United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
•EPA/ROO/R03-88/057
September 1988
&EPA
Superfund
Record of Decision
Ambler Asbestos, PA
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30373-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/Rnn/sn3-88/Q57
3. Recipient's Accession No.
4. Till* and Subtitle
SUPER*FUND RECORD OF DECISION
Ambler Asbestos Piles, PA
l—art-inn
5. Report Date
09/30/88
Authors)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contraet(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
1ft. Abstract (Limit: 200 words)
The Ambler Asbestos Piles site is located in the southwestern portion of the Borough
of Ambler, Montgomery County, Pennsylvania. Land around the site is used for
industrial, residential, commercial, and transportation purposes. The site is bordered
on the west by Wissahickon Creek and its flood plain. A low density housing development
lies to the southwest. The site consists of four distinct areas of asbestos
contamination: the Locust Street pile, the Plant Pile, the Pipe Plant Dump, and the
^asbestos settling basins/filter bed lagoons. The waste piles of concern in this
Operable unit are the .Locust Street Pile and the Plant Pile. Within a 0.25 mile radius
of the Locust Street Pile are approximately 40 residences and a public playground that
was closed in 1984. The K&M Company owned and operated the site from the late 1800s to
1962, and produced asbestos products such as paper, millboard, electrical insulation,
linings, conveyor belts, and high pressure peckings. The primary wastes generated and
disposed of in the Locust Street and Plant Piles during that period were spent
magnesium/calcium (from pharmaceutical operations) and asbestos process waste, in 1962,
Certainteed Corporation purchased a portion of the site and facilities from K&M and
manufactured asbestos-cement pipe at the plant. Nicolet Industries, Inc. purchased the
remainder of the site and manufactured asbestos millboard and monolithic products. The
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Ambler Asbestos Piles, PA
First Remedial Action
Contaminated Media: sw, sediments, debris
Key Contaminants: asbestos
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
I Availability Statement
19.
(This Report)
20. SetUN&eClass (This Page)
21.
Pages
22. Price
(See ANSI-Z39.18)
See Instructions on Reverie
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-88/057
Ambler Asbestos Piles, PA
First Remedial Action
16. ABSTRACT (continued)
Locust Street Pile continued to receive asbestos waste from Nicolet until sometime after
1964; however, waste continued to be deposited on the Plant Pile until 1980. EPA and
the Pennsylvania Department of Environmental Resources conducted their first
investigation of the site in 1971, noting visible emissions and substantial dust
concentrations attributed to asbestos. Subsequent investigations of the surface water,
bulk waste samples and air samples in 1983 revealed asbestos contamination. In
September 1983, the Centers for Disease Control issued a Public Health Advisory
recommending the closure of the nearby playground. In 1984, EPA implemented emergency
response actions to establish a soil and vegetative cover, install a drainage system,
and provide erosion control measures over the Locust Pile. In addition, Nicolet had
covered the Plant Pile by June 1984. The primary contaminant of concern affecting the
sediments, surface water, and debris is asbestos.
The selected remedial action for this site includes: installation of a geotextile and
soil cover on the exposed areas of waste piles; erosion control/repair on waste pile
slopes to facilitate vegetation; pump and treatment {using filters) of surface water
from lagoon and settling basins with onsite discharge, backfilling and regrading lagoon
and settling basins to promote positive drainage, and onsite disposal of collected
sediments and asbestos on the waste piles; implementation of slope stability control
measures, if deemed necessary after testing; installation of gabions or rip-rap to
prevent scouring action of Wissahickon Creek on the waste piles; runoff collection and
treatment; preparation of a contingency plan; and access restructions. The estimated
capital cost for this remedial action is $5,135,000, with estimated annual O&M costs of
$46,000 to $63,000 for years 2 through 6 and $33,000 for years 6 through 30.
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Record of Decision
Alternative Selection
Sitai Ambler Asbestos Piles, Ambler, Pennsylvania
Statement of Basis and Purpose
This decision document represents the selected remedial
action for the first operable unit at the Ambler Asbestos site,
in Ambler, Pennsylvania, developed in accordance with the Compre-
hensive Environmental Response, Compensation and Liability Act
of 1980, as amended by the Superfund Amendments and Reauthor-
ization Act of 1986 (CERCLA) , 42 U.S.C. Section 9601 ej: seq.
and to the extent practicable the National Contingency Plan
(NCP) , 40 C.F.R. Part 300. This decision is documented in the
contents of the administrative record for this site. The attached
index identifies some of the items which comprise the administra-
tive record upon which the selection of the remedial action is
based (the administrative record will be updated in the near
future) . The Commonwealth of Pennsylvania has concurred on the
remedy .
Description of th* 8*l*ct«d Remedy
The selected remedy for the first operable unit seeks to
prevent the release of asbestos from the site. A vegetative/ soil
cover will be installed over each of the two asbestos-containing
waste piles (Locust Street-Pile and Plant Pile) to prevent
airborne emissions, runoff will be collected and treated to
assure no waterborne asbestos can go off site.
Additional components of the selected remedy are as follows:
- A geotextile and soil cover will be installed on the
exposed plateau areas of the Locust Street and Plant
Piles and on the exposed side slope areas of the Locust
Street Pile.
- Repair to erosion on waste pile slopes due to storm events,
soil creep, freeze/thaw effects, etc., will be implemented.
- Water from the lagoon and settling basins will be pumped
and filtered for removal of asbestos fibers. Discharge
of the treated water will occur on-site with placement
of filter backwash on waste piles.
- The lagoon and settling basins will be backfilled with
clean low permeability compacted soil bringing the depres-
sion up to grade to promote long-term positive drainage.
- Additional borings will be collected into and through the
pile side slopes to supplement slope stability analysis
previously performed.
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- Slope stability control measures will be analyzed and
implemented if the aforementioned studies are found to
provide evidence of slope instability.
- Gabions or rip-rap will be installed to protect the toe
of the Locust Street Pile from the scouring action of
the Wissahickon Creek.
- Erosion/sedimentation controls during remedial activities
will be implemented to facilitate the establishment of
vegetation.
- Air monitoring for asbestos will occur during remedial
activities (personnel and environmental).
- Post-closure inspections, maintenance of the piles, lagoon,
and settling basin areas, and preparation of a contingency
plan will be accomplished.
Other alternatives will be further evaluated as part of a
Preremedial Design study to determine whether to pilot test
for, and possibly institute, one of these alternatives for the
site. If found to be unacceptable, based upon EPA's evaluation
criteria under CERCLA for remedial actions, the Alternative 4
will immediately be implemented.
If any alternative processes are found to be acceptable,
based upon EPA's evaluation under CERCLA for remedial actions,
EPA would amend the ROD. Public comment would be solicited in
the event of ROD amendment.
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State Requirements that are
applicable or relevant and appropriate to this remedial action
and is cost-effective as set forth in Section 121 of CERCLA, 42
U.S.C. Section 9621(c) and Section 300.68 of the NCP. This
remedy satisfies the statutory preference as set forth in Sec-
tion 121(b) of CERCLA, 42 U.S.C. Section 9621(b) for remedies
that employ treatment that reduce toxicity, mobility or volume
of the hazardous substances, pollutants or contaminants. This
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. However,
because treatment of the principal threat of the site was not
found to be practicable, this remedy does not accomplish the
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statutocy preference for treatment as a principal element of
the remedy. It should be noted that, since asbestos cannot be
combusted and is essentially chemically inert, a permanent
remedy as such cannot be effectively implemented at this site.
Therefore this remedy becomes the only currently feasible
remedy under CERCLA for asbestos at this site.
Because this remedy will result in hazardous substances
remaining on site above health-based levels, a review will be
conducted bi-annually for the first five years after initiation
and of remedial action and yearly thereafter, and this complies
with the requirement for review set forth in Section 121(c) of
CERCLA, 42 U.S.C. Section 9621(c).
Date
fan ley L.
Acting Regional
EPA Region III
Administrator
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Site mii*- Descrition* and Location
The Ambler Asbestos Piles site is located in the south-
western portion of the Borough of Ambler, Montgomery County,
Pennsylvania (see Figures 1 and 2) . The site is bordered on
the west by the Wissahickon Creek and its floodplain; on the
northwest by Butler Pike, a major transportation route; on the
north by Locust Street; and on the southeast by Church Street.
A portion of the site extends westward from Ambler into Upper
Dublin Township, Montgomery County. The, Ambler Asbestos Piles
Site consists of the Locust Street Pile, the Plant Pile, the
Pipe Plant Dump, and the asbestos settling basins/filter bed
lagoons Nicolet Inc. is the current owner of the Locust Street
and Plant Pile, and the asbestos settling basins/ filter bed
lagoons. CertainTeed Corporation is the owner of the Pipe
Plant dump.
The waste piles of concern in this operable unit are referred
to as the Locust Street Pile and the Plant Pile. These piles
contain spent magnesium/ calcium carbonate and waste from the
manufacture of asbestos products. The primary contaminant of
concern at the site is asbestos.
Within a quarter mile radius of the Locust Street Pile are
approximately 40 residential dwellings and a public playground
that was closed in 1984. The center of the Borough of Ambler
lies approximately a half mile north of the Locust Street Pile
and the adjacent Plant Pile. A low density housing development
lies to the southwest of the Locust Street Pile separated by
the Wissahickon Creek and its floodplain in Whitemarsh Township,
Montgomery County.
Individual discussions of the Locust Street Pile, Plant Pile
and filter bed lagoons, along with the Pipe Plant Dump are
presented in the following subsections.
A. Loeuat Street Pile
The Locust Street Pile is approximately 1200 feet long
and 300 feet wide and averages 50 feet in height above grade.
