Superfund Program
Proposed Plan
U.S. Radium Superfund Site
August 2006
U.S. Environmental Protection
Agency, Region II
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan presents the preferred No Action
remedy for the ground water at the U.S. Radium Corp.
Superfund Site located in Essex County, New Jersey
(Site) and presents the rationale for that preference. This
document is issued by the U.S. Environmental Protection
Agency (EPA), the lead agency for Site activities. The
New Jersey Department of Environmental Protection
(NJDEP) is the support agency.
The No Action remedy described herein is the preferred
remedy for Operable Unit 3 (OU3) of the Site, which
addresses ground water at the Site. Operable Units 1 and
2 addressed radiologically contaminated soil and building
materials at the Site. EPA, in consultation with NJDEP,
will select a final remedy for OU3 after reviewing and
considering all information submitted during the 30-day
public comment period. EPA, in consultation with
NJDEP, may modify the preferred remedy based on new
information or public comments.
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (CERCLA), and
Section 300.430(f) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This
Proposed Plan summarizes information that can be found
in greater detail in the Remedial Investigation (RI) report
and other documents contained in the Administrative
Record file for OU3 of this Site. EPA and NJDEP
encourage the public to review these documents to gain a
more comprehensive understanding of the Site and
Superfund activities that have been conducted at the Site.
SITE HISTORY
The former U.S. Radium Corporation facility, which
covers 2 acres in the City of Orange, is a former radium-
processing plant where extraction, production, application,
and distribution took place from about 1915 through 1926.
Approximately VT. ton of ore per day was processed and
disposed of on and off the property. The original facility
Dates to remember:
MARK YOUR CALENDAR
PUBLIC COMMENT PERIOD:
August 10 to September 8, 2006
U.S. EPA will accept written comments on the Proposed Plan
during the public comment period.
PUBLIC MEETING:
August 22, 2006
U.S. EPA will hold a public meeting to explain the Proposed
Plan and the preferred No Action remedy. Oral and written
comments will also be accepted at the meeting. The meeting
will be held at the Orange City Hall Council Chambers
located at 29 North Day Street in Orange, New Jersey at 7:00
p.m.
For more information, see the Administrative Record at
the following locations:
U.S. EPA Records Center
Region II
290 Broadway, 18th Floor.
New York, New York
10007-1866
(212)637-3261
Hours: Monday-Friday,
9 am to 5 pm
Orange Public Library
348 Main Street
Orange, New Jersey
(973)673-0153
West Orange Public Library
46 Mount Pleasant Avenue
buildings were removed in 1999 as part of the remedial
action. In addition, radium-contaminated soil and debris
were identified at approximately 250 noncontiguous
properties in the vicinity of the former plant and at various
satellite locations throughout the municipalities of Orange,
West Orange, and South Orange. At this time,
investigations to identify additional contaminated properties
are complete. The noncontiguous vicinity and satellite
properties are occupied by residences, light industries,
offices, grocery stores, and apartment buildings. The main
portion of the Site is located in a densely populated, urban
residential neighborhood. All area residents and businesses
are supplied with municipal water.
A Proposed Plan for the first operable unit (OU1) was
released to the public on April 28, 1993, along with an
OU1 Remedial Investigation and Feasibility Study (RI/FS)
Report. OU1 consisted of mostly residential properties. On
September 21, 1993, a Record of Decision (ROD) was
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signed for the OU1 properties, selecting a remedy of
excavation of radium-contaminated material from affected
properties, restoration of the
excavated areas, and off-site disposal of the radium-
contaminated material.
A Proposed Plan for the second operable unit (OU2) of the
Site was released to the public on May 23, 1995, along
with an OU2 RI/FS Report. OU2 consisted of the
remainder of the Site; namely, the former U.S. Radium
facility at High and Alden Streets, plus four other
commercial properties used by U.S. Radium. On August
29, 1995, a ROD was signed for the OU2 properties,
selecting essentially the same remedy as that for the OU1
properties: excavation of radium-contaminated material,
restoration of the excavated areas, and off-site disposal of
the radium-contaminated material.
