 e
1.000 dpm a/100 cm2
20 dpm/ 100 cm2
200 dpm/ 100 cm2
1000 dpm 0-7/1 00 cm2
'Where turface contamination by both alpha- and beia-gamma-emirting nuclides exists, the limit* established for alpha- a*d
bcia-gimma-cmiiiing nuclidei should ipply independently.
bAi uied io ihii tibk. dpm (didntepttioai per minute) metni th* me of emission by radioactive mtteritl u 4«t>rmla«d by u*j»ctiu»
the count! per mlnuu obterved by an ippioprUU detector for background, efficiency, aad noneuic facion ueod«t»
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APPENDIX III
NYSDEC LETTER OF CONCURRENCE
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MAR-30-1990 17-21 FROM NYS E-EPT OF ENV CON TO 9379357212264S6Q7 p.£2
New York State Department of Environmental Conservation
50 Wolf Road, Albany, N«w York 12233
MAR 3 0 1990 Thomas C. Jorllng
Commltslonar
Dear Ms. Cappelli:
The New York State Department of Environmental Conservation
has reviewed both the Draft Focused Feasibility Study and the
Draft Proposed Remedial Action Plan ("PRAP") for the Radium
Chemical Company Site ("Site"). These two draft reports were
sent to Dr. Paul J. Merges by letters dated February 12, 1990 and
March 9, 1990. The Department concurs with the PRAP in that
Alternative 4 is the preferred method for remediating the Site.
Both draft reports discuss "mixed waste" constituents
presently remaining on the Site. EPA has recently announced
their intent to delegate "mixed waste" authority under RCRA to
this Department. However, mixed waste delegation does not apply
to naturally occurring radioactive materials (NORM), such as the
radium contaminated hazardous wastes at the Radium Chemical Site.
Thus, it is recommended that EPA avoid using the term, "mixed
wastes" when referring to hazardous wastes also contaminated by
NORM. The reports should also discuss the disposal of explosive
materials (ether) found at the Site.
Thank you for the opportunity to comment on these reports.
If you have any questions, please contact Dr. Paul J. Merges,
Director, Bureau of Radiation at:
NYS Department of Environmental Conservation
Division of Hazardous Substances Regulation
Bureau of Radiation
50 Wolf Road, Room 510
Albany, New York 12233-7255
(518) 457-2225
Sincerely,
R. Darryl Banks
Deputy Commissioner
cc: Dr. Paul J. Merges
Ms. Janet Cappelli
Remedial Project Manager
U. S. Environmental Protection Agency
Jacob K. Javits Federal Building
Room 29-100
New York, NY 10278
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APPENDIX IV
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
RADIUM CHEMICAL COMPANY
W OODSIDE, NEW YORK
MAY 1990
This document »ai published for the U.S. Environmental Protection Agency (EPA) by Roy F. Weiton.
inc. (WUSTON) under ARCS Contract No. 68-W9-0022, Work Alignment No. 007-2L3H. It it a
compilation of poniom of the May 1, 1990 public meeting transcript (Document Control No. 4200-
07-AAPI). a draft question and answer information sheet reflecting questions asked and answers
provided at the May 1. 1990 public meeting (Document Control No. 4200-07-AAPK). • draft question
and answer information sheet reflecting questions asked and answers provided at the May 1, 1990
meeting with area businesses (Document Control No. 4200-07-AAPJ), the Proposed Remedial Action
Plan (Document Control No. 4200-07-AAOJ), and a Congressional inquiry (Document Control No.
4200-07-AAQX) and corresponding EPA response (Document Control No. 4200-07-AAQY).
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RESPONSIVENESS SUMMARY
RADIUM CHEMICAL COMPANY
WOODSIDE, NEW YORK
A. OVERVIEW
This Responsiveness Summary includes 1) information on the
site background (Section B), 2) an explanation of the
proposed and selected alternatives (Section C), 3) a summary
of the comments received during the public comment period and
Agency responses (Section 0) , and 4) the remaining concerns
(Section E).