According to the topographic map developed prior to the Removal
Action in 1984 (Figure 3) , the Locust Street Pile ranges in
elevation from approximately 240 feet above Mean Sea Level
(MSL) at the top of the southwestern portion of the pile to 170
feet above MSL at the base on the western side of the pile
adjacent to the Wissahickon Creek. The western side of the pile
is adjacent to Wissahickon Creek.
The Locust Street Pile side slopes range from 2.5:1 to
2.0:1 (horizontal: vertical) on the north, east and south, and
from 1.6:1 to 1.4:1 on the west. Slope lengths (angular) are
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roughly 75 to 100 feet on the west and east and 25 to 75 on the
north and south. The top of the pile is a relatively flat '
(0-3% slope) area which comprises approximately 20 to 25 percent
of the total pile (crest) area, a relatively flat (0-3% slope)
area which comprises approximately 20 to 25 percent of the total
percent of the total pile (crest) area.
A report prepared by Johnson and Schroder of the University
of Pennsylvania in 1977 for Nicolet Inc., stated that disposal
for asbestos began waste in the 1930's at the Locust Street
Pile Site. Disposal of general manufacturing waste may have
begun earlier than the 1930's since the manufacturing of phar-
maceutical and asbestos products at the site began in 1890's.
The report stated that a quarry had existed at the Locust Street
site prior to the disposal of wastes, but our investigation did
not support its existence.
Products manufactured in the 1930's includes asbestos
cement piping and shingles that required magnesium carbonate
(magnesia) as a raw material. The process of extracting magnesia
from dolomitic limestone produced 30 to 40 tons of carbonate
waste, per day. Once the quarry was filled (with spent magnesium
carbonate), cinders and slag from the boiler plant were used to
construct berms to contain the carbonate slurry. It was also
reported in the Johnson and Schroder report that dumping of the
carbonate waste on the northwest portion of the pile terminated
in the early 1940's. Aerial photographs of the Locust Street
Pile from 1950, 1964, and 1972 demonstrated continued dumping
on this northwest portion (plateau area) of the pile until the
late 1960's.
Deposition of wastes in the southern portion of the Locust
Street Pile as reported by Johnson and Schroder began at the
same time as the northwestern portion but received primarily
cinders and bad production runs of piping, shingles, and mill-
board. Dumping on the southern portion of the Locust Street
Pile was reported to have ceased in the late 1960's.
Analysis of waste samples taken from depths of 10-47 ft.
below the surface detailed in a University City Science Center
report, "Possible Health Hazards of Asbestos Waste Piles: Ambler,
PAN, (1975) indicate the carbonate waste consists of 70-85
percent calcium carbonate and 8-16 percent magnesium carbonate.
Analysis for asbestos was not performed at that time. Surface
samples taken by EPA's Emergency Response Team (ERT) and the
Technical Assistance Team (TAT) in 1983 prior to the Removal
Action from the Locust Street Pile indicated the presence of
both types of asbestos and in significant concentrations predom-
inantly on the large plateau area of the pile (Amosite 35-40%
and Chrysotile 0-8%). Amosite asbestos fibers were primarily
detected in samples taken from the side slopes of the Locust
Street Pile at concentrations of 0-5 percent. Chrysotile was
also found at concentrations of 2-10% in two of the ten samples
taken of the exposed side slopes.
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FIT team on May 12, 1986 which verified that no contaminants of
concern are migrating from this source.
Site History
The K & M Company owned the site from the late 1800's to
1962. The company initially operated as a pharmaceutical company
until 1897. The cornerstone of the K & M venture was milk of
magnesium hydroxide. The primary material used in the manufac-
ture of milk of magnesia is magnesium oxide. The plant was
located in Ambler due to the close proximity of large reserves
of dolomite from which the magnesia was extracted.
Asbestos products were produced by K & M from 1897 to 1962.
These included paper, millboard, electrical insulation, brake
linings, conveyor belt, and high pressure peckings (rubber and
asbestos).
The primary wastes generated at that time were spent
magnesium/ calcium carbonate (generated by the process of extrac-
ting magnesium carbonate from dolomite limestone) and asbestos
process waste including bad manufacturing runs and off-specifi-
cation products. Although, it was reported (Johnson and Schroder,
1977) that disposal activities did not begin on the Locust
Street Pile until the 1930's it is suspected that K & M used
the former quarry area (Locust Street Pile) to dispose of their
wastes.
During World War II, the K & M Plant became one of the
leading producers of asbestos products. During the period in
which K & M operated the plant, the Locust Street and Plant
Piles received much of the total volume of waste materials that
were deposited on the piles. Aerial photographs of the site
from 1950 prior to K & M selling the facility, indicate that
approximately 80 percent by surface area of the Locust Street
Pile was present. The northwestern portion of the pile was still
active in 1950 receiving a calcium carbonate slurry contained
by berms constructed of cinders. The southern portion of the
pile did not appear active in 1950.
Based on the 1950 aerial photographs, the Plant Pile was
approximately 60-70 percent complete and continued to receive
primarily carbonate waste. Since 1950, wastes were deposited
on the top of the piles contained by berms that were continuously
built up to contain additional waste.
By 1958 there were indications of continued activity on both
the Locust Street and Plant Piles. Additional material in the
form of gray slurry has been pumped on the large plateau area
of the Locust Street Pile. A large quantity of calcium/magnesium
carbonate slurry was also deposited on the Plant Pile since
1950 as evidenced by aerial photographs. No activity was evident
on the Pipe Plant Dump.
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B. Plant Pile
The Plant Pile is approximately 650 feet in length and
600 feet in width. According to the 1984 topographic map
(Figure the Plant Pile ranges in elevation from approximately
240 to 179 feet above MSL. The side slopes of the Plant Pile
range from 2.0:1 to 1.7:1 (horizontal: vertical) on the north,
1.7:1 to 1.4:1 on the east/ and 1.4:1 to 1.2:1 on side slopes
of the Plant Pile range from 2.0:1 to 1.7:1 (horizontal: the
south and west. Slope lengths (angular) are roughly 50 feet on
the south, 100 feet on the east and west, and 120 feet on the
north. The relatively flat (0-3% slope) area at the crest
comprises approximately 40 to 45 percent of the Plant Pile
area.
The Plant Pile is located southeast of the process plant
and the asbestos filter bed lagoons. Disposal of wastes, begin-
ning with calcium carbonate and magnesium hydroxide waste, was
initiated on the Plant Pile in 1940's after the capacity of the
Locust Street Pile was nearly reached (Johnson & Schroder, 1977).
The carbonate waste was deposited as a slurry and contained by
berms constructed of cinders and pumice rock. It was further
reported that prior to 1964 a paper machine contributed some
process waste. Aerial photographs of the Plant Pile from 1950
and 1958 demonstrate both a white and light gray slurry was
pumped onto the Plant Pile. The aerial photographs of the
Plant Pile from 1964, 1971, and 1978 show a change in the mater-
ial deposited on the pile. The material deposited during this
time was much darker than the material from previous photographs
but was still being deposited as a slurry* From 1970-1975 it
was reported that an asbestos cement sludge was pumped onto the
Plant Pile. .From 1975-76 asbestos millboard and the monolithic
product process waste was pumped as a slurry to the Plant Pile.
Continuous dumping was reported to have ceased in 1976; however,
aerial photographs from 1978 and 1981 indicate continued activity
on the Plant Pile.
C. Asbestos Settling gasina/filter Bed Lagoons
The asbestos settling basins and filter bed lagoons are
located between the Plant Pile and the Locust Street Pile. The
settling basins and filter bed lagoons received process waste-
water from the original manufacturing facility owned by Keasbey
and Mattison Company (X&M). After the plant was purchased by
Nicolet Industries, Inc. (now Nicolet Inc.) in 1962, the basins
and lagoons continued to receive wastewater from processing and
cooling operations. The two primary operations which reportedly
contributed to the asbestos waste entering the filter bed
lagoons are the millboard machines and the monolithic press.
Based on aerial photography, the sludge from the lagoons was
apparently dumped on the Plant Pile until 1978-79 via a pipeline.
The lagoons received process wastewater, but the sludge was
hauled off-site for disposal. Both the millboard machines and
the monolithic press operations have been taken out of operation.
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The only processed wastewater received as of the date
of this document is non-contact cooling water from the sheet
gasket machines, so little if any sludge should be produced.
The most recent operational information concerning the wastewater
management program, provided by Nicolet Inc., is dated July 25,
1979.
Beginning in 1973, the Pennsylvania Department of Environ-
mental Resources (FADER) ordered Nicolet to stop dumping on the
waste piles. This directly included the sludge from the filter
bed lagoons. Nicolet maintains that in 1979 they installed a
pelletizer unit to reduce solids entering the lagoons.
Based on information provided in the National Pollutant
Discharge Elimination System (NPDES) permit application filed
by Nicolet, Inc. on July 1, 1982, flow to the lagoons is 0.626
Million Gallons Per Day (MGD) and originates from the operations
shown in the flow diagram in Figure 5. The primary water contam-
inant reported at that time was asbestos which originated from
the millboard and monolithic press operations. Other potential
contaminants that were identified on the application as "believed
to be present" were chlorine, nitrogen (total organic), and
surfactants. Wastewater from boiler blowdown and solvent recovery
decant water is currently discharged to the Ambler Waste Water
Treatment Plant (Ambler WWTP). The decant water contains methanol
and toluene. Discharge of these waste streams to the Ambler
WWTP began in 1980. Prior to this time, however, these process
flows were also apparently discharged into the lagoons as evidenWQ
by residual organic odor detected emanating from the lagoons by
EPA and the Remedial Investigation (RI) investigation team during
the site visits for the studies.
