United States
Environmental Protection
Agency.
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/080
June 1989
3EPA
Superfund
Record of Decision
Montclair/West Orange
Radium, NJ
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50272-101
"REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/080
X Recipient's Accession Ho.
4. Tltte and Subtloe
SUPERFUND RECORD OF DECISION
Mqntclair/West Orange Radium, NJ
First Remedial Action
5. Report Date
06/30/89
7. Author(t)
8. Performing Organization Rapt No.
9. Performing Orgdniatfon Nun* and Address
10. Protect/Task/Work Unit No.
11. Contncl(C) or Grsnt(G) No.
(Q
(G)
11 Sponsoring Organization Nun* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type of Report A Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Umil: 200 words)
The Monclair/West Orange Radium site is in the towns of Montclair and West Orange in
Essex County, New Jersey. The site covers approximately 120 acres of residential
neighborhoods. The Glen Ridge Radium site is adjacent to this site and is being
addressed concurrently under one remedial action. The soil at the site is contaminated
•with radioactive waste materials suspected to have originated from radium processing or
Hltilization facilities located nearby during the early 1900s. The waste material was
| disposed of in then-rural areas of the communities. Houses were subsequently
I constructed on or near the radium waste disposal areas. Some of the radium-contaminated
soil is believed to have been used as fill in low-lying areas, and some of the fill was
mixed with cement for sidewalks and foundations. Temporary .radon ventilation systems
and gamma radiation shielding have been installed and maintained by EPA and the State to
reduce indoor exposures. In June 1985 the State initiated a pilot study, excavated
portions of the radium-contaminated soil and disposed of the soil offsite. The primary
contaminant of concern affecting the soil and structures is radium226 which decays to
radon gas. .
(See Attached Sheet)
17. Document Analysis a. Descriptor*
Record of Decision - Montclair/West Orange Radium, NJ
First Remedial Action
Contaminated Media: soil, debris
Key Contaminant: radium226
b. Identiilera/Open-Ended Terms
k-
^B. AVI
c. COSATI Held/Group
Avsil«bilty Sutement
19. Security Class (This Report)
None
20. Security Clsss (This Psge)
None
21. No. of Pages
98
22. Price
(See ANSI-Z3i.18)
See Initruetien* en fievene
Or HUNAU rOHM 272 (4*77)
(Formerly NTIS-35)
Department ol Commerce
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(4-77)
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EPA/ROD/R02-89/080
Montclair/West Orange Radium, NJ
First Remedial Action
16. Abstract (continued)
The selected remedial action for this site includes excavation of approximately
41,000 yd3 of highly contaminated soil and an unspecified amount of debris followed by
offsite disposal; installation and maintenance of indoor engineering controls at less
contaminated properties; environmental monitoring to ensure remedy effectiveness; and
continuation of a treatment technology study for future actions. EPA deferred a final .
decision for the less contaminated properties until after a 60-day public comment period
extension. The estimated present worth cost for this remedial action is $53,000,000
with no O&M costs.
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DECLARATION STATEMENT
RECORD OF DECISION
Montclair/West Orange Radium Site
ocation
Montclair/West Orange Radium Site, Essex County , New Jersey
of Basi d Purpose
This decision document presents the selected remedial action for
the Montclair/West Orange Radium site, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Super fund Amendments and
Reauthorization Act, and to the extent applicable, the National
Contingency Plan. This decision is based on the administrative
record for the site. The attached index identifies the items
that comprise the administrative record upon which the selections
of the remedial action is based.
The State of New Jersey concurs with the selected remedy.
Assessment of the Site
Actual or threatened exposures to hazardous substances released
from those site properties addressed in this Record of Decision
may present an imminent and substantial endangerment to public
health, welfare or the environment, if the response actions
selected in this Record of Decision are not implemented.
Description of the Remedy
The remedial action presented in this document represents the
first planned for the site. It provides a permanent solution for
many of the residential properties, including those with the most
extensive contamination. This action also provides an interim
solution for a number of contaminated properties, where radon gas
and/or indoor gamma radiation levels exceed health guidelines.
Additional: -remedial measures for these and other properties, both
public and private, with radium-contaminated soil above cleanup
standards, will be selected in a future Record of Decision after
further public comment.
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DECLARATION STATEMENT
RECORD OF DECISION
Glen Ridge Radium Site
s Mania BB*8 Location .
Glen Ridge Radium Site, Essex County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Glen Ridge Radium site, developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act, and to the extent applicable, the National Contingency Plan.
This decision is based on the administrative record for the site.
The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial
action is based. \
The State of New Jersey concurs with the selected remedy.
Assessment of the Site
Actual or threatened exposures to hazardous substances released
from those site properties addressed in this Record of Decision
may present an Imminent and substantial endangerment to public
health, welfare or the environment, if the response actions
selected in this Record of Decision are not implemented.
Description of the Remedy
The remedial action presented in this document represents the
first planned for the site. It provides a permanent solution for
many of the residential properties, including those with the most
extensive contamination. This action also provides an interim
solution for a number of contaminated properties, where radon gas
and/or indoor gamma radiation levels exceed health guidelines.
Additional remedial measures for these and other properties, both
public and private, with radium-contaminated soil above cleanup
standards, will be selected in a future Record of Decision after
further public comment.
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-2-
The selected remedy includes the following components:
- Total excavation of the most extensively contaminated
residential properties, with off-site disposal of radium*
contaminated materials;
- Installation and maintenance of indoor engineering controls
at less contaminated properties;
- Limited or "hot spot" excavation at residential properties,
where removal of small quantities of radium-contaminated
materials will completely remediate such properties;
- Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
- Continuation of treatment technology studies which may offer
practical remedial methods for any future actions at the
sites.
Declarations
The selected remedy is protective of human health and the
environment at many of the properties, and is cost-effective. .
At other properties, it provides for interim measures to reduce
some of the risks attributable to the contaminated soil. Due to
the limited scope of this action, only portions of the remedy
attain Federal and State requirements that are applicable or
relevant and appropriate for the site. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable. However, since treatment of the
principal threats of the site was not found to be practicable., it
does not satisfy the statutory preference for treatment as a
principal element.
Because the selected remedy will result in hazardous substances
remaining above health based levels on a number of properties, a
periodic review of the interim actions (i.e., engineering
controls) will be undertaken to ensure that they continue to
provide adequate protection of human health and the environment.
In addition,. EPA will continue to evaluate potential remedial
measures foe the purpose of providing a permanent solution for
the remaining- contamination.
William J. Muszynski, P.E.
Acting Regional Administrator
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DECISION SUMMARY
Montclair/West Orange and Glen Ridge Radium Sites
BACKGROUND
4 ;
Site Description
The Montclair/West Orange and Glen Ridge Radium sites are listed
as two sites on the Superfund National Priorities List (NPL) .
The two sites include three noncontiguous study areas located in
residential communities of suburban Essex County in northeastern
New Jersey about 12 miles west, of New York City. Figure 1 shows
the locations of the three study areas.
The Montclair study area covers approximately 100 acres and in-
cludes 239 properties in the Town of Montclair and 127 properties
in the Town of West Orange. The West Orange study area covers
approximately 20 acres and includes 75 properties in the Town of\
West Orange. The Glen Ridge study area covers approximately 90
acres and includes 274 properties in the Borough of Glen Ridge
and 32 properties in the Town of East Orange.
study areas are located in the eastern foothills of the
noroieast-southwest trending Watchung Mountains which rise 600
feet above sea level. The general slope of all three areas is to
the southeast, although considerable terracing and filling has
occurred throughout the areas.
The contaminated areas in Montclair, West Orange, Glen Ridge and
East Orange are present in older, well-established residential
neighborhoods with single- and two-family homes. The three study
areas include public areas, such as streets and/or parks, in
addition to the residential properties.
There is no surface water flowing through the Montclair and Glen
Ridge study areas. Wigwam Brook, which originates in the Wat-
chung Mountains, passes through the West Orange study area.
Groundwater? resources within the study areas are an unconsoli-
dated, glacial-overburden aquifer, and the deeper, fractured-
bedrock aquifer of the underlying Brunswick Formation. The
majority of the drinking water supplies for the towns within the
study areas are drawn from surface reservoirs in northern New
Jersey, although some deep bedrock aquifer wells in the vicinity
of the sites are used \for water supply.
Th(
e soil at the sites is contaminated to varying degrees with
active waste materials suspected to have originated from
processing or utilization facilities which were located
nearby in the early 1900s. The material was disposed of in then-
rural areas of the communities. Some of the radium-contaminated
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-2-
The selected remedy includes the following components:
- Total excavation of the most extensively contaminated
residential properties, with off-site disposal of radium-
contaminated materials;
- Installation and maintenance of indoor engineering controls
at less contaminated properties;
- Limited or "hot spot" excavation at residential properties,
where removal of small quantities of radium-contaminated
materials will completely remediate such properties;
- Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
- Continuation of treatment technology studies which may offer
practical remedial methods for any future actions at the
sites.
Declarations
\
The selected remedy is protective of human health and the
environment at many of the properties, and is cost-effective.
At other properties, it provides for interim measures to reduce
some of the risks attributable to the contaminated soil. Due to
the limited scope of this action, only portions of the remedy
attain Federal and State requirements that are applicable or
relevant and appropriate for the site. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable. However, since treatment of the
principal threats of the site was not found to be practicable, it
does not satisfy the statutory preference for treatment as a
principal element.
Because the selected remedy will result in hazardous substances
remaining above health based levels on a number of properties, a
periodic review of the interim actions (i.e., engineering
controls) will be undertaken to ensure that they continue to
provide adequate protection of human health and the environment.
In additionr EPA will continue to evaluate potential remedial
measures foe. the purpose of providing a permanent solution for
the remaining; contamination.
William/CT. Mus&ftski, P.E.
Acting Regional Administrator
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soil is also believed to have been moved from the original dis-
posal locations and used as fill material in low-lying areas.
Houses were subsequently constructed on or near the radium waste
disposal areas (also referred to as "core areas"). In a few in-
stances, it appears that some of the fill was mixed with Portland
cement to make concrete for sidewalks or foundations.
Site History and Enforcement Activities
The Montclair/West Orange and Glen Ridge Radium sites were iden-
tified as a result of a program initiated by the New Jersey
Department of Environmental Protection (NJDEP) to investigate
former radium processing facilities within the State. Recog-
nizing that the radioactive waste materials could have been
disposed of at locations distant from the facilities, NJDEP
requested in 1981 that the Environmental Protection Agency (EPA)
conduct an aerial gamma radiation survey of a 12-square mile area
of Essex County. This aerial survey identified a number of areas
exhibiting elevated levels of gamma radiation. Ground investiga-
tions conducted in 1983 confirmed contamination at the Montclair
and Glen Ridge study areas, and identified several houses with
gamma radiation and indoor concentrations of radon decay products
exceeding acceptable levels. (The West Orange study area was
added to the ongoing investigation in April 1984).
Actions to Date
EPA began preliminary investigations in late 1983 to assess the
extent of contamination at the Montclair/West Orange and Glen
Ridge sites. A program was established to monitor the levels of
radon decay products in affected houses on a quarterly basis.
Since that time, temporary radon ventilation systems and gamma
radiation shielding have been installed and maintained by EPA and
NJDEP to reduce indoor exposures to radon decay products and
gamma radiation. In October 1984, the Montclair/West Orange and
Glen Ridge Radium sites were proposed for inclusion to EPA's Na-
tional Priorities List of Superfund sites. (Final inclusion was
made in a special listing in February 1985). In November 1984,
EPA began a remedial investigation and feasibility study (RI/FS)
to determine the nature and extent of the problem, and develop
remedial alternatives to alleviate it.
Pilot Study Conducted in 1984
In May 1984, EPA and NJDEP jointly planned a pilot study to
evaluate the feasibility of excavation and off-site disposal of
.the radium-contaminated soil. Twelve properties, with varying
degrees of contamination, were selected for the pilot study and
preliminary engineering assessments were prepared. In the fall
pf 1984, EPA decided to forgo the pilot study since the full
•RI/FS had been initiated. NJDEP, however, decided to proceed
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with excavating the contaminated soil and initiated a pilot
program.
NJDEP began excavating in June 1985, after securing a disposal
site for the contaminated soil by contracting with a commercial
disposal facility in Nevada. Four properties in Glen Ridge had
been completely remediated when Nevada revoked NJDEP's disposal
permit. With no disposal facility available, NJDEP was forced to
leave containerized soil at its transloading facility in Kearny,
New Jersey, and around partially excavated properties in Mont-
clair. New Jersey subsequently sued Nevada before the U.S.
Supreme Court to reinstate the permit. While awaiting resolution
of the case, NJDEP continued to pursue other options for disposal
of the excavated materials.
NJDEP was able to remove the containers from Montclair in the
fall of 1987 and, in the summer of 1988, successfully disposed of
the remainder of the soil stored at Kearny. The pilot program
demonstrated that excavation of radium-contaminated soil is a
feasible remedial action, but that transportation and subsequent
disposal of the contaminated material makes any excavation and
off-site disposal alternative an extremely tenuous option. .'
Excavation Alternative Preferred in 1985
EPA issued a draft RI/FS report in September 1985, and announced
a 60-day public review period. EPA then held a public meeting on
November 13, 1985. At that meeting, it was noted that excavation
of the radium-contaminated soil was the Agency's preferred
approach for solving the problems at the sites, but the lack of a
disposal facility prevented the selection of a remedy involving
excavation, with off-site disposal. Because of this, EPA
installed gamma radiation shielding and/or ventilation equipment
in more than twenty additional properties that were affected by
excess radon gas and/or gamma radiation. EPA continued the
quarterly monitoring program and collected data on additional
properties within the study areas. In conjunction with NJDEP,
EPA also continued to maintain the temporary ventilation systems
and gamma radiation shielding. As they were discovered,
additional houses exceeding health guidelines were included in
the quarterly monitoring program.
Supplemental Feasibility Study Initiated
The problems with identifying a viable disposal location, either
in- or out-of-state, combined with the potential for being pre-
vented from using a site once it had been identified, as
evidenced by NJDEP's earlier efforts, led to a decision to re-
examine and search out additional remedies. EPA began a supple-
Cental feasibility study in March 1987 to develop and evaluate
measures to protect public health. As that study progressed, it
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ipame apparent that an evaluation of both interim and final
edial measures would need to be included.
Enforcement Activities
There are numerous allegations about the source of the materials
that were disposed of at and near the Montclair/West Orange and
Glen Ridge sites. However, as yet, there is no apparent evidence
that directly implicates any one person or organization. EPA
continues to pursue reports or inferences regarding the origin of
the material, and will continue to search for whatever evidence
might become available during the excavation of properties within
the Montclair/West Orange and Glen Ridge sites.
Relations Hiatorv
Public Meeting held in November 1985
EPA issued a draft RI/FS report in September 1985. EPA then
announced a 60-day public review period and held a public meeting
on November 13, 1985. At that meeting, it was noted that
excavation of the radium-contaminated soil was the Agency's v
preferred approach for solving the problems at the sites, but the
lack of a disposal facility prevented the selection of.a remedy
involving excavation with off-site disposal. The meeting was
^fey well attended, with approximately half of the 1500 persons
^Ksent unable to be accommodated in the meeting place. Even
though EPA was not endorsing an on-site disposal option, the com-
munities were adamantly opposed to any consideration of excava-
tion, relocation and consolidation of the radium-contaminated
soil onto the original core areas of disposal in the Towns of
Montclair. and Glen Ridge.
EPA prepared a Responsiveness Summary following the 1985 public
meeting and public comment period. This document compiled the
written and verbal comments directed to EPA, both at the public
meeting and during the comment period, and presented EPA's
response to the substantive comments and suggestions received.
EPA has since issued several fact sheets and updates informing
affected residents and concerned parties about project develop-
ments, and-has held numerous availability sessions to provide
additional forums to encourage public participation in the
remedial planning process.
Proposed Plan Presented in April 1989
EPA continued to investigate the sites, evaluating both long-term
solutions, including excavation and disposal of the contaminated
soil, and interim measures to solve the problems associated with
presence of the radium-contaminated soil. The results of
is& investigations are presented in a Supplemental Feasibility
:udy report which was made available to the public on April 4,
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1989. Concurrent with the study, EPA released for public comment
a proposed plan describing its preferred approach for addressing
the radium contamination at the sites. The original 60 -day
comment period was scheduled to end on June 2, 1989, but was ex-
tended one week to June 9, at the request of the Mayor of Glen
Ridge and others, to allow for additional review and comments.
Public notices announcing this public comment period, as well as
the extension, were published in several local, widely-distri-
buted newspapers including the Newark Star Ledger, the Montclair
Times, and the Glen Ridge Paper. Samples of the newspaper
notices are included in Appendix D of the responsiveness summary
which is attached to this document. In addition, EPA held public
availability sessions at its office trailers in Montclair for
four days following both April 3, 1989 briefings of the town
councils of the affected communities, and a public meeting
conducted on May 18, 1989. Meeting summaries of the town council
presentations are provided in Appendix B of the responsiveness
summary which includes the oral and written comments received
during this most recent comment period.
of site Characteristics
Soil on public and private properties within the sites is con-
taminated with radionuclides which are primarily those in the
uranium decay chain. These nuclides include isotopes of radium,
thorium, uranium, lead and others. As noted earlier, radioactive
waste materials, suspected to have originated from radium pro-
cessing or utilization facilities, were disposed of in then-rural
areas of the communities. Hence, the main radionuclide of con-
cern is radium226. The radioactive decay of these nuclides in the
soil is causing elevated indoor concentrations of radon gas and
radon decay products in some houses, while others additionally
exhibit elevated levels of indoor and/or outdoor gamma radiation.
A number of properties have only elevated levels of gamma
radiation. Radon gas and gamma radiation pose different types of
radiation threats and, therefore, require different control
techniques.
The concentration of radium226 measured in the soil ranges from
"background!* levels [see Table 1; i.e., approximately 1 picoCurie
per gram (pCi/g) ] up to 4,545 pCi/g. The range of thorium230
concentrations measured is approximately the same as that found
for radium.. The concentration of uranium and uranium238 is gen-
erally about ten times lower than that measured for the
thorium230 and radium radionuclides. The highest uranium
concentration was measured at 310 pCi/g.
Because radium, which radioactively decays into radon gas, is
found naturally in most soils, radon and radon decay product
levels have been measured at approximately 700 of the site
properties, with values ranging from 0.001 to 1.55 Working Levels
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[ (WL) ; see Table 1] . The background level within the study areas
is approximately 0.002 WL. Additionally, both indoor and outdoor
gamma radiation levels [reported in units of microRoentgens per
hour (jiR/hr) ; see Table 1] have been measured at many of the
study area properties. More detailed indoor and/or outdoor gamma
radiation surveys have. been completed at a limited number of pro-
perties.. Background gamma radiation is estimated to be approxi-
mately 8.3 /iR/hr within the study areas [see Table 1]. Indoor
gamma radiation levels measured at site properties range from 6
to 357 jiR/hr. Outdoor gamma radiation levels were detected in .
the range of 6 to more than 1,000 /iR/hr.
The major areas of soil contamination, or "core areas" are shown
in Figures 2, 3 and 4. These core areas were determined from
evaluation of the surface soil samples, boring data, and surface
gamma readings. The distribution of contaminated materials with-
in these core areas is typically found throughout entire proper-
ties to depths in excess of ten feet, even though some of these
properties show only spotty measurable contamination at the
surface. Additional surface soil and boring measurements
indicate that some of the radium-contaminated material may have
been moved from the original disposal locations and used as f ill\
in low-lying areas. Further relocation of material might also -•.
have occurred during the subsequent residential development of
the study areas. In summary, the lateral and vertical extent of
the contaminated material is irregular and not easily
predictable.
pf Site
Elevated concentrations of radium226, thorium230, uranium234 and
lead210 are present in soils at the Hontclair/West Orange and Glen
Ridge sites. In addition, elevated indoor levels of radon and
radon decay products have been measured in houses at these sites.
