PB94-963844
                                 EPA/ROD/R02-94/239
                                 March 1995
EPA  Superfund
       Record of Decision:
       Radiation Technology Incorporated
       (O.U. 1), Rockaway Township, NJ
       5/09/1994

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                             DECLARATION STATEMENT

                              RECORD OF DECISION

                    RADIATION TECHNOLOGY INCORPORATED (RTI)
Site Name and Location

Radiation Technology Incorporated (RTI)
Rockaway Township, Morris County, New Jersey

Statement of Basis and Purpose

This decision document presents  the selected  remedial action for ground water
contamination at the Radiation Technology Incorporated site, which was chosen in
accordance  with the Comprehensive  Environmental Response,  Compensation,  and
Liability Act of 1980, as amended  by the Super fund Amendments and Reauthorization
Act of  1986,  and, to the  extent practicable, the National  Oil  and Hazardous
Substances  Pollution  Contingency  Plan.    This decision  is  based  on  the
administrative record for the site.

The U.S. Environmental Protection Agency,  concurs with the selected remedy.

Assessment of the Site

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

Description of the Selected Remedy

The remedy presented in this document addresses the current and future threats
to human health and the environment associated with the contaminated ground water
at the Radiation Technology Incorporated site.  It provides for the restoration
of the contaminated ground water to the more  stringent of the federal and New
Jersey Safe Drinking Hater Act Maximum Contaminant Levels  (MCLs) and the New
Jersey Ground Water Quality Standards.   The need for remediation of contaminant
sources will be addressed in a subsequent  decision document.

The major components of the selected remedy include:

            Restoration of  contaminated ground water to the more stringent of the
            federal and  New Jersey MCLs and  New Jersey Ground  Water Quality
            Standards/ through extraction of the more highly contaminated ground
            water   and   natural  attenuation   of    residual   ground   water
            contamination.

            Treatment of the extracted ground water to levels attaining the more
            stringent of the federal and New Jersey MCLs and New Jersey Ground
            Water Quality Standards;

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            Reinjection of the treated ground water, and

            Appropriate environmental monitoring to ensure the effectiveness of
            the remedy.

Statutory 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 technologies to the maximum extent
practicable and  satisfies the  statutory preference for  remedies  that employ
treatment that reduces toxicity, mobility,  or volume  as  a  principal element.
Subsequent actions may be necessary to address  contaminant sources at the site.

Because this remedy will  result in hazardous  substances remaining on site, above
health-based  levels,   a  review  will be conducted within  five years  after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Robert C. Shinn, Jr.
Commissioner

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                         DECISION SUMMARY
                        RECORD OF DECISION
             RADIATION TECHNOLOGY INCORPORATED (RTI)


SITE NAME, LOCATION, AND DESCRIPTION

The Radiation Technology Incorporated  (RTI) site is situated in the
western portion of Morris County, New Jersey, at 108 Lake Denmark
Road in Rockavay Township (see Figure  1.1).  Rockaway Township has
a population of approximately 20,000 people.  The next closest town
to the site  is Denvilie,  which has a population of approximately
14,000.   Additional population centers in close  vicinity of the
site (less than 5 miles radius)  include Boonton Township, Rockaway
Borough, Dover Township,  and Wharton  Borough.   Although no large
population center is adjacent to the  RTI site,  it is immediately
northeast of the  U.S.  Military Picatinny Arsenal facilities, and
directly northwest of Lake Telemark, a small residential community.

The  area around  the  RTI  site  is  generally  rural  in  nature.
However,  there has been significant residential  and  industrial
development in the region.   To the west of the site,  significant
heavy industrial activities have been  ongoing at the Army and Navy
portions  of  the Picatinny  Military Arsenal facilities  since at
least the 1920s.  Areas to the east of the RTI site consist mainly
of  single-family  residences  situated in the population centers
mentioned previously.    Present  land use  in the  RTI study area is
generally considered light industrial.

The RTI site is located within the New Jersey Highlands, which is
part  of  the  Reading  Prong  of  the New England  physiographic
province.  In general,  the regional topography is characterized by
northeastward trenching  ridges  and parallel valley features with
interspersed lakes.  The ridges may reach elevations of 1,000 feet
or more above Mean Sea  Level (MSL)  and lowland valleys may drop to
elevations of 600 feet or less above MSL.

The  topography  associated  with  the New Jersey  Highlands  is
controlled mainly by the structure and lithologic character of the
bedrock.  In general,  the ridges tend to be developed on the more
massive and resistant bedrock and the valleys on the less resistant
bedrock.

To varying degrees,  the topography presently shows the effects of
Pleistocene  glaciation.   A  terminal moraine  of the  Wisconsin
glacial stage is situated in the central part of Morris County, New
Jersey.  The terminal moraine forms a belt which is approximately
two to three miles  wide and  is  roughly  parallel  to the Rockaway
River.  In general, north  of the terminal moraine the topography is
moderately rugged and the bedrock is usually well-exposed, except
in  the  valleys.  South of  the terminal moraine*  the  topography

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reflects  terrain typically  associated with glaciation—valleys
filled with alluvium and sparse rock exposures.

For  the entire  263 acres  owned by RTI,  elevations  range  from
approximately  950 feet above  MSL on  a  ridge southeast  of  Lake
Denmark road to  about  822  feet above MSL along the banks of Lake
Denmark.

The  entire RTI  site  consists of  263 acres of  land which  is
comprised  of three  distinct areas:   The active  RTI complex, the
former  Rockaway  Industrial Park  (RIP)  and  undeveloped land (see
Figure  1.2).   The active RTI complex is  a 15-acre parcel of land
west of Lake Denmark Road on which RTI's industrial operations and
facilities are located.  The former RIP is an inactive, partially
developed  65-acre area situated east of Lake Denmark Road and the
active RTI complex.  The remaining 183 acres are undeveloped land
located primarily north  and south of  the active RTI complex and
former  RIP.  Background  investigations of historical records and
surveillance of this undeveloped land did not identify any areas of
potential  discharge or dumping.   Therefore,  this area  was not
included as part of the  study  area.   Remedial investigative work
was performed at the active RTI complex (15 acres) and the former
RIP  (65 acres), thus these two areas are known as the study area.


SITE HISTORY AND ENFORCEMENT ACTIVITIES

The chronology of ownership for the site is:
           1941 to 1963, Reaction Motors,  Inc.;
           1963  to  1972,  Reaction  Motors  Division of
          Thiokol Chemical Corp; and,
           1972 to Present,  RTI, Inc.

Past activities  of  Reaction Motors/Thiokol  included testing and
development  of rocket engines and  prope11ants.   RTI's  present
operation  involves  low-level irradiation of cosmetics and medical
products.

During the period of November 1980 and  May 1981,  The Department of
Environmental  Protection  and   Energy  (DEPE)  and  the  Rockaway
Township Health Department  conducted various inspections of the RTI
site.   DEPE also conducted investigations into the chemical types
and  quantities,  waste  disposal practices  and chemical  waste
characteristics   associated    with    various   production   and
manufacturing processes used at the site.

In March  1981, the Rockaway Township  Health Department informed
DEPE that  it had tested  two principal  water supply wells on site
due  to  taste and odor complaints from some  RTI employees about
untreated  drinking  water on site.   Both wells  were  found to be
contaminated  with  volatile organic  compounds  (VOCs)  and  were
condemned  by the Health Department in June 1981.

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As a result of DEPE's investigations, an Administrative Order and
Notice  of  Prosecution were issued  to RTI  on August  27,  1981,
ordering RTI to  properly remove and clean  up  all spills, buried
wastes  and improperly  stored waste  materials.   DEPE  issued  a
directive to RTI in November 1981 which stated  that its activities
had contaminated the  shallow ground water  table  with VOCs.   The
directive  further  mandated  that  RTI  hire  a  hydrogeological
consultant to determine the degree and extent of the contamination.

In December 1981, RTI  responded to DEPE's directive and disclaimed
responsibility for the ground water contamination associated with
the site.  As a result of RTI's failure to comply with the various
enforcement and  administrative actions  issued by the  DEPE,  the
Department  filed a verified  complaint  in  March 1982  with  the
Superior Court of New Jersey, Chancery Division, Morris County.  In
settlement of the verified complaint, RTI and DEPE entered into a
Consent Order in July  1983 under which  RTI was  required to install
six ground water monitoring wells on site.

Subsequent  to  the Consent  Order,  six  monitoring  wells  were
installed by RTI in September and October of 1983.  .In September
1983, the  RTI  site was  proposed for  inclusion  on the National
Priorities List  (NPL) of Superfund sites.   In August 1984,  DEPE
issued a Site Evaluation Report with the objective of identifying
sources  of ground  water contamination at and  around  the  RTI
property.  The results of the well sampling  and analysis indicated
that elevated levels of VOCs were present in the samples analyzed.
Subsequently, the RTI site  was  included on the NPL  in September
1984.

In May 1986, DEPE solicited proposals from contractors to perform
a remedial  investigation/feasibility  study (RI/FS)   for  the  RTI
site.   DEPE issued RTI   a  directive in June  1986  outlining the
findings of DEPE site investigations to date and requiring RTI to
pay costs associated with the performance of the RI/FS.  In March
1987, RTI entered into an Administrative Consent Order  (AGO)  with
DEPE requiring  the company  to pay  for Phase  I of the  RI to be
performed by a DEPE contractor.  In August 1987, DEPE's contractor,
Acres International Corporation, initiated the RI/FS.

In addition  to the RI/FS,  other surveys and  remedial  work  were
performed.  Radiological surveys were conducted within the 15-acre
RTI site  under Nuclear Regulatory  Commission  (NRC)   supervision.
RTI is licensed by the NRC to possess and use cobalt-60 and cesium-
137, both of which NRC regulates pursuant to the Atomic Energy Act.
Remediation of  all radiologically contaminated soil  areas found
during the surveys  was completed by  RTI under NRC  direction in two
stages during August  1990 and February 1991.   Presently, NRC is
requiring RTI to monitor ground water through 1995 for radioactive
contamination.   This  data will be submitted to .DEPE  and EPA for
evaluation.   NRC  and DEPE  investigative work to  date  has  not
indicated the presence of any radiological contaminants exceeding

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state and federal ground water standards.

Additional  removal  actions  were  conducted  by  RTI  under  the
direction of DEPE.  During July 1990, a leaking underground storage
tank containing solvents was  excavated  and  later  disposed of off
site.  Also, RTI performed an interim removal action in Hay 1993,
which included tanks, drums, contaminated soil and sumps, under a
separate Memorandum of Agreement  (MOA) with DEPE.

In December 1992, RTI and Thiokpl Corporation entered into an AGO
to reimburse DEPE  for the remainder of the RI/FS  and to conduct
design and remedial activities for contaminated ground water with
DEPE oversight.


HIGHLIGHTS OF COMMUNITY PARTICIPATION

A Community Relations Plan  (CRP) was developed to ensure the public
opportunities for involvement in site-related decisions, including
site  analysis  and  characterization,  alternatives  analysis,  and
remedy selection.  In addition, the CRP was used by DEPE and EPA to
determine,  based on  community  interviews,  activities to ensure
public involvement and to provide opportunities for the community
to learn about the site.

A meeting  was held  in May 1987  to provide residents and local
officials with an update  on past  activities  and to  inform the
public of current and future activities planned for the site.

The RI/FS reports,  which addressed the ground water contamination,
were released  to the  public in July 1993.   A Proposed Plan, that
identified  EPA's  and DEPE's preferred  remedial alternative, was
also released  in July 1993.  The documents were made available to
the  public  at an  information repository maintained  at  Rockaway
Township Public  Library.   A public comment period was  held from
July 30 through September 27, 1993.  A public meeting was held on
August  11,  1993, to  present the findings  of the RI/FS  and the
Proposed Plan,  and to solicit public comment.   A  notice of the
public comment period and public meeting was published in the July
30,  1993  edition of  the  "The Record"  (Morristown).   The issues
raised at the public meeting and during the public comment period
are addressed in the Responsiveness Summary, which is part of this
Record of Decision  (ROD).


SCOPE AND ROLE OF ACTION

This ROD presents the selected ground water remedial action for the
RTI site, chosen in accordance with the Comprehensive Environmental
Response, Compensation,  and Liability  Act  of  1980  (CERCLA),  as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA),  and,   to  the  extent  practicable, the  National  Oil and

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Hazardous  Substances Pollution  Contingency Plan  (NCP)  and the
Industrial Site  Recovery Act, P.L.  1993,  c. 139  (S-1070).   The
selection  of the  remedy  described  in  this ROD  is  based  upon
documentation comprising the administrative record.