D. Pipe Plant pmnp
Adjacent to the Plant Pile, there is a previous dump site
identified as the "Pipe Plant Dump." This pile reportedly
received primarily asbestos-containing solid pipe scrap from
1962 to 1974. The Pipe Plant Dump was covered and vegetated in
1974 by the owner (CertainTeed Corporation). The Pipe Plant
Dump is not currently part of this Record of Decision (ROD).
The Pipe Plant Dump is part of the site on the National Priori-
ties List (NPL) and therefore requires an RI/FS Remedial Inves-
tigation/Feasibility Study (RI/FS) to complete an Endangerment
Assessment of this Pile. An RI is currently being conducted by
CertainTeed Corporation, the Potentially Responsible Party
(PRP) for the Pipe Plant Dump. A second ROD will be issued in
the future for this second operable unit.
On November 11, 1985, the CertainTeed Pile was inspected
by U.S. EPA, PADER, the REM II team, and CertainTeed Corporation.
The cover on the pile was found to be in good condition and
well vegetated. Little evidence of erosion and scouring along
the south side by the unnamed tributary was observed. Surface
water samples from the unnamed tributary were taken by the EPA
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In 1962, CertainTeed Corporation, a manufacturer of construc-
tion materials, purchased a portion of the site and plant facil-
ities from K & M, including the pipe manufacturing plant and THE
Pile. Thereafter, CertainTeed manufactured asbestos-cement
pipe at the plant. Nicolet Industries, Inc., a manufacturer of
building and automobile supplies, purchased the remaining plant
facilities along the Locust Street Pile, the Plant Pile, and
the asbestos filter bed lagoons.
The aerial photograph of the site taken in 1964, following
the purchase of the Locust Street and Plant Piles by Nicolet
Industries, Inc., indicate disposal activity on the plateau
areas of both piles since 1958. Wastes were apparently being
deposited as a slurry but were dark gray and black in color
compared to the white and light gray color of the waste in the
previous aerial photographs. It appears then that the wastes
deposited on the piles following the purchase of the site by
Nicolet changed from primarily calcium/magnesium carbonate to
process waste from the asbestos millboard and monolithic product
manufacturing. This darker material may be sludge from the
filter bed lagoons.
The 1964 photographs also shows the deposition of wastes
on the CertainTeed Pile that included), asbestos-cement shingles,
acoustical products and asbestos-cement piping. The wastes
deposited were solids consisting of off-specification piping
and process waste from the asbestos-cement pipe manufacturing
facility.
The aerial photograph of the site nine years after the
purchase of the Locust Street and Plant Piles by Nicolet Inc.
indicate that disposal on the Locust Street Pile ceased sometime
after 1964. Vegetation was evident on the two large plateau
areas of the northwestern portion of the Pile and trees had
grown along the slopes of the southern portion of the pile
where no activity had been identified since 1950. Conversely,
dark flow patterns on the Plant Pile indicated continued disposal
of wastes. Trees were subsequently noted on the Plant Pile in
1971.
PADER and EPA became actively involved with the site in 1971,
when a complaint was lodged with EPA by the Executive Director
of the Wissahickon Valley Watershed Authority. From November
21, 1971 to January 18, 1972, a field survey water and air contam-
ination at the site was conducted by EPA. Visible emissions
were noted and substantial dust concentrations were measured
and attributed to asbestos contamination.
In December 1971, Nicolet Industries, Inc. applied for
approval to continue to dump on the Plant Pile. While this
application was pending they continued to dump. Aerial photographs
of the site from 1978 indicate continuous disposal on the Plant
Pile since 1971. In 1973, PADER ordered Nicolet to stop dumping
and to cover and stabilize the Plant Pile. Nicolet then applied
for a solid waste management permit.
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In February 1974, PADER issued an order to both Nicolet and
CertainTeed concerning the termination of disposal operations.
Shortly thereafter, CertainTeed Corporation discontinued its
operations at the site, covered and vegetated the CertainTeed
Pile, and moved operations out of the region; CertainTeed still
retains ownership of the pile. Nicolet, however, appealed the
PADER order and was subject to a subsequent order by PAOER to
cease its solid waste disposal. Nicolet continued dumping
until 1980.
Aerial photographs of the site from 1984 showed a different
flow pattern in the deposited waste on the Plant Pile than the
1978 photograph. In November 1978, amid increasing national
concern about asbestos and other industrial wastes, EPA placed
the Ambler site on a list of regulated asbestos sites pursuant
to National Emissions Standards for Hazardous Air Pollutants
(NESHAPS).
On June 2, 1983 the EPA's FIT team conducted a sampling
program of the Locust Street Pile that included surface
water, bulk waste samples and air samples. The results of the
sampling program revealed downstream concentrations (260 MFL)
of chrysotile fibers to be 10 times greater than the upstream
concentrations (18 MFL). Bulk samples from the Locust Street
Pile contained up to 30 percent chrysotile asbestos fibers and
•3 percent amosite fibers. On September 15, 1983, U.S. EPA
Region III On-Scene Coordinator (OSC) tasked the Technical
Assistance Team (TAT) to conduct an assessment at the asbestos
waste piles at the Nicolet, Inc. property. During the investi-
gation, the TAT team observed steep, unvegetated and eroded
slopes.
On September 27, 1983, the initial site assessment was
conducted by the EPA Emergency Response Team (ERT), the PADER
and the TAT. Air samples, bulk surface samples, and wipe samples
from the playground equipment adjacent to the asbestos waste
piles were collected. The samples were analyzed for asbestos
and tested positive in the bulk surface samples and in the wipe
samples. As a results these findings, the Centers for Disease
Control (CDC) issued a Public Health Advisory recommending the
closure of the playground. The OSC submitted a Request for
Emergency Funding to initiate actions to alleviate the health
risk caused by the piles.
On December 15, 1983, in accordance with CERCLA Section 104
and Section 300.65 of the NCP, EPA determined that the site
posed an imminent and substantial danger to the public health
and welfare and made the decision to proceed with an emergency
response action. EPA requested that Nicolet cover the piles.
However, Nicolet replied that it would not comply with the
specific terms outlined by EPA.
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District of Pennsylvania issued an order allowing EPA access to
the Nicolet site in order to perform an emergency response
action pursuant to Section 104 of CERCLA.
The EPA proceeded to implement the emergency response actions
at the site/ which included:
- Covering the Locust Street Pile with six to eighteen
inches of soil;
- Stabilizing the covered slopes with erosion control
netting;
- Hydroseeding the Locust Street Pile to minimize
erosion;
- Installing a drainage system for the Locust Street
Pile and;
- Dismantling and removing the Locust Street playground.
Covering of the Locust Street Pile was completed on July 22,
1984. EPA completed all drainage work, erosion control, and
fencing by October 12, 1984. Upon completion of these tasks,
EPA sampled several neighborhood homes for asbestos fibers and
reported that nearby homes had not been contaminated by asbestos
fibers during activity at the site. This latter activity was
completed May 21, 1985.
In an independent effort, Nicolet began covering the Plant
Pile on or about April 16, 1984, and completed the effort on
June 1, 1984.
A site visit conducted by EPA on April 1, 1985 revealed
erosion of the cover of the Plant Pile, while the Locust Street
Pile was intact. EPA, Nicolet, and the REM II team personnel
conducted joint initial site inspections on June 3 and June 11,
1985 to determine the scope of any required initial measures.
It was recommended that the former playground area be landscape
maintained for aesthetic, and vermin and insect management
purposes.
In March 1985 EPA initiated the Workplan for the Remedial
Investigation and Feasibility Study. The Study was completed
August 1988.
CHRONOLOGY
Dates Bv«nt
1890's K & M Company started manufacturing pro-
ducts and disposed of pharmaceutical and
asbestos waste adjacent to the plant in
Ambler, PA.
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Dates
Early
1930's
Early
1940's
1962
3/71
11/15/71
12/2/71
12/13/71
- 9 -
Event (Cont.)
Waste disposal at the Locust Street Pile
was ongoing. The majority of the waste
disposed on the pile consisted of carbonate
residues from the processing of dolomitic
limestone for the extraction of magnesia.
The waste, in the form of a slurry, was
added to the pile at a rate of 30 to 40
tons per day.
Waste disposal at the Plant Pile began.
Wastes disposed of from 1933 to 1962 included
primarily a calcium carbonate slurry and
later process waste from the asbestos
paper machine operation.
Nicolet Industries Inc. purchased most of
the K&M facility including the Locust
Street Pile, Plant Pile and filter bed
lagoons. CertainTeed Corporation purchased
the pipe manufacturing plant and the Pipe
Plant Dump. Both companies continued to
dump their wastes that consisted mostly of
asbestos process waste and off-spec asbestos!
products.
NESHAP listed asbestos as a hazardous air
pollutants.
EPA Region III received a complaint from
the Executive Director of the Wissahickon
Valley Watershed Authority about asbestos
contamination of ambient air and the Wissa-
hickon -Creek, a tributary to the Schuylkill
River.
Nicolet applied to PADER for a permit to
continue using the piles for disposal of
asbestos waste. Nicolet was required to
have a permit under the PADER Solid Waste
Management Act of 1968.
EPA field investigation started. Residents
reported visual evidence of asbestos dust
in homes and the playground on Locust
Street whenever windy weather occurred.
Also, surface water samples on the property
indicated that waste streams leaving the
CertainTeed and Nicolet Piles contained
asbestos in excess of background concentra-'
tion limits specified in 1971 Water Quality
Criteria published by EPA in "Quality Cri-
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-10-
Dataa
1/3/72
3/2/72
4/6/73
9/10/73
10/22, 23,
& 24/73
2/19/74
3/3/74
Event (Cont.)
teria for Water" (the Red Book). These
criteria for asbestos were later replaced
by criteria published in 45 F.R. 79318
(November 28, 1980).