B. SITE BACKGROUND
The Radium Chemical Company (RCC) Site is located at 60-06
27th Avenue in Woodside, Queens, New York. The Site consists
of a one-story building bordered on the west by 27th Avenue
and on the east by the Brooklyn-Queens Expressway (BQE) , a
major urban highway. The area surrounding the Site is
classified as a light commercial/industrial sector. A Health
Fitness Club is located within 100 feet of the Site and
numerous pedestrians pass the Site fence and building daily.
Vehicular traffic is very heavy along 27th Avenue, a primary
access route to the BQE.
The RCC building is approximately 10,000 square feet in size;
7,220 square feet of which encompassed the Radium Chemical
Company. The Solux Company occupies space in an adjoining
part of the building. The Radium Chemical Company and Solux
facilities share a common wall within the building, and some
of the Solux floor space at one time was leased to Radium
Chemical.
The RCC Site and the surrounding population within a 3-mile
radius obtain drinking water from the New York City municipal
system, which comes from surface impoundments 10 miles from
the Site. The ground water underlying the Site is very
shallow at 5 - 10 feet, but is not used as a drinking water
supply. The nearest drinking water well is 6 miles from the
Site. The nearest surface water body to the Site is the East
River, over 1.5 miles away. The nearest residence is located
500 feet from the Site. It is estimated that 27,000 people
reside in high rise apartments and row houses within a 1-mile
radius of the Site.
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RCC was founded in New York in 1913. The company initially
produced luminous paint for watch dials, and instruments."
Later, the company manufactured, leased and sold radium-226
in the form of radiation therapy and radiographic sources to
hospitals, medical centers, and research laboratories.
Sources were also leased or sold in limited quantities to the
oil-industry for geophysical logging. In the late 1950s, RCC
transferred its operations to the present location in
Woodside, New York. The radium and radon devices were stored
on-site in lead containers in a concrete vault room.
Eventually the demand for radium sources lagged as they were
replaced with advanced radiation therapy techniques using
cesium and cobalt sources. Subsequently, many leased radium
sources were returned to RCC and were stored on-site.
In 1983, the State of New York suspended the RCC operating
license due to various disposal and safety infractions. RCC
attempted to get permission to begin operations again in 1986,
but was denied. The New York State Department of Labor issued
an Order against RCC on October 17, 1987, for the removal of
the radium sources and decontamination of the building. The
owner was unable to finance the remediation and, subsequently,
abandoned the building. This resulted in a second Stipulation
and Order, issued on July 20, 1988, determining that the
facility could not be maintained and that it was de facto
abandoned by RCC. Remaining on-site were a large number of
radium-containing sealed devices, some of which were suspected
of releasing radium and radon gas. The amount of radium-226
at the Site was estimated, at the time, to be 110 Curies (Ci).
Also on-site were hundreds of containers of laboratory
chemicals, many of which were reactive, corrosive, flammable,
and/or potentially shock sensitive.
In July 1988, at the request of the State of New York, EPA
undertook a limited emergency removal action to secure the
facility and remove the radioactive sources. EPA provided
24-hour security, instituted a comprehensive program of public
outreach, and initiated measures to stabilize the Site. By
August 1988, EPA had erected fencing around the perimeter and
installed remote monitoring surveillance, a foam fire
suppressant system, special vents, and other safety measures.
In February 1989, EPA developed a support agreement with the
U.S. Army Armament, Munition, and Chemical Command to utilize
an existing contract with Chem-Nuclear Systems, Incorporated. ,
to remove the radium sources and other radioactive and
hazardous materials from the Site and transport them to
approved disposal facilities. The removal action was
completed in October 1989. Approximately 120 Ci of radium in
the form of sources, contaminated debris, and loose radiur.
salts and luminous compounds were removed from the Site. This
material was disposed of in facilities, operated by U.S.