This  document  solely addresses  remediation of  the  contaminated
ground water at the RTI  site.  Potential  ingestion of contaminated
ground water at  the  site presents  a  risk to human health because
DEPE's  and  EPA's  acceptable  risk  range  is  exceeded  and the
concentrations of various contaminants in ground water exceed State
Ground Water Quality Standards  (NJAC  7:9-6)  (GHQS)  and federal
Maximum Contaminant Levels (MCLs).  Remedial alternatives have been
developed which  address  contaminated ground water and focuses on
the  protection  of  human  health and  environment.   Information
obtained during  the Phase  I  and II Remedial  Investigation also
identified potential source areas of  contamination,  i.e. soils,
sumps, tanks and drums.   As  previously noted,  RTI  performed an
interim  removal action  to address  potential  source areas  of
contamination to meet DEPE's current non-residential requirements
for  polychlorinated  biphenyls and  inorganic compounds  in soil,
while VOC  levels in the soil were below state  action levels for
remediation.   The  need  for any further remedial action in the
source areas will be addressed under a separate ROD.


SUMMARY OF SITE CHARACTERISTICS

The RI for the study area was  conducted in three phases.  During
1987,  the  Phase I  RI  concentrated  on the  15-acre  active RTI
complex.  The Phase II RI included the 65-acre former RIP as well
as the active RTI complex and was conducted in 1989 and 1990.  Data
gaps  were  identified in  the RI  report by  DEPE  and  provided the
basis for a supplemental Phase II investigation conducted in July
1992.

The  study  area  is  located within two  sub-basins of  the Rockaway
River drainage basin.  Most of the study area to the east of Lake
Denmark Road, including most of the former RIP,  drains to the  south
and is in a drainage basin that includes  Lake Telemark, Lake Ames,
and Beaver Brook. The study area to the west of Lake Denmark Road,
including the active RTI  complex,  drains to the west and is in a
drainage basin which includes Lake  Denmark, Lake Picatinny, and
Green Pond Brook.

From a geologic perspective, the study area is underlain by three
lithologic units: glacial till, saprolite and crystalline bedrock.
Ground water is present  within two  distinct  hydrostratigraphic
units:  the glacial till/upper saprolite   (overburden) and bedrock
units, referred to as the  overburden water bearing zone and bedrock
aquifer, respectively.

The overburden water bearing zone is  a  shallow unit limited to the

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active RTI complex and the extreme southern portion of the former
RIP.  A bedrock aquifer is present throughout the entire study area
and  locally  serves  as  the  source  of  water for domestic  and
industrial veils.  Horizontal  flow direction  varies according to
the geohydrologic  basin—two  such basins exist at  the  RTI site.
Ground  water recharge   zones  are  present in areas  of  higher
elevation.   Ground water discharge  occurs in proximity  to Lake
Denmark and adjacent wetlands or to the on-site intermittent stream
which flows to Lake Telemark.

Contamination is present  in  both the  overburden water bearing zone
and  bedrock  aquifer.    Concentrations  of   volatile  organic,
semi-volatile and inorganic compounds exceed state GWQS and federal
MCLs.  The ground water is classified as  Class IIA and the primary
designated use for this class is potable water.  Results of both RI
phases confirm that contamination in the overburden water bearing
zone is variable and  localized,  creating a sporadic distribution
pattern.

The VOCs detected in the overburden water bearing zone with maximum
concentrations above  the state GWQS and  federal  MCLs  included:
acetone;  1,1,1-trichloroethane  (1,1,1-TCA);   1,1-dichloroethane
(1,1-DCA);   1,1,2-trichloroethane   (1,1,2-TCA);   trichloroethene
(TCE);  l,1-dichloroethene  (1,1 DCE);   tetrachloroethene   (PCE);
carbon  tetrachloride;  chloroform; and,  methylene  chloride (see
Table 1.1) .  Bis(2-ethylhexyl)  phthalate was the only semi-volatile
organic compound detected at  levels  above state GWQS and federal
MCLs.  Lead and  chromium  (total) were detected sporadically  in the
overburden water bearing zone at 18 micrograms per liter (ug/L or
parts per billion)  and  167 ug/L, respectively, marginally above
state GWQS (5 ug/L and 100 ug/1) and  federal MCLs (15 ug/1 and 100
ug/L).

In general, the bedrock aquifer exhibited higher levels of ground
water  contamination  than  the  overburden  water  bearing  zone
primarily due to halocarbons (see Table 1.2).   During the Phase I
RI, VOC contamination was found in every bedrock well.  The total
VOC concentrations ranged from 1 ug/L to 2,003 ug/L.   Aside from
acetone,  the primary contaminants   were 1,1,1-TCA, TCE,  carbon
tetrachloride and the degradation products of these compounds.

Due to  the  installation  and sampling of additional wells during
Phase   II  RI,   the   horizontal  extent  area  of   ground  water
contamination was  defined.   Phase II RI results documented that
VOCs were the major contaminants  present in the  bedrock aquifer.
On the active RTI complex, halocarbons,  freons and acetone were the
primary VOCs present.  Total VOC concentrations ranged from  7 ug/L
to 7,600 ug/L.  TCE concentrations exceeded the 1 ug/L state GWQS
and 5 ug/L federal MCL; the maximum concentration detected was 140
ug/L.   The vinyl  chloride concentration in one well was 99 ug/L,
which  exceeded  the 0.08 ug/L  state GWQS.  Carbon tetrachloride
levels were over the  0.4 ug/L state GWQS.  Geographically, these

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contaminant groups are distributed from the active RTI facility to
the vest and south toward the RTI property boundary with Picatinny
Arsenal.  The highest concentrations are generally present within
the RTI active portion of the site, where the total concentration
of VOCs range up to an excess of 13,000 ug/L.  Freon, a Dense Non-
Aqueous Phase Liquid  (DNAPL),  is the most significant contributor
to this high concentration of VOCs.  Although the levels of freon
detected  at the  study  area  were  below health based  criteria
developed by DEPE consistent  with state GHQS, the  Department is
concerned    with    the    possibility    that    Freon-113
(l,l,2-trichloro-l,2,2-trifluoroethane)  exists  in  the  bedrock
aquifer in concentrations indicative of free product.

During the  supplemental  Phase  II RI performed during  July 1992,
packer  pump tests  were  performed  on  the  intake  portion of  a
formerly used production well behind the active RTI facility.  The
testing indicated that sufficient flow could be obtained from the
bedrock aquifer to  allow for installation of  a  ground water pump
and treatment system.

VOCs detected in the bedrock aquifer during the supplemental Phase
II RI with maximum concentrations above state GWQS and federal MCLs
included:   acetone;  1,1,1-TCA; 1,1-DCA; 1,1,2-TCA;  TCE; 1,1-DCE;
1,2-dichloroethylene   [total]   (1,2-DCE  [total]);  PCE;   vinyl
chloride; carbon  tetrachloride;  chloroform;  methylene chloride;
benzene;  and,   chlorobenzene   (see   Figures   1.1   and   1.2).
Bis(2-ethylhexyl)  phthalate and   2-chlorophenol were  the  only
semi-volatile organic compounds detected in the bedrock aquifer at
levels  above state  GWQS and  federal  MCLs.    Lead,  silver  and
aluminum  were  detected  sporadically in the  bedrock  aquifer at
concentrations marginally above the standards.

During the Phase II RI, five residential wells were sampled close
to the study area.  None  of  the wells exhibited contamination with
target  VOCs and  heavy  metals.     (One  exception  was the  lead
concentration in well RW-01 which was measured at 496 ug/L, above
the  5 ug/L state  GWQS.   However,  the lead   contamination  is
considered  to be non-site related because  the range of  lead
concentrations detected in bedrock wells on site were considerably
lower, 4.3 ug/L to 14.1 ug/L.  It should be noted that re-sampling
of RW-01  resulted in a  5 ug/L measurement.)   To reaffirm these
findings, another round of residential  well  sampling will  be
scheduled during the design phase.

The  analytical  results  for ground  water samples collected from
monitor veils located along  the abandoned railroad bed adjacent to
Lake Denmark were compared  to DEPE  and EPA  in-stream criteria to
evaluate the potential impacts of contaminated ground water on Lake
Denmark water  quality.   This criteria of evaluating potential
impacts of  contaminated  ground water on surface water bodies is
consistent with state GWQS.  Values for TCE (140 ug/L, 18 ug/L, and
91 ug/L)  and carbon tetrachloride  (87 ug/L, 4.8 ug/L, and 47 ug/L)

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exceeded the state and federal in-stream criteria of 1 ug/L and 2
ug/L, respectively.  Levels of chloroform (8 ug/L) and 1,1-DCE (27
ug/L) exceeded  the criteria of 6 ug/L and  5  ug/L,  respectively.
Concentrations  1,1,2-TCA (14 ug/L)  exceeded  the criteria  of 10
ug/L.  In MW-18D, 1,1,1-TCA  (150 to 240 ug/L) exceeded the criteria
of 30 ug/L.  The concentration of bis(2-ethylhexyl) phthalate (2782
ug/L) exceeded  the criteria  (2  ug/L) in one well only.   These
contaminant values, with the exception of chloroform, also exceed
state  remedial  surface  water discharge standards derived  from
DEPE's "Technical  Manual for Discharges to Surface  Water" (July
1993),

During the  Phase  II RI  surface water and sediment  samples were
taken in the Lake Telemark drainage area.  Surface water analyses
revealed the presence of the following metals: cadmium (11 ug/L),
copper (150 ug/L),  aluminum (3,253 ug/L), lead (158 ug/L) and zinc
(133 ug/L).  All levels exceed DEPE Surface Water Quality Criteria
with  the exception  of  aluminum for which  no criteria  exist.
Sediment samples showed lead in the  range of 6.3  micrograms per
kilogram (meg/kg or parts per billion) to 116 meg/kg and zinc, 28.4
meg/kg to 792 meg/kg.  Since the metals noted above were not part
of processes used  by businesses operating at the site nor found to
any great extent near source areas of other contamination on site,
these metals are not considered site related.

Sediment sampling  of Lake  Denmark was  conducted as part  of the
supplemental Phase II  RI to determine whether contaminants were
entering the lake.  Compounds detected included: 1,1 DCA; 1,2 DCE
(total);  2  butanone;  TCE;  Freon  113;   1,2,   dichloro-1,1,2
trifluoroethane; acetone; and, toluene.   Acetone and toluene were
detected at the highest concentrations of 1,600 meg/kg and 4,200
meg/kg,  respectively.    Since these  constituents  were  found in
monitoring wells on site and based on the direction of ground water
flow, it is believed that  ground  water  contamination is entering
the lake from the RTI site.
SUMMARY OF SITE RISKS

Based upon the results  of the RI,  a baseline risk assessment was
conducted to estimate the risks associated with current and future
site conditions.   The baseline risk assessment estimates the human
health  and   ecological   risk   which  could  result   from  the
contamination at the  site if  no remedial action were taken.  The
analysis assists in evaluating whether remediation is necessary.


HUMAN HEALTH RISK ASSESSMENT

The purpose  of performing a  Human Health Risk  Assessment  is to
evaluate  current  and  potential  threats posed by  uncontrolled
hazardous substance  releases.    A  four-step process is used for

                                &

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assessing site-related human health risks:

Hazard Identification - identifies the contaminants of concern at
the site based on  several  factors such as toxicity,  frequency of
occurrence, and concentration.

Exposure Assessment  - estimates  the  magnitude of actual and/or
potential  human  exposures, the  frequency and duration  of these
exposures,  and  the pathways  (e.g.,  ingesting  contaminated well
water) by which humans are potentially exposed.    The reasonable
maximum exposure (RME) is used as the highest exposure that could
reasonably be expected to occur for a given exposure pathway at a
site.

Toxicity  Assessment   -  determines the types  of adverse health
effects associated with chemical exposures,  and the  relationship
between  magnitude  of exposure  (dose)  and  severity of  adverse
effects (response).

Risk  Characterisation - summarizes and combines outputs of the
exposure and toxicity assessments to provide a quantitative  (e.g.,
one-i'n-a-million excess  cancer risk)   assessment  of  site-related
risks.    An  evaluation   of   the  uncertainty  surrounding  the
quantitative  estimate  is  useful  for  making  risk  management
decisions.

The baseline risk assessment began with selecting contaminants of
concern which would be representative of site risks.   The primary
contaminants  of  concern  are  1,1,1-TCA,   TCE,  Freon-113,  vinyl
chloride, 1,1-DCE,  carbon tetrachloride and associated degradation
products.  Most of these contaminants of concern listed above are
known or are suspected of causing cancer in animals and/or humans.
The baseline risk  assessment  quantitatively  evaluated the health
effects which could result from ingestion of untreated ground water
by residents and inhalation of VOCs by residents while showering
with  untreated  ground water.    Based  on  the  current usage and
hydrogeology of the site, and  on  the results of analyses performed
on ground  water  samples collected from local  residential wells,
exposure to VOC contaminants  is  not believed to be occurring and
was not evaluated under current site conditions.  Residential wells
are considered to be side and  up-gradient  of the RTI site  in terms
of the direction of predominant ground  water flow.  However, since
the  most significant ground  water contamination exists  in the
bedrock aquifer and flow within bedrock aquifers is often difficult
to predict due to variable fractures,, no assurance  exists that
nearby wells will not be impacted in the future.