Ambient air monitoring was initiated by EPA
Region III. Field testing found 690 mg/m3
and 270 mg/m3 dust in ambient air at
sites near the two plant locations, a
great portion of which was attributed to
asbestos presence.
CertainTeed applied to PADER for a permit
to continue using the piles for asbestos
waste disposal.
National Emissions Standards for Hazardous
Air Pollutants (NESHAPS) for asbestos were
promulgated by EPA with amendments proposed
on 10/25/74 clarifying operation of waste
disposal sites for asbestos. "No visible
emissions" standard enacted for milling and
manufacturing of asbestos products.
EPA Region III visited the asbestos piles
at Nicolet and CertainTeed. Arrangements
were made to sample ambient air over and
around the piles.
Ambient asbestos air monitoring was conduc-
ted. The following asbestos concentrations
were recorded:
- CertainTeed pile (114.5 ng/m3)
- Nicolet Pile (41-114 ng/m3)
- Nicolet settling lagoons (1,563 ng/m3)
- Locust Street playground (10 ng/m3)
PADER issued an administrative order to
Nicolet Industries and CertainTeed Corp.
to cease dumping asbestos waste onto the
piles. Pile access was limited and covering
was ordered to be with material suitable
for planting and growing vegetation. The
piles were to be stabilized and water
percolation and surface water management
planned.
CertainTeed signed a consent order with
PADER and agreed to follow PADER legal
order of 2/19/74.
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- 11 -
Dates event (Cont.)
4/17/74 PADER was told by Nicolet that they could not
comply with PADER order of 2/19/74.
6/25/74
10/14/75
11/78
3/79
6/83
9/83
12/83
12/15/83
3/26/84
4/84
9/84
EPA proposed clarifying amendments to NESHAPS
that regulate active and inactive sites for
land disposal of asbestos wastes.
EPA promulgated clarifying amendments to
NESHAPS that regulated active and inactive
asbestos waste sites. 40 C.F.R. Section
61, Subpart M regulates the operation of
waste asbestos dump sites. Waste collection
and disposal included under "no visible
emissions standard."
EPA placed the Ambler site on a list of
NESHAPS asbestos sites among growing concern
over the effects of asbestos.
EPA initiated a technical assistance program
to help schools identify and control friable
asbestos-containing materials.
NUS FIT sampling and testing performed on-
site (air, waste, and water).
OSC, ERT, and TAT sampling and testing
performed on-site (air, waste, and wipe
samples).
The Centers for Disease Control issued a
Public Health Advisory recommending, among
other things, the closure of the playground
located on the toe of the east side of the
Locust Street Pile.
CERCLA fund authorization was obtained for
an emergency response action at the site.
An emergency response action was undertaken
which involved establishing a vegetated soil
cover, placement of erosion control netting,
and surface drainage system for the Locust
Street Pile and playground site area. The
playground was closed, dismantled and removed.
ERT sampling and testing performed (air).
ERT residential sampling performed (air and
waste).
-------
Dates
10/84
5/85
.6/85
10/85
11/85
6/6/86
9/3/86
9/ 30 -
10/2/86
12/29/86
8/21/87
- 12 -
Event (Cont.)
Site proposed for inclusion on NPL.
REM II and EPA began RI/FS (Work Plan Phase)
under CERCLA (Superfund).
REM II, EPA, and Nicolet conducted initial
RI/FS site inspection.
Landscape maintenance of former playground
area along Chestnut Street performed by a
subcontractor to REM II.
CertainTeed Pipe Plant Dump (and other site
areas) inspected by U.S. EPA, PADER, and
the REM II team. Nicolet agreed to a
partial records search by EPA and REM II,
which was performed.
Site ranked 523 of 703 on the NPL.
Public meeting held at Ambler Borough Hall
to present the RI/FS Work Plan.
A site inspection along with ambient air
sampling, as part of the Designated Activi-
ties, was conducted by the REM II team.
RI field investigation conducted by the
REM II team. Waste, cover soil, surface
water, sediment, and ambient air samples
collected and sent for analysis through
EPA's Contract Laboratory Program (CLP) .
During the removal action at the Ambler Asbestos site in
1984, EPA worked closely with Ambler Borough officials in dis-
seminating information to the public. The residents who live
on Locust Street the ones mostly interested in the site, since
the playground that was their childrens' only recreation area
had to be closed due to its close proximity to the asbestos
piles.
On September 3, 1986 EPA held a public meeting to announce
the start of the Remedial Investigation and Feasibility Study
(RI/FS) . During the months prior to the meeting, Borough offi-
cials became interested in the vitrification process by Vitrifix,
Inc. to treat the asbestos piles. EPA met with the local offi-
cials at the beginning of the RI and assured them that the process
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- 13 -
would be reviewed along with other cleanup alternatives during
the Feasibility Study (FS) phase.
An advertisement was placed in the Philadelphia Inquirer on
May 31, 1988. The ad listed all of the cleanup alternatives
and announced EPA's preferred alternative and started a 30 day
public comment period for the proposed plan and RI/FS.
A public meeting was held on June 16, 1988 in accordance
with Section 117(a)(2) of CERCLA, 42 U.S.C. Section 9617 (a)
(2) and 40 C.F.R. Section 300.67 (d) with about 25 attendees in
addition to Ambler Borough Council, PAOER and EPA representatives.
The residents requested EPA to place the site fence and signs
as close to the piles as possible. The Mayor and Borough Council
requested EPA to meet with other companies including Vitrifix,
since the local officials are not in favor of EPA's containment
alternative, and would prefer EPA look into other innovative
technologies for remediating the asbestos piles.
The Borough Council and Nicolet, Inc. also asked EPA to
extend the comment period thirty days. Originally EPA extended
it only to July 13, then granted the request, ending the comment
period on July 29. Another request for an additional three
months came into EPA from Council. EPA did not extend the
comment period, but did agree to meet with Borough officials on
September 22, 1988. Ambler Borough Council invited their tech-
nical expert to the meeting. They asked that the Record of
Decision not be signed so that their technical expert could
look into other companies with innovative technologies for
remediating the site. EPA explained that the signing of the
ROD signifies that the containment alternative has been chosen,
but the signing does not preclude the Agency from meeting with
other companies with other innovative alternatives. . A letter
was sent to EPA Region Ill's Deputy Regional Administrator
requesting delay of the ROD signing. That letter was received
from the Ambler Borough solicitor on September 26, 1988.
As described above, EPA has met the public participation
requirements of Sections 113 (K) (2) (B) and Section 117 of
CERCLA, 42 U.S.C. Section 9617.
p Problsa
The ERT and TAT sampling and testing on and near the Ambler
Asbestos Piles site demonstrated that asbestos fibers had migrated
off the manufacturing site into adjacent public areas which
included a neighborhood playground as evidenced by air, waste,
and wipe sampling/ analysis. The CDC issued a public health
advisory closing the playground based on the evidence of air
transport of asbestos fibers from the piles to areas where human
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- 14 -
contact could result from inhalation or ingestion, and an Imme-
diate Removal Action was implemented in 1984.
The side slopes and some of the flat areas of the Locust
Street and Plant piles are now covered as the result of the
Removal Action by the EPA and an independent effort by Nicolet
respectively. The large plateau areas of both piles remain
uncovered. Portions of the slopes of the Locust Street Pile
where large trees have grown are also exposed. Evidence of
erosion and sloughing of the cover were evident on both piles
during the RI. The currently exposed areas of both piles
and/or future source areas of both piles exposed due to cover
or .slope failure create the potential for release of asbestos
fiber to the ambient air that can be inhaled by local residents,
and/or continued contamination of the adjacent surface water.
Phvaiograohv
The Ambler Asbestos Piles site lies within the Delaware
River drainage basin. The area is characterized by relatively
flat topography with occasional rolling hills with the greatest
change in relief occurring along the flood plains of the many
creeks and tributaries that flow through this area. Elevations
within a mile of the site range from 160 to 300 feet above Mean
Sea Level (MSL).
The site is located adjacent to the 100 year floodplain of
Wissahickon Creek (see Figure 6). Wissahickon Creek flows along
the western side of the Locust Street Pile. The 100 year flood-
plain along this side of the Pile reaches an elevation of 176
feet (MSL) or approximately 8 feet above the toe of the pile at
creek's edge.
The Locust Street an Plant Piles rise above the natural
grade 65 feet and 70 feet respectively, and therefore are a
predominant feature in Ambler. The map view areas of the Locust
Street and Plant Piles are approximately 422,000 square feet
(9.7 acres) and 412,000 feet (9.5 acres), respectively (EPIC,
June 1987) . The estimated volume of these piles is approximately
464,000 cubic yards for the Locust Street Pile and 571,000
cubic yards for the Plant Pile (EPIC, June 1987).
Land Use
Land uses around the site included industrial, residential,
commercial, and transportation. Figure 6 presents a land use
map of the site and the area within 0.5 miles of the site based
on zoning maps from Ambler Borough, Upper Dublin Township and
Whitermarsh Township. Figure 7 depicts various land uses within
an approximate 1.2 mile radius of the site based on land use
identification using remote sensing data (EPIC, June 1987).
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- 15 -
The Ambler Asbestos Piles site occupies approximately 22.6
acres of an industrial zoned area along the southwest border of
the Ambler Borough line. Residential housing is located immedi-
ately northwest of the Locust Street Pile and approximately 500
feet east and west of the Plant Pile. Numerous educational and
recreational facilities are located within 1.2 miles of the
site. Agricultural land is located approximately 2,000 feet
to the west (EPIC), June 1987.