The residents within the study areas are or have been exposed to
unacceptable risks from gamma radiation, and the radon and radon
decay products generated from the radioactive decay of the
contaminated material at the sites.
The Federal. Centers for Disease Control (CDC) and the Agency for
Toxic Substances and Disease Registry (ATSDR) have evaluated
exposure pathways through which radiation poses a threat at the
sites. These pathways include inhalation of radon and radon
decay products, irradiation by gamma radiation, ingestion and/or
inhalation of radium-contaminated soil, and ingestion of con-
taminated vegetables grown in the soil. As the radium in the
'soil undergoes radioactive decay, it forms radon gas. Since it
is a gas , radon can easily move through soil to the ground-
surface or into houses. Typical radon entry routes are shown in
^Figure 5. Within a matter of days, the radon gas itself decays
into a series of radioactive particulates referred to as "radon
progeny", "radon daughters", or "radon decay products". While
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radon gas is quickly dissipated in the outdoor air, as it decays
inside a house, the concentration of radon decay products in the
indoor air increases. The above-background lifetime risks from
this exposure pathway range from 0 to 361 excess deaths per 1000
persons exposed.
While long-term exposure to indoor radon gas and radon decay
products presents the greatest single health risk at the sites,
other pathways of exposure are not insignificant. The radioac-
tive decay of radium also results in the emission of highly pene-
trating gamma radiation. Gamma radiation is of concern because
it may expose anyone standing near a contaminated area to an
irradiation over the whole body. The greater the duration or
intensity of the exposure, the larger the dose and, therefore,
the greater the risk of adverse health effects such as cancer,
birth defects, and genetic defects. The above-background life-
time risks from this exposure pathway range from 0.5 to 12 excess
deaths per 1000 persons exposed.
Additionally, because airborne particulate matter (e.g., wind-
blown dust or soil) may contain small concentrations of radium, .
inhalation of radium is a possibility at the sites. Inadvertent^
ingestion of radium-contaminated soil, and ingestion of radium-
contaminated vegetables, are other pathways that can result in
doses to various internal bodily organs. This, in turn, can re-
sult in an increased risk of developing leukemia, anemia, and
bone cancer. However, studies have shown that the projected ra-
diation doses from these pathways are much smaller than those es-
timated for either radon decay product inhalation, or direct
gamma radiation exposure using even the most conservative assump-
tions.1 The above-background lifetime risks from these three
exposure pathways range, respectively, from 0.01 to 0.5, 0.1 to
2.2, and 0.2 to 5 excess deaths per 1000 persons exposed.
Exposure level scenarios at the Montclair/West Orange and Glen
Ridge sites are based on the assumptions that: 1) residents spend
75 percent of their time indoors and 25 percent outdoors;
2) young children through the age of five ingest one gram of soil
per day, while an adult would ingest 0.1 grams per day; 3) 15
kilograms of vegetables grown in contaminated soil are consumed
by an adult resident each year; 4) 60 micrograms per cubic meter
of contaminated dust are inhaled by an adult on a daily basis;
and 5) average exposure is determined using a 70-year lifetime.
Groundwater exposure was not considered in the risk assessment.
Public drinking water supply wells have shown no evidence of
1 U.S. Environmental Protection Agency, Feasibility Study.
Denver Radium Site, Operable Unit II, Prepared by CH2M Hill,
Inc., August 1987.
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contamination to date and, therefore, no risk was calculated from
this potential exposure pathway.
The remedial objective is to reduce, to the lowest levels
practical, the existing public health threats posed by indoor
radon and radon decay product concentrations, indoor and outdoor
gamma radiation levels, and inhalation and/or ingestion of
radium-contaminated materials.
Scope *ind Role of the Selected Remedy
Excavation of the radium-contaminated material is the Agency's
preferred solution to the problem. However, because of the
uncertainties involved in maintaining the availability of a
disposal facility; as well as a desire to minimize the disruption
of the communities during remedial action, EPA intends to
initiate remedial action at the Montclair/West Orange and Glen
Ridge Radium sites in a phased manner. EPA believes such an
approach to be appropriate in light of the difficulty in assuring
transport and disposal capacity for large amounts of contaminated
materials, over a long period of time.
The selected remedy will address the most highly contaminated
residential properties by fully excavating the radium-contami-
nated soil and transporting it to an off-site disposal facility.
In addition, EPA intends to undertake limited or "hot spot" exca-
vation of near-surface contamination at a number of residential
properties where such action would provide a final remedy for
those properties. Interim actions will be taken at some of the
remaining properties with soil contamination above the cleanup
standards. The indoor engineering controls include the
installation of state-of-the-art radon mitigation systems and/or
shielding for gamma radiation protection where appropriate.
EPA had also proposed to partially excavate contaminated soil
from many of these remaining properties and establish institu-
tional controls to reduce exposure of residents to contaminated
materials. EPA also proposed to establish institutional controls
for public properties within the study areas as a means of
preventing workers conducting typical subsurface utility
maintenance? and repair work from being exposed to contaminated
soil remaining beneath public areas and streets. As a result of
public comments and concerns, EPA is deferring a decision on
partial excavation and institutional controls and is providing a
60-day comment period to receive additional input from area
residents and local officials on the two issues of partial
excavation and institutional controls.
This approach allows EPA to begin excavating the radium-contami-
nated materials which have affected the residential communities
hile mitigating the health impacts associated with indoor expo-
sure to radon gas, radon decay products, and gamma radiation in a
8
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timely manner. In addition, the remedy allows for further devel-
opment of promising treatment technologies which ultimately may
offer a more implementable and cost-effective remedy for any
future actions at those properties with contamination remaining
on them. EPA will evaluate any new technologies which are devel-
oped and assess the continued availability of off-site disposal
capacity, to determine the most appropriate method for addressing
these properties. Any future actions at these properties will be
the subject of subsequent Records of Decision.
Groundvater Investigation
EPA is initiating a separate study of the groundwater at the
sites. The intent of the study is to determine the extent of any
contamination resulting from the presence of the contaminated
soil and to evaluate mitigation alternatives, should contamina-
tion be encountered. Any remedial action related to groundwater
contamination will also be addressed by a subsequent Record of
Decision.
Documentation of Changes from the Proposed Plan
Public comment was mixed with respect to the proposed alternative
that was presented on April 4, 1989. Several components of the
alternative were fully supported by the public, however, other
portions met with considerable opposition. In order to implement
the major portion of the remedy supported by the public, EPA is
modifying its preferred approach in selecting a remedy. All of
the essential components of Alternative 7, The Combined Approach,
are still incorporated in the selected remedy. However, it has
been modified to defer decision on outdoor gamma radiation
shielding and partial excavation of radium-contaminated soil,
where such excavation does not result in final remediation. In
addition, a few properties located between extensively
contaminated properties will be fully remediated.
The proposed plan called for partial excavation of some private
properties to remove radium-contaminated surface soil to a depth
of a few feet. Replacement of the excavated material with clean
soil would then have provided sufficient shielding to attenuate,
to levels at or below background, any gamma radiation emanating
from contaminated material remaining at depth. The implementa-
tion of this excavation scheme would have complied with public
health criteria, both indoors and outdoors, at all properties.
However, it would leave contaminated material beneath the public
areas and streets. In addition, institutional controls (that is,
restrictions on later excavation of the properties) would have
been an integral part of this remedy to ensure the effectiveness
ofx the indoor and, particularly, the outdoor engineering
controls.
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term "institutional controls" is used throughout this docu-
Lt to denote those societal control measures that a community
!uld employ to prevent disruption of radiation protection reme-
dies or exposure to contaminated soil remaining near or even
well-below the ground surface. Such controls could include muni-
cipal or county health ordinances. For example, any activity
undertaken by a property owner which could disrupt either, the
protective measures or contaminated soil might be subject to an
approval process . The approval process might be developed within
the individual municipalities. The process may include requiring
permits for certain home repairs or additions, or for outdoor
activities which might disturb the contaminated soil. The pro-
cess could also include requiring that sellers of property with
engineering controls or contaminated soil obtain a certificate of
compliance indicating that the property attains the established
health guidelines prior to transfer of the property in question.
Institutional controls are needed if radioactive materials remain
at the sites because the materials will continue to emit radia-
tion for years. The properties would be monitored periodically
to ensure that the remedial measures remain protective.
The selected remedy now does not include any of the partial exca^-
vations where removal of a few feet of contaminated soil would
not accomplish a final remedy for that property. A few feet of
soil might still be excavated at some properties, but only if the
^toavation would fully clean up that property. The selection of
i^Pedial measures to address outdoor soil contamination on the
remaining properties, both private and public, is being deferred
until additional discussion with affected property owners and
town officials has been completed. Following the receipt and
consideration of all additional comments, EPA will prepare subse-
quent Records of Decision selecting the appropriate actions for
the remaining properties.
DESCRIPTION OF ALTERNATIVES
Of Remedial Alternatives
fhe recent supplemental feasibility study report issued on April
4, 1989 entitled "Supplemental Feasibility Study for the Mont-
clair/ West Orange and Glen Ridge Radium Sites" describes a large
number of remedial options and technologies. After screening of
these optionsv seven remedial alternatives were identified for
detailed evaluation in the supplemental feasibility study report.
Table 2 provides an itemized list of the costs associated with
various components of the candidate remedial alternatives. Table
3 lists the criteria upon which the following alternatives were
evaluated. Note that the costs for the alternatives described
below are expressed in terms of present worth.
10
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Alternative 1: No Action
COST: Not Applicable (N/A) TIME TO IMPLEMENT: N/A
Under this alternative, the existing temporary radon ventilation
systems and gamma radiation shielding would remain in place, but
there would be no provision for operation and maintenance. With
a projected life of only several years, it is assumed that the
temporary radon ventilation systems would soon fail and that
indoor concentrations of radon and radon decay products would
return to pre-ventilation conditions. Unlike state-of-the-art
radon mitigation systems, the temporary ventilation systems cur-
rently installed at the Montclair/West Orange and Glen Ridge
Radium sites rely heavily on mechanical devices to control radon
and radon decay product concentrations. These temporary systems
have remained effective thus far primarily because an active mon-
itoring and maintenance program is being implemented by EPA and
NJDEP. The gamma radiation shielding would be expected to remain
effective for many years; however, in time, it too would lose a
measure of its effectiveness unless properly maintained.
Alternative 2: Continue Existing Action
COST: $5.0 million TIME TO IMPLEMENT: N/A
The second alternative is an interim alternative in which condi-
tions at the sites would remain as they exist. No further reme-
dial action would take place, but operation and maintenance of
the existing temporary radon ventilation systems and gamma radia-
tion shielding would be provided for a period of ten years. The
quarterly monitoring program that has been on-going to measure
radon and/or radon decay product concentrations in houses would
continue. Institutional controls would not be established. All
of the estimated 323,000 cubic yards of contaminated material
would remain on site.
Alternative 3: Engineering Controls
COST: $20.0 million TIME TO IMPLEMENT: 3 years
This interim alternative involves the implementation of one or
more of the following engineering controls, as determined
necessary,- at. study area properties:
o installation of state-of-the-art systems to reduce
indoor concentrations of radon and radon decay products
(these systems would be similar to those used in
Montclair and Glen Ridge and in areas of naturally
occurring radon); ,
o Installation of additional indoor gamma radiation
shielding;
11
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o Installation of outdoor gamma radiation shielding
and/or covering of radium-contaminated soil;
o Relocation or redistribution of "hot-spots" of radium-
contaminated soil on properties.
Institutional controls (e.g., municipal or health ordinances)
would also be necessary to ensure the effectiveness of the engi-
neering controls.
Alternative 4: The Park(a) Alternative
COST: $74.0 to 78.5 million TIME TO IMPLEMENT: 4 years
The intent of this alternative is to return radium-contaminated
soil that had been relocated from the original disposal or core
areas back to the core areas. The contaminated soil would be
capped with clean material to protect public health and the
environment and to provide useful park areas. One park would be
established in Glen Ridge and another in Montclair, covering
approximately 6 and 11 acres, respectively. \
This alternative would require the acquisition of approximately
75 properties located within the proposed park boundaries.
Houses located on those properties, which are already the most
contaminated properties at the sites, would be demolished. Radi-
um-contaminated soil would be excavated from properties located
outside of the park boundaries and placed on the contaminated
soil within the parks. The radium-contaminated soil would be
securely covered to control the release of radon gas, to shield
against gamma radiation, and to prevent the material from being a
source of groundwater contamination. After covering, the areas
would slope to elevations several feet above the existing ground
surface, depending on the type cap chosen, and would be land-
scaped into recreational parks which would be open for public
use.
Alternative 5: Total Excavation, With Off-Site Disposal
COST: $ 252.7 to 348.7 million TIME TO IMPLEMENT: 7 years
Under this.alternative, all on-site soil contaminated with radium
exceeding the cleanup standards (see Table 3) would be excavated
from private properties and public areas, including soil now
located under the streets, and replaced with clean fill. The
-volume of radium-contaminated soil present at the sites is cur-
rently estimated to total 323,000 cubic yards. The excavated
sail would be transported for final disposal at a licensed, off-
site facility.
12
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Alternative 6: Partial Excavation, With Off-Site Disposal
COST: $67.7 to 184.4 million TIME TO IMPLEMENT: 5 years
This alternative would involve the excavation of radium-contami-
nated soil to a depth of a few feet. Two separate depths of
excavation, two (2) feet and five (5) feet, were used to develop
cost estimates. Smaller volumes of soil (approximately 64,000
and 143,000 cubic yards, respectively), compared to Alternative
5, would be removed. As with Alternative 5, the excavated soil
.would be transported off-site for final disposal at a licensed
facility. Since this alternative results in radium-contaminated
soil remaining on private properties and public areas, engineer-
ing and institutional controls would be necessary to ensure the
protection of human health.
Alternative 7: The combined Approach
COST: $53.0 to 66.0 million TIME TO IMPLEMENT: 3 years
This alternative is essentially a combination of Alternatives 1,
2, 3, 5, and 6. Under Alternative 7, the actions to be imple- \
mented on a particular property would depend on the nature and
extent of contamination on that property. These actions would
include total excavation of the most extensively contaminated
properties and limited and/or partial excavation at others;
indoor and/or outdoor engineering controls at less contaminated
properties to reduce exposure to radon, radon decay products,
gamma radiation, and radium-contaminated soil; and institutional
controls to ensure the effectiveness of the engineering controls.
All actions would be designed to ensure protection of public
health. Alternative 7 was developed to offer a comprehensive and
fully implementable remedy to address public health risks at the
sites.
of Comparative
t
Evaluation Criteria
The seven alternatives noted above were evaluated using criteria
derived from the National Contingency Plan (published in the Code
of Federal Regulations at 40 CFR Part 300) and the Superfund
Amendments;.and Reauthorization Act of 1986 (SARA). These criter-
ia relate directly to factors mandated by SARA in Section 121,
including Section 121 (b)(1)(A-G). The criteria are as follows:
o Protection of human health and the environment
/,o Compliance with legally applicable or relevant and
/ appropriate requirements (ARARs)
13
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o Reduction of the toxicity, mobility, or volume of
hazardous substances
o Short-term effectiveness
o Long-term effectiveness and permanence
o Implementability
o Cost
o Community acceptance
o State acceptance
Comparisons
Table 4 summarizes the relative performance of the seven candi-
date alternatives in relation to the evaluation criteria. A com-
parative discussion of the major components of the alternatives,
using the evaluation criteria, follows:
Protection of Human Health and the Environment
Protection of human health and the environment is the central
mandate of the Comprehensive Environmental Response, Compensa-
tion, and Liability Act of 1980 (CERCLA), as amended by SARA.
Protection is achieved by reducing health and environmental
threats and by taking appropriate action to ensure that, in the
future, there would be no unacceptable risks to human health and
the environment through any exposure pathway.
Alternatives 4 and 5 would be fully protective of human health
and the environment.
To the extent that institutional controls would be effective,
Alternatives 3, 6, and 7 would provide for protection of human
health. For Alternatives 6 and 7, in instances where all con-
taminated soil is removed, these alternatives would be fully
protective of human health and the environment, regardless of the
effectiveness of institutional controls.
Under Alternatives 1 and 2, radon and radon decay product levels
would be reduced only in the houses which currently have ventila-
tion systems. However, as the temporary ventilation systems fail
under Alternative 1, indoor concentrations of radon and radon
decay products would return to pre-ventilation conditions. With
the exception of the currently shielded houses, there also would
be" no reduction in gamma radiation exposure indoors. Outdoors,
there would be no reduction in exposure to gamma radiation or the
threat of direct contact with radium-contaminated soil.
14
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The selected remedy would be fully protective of human health and
the environment where all contaminated soil is excavated. At
other properties where indoor engineering controls are installed,
public health would be protected. However, where contaminated
soil remains on-site in its current state, the risk to public
health and the environment would remain.
Compliance with Applicable or Relevant and Appropriate
Reou i r ements ( ARARs 1
Section 121 (d) of CERCLA, as amended by SARA, requires that reme-
dies for Superfund sites comply with Federal and State laws that
are directly applicable and, therefore, legally enforceable.
Remedies must also comply with the requirements of laws and regu-
lations that are not applicable, but are relevant and appropri-
ate; in other words, requirements that pertain to situations suf-
ficiently similar to those encountered at a Superfund site such
that their use is well suited to the site. Combined, these are
referred to as "applicable or relevant and appropriate require-
ments" (ARARs) .
No requirements have been determined to be applicable to the re-\
mediation of the sites. However, as noted earlier (see Table 3),
the Federal regulations governing the cleanup of uranium mill
tailings, 40 CFR 192, have been determined to be relevant and ap-
propriate. Table 5 highlights the uranium mill tailings cleanup
standards and summarizes additional ARARs for the two sites.
The requirements of 40 CFR 192, Subpart B- "Standards for Cleanup
of Land and Buildings Contaminated with Residual Radioactive
Material from Inactive Uranium Processing Sites" are that as a
result of residual radioactive materials from any designated
processing site:
The concentration of radium226 in land averaged over any
area of 100 square meters (120 square yards) shall not
exceed the background level by more than-
(1) 5 picoCuries per gram [pCi/g] averaged over the first
15 centimeters (cm) [6 inches] of soil below the
surface, and
(2) 15 pCi/g, averaged over 15 cm [6 inch] thick layers of
soil more than 15 cm below the surface.
The health': ARARs include an annual average exposure of 4 pico-
Curies peir liter (pci/l) of air for radon (see Table 3). This
exposure, which is a guideline, corresponds approximately to an
annual average exposure of 0.02 WL for radon decay products. The
. 0.02 WL for radon decay products and the 20 AtR/hr above back-
ground for gamma radiation are also standards as defined in 40
192.
Table 6 identifies the degree to which the various alternatives
comply with each of the listed ARARs. Inspection of Table 6
15
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indicates that Alternative 5 complies with all the ARARs. Alter-
native 4 also complies with all ARARs with the exception of the
alternate cap design for the parks, where the alternate design
may fail the longevity requirement.
The selected remedy also complies fully with the soil cleanup and
public health ARARs, but only for those properties where no con-
taminated soil will remain following remediation. At properties
where indoor engineering controls are installed, compliance with
some public health ARARs will be achieved, however, no soil
.cleanup standards will be met. At the remaining properties,
neither health nor soil cleanup goals will be met.
Alternatives 6 and 7 comply with the public health ARARs, assum-
ing that institutional controls are effective. Alternatives 6
and 7 also comply with the soil cleanup standards, however, only
for a limited number of properties.
Alternative 2 complies with some health ARARs, however, it does
not meet any soil cleanup standards. Alternative 1 fails to
comply with public health and soil cleanup ARARs.
Only Alternatives 4 and 5 fully comply with all the ARARs as
identified. Alternatives 2, 3, 6, 7, and the selected remedy are
all interim remedies and would require additional measures to
comply with all of the ARARs available for the sites.
Reduction of Toxicity. Mobility, or Volume
This evaluation criterion relates to the performance of a tech-
nology or remedial alternative in terms of eliminating or con-
trolling risks posed by the toxicity, mobility, or volume of
hazardous substances.
