United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R02-90/126
June 1990
oEPA
Superfund
Record of Decision
Montclair/West Orange
Radium, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/126
3. Recipient'* Acceulon No.
F Title and Subtitle
SUPERFUND RECORD OF DECISION
Montclair/West'Orange Radium, NJ
Second Remedial Action - Final
5. Report Date
06/01/90
7. Author(i)
8. Performing Organization Rept. No.
t. Performing Organization Name and Addreaa
10. Proiect/Taek/WorkUnitNo.
11. ContractfC) or Grant(G) No.
(C)
12. Sponsoring Organization Name and Addrea*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notea
16. Abalract (limit: 200 worda)
The 120-acre Montclair/West Orange Radium site is comprised of 239 residential
properties in the Town of Montclair and 127 residential properties in the Town of West
Orange, Essex County, NJ. The site is located in proximity to the Glen Ridge Radium
Superfund site. In the early 1900s, a radium processing or utilization facility was
^located near the site. It is suspected that radioactive waste material from the
Wfacility was disposed of in then rural areas within the community. Some of the
radioactively-contaminated soil is believed to have been moved from the original
disposal location, used as fill materials in low-lying areas, or mixed with Portland
cement to make concrete sidewalks or foundations. Subsequently, houses were constructed
on or near the radium waste disposal areas. EPA investigations in 1981 and 1983,
confirmed the presence of gamma radiation contamination in the Glen Ridge area and in
several adjacent houses. Subsequently, EPA established an air quality monitoring
program to determine the levels of radon decay products in the contaminated houses. In
1984, EPA initiated a remedial investigation/feasibility study to determine the nature
and extent of the problem and develop remedial alternatives for the site. Also in 1984,
(See Attached Page)
17. Document Analyeia a. Descriptor*
Record of Decision - Montclair/West Orange Radium, NJ
Second Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: radioactive materials
b. Mentifiera/Open-Ended Term*
(radium"266),
metals (lead)
c. COSAT1 Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Claa* (Thi* Page)
None
21. No. ofPagea
58
C2. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/126
Montclair/West Orange Radium, NJ
Second Remedial Action - Final
Abstract (Continued)
the Agency installed and maintained temporary radon ventilation systems, and gamma
radiation shielding in twenty residences. In 1985, the State implemented the pilot
study, which included excavating and disposing, of contaminated soil offsite from 12 Glen
Ridge site properties and several properties in Montclair. A 1989 Record of Decision
(ROD) addressed partial excavation and offsite disposal of contaminated soil from a
number of residences as the selected remedial action. This ROD also addresses
contaminated onsite soil, and is a final source control remedy. A separate ground water
study has been initiated, and will be addressed in a subsequent ROD, if necessary. The
primary contaminants of concern affecting the soil are radioactive materials, especially
radium~266; ancj metals including lead.
The selected remedial action for this site includes excavating 323,000 cubic yards of
contaminated soil (including Glen Ridge Radium site soil, which will be remediated
concurrently) and disposing of the soil offsite; restoring the excavated areas; and
conducting environmental monitoring. The estimated present worth cost for this remedial
action ranges from $252,700,000 to $348,700,000 for the Montclair/West Orange and Glen
Ridge Radium sites combined. No O&M costs are associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS: All material contaminated with concentrations of radon
greater than 5.0 pCi/g of soil in the first 6 inches, and 15 pCi/g in subsurface soil
will be excavated and removed offsite.
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DECLARATION STATEMENT
RECORD OF DECISION
Montclair/West Orange Radium Site
Bite w«m» and Location
Montclair/West Orange Radium Site, Essex County, New Jersey
Statoaept of Baa|p a,nd Purpose
This decision document presents the selected remedial action for
the Nontclair/West Orange 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 State of New Jersey concurs with the selected remedy.
Assessment of the Site
Actual or threatened exposures to hazardous substances released
from the residential and public 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 remedy presented in this document complements the remedial
actions described in the previous Record of Decision for this
site and the nearby Glen Ridge Radium site. It provides for the
cleanup of the remaining residential and public properties
contaminated with radiological materials. Together with the
previous actions which address primarily the most extensively
contaminated properties, the selected remedy provides a permanent
solution for all affected properties in the communities.
The selected remedy includes the following components:
Excavation of all radium-contaminated materials exceeding
cleanup criteria from residential and public properties;
Transportation of the excavated materials to an appropriate
off-site facility for disposal;
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-2-
Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
Continuation of treatment technology studies which nay
reduce the volume of radium-contaminated materials for
off-site disposal.
Declarations
The selected remedy is protective of human health and the
environment and is cost effective. Zt attains Federal and State
requirements that are applicable or relevant and appropriate for
the site. The remedy utilizes permanent solutions and altern-
ative treatment technologies to the maximum extent practicable.
Since treatment of the principal threats of the site was not
found to be practicable at this time, it does not satisfy the
statutory preference for treatment as a principal element.
However, treatment technology studies will continue for the
purpose of providing a more efficient and economical method for
the removal of contaminated materials from the site.
Once fully implemented, the selected remedy will not result in
hazardous substances remaining on the site above health based
levels. Therefore, the five year review will not apply to this
action.
EPA recognizes the difficulties in implementing the remedial
project described in this Record of Decision. Implementation, by
necessity, will occur in a phased manner, and will be contingent
on four critical factors including the availability of a disposal
site, the availability of safe and efficient transportation to
the disposal site, the availability of the necessary funding, and
the cooperation of the communities and affected residents.
Date vXcbffstantine sidamon-EristofJ
Regional Administrator
y
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DECLARATION STATEMENT
RECORD OF DECISION
Glen Ridge Radium Site
Bite Hfl1** and Location
Glen Ridge Radium Site, Essex County, New Jersey
ment of Basis and Purose
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 State of New Jersey concurs with the selected remedy.
Assessment of the Bite
Actual or threatened exposures to hazardous substances released
from the residential and public properties addressed in this
Record of Decision may present an imminent and substantial
endangennent 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 remedy presented in this document complements the remedial
actions described in the previous Record of Decision for this
site and the nearby Montclair/West Orange Radium site. It
provides for the cleanup of the remaining residential and public
properties contaminated with radiological materials. Together
with the previous actions which address primarily the most
extensively contaminated properties, the selected remedy provides
a permanent solution for all affected properties in the
communities .
The selected remedy includes the following components:
Excavation of all radium-contaminated materials exceeding
cleanup criteria from residential and public properties;
Transportation of the excavated materials to «n appropriate
off-site facility for disposal;
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Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
Continuation of treatment technology studies which may
reduce the volume of radium-contaminated materials for
off-site disposal.
Declarations
The selected remedy is protective of human health and the
environment and is cost effective. It attains Federal and State
requirements that are applicable or relevant and appropriate for
the site. The remedy utilizes permanent volutions and altern-
ative treatment technologies to the maximum extent practicable.
Since treatment of the principal threats of the site was not
found to be practicable at this time, it does not satisfy the
statutory preference for treatment as a principal element.
However, treatment technology studies will continue for the
purpose of providing a more efficient and economical method for
the removal of contaminated materials from the site.
Once fully implemented, the selected remedy will not result in
hazardous substances remaining on the site above health based
levels. Therefore, the five year review will not apply to this
action.