Buildi.no aod structure*
There are number of significant structures in the vicinity
of the waste piles. In the Nicolet manufacturing area there are
four major buildings housing various offices and production
processes, as well as related structures for waste treatment,
storage, and shipping. South of Wissahickon Avenue between
Chestnut and Locust Streets are a number of row houses and
single family homes. North of Wissahickon Avenue are a number
of commercial and light- industrial establishments. The play-
ground adjacent to the Locust Street Pile has been closed and
all equipment removed.
Commuter rail tracks run parallel to Maple Street east of
the Plant Pile and the Nicolet plant site.
Potential Receptors
There are a number of potential receptors within the vicinity
of the waste piles. The nearest residence is within 200 feet
northeast of the Locust Street Pile, and an estimated 6,000
persons live within 1/2 mile of the site.
The Nicolet manufacturing area is adjacent to the Plant
Pile, Locust Street Pile and lagoons. In addition, there are
number of commercial and light industrial establishments just
north of Wissahickon Avenue within a few hundred yards of the
site.
The Central Business District of Ambler is located approxi-
mately onehalf mile northeast of the waste pile and lagoons.
1. Air Quality
The Ambler Asbestos Piles Site is located in the Metro-
politan Philadelphia, Interstate Air Quality Control Region
(U.S. EPA, July 1985). This region is classified as an attain-
ment area for all criteria pollutants except photochemical
oxidants (precursors to ozone) . The air quality within the air
basin containing the Ambler Asbestos Site meets the national
standards for sulfur dioxide (SO2) and meets or exceeds the
national standards for total suspended particulates (TSP) . It
cannot be classified as exceeding the national standards for
both carbon monoxide (CO) and nitrogen dioxide (N02) . The
entire state of Pennsylvania does not meet the standard for
ozone (03) . Locally, air quality is potentially impacted by
industrial and private sources.
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-16 -
II. Biological Resources
A. Terrestrial Resources
The Ambler Asbestos Piles site does support a
significant terrestrial habitat on the covered waste piles.
Crown vetch that was planted during the 1984 Immediate Removal
action has flourished to provide then majority of the present
vegetative cover on the waste piles. A variety of grasses and
shrubs as well as young to mature trees are also supported in
areas of the piles. The developed cover provides cover and
habitat for species present in the surrounding area.
A variety of birds (hawk, pheasant, Canada geese, mallard
duck, songbirds, and crowns) utilize the area for foraging and
nesting purposes. Oeer have been sighted on the Locust Street
Pile. Other wildlife that have been sighted include racoons,
ground hogs, muskrat, skunks, and squirrels.
Burrows have been observed on several slopes of the Locust
Street and Plant Piles. The burrows extend into the cover and
into the waste materials. Burrowing animals have caused minor
problems in the re-exposure of waste materials at several loca-
tions on the piles.
B. Aquatic Resources
Wissahickon Creek runs along the south and west sides of
the Locust Street Pile. The creek contributes to the Schuylkill
River from which public water supply is taken 12 miles downstream
of the site. Fauna supported in the Wissahickon in the vicinity
of the site include sunfish, minnows, and eels. Wissahickon
Creek is stocked annually with trout downstream of the site at
Fort Washington State Park. The stream is fished from spring
to summer. Most of the trout do not survive the summer due to
high temperature and low dissolved oxygen in the stream.
III. Qeoloav
The site study area is underlain by bedrock of the Stock-
ton Formation of Triassic age. The Stockton Formation is
described by Barksdale (1958) as consisting of light-colored,
coarse-grained, arkosic sandstone and conglomerate; red to
brown fine-grained siliceous sandstone; and red shale. The
reddish arkosic units are the most characteristic of the Forma-
tion, especially the lower members of the Stockton Formation
that underlie the site. Individual layers within the Stockton
Formation commonly pinch out or grade into beds of different
texture or mineralogy, and rarely can be traced for any signif-
icant distance. Sequences of beds, however, may persist for
several miles. A geologic map of the Ambler United States
Geologic Survey (USGS) quadrangle is presented in Figure 8.
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- 17 -
The Stockton Formation crops out in an east-northeast
trending band approximately five miles wide in the Ambler area.
Bedding strikes northeast and dips to the northwest at 10 to 20
degrees. Bedding plans commonly show ripple marks, mud cracks,
raindrop impressions, cross bedding, and pinch and swell struc-
tures. The thickness of the unit ranges from 1,000 to 5,000
feet and probably averages about 3,000 feet near the site. The
Formation is extensively faulted and is cut by at least two
sets of vertical joints, one parallel to strike and one at
about a 50 degree angle to strike.
Weathering of the Stockton Formation generally results in
deposits of sandy clay loams of vairable thickness that form an
undulating topography of moderately low relief. Valleys are
typically eroded into the softer sandstone beds while uplands
are more commonly underlain by the arkosic beds. The depth of
bedrock in the study area has been estimated to be less than 10
feet (Preliminary Assessment/Site Investigation, NUS, 1983).
However, it has been reported that quarry activities may have
occurred under the Locust Street Pile (Johnson and Schroder,
1977).
IV. Hydrology
A. Ground Water Hydrology
Ground water flows in the Stockton Formation through
both primary intergranular openings as well as secondary joints
and faults. Flow direction is locally quite variable and hydro-
logic boundaries are frequent. In general, regional ground
water flow is either along the strike of the formation or down
dip. To a great extent, the occurrence and movement of ground
water in the Stockton Formation is controlled by the configuration
of the base of the weathered zone and by vertical changes in
the permeability of the deposits (Barksdale et al., 1958). In
the vicinity of the waste piles, ground water flow is expected
to be toward Wissahickon Creek. Shallow flow is likely to be
unconfined while deeper ground water is under artesian or semi-
artisian conditions. The depth to ground water has been reported
to be less than 5 feet in this site area.
Aquifer tests in the Stockton Formation (semiartisian
deeper ground water) indicate that the unit is one of the best
sources of ground water in southeastern Pennsylvania. Transmis-
sibility ranges from 1,000 to 35,000 gallons per day per foot
(gpd/ft) with typical values between 5,000 and 9,000 gpd/ft.
The storage coefficient ranges from 0.0001 to 0.000001 indicating
a range of conditions from semi-artisian to true artesian.
Well yields range from 1 to 900 gallons per minute (gpm) with
typical values from 50 to 100 gpm. Specific capacity varies
from 0.35 to 44 gpm/ft with a median value of about 6 gpm/ft
(Barksdale et at., 1958; R. E. Wright Associates, Inc., 1982).
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- 18 -
Water quality in the Stockton Formation is generally good
but is highly variable depending on local hydrogeologic and
land use conditions: Typical values of water quality parameters
are: iron, 0.10 mg/1; manganese, 0.04 mg/1; bicarbonate, 84
mg/1; nitrate, 10 mg/1; sulfate, 24 mg/1; total dissolved
solids, 150 mg/1; hardness, 100 mg/1; specific conductance, 250
micro-ohms/cm; and pH, 7.2 (R.E. Wright Associates, Inc.,
1982). Water from the Stockton Formation is a primary source
of drinking water for a number or private and public users
including the Borough of Ambler.
Water supply for the site area is provided by the Ambler
Borough Water Department through a series of nine supply wells.
During the period from July through December 1983, individual
supply wells pumped between 60 and 730 gallons per minute for a
weekly total of between 1,500 and 2,400 gallons per minute.
The municipal well nearest to the water piles is approximately
0.4 miles east of the Pipe Plant Dump. This well is 500 ft
deep, and pumps roughly 100 gpm (NUS, 1983). The nearest known
private (residential drinking water) well is the Burke well.
B. Surface Water Hydrology
The major surface water body in the area is wissahickon
Creek, which flows southeast at a gradient of roughly 22 feet
per miles. The creek and its flood plain from the southern and
western borders of the site. Prophecy Creek and several unnamed
easterly flowing tributaries empty into Wissahickon Creek west
(upgradient) of the site.
Surface drainage from the waste piles and the manufacturing
areas flow to Wissahickon creek via storm sewers and small
surface channels. Two borough storm sewers run underneath the
Locust Street Pile. One of these pipes discharges into a
drainage ditch west of Nicolet's filter beds and subsequently
into the drainageway from the lagoons that flow into the Wissa-
hickon Creek. The other large outlet (5' x 5' box culvert) is
located just below the filter bed lagoons and discharges directly
into the drainageway at the same point as the filter bed lagoons.
No seeps were observed on the slopes of the Locust Street Pile
and Plant Piles. White milky seeps were observed at the toe of
the western side of the Locust Street Pile that run along the
Wissahickon Creek. Bedrock outcrops at this toe. The seeps
were observed coming from the interface of the bedrock and
overburden.
The flood plain of Wissahickon Creek is a ground water
discharge zone and several permanent and seasonal springs have
been reported in the area. No specific data exists on the
water quality or the rates of discharge of the springs.
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- 19 -
Public Water supply
Water supply for the site area is provided by the Ambler
Borough Water Department through a series of nine supply wells.
The municipal well nearest to the waste pile, Well No. 9 on
Figure 9 is approximately 0.4 miles east of the Pipe Plant
Pile. This well is 500 ft deep, and pumps roughly 100 gpm
(NUS, 1983). Other municipal wells in the area are Well No. 4,
which is 305 ft. deep and pumps at an average rate of 75 gpm,
and Well No. 11, which is 500 feet deep and pumps at a rate of
100 gpm. All well water is pumped into common storage tanks.
The only reported treatment to the water is the addition of
chlorine. The water is tested periodically for total solids,
color, odor, turbidity, sediment, pH, minerals, fecal coliform,
chlorination by-products and volatile organics.