As radioactivity is an intrinsic property of the nuclides in the
contaminated soil, its toxicity cannot be altered by treatment.
Mobility and/or volume may be addressed by treatment, but as
toxicity is not altered, such treatment does not provide a suffi-
cient reduction in health risk or environmental threat. There-
fore, none of the remedial alternatives that were considered
satisfy this evaluation factor.
As previously noted, however, EPA is continuing to investigate
technologies that might at some time prove useful in significant-
ly reducing the volume of radium-contaminated soil necessary for
off-site transport and disposal.2 Preliminary results indicate
that it is possible to use simple physical separation techniques
/ 2 U.S. Environmental Protection Agency, Technological Ap-
proaches to the Cleanup of Radioloaically Contaminated
Superfund Sites. (EPA/540/2-88/002), August 1988.
16
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to remove a portion of uncontaminated material, such as rocks and
debris, from the contaminated soil. This physical separation
will be conducted to reduce the volume of soil requiring off-site
disposal. The uncontaminated material will remain on the site.
Another of these experiments involves the use of chemical extrac-
tion techniques. EPA, in conjunction with NJDEP, will continue
to evaluate the more promising methods to determine their poten-
tial usefulness for further remediation of the sites.
Short-Term Effectiveness
Short-term effectiveness measures how well an alternative is
expected to perform, the time to achieve performance, and the
potential adverse impacts of its implementation.
Alternatives 3, 4, 5, 6, 7, and the selected remedy provide
effective short-term protection. The alternatives become
effective as they are implemented at individual properties.
Generally, the more quickly an alternative can be implemented,
the greater the short-term effectiveness. Any adverse short-term
impacts during remediation (such as the creation of dust) could \
be controlled by implementing dust suppression measures.
The selected remedy can be implemented very quickly for the
indoor engineering controls. Also, the time estimated for
completion of the excavation component of the selected remedy is
shorter than that for the other excavation alternatives.
Alternatives 1 and 2 provide only very short-term effectiveness
for the properties with temporary remedial systems. Within
several years, as these systems fail under Alternative 1, and
immediately, where no system currently exists in Alternatives 1
and 2, there would be no effective remediation.
Loncr-Term Effectiveness and Permanence
Long-term effectiveness and permanence address the long-term
protection and reliability that an alternative affords. Table 7
lists the factors which are considered in the determination of
long-term effectiveness and permanence. The table also provides
a summary of; each factor and an overall assessment of the effec-
tiveness and permanence of each alternative.
Alternatives 4 and 5 are fully effective for the long-term, and
are considered final remedial actions. For Alternative 4, only
the standard design evaluated provides effective isolation for
the minimum 200 years stipulated in the relevant and appropriate
standards for these sites. Alternatives 3, 6, and 7 are not as
effective as long-term remedies, since they rely on the use of
'engineering and institutional controls at many properties.
Alternatives 6 and 7, however, do provide final and effective,
17
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long-term solutions at the large number of properties where the
ARARs are achieved.
Alternatives 1 and 2 provide essentially no long-term effective-
ness or permanence.
The selected remedy provides effective, long-term protection at
the properties where public health and soil cleanup ARARs are
achieved. Engineering controls, where implemented, would be only
temporarily effective.
Implementability
Implementability considerations address how easy or difficult,
feasible or infeasible, it would be to carry out a given alter-
native from design through construction and operation and main-
tenance .
The indoor remedial activities associated with Alternative 3 are
generally straightforward to implement. The outdoor actions
would involve some techniques that have not been attempted or
fully demonstrated and, therefore, some difficulties may arise.
Alternatives 4, 5, 6, 7, and the selected remedy all involve the
use of standard construction practices. That aspect of their
implementation is expected to be straightforward.
The selected remedy entails the installation of indoor engineer-
ing controls and the implementation of straightforward construc-
tion methods. Hence, the selected remedy should be easy to
implement.
As previously noted, however, the difficulty in guaranteeing
interstate transportation and the continued availability of a
disposal site for those alternatives requiring off-site disposal
would directly affect their Implementability.
In addition, alternatives 3, 6, and 7 involve the use of
institutional controls. State, County and Municipal authorities
would have to be involved in the process of developing and
implementing: the institutional controls. Any difficulty which
may be encountered in coordination among the involved
governmental:, agencies would affect the Implementability of these
alternatives.
cost
Costs are evaluated in terms of remedial action costs, operation
and maintenance costs, institutional control costs, and replace-
ment costs. Table 2 presents a range of present worth cost
"estimates associated with each of the seven alternatives, with
specific estimates for the above-mentioned factors.
18
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With no further action taken, there is no additional cost assoc-
iated with Alternative 1. Alternative 2 would consist entirely
of operation and maintenance, and administration costs, whose
present worth is estimated to be $5.0 million. Alternative 3 is
estimated to cost a total of $20.8 million.
Depending on the type of containment selected for the Parks Al-
ternative, the cost for Alternative 4 is estimated to range from
$74.0 to $78.5 million, with the standard design being more
expensive.
Alternative 5 is estimated to cost approximately $252.7 to $348.7
million. The range in estimates is attributed to marked differ-
ences for alternate transportation costs.
For Alternative 6, costs were estimated to be $67.7 to $86.6
million for a two-foot partial excavation option, and $142.1 to
$184.4 million for a five-foot partial excavation option. Again,
the range of the estimate is based on the substantial cost dif-
ferences for alternate modes of transport.
\
Alternative 7, which is a combination of the above alternatives>
is estimated to cost $53.0 to $66.0 million.
For the selected remedy, which represents a minor modification of
Alternative 7, the estimated cost is $53.0 million. Although
there is a cost reduction associated with the elimination of
partial excavation, there is an equivalent, if not greater, cost
increase associated with the inclusion of 3 additional core area
properties for full excavation.
State Acceptance
The State Acceptance factor addresses the concern and degree of
support that the State government has expressed regarding the
remedial alternative being proposed.
The State of New Jersey supports the remedial actions called for
by the selected remedy.
Community Acceptance
This evaluation factor addresses the degree to which members of
the local community support the remedial alternatives being
considered.
The community response to EPA's Proposed Plan was mixed. There
is a consensus of support for that portion of the proposal that
calls for full remediation of the most severely contaminated
'properties, especially the New Jersey pilot program properties
where the residents have been relocated. The community generally
19
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approves of the implementation of the indoor engineering controls
to reduce the risk from exposure to excessive indoor gamma radia-
tion levels and/or radon gas concentrations. The community
responded with considerable reservation, skepticism and, in many
cases, complete opposition to the proposal to implement interim,
or partial excavation remedies that were envisioned for many of
the properties, including the public areas and parks. The imple-
mentation of institutional controls is also not supported by the
towns or the public. Imposition of institutional controls is
perceived as an additional financial burden that may be unfair
and unenforceable.
The community has endured a long period of investigation and
study, and supports EPA's commitment to action. However, the
public prefers to support only those measures that are final
remedies for the sites, and does not support partial excavation
solutions.
Alternative 5 has received unanimous support, as it is a final
remedy which complies with all ARARs. Even though short-term
disruption to the community would be high, and with the uncertain
availability of off-site disposal capacity, the public is fully \
supportive of this alternative.
Alternatives 1 and 2 have received little or no community sup-
port.
The community does support the implementation of indoor engineer-
ing controls, but, only as a short-term remedy until all the
contaminated soil is finally removed from the sites.
Alternative 4 has no support in the Town of Montclair, and very
little in Glen Ridge. The disruption to the community is per-
ceived to be both socially and financially unacceptable.
Alternatives 6 and 7 are partially accepted by the public as
these provide for complete remediation of a number of properties.
Where the remedies are only partial, the community has expressed
substantial reservations.
The selected remedy incorporates those components of Alternative
7 that received the most favorable response from the community.
More than twenty of the most extensively contaminated properties
are slated^for full excavation, in addition to the four New
Jersey pilot program properties. Limited excavation will also
fully remediate a number of additional properties, and indoor
.engineering controls will be installed at all properties where
radon and radon decay product concentrations and indoor gamma
radiation levels exceed the health criteria. The community has
stiown support for all parts of this remedy.
20
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SELECTED REMEDY
The following describes in detail the remedial action plan which
the U.S. Environmental Protection Agency is selecting to imple-
ment at the sites. This selection is a modified version of
Alternative 7 as presented in the Proposed Plan.
Description
The properties within the three study areas are grouped into the
categories described below: .
Category "I" Properties ~ Core area properties which have exten-
sive radium contamination throughout the property, including
under, and around the house foundation, have elevated levels of
gamma radiation, and have concentrations of radon or radon decay
products in excess of health guidelines;
Category "II" Properties — Properties with basement wall or out-
door gamma radiation levels equal to or greater than 50 micro-
Roentgens per hour and with extensive radium contamination;
Category "III" Properties — Properties with radon, radon decay
product, or gamma radiation levels above health guidelines and
with limited, or "hot spot" radium contamination;
Category "IV" Properties — Properties with soil contamination
above cleanup standards, but with no radon, radon decay product,
or gamma radiation levels above health guidelines;
Category "V" Properties — Properties which have no detectable
radium-contaminated soil present in excess of the soil cleanup
standards;
NJDEP Pilot Program Properties — Four properties partially
excavated under the NJDEP pilot excavation program; and
Public Areas and Streets — Areas not privately owned which have
some degree of radium-contaminated soil present.
Based on currently available information, Table 8 presents an
estimate of the number of properties in each category.
Category "I" Properties: Full Excavation
By definition, category "I" properties have the most extensive
radium contamination, exhibit the greatest human health threats,
and would be the most difficult to remedy with engineering and
institutional controls alone.
21
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Soil from approximately 23 category "I" properties will be exca-
vated to achieve the requirements of 40 CFR 192, Subpart B. This
includes the four partially excavated NJDEP pilot program proper-
ties. Based on sampling efforts, the NJDEP pilot program, and
historical records, it is estimated that 41,000 cubic yards of
contaminated soil will be excavated from the category "I" proper-
ties. This volume estimate may change, however, based on addi-
tional information obtained during remedial design activities.
The excavated soil will be disposed of at a licensed, off-site
facility and replaced with clean soil.
As mentioned earlier, preliminary results from EPA treatment
technology studies indicate that it may be possible to physically
remove a portion pf uncontaminated material from the contaminated
soil using simple separation techniques. To reduce the volume of
soil requiring off-site disposal, these physical separation tech-
niques, such as the removal of uncontaminated rocks and debris,
will be used to the maximum extent practical at the Montclair/
West Orange and Glen Ridge sites. This uncontaminated material
can then be used as fill for excavated properties.
During excavation, residents of the category "I" properties
have to temporarily relocate at government expense. However,
excavation will occur in a pattern designed to prevent any. long-
term disruption to individual residents or the community. For
example, a limited number of properties could be excavated at a
time, with the excavated soil being immediately transported for
off -site disposal, thereby eliminating the need for any on-site
storage. Clean soil, including uncontaminated material segrega-
ted using physical separation techniques, will replace the
excavated soil and be landscaped according to the needs of the
individual properties.
Should circumstances arise to prevent the continuation of off-
site disposal, excavation activities will cease and any material
not yet disposed of would be returned to the site. At that
point , the properties and houses would receive engineering con-
trols designed to protect human health to the maximum extent
practicable. If it were found that such controls could not ef-
fectively protect human health, the Federal government would
offer to purchase the affected properties and provide the resi-
dents the option of permanent relocation.
Remediation: of category "I" properties reflects Alternative 5
identified in the supplemental feasibility study report.
Category "II" Properties: Indoor Engineering Controls, Limited
Excavation (Where Appropriate)
Remediation at some of the approximately 75 category "II" pro-
perties will consist of indoor engineering controls to reduce
exposures to radon gas and decay products, and gamma radiation.
22
-------
These activities will occur simultaneously with the remediation
of the category "I" properties. EPA had proposed to excavate a
limited amount of surface soil from these properties and
establish institutional controls to protect residents from
exposure to contaminated soil remaining at depth. However, based
on public comment, EPA is deferring a decision on any partial
excavation activities pending further input from area residents
and town officials. Therefore, radium-contaminated soil will
remain on a number of category "II" properties with outdoor gamma
radiation levels exceeding the health guidelines.
Where necessary, state-of-the-art radon control systems will be
installed in houses. These systems, which will be designed on a
house-to-house basis, are intended to capture radon gas before it
enters a house. Similar systems have been successfully installed
and used in houses in the Montclair and Glen Ridge study areas,
as well as in other parts of the country affected by naturally
occurring radon. A typical system diverts radon gas from beneath
a basement slab, conveys the gas through PVC (polyvinyl chloride)
plastic piping, and ventilates the radon to the outdoor air.
Radon gas can be safely dissipated in outdoor air, and will not
pose a health threat since outdoor accumulations would not occurc
A number of houses may require indoor gamma radiation shielding.
Lead or steel sheeting will be placed on basement floors and/or
walls. Concrete could be used in other areas, such as crawl-
spaces. Where shielding is installed in a basement, it will be
covered by either carpeting or wallboard.
In some cases, it may be possible to excavate a limited amount of
soil from category "II" properties, and thereby fully remove all
of the radium-contaminated soil present. This limited excavation
is intended to remove all radium-contaminated soil from a proper-
ty and will only be undertaken if the soil cleanup standards can
be achieved. It is estimated that radium-contaminated soil will
be excavated to a depth of a few feet, and that the volume exca-
vated from all of the limited excavation properties will total
about 4,000 cubic yards. This volume estimate could change, how-
ever, based on additional information obtained during remedial
design activities.
As previously noted, radium-contaminated material may also have
been mixed: with Portland cement and used to make sidewalks or
foundations. Where necessary, these materials will be removed
and appropriately replaced. Excavated material will be disposed
of at a licensed, off-site facility. As with the category "I"
.properties, physical separation techniques will be used to the
maximum extent practical.
In a few instances, engineering and/or construction considera-
tions may warrant the full excavation of a limited number of
category "II" properties. For example, where category "I" pro-
23
-------
perties flank a category "II" property, it may be prudent to ful-
ly excavate the category "II" property. At this time, a few pro-
perties in the Montclair study area are located between category
"I" properties. These category "II" property residents may then
have to temporarily relocate at government expense during the
remedial activity. However, as with the category "I" properties,
excavation will be designed to minimize disruption to the resi-
dents and the community. Remediation of those properties where
all radium-contaminated soil is removed reflects Alternative 5.
It is estimated that approximately 3,500 cubic yards of soil will
be excavated from these three properties. This volume estimate
may change, however, based on additional information obtained
during remedial design activities.
EPA had proposed to establish institutional controls at proper-
ties where radium-contaminated soil would remain to ensure the
effectiveness of the indoor engineering controls, as well as to
prevent exposure to any contaminated soil lying at or below the
ground surface. However, as previously discussed, a decision on
institutional controls is being deferred pending further comment
from area residents and town officials.
\
Category "III" Properties: Indoor Engineering Controls, Limited,
or "Hot Spot" Excavation (Where Appropriate)
The approximately 65 category "III" properties generally have
more limited, or "hot spot", contamination present. For these
properties, indoor engineering controls, as described for the
category "II" properties, might be employed. As with the cate-
gory "II" properties, in some cases, it may be possible to remove
hot spots from a category "III" property such that the concentra-
tion of radium attains the 40 CFR 192 soil cleanup standards.
Again, no excavation will be undertaken unless the small volume
of soil removed will provide a final remedy to those properties.
For those properties where all radium-contaminated soil is
removed, the remediation reflects Alternative 5.
It is not anticipated that any category "III" property residents
will have to consider temporary relocation. As with a number of
the category "II" properties, there will be radium-contaminated
soil remaining at some category "III" properties with outdoor
gamma radiation levels exceeding health guidelines. Remedial ac-
tions at these properties, and similar category "II" properties,
will be addressed in subsequent Records of Decision, pending
additional public comment.
.Category "IV" Properties: Additional Monitoring
Category "IV" properties may have radium-contaminated soil pre-
sent above soil cleanup standards, but exhibit no radon gas or
radon decay product concentrations in excess of the health guide-
lines. Gamma radiation levels, while elevated above background,
24
-------
are also within the health guidelines. This could be a result of
low concentrations of radium in the soil near the ground surface,
or higher concentrations at depths where the overlying soil acts
to shield the gamma radiation. Further work must be done during
remedial design activities to determine the cause of the elevated
gamma radiation levels.
Based on the results of the design testing, it is envisioned that
most of the category "IV" properties will be reclassified. If
radium contamination in excess of soil cleanup standards is not
found, a property will be reclassified as category "V". Remed-
iation of these category "IV" properties reflects Alternative 1.
If it is determined that significant radium contamination is pre-
sent below the surface, a decision involving appropriate remedial
measures for those properties will be made in subsequent Records
of Decision.
Category "V" Properties: No Further Action Required
Those properties within the study areas which are confirmed
during remedial design activities to have no radium-contaminated
soil present above the 40 CFR 192 soil cleanup standards will be\
classified as -category "V". These properties will need no
further study or remedial action. This reflects Alternative 1.
However, should contamination in excess of soil cleanup standards
be found during any design or construction activities, a property
will be reclassified as appropriate.
NJDEF Pilot Program Properties
Five properties from the NJDEP pilot excavation program remain
partially excavated in Montclair. The residents of four of these
properties are temporarily relocated at the present time. These
four properties will receive the remediation described for
category "I" properties. In addition, remediation will be
completed at the fifth property. An estimated 7,000 cubic yards
of contaminated soil will be excavated from the pilot program
properties. (This volume is included in the estimate given for
category "I"). Remediation of these properties reflects
Alternative 5.
Additional,, Properties
Some properties within the study areas have received limited, or
no, testing to date. This can be due to a number of reasons,
including property access denials. It is assumed that some of
.these properties will be included in the categories requiring
remedial action, but that remediation will consist primarily of
engineering controls or limited soil removal. These additional
properties are not expected to significantly affect the scope of
the remedial action.
25
-------
Cost Estimate
The cost of the selected remedial action is estimated to be $53
million for the two National Priorities List sites combined.
This includes the costs of excavation, temporary resident reloca-
tion, and property restoration; transportation; disposal; moni-
toring; radon mitigation; and gamma radiation shielding. The
nature of any future remedial activities not specified in this
remedy has yet to be determined and, therefore, the associated
costs have not been estimated. The cost estimate for this modi-
fied remedy is very similar to that presented for Alternative 7.
Because the partial surficial excavation has been eliminated from
this particular remedial phase, there is a slight cost savings
compared with Alternative 7. However, additional costs are
incurred by including the category "II" properties located
between category "I" properties in the full excavation scheme.
The volume reduction associated with eliminating partial exca-
vation is offset by the increased soil volume resulting from
fully excavating the few additional category "II" properties.
Thus, the cost for this modified selection is equal to, if not
slightly higher than the original cost estimate provided for
Alternative 7.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on the Superfund Amendments
and Reauthorization Act of 1986 (SARA) and the regulations con-
tained in the National Contingency Plan. SARA requires that EPA
utilize permanent solutions and alternative treatment technolo-
gies to the maximum extent practicable.
For a majority of site properties, this remedy does fully protect
human health and the environment. It is estimated that no
radium-contaminated soil above the cleanup standards will remain
on almost two-thirds of the approximately 750 properties within
the boundaries of these two Superfund sites. Implementation of
this remedy will eliminate additional risks attributable to
exposures to indoor or outdoor gamma radiation, indoor radon gas
or radon decay products, inhalation and/or ingestion of
contaminated soil, and ingestion of contaminated vegetables grown
in contaminated soil.
As noted earlier, this remedy also provides for interim measures
at additional properties within the sites. For those properties,
this remedy will serve to reduce some of the risks attributable
,to the effects of the radioactive decay of the radium-contamin-
ated soil, and so is at least partially protective of public
26
-------
health. This remedy, in all cases, will comply with the ARARs
for exposure to indoor gamma radiation and the inhalation of
radon gas or radon decay products. Final, or additional remedial
measures, to be selected in subsequent Records of Decision, will
more fully provide for the protection of public health and the
environment at those properties with interim remedial measures
implemented under ^this Record of Decision.