The OU1 and OU2 remedial actions are now essentially
complete. Overall, approximately 650 properties were
investigated during the remedial design. Of these
properties, approximately 250 were identified as requiring
remediation under the selected actions.
Previous ground water sampling events indicated the
presence of dissolved radionuclides, specifically radium,
thorium, and uranium in the ground water underlying the
former U.S. Radium facility, but the results were not
conclusive. Since the time of the OU1 and OU2
investigations, most of the contaminated source material
has been removed from the former U.S. Radium facility
area.
SITE CHARACTERISTICS
The City of Orange is located in the lower valley portion
of the Passaic River Drainage Basin. Ground water in the
Site's vicinity occurs in the unconsolidated glacial
sediments (shallow, overburden aquifer) and in Passaic
Formation bedrock (deeper aquifer). Ground water flow in
the overburden is generally east-southeast. A slight
upward flow of ground water is present at the Site,
particularly in wells immediately down-gradient of the
former U.S. Radium facility. The upward gradient
between the deeper ground water and the shallow
overburden ground water limits the downward movement
of ground water. The overburden aquifer currently is not
used for domestic or industrial water supply. While it is
not expected that it will be used in the future as a source
of potable water, it is classified by NJDEP as Class IIA,
which means that it can be with appropriate treatment. All
area residents are supplied with municipal water provided
through United Water of Orange.
From the early 1990s to 2005, the soil remedial action
resulted in the removal of up to 15 feet of radiologically
contaminated material at the former U.S. Radium facility.
Therefore, the primary source of radiological contaminants
beneath and immediately down-gradient of the Site has been
removed.
The ground water investigation was conducted in two
phases (see Figure 1). First, a site-wide analysis was
conducted which included wells located both at the former
facility area and at various locations in the vicinity of the
former facility where radiological contamination was found
at residential and/or commercial properties. The second
phase of investigation focused on a small area at which
elevated concentrations of uranium in ground water were
detected.
It should be noted that the investigation evaluated the
ground water for the presence of site-related radiological
contamination only; other organic and inorganic
contaminants may be present in the ground water, but were
not part of this RI.
Site-Wide Ground Water Investigation
A comprehensive ground water investigation was planned
in order to determine if site-related contamination had
affected ground water at the former facility area or near any
of the other approximately 250 properties from which
radiological contamination was removed. As such, ground
water samples were collected from 13 wells in 2003, and
again in 2004 to verify the results. Two of these wells were
located on the former facility area, and the rest were placed
throughout Orange and West Orange. As part of this
investigation, water from one of the supply wells located at
Gist Place, which are used for the City of Orange residents,
was tested for the presence of radiological contamination.
Results of the sampling showed no evidence of a site-wide
ground water radiological contamination problem. In
general, concentrations of the site-related radionuclides
were comparable to naturally occurring concentrations. In
particular, the water supply well did not exhibit any
elevated concentrations of site-related contaminants.
One of EPA's shallow monitoring wells (Well P-2) did,
however, have elevated concentrations of uranium. The
maximum concentration of uranium detected in this well
was approximately 127 micrograms per liter (ug/1), where
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as the Federal Primary Drinking Water Standard for
uranium is 30 ug/1. This well is located at the southeast
corner of the former facility property. None of the other
site-related contaminants, including the primary
contaminant of concern at the Site, radium, were elevated
at this well, nor were uranium concentrations elevated in a
well co-located with this well but drawing water from a
deeper interval. In addition, a well located approximately
800 feet down-gradient of this well did not exhibit elevated
concentrations of uranium.
Therefore, it was determined that additional investigation
would be required to bound this apparently limited area of
contamination near Well P-2. Since it was determined that
a site-wide ground water problem does not exist, the
remainder of the investigation focused on the Well P-2
area.
Well P-2 Area Investigation
The Well P-2 Area ground water investigation was
completed over several phases.
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In June 2004, soil and ground water samples were
obtained from 7 locations in the vicinity of Well P-2. The
samples were collected from several discrete intervals
below the ground surface, and the soil data was used to
determine if a source of uranium remained there. In order
to further define the area of contamination, ground water
from 9 additional locations was sampled in spring 2005.
Ground water was collected at five-foot intervals to a
maximum depth of approximately 50 feet below the
ground surface, which is where the bedrock starts.