The nearest public water intake from surface waters is
located approximately 12 miles downstream of the site on the
Schuylkill River about one half mile downstream of the confluence
of Wissahickon Creek and the Schuylkill River. Figure 10 is a
flow diagram indicating how this water is treated based on
conversations with the operators in December 1987. Both the
flocculation and the rapid sand filtration treatment unit should
remove most asbestos, if any is present in the water. Because
of the treatment the water receives and the dilution that occurs
when Wissahickon Creek flows into the Schuylkill River, asbestos!
would not appear to be a problem in the water from this intake.
Ground water is not expected to be a significant migration
pathway for asbestos at this site. This is due to two factors:
1) the site's location in a hydrologic discharge zone where
generally base flow is slightly upward and toward the stream;
and 2) the relative insignificant subsurface downward or lateral
migration of asbestos fibers in soil. To date, there is no
documentation of ground water transport of asbestos particles
(Dalton, U.S. EPA, 1985).
The field investigation and analytical program was designed
to determine if potential public health risks and environmental
impacts still exist at the Ambler Asbestos Piles site and if
remedial action is needed in accordance with 40 C.F.R. Section
300.68 of the NCP. In order to complete the Endangerment Assess-
ment the following Remedial Investigation/Feasibility Study
objectives were identified:
- Locate immediate and/or potential future sources of
asbestos release by identified pathways of migration
(surface water, air) which can reach sensitive
receptors resulting in public health risks and
environmental impacts. This includes analysis of
whether exposed asbestos could produce unacceptable
risks to persons on-site by direct contact (either
via authorized or unauthorized site entry);
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- 20 -
- Identify contaminants other than asbestos that may
pose an'immediate or potential risk to public
health and/or the environment;
- Determine whether the site is securely closed as a
result of the previous "Removal Actions11 (i.e., no
pathways for asbestos or other contaminant release
are found in quantity or concentration that pose a
risk to human health or the environment).
Previous field investigations and studies have addressed
the first objective, however, they were conducted prior to the
1984 Removal Action. This field investigation and analytical
program was designed to address the objectives with regard to
post-Removal Action site conditions. The investigation focused
on addressing the following data gaps, in order to meet the
RI/FS objectives:
- The content of the piles and especially the degree
of asbestos containing materials within and up to
100 feet from the identified waste piles and lagoon
area;
• An assessment of the condition, thickness, and long-
term life of the cover materials over the two
identified asbestos and process waste piles;
Data on the physical/structural characteristics
(shear strength, moisture content, consolidation
properties) and material distribution of the piles;
An evaluation of the present and future slope
stability and potential settlement of the waste
piles, as well as other on-site physical features
that would affect contaminant migration, containment,
and/or cleanup;
- The presence of asbestos in the sediments and
surface waters at and adjacent to the site after the
Removal Action;
• The present and potential impacts on the adjacent
Wissahickon Creek;
Information on background levels of asbestos in
ambient air in Ambler and the surrounding area
including the level of asbestos in the ambient air
up and down gradient of the site after the Removal
Action.
- The presence of contaminants other than asbestos at
concentrations which pose a risk to human health
and/or the environment.
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-21-
These data gaps -were organized into task objectives from
which the phased field investigation was developed. Table l
presents an outline of the phased Field Investigation Program.
The task objectives listed in Table 1 relate to the tasks under
each phase.
A phased approach was utilized to identify potential areas
requiring further investigation and testing at an early stage.
Phase I was performed in three subphases; site survey, non-
intrusive sampling and intrusive sampling. Greater safety
measures were employed during the intrusive sampling. Air
monitoring was performed throughout the survey and sampling
programs. An additional phase (Phase 2) was to be performed
if contaminants of concern other than asbestos were found at
concentrations that pose a potential health and/or environmental
risk. A phase 2 program was not implemented based on the analy-
tical results from waste sampling at the Locust Street and
Plant Piles.
Description of Maior Potential XRARa
An ARAR, as defined, is an environmental law, regulation,
or guideline that is either "applicable" or "relevant and appro-
priate" to a remedial action. "Applicable" requirements are
those cleanup standards, standards of control, and other environ
mental protection requirements, criteria, or limitations, promu-
lgated under Federal or State laws that specifically address
chemicals/contaminants of concerns, remedial actions, locations
of remediation, or other circumstances at a CERCLA-regulated
site. "Relevant and appropriate" requirements are those which
address problems or situations sufficiently similar to those
encountered at a CERCLA-regulated site that their use is well
suited to the particular site (Section 121 of CERCLA, 42 U.S.C.
Section 9621 and 40 C.F. R. Section 300.68(1)).
ARARs can be divided into the following categories:
• Chemical/contaminant-specific requirements - Health or
risk-based concentration limits or ranges in various
environmental media for specific hazardous substances,
pollutants, or chemicals/contaminants. These limits may
take the form of cleanup levels, discharge levels and/or
maximum intake levels (such as for drinking water and
breathing air for humans).
- Action-specific requirements - Controls or restrictions
on particular types of remedial activities in related
areas such as hazardous waste management or wastewater
treatment.
- Location-specific requirements - Restrictions on remedial
activities that are based on the characteristics of a
site or its immediate environment. An example would be
restrictions on wetlands development.
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- 22 -
This section describes the chemical/contaminant-specific
ARARs which relate to the Ambler Asbestos Piles Remedial Action.
The action specific requirements will be discussed under the
development of remedial alternatives. There are no location
specific requirements for this site.
A review of various potential chemical/constituent specific
requirements and the determination of which may be applicable,
relevant, or appropriate to the Ambler site RI was conducted.
The results are discussed in the remainder of this section.
of Asbestos-Re
While asbestos has been used in industry for a long time,
the regulation of asbestos is a relatively recent development.
Most of the significant asbestos regulations were promulgated
in the last 15 years; additional regulations will probably be
introduced in the next few years.
The areas covered by the existing regulations include:
- Control of air emissions from industrial sources; and
• Air concentration limits for workers during abatement
work and in schools;
A summary of the existing asbestos regulatory limits or
goals is presented in Table 2. A category of existing guidelines
will be discussed in a "To be Considered" section below.
The current regulations do not address either limits for
asbestos concentrations in ambient air or asbestos concentrations
in wastewater effluent. Most of the regulatory effort to date
has been focused on occupational exposures in industrial and
educational settings. The development of guidelines for the
general population has moved less rapidly due to the complexity
of sampling, analyzing and interpreting asbestos concentrations
in ambient air. The existing regulations and occupational health
studies can however be used as a guideline in evaluating the
quality of ambient air and water at the Ambler site.
A brief discussion of potential applicable or relevant and
appropriate asbestos regulations is presented in the following
subsections.
- 40 C.F.R. Part 61, Subpart M — National Emission Stan-
dards for Hazardous Air Pollutants.
Section 112 of the Clean Air Act, as amended, 42 U.S.C.
Section 7412, requires that National Emission Standards for
Hazardous Air Pollutants (NESHAPs) be set for hazardous air
pollutants. The National Emission Standards for asbestos
(Subpart M of 40 CFR Part 61) include standards for a variety of
asbestos manufacturing, construction, and disposal operations.
-------
-23-
Of particular relevance to the Ambler site is Section 61.153,
"Standard for Inactive Waste Disposal Sites for Asbestos Mills
and Manufacturing and Fabricating Operations." Each owner or
operator is required to comply with one of the following:
- Either discharge no visible emissions; or
- Cover the waste material with at least 6 inches of compacted
non-asbestos containing material, and grow and maintain a
cover of vegetation; or
- Cover the waste material with at least 2 feet of compacted
non-asbestos contacting material (no vegetation required);
or
- Apply a dust suppressant that binds the dust and controls
wind erosion.
The rules also include requirements for fencing, posting of
warning signs, and long term monitoring involving visual inspec-
tion of the site for emissions.
TABLE 2
SUMMARY 07 ASBESTOS REGULATORY LIMITS OR GOALS
MEDIUM
REGULATION
AGENCY
- REGULATORY
LIMIT OR GOAL
Air
Water
40 CFR 61
40 CFR 763
EPA
EPA
29 CFR 1910
and
29 CFR 1926
45 FR 79318
(November 28,
1980)
OSHA
EPA
No visible emissions to
outside air.
2 (fibers/cubic centimeter)
by PCM (8 hour time weighted
average) for asbestos
abatement worker exposure.
0.02 f/cc TEM performance
standard for remediation
in schools.
O.2 f/cc by PCM (8-hr time
weighted average) for indus-
trial and construction
worker exposure.
Zero concentration in surface
water for maximum protection
of human health; drinking
water concentration of 30,000
fibers per liter indicated to
result in increased lifetime
cancer risk 10~6.
-------
40 CFR 141 Proposed Maximum Concentra-
tion Level Goal (MCLG)
of 7.1 million fibers
per liter (fibers < 10 urn)
for drinking water.
40 CFR Part 763, Subpart 6 — ASBESTOS ABATEMENT PROJECTS
Section 6 of the Toxic Substances Control Act (TSCA)
provides EPA with the authority to control the manufacturing,
processing, distribution, labeling, and disposal of chemical
substances and mixtures. The regulations addressing asbestos
under this Act are contained in 40 CFR 763. Subpart G of this
rule, "Asbestos Abatement Projects,1* describes the requirements
to be followed during asbestos abatement projects. The maximum
8-hour time-weighted average airborne concentration for any worker
without protection in an abatement project is 2 f/cc (greater
than 5* um size). The ceiling concentration is 10 f/cc (greater
than 5 um size). Samples are collected on an 8 um filter using
a high volume air pump and measured by Phase Contract Microscopy
(PCM.)
Subpart E of this rule, "Asbestos-Containing Materials in
Schools" sets requirements for remedial action in schools. It
includes a standard for determining if further action is necessary
after abatement. If the average concentration does not exceed
the limit of quantification for the Transmission Electron Miscro-
scopy (TEM), no further action is required. The limit of quant-
ification is defined as four times the analytical sensitivity.