There are few short-term risks associated with the implementation
of this remedy. Where excavation occurs, dust suppression
measures can reduce the risk of inhalation of radium-contaminated
dust. For those properties where this remedy provides only an
interim solution, some additional short-term risk does exist from
outdoor exposure to gamma radiation, ingestion and/or inhalation
of contaminated soil, and ingestion of vegetables grown in
contaminated soil. Public comment indicates that this short-term
risk is not unacceptable. In addition, no adverse cross-media
impacts are expected from the remedy.
of ARARs
As presented earlier, the primary ARARs for these two sites are .
contained in 40 CFR 192, Subpart B. This regulation deals with v
the cleanup of inactive uranium processing facilities. EPA has
determined that while these standards are not legally applicable,
they are relevant and appropriate to the situation at the Mont-
clair/West Orange and Glen Ridge sites. Table 5 lists and
summarizes these standards and other ARARs that may be pertinent
during the implementation of this remedial action.
When implemented, almost two-thirds of the properties within the
study areas will comply with public health and soil cleanup
ARARs. In addition, all properties where interim remedies are
instituted will comply with the indoor radon decay product and
gamma radiation ARARs. Those properties that do not comply with
outdoor gamma radiation and soil cleanup ARARs will be addressed
in subsequent Records of Decision.
Cost Effectiveness
The selected remedy is cost-effective because it provides overall
effectiveness^ relative to its cost. The remedy provides for com-
plete protection of public health and the environment at a great
number of the properties within the two sites. It has been
examined closely to ensure that it is the least costly means of
achieving the required level of protection. Additionally, the
cost efficiency of this selected remedy will be furthered by
value engineering conducted during remedial design.
27
-------
Utilization of Permanent Solutions and Alternate Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
EPA and the State of New Jersey have determined that the selected
remedy represents the maximum extent to which permanent, solutions
and currently available treatment technologies can be utilized in
a cost-effective manner for this phase of the source control re-
medial action at the Montclair/West Orange and Glen Ridge sites.
Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA and the State of New
Jersey have determined that the selected remedy provides the best
balance of trade-offs in terms of long-term effectiveness and
permanence, short-term effectiveness, implementability, and cost,
and considering the statutory preference for treatment as a
principal element and State and community acceptance.
While this remedy does not offer as high a degree of long-term
effectiveness as the complete excavation of all contaminated
soils, it will allow for exploration of additional disposal
capacity and development of treatment technologies. For the
majority of the properties, the selected remedy provides the same
long-term effectiveness as does Alternative 5. . Alternative 4,
which also offers a final solution, is, however, totally
unacceptable to the public and would be the most difficult to
implement.
None of the alternatives reduces the toxicity, mobility, or
volume of the contaminated material. Selection of this remedy,
however, will allow for further exploration and investigation of
treatment techniques to reduce the volume of material requiring
off-site disposal. Substantial cost savings would be realized by
reducing the volume of contaminated material requiring transport-
ation and disposal.
Experience has shown how difficult it can be to assure transpor-
tation and disposal for large amounts of contaminated material.
The selected remedy limits the amount of soil for off-site
disposal, while also minimizing the disruption to the residential
communities. Thus, it is somewhat more implementable and can be
accomplished more quickly than other equivalent remedies. In
addition, the cost of the selected remedy is less than that of
these other remedies. EPA and the State of New Jersey believe
that this remedy satisfies public concerns that remedial action
begin at the sites, actions that provide for final and complete
remediation of properties, while giving additional opportunity
for public comment. Therefore, the selected remedy is determined
.to be the most appropriate for initiating remedial action at the
Montclair/West Orange and Glen Ridge Radium sites.
28
-------
Preference for Treatment as a Principal Element
The principal threat at these sites is the generation of excess
concentrations of radon gas and radon decay products indoors,
which are subsequently inhaled by the residents of those houses.
In addition, there are threats from exposure to excess levels of
indoor and/or outdoor gamma radiation, ingestion and/or inhala-
tion of radium-contaminated soil, and ingestion of vegetables
grown in contaminated soil. Because there is no treatment
available that destroys the radioactive source of these threats,
the selected remedy does not satisfy the statutory preference for
treatment as the principal element. The remedy does reduce the
exposure to all excess indoor concentrations of radon and radon
decay products. It also provides for complete remediation at a
number of properties, thereby reducing the exposure risk from all
pathways.
The Responsiveness Summary which addresses written and verbal
comments follows the Figures and Tables.
29
-------
W >»«- °
J$i$g?,jjg
Glen Ridge
Study Area
Source: U.S.G.S. Orange. N.J. Quadrangle
Location of Three Study Areas
Montclair/W«st Orange and Glan Ridge Radium Sites
-------
> Core area boundary
as determined by
anal/sis of boring
bos.
Estimated boundary *
of redistrixitad core
malarial as determined
by analysis of indoor
and outdoor gamma
towb.
f Cora areas.
Study area perimeter
Discrete pockets of contamination as determined by borings.
0
scale
500
—<
feet (approximate)
COM
Figure 2
Glen RidgdQbdy Area
p'O/VMfJ
< consult
-------
Core area
boundary
as determined
by analysis of
boring toga.
Estimated
boundary of
redistributed
core material
as determined
by analysis
of indoor and
outdoor gamma
toveb.
Cor* areas.
Study area perimeter
Discrete pockets of contamination as determined by borings.
0
scale
500
rH
(eel (approximate)
COM
Figure 3
Montclair Study Area
Montclajr/West Oranqe and RMn RlHn« paHbim ci«««
-------
Cora area boundary
as determined by
analysis of boring logs.
•Estimated boundary of
redistributed core material as
determined by analysis ol indoor
and outdoor gamma levels.
Cor* areas.
Study area perimeter
Discrete pockets of contamination as determined by borings.
0
scalu
500
_=1
leal (approximate)
COM
Figure 4
West Orang^pbdy Area
-------
jr/-•
&/.«
6
'8'
2 Hollow block walls
3 Mortar joints
4 Porous concrete block
5 Holes for utility and service pipes, cables, etc.
6 Sin plate and header joist gaps
7 Slab • footing joints
8 Exposed soil
9 Drains, sumps and weeping(drain) tiles
10 Crawl spaces
Not to Scale
^#vl
.v»* J?"V
•Si -.
t>
•»•
• Y ••/»£?.'
#
; ; **3®
' •' ' ' ' •'''"'•' ""*' ' • ••^^^a'^^ttgsaQR^^ P^E ,2c'V^'
1 Floor and wan cracks '•'•'. • • ?fe^ ^^P^y^-' T ^|\:.-"'"^-^
2 Hollowbtockwails ' ' ''»f"£!SJ:^%&£ ' : J'--:;Ji (9 TUc^^^
3 Mortar joints • J'rv(-:>?"":v^':."•'. • Vatl. •UniiiMrfiS^;' .."•'•'•'
Adapted from *Radon Reduction Tcchniquas
for D«tach«d HOUSM; Technical Guidance.* USEPA
Figure 5
Typical Radon Entry Routes
Montdair/West Orange and Glen Ridge Radium Sites
-------
RADIATION UNITS
Type
Radon
Radon Progc
Units of Measure
pico Curie per liter
(pCi/l)
my Working Level (WL)
MWGSIte
Background
-------
Summary of the Cost of Each Alternative (million dollars)^
Costs Incurred During Remediation
Engineering/construction
-Construction/restoration
- Excavation/restoration
• Transportation
- Disposal
- Relocation
- Police/security/traflic
- Administration of alternative
Costs Incurred after Remediation
O&M and monitoring
Five year reviews
Administration of Institutional Controls
Potential for future remedial actions
Total
1
No Action
--
•
.
-
-
-
-
-
-
•
0
2
Continue
Existing
-
-
-
-
-
*
-
1-9
0.05
3.1
High
$5.0"
3
Engineering
Controls
11.3
-
-
-
• -
0.7
2.4
3.1
0.16
3.1
High
$20.8"
' 4
Park
Alternative
-
40.1a
0-7
12.6-17.3*
11.9
0.6
2.0
1.0
0.1
5.0
0
$74.0-78.5
5
Full
Excavation
Oflslte
Disposal
-
63.6"
83.3-179.3°
80.8
1.1
0.9
2.8
•
-
•
0
$252.7-348.7
6
Partial Excavation
Of I site Disposal
Two Foot Five Foot
Excavation Excavation
6.7 6.7
19.0V 51.6*
16.8-35.7° 36.9-79.2°
16.1 35.7
0.8 1.1
0.3 0.9
1.6 2.8
3.1 3.1
0.16 0.16
3.1 3.1
High Medium
$67.7-86.6" $142.1-184.4
7
Combination
Alternative
4.7
16.6"
11.7-24.7°
11.1
0.3
0.3
1.9
3.1
0.16
3.1
Medium
$53.0-66.0"
8 Excavation costs vary according to the degree of contamination ($120/yd3 or $300/yd3). The higher costs would apply to houses with the most contamination; i.e., the
163 properties above health guidelines.
b Lower cost is for "alternate" cap, higher cost is for 10.5 foot 'standard* cap.
° Lower cost is for rail transport; higher cost is for trucking
* Costs presented are present worth based on a 10 percent interest rate over a 10 yr. period.
"Should anticipate spending from $74 to $250 million to implement final remedy.
-------
TABLE 3
SUMMARY 07 EPA CRITERIA3'4'5
HEALTH GUIDELINES
Tooic
Radon
Units of Measure
picoCuries/liter
(pCi/1)
Value
4 pCi/13
Radon Decay
Products
Working Levels (WL)
0.02 WL*
Gamma Radiation
Rate
microRoentgens/hour 20 MR/hr above
(/iR/hr) Background4
SOIL CLEANUP STANDARDS
Radium
Concentration
in Soil
picoCuries/gram
(pCi/g)
5 pCi/g in first
15 centimeters
(6 inches)4'5
15 pCi/g in sub-
surface soil5
4.0 pCi/1 is a guideline; a standard for radon has not
been established. (At 50 percent equilibrium, an annual
average exposure of 0.02 WL of radon decay products cor-
responds to an annual average exposure to a concentration
of 4.0 picoCuries of radon per liter of air.)
4 40 CFR 192, "Standards for Cleanup of Land and Buildings
Contaminated with Residual Radioactive Materials From In-
active Uranium Processing Sites"
5 Averaged over 100 square meters (120 square yards)
-------
• Overall Evaluation of the Alternatives -
Alternative
1 2
3 4 5 6 7
Compliance with ARARa
Reduction In toxictty,
mobility, or volume
Above-background risk
remaining after remediation
(no. of excess deaths per
1,000 people exposed)
Potential short-term risks
Time to Implement (years)
Long-term effectlveneae and
permanence
Implementablllty
Coat In mllHona
Overall evaluation for
protectlvenees
Does not
comply with
any ARARs
None
3-367
None
NA
Not
effective
NA
0
No
protection
provided
Doe* not
comply with
most ARAR*
N_
3-36
Some
NA
Not
effective
NA
5.0
Not
adequate
Does not
comply with
soil ARAR
N_-
2.6-18
Low
4.8
Temporarily
effective
Few
obstacles
20.8
Provide*
short-term
protection
Complies
with all
ARARs
None
0.9-1.6
Medium
4
Effective
and
final
Possibly
major
obstacle*
74.0-78.5
Protective
of public
health and
Complies
with all
ARARs
None
0.9-1.6
High
5.6
Effective
and
final
Possibly
major
obstacles
252.7-348.7
Protective
of public
health and
Does not
comply
with sol
ARAR
None
2.6-17
High
3.2 (2ft option)
5.4 (5ft option)
Temporarily
effective (2ft)
Maybe
effective for
long term (5ft)
Possibly
major
obstacles
67.7-86.6 (2ft)
142.1-184.4 (5ft)
Provides short
term protection
of public
Does not
comply
with soil
ARAR
None
1.34.5
\
High
3.2
Temporarily
effective
ERMdMindtallor
Ctftgoryliorain
Possibly
major
obstacles
53.0-66.0
Provides
short term
protection
-------
Summary of Major ARARs
Type of requirement
PUBLIC HEALTH
•Radon Decay Products
•Gamma radiation
•Maximum exposure to
radiation
•Ingestion of soil
•Ingestion of vegetables
OCCUPATIONAL
CLEANUP OF LANDS
•Ra-226 and Th-230
CLEANUP OF SURFACES
LAND DISPOSAL
•Longevity
•Radon emission rate
•Design
•Correction and prevention
of ground water
contamination
TRANSPORTATION
ENVIRONMENTAL
•Soluble Ra-226 iru
- Drinking water
-Ground water
-Surface water
-Air
/Soluble Th-230 in air
/
HISTORIC DISTRICT
ARAR
0.02 WL
(as an annual average)
20ufl/hr
above background
0.17rem/yr
above background
none
40 pCi/g of Ra-226
in soil
(See appendix B)
5 pCi/g above back-
ground at surface2;
15 pCi/g above back-
ground at subsurface2
(See appendix B)
At least 200 yrs.
20 pCi/m*/sec.
(See appendix B)
(See appendix B)
(See appendix B)
5pCi/l
(Ra-226 and Ra-228
combined)
30pCi/l3
30pCi/1
0.003 pCi/l
0.00008 pCi/l
(See appendix B)
Source of ARAR
40 CFR 192;
EPA guidance
40 CFR 192;
EPA guidance
EPA guidance;
FRC report
NCRP Report No. 77
10 CFR 20;
NJ.A.C.728
40 CFR 192;
DOE 5480-1A
NRC Reg. Guide 1.86
40 CFR 192
40 CFR 192
40 CFR 264;
NJ.A.C. 726-1 1.4, 11.7
40 CFR 192
49 CFR 173
40 CFR 141;
NJ.A.C. 73-6.6
10 CFR 20;
NJ.A.C. 728-6.5
NJ.A.C. 728-6.5
10 CFR 20;
N.J.A.C. 728-6.5
10 CFR 20;
NJ.A.C. 728-6.5
National Historic
Preservation Act of 1966
Highest value
measured
on site
1.5WL
LOOOulVhr
2.1 rem/yr1
(estimated using
maximum risk
scenario)
1, 500 pCi/g surface
4,545 pCi/g subsurface
1, 500 pCi/g surface;
4545 pCi/g subsurface
574 pCi/m'/sec.
122 pCi/l
11.8pCi/l
<1 pCi/l
Not measured
0.00004 pCi/l
(Total gross alpha)
Average
background
0.002 WL
8.3uA/hr
0.073 rem/yr'
1pCi/g
1 pCi/g
\
<1 pCi/rrrVsec.
0.2 pCM
0.5 pCi/l
0.1-0.5pCi/l
NA
<0.000001 pCi/I
'Estimated using indoor/outdoor gamma measurements.
Does not include exposure to radon decay products.
2 Averaged over 100 square meter area.
1 If classified as a drinking water aquifer, limit is 5 pCi/l for Ra-226
and Ra-228 combined.
-------
TABLE SW-^
Compliance with ARARs
ARAR
Alternative
1 2
34 5 6
7
PUBUC HEALTH
Radon decay
producta
Gamma radiation
Radlonuclldea In aoll
CLEANUP
of landa and bulldlnga
contaminated with
radioactive malarial
DISPOSAL
TRANSPORTATION
ENVIRONMENTAL
drinking water, ground
and surface waters,
outdoor air
HISTORIC DISTRICT
SUMMARY
/
/
/
/
/
Does not
comply
Doe* not
comply
Does not
comply
Does not
comply
NA
NA
Complies
No impact
Does not
comply witn
Public Health
Not for
al houses
Does not
comply
Does not
comply
Does not
comply
NA
NA
Complies
MramaJ
impact
Does net
comply with
some Public
Complies
CompGes
Complies,
with
Institutional
Controls
Does not
comply
NA
NA
Compfies
Possible
impact
Complies with
Public Health
ARAR's
or soU cleanup Health ARAR's
ARARs
or the soil
cleanup ARAR
Does not
comply with
soil cleanup
ARAR
Complies
Complies
Complies
Complies
Std. design
complies
Alt design
may not
comply
Complies
Complies
Possible
impact
Complies
with all
ARARs
(std. design)
Complies
with all
but longevity
requirement
(alt design)
Compfies
Complies
CompGes
CompGes
Win comply
with host state
requirements
Complies
Complies
Possible
impact
Compfies
with all
ARARs
Complies
CompGes
Complies,
with
Institutional
Controls
Does not
comply (2ft)
Compfies
for some
properties
(5ft)
WiD comply
with host state
requirements
CompGes
Compfies
Possible
impact
Complies with
Public Health
ARAR's
Does not
comply with
soil ARAR (2ft)
5 foot option
complies
with soil ARAR
on some
properties
1
Complies
CompGes
CompGes, with
Institutional
Controls
CompGes for
Category land
certain other
properties
'
Win comply ^
with host staV
requirements |
Complies
Complies
Possible
impact
Complies with
Public Health
ARAR's
Complies with
soil ARAR on
Category!
and certain
other
properties
-------
Evaluation of Long-Term: Effectiveness and Permanence^
FACTOR
Alternative
1 2 3 4 5
6
7 "
Permanence
Magnitude of
residual risk
Type/degree of
long-term
mamagemenl
Long-term
reliability of
Institutional
controls
Human exposure
Environmental
exposure
Long-term
rellbillty of
engineering
control
Need for
replacement
of remedy
Summary
Final Interim
High High
None Institutional
'. con trow
that
are difficult to
implement
. NA Not reliable
High High
High High
NA Not reliable
' NA Definite
Not Not
effective effective
Interim
Medium
Institutional
controls
that
are difficult to
implement
Notifiable
Medium
High
Unknown
Definite
Temporarily
effective
Final
None
Institutional
controls
on site
that are
easy to
implement
Reliable
Low
Low
Reliable
(std. design)
At least 30 yrs
(aft design)
Not likely
Final and
effective
(std. design)
Effective but
not Final
(aft design)
Final
None
Institutional
controls
off site
that are
easy to
implement
Reliable
Low
Low
Reliable
Not likely
Final and
effective
Interim
(5 ft could be
final on some
properties)
Medium (2 ft)
Low (5 ft)
Institutional
controls
that are
difficult to
implement
Not
reliable (2 ft)
More
reliable (5 ft)
Medium (2ft)
Low (5 ft)
High (2 ft)
Medium (5 ft)
Unknown
Definite (2 ft)
Possible (5 ft)
Temporarily
effective (2 fir
Maybe
effective (5 ft)
Interim
(Category 1 *
properties are final)
Medium/Low
None
(Category 1* prepsrtfM)
Institutional
controls
that are
difficult to
implement
Not
reliable
Medium/Low
Low (Category 1*
properties)
Medium
Unknown
Reliable
(Category 1* propsriMi)
Possible
Not likely
(Category 1* properties)
Temporarily
effective
Final and
Effective
(Category 1*
properties)
' Includes certain properties in other categories.
-------
TABLE 8
ESTIMATED NUMBER OF PROPERTIES IN CATEGORIES
jory
Study Area
Total
MONTCLAIR
16*
:i so
ill 34
:v 162
104
WEST ORANGE
2
4
8
28
33
GLEN RIDGE
5
21
23
96
161
TOTALS
23
75
65
286
298
747
Includes four properties partially excavated as part of
the NJDEP pilot excavation program.
-------
USEPA CONTRACT NUMBER: 68-W8-OJ24
USEPA WORK ASSIGNMENT NUMBERS: 005-2LA9/006-2LB1
FINAL RESPONSIVENESS SUMMARY
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
JUNE 1989
NOTICE
The preparation of this document has been funded by the United States
Environmental Protection Agency (USEPA) under the ARCS Region II Contract
Number 68-W8-0124 to ICF Technology Incorporated (ICF).