These portions of the investigation revealed an area of
uranium contamination in the ground water limited in both
areal and vertical extent. The results showed that the
depth of contamination is limited to the shallow portion of
the aquifer just below the water table and extends laterally
for approximately 100 feet, to a location approximately 45
feet down-gradient of the former facility area. Samples
collected further up-gradient and down-gradient of these
locations, and at greater depths, contained significantly
lower concentrations of uranium, below drinking water
standards. Soil sample results did not identify a clear
source of uranium in ground water.
Based on the results obtained above, 10 additional
monitoring wells were installed in 2006. These wells were
installed at locations from which data can be obtained
within, below, and just outside of the area of contamination
over a long-term period. Ground water from these new
wells, along with 10 previously sampled wells, has since
been analyzed twice, in April and May 2006, for the
presence of radiological contamination. The results
confirm the earlier findings that the contamination is limited
in both areal and vertical extent. The results of data from
these wells were also used to determine that ground water
flows at a slightly upward gradient, which further limits the
migration of contamination to the deeper bedrock aquifer.
Since no source of contamination in the soil was located
during the 2004 and 2005 sampling efforts, additional soil
from USGS Orange. Wew Jersey 7 5 minute Qudc'fang/e, dated '955
COM
Figure 1
Site Location Map
U.S. Radium Superfund Site
Orange, New Jersey
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samples were obtained in spring 2006. Soil samples were
collected at approximately 50 locations on the former
facility property, with a large portion concentrated near
well P-2. Once again, samples were obtained from
discrete intervals down to bedrock in some locations. An
iterative approach was used, and additional locations were
sampled as results were obtained. Ground water was also
sampled at some locations to gain additional information
about the potential source area and flow patterns.
The soil investigation revealed that the bulk of the uranium
remaining in the soil was located over a relatively small
area of approximately 50 feet by 50 feet just up-gradient
of and encompassing Well P-2. The bulk of the elevated
uranium concentrations was also limited to a depth of
approximately 8 to 10 feet below the ground surface;
samples obtained from intervals deeper than this generally
had significantly lower concentrations of uranium These
results are in line with the results EPA obtained from Well
P-2, which draws water from a depth of 7 to 17 feet below
the ground surface; water from Well P-2D, which draws
water from 33.5 to 43.5 feet below the ground surface
does not exhibit elevated concentrations of uranium.
As a result of these findings, additional soil removal was
initiated in July 2006. Approximately 200 to 400 cubic
yards of soil with slightly elevated concentrations of
uranium are being removed from the Site, and will be
disposed of at an appropriate off-site facility. This will
effectively remove the majority of the known source of the
ground water contamination.
It should be noted that the earlier excavation activities
conducted at the former facility area focused on the
presence of radium, which is the primary contaminant of
concern at the Site. A field screening process was used to
determine if all of the radium-contaminated soil had been
removed, but this process could not detect the presence of
uranium. As a result, this small area of uranium
contamination in soil was not addressed previously. This
is not, however, indicative of a site-wide problem, as
evidenced by the ground water sampling results and,
primarily, by the operational procedures that were utilized
by the former U. S. Radium Corporation, as described
below.
Historical Analysis
The first question that arose from the above findings was
how the uranium got into the soil. In order to answer this
question, the operational procedures used by the U.S.
Radium Corporation were reviewed.
The corporation would obtain ore containing naturally high
levels of radium. In order to extract the radium, the
uranium that was also present in the ore had to be removed.
Thus, acid was used to leach the uranium out of the ore
and, presumably, the uranium-rich acid waste was then
disposed of outside of the treatment building, either directly
onto the ground or into floor drains. Plans exist which
show the layout of the buildings that existed when the U.S.
Radium Corporation was operating and the uses of those
buildings. The area of contamination is outside of the
footprint of any of the buildings that existed and on a
corner of the former facility property. Therefore, the
presumed operational procedures employed by the
corporation support the findings of the investigation.
Geochemical Analysis
Once it was understood how the uranium got into the
ground water, the next question became why is it not
moving significantly off-site. The area of contamination
has essentially remained stationary since it was first placed
there approximately 90 years ago. In order to understand
this, a geochemical analysis was performed.