Site  ground water  is  part  of  an  aquifer  that  serves  as  the sole
drinking water  source for  area  residents.  As a result,  it is
possible that residents  could elect to install private  drinking
water wells in the future in areas affected by site contaminants.
Therefore,  future  ingestion  of  ground water  by residents was

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evaluated.  In addition, exposure via ingestion of ground water by
RTI  employees  may  also  occur  under  future  site  conditions.
However, because the exposure  to employees is of short duration,
compared  to potential  residential  exposure, this  work-related
scenario is expected to be less significant and was not evaluated
quantitatively.

Due to  the  potential  use of ground water  in  the future in areas
affected by site contaminants,  residents may  also be exposed via
dermal contact with and inhalation of contaminants in ground water.
Exposure is expected to occur primarily through bathing, showering
and/or cooking. Exposure via dermal contact with  and inhalation of
contaminants in ground water by site employees may also occur but
is  expected  to be  less  significant  than  future  exposure  to
residents due to shorter and less frequent exposure.

The  inhalation of  contaminants  volatilizing from ground  water
seeping into basements is not expected to occur due to the depth of
ground water (20 to 30 feet) in adjacent residential areas and in
areas potentially developed for residential use.  In addition, the
RTI facility does not have any areas that  were constructed below
ground surface.  As a result, exposure via  this pathway is assumed
to be insignificant and is not evaluated.

EPA's allowable cancer risk range  is 10"4 to 10"6 which  can be
interpreted to mean that an individual may  have the probability of
approximately one  in  ten thousand to one  in  a million increased
chance of developing cancer as a result of site-related exposure to
a carcinogen during a 70-year lifetime under the specific exposure
conditions at the site.  DEPE's allowable cancer risk is  one in one
million  (10~6>  based on P.L.  1993, c.139, Section 35d  (S-1070).

The potential carcinogenic  risk value associated with the ingestion
of ground water was estimated  to be 3 x 10~3  (or three in 1,000)
which exceeds the acceptable risk range established by EPA (1  x 10"
4, one in 10,000 to 1 x 10~6, one in a million)  (see
Table  2.1  -  Summary  of  Carcinogenic  Risk  Estimated for  the
Radiation Technology Site).  This value is attributable primarily
to the  presence of vinyl chloride which was detected at 99 ug/L.
Maximum  detected  concentrations of 1,1-DCE  (21  ug/L)  and carbon
tetrachloride  (140 ug/L) detected in samples also contributed to
the  total  elevated risk  estimate .with  chemical-specific  risk
estimates of l  x 10~4 and 2 x 10~4,  respectively.

For a ground water dermal  contact scenario for future residents,
the total risk value was estimated to be 2  x 10~4.  This value was
primarily due to the presence of carbon tetrachloride, 1,1-DCE and
vinyl chloride.

The risk value for the inhalation of ground water contaminants
through shower vapors by residents under a  future use scenario was
estimated  to be  4  x 10~4.   This  was  mainly attributed  to the

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concentrations of 1.l-DCE and vinyl chloride, which both had risk
values  of 2  x 10~4.    (See  attached risk  tables -  Summary of
Carcinogenic and Non-carcinogenic Risk).

To assess the overall  potential for non-carcinogenic effects posed
by more than one contaminant, EPA has developed a hazard index  (HI)
(see Table 2.2 - Summary of Non-Carcinogenic Risk Estimated for the
Radiation  Technology  Site).    This   index  measures  the  assumed
exposures   to   several   chemicals   at   low   concentrations,
simultaneously, which could result in adverse health effects.  In
accordance with this  approach,  a  hazard quotient (HQ), i.e., the
ratio of the level of exposure to an acceptable level,  greater than
1.0 indicates that the exposure level  exceeds  the protective level
for that particular chemical.   Also,  if the hazard quotients for
individual chemicals are less than 1.0, but the  sum of the hazard
quotients  for all substances  in an  exposure medium (i.e.,  the
hazard  index is  greater than 1.0),   there  may be a  concern for
potential health effects.   Furthermore,  the HI is summed for all
media common to a particular receptor.

A chronic HI of 10  for the  ingestion of unfiltered ground water by
future  residents was  high mainly due to the  presence of carbon
tetrachloride and manganese, whose HQs  exceeded unity.  Although
carbon tetrachloride was infrequently detected (in three out of 21
samples analyzed),  manganese was detected in all  samples analyzed.
Ten   contaminants    (1,1,1-TCA,   1,2-DCE   [total],   acetone,
chlorobenzene, ethylbenzene,  TCE, aluminum,  arsenic,  iron,  and
nickel) had HQs between 1 and 0.5.  The remaining 12  contaminants
for which daily exposure doses were  calculated had HQs less than
0.1.

The HI  for the ground  water dermal   contact  scenario for future
residents exceeded unity (2).   This  was mainly attributed to the
presence of carbon  tetrachloride (HQ=1)  at a maximum concentration
of  140  ug/L.  Sufficient  toxicity information  was  available to
calculate HQs for 24 other  contaminants,  all of which  had HQs less
than O.l.

The HI  for the inhalation of ground water contaminants through
shower  vapors  by residents under a future  use scenario was less
than one  (0.4).   Therefore,  exposure from this  scenario  is not
expected to pose a significant non-carcinogenic risk.

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


ECOLOGICAL RISK ASSESSMENT

As  part of the Ecological Risk Assessment,  a qualitative and/or

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semi-quantitative appraisal of the actual or potential effects of
a hazardous  waste site  on plants and  animals  is performed.   A
four-step process  is used for assessing  site-related ecological
risks:

Problem  Formulation -  a  qualitative  evaluation of  contaminant
release, migration,  and fate; identification of  contaminants of
concern, receptors, exposure pathways, and known ecological effects
of the contaminants; and selection of endpoints for further study.

Exposure Assessment - a quantitative evaluation of  contaminant
release, migration, and fate; characterization of exposure pathways
and receptors;  and measurement of estimation of exposure point
concentrations.

Ecological Effects Assessment - literature reviews, field studies,
and toxicity tests, linking contaminant concentrations to effects
on ecological receptors.

Risk Cbaracterisation - measurement or estimation of both current
and future adverse effects.

This  ecological risk  assessment   describes  the terrestrial  and
aquatic habitats and species that have been noted or are expected
to be present at the RTI property and evaluates the potential risks
associated  with  the exposure  of  these biota  to  contaminants
detected during the RI.   The  objective of  this risk assessment was
to evaluate whether  contaminants  present  at  the  RTI property may
pose adverse  impacts to  biota present in  habitats on the site or
adjacent to the site.  Quantitative measures to evaluate ecological
risks  (e.g.,  wildlife  population  inventories,  biota  sampling,
bioassays, and predictive modelling) were not within the scope of
this risk assessment.

The RI identified surface water concentrations of copper within a
small intermittent stream leading from the active RTI facility to
Lake  Denmark which  may result  in potential  acute  and chronic
impacts to aquatic biota inhabiting this stream.  Cyanide and zinc
concentrations  also contribute to  risk within the  Lake Denmark
drainage area surface  waters.  Sediment  contaminants within the
Lake Denmark  drainage area that may result  in adverse impacts to
sensitive  aquatic  biota  include  4,4-DDT   (and  its  derivative
4,4-DDE) and  antimony.   Concentrations of barium,  copper, iron,
lead,  manganese,  mercury,  and   silver  may also  impact  biota
(particularly species sensitive to contaminants) inhabiting aquatic
environments  present within this  area.   However, most  of these
metals may be naturally  occurring as  noted  by the fact that this
site was part of the Dover Mining District that was heavily mined
earlier this century.  Based upon knowledge of past activities at
the RTI  site,  barium is the only  metal of  those mentioned above
that may have been discharged due to industrial activities.


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Although sediments within Lake Denmark contain a variety of VOCs,
concentrations are not likely to result in acute or chronic impacts
to   aquatic   organisms  inhabiting   this  environment.     Mean
concentrations of all VOCs are below levels shown to cause acute
and  chronic   ecological  effects.     Sampling   of  additional
contaminants that are generally more toxic (e.g.,  pesticides and
inorganics) was not conducted during the  RI because they are not
believed to have been discharged due to industrial activities.
Additional sampling of surface water and sediments in an expanded
area of Lake Denmark for VOCs and other site related compounds will
be conducted during the design phase.

Surface water concentrations of copper,  cadmium,  aluminum, lead,
and  zinc  may result  in  potential acute  and chronic  impacts to
aquatic biotas  inhabiting the streams within the  Lake Telemark
drainage  area.    These  metals  may  be  naturally   occurring  as
previously mentioned.   Potential acute impacts  are particularly
likely  within  an area  of  emergent marsh  where  the  highest
concentrations of several inorganics  were  noted.  Although surface
water concentrations of Aroclor-1260, antimony, iron, and mercury
may  also  contribute to chronic risk,  each of these contaminants
(except iron)  was detected  infrequently;  therefore,  widespread
exposure to aquatic organisms is unlikely.

Although  acute   and   chronic  impacts   from  organic  sediment
contaminants  within   the Lake  Telemark  drainage  area are  not
expected to occur, concentrations of barium, iron, lead, manganese,
and  zinc  may  result  in  adverse effects to  aquatic  organisms.
However, these constituents are not believed to be site related.


SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA requires that  each selected site  remedy be protective of
human health and the  environment, be cost effective, comply with
other  statutory  laws, and use  permanent  solutions, alternative
treatment technologies, and resource recovery alternatives to the
maximum extent practicable.  The FS report evaluates  in detail six
remedial alternatives for addressing the contamination associated
with the RTI study area, Table 3  presents a "Summary of Costs of
Alternatives."    The  estimated  capital  cost,   operation  and
maintenance  (O&M)  cost,  and net present worth  cost for  each
alternative discussed below are provided for comparison.

These alternatives are:

Alternative 1GW - HO Action

Estimated Capital Cost: $0
Estimated Annual O&M cost: $0
Estimated Net Present Worth Cost:  $41,000
Estimated Implementation Timeframe:  0

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The no  action alternative provides a baseline  for comparison to
other remedial options.  Under this alternative no remedial action
would be taken.  After five years a  review would be conducted to
determine if any remedial action is necessary.

Alternative 2GW - Institutional Control

Estimated Capital Cost: $228,000
Estimated Annual O&M Cost: $94,000
Estimated Net Present Worth Cost: $2,122,000
Estimated Implementation Timeframe:  30 Years

Alternative 26W is composed of four components:  increased public
awareness;  design,  installation  and semi-annual  sampling of  a
sentinel  well system  (on-site  monitor  wells  located near  the
perimeter of  the site to  provide  an early warning of potential
plume migration toward residential areas);  quarterly sampling of
selected  on-site monitor  wells;  and,   semi-annual sampling  of
selected residential wells.

The  elements  of  this  alternative  have  been  assumed  to  be
implemented for a period of 30 years  in the  FS.  The status of the
nature  and  extent  of the  ground water  contamination would  be
assessed every year.   Every five years,  the site status would be
evaluated and the need for continued or additional remedial action
would be addressed.

Alternative 3GW - Ground Water
Collection with Hydrofraeturing
and Air Stripping Treatment

Estimated Capital Cost: $486,000
Estimated Annual O&N Cost  (Years 1 to 5): $140,000
Estimated Annual O&M Cost  (Years 6 to 10): $108,000
Estimated Net Present Worth Cost: $1,963,000
Estimated Implementation Timeframe:  10 years

This  alternative  addresses  the  area of  highest ground  water
contamination using pump and treat technology.   Alternative 36W
consists of these major  components:   increased public awareness;
design, installation and  semi-annual  sampling of a sentinel well
system; quarterly sampling of selected site  on-site monitor wells;
semi-annual sampling of selected residential wells; provision for
point-of-entry  treatment  (POET)  units  for potable wells;  and,
design  and  installation of a ground water  pump  and treat system
which includes air stripping and carbon treatment of the off gases.
The  number  and  location  of recovery  wells  and the  need  to
hydrofracture bedrock  could change  based on  the  actual  design.
Treatment efficiency for air stripping is 99.5 percent  for removal
of chlorinated hydrocarbons.  Gases  released during this process
will be treated with a vapor phase carbon treatment unit and air
emissions will comply with ARARs.

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Residual contamination in the ground water beyond the capture zone
would dissipate through natural attenuation; the length of time for
this process to occur  is uncertain and not incorporated into the
10-year timeframe under this alternative nor in  its present worth
cost.

This alternative reinjects treated effluent to the overburden water
bearing zone.  The extracted ground water will be treated to meet
effluent standards based  on state GWQS and federal MCLs.  Discharge
of treated effluent to  adjacent wetlands and Lake Denmark have been
retained as  options  in case discharging  to the overburden water
bearing zone is not possible.  If this occurs, the discharge will
meet DEPE Surface Water Quality Criteria and federal Ambient Water
Quality Criteria.