-------
The purpose of this Responsiveness Summary is to provide the
public with a summary of citizen comments and concerns about the
Montclair/West Orange and Glen Ridge Radium sites in Essex
bounty, New Jersey, and the U.S. Environmental Protection
Agency's (EPA) responses to those concerns. This responsiveness
summary addresses comments received during the public comment
period on the Supplemental Feasibility Study (FS) report and
Proposed Plan which were released in April 1989.
EPA first released a remedial investigation and feasibility study
(RI/FS) report for the sites in the fall of 1985, followed by a
public comment period which extended from September 18, 1985 to
November 27, 1985. During a public meeting to discuss the RI/FS
held in November 1985, the Agency indicated that excavation of
the radium-contaminated material was the preferred solution for
the Montclair/West Orange and Glen Ridge-Radium sites. However,
based on the State of New Jersey's experience since the 1985,
locating and assuring the continuing availability of a disposal
facility can pose major obstacles to implementing any excavation
remedy. For this reason, EPA has developed and evaluated
additional alternatives to address the problem while at the same
time maintaining temporary measures to lower exposures in the
affected homes.
• '•'" • • • \
A summary of the comments received during the April 4 through
June 9, 1989 public comment period is provided in this respon-
siveness summary. Additional community concerns about EPA's
remediation efforts at the Montclair/West Orange and Glen Ridge
Radium sites are summarized in the "Final Summary of Citizens'
Concern About the Remedial Investigation and Feasibility Study"
and "Final Public Information Meeting Summaries for the Mont-
clair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey". The report, "Final Summary of Citizens' Concern About
the Remedial Investigation and Feasibility Study", is a summary
of verbal and written comments received during the public comment
period of September 18, 1985 to November 27, 1985. The report,
"Final Public Information Meeting Summaries for the Montclair/
West Orange and Glen Ridge Radium Sites, Essex County, New Jer-
sey" is a summary of EPA's presentation, and comments received at
special Town Council meetings convened by the Mayors of Mont-
clair, West Orange, and Glen Ridge on April 3, 1989. These
meetings were held to initiate community discussion on the
Supplemental. FS report and Proposed Plan for the Montclair/West
Orange and; Glen Ridge Radium sites. Both of these reports are
available" for review at the information repositories identified
in Appendix A.
All comments and concerns summarized in this document, along with
those summarized in the "Final Summary of Citizens' Concern About
the Remedial Investigation and Feasibility Study" and in the
"Final Public Information Meeting Summaries for the Montclair/
West Orange and Glen Ridge Radium Sites, Essex County, New Jer-
-------
sey", have been considered by EPA in making a decision regarding
the selection of an alternative for remedial action at the Mont-
.clair/West Orange and Glen Ridge Radium sites. Additionally, EPA
plans to initiate a supplemental groundwater investigation for
the Montclair/West Orange and Glen Ridge Radium sites after the
Record of Decision (ROD) has been signed.
This responsiveness summary for the Montclair/West Orange and
Glen Ridge Radium sites is divided into the following sections:
Z. Responsiveness summary Overview. This section briefly
outlines the remedial alternatives that were evaluated
as part of the Supplemental Feasibility Study (FS), and
summarized in EPA's Proposed Plan.
XI. Background on Community Involvement and concerns. This
section provides a brief history of community interest
in the Montclair/West Orange and Glen Ridge Radium
sites. In addition, this section describes community
relations activities conducted at the sites.
III. Summary of Major Questions and comments. This section
summarizes major questions and comments made verbally\
and in writing to EPA during the 1989 public comment
period on the Supplemental FS and the. Proposed Plan and
provides EPA responses to these comments.
XV. Remaining Concerns. This section discusses community
concerns that remain to be addressed once the ROD is
signed. These concerns focus on the details of how the
selected remedial alternative will be implemented.
Appendix A Location of the information repositories for the
Montclair/ West Orange and Glen Ridge Radium
sites.
Appendix B "Final Public Information Meeting Summaries for
the Montclair/ West Orange and Glen Ridge Radium
Sites, Essex County, New Jersey".
Appendix C Public Meeting Agenda and sign-in sheets from the
•• - public meeting held by EPA on May 18, 1989 to
discuss the Supplemental FS and EPA's Proposed
•jSv Plan for remedial action.
. 'L T:*} • '•
Appendix D Selected Newspaper notices announcing dates of the
public comment period, extensions granted and
location and time of the public meeting.
-------
X. Responsiveness Summary Overview.
The Montclair/West Orange and Glen Ridge Radium sites are located
in Essex County, New Jersey. The soil at the sites is contami-
nated to varying degrees with radioactive waste materials
suspected to have originated from nearby radium processing or
utilization facilities in the early 1900s. The material, which
is similar to uranium mill tailings, was disposed of in then-
rural areas of the communities. Some of the radium-contaminated
material is also believed to have been moved from the original
disposal locations and used as fill material in low-lying areas.
Houses were constructed on or near the radium waste disposal
areas (also referred to as "core areas"). In a few instances, it
appears that some of the material was mixed with Portland cement
to make concrete for sidewalks and foundations. As a result, the
public is being exposed to elevated indoor concentrations of
radon and radon decay products, as well as excessive levels of
indoor and outdoor gamma radiation.
The remedial alternatives evaluated as part of the Supplemental
FS are outlined below.
Alternative 1: No Additional Action
Alternative 2: Continue Existing Action
Alternative 3: Engineering Controls
Alternative 4: The Park(s) Alternative
Alternative 5: Total Excavation, With Off-Site Disposal
Alternative 6: Partial Excavation, With Off-Site Disposal
Alternative 7: The Combined Approach
EPA had identified Alternative 7, The Combined Approach, as the
Agency's preferred alternative in the Proposed Plan. Under
Alternative 7, the actions to be implemented on a particular
property would depend on the nature and extent of contamination
at that property. These actions would include: total excavation
of the most extensively contaminated properties and limited exca-
vation at others; engineering controls to reduce exposure to
radon, radon decay products, gamma radiation, and radium-contami-
nated soil; and institutional controls to ensure the effective-
ness of the engineering controls. All actions would be designed
to ensure protection of public health. Alternative 7 was devel-
oped to offer a comprehensive and fully implementable remedy to
address public health risks at the sites. This alternative would
take approximately 3 years to implement.
EPA's selected remedy is a slight modification of Alternative 7.
The remedy will address the most highly contaminated properties
by fully excavating the radium-contaminated soil. In addition,
at many of the properties, EPA intends to undertake limited
excavation of near surface contamination, but only at properties
where such an action would provide a final remedy. This differs
/from the proposed plan, where the partial excavation would have
-------
left contaminated material, at depth, at a number of properties.
This modification obviates the necessity for institutional
controls at many of the properties at the remedy implemented will
be final and permanent. A decision on those properties where no
soil will be excavated will be deferred pending additional
dialogue with local officials and affected residents, and will be
included in subsequent Records of Decision.
A summary of the site background, alternatives evaluated and a
comparison of alternatives are presented in the Proposed Plan and
more fully described in the Supplemental FS report. The
Supplemental FS report is available for public review at the
information repositories identified in Appendix A.
II. Background on Community Involvement and Concerns.
This section provides a brief history of community participation
in the Montclair/West Orange.and Glen Ridge Radium sites during
remedial planning activities conducted to date.
A history of community involvement from the initial discovery of
the sites in 1979 through October 1986 is documented in the
report "Final Summary of Citizens' Concern About the Remedial
Investigation and Feasibility Study". This report also includes^
a summary of concerns expressed during the public comment period
of September 18, to November 27, 1985 for the- RI/FS.
EPA has also continued to inform the public concerning develop-
ments and progress on the Montclair/West Orange and Glen Ridge
sites. In November 1986, EPA issued an update informing the
affected residents of additional sampling and testing that was to
be performed. In addition, EPA held availability sessions from
December 8 to 11, 1986 to allow residents to discuss property-
specific radon gas and gamma radiation test results. In March
1987, EPA issued another update along with the latest health
assessment which reconfirmed the Agency for Toxic Substances and
Disease Registry's (ATSDR's) and Centers for Disease Control's
(CDC's) earlier findings for the sites. Public availability
sessions were also held from March 30, 1987 to April 1, 1987 to
provide residents an opportunity to discuss the health
assessment. Another update, discussing progress on the
supplemental feasibility study, was mailed to affected residents
and concerned individuals later in 1987.
-It -
•. x • •
Community relations activities conducted subsequent to the re-
lease of the Supplemental FS report are summarized in the remain-
der of this section. On April 3, 1989, EPA attended special Town
Council meetings that were convened by the mayors of the communi-
ties of Montclair, West Orange and Glen Ridge to discuss the
findings of the Supplemental Feasibility Study. The issues
identified at the three Town Council meetings are summarized in
/the "Final Public Information Meeting Summaries for the Mont-
-------
clair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey", which is attached as Appendix B.
On April 4, 1989, EPA mailed the affected residents a copy of the
Proposed Plan, along with a stamped, addressed postcard to allow
interested residents to request a copy of Volume 1 of the draft
Supplemental FS report. Public availability sessions were
conducted on April 5 to 7, 1989 from 2:00 p.m. until 7:00 p.m.,
and on April 8 from 10:00 a.m. to 3:00 p.m., at EPA's office
trailers on Oak Street, adjacent to Nishuane Park in Montclair.
These sessions were held to discuss the Supplemental FS and the
Proposed Plan. Over 100 affected residents, interested citizens,
local officials and news reporters attended the public availabil-
ity sessions.
EPA held a public meeting on May 18, 1989 to discuss the Supple-
mental Feasibility Study and receive formal public comment. EPA
Region II representatives included: William Muszynski, Acting
Regional Administrator; John Frisco, Associate Director for
Remedial Programs; Robert McKnight, Chief, Northern New Jersey
Remedial Action Section; and Raimo Liias, Remedial Project
Manager. William Nelson represented ATSDR. Other EPA and New
Jersey Department of Environmental Protection (NJDEP) staff and \
EPA's contractor also attended. -. \
An agenda for the public meeting, and a sign-in sheet of those
who attended the meeting are attached as Appendix C. Approxi-
mately 50 affected residents, interested citizens, local offi-
cials and news reporters attended the public meeting. On May 19
(from 2:00 p.m. until 7:00 p.m.) and on May 20 (from 10:00 a.m.
to 3:00 p.m.), additional public availability sessions were held
at EPA's office trailers on Oak Street in Montclair.
ZZX. Summary of Major Questions and Concerns Raised during the
Public Comment Period and EPA's Response to Comments.
This section addresses the public comment period held from April
4, 1989 through June 9, 1989. A preference for Alternative 5,
Total Excavation, With Off-Site Disposal, has been expressed con-
sistently by the local officials, community groups, and individu-
al citizens who have commented on EPA's activities since the
initial RZ/FS report was "released in 1985. Written and verbal
comments received during the public comment period on the Supple-
mental FS report and Proposed Plan reiterate this preference.
The numbers of citizens actively participating in the decision
making process for the sites, and the tone of the comments
received have changed significantly between November 1985 and the
present.
In 1985, during the comment period on the RI/FS, over 1500
citizens participated in the public comment process. At that
/time, the entire community was adamant that EPA totally remove
-------
all contaminated materials from the communities. Public involve-
ment during the recent comment period on the Supplemental FS was
significantly less dramatic, with approximately 150 citizens
participating. More importantly, the tone and type of comments
received have changed significantly. While the communities'
clearly prefer full excavation and off-site removal of all con-
taminated materials, discussions with affected residents, especi-
ally during the one-on-one public availability sessions, illus-
trated the communities' awareness and empathy for the difficult-
ies encountered in securing a disposal site for the excavated,
contaminated material.
A summary of verbal and written comments received during the
public comment period are categorized in the nine topical areas
listed below:
Health Related Concerns
Institutional Controls
Engineering Controls
Technical Issues
Project Schedule
Proposed Alternative
Other Alternatives Evaluated
Cost
Miscellaneous Concerns
Health Related Concerns
COMMENT: Residents expressed concern that EPA's Proposed Plan
addressed only the environmental impacts of the contamination.
They requested that EPA ask the Centers for Disease Control to
conduct a longitudinal health study of residents living within
the study area.
EPA RESPONSE: The New Jersey Department of Health would be
responsible for conducting any health studies of this type at the
sites. EPA will inform the New Jersey Department of Health and
ATSDR that some residents have requested this type of study.
COMMENT: Several residents expressed concern that Alternative 7,
The Combined Approach, was not as protective of public health as
Alternative-5,. Total Excavation, With Off-Site Disposal.
:?" -
EPA RESPONSE: Alternative 7, The Combined Approach, does provide
for the protection of public health at all properties within the
study areas.
COMMENT: The Montclair Environment Advisory Committee asked why
maximum exposure situations were not included in Table 4-2,
"Above-Background Risks Remaining After Remediation", of the
Supplemental FS report.
-------
EPA RESPONSE: Exposure is based on the sum of the proportions of
potential exposures received through the various routes. Not all
the residents would be exposed to the maximum exposures received
at the most contaminated properties. Shown on the table, the
risks presented are averaged over the twelve properties
specifically selected to encompass the range of exposure
scenarios. Hence, the maximum exposure ranges would not be
appropriate.
COMMENT: Local officials, the Montclair Environment Advisory,
and several residents asked what safeguards were incorporated
into Alternative 7, The Combined Approach, to prevent exposure to
contaminated material during excavation.
EPA RESPONSE: During excavation, monitoring, erosion control and
dust, suppression measures would be implemented. Additionally,
EPA intends to have all disposal and transportation details in
place prior to the initiation of any excavation.
Institutional Controls
COMMENT: Local officials and the Montclair Environment Advisory
Committee asked how, under the Proposed Plan, EPA would ensure \
the health and safety of town employees or outside contractors;
when they are conducting normal repair and maintenance of streets
and utilities in contaminated areas.
EPA RESPONSE: EPA will assist the affected communities in devel-
oping proper protocols for monitoring and handling materials
excavated during maintenance operations beneath public properties
and streets. EPA could provide monitoring assistance during
excavation of radium-contaminated areas, and could provide assis-
tance with disposing of material removed during these operations.
COMMENT: Local officials, citizen groups, and many interested
individuals asked for details on how the institutional controls
proposed as part of Alternative 7, The Combined Approach, would
be enforced at properties where there is residual contaminated
material.
EPA RESPONSE: EPA has deferred the decision on partial exca-
vation of any properties, so that institutional controls for
those properties will be addressed in subsequent Records of
Decision.- , No details have yet been established on how the
institutional controls would be implemented or enforced. EPA
will seek the input and support of local officials and other
interested community members during the additional.comment period
to ensure that appropriate and effective institutional controls
are implemented.
-------
Engineering Controls
COMMENT: The Montclair Environment Advisory Committee asked
'about the procedures EPA would use to obtain clean soil for
backfilling the excavated areas.
EPA RESPONSE: After the ROD is signed, during the design phase,
EPA will seek competitive bids for replacement soil to be used as
backfill for the excavated areas. All soil used for backfill
will meet required standards prior to application at any
property.
COMMENT: Many interested parties asked about EPA's schedule for
reviewing the interim measures that are proposed to be imple-
mented as part of Alternative 7, The Combined Approach. Many
also asked about EPA's future plans for monitoring at the sites.
EPA RESPONSE: EPA intends to continue its efforts to find a
permanent solution for those properties where interim measures
are implemented, as soon as the ROD is signed. EPA will also
continue to monitor all of the affected properties throughout the
design and implementation of the remedial action. A review will
be conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate \
protection of human health and the environment.
COMMENT: Several interested parties questioned the track record
of the engineering controls, i.e., sub-slab ventilation systems
proposed in Alternative 7, The Combined Approach. They also ex-
pressed concern about the potential for erosion of the clean soil
cover that is proposed for some of the Category II and III pro-
perties. They also expressed concern about the potential for
children and gardeners to ingest contaminated material under this
alternative.
EPA RESPONSE: EPA is confident that sub-slab ventilation systems
are effective, and that it is the appropriate radon reduction
technique to employ. Additionally, slopes in and around the
study area are not sufficiently steep such that erosion should be
a problem. EPA has deferred the decision on partial excavation
of any properties. At properties with identified gamma anoma-
lies, where no excavation occurs, there will be the potential for
children and gardeners to ingest contaminated material. However,
with an appropriate soil cover as envisioned as part of the
shielding,,program under Alternative 7, The Combined Approach,
there should be no exposure to gamma radiation above the health
guidelines. With the soil shielding and the woven nylon indica-
tor fabric, that was proposed to be buried at depth at category
"11" and "III" homes, there would be no residual contaminated
material at the surface. Hence, there would be little or no
irigestion of contaminated soil by children or gardeners. Neither
8
-------
should there be any significant uptake of radium in vegetables
grown on remediated properties.
COMMENT: The Mohtclair Environment Advisory Committee asked what
safety measures would be implemented in case of system malfunc-
tion of the engineering controls.
EPA RESPONSE: The new radon reduction systems that are proposed
as part of the engineering controls include indicator or safety
switches which warn of system malfunctions. Indicator lights are
lit when the system is operating, and go off when there is a pro-
blem. This provides for a positive identification of operational
problems.
Technical Issues
COMMENT: The Montclair Environment Advisory Committee wanted to
know if data gaps about the contamination present at specific
properties could effect the implementation of EPA's Proposed
Plan.
EPA RESPONSE: The data collected to date is sufficient to select
a remedial plan for the sites. Additional data will be collected
during the design activities that will further refine the specif-
ic remedial activities to be conducted at some of the
properties.
COMMENT: The Montclair Environment Advisory Committee inquired
whether the amount and location of all of the waste, i.e., source
material, from the U.S. Radium site had been identified.
Additionally, they were interested to know whether EPA was
actively pursuing potentially responsible parties.
EPA RESPONSE: Estimates of the U.S. Radium plant's waste
production have been made, however, the source(s) of the material
disposed of at the Montclair/West Orange and Glen Ridge sites has
not been conclusively determined. EPA is still attempting to
discover evidence that will substantiate the allegations
regarding the source(s) of the radium-contaminated materials
discovered at the sites.
Project Schedule
COMMENT: Many of those who commented, inquired into EPA's
proposed timetable for implementing the Proposed Plan. Local
officials, citizen groups and individual citizens encouraged EPA
to begin remediating properties in 1989 instead of 1990 as
identified in the Proposed Plan, especially the four NJDEP pilot
program properties.
EPA RESPONSE: EPA is exploring all available mechanisms to
provide relief for the four families that have been displaced
-------
because of the NJDEP pilot program. Unfortunately, it is not
likely that these four properties can be remediated before the
end of this calendar year because of the length of time required
to secure contractors to design and implement the selected
remedy. Additional time will be required to complete the
coordination for the transportation and disposal of the soil that
will be removed from the four properties.
COMMENT: Several interested citizens asked how long EPA expected
it would take to complete the implementation of Alternative 7,
The Combined Approach.
EPA RESPONSE: EPA estimates that the length of time to complete
the implementation of the selected remedy would be about 3 years
from the signing of the ROD.
COMMENT: Several interested parties asked when the regulatory
and transportation details for implementing, Alternative 7, The
Combined Approach, would be developed. Additionally, these
parties expressed interest in EPA's proposed process for
obtaining clean soil to be used to replace the excavated
contaminated soil.
EPA RESPONSE: Arrangements for disposal and transportation of
the soil will be developed during the design phase and will be
established prior to the initiation of excavation. The source of
all replacement soil will be determined by competitive bid, and
will meet required standards prior to purchase and application at
any property.
Proposed Plan
COMMENT: Local officials from Montclair and Glen Ridge, the
Montclair Environment Advisory Committee and many individual
citizens commented that Alternative 5, Total Excavation, With
Off-Site Disposal, should be selected instead of EPA's Proposed
Plan (Alternative 7, The Combined Approach).
EPA RESPONSE: Based on the past experience of the NJDEP in
securing and maintaining the availability of a disposal site,
coupled with the desire to minimize the disruption to the com-
munity, EPA is selecting a more limited remedial option than
complete excavation of the estimated 323,000 cubic yards of
contaminate* material. EPA intends to fully excavate approxi-
mately 23 properties, with off-site transport and disposal of
more than 42,000 cubic yards. In addition, EPA intends to under-
take full excavation at several more properties, where near-sur-
face excavation would provide for a final remediation of the
property. This would account for approximately 4,000 additional
cubic yards.