EPA recognizes the difficulties in implementing the remedial
project described in this Record of Decision. Implementation, by
necessity, will occur in a phased manner, and will be contingent
on four critical factors including the availability of a disposal
site, the availability of safe and efficient transportation to
the disposal site, the availability of the necessary funding, and
the cooperation of the communities and affected residents.
Date ./(SJhstantine Sidamon-Eristof
/^ Regional Administrator
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DECISION SUMMARY
Montclair/West Orange and Glen Ridge Radium Sites
BACKGROUND
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 proper-
ties 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 approxima-
tely 90 acres and includes 274 properties in the Borough of Glen
Ridge and 32 properties in the Town of East Orange.
The three study areas are located in the eastern foothills of the
northeast-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 exist 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.
The soil at the sites is contaminated to varying degrees with
radioactive waste materials suspected to have originated from
radium 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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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 Mohtclair
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 on 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 eval-
uate the feasibility of excavation and off-site disposal of the
radium-contaminated soil. Twelve properties, with varying de-
grees of contamination, were selected for the study and prelimi-
nary engineering assessments were prepared. In the fall of 1984,
EPA decided to forgo the pilot study since the full RI/FS had
been initiated. NJDEP, however, decided to proceed with excava-
tion of the contaminated soil and initiated a pilot program.
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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 a very tenuous option.
Excavation Alternative Preferred in 1985
In September 1985, EPA issued a draft RI/FS report, and announced
a 60-day public review period. EPA held a public meeting on
November 13, 1985 to further discuss its findings. 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 dis-
posal. Because of this, EPA installed ventilation equipment
and/or gamma radiation shielding 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-
mental feasibility study in March 1987 to develop and evaluate
measures to protect public health. As that study progressed, it
became apparent that an evaluation of both interim and final
remedial measures would need to be included.
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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 evidence that
directly implicates any one person or organization. EPA con-
tinues 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 Histor
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
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
very well attended, with approximately half of the 1500 persons
present 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 the presence of the radium-contaminated soil.
The results of these investigations are presented in a sup-
plemental feasibility study report which was made available to
the public on April 4, 1989. Concurrent with the study, EPA
released for public comment a proposed plan describing its
preferred approach for addressing the radium contamination at the
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sites. The original 60-day comment period was scheduled to end
on June 2, 1989, but was extended 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. In addition, EPA held public
availability sessions at its office trailers in Montclair for
four days following both the April 3, 1989 briefings of the town
councils of the affected communities, and a public meeting
conducted on May 18, 1989.
Records of Decision signed on June 30, 1989
Public response to the proposed plan was mixed. There was almost
unanimous support for those components of the plan that called
for full excavation with off-site disposal of contaminated
material, and installation of state-of-the-art radon mitigation
systems. EPA signed Records of Decision on June 30, 1989,
selecting those measures which were publicly supported. Numerous
reservations were expressed involving other components of the
plan which called for partial excavation and/or the imposition of
institutional controls.- At the request of a number of local
officials and concerned citizens, additional comments on these
components of the proposed plan were encouraged. The decision on
these measures was deferred pending completion of a public
comment period that was extended until January 31, 1990. This
document describes EPA's selection of remedial measures for the
remaining properties not included in the June 1989 RODs.
Summary of Site Characteristics
Soil on public and private properties within the sites is con-
taminated with radionuclides primarily found 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 processing or
utilization facilities, were disposed of in then-rural areas of
the communities. Hence, the main radionuclide of concern 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
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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 uranium234 and uranium23* is gen-
erally about one tenth of that measured for the thorium230 and
radium226 radionuclides. The highest uranium concentration was
measured at 310 pCi/g.
Because radium radioactively decays into radon gas, 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 [(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 (pR/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 properties. Background gamma radiation is
estimated to be approximately 8.3 pR/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 jiR/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 sur-
face. 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 fill 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.
Summary of Site Risks
Elevated concentrations of radium226, thorium230, uranium234 and
lead210 are present in soils at the Montclair/West Orange and Glen
Ridge sites. In addition, elevated 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
6
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decay products,, irradiation by gamma radiation, ingest ion 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 move easily through soil to the ground sur-
face 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
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 cause doses
to various internal bodily organs. This, in turn, can result in
an increased risk of developing leukemia, anemia, and bone can-
cer. However, studies have shown that the projected radiation
doses from these pathways are much smaller than those estimated
for either radon decay product inhalation, or direct gamma radia-
tion exposure using even the most conservative assumptions.1 The
above-background lifetime risks from these three exposure path-
ways 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
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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per day, while an adult would ingest 0.1 grains per day; 3) 15
kilogram's 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
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 and Role of the Selected Remedy
Excavation of the radium-contaminated material remains the
Agency's preferred solution to the problem. The measures
selected in this document will complement those described in the
decision documents signed on June 30, 1989 and reflect the
selection of Alternative 5. The uncertainties noted in the June
1989 decision including maintaining the availability of a
disposal facility, the desire to minimize the disruption of the
communities during remedial action, as well as the essential
cooperation of the affected citizens, make it necessary that EPA
implement remedial action at the Montclair/West Orange and Glen
Ridge Radium sites in a phased manner. EPA believes such an
approach is appropriate in light of the difficulty in assuring
transportation and disposal capacity for large amounts of
contaminated materials, over a long period of time.
The selected remedy now designates for cleanup all contaminated
properties exceeding cleanup standards by excavating the radium-
contaminated soil and transporting it to an off-site disposal
facility. However, because of the logistical difficulties asso-
ciated with this complex and lengthy remedy, certain properties
will be excavated before others. The implementation schedule for
this remedy will be determined during the design phase of the
project. EPA intends to address public lands recognizing that,
because they may present a lesser health risk, they may have a
lower cleanup priority. Additionally, EPA will support the
affected communities by offering health and safety and waste
handling assistance, as appropriate, during maintenance or
repairs in the study areas. Because of the lengthy period of
time required to fully excavate the numerous properties within
the study areas, interim actions will be taken at some of the
properties with soil contamination exceeding the cleanup stan-
dards. These interim actions, as specified in the June 1989
RODs, include indoor engineering controls such as the installa-
8
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tion of state-of-the-art radon mitigation systems and/or
shielding for gamma radiation protection where appropriate.
In addition, EPA continues to explore the development of promis-
ing treatment technologies which ultimately may offer a more
easily implementable and cost-effective method for cleaning up
those properties with contamination remaining on them. As part
of the remedy, EPA will evaluate any new technologies which are
developed and will continue to assess the availability of off-
site disposal capacity, thereby determining the most appropriate
method for addressing these properties.
Groundwater Investigation
EPA has initiated 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 contaminated soil and to
evaluate mitigation alternatives, should contamination be en-
countered. Any remedial action related to groundwater contami-
nation will be addressed by subsequent Records of Decision.
Documentation of Changes from the Proposed Plan
Public comment was mixed with respect to the proposed alterna-
tive 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. EPA chose to
proceed with the implementation of these portions of the remedy
supported by the public, and signed Records of Decisions for the
sites on June 30, 1989.
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.
In addition, institutional controls (that is, restrictions to
prevent disruption of the clean soil shield at the properties)
would have been an integral part of this remedy to ensure the
effectiveness of the indoor and, particularly, the outdoor
engineering controls.
The selected remedy no longer includes any partial excavations.