Several possible explanations for the low-mobility of the
uranium were explored, including adsorption and
coprecipitation. Adsorption is the process whereby an ion
in solution adheres to the surface of a soil or sediment grain
in contact with it. These adsorbed substances will then not
move with the ground water flow. Coprecipitation occurs
when an element, such as uranium, is incorporated into a
solid mineral, thus affecting the mobility of the substance.
Some major factors that may affect the mobility of uranium
in ground water include the pH of the water, the oxidation-
reduction potential of the water (Eh), carbonate and
phosphate levels in the water,
organic carbon levels, and the nature of the soil and/or
sediment in the aquifer.
In this case, it was found that neither adsorption nor
precipitation of pure uranium were the dominant processes
affecting the mobility of the uranium. Rather, pure
uranium is being reduced to another form which then
coprecipitates easily with another mineral, calcite. Organic
carbon levels in the aquifer increase just down-gradient of
Well P-2, and thus the uranium is removed from the ground
water as it flows away from the Site.
While the above explanation is greatly simplified, more
detail can be found in the Remedial Investigation report.
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The results of the geochemical analysis correspond with
the uranium concentrations that have been actually
detected in the ground water. The analysis provides an
adequate explanation of why the uranium contamination
was found over such a limited area, and also provides
assurance that the area of contamination will not likely
expand in the future.
SCOPE AND ROLE OF THE ACTION
The remediation of the Site has been addressed in three
operable units. OU1 and OU2 were the subject of prior
RODs and have been addressed.
This action, referred to as OU3, is intended to be the final
action for the Site. This Proposed Plan summarizes the
rationale for the preferred No Action alternative to address
ground water at the U. S. Radium Site.
SUMMARY OF SITE RISKS
As part of the RI for the ground water, two baseline
human health risk assessments (BHHRA) were performed.
A BHHRA is an analysis of the potential adverse human
health effects caused by exposure to hazardous substances
from a site in the absence of any actions or controls to
mitigate that exposure under current and potential future
land uses.
The first BHHRA was based on the results of the site-wide
investigation and excluded data from the P-2 Well. The
second BHHRA was based on data obtained during the
Well P-2 Area investigation.
Site-Wide Risk Assessment
As described in the box "What is Risk and How is it
Calculated?", the site-wide BHHRA followed a four step
process that includes: Hazard Identification, Dose
Response, Exposure Assessment, and Risk
Characterization. A brief description of the results of each
of these steps is provided below.
Hazard Identification: The BHHRA used data meeting all
appropriate QA/QC requirements. The assessment
identified a number of Contaminants of Potential Concern
(COPCs) that were evaluated in the BHHRA. Based on
this analysis, the primary COPCs evaluated included
radium, radon, thorium, and uranium.
Dose-Response: Toxicity data was obtained form EPA's
consensus toxicity database, the Integrated Risk
Information System, and other appropriate sources
including the Health Effects Assessment Tables. Toxicity
data included radionuclide-specific toxicity values for
cancer and non-cancer health effects. Toxicity values for
inhalation, dermal absorption, and ingestion of COPCs in
ground water were selected based on the potential routes of
exposure and available toxicity information.
Exposure Assessment: The BHHRA focused on future
health effects to both adult and child residents exposed to
ground water from the overburden water bearing used being
used as a tap water source in the future. Exposure routes
included ingestion and dermal contact with the water, and
inhalation of the COPCs while showering. The BHHRA
evaluated exposures in the absence of institutional controls
or remedial actions. Reasonable Maximum Exposure
(RME) assumptions were used to be protective of human
health and account for uncertainties
in the risk assessment process.
Risk Characterization: Data from the previous steps were
combined to calculate cancer risks and non-cancer health
hazards, which are expressed as a total Hazard index (HI).
The site-wide BHHRA found that the potential future risks
were within the upper bounds of the risk range for cancer of
10"6 to 10"4, and below an HI of 1 for non-cancer. The total
RME cancer risk for adult and child residents exposed to
the Site ground water was 3x10"4, where approximately
90% of this risk is associated with inhalation of radon in
the air while showering from ground
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WHAT IS RISK AND HOW IS IT CALCULATED?