10
-------
COMMENT: The Montclair Environment Advisory Committee asked why
the depth of soil to be excavated at category "n" properties was
determined to be two feet.
EPA RESPONSE: Excavation of two feet of contaminated material is
estimated to allow for the placement of sufficient clean soil to
provide effective shielding against gamma radiation.
COMMENT: Several residents asked what safeguards or guarantees
EPA could provide with respect to ensuring the ongoing availabil-
ity of a disposal site.
EPA RESPONSE: EPA cannot guarantee that problems similar to
those which occurred under the NJDEP pilot program in maintaining
the availability of a disposal facility will not reoccur under
EPA's Proposed Plan. However, EPA has proposed a plan to mini-
mize the impacts of such an occurrence. EPA does not intend to
store any of the contaminated soil that is excavated at any New
Jersey facility. EPA intends to continuously remove the contami-
nated soil for transport to a disposal site. EPA plans to use a
continuous shipping process, which may require a loading facility
to be available. The loading facility is an issue that EPA
intends to address in the design phase prior to the initiation of
any excavation. Additionally, if either the transportation or "-;
disposal components of EPA's remedy are interrupted, EPA intends
to stop all excavation, replace the contaminated material,
install engineering controls to the maximum extent practical and
return the affected resident(s) to their home(s).
COMMENT: Local officials, citizen groups and individual citizens
wanted to know if EPA intends to remove contaminated material
from beneath public properties and streets as part of their
Proposed Plan. Many who commented encouraged EPA to include
public properties and streets in their ROD.
EPA RESPONSE: EPA did not include excavation of soil from
beneath public properties and streets as part of the Proposed
Plan. Instead, institutional controls would have been imposed to
ensure the protection of workers who might come into contact with
contaminated soil during repair or maintenance activities. Based
on the comments received on this issue, EPA has decided to defer
a decision on public properties and streets to give local
officials and area residents an opportunity to provide additional
input on appropriate remedial measures for these properties.
COMMENT: Local officials, the Montclair Environment Advisory
Committee and several residents asked if any Township or Boro
properties were within category I, II, III or IV.
EPA RESPONSE: Several Town or Boro properties, including some
public streets and sidewalks, may be classified as any one of the
11
-------
categories. Confirmational testing during the design activities
could revise the classification of some properties.
COMMENT: Several interested parties asked whether NJDEP
supported EPA's Proposed Plan.
EPA RESPONSE: NJDEP fully supports EPA's Proposed Plan and
selected remedy.
COMMENT: A member of Montclair Environment Advisory Committee
asked if EPA's Proposed Plan for remediation of the Montclair/
West Orange and Glen Ridge Radium sites was linked in any way to
New Jersey's Low Level Waste Compact.
EPA RESPONSE: The Low level Waste Compact specifically deals
with the disposal of low level radioactive materials that are
regulated by the Nuclear Regulatory Commission (NRC). The
contaminated material discovered at the Montclair/West Orange and
Glen Ridge sites is considered diffuse naturally occurring
radioactive material (NORM), and, therefore, not regulated by the
NRC. EPA is certain that there is no connection with the New
Jersey Low Level Waste Compact siting process.
Otber Alternatives Evaluated :
COMMENT: A resident of Glen Ridge inquired as to the feasibility
of selecting Alternative 4, The Parks Alternative, in Glen Ridge
and another alternative such as Alternative 7, The Combined
Approach, or Alternative 5, Total Excavation, With Off-Site
Disposal, in Montclair.
EPA RESPONSE: EPA could make different decisions for the
Montclair/West Orange and Glen Ridge Radium sites. EPA has
studied the impact of the relocation and disruption that the
implementation of Alternative 4, The Parks Alternative, might
entail. Because of the potential social and economic impacts of
this option, EPA has not recommended selection of this alterna-
tive for either site. The consensus of public and local official
opinion opposes any on-site disposal option.
COMMENT: Several interested parties questioned how Alternative
4, The Parks Alternative, could be considered environmentally
protective since residual contaminated material would be left
permanently; on-site under this alternative.
EPA RESPONSE: It is impossible to destroy radioactivity.
Therefore, containment and/or isolation are two options that
could protect the environment from the migration of contamination
from the parks. Alternative 4, The Parks Alternative, contains
provisions for a protective cap that would prevent the migration
of contamination. Thus, this alternative is both technically
'sound and feasible. However, as mentioned above, EPA is not
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recommending this alternative be selected because of the social
and economic impacts that such an option could entail.
Cost
COMMENT: Several interested parties asked who was responsible
for the cost of monitoring, operating, and maintaining engineer-
ing and institutional controls that are proposed as part of any
alternative.
EPA RESPONSE: EPA or the State of New Jersey would provide for
the cost of monitoring, operating, and maintaining engineering
and institutional controls that would be required as part of any
alternative.
COMMENT: Several interested citizens asked how much EPA's
Proposed Plan (Alternative 7, The Combined Approach) is estimated
to cost.
EPA RESPONSE: The estimated cost of the Proposed Plan,
Alternative 7, The Combined Approach, is $53 million.
Miscellaneous Concerns
COMMENT: The Montclair Environment Advisory Committee was •
interested to know how many residents had participated in the
public availability sessions conducted by EPA on April 5 to 8,
1989.
EPA RESPONSE: Sixty-nine study area residents visited the
trailers in April. Another 20 interested citizens also visited.
Phone contact was made with an additional 50 study area
residents. All residents of category I properties were either
contacted and/or visited and given an opportunity to meet with
EPA on an individual basis.
COMMENT: The Montclair Environment Advisory Committee asked how
realtors could obtain information about which category individual
properties fall into within the study area.
EPA RESPONSEi Realtors should be able to get category informa-
tion from each individual homeowner. EPA's practice is not to
release information about individual properties to anyone except
the property*owner without the property owner's permission.
XV. Remaining Concerns.
The remaining community concerns focus on two primary areas.
First, virtually all persons who commented on EPA's Proposed Plan
expressed concern about the details of implementation of the
selected remedial alternative. Extensive coordination with resi-
'dents and local officials will be required to successfully imple-
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ment the selected remedial alternative. Numerous details on how
institutional controls and temporary relocation efforts will be
.implemented, will be addressed in the comment period which has
been extended to provide for additional dialogue between con-
cerned citizens, local officials and the EPA. Given the problems
which occurred during NJDEP's pilot program, residents remain
skeptical of EPA's ability to successfully remediate the sites.
Second, interested citizens attending the May 18, 1989 public
meeting in Montclair, inquired about the schedule for EPA's
planned groundwater investigation and its potential effect on
EPA's Proposed Plan for remedial action. EPA explained that it
plans to proceed with the groundwater investigation following the
signing of the ROD. Further, EPA explained that, at this time,
it does not expect the results of the additional groundwater in-
vestigations to affect the plan for remediation of the sites.
Concern about the potential for groundwater contamination and its
potential effect on the community is expected to continue until
the groundwater investigations are complete and the results
evaluated.
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APPENDIX A
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List of Repositories
United States Environmental Protection Agency, Region II
Room 711
26 Federal Plaza
New York, New York 10278
New Jersey Department of Environmental Protection
401 East State Street
Trenton, New Jersey 08625
Office of the Mayor and the Montclair Task Force
Hontclair Municipal Building
205 Claremont Avenue
Montclair, New Jersey 07042
Montclair Public Library
50 South Fullerton Avenue
Montclair, New Jersey 07042
Office of the Mayor
Municipal Building
825 Bloomfield Avenue
Glen Ridge, New Jersey 07028
Office of the Mayor and the West Orange Task Force
Municipal Building
66 Main Street
West Orange, New Jersey 07052
Glen Ridge Public Library
Bloomfield Avenue
Glen Ridge, New Jersey 07028
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APPENDIX B
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FINAL PUBLIC INFORMATION MEETING SUMMARIES
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
Work Assignment Nos. 037-2LB1/038-2LA9
Document Nos. 135-CR1-MTHDNZ
136-CR1-MTHDPA
This document has been prepared for the U.S. Environmental
Protection Agency under contract 68-01-6939. The material
contained herein is not to be disclosed to, discussed with, or
made/available to any person or persons for any reason without
the/prior expressed approval of a responsible official of the
U.S. Environmental Protection Agency.
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MONTCLAIR TOWN COUNCIL MEETING
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
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PUBLIC INFORMATION MEETING SUMMARY
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
TOWNSHIP OF MONTCLAIR, ESSEX COUNTY, NEW JERSEY
MONTCLAIR TOWN COUNCIL MEETING
On April 3, 1989 at 7:00 p.m., the U.S. Environmental Protection
Agency (EPA) attended a special Montclair Town Council meeting at
the invitation of Mayor Clifford Lindholm. The meeting was held
to discuss the Montclair/West Orange and Glen Ridge Radium sites
located in Essex County, New Jersey. EPA's purpose in attending
the meeting was to inform local officials and residents that EPA
had completed the draft Supplemental Feasibility Study (FS) for
the Montclair/West Orange and Glen Ridge Radium sites and to
explain EPA's Proposed Plan for remediation of the sites. The
presentation included a brief review of the draft Supplemental FS
prepared for the sites and an introduction to the Proposed Plan.
In addition, EPA responded to questions from interested local
officials and citizens. Attached to this meeting summary as
Appendix A, is a fact sheet that was distributed at the meeting.
Approximately 40 people attended the public meeting.
EPA Region II representatives included: William Muszynski, Acting
Regional Administrator; John Frisco, Associate Director,
Emergency and Remedial Response Division; and Lillian Johnson,
Community Relations Section Chief, Office of External Programs.
EPA contractor personnel included Colleen Ranney, REM II site
Manager, and Sheila Conway, REM II Community Relations
Specialist.
The public meeting began with Montclair Mayor Clifford Lindholm's
introduction of Mr. Muszynski, Acting Regional Administrator, EPA
Region II. Mr. Muszynski explained that EPA has been struggling
with the difficult problem of disposal of the contaminated soil
since the initial Montclair/West Orange and Glen Ridge Remedial
Investigation and Feasibility Study (RI/FS) draft report was
released in 1985. He went on to explain that additional sampling
and evaluation of remedial alternatives has been conducted and
EPA is now asking the public to comment on the Proposed Plan.
Mr. Muszynski invited local officials, affected residents, and
interested citizens to actively participate in the decision
making process for the sites. To encourage public participation,
in the decision making process, he noted that copies of the
Proposed -Plan and draft Supplemental FS report were being placed
in the library and Town Hall for public review. Additionally, he
stated that EPA would be mailing the Proposed Plan to all
affected residents on or about April 5, 1989. Included in the
mailing would be a stamped, addressed postcard that would allow
interested residents to request Volume 1 of the draft
Supplemental FS report.
/ • . . .
Mr. Muszynski then outlined the public participation process for
this phase of the project, noting that a public comment period on
the Proposed Plan would be held from April 4 to June 2, 1989. He
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also explained that, in addition to the Town Council meeting, EPA
staff will be available to meet with residents on an individual
basis on April 5-7, 1989 from 2:00 p.m. until 7:00 p.m., and on
Saturday April 8 from 10:00 a.m. to 3:00 p.m. at EPA's office
trailers on Oak Street, adjacent to Nishuane Park in Montclair.
He further explained that a public meeting and additional public
availability sessions would be held in mid-May.
Fact sheets were then distributed to all in attendance which
provided a summary of the Proposed Plan. Following his overview,
Mr. Muszynski introduced John Frisco, Associate Director of the
Emergency and Remedial Response Division.
Mr. Frisco presented the history of the Montclair/West Orange and
Glen Ridge sites and explained that EPA's preferred remedial
alternative — to excavate all radium-contaminated soil and
transport it to an off-site disposal facility — was recommended
following the initial RI/FS in 1985. He explained that the New
Jersey Department of Environmental Protection (NJDEP) had
initiated a pilot program at twelve properties in Montclair and
Glen Ridge to study the feasibility of excavating and disposing
of radium-contaminated soil.
Mr. Frisco then explained that, after successful remediation at .
four properties in Glen Ridge, and in the middle of excavation of
four Montclair properties, New Jersey's disposal permit was
revoked and the State was left without a disposal facility.
Consequently, NJDEP left drums of containerized soil at a loading
and transfer facility in Kearny, New Jersey and in the yards of
the four Montclair pilot program properties.
The pilot program demonstrated that excavation, removal, and
disposal of radium-contaminated soil was technically feasible.
Although, securing a disposal facility and the transportation
components of the overall remedial action program remain
uncertain factors.
Mr. Frisco further explained that EPA has tried to examine
several feasible alternatives to reduce the volume of soil
requiring excavation while trying to secure a disposal facility.
He then presented the Proposed Plan, which consists of two parts:
(1) excavation of radium-contaminated soils in the most highly
contaminated: properties, followed by transport of the soils to an
off-site disposal facility; and (2) interim actions that will be
implemented at less contaminated properties, to include partial
or "hot spot1* excavation/ engineering controls (e.g., radon
control systems and gamma radiation shielding) and institutional
controls.
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Mr. Frisco then reviewed the criteria for the five categories and
the number of properties within each category in Montclair, as
described below.
Category "I" Properties - Includes 16 core area properties, all
of which have extensive radium contamination throughout the
property, including under and around the house foundation;
elevated levels of gamma radiation; and concentrations of radon
or radon decay products in excess of health guidelines.
Category "II" Properties - Includes 50 properties with basement
wall or outdoor gamma radiation levels equal to or greater than
50 micro-Roentgens per hour and with extensive radium
contamination.
Category "III" Properties - Includes 34 properties with radon,
radon decay product or gamma radiation levels above health
guidelines and with limited, or "hot spot", radium contamination.
Category "IV" Properties - Includes 162 properties with soil
contamination above cleanup standards, but with no radon, radon
decay product or gamma radiation levels above health guidelines.
- • ' \
Category "V" Properties - Includes 104 properties which have no
detectable radium-contaminated soil present in excess of the soil
cleanup standards.
Mr. Frisco ended his presentation with a review of the decision
making process, emphasizing the opportunities for public
involvement throughout this process. Following the above
presentation by EPA, Mr. MuszynsJci opened the meeting to comments
and questions from the public. These comments focused on the
following topics:
• Project Schedule;
• Technical Issues;
PRP Concerns; and
• Administrative Issues.
A summary of comments by topic and EPA responses to these
comments is presented below.
1. Project Schedule
COMMENT: A resident inquired about the four families from the
NJDEP pilot project who have been out of their homes for three
years, and asked to know when they would be back in their homes.
EPA RESPONSE: At this time, EPA does not have a timeline as to
.when these families will be back in their homes. However, EPA
will work with these residents as part of the Category I
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properties, as expeditiously as possible. The Superfund law
requires that before EPA can complete the remediation that NJDEP
"began at these properties, it must complete the public comment
and decision making process. EPA will then have to solicit
competitive bids from contractors to perform the remedial work.
Regretfully, this entire process could and probably will take
many months, perhaps a year. EPA is aware of the disruption that
this has caused these families and will try to resolve this
situation as expeditiously as it can. Furthermore, EPA has
designed the proposed excavation so that this type of situation
will not recur. During excavation at Category I properties under
EPA's Proposed Plan, 1) if a family were temporarily relocated
and the property was partially excavated, and 2) the disposal
facility became unavailable for some reason, EPA would place the
contaminated soil back into the ground and promptly move the
family back into the house until another solution could be found.
EPA recognizes and shares the communities' concern about this
issue. The Agency wants to work with each of the affected
families to design a remediation plan for their property which is
the least disruptive and which ensures that all health guidelines
are met.
COMMENT* A resident expressed concern over how long .the interim
measures would be required.
EPA RESPONSE: EPA will continue to explore remedial technologies
to permanently address the residual contamination. Some of the
technologies that could reduce the volume of contaminated soil
are currently in developmental stages. However, interim measures
would remain in place until a permanent solution could be
identified. EPA is required to re-evaluate interim measures
within five years, and is committed to continuing the search to
find a permanent solution for those properties where interim
measures are proposed.
COMMENT: The mayor asked if EPA would review the time schedule
for making a final decision on the Proposed Plan.
EPA RESPONSE: About midway into the public comment period (which
begins April 4, 1989) a public meeting will be held to receive
questions and comments. This schedule will allow time for the
resident* to become familiar with the Proposed Plan and the draft
Supplemental. FS. In addition, it will allow residents to meet
individually with EPA representatives if they so choose, and
formulate their concerns and questions for the public meeting.
Comments are welcomed both at the public meeting and in writing
throughout the public comment period. At the end of the public
comment period, the comments and EPA's responses will be
summarized into what is known as a Responsiveness Summary (RS).
The EPA Region II Regional Administrator will review and consider
the public comments contained in the RS in making the final
decision. The final decision is documented in a document known
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as the Record of Decision (ROD). The ROD is generally signed
within 30 days after the close of the public comment period. The
"contract process for the design and implementation of the
selected remedial alternative cannot begin until after the ROD is
signed. The contract process normally begins immediately after
the ROD is signed. On April 5, 6, 7, and 8, EPA will conduct
public availability sessions at EPA's office trailers on Oak
Street adjacent to Nishuane Park in Montclair, to listen to
residents concerns and answer questions.
2. Technical Issues
COMMENTt A resident asked if there were any data gaps in
determining the extent of the radium contamination.
EPA RESPONSE: EPA is fairly confident that the RI accurately
established the outline of the contaminated area. Nonetheless,
EPA plans to conduct additional monitoring during the design and
remedial action phase to confirm the extent of radium
contamination.
COMMENT: A resident inquired about interim engineering controls
and institutional controls, asking who will install, monitor,
inspect and pay for them.
EPA RESPONSE: EPA is responsible for the integrity of the
interim engineering controls, which includes inspection and
monitoring. As for the institutional controls, EPA would look to
the community and township to help implement such controls.
COMMENT: The mayor asked which properties would be considered
permanently clean.
EPA RESPONSE: The properties considered permanently clean
correspond to those in Categories I, V, and part of IV; not those
in Categories II and III.
COMMENT: A resident asked if the standards for all homes will be
consistent as to the thickness of soil to control radon flux.
EPA RESPONSE: Up to two feet of soil will be removed and
replaced with clean soil at homes in Category II. Although radon
flux variea depending on contamination, EPA does not believe that
this is a problem outside the house.
COMMENT: A resident asked about how the relocation of residents
during the excavation of the Category I homes would be managed.
EPA RESPONSE: EPA recognizes that there are many complex issues
and details to be resolved to successfully implement the Proposed
Plan. EPA is committed to working with the town and the
residents both individually and collectively, to ensure that the
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remediation process causes as little disruption as possible.
COMMENT! A council member expressed concern about how EPA
intends to address storage and shipping of the contaminated soil
that is excavated.
EPA RESPONSEt EPA does not intend to store the contaminated soil
on the properties nor at any other New Jersey facility but to
continuously remove the soil to a loading facility for rail
transport to a disposal site. EPA hopes that, by using a
continuous shipping process, a loading facility can be made
available — perhaps at Kearny, New Jersey. The absence of a
loading facility is a problem that will need to be addressed
during the design phase. EPA will not excavate additional soil
until a loading facility is identified, and all arrangements for
the disposal of the contaminated soil are in place.
COMMENT: A council member asked if a barrier will be used to
identify where the clean fill ends and the contaminated soil
begins at Category II and III properties.
EPA RESPONSE: A orange woven nylon barrier will be placed under
two feet of clean fill to identify where the clean fill ends arid
where the remaining residual contamination begins.
COMMENT: A council member asked if EPA has experience at sites
where similar remediation technologies have been successful.
EPA RESPONSE: Yes. For example, state-of-the-art engineering
controls similar to what EPA is proposing for some of the
properties have been successfully installed in homes with
naturally occurring radon in Clinton, New Jersey. EPA will
continue to monitor the properties where interim measures are
proposed to ensure that the public health is protected.