EPA now commits to the full excavation of all contaminated soil
exceeding the soil cleanup standards at all properties. However,
EPA acknowledges that implementation of this remedy is dependent
on four important factors. These critical factors are: (1) the
continued availability of an off-site disposal facility; (2) the
viability of safe and effective transportation to the disposal
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facility; (3) the cooperation of the affected homeowners; and (4)
the availability of sufficient funds for the excavation and off-
site disposal of the estimated 323,000 cubic yards of radium-
contaminated material.
DESCRIPTION OF ALTERNATIVES
Summary of Remedial Alternatives
The supplemental feasibility study report issued on April 4, 1989
entitled "Supplemental Feasibility Study for the Montclair/West
Orange and Glen Ridge Radium Sites" describes a number of remedi-
al options and technologies. After screening of these options,
seven remedial alternatives were identified for detailed evalua-
tion. Table 2 provides an itemized list of the estimated costs
associated with various components of the candidate remedial al-
ternatives. Table 3 lists the criteria upon which the following
alternatives were evaluated. Note that the costs for the alter-
natives described below are expressed in terms of present worth.
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 the state-of-the-
art radon mitigation systems, the temporary ventilation systems
currently 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 of an active
monitoring and maintenance program 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 radi-
ation 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
10
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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 recently
installed in Montclair and Glen Ridge and in areas of
naturally occurring radon);
o Installation of additional indoor gamma radiation
shielding;
o Installation of outdoor gamma radiation shielding
and/or covering of radium-contaminated soil;
o Relocation or redistribution of "hot-spots11 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(s) 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 moved from the original disposal or core areas
back to these 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. The
houses located on those properties, which are already the most
contaminated properties at the sites, would be demolished.
Radium-contaminated soil would be excavated from properties
located outside of the park boundaries and placed on the contam-
inated 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
11
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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
landscaped 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: 10 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
total volume of radium-contaminated soil present at the sites is
currently estimated to be 323,000 cubic yards. The excavated
soil would be transported for final disposal at a licensed, off-
site facility. The range in the estimate for the cost of this
alternative is attributed to marked price differences for
alternate transportation modes.
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 and 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
12
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health. Alternative 7 was developed to offer a comprehensive and
fully implementable remedy to address public health risks at the
sites.
Summary of Comparative Analysis of Alternatives
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 cri-
teria 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)
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.
13
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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.
Alternative 4 and the selected remedy, which reflects Alternative
5, would be fully protective of human health and the environment.
Compliance with Applicable or Relevant and Appropriate
Requirements
Section 121(d) of CERCLA, as amended by SARA, requires that re-
medies 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 reg-
ulations 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 averaged over the first 15 cen-
timeters (cm) [6 inches] of soil below the surface, and
14
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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 per liter (pCi/1) 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 jiR/hr above back-
ground for gamma radiation are also standards as defined in 40
CFR 192.
Table 6 identifies the degree to which the various alternatives
comply with each of the listed ARARs. Inspection of Table 6
indicates that Alternative 5 complies with all of the ARARs. Al-
ternative 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.
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.
At properties where indoor engineering controls are installed, as
envisioned in Alternative 3, compliance with some public health
ARARs will be achieved, however, no soil cleanup standards will
be met. 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.
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 suf-
ficient 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 signifi-
cantly reducing the volume of radium-contaminated soil necessary
15
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for off .-site transportation and disposal.2 Preliminary results
indicate that it is possible to use simple physical separation
techniques 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, and 7 provide effective short-term pro-
tection. The alternatives become effective as they are imple-
mented at individual properties. Generally, the more quickly an
alternative can be implemented, the greater the short-term effec-
tiveness. However, the more extensive or comprehensive the
initial cleanup program, the more disruptive the remedial
activities may become to the affected communities. Another
adverse short-term impact during remediation, the creation of
dust, could be controlled by implementing dust suppression
measures.
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 systems currently exist in Alternatives l
and 2, there would be no effective remediation.
Short-term effectiveness would be high for the selected remedy.
However, EPA realizes that the disruption to the community during
the implementation of such an extraordinary excavation project
would be extensive and, therefore, expects to conduct the
cleanup in phases. The completion of indoor engineering
controls, as specified in the June 1989 RODs, will mitigate any
potential increases in short-term risk attributable to the more
lengthy schedule estimated for excavation and completion of all
remedial measures.
2 U.S. Environmental Protection Agency, Technological
Approaches to the Cleanup of Radiologically Contaminated
Superfund Sites. (EPA/540/2-88/002), August 1988.
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Long-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,
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
all properties. Engineering controls, where implemented, would
be only temporarily effective, but, as noted above, would serve
to minimize potential short-term risks during implementation.
Implementabilitv
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, and 7 all involve the use of standard
construction practices. That aspect of their implementation is
expected to be straightforward.
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.
The selected remedy involves the use of straightforward construc-
tion methods. However, the magnitude and length of the cleanup
program will likely entail substantial disruption to the normal
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activities of the communities. Otherwise, the selected remedy
should be implementable.
In contrast, Alternatives 3, 6, and 7 involve the use of
institutional controls in addition to standard construction
methods. 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.
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, with a
present worth estimated to be $5.0 million. Alternative 3 is es-
timated to cost a total of $20.8 million.
Depending on the type of containment selected for the Parks
Alternative, 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
differences for alternate modes of transportation.
Alternative 7, which is a combination of the above alternatives,
is estimated to cost $53.0 to $66.0 million.
For the selected remedy, the estimated cost is $199.7 to $295.7
million. This represents the difference between the estimated
range of $252.7 to $348.7 million for Alternative 5, less that
portion of the cleanup funded as a result of the first RODs,
i.e., $53.0 million.
State Acceptance
The State Acceptance factor addresses the concern and degree of
support that the State government has expressed regarding the
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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
was a consensus of support for that portion of the proposal that
called for full remediation of the most severely contaminated
properties, especially the New Jersey pilot program properties
where the residents have been relocated. The community general-
ly approved of the implementation of the indoor engineering
controls to reduce the risk from exposure to excessive indoor
gamma radiation 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 implementation of institutional controls was
objected to by the towns and the public. Imposition of institu-
tional 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 the continued
availability of off-site disposal capacity is uncertain, the
public is fully supportive of this alternative.
Alternatives 1 and 2 have received little or no community sup-
port.
The community supports the implementation of indoor engineering
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.
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Alternatives 6 and 7 are partially accepted by the public as
these provide for complete remediation of a number of proper-
ties. Where the remedies are only partial, the community has
expressed substantial reservations.
The selected remedy commits to full excavation with off-site
disposal of all materials exceeding the cleanup criteria, and, as
such, is fully supported by the community.
SELECTED REMEDY
The remedial action plan being selected by the Environmental
Protection Agency is intended to complement those measures
incorporated in the Records of Decision signed for the sites on
June 30, 1989. This current selection indicates EPA's commitment
in principle to excavate all contaminated materials which exceed
soil cleanup standards. This commitment to full excavation with
off-site disposal reflects Alternative 5 as presented in EPA's
Supplemental Feasibility Study Report and Proposed Plan of April
1989.
Although EPA intends to fully implement Alternative 5, imple-
mentation of this remedy will necessarily occur in phases.
First, EPA will undertake those measures which were selected in
the RODs signed on June 30, 1989. During the implementation of
those ROD decisions, EPA will design and then implement the
remainder of Alternative 5 on a phased schedule which shall be
worked out with community and public involvement.