A Superfund human health risk assessment is an analysis of the
potential adverse health effects caused by hazardous substances
released from a site in the absence of any actions to control or
mitigate these releases; it estimates the "baseline risk" in the
absence of any remedial actions at the site under current and
future land uses. To estimate this baseline risk at a Superfund
site , a four-step process utilized for assessing site-related
human health risk for reasonable maximum exposure (RME)
scenarios.
Hazard Identification: The hazard identification step identifies
the contaminants of potential concern (COPC) in ground water
for this specific site. Factors considered include: toxicity,
frequency of occurrence, fate and transport of the contaminants
in the environment, concentrations of the contaminants in
specific media, mobility, persistence, and bioaccumulation.
Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples of exposure pathways for a groundwater site include
ingestion of groundwater and inhalation of volatiles while
showering. Factors relating to the exposure assessment include
but are not limited to the concentrations that people might be
exposed to and the potential frequency and duration of
exposure. Using these factors, a RME scenario, which portrays
the highest level of human exposure that could reasonably be
expected to occur is calculated.
Toxicity Assessment: The toxicity step determines the types of
adverse health effects associated with exposures to chemicals
or radionuclides, and the relationship between the magnitude
of exposure (dose) and severity of adverse effects (response).
Potential health effects are chemical or radionuclide-specific
and may include the risk of developing cancer over a lifetime
or other non-cancer health effects such as changes in the
normal functions of organs within the body (e.g., changes in the
effectiveness of the immune system). Some chemicals are
capable of causing both cancer and non-cancer health effects.
Risk Characterization: This step summarizes and combines
outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are evaluated
based on the potential risk for developing cancer and the
potential for non-cancer health hazards. The likelihood of an
individual developing cancer is expressed as a probability. For
example, a 10 4 cancer risk means a "one in ten thousand
excess cancer risk"; or one additional cancer maybe seen in a
population of 10,000 people as a result of exposure to site
contaminants under the conditions explained in the exposure
assessment. Current federal Superfund guidelines for
acceptable exposures are an individual lifetime excess cancer
risk in the range of 104 to 106 (corresponding to a one-in-ten-
thousand to a one-in-a-million excess cancer risk). For non-
cancer health effects, a "Hazard Index" (HI) is calculated. An
HI represents the sum of the individual exposure levels
compared to their corresponding Reference Doses (RfDs). The
key concept for a non-cancer Hazard Index is that a "threshold
level" (measured as an HI of 1) exists below which non-cancer
water. The concentrations of radon present in the ground
water are naturally occurring and not site-related.
Well P-2 Area Risk Assessment
The same four-step process was used for the Well P-2 Area
risk assessment. It was based on the maximum detected
concentration of each COPC in the focused Well P-2 Area.
This risk assessment showed that, even at Well P-2, the
potential future cancer risks were within the upper bounds
of the risk range. The non-cancer hazard index slightly
exceeded the threshold level of 1 for a potential future
receptor, with a total HI of approximately 4 for the RME
future resident, while the Central Tendency, or average,
exposures resulted in an HI of approximately 2. The future
residential scenario assumed the RME individual would be
exposed to only this small geographic area and would
obtain all of their drinking water from only this one
locatioa EPA has taken actions through the removal
program to remove the source in this area, which will
further reduce the potential future non-cancer hazard
identified above. EPA will continue to monitor the wells in
and around this area to assure the remedy remains
protective.
Ecological Risks
The need for an ecological risk assessment was evaluated
during OU1 and OU2 of this Site. There are no exposure
pathways for ecological receptors to ground water at this
Site. Therefore, an ecological risk assessment was not
performed as part of this investigation.
EVALUATION AND SUMMARY OF THE
PREFERRED NO ACTION ALTERNATIVE
After careful consideration of the site-specific details and
analysis of all data collected, EPA has determined that a No
Action remedy, with monitoring, is the preferred remedial
approach. EPA has determined that this remedial approach
is protective of human health and the environment based on
the following:
• Currently, water is provided to the residents in the
vicinity of the Site via the local water company. There
is presently no elevated risk posed by the Site ground
water since no potable wells are located within the
contaminated area or considered threatened by the
contaminated area. The supply well that provides
water to area residents has been tested several times
and does not contain elevated concentrations of site-
related contaminants. Further, water from the supply
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well is regulated by NJDEP and is tested on a regular
basis. The supply wells are not threatened by site-
related contamination for two primary reasons. First,
the area of contamination is not moving significantly
from where it is now. Second, even if it were to move,
the supply wells draw water from the bedrock aquifer,
which is significantly deeper than the affected water.