-------
Ecology, Incorporated, located in Richland, Washington" and
Beatty, Nevada. * ,
On February 10, 1989, prior to the removal action described
above, the U.S. Agency for Toxic Substances and Disease
Registry (ATSDR) issued a Public Health Advisory to alert the
public, EPA, and the state of New York of a serious threat to
human health, based on 'the threatened release of radium-226
from the RCC site. EPA had requested ATSDR to perform the
assessment so that the Site would be recognized as a high
priority and be eligible to receive federal Superfund funding
for complete remediation. In an August 1989 special National
Priorities List (NPL) update, EPA proposed the RCC Site for
the NPL based on the ATSDR advisory. On November 21, 1989,
the RCC Site was added to the NPL.
Currently, the Site is inactive and secure. Residual
radioactive contamination exists within the facility. Also
inside the facility are two 55-gallon drums containing a small
volume of chemicals and a 30-gallon container of mercury that
had been used in RCC's manufacturing operations. These
chemicals were found to contain radioactive contamination and
are classified as radium-contaminated hazardous waste.
Radium decays to form radon gas and other decay products.
. Within tightly enclosed buildings, the danger exists for
potential build-up of radon gas above the standards set to
protect human health, representing a long-term exposure hazard
to people who live or work in the buildings.
C. SUMMARY OF PROPOSED AND SELECTED ALTERNATIVES
Although the removal actions to date have stabilized the Site
and reduced the immediate risk, it is now necessary to address
the long-term remediation of the Site. The Superfund law
requires each site remedy that is selected to be protective
of human health and the environment, cost-effective, and in
accordance with statutory requirements. Permanent solutions
to contamination problems are to be achieved to the maximum
extent practicable.
The remedial alternatives are:
Alternative 1: No Further Action
Alternative 2: Total Decontamination of Facility
Alternative 3: Complete Dismantling and Removal of
Facility
• Alternative 4: Partial Decontamination and Complete
Dismantling of Facility
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After detailed evaluation of" all alternatives, EPA has selected
Alternative 4:" Partial Decontamination and Complete Dismantling*
of the Facility as its preferred alternative. Under this
alternative, parts of the RCC facility would first be
decontaminated and then the entire facility would be dismantled.
The work would involve the partial decontamination of certain areas
in the facility in order to reduce the volume of radioactive
material requiring disposal. Since it is not possible to determine
the level of contamination in soils and sewer lines at this time,
this alternative would also include a site characterization survey
to further quantify the extent of contamination in soil and sewer
lines in the immediate vicinity of the Site. If contamination is
discovered below grade, the materials will have to be removed and
replaced with clean soils. If sewers are found to be contaminated,
they will require removal and replacement. All contaminated
material would be packaged in accordance with Department of
Transportation regulations and disposed of in an approved
out-of-state disposal facility.
The radium-contaminated hazardous waste presents a unique problem.
Certain constituents of the radium-contaminated hazardous waste
would be treated for their hazardous nature and disposed of as
radioactive waste at an approved waste repository. An attempt will
be made to temporarily store the remaining radium-contaminated
hazardous waste at an off-site location until such time as a
facility becomes permitted to accept it for disposal. If that
attempt to locate an off-site facility fails, the remaining radium-
contaminated hazardous waste will have to be secured and stored
on-site. It may be stored in the lease area portion of the
building while decontamination and dismantling efforts are
performed in other portions of the facility.
Based on current information, this alternative orovides the best
balance among the nine criteria used as a mea of evaluation.
Alternative 4 provides protection of human lealth and the
environment, while minimizing future costs ana problems. This
partial decontamination and complete dismantling option seems to
offer the best balance in time spent, volume of radioactive waste
generated, and overall costs. The volume of waste generated,
although greater than that of the decontamination option, is less
than that of the total dismantling option. This is an important
consideration, as the availability of disposal space for radium
contaminated material is expected to continue to decrease in the
future. After implementation of Alternative 4, the source for
radon generation will be removed and the site property will be
restored to a condition allowing unrestricted use.