At the proposed pulse-pumping rate, one pore volume  of ground water
in the most contaminated area would be removed in one half year.
It is  estimated  that  the removal of  10  pore  volumes in 5 years
time would be  sufficient to  reduce contaminant concentrations to
levels meeting state  GWQS and federal MCLs.  This time frame will be
optimized during design and subsequent operation.    Ground water
monitoring will continue for five years  after completion  of the
pump and treat phase of this alternative to confirm the results.

Alternative 46W - Ground Water
Collection with Hydrofracturing and
H202/DV Treatment

Estimated Capital Cost: $704,000
Estimated Annual O&M Cost (Years l to 5): $233,000
Estimated Annual O&M Cost (Years 6 to 10): $108,000
Estimated Net Present Worth Cost: $2,800,000
Estimated Implementation Timeframe: 10 years

Alternative  4GW   is  identical  to  Alternative  3GW  described
previously  except  Hydrogen  Peroxide   (H2O2)/Ultraviolet  (UV)
treatment  has been  substituted  for air  stripping.    Treatment
efficiency for H202/UV is 98 percent  for  removal  of chlorinated
hydrocarbons.

Alternative sow - around Water
collection and Air stripping
Treatment without Hydrofracturing

Estimated Capital Cost: $457,000
Estimated Annual O&M (Years 1 to 9): $128,000
Estimated Annual O&M (Years 10 to 14): $108,000
Estimated Net Present Worth Cost: $2,241,000
Estimated Implementation Timeframe: 14 years

Alternative 5GW is identical to Alternative 3GW  except wells P-6,
R-l and 14D would  not  be hydrofractured to increase well yields.

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The veils would be pulse pumped at a rate to be determined during
the design phase.   The decrease in well yields from P-6,  R-l and
140 increases time of operation nearly five years and present worth
costs by approximately  $300,000.

Alternative 6GW - complete Aquifer
Restoration vita Hydrofracturing and Air
Stripping Treatment

Estimated Capital Cost: $1,015,000
Estimated Annual O&M Cost (Years 1 to 14): $207,000
Estimated Annual O&M Cost (Years 15 to 19):  $108,000
Estimated Net Present Worth Cost: $4,445,000
Estimated Implementation Timeframe: 19 years

The objective of this alternative is to actively restore the entire
contaminated bedrock aquifer to comply with state GHQS and federal
MCLs.  Trichloroethene and  its associated compounds are the most
critical contaminants  because  they affect the largest portion of
the  study   area   and  require  remedial  action   at  very  low
concentrations.  The three recovery wells described  in Alternative
36W will be supplemented with seven down-gradient perimeter wells.
The system would  operate  under a pulse-pump regime and extracted
ground water would be  treated by an air stripper system.  H2O2/UV
was dropped as a treatment system for this alternative because it
is  less  efficient  and more costly  than air stripping.   Gases
released during this process will be  treated  with  a vapor phase
carbon   treatment  unit.     With  each   recovery   well   being
hydrofractured, a sustained pumping rate of approximately 170 gpm
will extract 50 pore volumes of the contaminated plume in 14 years.

Effluent will be  treated  to  meet state GWQS and federal MCLs and
will be  reinjected  into the  overburden water bearing zone,  or if
necessary, discharged  to Lake Denmark  or into adjacent marshes,
where such  discharge will meet state and federal  surface water
quality standards.


SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

During  the  detailed  analysis  of remedial   alternatives,  each
alternative is assessed against nine evaluation criteria: overall
protection of  human health and  the environment;  compliance with
applicable  or  relevant  and  appropriate  requirements  (ARARs);
long-term  effectiveness and permanence;  reduction  of  toxicity,
mobility  or  volume; short-term effectiveness; implementability;
cost; state/support agency acceptance; and,  community acceptance.

The evaluation criteria are described below:

Overall  Protection  of Human  Health   and  the  Environment:  This
criterion  addresses whether or not  a remedy provides  adequate

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protection and  describes how  risks  are eliminated,  reduced,  or
controlled   through   treatment,    engineering   controls,   or
institutional controls.

Compliance with ARARs:  This criterion addresses whether or not a
remedy will meet all of the  applicable or relevant and appropriate
requirements of other  environmental  statutes and requirements or
provide grounds for a waiver.

Long-term Effectiveness Permanence:  This criterion refers to the
ability of a remedy to maintain protection of human health and the
environment, once cleanup goals have been met.

Reduction of Toxicity, Mobility or  Volume through Treatment:  This
criterion refers to the  anticipated  performance of the treatment
technologies a remedy may employ.

Short-term Effectiveness:  This criterion 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.

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

Cost:    This   criterion  includes  capital  and  operation  and
maintenance costs.

State/Support Agency Acceptance:  This criterion indicates whether,
based on its review of the RI/FS report and  Proposed Plan, DEPE or
EPA concurs, opposes or has no comment on the selected remedy.

Community  Acceptance:    This  criterion  refers  to the public's
general response to the alternatives described in the Proposed Plan
and the RI/FS reports.  Responses to  public  comments are addressed
in the Responsiveness Summary of the ROD.

The following is a comparative analysis of the alternatives based
upon the evaluation criteria noted above.

Overall Protection of Human Health and the Environment

With  regard to  existing receptors,  all  treatment  alternatives
evaluated provide protection of human health and the environment.
The results of the quantitative risk assessment for the RTI study
area indicated that chemical contaminants in site ground water do
not pose a present threat to human health or the environment.

With regard to  potential risk to future receptors, all treatment
alternatives provide protection to human health or the environment.

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Under certain future conditions, where new and existing residential
wells are impacted by site ground water contamination, Alternatives
3GW, 4GW, 5GW, and 6GW would provide protection through treatment
of extracted ground water.

Alternatives 3GW, 4GW, and 5GW provide protection through treatment
of ground water extracted from the most contaminated portion of the
aquifer  near  the active  RTI  facilities.    These ground  water
collection systems would recover a majority of the contamination
including vinyl chloride which is the contaminant of concern that
poses  a  significant  risk  under  future  scenarios.    Residual
contamination  in the ground water beyond the  capture  zone will
dissipate through natural attenuation.

Alternative  6GW  provides  protection through  complete  aquifer
restoration.  Under this  system, contaminated ground water would be
collected at the  most contaminated portion of the aquifer and at
the down-gradient edge  of the contaminant  plume.   No additional
protection to  human  health  and the environment is provided under
this alternative  than  what would  be  provided under Alternatives
3GW, 4GW and 5GW, according to risk assessment data.  Furthermore,
due to  the complex  nature  of the bedrock aquifer and the wide
dispersion of  contaminants,  it is  not known if complete  aquifer
restoration is technically feasible at this time.

Disposal of treated ground water under Alternatives 3GW through 6GW
would be protective of the environment because required discharge
standards will be met.  Air emissions from the air stripper/vapor
phase carbon treatment system under Alternatives 3GW, 5GW and 6GW
will not exceed the standards set by state and federal agencies.

Compliance with ARARs

The three types of ARARs used throughout this evaluation include:
chemical-specific  ARARs which  are the  criteria used  for  the
remediation   goals;   location-specific   ARARs  which   restrict
activities because they are located within sensitive areas such as
floodplains, wetlands  or historical  areas;  and,  action-specific
ARARs which  are  part  of the  remedial  action  such  as  discharge
criteria for ground water.

Active remediation of the entire plume under Alternative 6GW would
remediate the  contaminated ground water across the entire site to
chemical-specific  ARARs  in   the  shortest  period   of  time.
Alternatives 3GW, 4GW and 5GW would require a longer period of time
to attain chemical-specific  ARARs across  the entire site  as they
combine  natural attenuation with active  remediation of the most
contaminated portion of the plume.

All treatment alternatives would comply with action-specific ARARs
by  meeting ground water  discharge criteria  and air  emissions
criteria.      Also,   the   alternatives   would   comply   with

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location-specific ARARs.

The specific ARARs for the selected remedy are listed below:

Action-specific ARARs:
          Federal Hazardous  Waste Manifest Requirements for Off-
          site Waste Transport  (40 CFR Part 262)
          Department of  Transportation  (DOT)  Rules for Hazardous
          Materials Transport (49 CFR Part 268)
          Resource  Conservation  and Recovery Act   (RCRA)  Land
          Disposal Restrictions Material Response  (29  CFR Parts
          1904, 1910, 1926)
          Clean Water Act Water Quality  Criteria (40 CFR Part 131)
          Clean Air Act National Ambient Air Quality Standards, 940
          CFR Part 50)
          New Jersey Safe Drinking Water Act Maximum Contaminant
          Levels (NJAC 7:10)
          Safe Drinking Water Act (SDWA)  National Primary Drinking
          Water Regulations  (40 CFR Parts 141, 142, and 143)
          New  Jersey  Water  Pollution  Control Act  Standards for
          Groundwater  (NJAC  7:14 A-6:15)
          New Jersey Water Pollution Discharge Elimination System
          (NJAC 7:14A)
          New Jersey Air Pollution Control (NJAC 7:27-5, 13,16 and
          17)
          National Pollution Discharge Elimination System  (40 CFR
          122 and 125)
          Standards for Hazardous Waste Transporters  (40 CFR 263)
          Noise Pollution  (NJAC 7:29-1)
          P.L. 1993, C.139 (S-1070)

Chemical-specific ARARs:
          Safe Drinking  Water Act (SDWA),  MCLs and MCL Goals (40
          CFR Part 141)
          Clean Water Act Water Quality  Criteria (40 CFR Part 131)
          Clean Air Act National Ambient Air Quality Standards, (40
          CFR Part 50)
          New Jersey Safe Drinking Water Act Maximum Contaminant
          Levels (NJAC 7:10)
          New  Jersey  Water  Pollution  Control Act  Standards for
          Groundwater  (NJAC  7:9-6;  NJAC 7:14 A-6:15)
          New Jersey Water Pollution Discharge Elimination System
          (NJAC 7:14)
          New Jersey Air Pollution Control (NJAC 7:27-5,  13, 16 and
          17)
          National Pollution Discharge Elimination System  (40 CFR
          Parts 122 and  125)
          Standards for  Hazards for Hazardous Waste Transporters
          (40 CFR Part 263)
          National Emission Standards for Hazardous Air Pollutants
          (40 CFR Part 61)
          P.L. 1993, C.139 (S-1070)

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Location-Spacific ARARs
          Clean Air Act National Ambient Air Quality Standards, 40
          CFR Part 50
          40 CFR Part  6 Appendix A (Regulations for implementing
          Executive Order 11990—Protection of Wetlands)
          Clean Water Act, 33 U.S.C. 1344
          Executive Order 11988—-Floodplain Management

Reduction of Toxicity, Mobility, or Volume through Treatment

Alternatives 3GW, 4GW,  5GW and  66W would satisfy this criterion.
Each alternative employs treatment that is capable of removing the
VOC contaminants from the extracted ground water thereby reducing
the mobility of the contaminant plume.  Ground water treatment with
air stripping and vapor phase carbon Alternatives 3GW, 5GW, and 6GW
would create spent carbon that would need to be sent off-site for
disposal  or   regeneration.     Alternative  4GW,  using  H2O2/UV
treatment, would  generate no residuals.   Alternative  6GW would
provide  the  greatest  reduction  in  mobility  of  contaminants.
Alternatives  1GW  and  2GW would not reduce  the mobility  of  the
contaminant plume.

Long-Term Effectiveness and Permanence

Alternative  6GW  provides  the  best  long-term  effectiveness  and
permanence because  it proposes  to recover and treat  the entire
contaminant plume.   Some residual contamination will remain within
the  aquifer  at  levels below  ARARs and  will  dissipate  through
natural  attenuation without  endangering  human health and  the
environment.

Alternatives  3GW,   4GW,  and  5GW  recover  and treat  the  most
contaminated portion  of the aquifer.  Residual contamination at
higher levels and in a greater area than those in Alternative 6GW
would  remain, but  would  eventually  dissipate through  natural
attenuation.

All  ground  water  treatment  options  would  provide  long-term
effectiveness and treatment of VOC contaminants. Alternatives 1GW
and 2GW are neither effective nor permanent.

Short-Term Effectiveness

Alternatives 1GW and 2GW are  the least disruptive to the current
operations, existing use of land and  the environment.   Only the
installation of off-site monitor wells and sampling events would be
performed in  the  area under 2GW.   Construction time required to
install  the  proposed  monitor wells would be  approximately  one
month.

Alternatives 3GW, 4GW,  5GW, and 6GW would be somewhat disruptive to
the  current  operations  and  existing  conditions  since  these

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alternatives  involve  the  construction  of  recovery  wells  and
treatment facilities.  These alternatives could also threaten the
veil yield at active production well  P-2 and therefore the water
supply to RTI during ground water recovery operations near the RTI
facility.   Overall construction tine for these  alternatives is
about one year.

No impacts to human health and the environment from construction
and implementation of the alternatives are expected.