EPA's implementation of this remedy, however, is contingent upon
four critical considerations, any or all of which may severely
inhibit EPA from completing the selected measures. These criti-
cal factors are: (1) the continued availability of an off-site
disposal facility; (2) the viability of safe and effective trans-
portation to the disposal facility; (3) the cooperation of af-
fected homeowners and local officials; and (4) the availability
of sufficient funds for the excavation and off-site disposal of
the estimated 323,000 cubic yards of radium-contaminated mater-
ial. EPA fully recognizes that it is impossible to "guarantee"
that all four of the above critical factors will be available
throughout the period required to implement the selected remedy.
Thus, EPA intends to continue investigating material reduction
techniques which reduce the amount of material to be transported
off-site for disposal.
Description
The properties within the three study areas are grouped into the
categories listed below. The criteria defining these categories,
which are presented in the June 1989 RODs, remains unchanged by
the remedy selection in this ROD.
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Category "I" Properties — Core area properties which have ex-
tensive, 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
outdoor gamma radiation levels equal to or greater than 50 mic-
roRoentgens 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.
Additional Properties — Some properties within the study areas
have received limited, or no testing to date. These properties
have been temporarily included in Category "V".
Table 8 presents an estimate of the number of properties in each
category based on currently available information.
Unlike the 1989 RODs for the sites, these latest RODs now
identify a remedy for all properties in all categories. These
intended remedial measures are presented below.
Category "I" Properties
EPA's 1989 RODs provide for the excavation and removal of all
contaminated material to achieve the requirements of 40 CFR 192,
Subpart B at all category I properties. EPA has obtained the
funding required to begin this initial phase of the cleanup of
all category I properties. As the remedy for this category of
homes already reflects Alternative 5 as described in the Supple-
mental Feasibility Study Report and Proposed Plan of April 1989,
this new ROD neither changes nor adds to the measures selected
for the category I properties.
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Category "II" Properties
EPA's 1989 ROOs identified remedial measures to be implemented at
some of the category II and III properties. Specifically,
initial remediation at some of the approximately 72 category II
properties will consist of indoor engineering controls to reduce
exposures to radon gas and decay products, and gamma radiation.
These activities will occur independently of the remediation of
the category I properties. In addition, the June RODs state
that, in some cases, it may be possible to excavate a limited
amount of soil from category II properties and thereby fully
remove the radium-contaminated soil present. This limited exca-
vation is intended to remove all radium-contaminated soil from a
property and will only be undertaken if the soil cleanup stan-
dards can be achieved. It is estimated that radium-contaminated
soil will be excavated to a depth of a few feet, and that the
volume excavated from all of the limited excavation properties
will total about 4,000 cubic yards. This volume estimate could
change, however, based on additional information obtained during
remedial design activities.
As previously noted, radium may have contaminated sidewalks or
foundations. Where necessary, these areas will be removed and
appropriately replaced. Contaminated material will be disposed
of at a licensed, off-site facility.
As mentioned earlier, preliminary results from EPA treatment
technology studies indicate that it may be possible to physically
remove a portion of 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,
as well as any new techniques developed as a result of EPA's
treatability studies, will be used to the maximum extent practi-
cal at the Montclair/West Orange and Glen Ridge sites. This
uncontaminated material can then be used as fill for excavated
properties. The scope of these activities is unchanged by the
additional measures outlined in these current ROOs.
In April 1989, EPA had proposed to excavate a limited amount of
surface soil from many of the category II (and also category III)
properties, and to establish institutional controls to protect
residents from exposure to contaminated soil remaining at depth.
However, based on public comment, EPA deferred a decision on
those partial excavation activities pending further input from
area residents and local officials.
Now, as stated above, EPA is committed in principle to excavating
radium-contaminated material at all properties where contamina-
tion exceeds soil cleanup standards. EPA, however, reiterates
its concerns regarding the four critical factors that might
prohibit completion of the excavation and off-site disposal of
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the radium-contaminated materials. The commitment to full
excavation requires that EPA undertake a unique cleanup project
that is estimated to take ten or more years to complete and will
require extensive involvement and cooperation with the
communities and the affected citizens. In addition, funding is .
provided to the agency on an annual basis, and the funds for such
a lengthy and extensive project are not currently available. As
a result, EPA is not able to present a schedule or timetable, nor
to prioritize the order of completion of full excavation at all
the category II and III properties. Therefore, radium-contami-
nated soil will remain on a number of category II and III proper-
ties with outdoor gamma radiation levels exceeding the health
guidelines until the above concerns are resolved.
During excavation, a few residents of the category II properties
may have to relocate temporarily 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 would be excavated at a
time. Where possible, clusters or groups of adjoining homes will
be remediated simultaneously, with the excavated soil being
immediately transported offsite for disposal, thereby elimi-
nating the need for any on-site storage. Clean soil, including
uncontaminated material segregated using physical separation or
other techniques, will replace the excavated soil and be land-
scaped 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. The proper-
ties and houses will have received indoor engineering controls
designed to protect human health to the maximum extent practic-
able. If it were found that such controls could not effectively
protect human health, the Federal government would seek to
purchase the affected properties and provide the residents the
option of permanent relocation.
In April 1989, EPA proposed to establish institutional controls
at properties 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. Now, EPA does not intend to seek the
imposition of institutional controls, e.g., deed restrictions, at
any properties. However, EPA does encourage some municipal over-
sight/awareness of those unremediated properties during the
lengthy period envisioned for the implementation of this compli-
cated and extensive cleanup program.
Category "III" Properties
As noted above, EPA's June 30, 1989 RODs identified remedial
measures to be implemented at some of the category II and III
23
-------
properties. Specifically, the approximately 65 category III
properties generally have more limited, or "hot spot", contami-
nation 'present. For these properties, indoor engineering
controls, as indicated for the category II properties, might be
employed where appropriate. As is true of the category II
properties, in some cases, it may be possible to remove hot spots
from a category III property such that the concentration of any
remaining radiological materials attains permissible guidelines
and/or standards. Again, the 1&89 RODs state that no excavation
will be undertaken unless the small volume of soil removed pro-
vides 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 may be
radium-contaminated soil remaining at some category III proper-
ties with outdoor gamma radiation levels exceeding health guide-
lines until the full implementation of the measures specified in
these current RODs are completed. Again, EPA cannot assure the
continued availability of a licensed disposal site, the main-
tenance of safe and effective transportation of the excavated
contaminated material, the cooperation of the affected residents
and local officials and the necessary funding to fully implement
the intent of these ROOs.
Category "IV" Properties
Category IV properties may have radium-contaminated soil present
above soil cleanup standards, but exhibit no radon gas or radon
decay product concentrations in excess of the health guidelines.
Gamma radiation levels, while elevated above background, are also
within the health guidelines. This could be a result of low con-
centrations 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, requiring
no remedial action. If it is determined that significant radium
contamination is present below the surface, excavation to meet
the permissible guidelines and/or standards will be pursued
depending upon the status of the four critical factors.
24
-------
Category "V" Properties
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. However, should contamination in
excess of soil cleanup standards be found during any design or
construction activities, a property will be reclassified and
remediated as appropriate.
NJDEP Pilot Program Properties
Five properties from the NJDEP pilot excavation program remain
partially excavated in Montclair. As noted in the 1989 RODs,
these properties will be fully excavated to the permissible
standards and are included in the schedule and funding outlined
in those documents.