COMMENT: A resident asked if EPA will purchase properties within
Categories II, III, and IV for a fair market value.
EPA RESPONSE: At this time EPA has no plans to buy any of the
properties. EPA intends to work with the residents individually,
to design the least disruptive solution for remediating their
property* -
COMMENT*' Air attendee asked what EPA plans to do in terms of
security during the excavation period when residents are out of
their homes.
EPA RESPONSE: At other Superfund sites where security has been a
concern, EPA's construction contractors normally retain security
firms. EPA has set aside funds for site security as part of the
/remediation costs for this project.
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COMMENT: A resident inquired about radon decay products
affecting groundwater in Categories II, III, and IV.
EPA RESPONSES A groundwater study will begin within the next 30
to 60 days to address this issue.
COMMENT: A resident asked how, for properties in Categories II
and III, EPA knows when to stop excavating.
EPA RESPONSE: During the design for each property, the amount of
soil that needs to be excavated, as well as, any engineering
controls and institutional controls, will be determined. This
determination will be documented in an agreement with the
property owner prior to initiating remediation.
3. PRP Concerns
COMMENT: A resident asked if EPA is still pursuing Potentially
Responsible Parties at this site.
EPA RESPONSE: Yes, to the degree that EPA can obtain sufficient
information and documentation that can be used in a court of law.
However, documenting and recreating events that occurred so lorig
ago is very difficult.
4. Administrative Concerns
COMMENT: A resident asked if EPA will provide legal counsel to
all residents.
EPA RESPONSE: EPA will examine if and how if it can provide this
service under its current Superfund authority.
COMMENT: A resident understood that residents will have
restricted properties in Montclair, and asked if property
restrictions will apply to the various homes in each of the
different categories.
EPA RESPONSE: Each property owner will get a letter from EPA
indicating the category in which the property has been placed, or
certifying that a particular property is clean. There are likely
to be som«r- restrict ions on future activities on certain
properties in Categories II, III and IV.
COMMENT: A resident asked if EPA intends to inspect and monitor
the properties during and after the remedial alternative is
implemented.
EPA RESPONSE: EPA does not intend to walk away once the ROD is
signed, but, rather, to be present at the sites on a regular
basis and to monitor the progress of the remediation. In
addition, EPA is responsible for identifying a permanent solution
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for those properties where interim measures are to be
implemented.
COMMENT: An attendee asked what criteria EPA used in its
evaluation process.
EPA RESPONSE: Superfund law and regulations require EPA to use
nine criteria including: protection of human health and the
environment; compliance with legally applicable or relevant and
appropriate requirements; reduction of toxicity, mobility, or
volume of hazardous substances; short term effectiveness of the
remedy; long term effectiveness and permanence of the remedy;
implementability of the remedy; cost of the remedy; community
acceptance; and state acceptance.
COMMENT: A council member asked if EPA will work with the
municipality during the design of the remedial alternative
selected.
EPA RESPONSE: EPA intends to work closely with the municipality
throughout the remedial process. EPA seeks input and support
from the municipality in helping ensure that the remediation is
successful and causes as little disruption as possible. v
COMMENT: A council member stated that the council is concerned
about the public reaction to the proposed program, stating that
the entire experience with the NJDEP pilot project frightened
many community members. In the council's view, a major public
relations campaign needs to be undertaken, and individual
appointments with the affected Category I property owners need to
be set up. In addition, the new administration at EPA in
Washington needs to stand by the decision that is made and not
change priorities: the community needs to be assured that the
priorities concerning this issue will not change.
EPA RESPONSE: It is EPA's intention to work with each property
owner individually. For example, EPA wants to work with each
Category I family whose property requires excavation to find out
the best way to conduct the excavation. EPA does not want to
keep people out of their homes for extended periods of time.
Moreover, the Agency has the same commitment to ensure that the
remediation: is conducted in a manner that is convenient, and
causes as^little disruption as possible to the Category II, III,
and IV property owners. Approximately $53 million has been set
aside to implement the Proposed Plan this year. By law, once the
ROD is signed the only way EPA can deviate from that decision is
to reopen the ROD, an action that would require another public
comment period and the signing of another ROD.
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COMMENT: A council member asked if EPA would consider moving a
Category X home to another site.
EPA RESPONSES EPA is willing to work individually with each
homeowner and is open to discussion on this issue.
COMMENT: One resident stated that, regarding public relations,
the best public relations EPA could do is to complete the
remediation that NJDEP began and get those four displaced
families back in their homes, adding that the community is very
concerned about this issue.
SPA RESPONSES EPA recognizes the considerable disruption the
four pilot project families have endured and empathizes with
them. EPA hopes to resolve their situation as expeditiously as
possible. EPA must, however, go through all required review,
selection, and bidding processes that the law requires.
COMMENT: A resident asked if institutional controls such as deed
restrictions will result in the loss of market value of the
homes.
EPA RESPONSES This is a difficult question to answer, because
depends on complex factors, such as how it would affect the
attractability to a potential buyer.
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APPENDIX A
Montclair/West Orange and Glen Ridge Radium .Sit
Proposed Plan Summary
INTRODUCTION
This summary highlights the plan for remedial action that the
U.S. Environmental Protection Agency (EPA) is proposing for the
Montclair/West Orange and Glen Ridge Radium Superfund sites in
Essex County, New Jersey.
To review the problem, more than 300,000 cubic yards of soil on
public and private properties within portions of the three commu-
nities are contaminated to varying degrees with radium. This is
causing elevated indoor concentrations of radon gas and radon
decay products in some houses, while others additionally exhibit
elevated indoor and/or outdoor gamma radiation levels. Radon gas
and gamma radiation present different types of radiation problems^
and, therefore, require different control techniques.
As noted during a public meeting held in November 1985, excava-
tion of the radium-contaminated material is the Agency's pre-
ferred solution to the problem. However, experience since the
1985 recommendation has shown that it can be very difficult to
locate and assure the continuing availability of a disposal
facility. For that reason, EPA has been developing and evalua-
ting additional alternatives to solve the problem. During this
time, EPA has continued to maintain temporary measures to lower
the exposure in affected homes.
SUPPLEMENTAL FEASIBILITY STUDY
Recognizing that the remediation of the Montclair/West Orange and
Glen Ridge Radium sites through excavation and off-site disposal
of the contaminated material could be extremely difficult, EPA
decided to re-examine and search out additional remedies. EPA
began a supplemental feasibility study in March 1987 to develop
and evaluate^measures to protect public health. The alternatives
considered- iit the supplemental study consist of the following:
o No Additional Action
o Continue Existing Action
o Engineering Controls
o The Park(s) Alternative
o Total Excavation, With Off-site Disposal
o Partial Excavation, With Off-site Disposal
o The Combined Approach
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THE PROPOSED PLAN
EPA is proposing for public discussion a plan for remediation of
the Montclair/West Orange and Glen Ridge Radium sites that would
address the most highly contaminated properties by excavating the
radium-contaminated soil and transporting it to an off-site dis-
posal facility. Additional interim actions would be taken on the
less contaminated properties to further ensure protection of pub-
lic health. The properties within the three study areas would be
grouped into the following categories:
Category "I" Properties — Core area properties which have
extensive radium contamination throughout the property,
including under and around the house foundation, have elevated
levels of gamma radiation, and have concentrations of radon or
radon decay products in excess of health guidelines. The 231
category "I" properties would be fully excavated to achieve
soil cleanup standards and restored with clean soil.
Category "11" Properties — Properties with basement wall or
outdoor gamma radiation levels equal to or greater than 50
microRoentgens per hour and with extensive radium contamina-\
tion, but not under the house foundation. Interim remediation
of the 75 category "11" properties would consist primarily of
engineering controls to reduce exposures to radon gas and
decay products, gamma radiation, and radium-contaminated soil.
The engineering controls may include the installation of
state-of-the-art radon control systems, lead shielding for
gamma radiation, and the covering of contaminated soil with
topsoil and sod. These activities would occur simultaneously
with the remediation of the category "I" properties. It is
anticipated that a limited amount of radium-contaminated soil
will need to be removed from the category "II" properties to
facilitate the installation of the engineering controls.
Because contaminated soil would remain beneath these proper-
ties, institutional controls (e.g., municipal or county health
ordinances) would be required.
Category "III" Properties — Properties with radon, radon
decay product and/or gamma radiation levels above, health
guidelines, and with limited, or "hot spot", contamination.
The 65 category "III" properties would receive engineering and
institutional controls. In some cases, small amounts of soil
may be removed.
Includes four properties that are partially excavated as
part of the New Jersey Department of Environmental Protec-
tion's pilot excavation program.
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Category "IV" Properties — Properties with soil contamination
above cleanup standards, but with no radon, radon decay
product or gamma radiation levels above health guidelines.
The approximately 286 category "IV" properties would receive
additional monitoring and institutional controls.
"V" Properties— Properties which exhibit no radium-contami-
nated soil in excess of soil cleanup standards. The approxi-
mately 298 category "V" properties would need no further study
or remedial action.
Public Areas and Streets — Areas not privately owned which
have some degree of radium-contaminated soil present would
require institutional controls.
It is estimated that approximately 50,000 cubic yards of radium-
contaminated soil would be excavated during this remedial action.
The cost of the proposed remedial action has been estimated to be
$53 million. EPA is aware that implementation of the plan pro-
posed above would be disruptive to individual homeowners and the
community as a whole. EPA intends to fully consult with the
affected residents and the community regarding a safe and expediW
tious implementation of the above proposal. ' :
OTHER ACTIVITIES
EPA has been studying and experimenting with various "treatment"
technologies in an attempt to identify methods which might fur-
ther reduce the volume of soil requiring off-site disposal.
These experiments, which involve the use of physical separation
and chemical extraction techniques, will continue. EPA will con-
tinue to evaluate the more promising methods to determine their
potential usefulness for further remediation of the remaining
properties.
Additionally, EPA is initiating a study of the groundwater at the
sites. The intent of the study will be to determine the extent
of any contamination due to the tainted soil and to evaluate
mitigation alternatives.
SUMMARY
In brief, this Proposed Plan reconfirms EPA's 1985 finding that
the preferred solution for the radium sites is to excavate the
contaminated^ soil, dispose of it in an accredited disposal facil-
ity, and restore the affected properties with clean soil. How-
ever, because of the need for continued study of treatment tech-
nologies, and the difficulty in assuring the continuing availa-
bility of a disposal site, EPA is proposing a phased program of
remedial action. This proposed remedial action, identified as
t^ie "Combined Approach", will involve the excavation of the most
Contaminated properties, and, for the less contaminated proper-
ties, the installation of engineering controls and the establish-
ment of institutional controls. The proposed remedy would be
protective of public health.
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Implementing this remedy would give EPA valuable experience with
excavation techniques and experience in working out details with
residents and community leaders on restoring properties. To car-
ry out the additional work needed to reach a permanent cleanup,
EPA and the New Jersey Department of Environmental Protection
would continue to explore the availability of additional disposal
capacity and would also explore alternative technical solutions
•for the remaining contamination.
Any additional remedial action which may be taken at the sites
would be the subject of a future Record of Decision.
Printed on Recycled Paper
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GLEN RIDGE TOWN COUNCIL MEETING
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
-------
PUBLIC INFORMATION MEETING SUMMARY
MONTCIAIR/WEST ORANGE AND GLEN RIOGE RADIUM SITES
BOROUGH OF GLEN RIDGE, ESSEX COUNTY, NEW JERSEY
On April 3, 1989 at 7:30 p.m., the U.S. Environmental Protection
Agency (EPA) attended a special Glen Ridge Town Council meeting
at the invitation of Mayor Edward Callahan. The meeting was held
to discuss the Montclair/West Orange and Glen Ridge Radium sites
located in Essex County, New Jersey. EPA's purpose in attending
the meeting was to inform local officials and residents that EPA
had completed the draft Supplemental Feasibility Study (FS) for
the Montclair/West Orange and Glen Ridge Radium sites and to
explain EPA's Proposed Plan for remediation of the sites. The
presentation included a brief review of the draft Supplemental FS
report prepared for the sites and an introduction to the Proposed
Plan. In addition, EPA responded to questions from interested
local officials and citizens. Attached to this meeting summary
as Appendix A, is a fact sheet that was distributed at the
meeting. Approximately three people attended the public meeting.
EPA Region II representatives included: Stephen Luftig, Director,
Emergency and Remedial Response Division; and Raimo Liias,
Remedial Project Manager, Northern New Jersey Remedial Action
Section; and Cecelia Echols, Community Relations Specialist,
Office of External Programs. EPA contractor personnel included
Peter Mavraganis, REM II Community Relations Specialist, and
Peter Tunnicliffe, REM II Regional Manager.
The public meeting began with Glen Ridge Mayor Edward Callahan's
introduction of Mr. Luftig, Director, Emergency and Remedial
Response Division, Region II EPA. Mr. Luftig explained that EPA
has been grappling with the difficult problem of disposal of the
contaminated soil since the initial Montclair/West Orange and
Glen Ridge Remedial Investigation and Feasibility Study (RI/FS)
report was released in 1985. He went on to explain that
additional sampling and evaluation of remedial alternatives has
been conducted and EPA is now asking the public to comment on the
Proposed Plan.
Mr. Luftig invited local officials, affected residents, and
interested citizens to actively participate in the decision
making process for the sites. To encourage public participation
in the decision making process, he noted that copies of the
Proposed Plan and draft Supplemental FS report were being placed
in the library and Town Hall for public review. Additionally, he
stated that EPA would be mailing the Proposed Plan to all
affected residents on or about April 5, 1989. Included in the
mailing would be a stamped, addressed postcard that would allow
interested residents to request Volume 1 of the draft
Supplemental FS report.
-------
Mr. Luftig then outlined the public participation process for
this phase of the project, noting that a public comment period on
the Proposed Plan would be held from April 4 to June 2, 1989. He
also explained, that in addition to the Town Council meeting, EPA
staff will be available to meet with residents on an individual
basis on April 5-7, 1989 from 2:00 p.m. until 7:00 p.m., and on
Saturday, April 8 from 10:00 a.m. to 3:00 p.m. at EPA's office
trailers on Oak Street, adjacent to Nishuane Park in Montclair.
He further explained that a public meeting and additional public
availability sessions would be held in mid-May.
Fact sheets were then distributed to all in attendance which
provided a summary of the Proposed Plan. Following his overview,
Mr. Luftig introduced Raimo Liias, Remedial Project Manager,
Northern New Jersey Remedial Action Branch, who gave a
presentation.
Mr. Liias presented the history of the Montclair/West Orange and
Glen Ridge sites and explained that EPA's preferred remedial
alternative — to excavate all radium-contaminated soil and
transport it to an off-site disposal facility — was recommended
following the initial RI/FS in 1985. He explained that the New
Jersey Department of Environmental Protection (NJDEP) had \
initiated a pilot program at twelve properties in Montclair and
Glen Ridge to study the feasibility of excavating and disposing
of radium-contaminated soil.
Mr. Liias then explained that, after successful remediation at
four properties in Glen Ridge, and in the middle of excavation of
four Montclair properties, New Jersey's disposal permit was
revoked and the State was left without a disposal facility.
Consequently, NJDEP left drums of containerized soil at a loading
and transfer facility in Kearny, New Jersey and in the yards of
the four Montclair pilot project properties.
The pilot program demonstrated that excavation, removal, and
disposal of radium-contaminated soil was technically feasible.
Although, securing a disposal facility and the transportation
components of the overall remedial action program remain
uncertain factors.
Mr. Liias further explained that EPA has tried to examine several
feasible alternatives to reduce the volume of soil requiring
excavation-While trying to secure a disposal facility. He then
presented the Proposed Plan, which consists of two parts: (1)
excavation of radium-contaminated soils in the most highly
contaminated properties, followed by transport of the soils to an
off-site disposal facility; and (2) interim actions that will be
implemented at less contaminated properties, to include partial
or "hot spot* excavation, engineering controls (e.g., radon
.control systems and gamma radiation shielding) and institutional
controls.
-------
Mr. Liias then reviewed the criteria for the five categories and
the number of properties within each category in Glen Ridge, as
described below.
Category "I" Properties - Includes 5 core area properties, all of
which have extensive radium contamination throughout the
property, including under and around the house foundation;
elevated levels of gamma radiation; and concentrations of radon
or radon decay products in excess of health guidelines.
Category "11" Properties - Includes 21 properties with basement
wall or outdoor gamma radiation levels equal to or greater than
50 micro-Roentgens per hour and with extensive radium
contamination.
Category "III1* Properties - Includes 23 properties with radon,
radon decay product or gamma radiation levels above health
guidelines and with limited, or "hot spot11, radium contamination.
Category "IV" Properties - Includes 96 properties with soil
contamination above cleanup standards, but with no radon/ radon
decay product or gamma radiation levels above health guidelines.
: • V •
Category "V" Properties - Includes 161 properties which have no
detectable radium-contaminated soil present in excess of the soil
cleanup standards.
Liias ended his presentation with a review of the decision
iking process, emphasizing the opportunities for public
involvement throughout this process. Following the above
presentation by EPA, comments and questions from the public were
invited. However, the town council decided to adjourn the
meeting early and indicated that they would submit a list of
comments and questions at a later date.
-3-
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WEST ORANGE TOWN COUNCIL MEETING
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
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PUBLIC INFORMATION MEETING SUMMARY
MONTCLAIR/WEST ORANG3 AND GLEN RIDGE RADIUM SITES
TOWN 07 WEST ORANGE, ESSEX COUNTY, NEW JERSEY
On April 3, 1989 at 7:00 p.m., the U.S. Environmental Protection
Agency (EPA) attended a special West Orange Town Council meeting
at the invitation of Mayor Samuel Spina. The meeting was held to
discuss the Montclair/West Orange.and Glen Ridge Radium sites
located in Essex County, New Jersey. EPA's purpose in attending
the meeting was to inform local officials and residents that EPA
had completed the draft Supplemental Feasibility Study (FS) for
the Montclair/West Orange and Glen Ridge Radium sites and to
explain EPA's Proposed Plan for the sites. The presentation
included a brief review of the draft Supplemental FS prepared for
the sites and an introduction to the Proposed Plan. In addition,
EPA responded to questions from interested local officials and
citizens. Attached to this meeting summary as Appendix A, is a
fact sheet that was distributed at the meeting. Approximately
eight people attended the public meeting.
EPA Region II representatives included: James Marshall, EPA
Acting Deputy Regional Administrator; Ronald Borsellino, Branch
Chief, New Jersey Remedial Action Branch; and William Baker, \
Acting Director, Office of External Programs. Carl Zoephel, REM
II Community Relations Specialist represented EPA's Region II's
contractor.
The public meeting began with West Orange Mayor Samuel Spina's
introduction of James Marshall, Acting Deputy Regional
Administrator of EPA Region II. Mr. Marshall explained that EPA
has been grappling with the difficult problem of disposal of the
contaminated soil since the initial Montclair/West Orange and
Glen Ridge Remedial Investigation and Feasibility Study (RI/FS)
was released in 1985. He went on to explain that additional
sampling and evaluation of remedial alternatives has been
conducted and EPA is now asking the public to comment on the
Proposed Plan.
Mr. Marshall invited local officials, affected residents, and
interested citizens to actively participate in the decision
making process for the sites. To encourage public participation
in the decision making process, he noted that copies of the
Proposed Plait, and draft Supplemental FS report were being placed
in the library and Town Hall for public review. Additionally, he
stated that EPA would be mailing the Proposed Plan to all
affected residents on or about April 5, 1989. Included in the
mailing would be a stamped, addressed postcard that would allow
.interested residents to request Volume 1 of the draft
Supplemental FS report.
Mr. Marshall then outlined the public participation process for
this phase of the project, noting that a public comment period on
the Proposed Plan would be held from April 4 to June 2, 1989. He
also explained that, in addition to the Town Council meeting, EPA
-------
staff will be available to meet with residents on an individual
basis on April 5-7, 1989, from 2:00 p.m. until 7:00 p.m., and on
Saturday, April 8 from 10:00 a.m. to 3:00 p.m. at EPA's office
trailers on Oak Street, adjacent to Nishuana Park in Montclair.