The analytical sensitivity is currently less than 0.005 f/cc of
air. Thus, if the concentration is below 0.02 f/cc, no further
quantification is required. Alternatively, if the average concen-
tration is not significantly different than the outside concen-
tration, no further action is required.
40 CFR Part 141 — NATIONAL PRIMARY DRINKING WATER REGULATIONS
Section 1411-12 of the Public Health Service Act as amended
by the Safe Drinking Water Act, 42 U.S.C. Sections 300 (g)-
(g)(1)i provides for the development of Maximum Contaminant
Levels (MCLs) in drinking water. Under this rule, Maximum
Concentration Level Goals (MCLGs) are to be initially developed,
which are non-enforceable goals based entirely on health consid-
erations. The MCLs represent enforceable drinking water standards
which are to be set as close to the MCLG as is realistically
feasible. MCLs are based on health, technical feasibility, and
cost-benefit analysis. A MCLG for asbestos in drinking water of
7.1 million fibers per liter (MFL) for fibers greater than 10
um was proposed by EPA in 1985 based on an increased lifetime
cancer risk level of 1 x 10-6. As of April 1988 an accompanying
proposed rule (MCL) has not yet been promulgated.
The proposed MCLG is approximately two orders of magnitude
higher than the existing Ambient Water Quality Criteria concen-
tration, discussed in the previous subsection, because it is
based on recent ingestion studies using laboratory animals
(rats) rather than extrapolation of inhalation effects to inges-
-------
- 25 -
tion. The results of this study showed no evidence of carcino-
genicity for ingestion of the short-range fibers (<5 um) in
either male or female rats and no evidence of carcinogenicity
for ingestion of the intermediate range fibers in the female rats.
However, there was an increase in benign polyps of the large
intestine for the male rats ingesting the intermediate range
fibers (.10 um) at a dosage of 1 percent of their diet.
COMMONWEALTH OF PENNSYLVANIA (STATE) ASBESTOS REGULATIONS
The Ambler Asbestos Piles are existing industrial waste
piles. FADER currently regulates existing asbestos piles under
the NESHAPS regulations. The NESHAPs regulations require a 6-
inch vegetated cover for closure of asbestos disposal sites.
NESHAP asbestos air emission standards state that no visible
emission are permitted from an asbestos disposal site. The
Locust Street and Plant Piles are not completely covered and
therefore are not meeting NESHAPs regulations for closure. No
visible emissions were observed however, from the uncovered areas
during the RI field investigation.
Asbestos is a solid waste as defined under the Solid Waste
Management Act, Act of July 7, 1980, Act No. 1980-97, 35 P.S.
Section 691.1 e_t seq.. Disposal of asbestos and asbestos
containing waste at an unpermitted facility in Pennsylvania is
unlawful. Permitted facilities must comply with the Department's
rules and regulations governing solid waste management facilities
The Commonwealth consistently requires that asbestos and asbestos1
containing waste be disposed at permitted solid waste management
facilities subject to the above Act and the Department's rules
and regulations governing solid waste management facilities.
The State ARAR's applicable to closure of the Locust Street and
codified in 25 P.S., Chapter 273. Applicable requirements
related to slope design, cap design, vegetative cover, and
surface water control are found in Chapter 273.
OTHER INTORMATION TO BE CONSIDERED
The information presented below, although not ARARs, were
considered by EPA and the remedy selected is consistent with these
guidelines.
To date, no ambient air standards for asbestos have been
developed. Numerous ambient air studies have been conducted
which have established background asbestos concentrations.
These have been used to develop guidelines for identifying what
concentrations may constitute "elevated" asbestos concentrations
at various geographic locations. One prominent study was conduc-
ted by Dr. E.J. Chatfield for the Ontario Research Foundation
in May 1983 which summarized the literature findings in this
regard. Listed below are the recommended ambient air guidelines
for several areas in the United States, Canada, and Europe
based on the Chatfield study.
-------
- 26 -
RECOMMENDED AMBIENT AIR GUIDELINES
State of Connecticut (proposed) -
30 day Average (electron microscopy)
Province of Ontario -
- 24 hour Average (electron
microscopy) (>5 urn)
-30 minute Average weight
Province of British Columbia (Optical)
West Germany
microscopy)
- (>5 urn)
(proposed) (electron
Montreal Urban Community (optical)
New York City (recommended by
Nicholson) (electron microscopy)
•
France (Conseil Superieur d'Hygiene
Publique de France proposed ambient
air quality inside buildings) (electron
microscopy)
30 ng/m3 or
30,000 total
asbestos
fibers/m3
(equates to 0.03
fibers/cc)
40 fibers/liter
(equates to 0.04
fibers/cc)
5 ug/m3
<0.04 fiber/cc
1 fiber/liter
equates to 0.001
fibers/cc)
0.05 fiber/cc
100 ng/m3
50 nf/m3
These guidelines and others developed by the scientific
community are based on potential adverse health effects which
have been indicated for asbestos exposures; and are discussed
in greater detail in the Endangerment Assessment.
OCCUPATIONAL HEALTH AND SAJ1TY ACT (OSHA)
29 era Part 1910 AND 29 era Part 1926
(L*t«»t revision April 30, 1984)
OSHA regulates asbestos exposure in the workplace. Occupa-
tional exposure to asbestos in all industries except construction
is regulated by 29 CFR Part 1910. Construction industry exposure
is regulated by 29 CFR Part 1926. The two rules are essentially
the same. The rules address areas such as maximum exposure
levels, workplace cleanliness, respirator use, and employee
health monitoring. They set an 8 hour time weighted average
Permissible Exposure Limit (PEL) of 0.2. fibers per cubic centi-
meter of air as determined by PCM. Only fibers longer than 5
urn and a length-towidth ratio of 3:1 or greater are counted.
If this concentration is exceeded, engineering controls must be
implemented or work practices such as respiratory protection
must be used.
-------
- 27 -
45 FR 79318 — AMBIENT WATER QUALITY CRITERIA
(November 28, 1980)
The EPA has published recommendations on toxic pollutant
water quality criteria as required by 1977 amendments to the
Clean Water Act, as amended. The criteria are not binding
standards but rather guidelines for the states to use to estab-
lish surface water quality standards. Guidance was provided
for 64 toxic pollutants including asbestos. The guidance
document states that for maximum protection of human health,
the ambient water concentration should be zero based on the
assumption that there is no threshold below which asbestos is
not a carcinogen. Recognizing that zero concentrations are
probably not obtainable, the EPA estimated that an increased
lifetime cancer risk of 10-5, 10-6, and 10-7 could result from
ingestion of surface water containing asbestos concentrations of
300,000, 30,000 and 3,000 fibers/liter, respectively. These
values were based on extrapolating the potential risk associated'
with ingestion of asbestos in drinking water. These guidelines
were not based on ingestion studies.
Bndangerment Assessment
EPA is required to undertake an Endangerment Assessment (EA)
to properly document and justify its assertion that "an imminent
and substantial endangerment to the public health of welfare or
the environment "resulting from11 an actual or threatened release
of a hazardous substance may exist (Section 106 of CERCLA, 42
U.S.C. Section 9606). This EA addresses the potential human
health and environmental impacts associated with the Ambler
site under the no-action alternative, that is, in the absence
of remedial corrective action).
The results of sampling performed during the Remedial Inves-
tigation (RI) in soil, surface water, sediment, and air were
reviewed to identify chemicals to be evaluated in this Endanger-
ment Assessment. Chemicals were selected for detailed evaluation
if they were present in environmental media at concentrations
above background concentrations and/or could be related to past
disposal practices at the site. The chemicals that were selected
(see Table 3) consisted of asbestos, the primary chemical of
concern at the Ambler site (detected in all sampled environmental
media), twelve inorganic chemicals, most of which were detected
in surface water, and two categories of polycyclic aromatic
hydrocarbons (PAHs), noncarcinogenic PAHs and carcinogenic
PAHs. Among the selected chemicals, adequate toxicity values
for use in a quantitative risk assessment were not available
for five of the selected inorganics (aluminum, calcium, iron,
magnesium and potassium). These chemicals were not, therefore
evaluated in this Endangerment Assessment. Available data,
however, indicate that these chemicals are of relatively low
toxicity via the oral route compared to the other chemicals
evaluated and most are also essential human nutrients.
-------
-28-
Aaaeasaent
Pathways through which individuals may be exposed to chem-
icals at and from the Ambler site were reviewed and those pathways
most likely to be of concern to human health were identified for
further analysis. The most important potential human pathways
of exposure for the Ambler site that were evaluated were:
- Inhalation of asbestos in ambient air;
- Inhalation of asbestos during certain activities which
stir up asbestos;
- Incidental ingestion of chemicals in surface water;
- Incidental ingestion of chemicals in soil; and
•
- Incidental ingestion of chemicals in sediment.
Under present site and land use conditions, the potentially
exposed populations include residents living in the Ambler site
area, individuals who work in the site area, and individuals
who regularly visit the area (such as those using the Wissahickon
Watershed Association facility). In the future, assuming no
further remediation actions are taken at the site, additional
residences or commercial facilities could be'built adjacent to
the site. Given the inherent instability of the Locust Street
and Plant Piles it would not be feasible to build structures on
them. However, other nearby on-site industrial construction or
activities could potentially affect the piles and increase
exposed areas of asbestos and migration of asbestos from the
site.