Public Areas and Streets
Public areas and streets comprise a significant volume of the
contaminated material estimated at the sites. EPA had proposed
very limited excavation and/or outdoor engineering controls at
the majority of these properties to reduce the exposure of
residents and users of these open areas. EPA supports the
eventual excavation and cleanup of these areas, and intends to
utilize alternative treatment processes to reduce the substantial
volumes of uncontaminated materials associated with these areas.
In addition, EPA will assist the affected communities with the
special handling and disposal requirements of any radium-
contaminated materials excavated during maintenance or repairs in
the study areas. As EPA is undertaking an extensive project
within the communities, EPA personnel or its contractors will be
able to provide the technical expertise and safety training to
guide local efforts during typical municipal repair and/or main-
tenance services throughout the life of the cleanup program.
Regular discussions and consultations with the communities and
the public concerning the scheduling of the cleanup of these
areas will be extremely important. Site monitoring will be
conducted over the next ten years at a minimum.
Additional Properties
Some properties within the study areas have received limited, or
no, testing to date. This is due to a number of reasons, includ-
ing property access denials. EPA plans to ensure that all pro-
perties will have been tested when the remedial design is
complete. 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
25
-------
expected to significantly affect the overall scope of the
remedial'action.
Cost Estimate
The cost of the selected remedial action is estimated to be
between $199.7 and $295.7 million for the two National Priorities
List sites combined. This reflects the cost of alternative 5
less the $53.0 million already designated by the 1989 RODs. This
includes the costs of excavation, temporary resident relocation,
and property restoration; transportation; disposal; and moni-
toring. The wide range of costs reflects the difference in
estimates for alternate modes of transporting the contaminated
material for off-site disposal.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on the Superfund Amendments
and Reauthorization Act of 1986 and the regulations contained in
the National Contingency Plan. SARA requires that EPA utilize
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Protection of HMman Health and the Environment
This remedy is fully protective of human health and the environ-
ment. It is estimated that no radium-contaminated soil above the
cleanup standards will remain on any of the approximately 750
properties within the boundaries of these two Superfund sites.
Implementation of this remedy will eliminate risks attributable
to exposures to indoor or outdoor gamma radiation, indoor radon
gas or radon decay products, inhalation and/or ingestion of con-
taminated soil, and ingestion of contaminated vegetables grown in
contaminated soil.
As noted earlier, the 1989 RODs also provide for interim mea-
sures at a number of properties within the study areas. For
those properties, some of the risks attributable to the effects
of the radioactive decay of the radium-contaminated soil will be
minimized by the implementation of the interim measures during
the lengthy and potentially discontinuous completion of the
cleanup program. This remedy is intended to fully comply with
the ARARs in all cases.
There are few short-term risks associated with the implementa-
tion of this remedy. Where excavation occurs, dust suppression
measures can reduce the risk of inhalation of radium-contami-
nated dust. For those properties where this remedy is not
immediately implemented, some additional short-term risk may
occur 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
26
-------
short-term risk is not unacceptable. In addition, no adverse
cross-media impacts are expected from the remedy.
afctn-t nment Of ARARS
As presented earlier, the primary ARARs for these two sites are
contained in 40 CFR 192, Subpart B. This regulation deals with
the cleanup of inactive uranium processing facilities. EPA has
determined that while these standards are not legally applicable,
they are relevant and appropriate to the situation at the Mont-
clair/West Orange and Glen Ridge Radium sites. Table 5 lists and
summarizes these standards and other ARARs that may be pertinent
during the implementation of this remedial action.
When implemented, all of the properties within the study areas
should comply with public health and soil cleanup ARARs. In
addition, all properties where interim remedies are instituted
should comply with the indoor radon decay product and gamma
radiation ARARs.
Cost-Effectiveness
The selected remedy is cost-effective because it provides overall
effectiveness relative to its cost. The remedy provides for
protection of public health and the environment at all 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.
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 Radium
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 the statutory preference for treatment as a principal
element and State and community acceptance.
This remedy offers the highest degree of long-term effectiveness
of any alternative evaluated. It allows for the exploration of
additional disposal capacity and the development of alternative
treatment technologies. Alternative 4 also offers a final
27
-------
solution, but is 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 might be realized by
reducing the volume of contaminated material requiring off-site
transportation and disposal.
Experience has shown how difficult it can be to assure transpor-
tation and disposal availability for large amounts of
contaminated material. The selected remedy acknowledges the
extensive excavation program with the attendant large amount of
soil for off-site disposal, but plans minimizing the disruption
to the residential communities by conducting the cleanup in a
phased manner over an extended period of time. Thus, the remedy
becomes somewhat more implementable.
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 avail-
able that destroys the radioactive source of these threats, the
selected remedy does not satisfy the statutory preference for
treatment as the principal element. Coupled with the measures
specified in the June 1989 RODs, this remedy reduces the exposure
to all excess indoor concentrations of radon and radon decay
products. It also provides for complete remediation at all
properties, thereby reducing the exposure risk from all other
pathways.
The Responsiveness Summary which addresses written and verbal
comments follows the figures and tables.
28
-------
&,
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Source: U.S.G.S. Orange, N J. Quadrangle
Figure 1
Location of Three Study Areas
MofflclairAVtst Orangt and Gltn Ridgt Radius Suts
-------
• Con
analysis of boring
bjp.
^^—• Eeflmaled boundary «•—•
by waysis of indoor
•nd outdoor gamma
K3orearea«.
Study area parlmel
Discrete pockefa of <
0
h
scale
500
__—l
leal (apprextmala)
COM
Figure 2
Glen Ridge Stud^ma
Montctalr/Wesl Oranga and Glen Ridge Radium SHes
-------
Cora
boundary
as determined I
by anaysn of
boring togs.
boundary of
redistributed
001* material
as determined
by analysis
of Indoor ano
outdoor gamma
Study area perimeter
Discrete pockets of contamination as determined by borings.
0
h
scale
500
_—l
leet (approximate)
COM
Figure 3
Montclair Study Area
Montclalr/West Oranqe and Ol«n niHn« PaHhim ci«~
-------
Cora MM boundary
asdatarmtoedby
analysis of boring tog*.
* twrnataoboundan/OT
fadbMwlad am material n
drfarminad by analysis of Indoor
and outdoor gamma lerals.
Coraaraat.
Study araa parimatar
Dhoata pocket* of oontaminaHon a» Marmlnad by borings.
0
scale
500
"»ael (•pproibtial*)
COM
Figure 4
West Orange St
Montdalr/Wmt Orenga and Glen Rklge Radium Silts
-------
".'.'** ' '• '*"**•*«*•
;^-.r-"'.' .-"rii
1 Fbor and wall cracks • -. •.• ^J:V•*''••-v'?
2 Hollow block walls ' ' ' •<:!>'''''i>^
3 Mortar joints
4 Porous concrete block
5 Holes for utility and service pipes, cables, etc
6 Sill plate and header joist gaps
7 Slab • footing joints
8 Exposed soil
9 DCains, sumps and weeping(drain) tiles
10 Crawl spaces
Not to Salt
. . . •-.