XBplwMntability

The design and construction of all  the alternatives  is expected to
require about two years.  Alternative 2GW would require about one
year.

Alternatives 3GW,  4GW,  5GW, and 6GW  require the  installation of
buried piping  on the active  portions of the RTI facility.   The
location of  building  foundations  and utilities would  need to be
located during the design.  To ensure that adequate well yields can
be realized from the proposed recovery wells, a pump test will be
required during the design phase.

Air  stripping and vapor  phase carbon  adsorption technologies
included in Alternatives 3GW, 5GW and 6GW are proven technologies
and easily implemented.  Conversely, H202/UV included in 4GW is a
new  technology  for  treatment and destruction  of ground water
contaminants and not as readily available.

The  remedies  which  involve  active  pumping  and  treating  of
contaminated ground water will attempt to remove or control DNAPL
sources  where practicable.    This approach will  limit  further
contamination of ground water. These  remedies are consistent with
EPA's  Office of Solid Waste and  Emergency Response  Directive
9236.2-25 "Guidance for Evaluating the Technical Impracticability
of Ground Water Restoration."

Cost

Alternative  1GW  requires  a review after five years  and  has  a
present worth cost (PWC) of $41,000.  Alternative 2GW consists of
installing  four  new  sentinel  wells,  expanding  three  existing
monitor  wells  and  sampling  on-site  and   off-site  conditions.
Alternative 2GW has a PWC of $2,122,000 over 30 years.  Alternative
3GW  consists of extracting  the  most highly contaminated ground
water  from  the bedrock aquifer and treating with  air stripping
technology.  The  PWC for Alternative 3GW is $1,963,000 and would be
implemented  for  10 years.    Alternative  4GW is  identical  to
Alternative 3GW  except that H2O2/UV technology is substituted for
air  stripping to  treat  extracted ground  water.    The  PWC  for
Alternative  4GW  is $2,800,000  and would  be implemented  for 10
years.  Alternative 5GW has the same components as Alternative 3GW

                               21

-------
except the recovery wells are not hydrofractured to increase well
yields.  The lower yields result in a longer implementation period,
about 14 years, and an  increased  PWC of $2,241,000.   The goal of
Alternative  6GW  is restoration of  the bedrock aquifer  using 10
recovery  wells  and  air  stripping  technology.     The  PWC  of
Alternative  6GW  is $4,445,000  and would be implemented  for 14
years.

Under the provisions of P.L. 1993, c.139, Section 35g relating to
remedial  costs,   DEPE  cannot  require  a  responsible  party  to
implement a permanent remedy  at  a  contaminated  site if  a non-
permanent remedy can be  implemented for less than half the cost.
Of the alternatives presented in this ROD, the non-permanent remedy
3GW is less than  50  percent of the  cost of  the permanent remedy
6GW.  Consequently, DEPE  cannot require the  responsible party to
implement the permanent remedy, 6GW.

Support Agency Acceptance

The  Support  Agency  Acceptance  factor  addresses  whether  EPA
supports, opposes,  and/or has  identified any  reservations with the
preferred alternative.

EPA agrees with and supports the selected alternative presented in
this ROD.

Community Acceptance

This evaluation factor addresses  public reaction  to the remedial
alternatives which were considered,  and the preferred alternative.

Issues raised during the  public comment period  and at the public
meeting held on August 11, 1993 are addressed  in the Responsiveness
Summary section of this ROD.  Comments received during the public
comment  period  indicated that  the  local residents  and Rockaway
Township  officials  supported the preferred  alternative  for the
cleanup  of  contaminated  ground water.   RTI  submitted  extensive
comments  opposing  the  Department's  preferred  alternative  (see
Responsiveness Summary).   Assemblyman Joseph V.  Doria,  Jr. also
commented raising many of the  same  issues addressed by RTI. Upon
review of these  comments, DEPE and EPA have determined  that no
significant changes to the remedy, as it was originally identified
in the Proposed Plan,  were necessary.


THE SELECTED REMEDY

After careful consideration of the remedial alternatives, DEPE has
selected and EPA concurs  with  an  alternative believed to provide
the best balance  among alternatives  with respect to the evaluation
criteria for groundwater remediation.  The RI/FS reports should be
consulted for more information on the remedial alternatives.

                                22

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While the format for the remedy selection process is in accord with
the NCP, the preferred alternatives also are in compliance with the
provisions  of  P.L.  1993,  c.139 with respect  to the criteria for
effectiveness, permanence, implementability, cost, and protection
of public health and the environment.  DEPE believes the preferred
alternatives  would  be   protective  of  human  health  and  the
environment, would  comply with remedial action objectives, would
comply with state requirements,  is the  best use of public funds,
and would utilize permanent solutions  and  alternative treatment
technologies or resource recovery technologies where appropriate.

Alternative 3GW is  the selected alternative  to remediate ground
water contamination  at the RTI Superfund Site.  The components of
Alternative 3GW are: hydrofracturing and extracting ground water
from P-6, R-l and MW-14D;  treating the recovered water with an air
stripping  system with gases  released treated  by a  vapor phase
carbon treatment unit; and, reinjecting the treated effluent to the
overburden  water bearing  zone.   The  number and  disposition of
recovery wells may be modified during the design phase.

The goal of the remedial action is to reduce the concentration of
VOCs  in  the most  highly contaminated  portion  of  the bedrock
aquifer.  Based  on  the  information obtained during the RI, it is
anticipated that the preferred remedy  will  achieve  this goal.
Residual  contamination  outside the  capture  zone  will dissipate
through natural attenuation.  State GWQS and federal MCLs will be
achieved  through a  combination of ground  water  extraction and
treatment  and  natural  attenuation.     Monitoring of   the  less
contaminated  ground  water will  be  conducted  to determine  if
additional  remediation is necessary.

Continued sampling  of on-site monitor wells,  sentinel wells and
residential wells will ensure that contaminant concentrations are
being  reduced  on site  and that the  direction and  magnitude of
migrating contaminants does not result  in an exceedance of state
and federal drinking water standards for individual supply wells.
Also, there are provisions in this alternative for temporary POET
units  for residential well  users  if  site-related contamination
threatens such wells.

If it is determined  during design or implementation that the entire
volume of remediated ground water from the RTI capture zone cannot
be re injected into the overburden water bearing zone, other surface
water discharge options, or a combination of the above, included in
the FS will be  considered.  Alternative 3GW would be designed to
comply  with state  GWQS  and federal MCLs if reinjection  to the
overburden  water bearing zone is used.  Promulgated surface water
quality  standards would  apply to surface  discharge  of treated
ground water if that option is used.

The estimated capital cost of  this alternative is $486,000.  Based
on  comments  received  during  the  public  comment  period  the

-------
Department acknowledges  that the estimated capital  cost  for the
selected remedy could be considerably  less.   The DEPE contractor
estimated capital costs  for 3GW to be $486,000.  However,  another
estimate of  $232,000 submitted as part  of a public comment was
evaluated by the Department and found to be feasible.  A major part
of  the cost differential was due to  a  vide variation  in veil
drilling cost estimates.

Based on extracting 10 pore volumes of contaminated ground vater in
the targeted area,  it vill take  five years to meet the preferred
alternative goal.  Timeframe estimates for remediating contaminated
fractured bedrock aquifers are highly  speculative and the actual
period of operation may be quite different.  Five additional years
of sampling monitor and  residential veils vill be used to confirm
the results of the remedial action after  the goals of the pump and
treat  system have  been  met.    Data vill then  be compared  to
remediation goals established for this site to  identify whether any
further action is necessary.

In  summary,  the  selected alternative is believed  to provide the
best balance among  the  alternatives  with respect to the criteria
used to  evaluate  alternatives.   Therefore, based on information
available  at  this  time,  DEPE  and EPA  believe the  preferred
alternative  vould  provide overall protection of health  and the
environment, and vould  be cost-effective.   This action vould use
permanent solutions and  alternative treatment technologies to the
maximum extent practicable, given the scope of the action.

An analyses vill be made during the remedial design to ensure that
any adverse  impacts to any vetland areas  vill  be mitigated.   If
appropriate, some of the treated groundwater could be  discharged to
vetland areas to help offset  any devatering effects created by the
groundvater extraction.

A Cultural Resource survey vill  be prepared to ensure compliance
vith the National Historic Preservation Act.
REMEDIAL GOALS

The goal of the selected remedy is to restore the ground vater to
the more stringent of  the  state GWQS. and federal MCLs vithin the
zone of capture at the RTI  site and to allow residual ground vater
contamination outside the zone of capture to naturally attenuate.
This operable unit vill  remediate contaminants present in ground
vater.  Based on information obtained during the RI, DEPE and EPA
believe that the selected remedy vill achieve this goal.

It may become apparent, during implementation or operation of the
ground vater extraction system, that contaminant levels have ceased
to decline  and  are remaining constant at  levels higher than the
drinking-water  standards over some  portion of  the contaminated

                               11

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plume.  In that case,  performance standards and/or the remedy will
be re-evaluated.

The selected  remedy will  include ground water extraction  for a
period which  is presently  estimated  to be five years (but which,
depending upon the degree of contaminant reduction achieved,  may
ultimately  be  a  longer  period),  during  which  the  system's
performance will  be carefully monitored on a regular  basis and
adjusted  as  warranted by  the  performance data  collected during
operation.  Modifications may include any or all of the following:

          Discontinuing pumping at individual wells where cleanup
          goals have been attained.

          Alternating pumping at wells to eliminate stagnation.

          Pulse pumping to  allow aquifer equilibration and to allow
          adsorbed contaminants to partition into ground water.

          Installing additional extraction wells to facilitate or
          accelerate cleanup of the contaminated plume.

During the performance  of  the  long-term monitoring,  DEPE and EPA
may determine that the  remedial  action objective has been met to
the maximum extent practicable.  Periodic monitoring will be used
to reassess  the time frame  and the  technical  practicability of
achieving cleanup standards.  Upon meeting all remedial objectives,
or determining that  the  Site  has  been sufficiently .purged of
contaminants  so  that public  health  is  no longer threatened by
contaminants at the Site, EPA will initiate proceedings to delete
the Site from the NFL.
STATUTORY DETERMINATIONS

Remedy  selection  is  based  on  CERCLA,  as  amended,  and  the
regulations contained  in the NCP and P.L.  1993,  c.139 (S-1070).
DEPE's primary responsibility is to undertake remedial actions that
achieve  protection   of  human   health  and   the  environment.
Additionally, several other statutory requirements and preferences
have been  established.   These  specify that, when  complete,  the
selected remedy must comply with ARARs, unless a statutory waiver
is justified.  The remedy must also be cost effective and utilize
permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable.  Finally, there is
a preference for remedies which employ treatment that permanently
and  significantly reduce  the  toxicity,  mobility,  or  volume  of
hazardous  wastes  as  their  principal  element.   The  following
sections discuss  how the remedy selected for the  RTI  site meets
these requirements and preferences.

-------
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

The  selected remedy  protects  human health  and the  environment
through the extraction and treatment of contaminated ground water.
The extraction and treatment of the contaminated ground water will
significantly  reduce  the  threat  of  potential  exposure  to
contaminated ground water.  There are no short-term adverse impacts
associated  with  the  selected  remedy which cannot  be  readily
controlled.  While no cross-media impacts are expected  from the
remedy,  any environmental  impacts  associated with  site-related
contaminants  or  remedial  activities  will  be addressed in the
remedial design.


COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

The selected remedy will comply with all applicable or relevant and
appropriate action,  chemical and location-specific  requirements.
The ARARs are presented below.

     Action-Specific
The selected  remedy will be in  compliance  with all  federal and
state ARARs.  The cleanup goals for the remediation of the ground
water are the more stringent of the promulgated state and federal
MCLs which are standards for drinking water.

Emissions from the treatment unit would conform with the provisions
of the Clean Air Act.   This  will be  accomplished  through the
installation of  appropriate air  pollution  control equipment  if
necessary.     Occupational  Safety  and  Health   Administration
requirements would  be complied with during the  implementation of
the remedy.

With respect to state action-specific ARARs,  the air stripper and
any other regulated  equipment will be designed,  constructed, and
operated to meet the Air Pollution Control and the Noise Pollution
Control Act requirements and regulations.

     Chemical-Specific
The more stringent of the  state 6WQS and federal MCLs will be used
as cleanup goals for the ground water remediation.

     Location-Specific
The site is not within the coastal zone as defined by the State of
New Jersey.  Additionally, there are no federally designated wild
and scenic rivers and there are no significant agricultural lands
in the vicinity of the site.  The project area may be sensitive for
the  discovery  of  cultural resources.    Therefore,  as  discussed
earlier,  a  cultural  resource  survey will  be  prepared  during
remedial  design.    Additionally,  a wetlands assessment will  be
performed  at that  time to  determine  the potential  impacts  on
wetland areas.