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D. SUMMARY OF PUBLIC COMMENTS i AGENCY RESPONSES
D-l. SUMMARY OF QUESTIONS RAISED AT MEETING HELD WITH AREA
BUSINESSES AND RESPONSES - MAY 1, 1990 AT 4:00 P.M.
A meeting was held with; the area businesses owners. ...Following
a brief introduction of the various EPA representatives by Rich
Cahill, Public Affairs Specialist, the Remedial Project Manager,
Janet Cappelli, explained the four alternatives in the Proposed
Remedial Action Plan (Proposed Plan), and the reasons why EPA is
recommending Alternative 4, Partial Decontamination and Complete
Dismantling of the Facility. Concerns raised by area business
owners and managers following her presentation included the
following:
1. Is there a potential threat to our ground water?
EPA Response: EPA would not expect to find any ground water
contamination. EPA tested the soil to 24 inches and found
radioactive contamination in only the first six inches of
soil. The groundwater is at least ten feet below the
surface.
2. Why is EPA proposing to dismantle the entire building?
EPA Response: A full decontamination of the building would
likely damage the structural integrity of the building and
require reinforcement. Leaving the building standing would
also require EPA to perform continuous monitoring.
Dismantling would ensure that all radioactive materials are
taken off the site and would alleviate the need for
monitoring. The remedy may be modified if EPA discovers new
information when on site during the cleanup process.
3. An area business owner asked why he had not received results
from the air monitoring that was conducted during the
removal phase.
EPA Response: Shawn Googins, EPA, is in the process of
preparing a full report that will document that information.
Although the air monitoring report is not part of the
Administrative Record, it shall be placed, along with the
Administrative Record, at the repositories which are located
at the Woodside Branch Library and Sunnyside Branch Library.
Preliminary analysis of monitoring results shows that all
samples collected were within background limits.
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4. Is Shawn Googins still on the project?
EPA Response; Not directly. However, he will be involved
in a consultative capacity.
5. ... What were the purposes of the ambulances [seen.around the
site last Friday, 4/27]?
EPA Response; On that date, EPA entered the RCC facility
to check on site conditions. The presence of the ambulance
was requested by the New York City Department of Health as
a precautionary measure. During the remedial action,
ambulances may be on a stand-by basis for emergencies,
primarily construction injuries.
6. Is there still gamma radiation in the building?
EPA Response; Yes, along with beta and alpha radiation.
7. Will dust release be controlled during the remedial action?
EPA Response; Yes, EPA plans to institute a comprehensive
method of dust control. This includes an attempt to limit
all contamination to the interior of the building. One of
EPA's contractors, Ebasco Services, Inc., is preparing
specifications documenting how the remedial (cleanup)
contractor will contain contamination within the building.
High-efficiency particulate air (HEPA) filters on the
building roof will constantly be running while workers are
in the building. The HEPA filters will establish negative
pressure inside the building, thus containing the
contamination within the building. Dust suppression will
also be maintained by the use of dust vacuum cleaners and
water misting during all dismantling activities.
8. Will the "envelope" of contained radioactivity be broken as
the building is dismantled?
EPA Response; An envelope of radioactive containment will
be formed by the use of the HEPA system which creates a
negative pressure preventing outward flow of air. The
envelope will only be broken after all decontamination
efforts are completed.
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9. How is traffic going to be handled?
EPA Response: Traffic will be rerouted to minimize
disruption to the community. During the remedial action
phase, the traffic will probably be xerouted as it was
during the removal action, by preventing traffic flow
..-directly alongside, the site. EPA will try to prevent
traffic from moving through the BQE Racquetball Club parking
lot. EPA is open to suggestions from the area businesses
for further traffic control measures.
10. Who will assume liability if someone gets hurt walking
through the parking lot that separates Humiseal from the BQE
Racquetball Club?
EPA Response; Liability for incidents in the parking lot
rests with the property owner, Humiseal.
11. Shouldn't the New York City Traffic Department be
represented at these meetings?