--:"-:v;"::';iir^--i--:';
les, etc. • • * . /.«. •'• •'.. ': ". • -.-
Adapted from "Radon RaduObo T«chniquts
for Dctaef)*d Houtts; Technical Guidanca.* USEPA
Figure 5
Typical Radon Entry Routes
MomdairWtct,Or«ngt and Gton Ridg* Radium Silts
-------
TABLE 1
RADIATION UNITS
Type Units of Measure
Radon pico Curie per filer
(pCi/l)
O'%f4ftf» Divw&nnu \UnA^t*t 1 AUA! /lAfl \
MWG Site
Background
dpCi/l
nnnoiAil
EPA Guidelines
4pCI/l
nn9M/f
Gamma Radiation
Rate
MicroRoentgen per Hour
(uR/hr)
8.3 uR/hr
20 uR/hr above Background
Annual Gamma
Radiation Exposure
(to man)
Mfflirem per Year
(mrem/yr.)
86 mrem/yr.
170 mrem/yr.
above Background
Radtonucfide Activity
(concentration) in soil
pico Curie per gram
(pCi/g)
-------
Table 2
Summary of the Cost of Each Alternative (million dollars)11
Costs Incurred During Remediation
Engineering/construction
- Construction/restoration
- Excavation/restoration
- Transportation
-Disposal
- Relocation
- Police/securrry/lrafl te
- 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
-
40.1"
0.7
12.6-1 7.3*
11.9
0.6
2.0
1.0
0.1
5.0
0
$74.0-78.5
5
Full
Excavation
Offslte
Disposal
.
83.8*
83.3-1 79.3e
80.8
1.1
0.9
2.8
-
-
0
$252.7-348.7
6
Partial Excavation
Offslte Disposal
Two Foot Five Foot
Excavation Excavation
6.7 8.7
19.0" 51.6"
1 6.8-35.7* 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"
• Excavation costs vary according to the degree of contamination (SIM/yd3 or WOO/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.
c Lower cost Is for rail transport; higher cost Is for trucking
4 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 OF EPA CRITERIA345
HEALTH GUIDELINES
Topic
Radon
Units of Measure
picoCuries/liter
(pCi/1)
value
4 pCi/13
Radon Decay
Products
Working Levels (WL)
0.02 WL4
Gamma Radiation
Rate
microRoentgens/hour
(jiR/hr)
20 nR/hr above
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
3 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"
s Averaged over 100 square meters (120 square yards)
-------
TABLE4
Overall Evaluation of the Alternatives
Alternative
1«
A
3456
7
Compliance with ARARs
Reduction In toxlclty,
nobility, or volume
Above-background risk
remaining after remediation
(no. of excess deaths per
1,000 people exposed)
Potential short-term rfska
Time to Implement (years)
Long-term effectiveness and
permanence
Implemen lability
Cost In minions
/
Overall evaluation for
protectlveness
Does not
comply with
any ARAFU
None
3-367
None
NA
Not
effective
NA
0
No
protection
provided
Does not
comply with
most ARARi
None
3-36
Some
NA
Not
effective
NA
5.0
Not
adequate
Does not
comply with
•Oil ARAB
None
2.6-18
Low
4.6
Temporarily
effective
Few
obstacles
20.8
Provides
•non-term
protection
Complies
with all
ARARs
None
0.9-1.6
Medium
4
Effective
and
Final
Possibly
major
obstacles
74.0-78.5
Protective
of public
hearth and
Complies
with all
ARARs
None
0.0-1.6
High
5.6
Effective
and
Final
Possibly
major
obstacles
252.7-348.7
Protective
of public
hearth and
Does not
comply
with soil
ARAR
None
2.6-17
High
3.2 (2ft option)
5.4 (5ft option)
Temporarily
effective (2ft)
Maybe
affective for
long term (5ft)
Possibly
major
obstacles
67.746.6 (2ft)
142.1-184.4 (5ft)
Provides short
term protection
of public
Does not
comply
with soil
ARAR
None
1.3-6.5
High
3.2
Temporarily
effective
BtMMtndimJIw
Csugory It drain
sAirpicptitJK
Possibly
major
obstacles
53.0-66.0
Provides
•horttarm
protection
-------
Table 5
Summary of Major ARARs
11
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 in:
• Drinking water
/
• Ground water
- Surface water
•Air
•Soluble Th-230 in air
HISTORIC DISTRICT
ARAR
0.02 WL
(as an annual average)
20u.R/hr
above background
0.17remtyr
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 subsurface*
(See appendix B)
At least 200 yrs.
20 pCi/m'/sec.
(See appendix B)
(See appendix B)
(See appendix B)
SpCi/l
(Ra-226 and Ra-228
combined)
30pCi/l*
30pCi/l
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;
N.J.A.C. 7.28
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;
N J.A.C. 7:9-6.6
10 CFR 20;
N J.A.C. 728-6.5
NJ.A.C. 728-6.5
10 CFR 20;
NJ.A.C. 728-6.5
10 CFR 20;
N J.A.C. 728-6.5
National Historic
Preservation Act of 1966
Highest value
measured
on site
1.5 WL
1.000uR/hr
^Uem/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/m8/sec.
1.22pCi/l
11.8pCi/l
<1pCi/l
Not measured
0.00004 pCi/l
(Total gross alpha)
Average
background
0.002 WL
6.3 u.R/hr
0.073 rem/yr1
1pCi/g
1pCi/g
<1 pCiftn2/sec.
02pCi/l
OJSpCM
0.1-0.5 pCi/l
NA
<0.000001 pCi/l
'Estimated using indoor/outdoor gamma measurements.
Does not include exposure to radon decay products.
* Averaged over 100 square meter area.
'If classified as a drinking water aquifer, limit is 5 pCi/l for Ra-226
•nd Ra-228 combined.
-------
TABLES
Compliance with ARARs
ARAR
PUBLIC HEALTH
Radon decay
product*
Gamma radiation
Radionucllda* In aoll
CLEANUP
of land* and building*
contaminated with
radioactive material
DISPOSAL
TRANSPORTATION
ENVIRONMENTAL
drinking water, ground
and surface waters.
outdoor air
HISTORIC DISTRICT
SUMMARY '
Alternative
1
2
3
4
5
6
7
Does not
comply
Does not
comply
Does not
comply
Does not
comply
NA
NA
Complies
No impact
Does not
comply with
Public Health
Not for
•D houses
Does not
^comply
Does not
comply
'
Does not
comply
NA
NA
Complies
Minimal
impact
Does not
comply with
some Public
Complies
Complies
Complies.