                               26

-------
UTILIZATION OF  PERMANENT SOLUTIONS AND ALTERNATIVE  TREATMENT OR
RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

DEPE and EPA have 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 RTI
site.   Of the alternatives that are protective of human health and
the environment, and comply with  ARARs,  the DEPE   and  EPA have
determined that the selected remedy provides the best balance  in
terms  of long-term  effectiveness  and  permanence,  reduction  in
toxicity, mobility,  or volume achieved  through treatment,  short-
term  effectiveness,   implementability,   cost,     and  community
acceptance.

The selected alternative  reduces  toxicity, mobility,  and volume of
contaminants in  the  ground water;  complies  with  ARARs;  provides
both short-term  and  long-term effectiveness; and protects human
health and the environment. Contaminants  in  the ground water will
be  removed and  treated.   This will  significantly  reduce  the
toxicity, mobility and volume of  the contaminants,   and  offer a
permanent solution to  the risks  posed by  the contaminated ground
water.
COST EFFECTIVENESS

The selected alternative is determined to be cost effective because
it  provides  the  highest degree  of  protectiveness  among  the
alternatives evaluated at reasonable cost.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

By  extracting and  treating the  contaminated ground  water,  the
selected remedy addresses the threats posed by the site  through the
use of treatment technologies.  Therefore,  the statutory preference
for  remedies that  employ  treatment  as  a  principal  element  is
satisfied by the selected remedy.

-------
FOKMCK
INDUSTRIAL MKKWAY
RADIATION TECHNOCDOY.
INC. ACTIVE co*ptsx
              RADIATION TECHNOLOGY,INC Rl/FS

                 SITE LOCATION MAP

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                                                                                     LEGEND
9

\
                                                                                              FORMER ROCKAVMY
                                                                                              INDUSTRIAL PARKWAY
                                                                                     Y////X «*OIATION TECHNOLOGY.
                                                                                     I/////I INC. ACTlvftCONvW-RK
                                                                                            | UNDEVELOPED
                           RADIATION TECHNOLOGY, INC. RI/FS
                            PROPERTY IDENTIFICATION
                          WITHIN THE RTI STUDY AREA
                                                                                       lOURCCi ATI MMNM Htt M.MTt NWMOVN

-------
                 RADIATION TECHNOLOGY INC.
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-------
        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION I I
                          26 FEDERAL PLAZA
                      NEW YORK. NEW YORK 1O278
 MAR 3 0 1S34

Robert C. Shinn, Jr., Commissioner
State of New Jersey
Department of Environmental
  Protection and Energy
401 East State Street
Trenton, New Jersey  08625

Dear Commissioner Shinn:

     The U.S. Environmental Protection Agency (EPA) has evaluated
and concurs with the remedy recommended by the New Jersey
Department of Environmental Protection and Energy  (NJDEPE) for
remediation of ground water contamination at the Radiation
Technology Incorporated Superfund site in Rockaway Township,
Morris County, New Jersey.

     The remedy, which consists of Alternative 3GW described in
the February 1993 Feasibility Study report and the July 1993
Proposed Plan, addresses the current and future threats to human
health and the environment associated with contaminated ground
water at the site.  The need for remediation of contaminant
sources will be addressed in a subsequent decision document.
The major components of the ground water remedy include:

          Restoration of the contaminated ground water to the
          more stringent of the federal and New Jersey Safe
          Drinking Water Act Maximum Contaminant Levels (MCLs)
          and New Jersey Ground Water Quality Standards, through
          extraction of the more highly contaminated ground water
          and natural attenuation of residual ground water
          contamination;

     -    Treatment of the extracted ground water to levels
          attaining the more stringent of the federal and New
          Jersey MCLs and New Jersey Ground Water Quality
          Standards;

     -    Reinjection of treated ground water; and

     -    Appropriate environmental monitoring to ensure the
          effectiveness of the remedy.

-------
     The Record of Decision (ROD) which NJDEPE provided to EPA
evaluated several alternatives in the remedy-selection process.
These included a no action alternative (Alternative 1GW); an
institutional control alternative (2GW); three alternatives in
which contamination from the more highly contaminated portion of
the contaminant plume would be extracted, with natural
attenuation of residual contamination (3GW, 4GW, and 5GW); and an
alternative involving the active restoration of the entire
contaminated bedrock aquifer (6GW).

     Although EPA agrees with the remedy recommended by NJDEPE
(i.e., Alternative 3GW), EPA does not fully concur with the
rationale reflected in the ROD for selection of that alternative.
In particular, EPA disagrees with NJDEPE's use of the Industrial
Site Recovery Act in the remedy selection process.

     As you are aware, the methodology for identifying applicable
or relevant and appropriate requirements (ARARs) and the remedy
selection process for sites addressed under the Comprehensive
Environmental Response, Compensation and Liability Act as amended
(CERCLA) are set forth in the National Contingency Plan (NCP).
It is EPA's view that the identification of ISRA as an ARAR and
as a basis for rejecting or recommending any remedial action
alternative is not in accord with the NCP and, therefore, EPA
cannot fully concur in the rationale used by NJDEPE to identify
Alternative 3GW as the selected remedy.  EPA, however, does
believe that Alternative 3GW is an acceptable remedy under the
NCP.  The reasons for that conclusion are set forth below.

     All of the active restoration alternatives (3GW through 6GW)
appear to be protective of human health and the environment; to
comply with applicable or relevant and appropriate requirements;
and to reduce the toxicity, mobility, and volume of contamination
through treatment.  All three active remediation alternatives
also appear to provide short-term and long-term effectiveness,
and permanence.

     It is recognized that because Alternatives 3GW, 4GW, and 5GW
rely on the natural attenuation of residual contamination,
Alternative 6GW might result in the achievement of cleanup goals
in a shorter time period than the others.  However, due to the
complex nature of the bedrock aquifer at the Radiation Technology
site, as well as the wide dispersion of contaminants, the
technical feasibility of complete aquifer restoration as
envisioned in Alternative 6GW is questionable.  Further, it is
believed that the selected remedy, Alternative 3GW, will result
in the cost-effective extraction and treatment of a majority of
the contaminants that are estimated to pose a significant risk
under future-use scenarios, while cleanup objectives would be
attained for the less-contaminated ground water through natural
attenuation processes.  The selected remedy also provides for
monitoring of the less-contaminated ground water to determine if

-------
                                -3-

additional active remediation will be necessary.  Therefore, EPA
has concluded that Alternative 3GW is the appropriate CERCLA
remedy for ground water at the site.

     The selected remedy is consistent with the preferred
alternative described in the Proposed Plan including the need to
address the remediation of site soils and other contaminant
sources in a subsequent ROD.  Since the remedy will result in
hazardous substances remaining on the site above health-based
levels, a review will be conducted within five years after
commencement of the remedial action to ensure that it continues
to provide adequate protection of human health and the
environment.

     We look forward to working with NJDEPE toward the
remediation of the Radiation Technology site.  If you have any
questions, or would like to discuss this matter further, please
do not hesitate to contact me.

                                   Sincerely,
                                   William Jy^Juszyns^a, P.E.
                                   Acting Regional Iwiininistrator

-------
RADIATION TECHNOLOGY INC.
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20.000
40
100
900
3
0.2

-------
                                           RADIATION TECHNtiBBGV INC.
                         CHEMCAL SUMMARY AMD ARARs FOR SELECTED DEEP GROUND WATER
Compound
lflMMM^tfvlf*A
inonianica
Aluminum
ArMflfc
Barium
CaWum
Coooof
****rf^
Cyantia
Iron
Uad
Mapnaslum
Manoanaao
NcMHSoUltMltt)
Potottlum
SMvar
Sodum
Vanadum
Zinc
Fraquancyol .
Detection

5/6
1/6
1/6
6/6
6710
1/19
4/6
3/19
6/6
6/6
1/6
S/6
019
676
1/2
3/13
Maximum
Detected Value,
ug«

366
. t-«'c.
16*C
69.900
10
11.0
1,730*
14.1
12.700
306
e-c
2.030*0
25J
13^00*
rc
136
Avaraga Dalactod Fadaral MCL,
Valua. wg/l ugn

171
1.6
16
21.516
66
12
1.169
10
6.147
92
e
1.492
22
7^65
7
72

50-200
50
2.000
-
1.000
200
300
15
-
SO
100
-
50
-
-
5.000
Practical NJOEPE Ground
OuanlilatkMi Water Criteria,
Lavala. uo/l ug/l

200
e
200
-.
1,000
40
100
10
-
6
10
«•
2
400
—
30

200
0.02
2.000
-
1.000
200
300
6
-
60
100
-
_
10,000
_
5.000
NCMM:
H
i2l
Numbar ot Minptaa doaa not Muda rajacted or blank conuirinafon samplat
Fadaral MCU art National Primary Drinking Walar Raguladom; FbMl Ruto 1991
NJOEPE Ground Water Siandanto ara NJAC 7*<
Wnara NJOEPE Practical Quandteiton Uval (POL) Is Mghar niinwk^t^an^NJDEPE Gtou^ Walar
Wa> P-6 pump Met and raddmtfal wal data not Inducted

-------
                                  TABLE   2.1
                SUMMARY OP CARCINOGENIC RISK ESTIMATED FOR THE
                           RADIATION TECHNOLOGY SITE
SCENARIO
RECEPTOR
PRESENT/FOTORB    TOTAL RISK
GROUND WATER - CHEMICAL  CONTAMINANTS

Ingestion                Resident

Dermal Contact           Resident

Inhalation               Resident
                        P           2xlO"3**

                        P           1x10'**

                        P           2x10"**

                              Total 2xlO"3**
•Exceeds 10*6 risk
**Bxceeds 10'* risk

-------
                                  TABLE  2.2
               SUMMARY OF NONCARCINOGENIC RISK ESTIMATED FOR THE
                           RADIATION TECHNOLOGY SITE
Scenario
Receptor
Present/Future
Chronic HI
GROUND WATER-CHEMICAL CONTAMINANTS

Ingestion               Resident

Dermal Contact          Resident

Inhalation   .           Resident
                        F

                        F

                        F
                  5x10*°*
                  7xl(T1*

                  4X10'1

            Total SxlO40*
* - HI exceeds one  (1)

-------
                                      table 3
     Summary of Costs  of Alternatives
Ground Water Remediation

Alternative            Description
 1GW: No Action
2GW:  Institutional
       Control
Establishes a baseline
for comparison with
other alternatives
Five-year site review

Sampling of sentinel
well system
Sampling of site monitor
wells
Sampling of selected
residential wells
Site review every five
years
                      Estimated Costs
                                             Capital:      $0
                                             Annual O&M:  $0
                                             Present Worth: $41,000
Capital:      $228,000
Annual O&M:  $94.000
Present Worth: $2,122,000
                       Time to Complete

                             none
                           30 years
•3GW: Ground Water
      Collection with
      Hydrofracturing
      and Air Stripping
      Treatment
Sampling of sentinel
well system
Point-of-entry treatment
provisions
Hydrofacturing
Air stripping with vapor
phase carbon adsorp-
tion treatment
Discharge of treated
effluent to overburden
water bearing zone
Monitoring
Capital:      $486,000
Annual O&M:  $140,000
  (Years 1 to 5)
Annual O&M:  $108,000
  (Years 6 to 10)
Present Worth: $1,963,000
                            10 years
4GW:  Ground Water
      Collection with
      Hydrofracturing
      and Hydrogen
      Peroxide/Ultra
      Violet Treatment
Sampling of sentinel
well system
Point-of-entry treatment
provisions
Hydrofacturing
Hydrogen Peroxide/UV
treatment with vapor
phase carbon adsorp-
tion treatment
Discharge of treated
effluent to overburden
water bearing zone
Monitoring  	
Capital:      $704,000
Annual O&M:  $233,000
  (Years 1 to 5)
Annual O&M:  $108,000
  (Years 6 to 10)
Present Worth: $2,800,000
                            10 years
•  Selected Remedy
                                                 (Continued)

-------
                                Table 3 (continued)
     Summary of Costs  of Alternatives
Ground Water Remediation
Alternative
5GW:  Ground Water
      Collection and
      Air Stripping
      Treatment
      Without
      Hydrofacturing
Description
• Sampling of sentinel
  well system
• Point-of-entry treatment
  provisions
• Air stripping with vapor
  phase carbon adsorp-
  tion treatment
• Discharge of treated
  effluent to overburden
  water bearing zone
• Monitoring
Estimated Costs
Capital:      $457,000
Annual O&M:  $128,000
  (Years 1 to 9)
Annual O&M:  $108,000
  (Years 6 to 10)
Present Worth: $2,241,000
Time to Complete
    14 years
6GW:  Complete
      Aquifer Restora-
      tion with
      Hydrofracturing
      and Air Stripping
      Treatment
 Sampling of sentinel
 well system
 Point-of-entry treatment
 provisions
 Hydrofacturing
 Air stripping treatment
 with vapor phase carbon
 adsorption treatment
 Discharge of treated
 effluent to overburden
 water bearing zone
 Monitoring
Capital:      $1,015,000
Annual O&M:  $207,000
  (Years 1 to 14)
Annual O&M:  $108,000
  (Years 15 to 19)
Present Worth: $4,445,000
    19 years
                                                                         over—

-------
                      Responsiveness summary
         Radiation Technology Incorporated Superfund site
This responsiveness summary is divided into the following sections:

A.   Overview
B.   Summary of comments received during the public comment period
     and DEPE/EPA response
          — Part I:  Summary of local community concerns
          ~ Part II: Comprehensive response to specific technical
                      questions
C.   Appendices
A. Overview
    4
This Responsiveness  Summary details  public comments and concerns
regarding the proposed remediation for contaminated ground water at
the Radiation Technology Incorporated  (RTI)  Superfund  site.   A
public comment period was held from July 30 to September 27, 1993
to provide parties the opportunity to comment on the Proposed Plan,
Remedial Investigation (RI)  report, Feasibility Study  (FS) report,
and other supporting documents related to the RTI  site.  During the
comment  period   the New  Jersey Department  of  Environmental
Protection and Energy (DEPE) held a  public meeting on August 11,
1993 at  7 p.m.  at the  Rockaway Township Municipal  Building to
discuss results of the RI/FS and to present a preferred alternative
for remediation of contaminated ground water.