EPA Response: Terry Hamilton, New York City Traffic
Department, will be invited to attend future meetings. EPA
has already contacted him regarding the rerouting of traffic
for the remedial action.
12. What is the range of danger now?
EPA Response; The emergency removal action removed the
greatest source of radioactivity at the site, namely the
radium sources. Measurements taken after the removal action
was completed indicated the levels of radiation to be
substantially reduced. However, there exists levels of
radiation within the site, attributable to the residual
radioactive contamination, which are still above acceptable
health-based limits.
13. What disposal site will be used to receive the radioactive
waste removed from the site?
EPA Response; The radioactive waste will be transported to
a disposal site in Clive, Utah licensed strictly to handle
naturally occurring radioactive material (NORM). This is
the only facility in the country presently licensed tc
accept this type of waste. It is operated by Envirocare cf
Utah, Incorporated.
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14. What is the project timetable? ..
EPA Response: It is estimated that Alternative 4, Partial
Decontamination and Complete Dismantling of the Building,
will take a maximum of two years to complete. However, the
project is targeted for completion in one year.
>••• •• "•- •'.'. '• -or...
Public comments on the Proposed Plan will be received
through May 13, 1990. A remedy will be selected in June and
funds for the remedial action will be transferred to the
U.S. Army Corps of Engineers (which is responsible for
selecting the remedial contractor) by June 30, 1990. The
remedial action will then be initiated in July 1990. Actual
on-site presence by the remedial action contractor and the
U.S. Army Corps of Engineers will most likely not occur
until late August 1990.
15. How much did the removal action cost?
EPA Response; The removal action was initially budgeted at
$5 million. The actual cost was approximately $4.3 million.
D-2. SUMMARY OF QUESTIONS RAISED AT PUBLIC MEETING ON MAY 1, 1990
AT 7:30 P.M. AND RESPONSES
A public meeting was held on May 1, 1990 at the Bulova Corporate
Center. (See Appendix A for the agenda). Questions raised by
the public and the EPA responses follow.
1. Who retains title to the land (the Radium Chemical
property)?
EPA Response; The title will remain in the owner's name,
Joseph Kelly Jr., but EPA will be placing a lien on the
property. New York State has issued an order which found
the site property to be de facto abandoned, which may
relinquish Mr. Kelly's property right.
2. What is being done to limit the use of the property?
EPA Response; EPA is proposing to clean up the property
completely. Once that is done, the property will be
available for unrestricted use. Imposing limits on uses of
real property, i.e. institutional controls, is the
responsibility of local government and beyond EPA's control.
8
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3. Can Mr. Kelly have access to the site property? ' .
*• *
EPA Response; New York State has an order against Mr. Kelly
finding that he abandoned his property. With respect to
the site, Mr. Kelly was ordered not to interfere with any
remedial efforts that any agency shall make on that
v. property. Therefore, he cannot go back onto the property
during the remedial action.
4. IB Joseph Kelly being investigated under Federal lav?
EPA Response; Yes, EPA is presently investigating the
financial assets, if any, of Mr. Kelly.
5. Why isn't Mr. Kelly in jail? (Citizens expressed concerns
with the threats left to the community by Mr. Kelly)
EPA Response; The EPA planned remedial action is a civil law
action. EPA cannot comment on the existence, nature, or
extent of any criminal law investigation in the context of
this action.
6. Where is the waste from the site going to be taken?
EPA Response; It is EPA's intent to dispose of these
materials in a facility located in Clive, Utah operated by
Envirocare of Utah, Incorporated. The Utah facility is the
only facility that can accept the kind of radioactive waste
generated by the Radium Chemical Company site.
Specifically, the waste type is naturally occurring
radioactive material.
7. . How will the waste be transported? What kinds of routes are
used?
EPA Response; EPA is working very closely with the New York
City Police Department and the New York City Department of
Transportation to ensure that any transportation will be
done in a safe manner. The best route of transportation,
one that will minimize any risks to the community, will be
used. The transportation routes for the removal were
thoroughly investigated to ensure as minimal an impact to
the community surrounding the site as possible. Those
routes proved effective and therefore the same routes for
transportation out of the city will likely be used for the
remediation.