with
Institutional
Controls
Does not
comply
NA
m
NA
Complies
Possfcte
impact
Complies with
Public Health
ARAR's
or soil cleanup Health ARAR's
ARARs
or the Mil
cleanup ARAR
Does not
comply with
•oil cleanup
ARAR
Complies
Complies
Complies
Complies
Std. design
complies
Alt design
jnay not
comply
Complies
Complies
Possfcte
impact
Complies
with all
ARARs
(std design)
Complies
with all
but longevity
requirement
(alt design)
Complies
Complies
Complies
Complies
Will comply
with host state
requirements
Complies
Complies
Possible
impact
Complies
with all
AAARs
,f
Complies
Complies
Complies,
with
Institutional
Controls
Does not
comply (2ft)
Complies
for tome
properties
(5ft)
WiD comply
with host state
requirements
Complies
Complies
Possible
impact
Complies with
Public Health
ARAR's
Doe* not
comply with
•oil ARAR (2ft)
5 foot option
complies
with *o3ARAR
on come
properties
Complies
Complies
Complies, with
Institutional
Controls
Complies for
Category I and
certain other
properties
Will comply
with host state
requirements
Complies
Complies
Possible
impact
Complies with
Public Health
ARAR's
Complies with
•Oil ARAR on
Category I
and certain
other
properties
-------
TABLE 7
Evaluation of Long-Term Effectiveness and Permanence
FACTOR
Alternative
12345 6 7
Permanence
Magnitude of
residual risk
Type/degree of
long-term
mamagement
Long-term
reliability of
Institutional
control*
Human exposure
Environmental
exposure
Long-term
rellblllty of
engineering
control
Need for '
replacement
ol remedy
Summary
Final Interim
High High
None Institutional
controls
that
are difficult to
implement
NA Not reliable
High High
High High
NA Not reliable
NA Definite
Not Not
effective effective
tntenm
Medium
Institutional
controls
mat
are difficult to
implement
Not reliable
Medium
High
Unknown
Definite
Temporarily
effective
Fnal
None
Institutional
controls
on site
mat are
•asy to
implement
Reliable
Low
Low
Reliable
(aid. design)
At least 30 yrs
(aft. design)
Notikely
Final and
effective
(std. design)
Effective but
not Final
(alt design)
Fnal
None
Institutional
controls
off site
mat are
•asy to
implement
Reiable
Low
Low
Rafiable
Notikely
Final and
effective
.,
Interim
(5 ft could be
fcnalonsome
properties)
Medium (2 ft)
Low (5 ft)
Institutional
controls
that are
difficult to
implement
Not
reliable (2 ft)
More
refiable (5 ft)
Medium (2ft)
Low (5 ft)
High (2 ft)
Medium (5 ft)
Unknown
Definite (2 ft)
Possible (5 ft)
Temporarily
effective (2 ft)
Maybe
effective (5 ft)
Interim
(Category 1 •
properties are final)
Medium/Low
None
(Category 1* propertwi)
Institutional
controls
that are
difficult to
implement
Not
reliable
Medium/Low
Low (Category I*
properties)
Medium
Unknown
Reliable
(Category r properties)
Possible
Notikely
(Category r properties)
Temporarily
effective
Final and
Effective
(Category 1*
properties)
' Includes certain properties in other categories.
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TABLE 8
ESTIMATED NUMBER OF PROPERTIES IN CATEGORIES
Category
Study Area
Total
I
II
III
IV
V
MONTCLAIR WEST ORANGE
16* 2
50 4
34 8
162 28
104 33
GLEN RIDGE
5
21
23
96
161
TOTAL:
23
75
65
286
298
747
* Includes four properties partially excavated as part of
the NJDEP pilot excavation program.
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FINAL RESPONSIVENESS SUMMARY
FOR THE
MONTCLAIR/WEST ORANGE AND GLEN RIDGE RADIUM SITES
ESSEX COUNTY. NEW JERSEY
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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
County, New Jersey, and the U.S. Environmental Protection
Agency's (EPA) responses to those concerns. This responsiveness
summary addresses comments received during the extended public
comment period which closed on January 31, 1990. Other comments
concerning the Supplemental Feasibility Study (FS) report and
Proposed Plan received by EPA prior to June 9, 1989, are
addressed in the Responsiveness Summary included as part of the
Records of Decision for the sites signed on June 30, 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, locating and
assuring the continuing availability of a disposal facility can
pose major obstacles to implementing any excavation remedy. For
this reason, EPA developed and evaluated additional alternatives
to address the problem while at the same time maintaining tem-
porary measures to reduce exposures in the affected homes.
On June 30, 1989, EPA signed Records of Decision for the two
sites which selected a final remedy for a number of properties
within the sites, including all those with the most extensive
contamination. The selected remedy also provides for interim
indoor engineering controls for other properties with elevated
concentrations of radon and radon decay products and/or gamma
radiation levels. The June 1989 RODs include a summary of the
comments received between April 4 through June 9, 1989, and a
summary of the public meeting held on May 18, 1989.
At the request of local officials and concerned citizens' groups,
EPA deferred selection of remedies for a number of properties,
thereby allowing for additional review and comment. As noted
above, EPA kept the extended public comment period open until
January 31, 1990. This Responsiveness Summary includes those
comments received by EPA, and provides responses to the issues
and concerns raised.
Additional community concerns about EPA's remediation efforts at
the Montclair/West Orange and Glen Ridge Radium sites are also
summarized in the "Final Summary of Citizens' Concern About the
Remedial Investigation and Feasibility Study" and "Final Public
Information Meeting Summaries for the Montclair/West Orange and
Glen Ridge Radium Sites, Essex County, New Jersey." The report,
"Final Summary of Citizens' Concern About the Remedial Investi-
gation 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 Infor-
mation Meeting Summaries for the Montelair/ West Orange and Glen
Ridge Radium Sites, Essex County, New Jersey" is a summary of
EPA's presentation and comments received at special Town Council
meetings convened by the Mayors of Montclair, 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 June 1989 RODs, the "Final Summary of
Citizens' Concern About the Remedial Investigation and Feasibi-
lity Study" and the "Final Public Information Meeting Summaries
for the Montclair/ West Orange and Glen Ridge Radium Sites, Essex
County, New Jersey", have been considered by EPA in making a
decision regarding the selection of a remedy for the cleanup of
the Montclair/West Orange and Glen Ridge Radium sites.
Additionally, EPA has initiated a supplemental groundwater
investigation for the Montclair/West Orange and Glen Ridge Radium
sites.
This responsiveness summary for the Montclair/West Orange and
Glen Ridge Radium sites is divided into the following sections:
I. 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.
II. 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 the public comment
period between June 10, 1989, and January 31, 1990, and
provides EPA responses to these comments.
IV. Remaining Concerns. This section discusses community
concerns that remain to be addressed now that remedy
selection is completed for the remaining properties.
These concerns focus on the details of how the selected
remedial alternative will be implemented.
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Appendix A Location of the information repositories for the
Montclair/ West Orange and Glen Ridge Radium
sites.
I. Responsiveness Summary Overview.
The Nontclair/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 has identified Alternative 5, Total Excavation, with Off-
Site Disposal, as the Agency's preferred alternative. Under
Alternative 5, all contaminated material exceeding the cleanup
criteria would be excavated and transported offsite for disposal.
EPA recognizes the difficulty in undertaking this extensive
excavation program and has noted four (4) critical considerations
that must be operative for the successful implementation of this
remedial alternative. These critical factors are: (1) the con-
tinued availability of an off-site disposal facility; (2) the
viability of safe and effective transportation to the disposal
facility; (3) the cooperation of affected homeowners and local
officials; and (4) the availability of sufficient funds for the
excavation and off-site disposal of the estimated 323,000 cubic
yards of radium-contaminated material.
As it may require as many as ten years to complete this project,
coupled with the desire to minimize the disruption to the
affected residents, it thus becomes necessary to conduct the
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cleanup in phases. Furthermore, in order to reduce short-term
risk tp residents exposed to excessive levels of radon, radon
decay products and gamma radiation, interim indoor engineering
controls will be installed at a number of homes. These interim.
measures will be quickly implemented. These measures are not
intended as the final remedy for any property and are designed to
ensure protection of public health during the phased
implementation of the excavation program. EPA's selected remedy,
as noted above, is Alternative 5. The remedy will address all
properties by fully excavating all radium-contaminated soil in
excess of the soil cleanup criteria.