Furthermore, the presence of an upward gradient
within the bedrock zone creates a hydraulic barrier
which limits the migration of contaminants from the
shallow aquifer.
• A geochemical analysis of the Site data provides a
scientific basis for why the area of contamination is
neither moving nor expanding significantly. The
geochemical processes that are occurring at the Site
will continue into the future.
• Although non-cancer human health risks to potential
future residents are slightly elevated, this would only
occur if a potable well were installed in the Well P-2
area, which is considered highly unlikely. The extent
of contamination is limited and does not intersect any
current or potential future residential properties.
Further, the depth of contamination is shallower than
a potable well would likely be installed. Finally, all
area residents are supplied with municipal water; there
is no reason to install a potable well.
• Concentrations of uranium in the area of
contamination are expected to decrease with time,
since the bulk of the source of the contamination in the
soils is being removed.
As part of the No Action remedy, a ground water
monitoring program will be implemented. The monitoring
will assure that the No Action remedy remains effective
and protective of human health and the environment. The
monitoring program may be modified on an on-going basis
depending upon the sampling results obtained. Currently,
EPA does not believe that additional wells will be required
for the purpose of the sampling program. However, if the
results of any sampling round indicate that additional wells
are necessary, they will be installed. If all results clearly
show that uranium concentrations in ground water
decrease to levels below drinking water standards, then
monitoring may be discontinued. Alternatively, additional
action may be taken if monitoring shows that it is
warranted.
The present worth cost of the initial monitoring program,
which is anticipated to include semi-annual testing of the
20 wells that were sampled in 2006 and last for five years,
is estimated to be approximately $360,000. Because
contamination is being left in place, a Five-Year Review
will be required. Since the bulk of the source of the
uranium contamination is being removed, EPA anticipates
that the concentration of uranium in ground water will
decrease and that drinking water standards will be met by
the end of the first five years of monitoring.
The preferred No Action remedy for the Site has been
developed based on the findings contained in the Remedial
Investigation Report for OU3, which includes the baseline
Risk Assessment, a Focused Risk Assessment
memorandum developed for the Well P-2 Area, and a soil
investigation report prepared by EPA. As described herein,
the remedy does include ground water monitoring to ensure
that the public is not exposed to the small area of site-
related ground water contamination at the Site. EPA
believes the preferred remedial approach is protective of
human health and the environment.
COMMUNITY PARTICIPATION
EPA and NJDEP provide information regarding the cleanup
of the U.S. Radium Site to the public through public
meetings, the Administrative Record file for the Site, and
announcements published in the Star Ledger and the
Orange Transcript. EPA and the State encourage the
public to gain a more comprehensive understanding of the
Site and the Superfund activities that have been conducted
there. The dates for the public comment period, the date,
location and time of the public meeting, and the locations of
the Administrative Record files, are provided on the front
page of the Proposed Plan. EPA Region 2 has designated a
public liaison as a point-of-contact for community concerns
and questions about the federal Superfund program in New
York, New Jersey, Puerto Rico, and the U.S. Virgin
Islands. To support this effort, the Agency has established
a 24-hour, toll-free number that the public can call to
request information, express their concerns, or register
complaints about Superfund.
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For further information on the U.S. Radium Site, please contact:
Stephanie Vaughn Pat Seppi
Remedial Project Manager Community Relations Coordinator
(212)637-3914 (212)637-3679
U.S. EPA
290 Broadway, 19lh Floor.
New York, New York 10007-1866
The public liaison for EPA's Region 2 office is:
George H. Zachos
Regional Public Liaison
Toll-free (888) 283-7626
(732) 321-6621
U.S. EPA Region 2
2890 Woodbridge Avenues, MS-211
Edison, New Jersey08837
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