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Additionally, the U.S. Department of Transportation CUSDOT)
regulates the cross-country transportation of ra'dioactive
waste. USDOT also requires the waste to be packaged
according to specific guidelines. The waste from this site
will probably be transported by truck.* There are certain
specifications on how much waste can be put into each truck,
... what the levels of ..radiation at a certain distance from the
truck must be, and the routes that can be used. These
routes are designed to pass by the fewest number of
residences as possible.
8. A member of the public expressed concern because the site
is in a very populated area, and the BQE is a very heavily
congested public thoroughfare.
EPA Response; EPA will not transport the waste during rush
hours or during normal business hours. Transportation of
hazardous materials will be done during the hours with the
least amount of traffic.
One of the advantages of the site is its close proximity to
a major highway. To the degree possible, it is EPA's
intention to try to avoid going through residential areas.
The specific routes have not yet been determined, but
discussions have been initiated with the Department of
Transportation and the New York City Police Department.
9. Is the City doing anything because, according to the video
shown at the public meeting, Mr. Kelly is still receiving
cash flow from the Company?
EPA Response; This is not occurring any more. Everyone who
leased sources from the Radium Chemical Company was sent a
form letter stating that the lessees could not send the
sources back to Radium Chemical since the Company is no
longer in business. Those leasing could either purchase and
take full responsibility for the sources (needles) , or
dispose of them and send EPA the manifest showing exactly
how and where the sources were disposed of to ensure correct
procedures were followed.
10. Was gold stolen from this facility? What has happened to
the gold that was stolen from the Radium Chemical Site?
EPA Response; Gold was stolen from the Radium Chemical
Company in 1978. By the time Radium Chemical realized the
gold was missing, it was too late for them to track it. The
location of the gold is not known.
10
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11. Is the gold that is potentially being sold in the New York
area being checked for radioactivity?
Response [According to a representative from Assemblyman
Lafayette's Office]: State law require.s that all gold be
tested for radioactivity prior to its distribution.
EPA Response; The regulation of the gold is beyond the
scope of EPA.
12. Has any checking been done on the health of the people who
worked at Radium Chemical Company?
EPA Response; The New York City Department of Health
(NYCDOH) is checking up on the people who have worked at the
Company and are currently living in the New York City area.
NYCDOH sent them letters informing them of the situation and
asking them if they would like to be tested and/or have
their homes tested. The New York State Department of Health
(NYSDOH) is doing something similar. EPA has also
identified three past employees who live in the State of New
Jersey. EPA and NYSDOH are currently communicating with the
State of New Jersey regarding similar follow-ups.
D-3 ADDITIONAL WRITTEN COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD AND RESPONSES.
Several questions were raised regarding the storage of "mixed
waste" remaining at the site. Please note that although the
Proposed Plan identified hazardous waste contaminated by radium
as "mixed waste", the proper term for this waste is "radium-
contaminated hazardous waste". This is in response to comments
identifying that "mixed waste" only applies to radionuclides
governed under the Atomic Energy Act (AEA) , which does not govern
radium-226.
EPA's response to questions referring to "mixed waste" are
answered by substituting "radium-contaminated hazardous waste".
1. Could you explain what the nature of the attempt to
temporarily store the remaining radium-contaminated
hazardous waste at an off-site location will be?
EPA intends to remove the radium-contaminated hazardous
waste from the site as soon as possible. EPA's ability to
do so is dependent upon the availability of a facility which
is licensed and permitted to accept such wastes. New York
State is presently reviewing a permit application submitted
by the Nuclear Diagnostic Laboratories, Incorporated
11
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facility, located in Peekskill, New York, for temporary
storage of radium-contaminated hazardous waste." We are
identifying the means available for transporting the radium-
contaminated hazardous waste to these facilities in hopes
that they will soon be permitted.
• .*••• '• '•• '••'. •• '• *••„.