A summary of the site background, alternatives evaluated and a
comparison of alternatives are presented in these RODs, the June
1989 RODs, and the Proposed Plan. A fuller description of the
Alternatives is provided in the Supplemental FS report. All of
these documents and reports are 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 continued to inform the public concerning developments
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 assess-
ment. Another update, discussing progress on the supplemental
feasibility study, was mailed to affected residents and concerned
individuals later in 1987.
On April 3, 1989, EPA attended special Town Council meetings to
discuss the findings of the Supplemental Feasibility Study. The
issues identified at the three Town Council meetings are summa-
-------
rized in the "Final Public Information Meeting Summaries for the
Montclair/West Orange and Glen Ridge Radium Sites, Essex County,
New Jersey". 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 l of the draft Supplemental FS report. Public availabil-
ity sessions were also held on April 5 through 8, 1989, at EPA's
office trailers on Oak Street, adjacent to Nishuane Park in Mont-
clair. 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
availability sessions.
EPA also conducted a public meeting on May 18, 1989, to discuss
the Supplemental FS and to receive formal public comment. On May
19 and 20, additional public availability sessions were held at
EPA's office trailers on Oak Street in Montclair. Community
relations activities conducted subsequent to the completion of
the June 1989 RODS are summarized in the remainder of this
section.
On July 14, 1989, EPA held a public availability session at the
office trailers on Oak Street in Montclair to respond to any
questions concerning the just completed RODs. EPA also announced
that the public comment period had been extended until August 30,
1989, to allow for further discussions on those components of the
Proposed Plan about which there was substantial community con-
cern. During late August, an organized mailing from residents of
Glen Ridge called for continued exploration and discussion of al-
ternatives. As a result, EPA then further extended the comment
period until October 31, 1989. When regular meetings between
local officials, concerned residents' groups and EPA were initi-
ated to continue discussion of cleanup options, EPA agreed to one
final extension of the comment period until January 31, 1990.
EPA continues to inform the public and the affected communities
about progress on the development of these Records of Decision
and the initiation of remedial design and cleanup efforts at the
two sites. During the last 6 months, EPA has also prepared and
distributed three additional updates.
III. Summary of Major Questions and Concerns Raised during the
Public Comment Period and EPA's Response to Comments.
This section addresses the comments received during the continu-
ation of the public comment period from June 10, 1989, through
January 31, 1990. A preference for Alternative 5, Total Excava-
tion, With Off-Site Disposal, has been expressed consistently by
the local officials, community groups, and individual citizens
who have commented on EPA's activities since the initial RI/FS
report was released in 1985. Written and verbal comments
received throughout the continuation of this extended public
-------
comment period on the Supplemental FS report and Proposed Plan
reiterate this preference.
In 1985, 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 dis-
posal. As noted earlier, 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
involvement during the most recent comment period on the
Supplemental FS was significantly less dramatic, although the
tone and type of comments received express emphatic commitment to
total removal of the radium-contaminated material. While the
communities clearly prefer full excavation and off-site removal
of all contaminated materials, discussions with affected resi-
dents, especially during the public availability sessions,
reflected the communities' awareness and empathy for the diffi-
culties encountered in securing and maintaining the availability
of a disposal site for the excavated, contaminated material.
Comments received during the public comment period are
categorized in the nine topical areas listed below:
Health Related Concerns
Institutional and Municipal Issues
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, would have
-------
provided for the protection of public health at all properties
within the study areas, but would have relied heavily on insti-
tutional controls to ensure its effectiveness. However, concerns
voiced by local authorities over their ability to successfully
enforce such controls was one of the factors which led EPA to
select Alternative 5, Total Excavation With Off-Site Disposal.
COMMENT: Local officials, the Montclair Environment Advisory,
and several residents asked what safeguards were incorporated
into remedial plans to prevent exposure to contaminated material
during excavation.
EPA RESPONSE: During excavation, monitoring, erosion control and
dust suppression measures would be implemented.
Institutional and Municipal Issues
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 is currently developing an emergency response
protocol to assist the affected communities in monitoring and
handling materials excavated during maintenance operations
beneath public properties and streets. EPA will provide
monitoring assistance during excavation of radium-contaminated
areas, and will provide assistance with disposing of material
removed during these operations.
Engineering Controls
COMMENT: Several interested parties questioned the track record
of the engineering controls, i.e., sub-slab ventilation systems.
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. At properties with identified gamma anoma-
lies, there will be the potential for children and gardeners to
ingest contaminated material until excavation occurs.
Technical Issues
COMMENT: Comparisons with other Superfund sites suggest that a
significant cost savings could be realized by compacting the
excavated waste materials planned for offsite disposal. Also, is
EPA exploring volume reduction and/or soil compaction measures at
the sites?
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EPA RESPONSE: EPA is continuing efforts to develop alternative
treatment technologies which will reduce the volume of material
required for off-site disposal. However, disposal costs for any
excavated material are based on weight, not on volume
measurements. 'Therefore, compaction of soil will not provide for
disposal cost savings.
Project Schedule
COMMENT: Many of those who commented, inquired into EPA's
proposed timetable for implementing the cleanup. 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 was not
possible to remediate these four properties in 1989 because of
the length of time required to secure contractors to design and
implement the selected remedy. EPA is currently offering to
permanently relocate these four homeowners. Construction
contract documents have been prepared and will be made available
for bid when the four homeowners complete access agreements
allowing the cleanup of their properties. EPA expects to award
the contract to remove the contaminated soil from these four
properties in the Summer of 1990.
Proposed Plan
COMMENT: Is the EPA actively pursuing potentially responsible
parties?
EPA RESPONSE: EPA is still attempting to discover evidence that
will substantiate allegations regarding the source(s) of the
radium-contaminated materials discovered at the sites.
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 originally deferred selecting the extensive remedial
option of complete excavation of the estimated 323,000 cubic
yards of contaminated material. Now, EPA intends to fully
excavate all contaminated material exceeding cleanup criteria,
although EPA will undertake this program in a phased manner.
8
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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 remedial effort. 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 contam-
inated 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 is
addressing 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
cleanup plan. Many who commented encouraged EPA to include
public properties and streets in their ROD.
EPA RESPONSE: EPA did not originally include excavation of soil
from beneath public properties and streets as part of the
Proposed Plan. These areas are now included in the remediation .
plans, although excavation of these areas will most likely be
deferred until private properties have been completed.
COMMENT: Is EPA's remediation of the Montclair/West Orange and
Glen Ridge Radium sites 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 reiterates most emphatically that there is no
connection with the New Jersey Low Level Waste Compact siting
process. The materials found at the Montclair/West Orange and
Glen Ridge sites will not be eligible for disposal at the Compact
Site, when and if it receives its final approval.
-------
Other Alternatives Evaluated
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 contamina-
tion 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 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, and maintaining engineering 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 and maintaining engineering controls that
would be required as part of any alternative.
IV. 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-
ment the selected remedial alternative. These discussions are
now held on a regular basis and EPA intends to continue this
avenue for communication throughout the remedial process.
Second, citizens continue to inquire about EPA's planned
groundwater investigation and its potential effect on EPA's
remedial action. EPA has initiated this study and expects to
install appropriate wells later this summer. EPA expects that
the results of the groundwater investigation will not affect the
plan for remediation of the sites. Concern about the possible
for groundwater contamination and its potential effect on the
community is expected to continue until the groundwater
investigations are complete and the results evaluated.
10
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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
Montclair Municipal Building
205 Claremont Avenue
Montclair, New Jersey 07042
Montclair Public Library
50 South Fuller-ton 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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