B. Summary of Comments Received During the Public Comment Period
   and DEPE/EPA Response

Comments received during the public comment period from the local
community focused  primarily on  private residents' concerns about
their potable water supply,  notifying more residents who  live near
the site about actions related to remedial activity and support for
the preferred alternative.  The responsible party's (RTI) primary
comments  focused  on  its findings that  an  active ground water
treatment system  is  unnecessary and  that natural attenuation and
monitoring will  be  an effective and  less  costly remedy.   The
responsible  party also  commented  that the  health risk to area
residents from site ground water contamination is overstated as no
potable, off-site wells have been impacted to date.


Part I: summary and response to local community concerns

                                28

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Comment:  Two residents expressed concern  about potential ground
          water contamination affecting  their  drinking water and
          requested  to be  included  in  any  future sampling  of
          potable wells around the RTI site.

Response: The DEPE sampled five  residential potable wells during
          the RI in the vicinity  of the these concerned residents.
          None of these five wells were impacted. This information
          was shared with the two residents who commented.  Also,
          they were informed that the DEPE will evaluate if it is
          necessary  to   monitor  their  potable   wells  during
          implementation  of  the  selected alternative.   Finally,
          DEPE recommends  that residents with private potable wells
          have their water tested annually or on a periodic basis
          following  the  advice  of  the Rockaway Township health
          officer.


Comment:  One resident (in the Lake Telemark neighborhood) near the
          southeastern, undeveloped  side of the RTI site expressed
          concern that he received notice  of the August 11, 1993
          public  meeting  in the mail  only one  day  before the
          meeting was  scheduled  to  be held and that  it was the
          first time he had  heard about  contamination at the RTI
          site since moving to the community in 1984.

Response: Residents along Lake  Denmark Road,  who are closer to the
          •active RTI portion of the  site, were notified two weeks
          prior to  the public meeting.   Historically,  DEPE has
          primarily dealt with residents and developers concerned
          about properties along Lake Denmark Road.  Residents of
          the Lake Telemark area were mailed public meeting notices
          only a few  days  before the meeting after their names were
          added to DEPE's mailing list as a result of information
          requested  by the  Department  and  received from  the
          Rockaway Township Health Department.  Rockaway Township
          officials also received notice  of the public meeting two
          weeks prior through the mail and more than a month prior
          through telephone  conversations.   Finally,  a newspaper
          advertisement announcing  the  public meeting  date and
          preferred alternative was  published in the July 30, 1993
          edition of  the "Daily Record11 (Morristown).  DEPE regrets
          that  the  mailing  list was not  expanded and updated
          earlier for  residents  in  the  Lake Telemark community.
          DEPE  will  work . with  the  Rockaway  Township  Health
          Department to further expand its mailing list in the Lake
          Telemark community so  that its  residents  will receive
          timely notice of major site activities.
Comment:  One resident stated that children can enter the RTI site
          on the  eastern  side of the property line through many

                               21

-------
          large  holes  in  an  existing  fence.    This  resident
          requested that  warning signs be put up  on the fencing
          around  the  site to  keep  unsupervised  children  from
          entering the property.

Respons*: DEPE will discuss with the responsible party this request
          to  secure  the   fencing  around the  site  and to  post
          appropriate warning signs.


Comment:  Assemblyman  Joseph V.  Doria Jr.  requested  that  DEPE
          consider  RTI's  position  that  an  active  ground  water
          treatment system is unnecessary and  requested that the
          Department   change   the   preferred  alternative   to
          Alternative 2GW.

Response: DEPE provides responses to Mr.  Doria's comments in Part
          II:   Comprehensive   Response  to  Specific  Technical
          Questions as they are similar to comments received from
          the responsible  party itself.
    «.

Comment:  Rockaway Township Health Officer Steve Levinson provided
          comments in support of the preferred Alternative 36W and
          requested that  DEPE continue to involve his office in
          future sampling  events of residential potable wells.

Response: DEPE will  continue to work with the Rockaway Township
          Health  Department  to  coordinate  private  potable  well
          sampling events  in the future and ensure the results are
          forwarded to the health officer for appropriate action.
Part ZZ: Comprehensive Response to Specific Technical Questions

Comment:  RTI  does not agree  that provisions for  the potential
          presence  of a  Dense Non-Aqueous Phase Liquid (DNAPL)
          should  be  included as  a  factor  in  the  remedial
          alternatives considered in the FS.

Response: Freon-113,  a  DNAPL, is  present  and is a site-related
          contaminant.  The highest concentration of Freon-113 in
          ground water to date is 13,000 micrograms per  liter (ug/L
          or parts per billion).  While this concentration is below
          the  health  based criteria  developed by DEPE consistent
          with state  Ground Water  Quality  Standards (NJAC 7:9-6)
          (6WQS), the Department is concerned  with the possibility
          that Freon-113  exists  in  the  bedrock  aquifer  in
          concentrations  indicative of free product.  The aqueous
          solubility  of Freon-113 is 136,000 ug/L.  Freon-113 has
          a specific  gravity of 1.56.  According to EPA's January
          1992  publication  9355.4-07FFS   entitled  "Estimating

                                10

-------
          Potential  Occurrence of  DNAPL at  Super fund  Sites"  a
          compound need only  approach  one percent of its aqueous
          solubility  to  be  suspected  of  being present  as free
          product.   At the  RTI,  site  Freon-113 has  reached 10
          percent of  its  aqueous  solubility.   DEPE believes that
          the area containing the  highest concentrations of Freon-
          113, in the area of well P-6,  should be hydraulically
          controlled  as   a contaminant  source  control  measure.
          Furthermore, additional remedial measures for collecting
          any identified free product may be implemented.
Comment:  RTI  disagrees with  the Proposed  Plan  statement "The
          bedrock aquifer which underlies the RTI property serves
          as a sole drinking water source for area residents.  For
          this reason, complete aquifer remediation was considered
          as an alternative."

Response: The aquifer below the RTI site is the sole or principle
          source  of  drinking  water  for the  population  in  the
          region.  In addition, this aquifer (the Highlands Aquifer
          System) is classified as Class  IIA  per N.J.A.C. 7:9-6 et
          sea.  This classification identifies  the ground water as
          a  primary drinking  water  source  in the State  of  New
          Jersey .


Comment:  RTI states that the Risk Assessment future use scenarios
          are too conservative and inappropriate for the RTI site.

Response: The  future  use scenarios  as  presented  in the  Risk
          Assessment  are appropriate  for  this site  as required
          under EPA guidance.   This  is  primarily because it is
          possible  that the site or  surrounding  area  could be
          developed in the future  for residential use and that such
          development  may involve  the installation  of drinking
          wells.  Also, in accordance with P.L. 1993, c.139, DEPE
          addresses permanent remedies at contaminated sites.  And
          even if a permanent remedy is not selected,  removal of a
          ground  water contamination  source  is consistent with
          EPA's  Office  of Solid Waste  and  Emergency  Response
          Directive   9236.2-25  "Guidance   for  Evaluating  the
          Technical Impracticability of Ground  Water Restoration."
          Finally, the selected remedy complies with the provisions
          in P.L. 1993, c.139,  Section 35g that a permanent remedy
          (6GW) that costs 50 percent or more  than a nonpermanent
          remedy will not be selected.
Comment:  RTI stated  that  there  is no evidence that ground water
          discharge is occurring from the bedrock to Lake Denmark
          and  that  a dilution  calculation  should  be used  to

                               11

-------
          determine ground water contaminant impacts  to surface
          water.

Response: Sampling data  indicates that  sediments  in Lake Denmark
          are  contaminated  at  low  levels  with  site-related
          contaminants.  The presence of these contaminants, while
          not considered a problem  for the lake at the present
          time,  indicates  that  ground  water  is  most  likely
          discharging to the lake.  In addition, there is hydraulic
          head evidence as well as topographic evidence that ground
          water  is  discharging to Lake Denmark.   DEPE  does not
          accept dilution calculations for determining ground water
          impacts to surface water since  ground water  may impact
          organisms prior to dilution.  Typically,  DEPE compares
          ground  water   samples  from  the  wells  closest  to
          potentially-impacted water bodies  (in  this case  Lake
          Denmark) directly to federal or state in-stream criteria.
          Also,  DEPE  compares  these   ground  water  samples  to
          remedial discharge criteria derived from the Department's
          "Technical Manual for Discharges to Surface Hater" (July
          1993).

Comment:  RTI  states  that  DEPE  did  not  seriously  consider
          institutional controls, natural  attenuation and sentinel
          monitoring as an alternative for ground water remediation
          of the RTI site.

Response: DEPE considered and  thoroughly  evaluated institutional
          controls, natural attenuation and  sentinel monitoring in
          the  Feasibility Study.   DEPE's  preferred alternative
          includes natural attenuation as an integral part of the
          remedy.    Specifically,  natural   attenuation  will  be
          effective in the bedrock aquifer throughout most of the
          site except  for the  area around well P-6.   A  pump and
          treat  system is required  in the  area  of well  P-6 to
          control the source of ground water contamination.  There
          are several reasons that the area around  well  P-6 must be
          actively  treated.   First, the  concentration  of 1,1,1
          trichloroethane  (1,1,1 TCA) has  averaged more than 1,000
          ug/1 in well P-6 during the last 12 years.  This average
          concentration is more than  35 times higher than the state
          GWQS  for a  Class II-A  aquifer.     Second,  this  well
          contains levels of Freon indicative of free product and
          is one of three proposed extraction wells.  Third, other
          contaminants found in production and monitor wells exceed
          Class II-A standards by one to two orders of magnitude.
          One  proposed  extraction  well,   14-D,  contains  vinyl
          chloride at 99 ug/1,  which is above the 0.08 ug/1 state
          GWQS.  A third well  is proposed to be ,a new extraction
          well installed to create  a  desired cone of depression in
          the hot spot area.  These wells are only  proposed and are
          subject to change based on the actual design.

                               12

-------
          The  Department only  considers  a natural  remediation
          system if all sources of contamination and free product
          have been controlled.  The Department  believes that there
          is a potential that Freon-113  free product exists in the
          bedrock aquifer at  this site.   The fact that 1,1,1 TCA
          concentrations have not significantly decreased for more
          than a decade may  indicate that a source  of 1,1,1 TCA
          exists as well.  In addition,  contaminants present must
          not exist in concentrations that are expected to impact
          an ecological receptor above  applicable standards.   In
          this case, the state  or  federal in-stream criteria and
          state remedial discharge criteria would be the applicable
          standard in monitor wells close to Lake Denmark before
          dilution  occurs.    Finally, the selected remedy  has a
          lower cost than Alternative 26W,  solely a monitoring and
          natural attenuation alternative.

          Overall, data indicates that  product is present in the
          fractured bedrock below the water table. Alternative 3GW
          would  contain and  monitor this product  in the  most
          contaminated  area  and allow  the rest of the  site  to
          attenuate naturally.

Comment:  RTI contends  contaminant  concentrations are decreasing
          all across the site.

Response: A comparison of data  from 1987  to 1992 shows that most
          contaminants  of  concern  remained fairly constant  or
          slightly  increased.    Hence,  current  data  are  not
          sufficient to establish a definite downward trend.   If
          source removal  is  complete and there are  no residual
          sources in the aquifer, then  contaminant levels should
          naturally attenuate with time.  However, the Department
          believes that product sources  still exist in the bedrock
          aquifer that need to be remediated.


Comment:  RTI states that  the Department  has  "dismissed" ground
          water quality  sampling in the  overburden  and that the
          proposed plan does not rely heavily upon this data.