He further explained that a public meeting and additional public
availability sessions would be held in mid-May.
Fact sheets were then distributed to all in attendance which
provided a summary of the Proposed Plan. Following his overview,
Mr. Marshall introduced Ronald Borsellino, Chief, New Jersey
Remedial Action Branch, Region II EPA, who gave a presentation.
Mr. Borsellino presented the history of the Montclair/West Orange
and Glen Ridge sites and explained that EPA's preferred remedial
alternative — to excavate all radium-contaminated soil and
transport it to an off-site disposal facility — was recommended
following the initial RI/FS in 1985. He explained that the New
Jersey Department of Environmental Protection (NJDEP) had
initiated a pilot program at twelve properties in Montclair and
Glen Ridge to study the feasibility of excavating and disposing
of radium-contaminated soil.
Mr. Borsellino then explained that, after successful remediation^
at four properties in Glen Ridge, and in the middle of excavation
of four Montclair properties, New Jersey's disposal permit was
revoked and the State was left without a disposal facility.
Consequently, NJOEP left the drums of containerized soil at a
loading and transfer facility in Kearny, New Jersey and in the
yards of the four Montclair pilot program properties.
The pilot program demonstrated that excavation, removal, and
disposal of radium-contaminated soil was technically feasible.
However, the feasibility of transportation and disposal remain
uncertain factors in the overall remedial action program.
Mr. Borsellino further explained that EPA has tried to examine
several feasible alternatives to reduce the volume of soil
requiring excavation while trying to secure a disposal facility.
He then presented the Proposed Plan, which consists of two parts:
(1) excavation of radium-contaminated soils in the most highly
contaminated properties, followed by transport of the soils to an
off-site disposal facility; and (2) interim actions that will be
implemented at less contaminated properties, to include partial
or "hot spot* excavation, engineering controls (e.g., radon
control systems and gamma radiation shielding) and institutional
controls.
Mr. Borsellino then reviewed the criteria for the five categories
and the number of properties within each category in West Orange,
as .described below.
-2-
-------
Category "I" Properties - Includes 2 core area properties, both
of which have extensive radium contamination throughout the
property, including under and around the house foundation;
elevated levels of gamma radiation, and concentrations of radon
or radon decay products in excess of health guidelines.
Category "II1* Properties - Includes 4 properties with basement
wall or outdoor gamma radiation levels equal to or greater than
50 micro-Roentgens per hour and with extensive radium
contamination.
Category "III" Properties - Includes 8 properties with radon,
radon decay product or gamma radiation levels above health
guidelines and with limited, or "hot spot", radium contamination.
Category TV" Properties - Includes 28 properties with soil
contamination above cleanup standards, but with no radon, radon
decay product or gamma radiation levels above health guidelines.
Category "V" Properties - Includes 33 properties which have no
detectable radium-contaminated soil present in excess of the soil
cleanup standards.
\
Mr. Borsellino ended his presentation with a review of the
decision making process, emphasizing the opportunities for public
involvement throughout this process. Following the presentation
by EPA, Mr. Marshall opened the meeting to comments and questions
from the public. These comments focused on the following topics:
Project Schedule;
Technical Issues;
Health Concerns;
Administrative Issues; and
Financial Concerns.
A summary of comments and EPA responses to these comments is
presented below.
1* Pro'i ect Schedule
COMMENT: A resident asked about the length of time required to
excavate and remediate a property.
EPA RZSPOH83S Excavation and remediation for each property will
take approximately four months, depending on the nature and
extent of the contamination.
COMMENTt A resident asked when remedial work would start.
-3-
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EPA RESPONSE: Design work will begin following the 60-day
comment period after the Record of Decision (ROD) has been
signed, possibly in September. Engineering controls could start
fairly soon thereafter/ although excavation will be later.
2. Technical Concerns
COMMENT: An attendee asked what EPA is going to do with the
excavated soil.
EPA RESPONSE: The soil will be shipped off-site. EPA has
already ascertained that there is a Utah facility which can take
the material; there is also the possibility that other licensed
facilities may be available to take it.
COMMENT: A resident asked if the cutback on the amount of soil
being excavated is being made because of the difficulty with
disposal?
EPA RESPONSE: There is a certain amount of caution regarding the
securing of a disposal facility because of the previous problems
with the NJDEP pilot project. In addition, EPA does not want to
remove people from their homes for any longer than is necessary.
Cost is also a- factor.
COMMENT: A council member asked what institutional controls
would have to be implemented at the site in order to fulfill the
requirements of EPA's proposed alternative.
EPA RESPONSE: It will be up to each town council to develop,
implement, and enforce local institutional controls. EPA will
work closely with each town to address this issue.
COMMENT: A council member asked if the town department of public
works would be able to perform normal excavation activities on
town streets and sidewalks.
EPA RESPONSE: EPA will assist the town in developing proper
protocols for monitoring and handling materials excavated during
maintenance operations conducted on public streets and sidewalks.
EPA would be able to provide some financial assistance to defray
premiums required for proper off-site disposal of radium-
contaminated soils excavated from public areas within the study
areas.
COMMENT: A resident asked if EPA is using both radon and gamma
levels to determine the categories into which homes are placed.
EPA RESPONSE: Yes.
COMMENT: Regarding a house that contains indoor gamma radiation,
but no outdoor radiation, one resident asked if that means the
. '. ' ' -4-
-------
contamination is underneath the house?
-EPA RESPONSE: Probably. All houses being remediated will be re-
tested to confirm the results that EPA has obtained in previous
analyses.
COMMENT: The Health Officer asked how long it will take to
remediate the Category I properties.
EPA RESPONSE: Category I homes may take four years to remediate,
although EPA hopes to perform the work at properties in several
categories concurrently.
3. Health Concerns
COMMENT: A council member asked if any epidemiological studies
have been conducted.
TOWN HEALTH OFFICER RESPONSE: A study was started. However,
the study was inconclusive because several people had left the
area.
4. Administrative Concerns \
MMMMB^^HH^MM*«^MMMM^M^B^^«M^M*MMMMA^MA**ta . ,_
COMMENT: A resident indicated that people are not going to want
to leave their homes knowing what's happened in NJDEP's pilot
project.
EPA RESPONSE: EPA is sensitive to the community's concerns on
this issue and has tried to design the Proposed Plan to avoid
this type of situation from reoccurring. Unless there is a
disposal site available, EPA will not begin to relocate residents
and excavate their properties.
COMMENT: A resident asked who owns the disposal site.
EPA RESPONSE: It is privately owned and managed under both
federal and State of Utah regulations and supervision.
COMMENT: The mayor indicated that a woman at the meeting has a
house that will require full remediation. Can EPA explain what
will happen, in this case?
EPA RESPOH8B* The resident, will have to relocate while the
remedial process takes place. EPA is looking at options to
relocate residents in hotels, or perhaps, other houses. EPA will
work with the residents individually and collectively, as well as
with the local officials, to design how the excavation should be
conducted, so as to disrupt the property owners as little as
possible. The U.S. Department of Energy (DOE) has performed a
^number of successful temporary relocations during remediation
''projects that required excavations.
-5-
-------
COMMENT: A resident asked what would happen to elderly people
during the excavation.
EPA RESPONSE: EPA will work with each property owner
individually to design a remediation effort that is the most
convenient and least disruptive for that property owner, while
ensuring that public health is protected.
COMMENT: A resident asked how remediation will be handled.
EPA RESPONSE: The remediation will be designed on a house-by-
house, property-by-property basis.
COMMENT: A resident mentioned that most people are frightened by
the relocation. The NJDEP's pilot project at the homes on
Franklin Avenue was a "disaster".
EPA RESPONSE: EPA has designed the excavation component of the
Proposed Plan to avoid a reoccurrence of the difficult situation
that affects the residents who were part of the NJDEP pilot
project. If for any reason, there is a problem with the off-site
disposal facility, the property will be backfilled and the
families promptly moved back into their homes.
COMMENT: The Health Officer asked who will notify residents as
to the category into which their homes fall.
EPA RESPONSE: EPA will notify each resident within the study
area individually by letter as to the category of cleanup for
their property. All Category I property owners will also be
telephoned by EPA to give them the information directly.
COMMENT: A real estate agent asked if the categories will be
public knowledge.
BPA RESPONSE: EPA will not share specific information about
individual properties. However, the information contained within
the draft Supplemental FS report is public knowledge.
COMMENT: A council member asked what happened to the four
families who were part of the NJDEP pilot project in Montclair. ••
3PA RESPONSE* Unfortunately, NJDEP has not been able to complete
the remediation at these properties, and these residents are
still out: of their houses. As part of the Proposed Plan, EPA
rfould take over responsibility for finishing the remediation at
the NJDEP pilot program properties. EPA hopes to finish the
remediation efforts at these properties expeditiously.
-6-
-------
COMMENT: A question was raised concerning the security of houses
possessions during the period when Category I residents are
EPA RESPONSE: EPA has included funds for site security during
the excavation and remediation period when residents will be out
of their homes. In addition, EPA's construction contractors
typically retain a security firm as part of their contract, to
provide security for the site during the remedial action.
COMMENT: A resident asked if there is any way that funds would
be available especially for the elderly, to buy another house,
and suggested that EPA could sell the remediated houses at a
later date.
EPA RESPONSE: At this time EPA has no plans to buy any
properties, but is willing to talk individually with each
property owner about what is the best option, given their
particular situation.
COMMENT: The Health Officer asked if there will be any public
meetings to discuss how homeowners would be treated, or whether
this type of communication will be done on an individual basis :\
EPA RESPONSE: During the public comment period ~ which begins
on April 4 and runs until June 2, 1989 — EPA will be considering
comments received on the Proposed Plan. EPA also will hold a
public meeting, probably in mid-May, to discuss the
Proposed Plan. Depending on the response received and the needs
of the community, EPA would be happy to hold other meetings to
work out the details of how the remediation should be conducted.
COMMENT: The mayor asked if it would be easier for EPA to buy a
house at the fair market value, remediate it, and then sell it,
noting there are only two Category I properties in West Orange.
EPA RESPONSE: EPA is willing to explore all options to make
things easier for residents. EPA has certain legal constraints
within which it has to work, but is willing to talk with the
affected residents, concerned citizens, and local officials to
facilitate this effort.
COMMENT: A resident asked how EPA is going to respond to people
whose houses- are not going to be permanently remediated.
EPA RESPONSE: Every house with a radon or gamma radiation level
above health guidelines will be remediated to be within
protective health levels. Properties where interim measures are
implemented will be monitored and re-evaluated as additional
permanent solutions are identified.
-7-
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COMMENT: The mayor indicated that since there are more than two
houses in West Orange with ventilation systems, could the number
of Category I house increase.
EPA RESPONSE: It takes more than the .02 WL to be a Category I
house. Some houses may switch categories, but EPA does not
expect to identify any more Category I houses.
COMMENT: A real estate agent asked who the "unfortunate" people
are to which EPA referred earlier.
EPA RESPONSES The comment referred to the four Montclair pilot
project property owners, whose houses were evacuated by NJDEP.
COMMENT: The mayor asked who has jurisdiction in the remedial
action process.
EPA RESPONSE: EPA has the lead at the sites, although it is
working closely with the State. NJDEP had the lead on the pilot
project, but EPA always has had the overall lead. Under EPA's
Proposed Plan, the remediation that was begun by NJDEP at the \
pilot project homes would be completed by EPA.
COMMENT: A council member asked whether, at the point that a
Category II is remediated, EPA will certify that the house is
safe.
EPA RESPONSE: EPA will not certify homes, but will issue
documentation that engineering controls have been implemented and
that any residual contamination is below health guidelines.
COMMENT: A council member asked whether, if EPA were a private
individual, it would recommend moving into one of the remediated
Category II or III properties.
EPA RESPONSE: EPA is confident that the proposed remediation
plan will be successful. The same engineering controls have been
successfully implemented in homes with naturally occurring radon
in Clinton, New Jersey.
5. Financial Concerns
COMMENTr A real estate agent asked if homes not being remediated
will be affected by soil removal on adjoining properties.
EPA RESPONSE: EPA recognizes that contamination of adjoining
properties could occur and, if it does, EPA will handle any such
instances on a case-by-case basis.
• •
-8-
-------
APPENDIX C
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
JACOB K. JAVITS FEDERAL BULDINQ
NEW YORK. NEW YORK 10278
AGENDA
Public Meeting
Montelair/West Orange/Glen Ridge Radium Sites
Nishuane Elementary School
Montclair, New Jersey
Mav 18. 1989
7:30 P.M.
I. Opening Remarks
II. Technical Presentation
William Muszynski
Acting Regional Administrator
U.S. EPA, Region II \
John Frisco
Associate Director for Remedial
Action Programs
U.S. EPA, Region II
III. Questions and Answers
IV. Closing
Other EPA Participants
Steve Luftig, Director
Emergency and Remedial
Response Division
Robert McKnight, Chief
Northern New Jersey
Remedial Action Section
Ron Borsellino, Chief
New Jersey Remedial
Ac tioj* Branch
Raimo Liias, Remedial
Project Manager
-------
Momclair/West Orange and Glen Ridge Radium Sites
Sign In Sheet
Name
/7-
Address
Affiliation
Phon*
27 /
«=
30.
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Montclair/West Orange and Glen Ridge Radium Site
Name
Sign In Sheet
Address
Affiliation
Phoi
12
13
14
15
18.
19.
20.
21-
22.
23.
24-
25-
26.
27 L
28_i-_
29.
30.
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APPENDIX D
-------
The United States Environmental Protection Agenc
Announces
Proposed Cleanup Alternatives
for the
Montdair/West Orange and Glen Ridge Radium Siti
Essex County, New Jersey
The U.S. EnviranfiMntd Protection Agency (EPA) recently completed a Supp
mental FeaiibilHy Study that evaluated alternative* for the remediation
the Montdair/Weit Orange and den Ridge Radium »He» in Essex Coun
New Jersey. Based on this study, EPA has propoied its preferred altemati
for remedial action at these two sites.
EPA will hold an informational public meeting on Thursday, May 18, 1989
7:30 pm in the auditorium of the Nishuone School, located at the comer
Cedar Avenue and High Street in Montdair, New Jersey. EPA will discuss t
Supplemental Feasibility Study and the Proposed Plan for remedial actk
EPA will atse hold pubfic availability sessions on Friday, May 19, from 1:
to 7:30 pjn., and Saturday, May 20, from 10:00 cun. to 3:00 pun., at t
EPA trailer compound heated in Nishuane Park at the end of Oak Street
Montdair. These session* wiH provide uffeUed residents, property owne
J other Interested parties and officials on opportunity to discuss the imp»
of the proposed plan en an individual basis
The Supplemental Feasibility Study evaluated seven alternatives for c
dressing the cleanup of the Montdair/West Orange and Glen Ridge stt.
These weret
1) NO ADDITIONAL ACTION*
2) CONTINUE EXISTING ACTION;
3) ENGINEERING CONTROLS;
4) PA1K(S) ALTERNATIVE;
3) TOTAL EXCAVATION, WITH OFF-SITI DISPOSAL;
6) PARTIAL EXCAVATION, WITH OFF-SITE DISPOSAL;
7) COMBINED APPROACH.
EPA'S preferred alternative is number seven (7). This alternative invoK
complete excavation and remediation of the meet seriously confaminat
properties, provides for partial excavation and/or engineering controls for
other properties where contaminated soil exceeds the Health guidelines, a.
allows for additional monitoring for properties with any soil contominot
*lk^M^A esV^ ««W^^BM^A •4aBjoBMeUo*MeW
QDQV9J fltw CWamip STQnOQrBV*
The Supplemental Feasibility Study report, the Proposed Plan, and other »
its are available for review at the following locations:
Office of the) Mayer and th« Mentdair Task Pore*
Montdair Municipal Building
MS darement Avenue
Mentdair, New Jersey 07041
Office ef the Mayer and the West Orange Task Farce
Munldpol Building
66 Main Street
West Orange, New Jersey 07032
Office or tttt Moyoi*
823 Bleamrleld Avenue
Oten Ridge, New Jersey O702S
den Ridge Public Library
Bleetnflela. Avenue
Glen Ridge, New Jersey 07028
Montdair Public Library
SO South Fullerton Avenue
Mentdair, New Jersey 07042
Written comments on the Proposed Plan should be sent to;
Raima Ulas
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
-------
THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
ANNOUNCES
AN EXTENSION OF THE PUBLIC COMMENT PERIOD
OF THE
PROPOSED CLEANUP ALTERNATIVES
FOR THE
MONTCLAIR/WEST ORANGE AND
GLEN RIDGE RADIUM SITES
ESSEX COUNTY, NEW JERSEY
The U.S. Environmental Protection Agency (EPA) recently completed a Supi
plemental Feasfeility Study that evaluated alternatives for the remediation of
the Montdair/West Orange and Glen Ridge Radium Sites in Esse^ County;
New Jersey. Based on this study EPA has proposed its preferred alternative
for remedy action at these two sites. This is a notification that the EPA has
extended the public comment period which began on April 4, to June 9,
1989.
The Supplemental Feasibility Study report, the Proposed Plan, and other,
related documents are available for review at the following locations:
Office of the Mayor and the Montdair Task Force
Montaair Municipal Building
205 Garemont Avenue
Montdair, New Jersey 07042
Office of the Mayor and the West Orange Task Force
Municipal Building
66 Main Street
West Orange, New Jersey 07052
Office of the Mayor
825 Bloomfield Avenue
Glen Ridge, New Jersey 07028
Glen Ridge Public Library
Bloomfield Avenue
Glen Ridge, New Jersey 07028
Montdair Public Library
50 South Fullerton Avenue
Montdair, New Jersey 07042
Written comments on the Proposed Plan should be sent to:
RaimoUias
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
New York, New York 10278
Comments submitted to the above address should
be postmarked before June 9,1989.
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TO:- Ms. Mary Lou Cass
FROM: U.S. EPA, Region II
DATE: June 26, 1989
RE: Administrative Records for the Montelair/West Orancre
& Glen Ridae Radium Sites
Please find enclosed the official Administrative Record for
the Montclair/West Orange Radium Site as compiled by the
U.S. Environmental Protection Agency, Region II. Additiona^.
documents to be added to the Administrative Record will
follow shortly.
An index to the Administrative Record will also follow
shortly. The index, which inventories all of the documents
contained within the Administrative Record, will be a useful
guide in locating documents and should be kept with the
Administrative Record.
cc: Raimo Liias (U.S. EPA Region II)
Jennie Delcimento (U.S. EPA Region II)
Bob Goltz (COM FPC)
Lee Bishop (TechLaw, Inc.)
-------
To: Raimo Liias - U.^. EPA, Region II
From: Peter M. Price
Date: June 27, 1989
Re: Administrative Records for Montclair/West Orange & Glen Ridge
Radium Sites
Attached please find copies of the memos which were forwarded
with the first parts of the Administrative Records to their
respective site repositories. Three boxes comprised of documents
numbered MGL 001 0001 through MGL 005 0877 were sent out by way of
Federal Express overnight delivery on June 26, 1989, to the
following addresses:
Montclair Public Library
50 South Fullerton Avenue
Montclair, New Jersey 07042
(201) 744-0502
attn: Ms. Mary Lou Cass
Glen Ridge Library
Ridgewood Avenue
Glen Ridge, New Jersey 07028
(201) 748-5482
attn: Mrs. Jean Loos
The remaining parts of the Administrative Records, documents
numbered MGL 005 0878 through MGL 007 0576, are expected to be sent
out, also by way of Federal Express, on June 27, 1989.
• • 4
If you have any questions or comments please feel free to call
me at (212) 393-9634.
Attachments-
PMP/ny
cc: Jennie Delcimento - U.S. EPA, Region II
/ Bob Goltz - COM FPC
/ Lee Bishop - TechLaw, Chantilly
TECHLAW INC.
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