2. What are the difficulties in locating such a site?., what is
the likelihood of locating such a site?
The Environmental Protection Agency is responsible for
ensuring that the hazardous and radioactive components of
the radium-contaminated hazardous waste are disposed of
properly. In order for a commercial facility to dispose of
radium-contaminated hazardous waste, it must first receive
a permit under RCRA for disposal of radium-contaminated
hazardous waste as well as the state. Since the AEA does
not govern radium, the Nuclear Regulatory Commission's
authority does not extend to the disposal of radium-
contaminated hazardous waste.
Presently, no facility in the United States is fully
approved to accept radium-contaminated hazardous waste on
a temporary or permanent basis. However, the NORM
waste repository operated by Envirocare of Utah,
Incorporated, located in Clive, Utah, is in the process of
applying for a permit which will allow the facility to
accept radium-contaminated hazardous waste for burial. A
spokesman for Envirocare of Utah, Inc. indicated to us that
his facility will be permitted by December 1990. The
disposal cell necessary to bury the radium-contaminated
hazardous waste is already under construction, so that upon
issuance of the permit, the facility will be ready
immediately to accept radium-contaminated hazardous waste.
In addition, New York State, as discussed above, is
reviewing an application for a temporary storage facility
in Peekskill, New York.
3. If the attempt fails, how will the remaining radium-
contaminated hazardous waste be secured and how will it be
stored on-site?
The remedial action selected in the Record of Decision is
expected to begin in July 1990. The radium-contaminated
hazardous waste currently in the Radium Chemical facility
will be secured in the lease area portion of the building
while remediation efforts are conducted in other porticr.s
of the building. The entire remediation is expected to te
completed within two years. The removal of the radiu--
contaminated hazardous waste is an integral part of the
selected remedy for the site, and as such, the remediation
12
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would not be considered to be complete until the ''radium-
contaminated hazardous wastes are removed from the sit£.
If necessary, the radium-contaminated hazardous waste will
be stored in a portion of the building that is free of
contamination and completion of the remediation will be
delayed until the radium-contaminated hazardous waste can
v. be transported off;-site. In the absence of a^. permitted
facility, EPA has no option but to allow the radium-
contaminated hazardous waste to remain secure on-site until
such a facility for disposal is found.
4. What is the level of difficulty in securing the permit for
such a disposal? What is the likelihood of a permit being
granted?
Both license and permit applications require description of
the manner and condition of disposal; evaluation of
pertinent environmental information; usage of ground and
surface water in the area; public interaction, etc.
Difficulties which arise in siting RCRA disposal facilities
are often related to environmental conditions, land use and
lack of acceptance by members of the public in the vicinity
of the site.
13
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APPENDIX A
PUBLIC MEETING AGENDA
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Documen.c Concrol
-:OO-O:-.\ARA
'U.S. "ENVIRONMENTAL PROTECTION AGENCY ACTION
at the
Radium Chemical Company Site
60-06 27th Avenue
Woodside, Queens
PUBLIC MEETING
Bulova Corporate Center
Tuesday, May 1,1990
7:30 P.M.
AGENDA
Introduction
An Overvieiu of the Superfund
Program
Site History, Removal Action,
and the Proposed Remedial
Action Plan
Questions and Answers
Rich Cahill
Public Affairs Specialist
Environmental Protection Agency
George Pavlou
Associate Director
New York Superfund Programs
Environmental Protection Agency
Janet Cappelli
Superfund Project Manager
Environmental Protection Agency
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APPENDIX B
PUBLIC MEETING AND PRE-MEETING
SIGN-IN SHEETS
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PUBLIC MEETING REGISTRATION
Radium Chemical Company Superfund Site
Bulova Corporate Center
May 1,1990
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PUBLIC MEETING REGISTRATION
Radium Chemical Company Superfund Site
Bulova Corporate Center
May 1,1990
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^"-"PUBLIC MEETING REGISTRATION
Radium Chemical .Company Superfund Site
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May 1,1990
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