Response: The Proposed Plan does rely upon overburden ground water
          quality  data to  make the  determination  that  natural
          attenuation should be effective in the overburden water
          bearing  zones as noted  in  the  preferred alternative.
          Continued monitoring  of the  overburden aquifer  is  an
          integral part of the preferred alternative to be employed
          at the RTI site.


Comment:  RTI states that existing ground water contamination can
          flow only in a northwesterly direction.

                                ai

-------
Response: The Department disagrees with this  statement.   The RTI
          site is  situated  on a hydrogeologic  divide  and ground
          water may  migrate  in  a number  of  directions.   Also,
          ground water  located  at well P-2  (a  contaminated well
          located on or near this ground water divide) can migrate
          in a southeasterly direction towards on-site wetlands and
          a stream which discharges to Lake Telemark.  Also, ground
          water contamination has already migrated to well MW-18D
          which is southwest of  well P-6  and  well MW-14D (the
          presumed source area).  In addition, this statement does
          not consider that  the aquifer  is fractured  bedrock.
          Ground water will  migrate in a preferred direction along
          fracture strikes in a bedrock aquifer.


Comment:  RTI states that it is already engaged in remediation by
          pumping and treating one of its wells, P-2, in order to
          use the water for sanitary purposes.

Response: DEPE disagrees with RTI that its current minimal pumping
          of well P-2 is an  effective  ground water remedy.  Levels
          of VOCs in well P-2 are about one third to one half the
          those detected in  well P-6,  one of three extraction wells
          proposed as part of Alternative 3GW.  Natural attenuation
          will be a sufficient remedy for the area around well P-2.
          Pumping well P-2 does  not capture the  contaminant source
          area because its hydraulic influence is insufficient.


Comment:  RTI  challenges   DEPE's   capitol  cost   estimate  for
          implementing the preferred alternative and contends that
          it  can  implement  the  remedy for  less  money  than the
          state.

Response: DEPE's capital cost estimate is more than $200,000 above
          RTI's estimate.   Most of the difference  occurs in the
          drilling costs  of new wells  or expansion  of  existing
          wells.  DEPE agrees that RTI can implement the preferred
          alternative for less cost than presented in the Proposed
          Plan.
Comment:  RTI  commented  on  the  proposed  number,  depths  and
          locations of sentinel wells.

Response: Pursuant to  the state AGO, RTI  will propose
          the sentinel monitoring system for DEPE review
          during design.
Comment:  RTI suggests removing well RW-4 and well RW-5
          from the list of wells which will be monitored

                               34

-------
          as part  of protection of human  health.   RTI
          also suggests that  veils  RW-l,  RW-2 and RW-3
          should  be  sampled  only  once  and then  the
          sentinel veil system  be allowed to take over
          to   protect  these  veils   from   potential
          contaminants.   Lastly, RTI  suggests that the
          list  of analytes   for the residential  veil
          sampling   be  restricted  to   site  related
          contaminants  of concern  as  defined by  the
          Proposed Plan.

Response: Pursuant to the state AGO, RTI vill propose a
          residential   veil  monitoring   system   and
          protocol for DEPE reviev during design.


Comment:  RTI suggests that "ground vater contamination" be defined
          as  the  contaminants  of   concern   used  for the  risk
          assessment.

Response: Ground   vater  contaminants  are   defined  by   those
          constituents detected in  the ground vater  that  exceed
          state GWQS and federal MCLs.


Comment:  RTI suggests that  hydrofracturing not be used  for the
          purpose of remediation because contaminants may be spread
         •through the aquifer.

Response: Pursuant to the state AGO, RTI vill evaluate the use of
          hydrofracturing  during design   for DEPE  reviev  vhen
          aquifer pumping tests  vill be performed.  After hydraulic
          data are collected and aquifer characteristics are better
          known,  a  determination   can be  made  concerning  the
          appropriateness of  hydrofracturing the aquifer.


Comment:  RTI suggests that pulse pumping may not be an effective
          means to.control ground vater contamination.

Response: Pursuant  to  the   state  AGO,  RTI  vill  propose  the
          frequency  of pumping  in  design.   The system vill be
          designed  to  control  the  most  significant  area  of
          contamination.


Comment:  RTI  states  that  methylene chloride  and acetone  data
          should not be mentioned due  to the presence of these
          contaminants in sample blanks.

Response: DEPE believes  that  acetone and  methylene  chloride are
          present in the  ground vater  at  the RTI site.  Although

                                15

-------
          acetone and methylene chloride were found in ground water
          samples  and laboratory  blanks,  the  concentrations at
          which these compounds were detected in ground water were
          much  higher than would  be  expected  from  laboratory
          contamination alone.  Therefore, the Department believes
          that these compounds are present in the ground water at
          the site.  The fact that acetone and methylene chloride
          have been detected was not a key factor into the final
          decision to perform an active remediation at the site.


Comment:  RTI noted "The analytical data are reported by Acres as
          not yet having been validated."

Response: All data has now been validated by DEPE.


Comment:  RTI  commented  "Of  the   VOCs detected,  many  of  the
          detections  are  J-values  resulting  from large dilution
          factors and may not, in fact, be accurate.11

Response: RTI's suggestion that J values should  not be included is
          not valid.  When values are nJ'd,n  it  simply indicates a
          quantitative estimate.   Qualitatively,  the compound is
          present and cannot be ignored.


Comment:  RTI states that the saprolite layer is a very effective
          confining layer  between  overburden and bedrock,  along
          Lake Denmark.

Response: The  data  collected  in  the  RI  do  not support  this
          conclusion.  Data indicate that  the saprolite layer is
          not continuous along Lake Denmark.   Therefore, it cannot
          act as  an effective confining unit along  Lake Denmark
          except in localized areas.
Comment:  RTI states that the bedrock is not heavily fractured, and
          the  350 feet  deep production  well will  only support
          pumping  of 29  gallons per minute.   RTI further states
          "this  observed specific capacity is  consistent with a
          range  of hydraulic conductivities  for the  bedrock of
          about  2xlO~* to 2xlO~5 ft3/ft2/min.n

Response: DEPE   believes  that  there  is  insufficient  data  to
          accurately determine hydraulic conductivity at this time.
          Pursuant to the  state AGO,  RTI will  perform aquifer
          pumping  tests during design.  If it  is determined that a
          pumping  rate can not be achieved to contain the area of
          highest  ground water  contamination,  RTI  will propose
          measures to increase  conductivity in the aquifer (i.e.

                                16

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          hydrofracturing) for DEPE review.


Comment:  RTI requested a copy of the public meeting transcript and
          slides  used  for  the  presentation by  OEPE  and  its
          contractors.

B«»pon»«: A  copy  of each  document is attached  to  the
          Responsiveness Summary.
C.   Appendices


                                37

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t .
           Appendix 1.    Proposed Plan
           Appendix 2.    Public    notice    that
                          appeared  in  the   "Daily
                          Record" (Morristown)
           Appendix 3.    Public meeting transcript
           Appendix 4.    Slides  used   at   public
                          meeting by  DEPE and  its
                          contractors
           Appendix 5.    Written    comments
                          submitted   during    the
                          public comment period
                                     38

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION I I
                          26 FEDERAL PLAZA
                      NEW YORK. NEW YORK  1O276
Robert C. Shinn, Jr., Commissioner
State of New Jersey
Department of Environmental
  Protection and Energy
401 East State Street
Trenton, New Jersey  08625

Dear Commissioner Shinn:

     The U.S. Environmental Protection Agency (EPA) has evaluated
and concurs with the remedy recommended by the New Jersey
Department of Environmental Protection and Energy  (NJDEPE) for
remediation of ground water contamination at the Radiation
Technology Incorporated Superfund site in Rockaway Township,
Morris County, New Jersey.

     The remedy, which consists of Alternative 3GW described in
the February 1993 Feasibility Study report and the July 1993
Proposed Plan, addresses the current and future threats to human
health and the environment associated with contaminated ground
water at the site.  The need for remediation of contaminant
sources will be addressed in a subsequent decision document.
The major components of the ground water remedy include:

     -    Restoration of the contaminated ground water to the
          more stringent of the federal and New Jersey Safe
          Drinking Water Act Maximum Contaminant Levels (MCLs)
          and New Jersey Ground Water Quality Standards, through
          extraction of the more highly contaminated ground water
          and natural attenuation of residual ground water
          contamination;

     -    Treatment of the extracted ground water to levels
          attaining the more stringent of the federal and New
          Jersey MCLs and New Jersey Ground Water Quality
          Standards;

     -    Reinjection of treated ground water; and

     -    Appropriate environmental monitoring to ensure the
          effectiveness of the remedy.

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     The Record of Decision (ROD) which NJDEPE provided to EPA
evaluated several alternatives in the remedy-selection process.
These included a no action alternative (Alternative 1GW); an
institutional control alternative (2GW); three alternatives in
which contamination from the more highly contaminated portion of
the contaminant plume would be extracted, with natural
attenuation of residual contamination (3GW, 4GW, and 5GW); and an
alternative involving the active restoration of the entire
contaminated bedrock aquifer (6GW).

     Although EPA agrees with the remedy recommended by NJDEPE
(i.e., Alternative 3GW), EPA does not fully concur with the
rationale reflected in the ROD for selection of that alternative.
In particular, EPA disagrees with NJDEPE's use of the Industrial
Site Recovery Act in the remedy selection process.

     As you are aware, the methodology for identifying applicable
or relevant and appropriate requirements (ARARs) and the remedy
selection process for sites addressed under the Comprehensive
Environmental Response, Compensation and Liability Act as amended
(CERCLA) are set forth in the National Contingency Plan (NCP).
It is EPA's view that the identification of ISRA as an ARAR and
as a basis for rejecting or recommending any remedial action
alternative is not in accord with the NCP and, therefore, EPA
cannot fully concur in the rationale used by NJDEPE to identify
Alternative 3GW as the selected remedy.  EPA, however, does
believe that Alternative 3GW is an acceptable remedy under the
NCP.  The reasons for that conclusion are set forth below.

     All of the active restoration alternatives (3GW through 6GW)
appear to be protective of human health and the environment; to
comply with applicable or relevant and appropriate requirements;
and to reduce the toxicity, mobility, and volume of contamination
through treatment.  All three active remediation alternatives
also appear to provide short-term and long-term effectiveness,
and permanence.

     It is recognized that because Alternatives 3GW, 4GW, and 5GW
rely on the natural attenuation of residual contamination.
Alternative 6GW might result in the achievement of cleanup goals
in a shorter time period than the others.  However, due to the
complex nature of the bedrock aquifer at the Radiation Technology
site, as well as the wide dispersion of contaminants, the
technical feasibility of complete aquifer restoration as
envisioned in Alternative 6GW is questionable.  Further, it is
believed that the selected remedy, Alternative 3GW, will result
in the cost-effective extraction and treatment of a majority of
the contaminants that are estimated to pose a significant risk
under future-use scenarios, while cleanup objectives would be
attained for the less-contaminated ground water through natural
attenuation processes.  The selected remedy also provides for
monitoring of the less-contaminated ground water to determine if

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                                -3-

additional active remediation will be necessary.  Therefore, EPA
has concluded that Alternative 3GW is the appropriate CERCLA
remedy for ground water at the site.

     The selected remedy is consistent with the preferred
alternative described in the Proposed Plan including the need to
address the remediation of site soils and other contaminant
sources in a subsequent ROD.  Since the remedy will result in
hazardous substances remaining on the site above health-based
levels, a review will be conducted within five years after
commencement of the remedial action to ensure that it continues
to provide adequate protection of human health and the
environment.

     We look forward to working with NJDEPE toward the
remediation of the Radiation Technology site.  If you have any
questions, or would like to discuss this matter further, please
do not hesitate to contact me.

                                   Sincerely,
                                         ^
                                   William J,rfiuszynsfcf, p.E.
                                   Acting Regional Jreuninistrator

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                          ROD FACT SHEET

SITE	
Name           :    Radiation Technology Incorporated  (RTI)
Location/State :    Morris County, New Jersey
EPA Region     :    II
HRS Score (date):   42.56  (5/26/83)
Site ID #      :    NJD 047 684 451
ROD
Date Signed:        May 9, 1994
Remedy/ies: Pump and treat, via air stripping, contaminated
            groundwater
Operating Unit Number: OU-1
Capital cost: $ 486,000    (in 1994 dollars)
Construction Completion: late 1996    (month/year)
O & M 1997 through 2001: $140,000  (in 1994 dollars)
O & M 2002 through 2006: $108,000  (in 1994 dollars)
Present worth: $1,963,000
LEAD
Remdial/Enforcement:  Enforcement
EPA/State/PRP: State lead
Primary contact  (phone):  Gil Horwitz   (609) 633-0767
Secondary contact  (phone): Romona Pezzella  (212) 637-4385
Main PRP(s):  RTI
PRP Contact  (phone)
WASTE
Type:  volatiles
Med ium: groundwater
Origin: testing and development of rocket engines and propellants
Est. quantity  (cu.yd., gal., # drums, etc.)

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