Risks from the pathways listed above were characterized by
first comparing concentrations of chemicals in the sampled
environmental media to Applicable or Relevant and Appropriate
Requirements (ARARs) identified for the Ambler site. Because
ARARs were not available for all of the selected chemicals in
all of the sampled environmental media, a quantitative risk
assessment was also conducted. In this evaluation, estimates
of potential chemical intakes through each pathway identified
for evaluation were combined with the chemical specific toxicity
values to predict potential risks associated with the Ambler
site. For each pathway, an exposure scenario was developed
based on assumptions about the environmental behavior and trans-
port of the potential chemicals of concern, and the extent,
frequency, and duration of exposures.
-------
TABLE 3
SUMMARY OP ENVIRONMENTAL MEDIA Analysis
'Ix-mical
Environmental Media in Which Substances were Detected
Surface Hater
Soil
Bed latent
Air
Creek
Drainage-
ways
Lagoons
Borings
< 4 ft.
Borings Test
>- 4 ft. pits
Creek' and
Drainage-
ways Lagoon
V:ln»Sl OS
i»»r<|4nic:
AlnminuM
II ir turn
C.ilriu*
11 <>n
I.'••»nso(k| f luoranthene
; li<*nzo(a) pyrene
Clirysene
|n
-------
TABLE 3 (Continued!
SUMMARY OF KNVIRONMENTM. MEDIA Analysis
Environmental Media in Which Substanres
Surface Hater
Soil
Sedivent
Air
Creek
Oralnaqe-
ways
Lagoons
Borings
< 4 it.
Borlnqa Test
>- 4 ft. Pits
Creek ana
Drainage-
ways
Lagoon
N-mrArcinoqenlc pAHs :
?-Hothylnaphthalene
Ai-onaphthene
rlipn*nttir«n*
AIII hracene
I'yrene
ii«>itzi> (q ,h, i) perylene
-------
-29-
These factors were used to predict potential exposures to
the set of selected chemicals for both an average and a maximum
plausible exposure case. For noncarcinogens, results are presented
as the ratio of the Chronic Daily Intake (GDI) of each chemical
to its Reference Dose (RfO), and as the hazard index, which is
the sum of the GDI:RfO ratios for each chemical. If the hazard
index exceeds one, health hazards might result from such exposures.
In the case of carcinogens, the excess upper bound lifetime
cancer risk was estimated; this risk is expressed as a probabili-
ty. A risk of lxlO~6, for example, represents the probability
that an individual will develop cancer as a result of exposure
to a carcinogenic chemical over a 70-year lifetime. EPA has
suggested developing remedial alternatives for cleanup of Super-
fund sites for total excess lifetime cancer risks from 10"'
to 10"4.
For asbestos, based on the comparison to chemical-specific
ARARs, it was concluded that under present site use conditions
the "no visible emission" criteria for asbestos developed under
the Clean Air Act is not currently being exceeded. In the
future, however, increased erosion and weathering of the piles
could increase the potential for visible asbestos emission. In
addition, exceedance of these asbestos regulations would likely
occur if the site were disturbed by vehicular activities. Such
activities would most likely occur as part of a remedial action
involving removal of the site were disturbed by vehicular activ-
ities. Such activities would asbestos contaminated soil from
the site. In addition, concentrations of asbestos measured in
surface water would exceed the Ambient Water Quality Criterion
for the protection of human health.
It was concluded that potential releases of asbestos to
ambient air from the Ambler site may occur due to the existence
of exposed areas containing asbestos. It was further concluded
that potential human health risks to nearby residents may be
associated with releases of asbestos from such exposed areas at
the site into ambient air.
Potential asbestos inhalation exposures during specific
types of activities that can stir up asbestos fibers, such as
children playing in soil on the piles, were also qualitatively
evaluated. Under present site use conditions at the Ambler
site, activities that could stir up asbestos fibers include
playing and biking on the piles by children and outdoor tasks
conducted by workers employed in the site area (e.g., employees
at the Nicolet plant). It was concluded that these and other
activities could continue to occur in the absence of site remed-
iation (i.e., under the no-action alternative). Among sub-popu-
lations who may repeatedly engage in these types of activities,
cumulative asbestos exposures of concern to human health could
potentially result.
Quantitative risks were estimated for the remaining exposure
pathways. The results are summarized by pathway in Table 4 for
both noncarcinogenic and potentially carcinogenic chemicals.
-------
-30-
Risks associated with incidental ingestion of surface water
by children playing in WissahicJcon Creek, drainageways and
standing surface water were evaluated for selected chemicals
(asbestos and seven inorganic chemicals). The excess lifetime
cancer risks for asbestos were estimated for three separate
areas, Wissahickon Creek, drainageways and standing surface
water off-site behind the piles, and drainageways near the Maple
Avenue piles (upstream of the Ambler site). The cancer risks
ranged from 3xl09 for the average case to 7xl08 for the maximum
plausible case. It should be noted that there are several
sources of asbestos in Wissahickon Creek (e.g., other than the
Ambler site) and thus risks associated with ingestion of asbestos
from Wissahickon Creek cannot be attributed solely to the Ambler
site. Among the other chemicals selected for evaluation in
this risk assessment, only inorganics were detected in standing
surface water and drainageways. All of these inorganic chemicals
are noncarcinogens for which EPA has developed reference doses
(RfDs). All of the chemicalspecific CDI:RfD ratios for the
detected inorganics were well below one as was the hazard index
(the sum of all the chemicalspecific ratios), indicating that
noncarcinogenic effects would not occur from this exposure
pathway.
Risks associated with incidental ingestion of chemicals
present in on-site soil by children were evaluated for those
chemicals detected in 'surface soil samples (asbestos from zero
to four feet and PAHs from four to seven feet). For the noncar-
cinogenic PAHs, the ratio of the CDI to the RfD was well below
one, indicating that adverse noncarcinogenic human health effects
would not occur. The total excess lifetime cancer risks were
estimated to range from IxlO"6 for the average case to 6x10"
5 for the maximum plausible case; both risks were basically
associated with ingestion of asbestos. It is important to
recognize the complexity involved in estimating cancer risks
for incidental ingestion of asbestos present in soil.
EPA has developed a unit risk factor for exposure to asbes-
tos in surface water only, and not for exposure to asbestos
from other environmental media where concentrations may be
reported on a mass (not fiber) basis. In order to quantify
risks associated with incidental ingestion of asbestos in soil,
the EPA unit risk factor was converted into a mass-based potency
factor. Based on this conversion, the excess lifetime cancer
risks for incidental ingestion of asbestos from soil were esti-
mated to be lxlO~6 for the average case and 6xlO"5 for the
maximum plausible case. Because of the uncertainty inherent in
converting from a fiber-based unit risk factor to a mass-based
potency factor, the uncertainty associated with risks related
to exposure to asbestos through this pathway may exceed an
order of magnitude uncertainty. Additional uncertainty is
added by the fact that only benign tumors were noted in the
bioassay which is the basis of the potency factor.
-------
TABLE
SUMMARY OF POTENTIAL RISKS ASSOCIATED WITH EXPOSURE PATHWAYS
QUANTITATIVELY EVALUATED FOR THE AMBLER ASBESTOS SITE
Exposure
Pathway
Ingestion of surface water0
- Wissahickon Creek
- Drainageways and standing
surface water
• Near Maple Avenue piles
Ingestion of on- site soil
Ingestion of sediment from
drainageways and standing
surface water
Hazard
Average
Case
NS
-------
-31-
Exposures and risks associated with incidental ingestion
of sediment were evaluated for children who may play in the
Wissahickon Creek area, drainage-ways, or standing surface
water pools. The selected chemicals that were detected were
copper and PAHs; these chemicals were detected in drainage-way
sediments. Asbestos was not detected in drainageway or creek
sediments. The CDI:RfD ratios for copper and noncarcinogenic
PAHs and the hazard index were well below one indicating that
adverse noncarcinogenic PAHs in sediments, the excess lifetime
cancer risks were estimated to range from 4xlO~8 for the average
case scenario to 3 x 10~6 for the plausible maximum case scenario.
The source of the PAHs cannot be attributed solely to the Ambler
site.
Ecological Riafc Assessment
The following pathways by which environmental receptors at
and near the Ambler Asbestos Piles site could be potentially
exposed to contaminants originating at the site were considered:
- Contact with and ingestion of water by aquatic life
in Wissahickon Creek, and drainage ditches feeding
into the creek and other surface water;
- Direct contact with and ingestion of soil by birds and
mammals when preening, grooming, or foraging for
food;
- Ingestion of prey by birds and mammals;
- Ingestion of surface water by birds and mammals; and
- Uptake of contaminants in the (PAHs) soil by plants.
Based on a qualitative assessment of the potential impacts
of the above exposures, the following conclusions were reached,
that there is an adverse impace to the local ecology. (This
information is detailed in the RI/FS).
ARARs for the remaining selected chemicals consist of
Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) under the Safe Drinking Water Act and Ambient
Water Quality Criteria (AWQC) for the protection of human
health. Chemical concentrations measured in surface water at
and near the site can be compared to these ARARs although none
of the sampled surface water bodies are being used or are
planned to be used as a drinking water source. Concentrations
of the selected chemicals (twelve inorganic chemicals, most of
which were detected in surface water, and two categories of
polycyclic aromatic hydrocarbons (PAHs), non-carcinogenic PAHs
and carcinogenic PAHs), and five inorganics (aluminum, calcium,
magnesium, and potassium) in lagoon surface water did not
-------
-32-
exceed the available ARARs. Among the chemicals detected in
standing surface water and drainageways (only asbestos was
sampled for in Wissahickon Creek), the maximum concentrations
of lead, manganese and nickel exceeded the proposed MCLG, the
secondary MCL (not health-based) and the AWQC, respectively.
The geometric mean concentration of manganese also exceeded the
secondary MCL.
It should be noted that this comparison was very conserva-
tive in that none of these surface water bodies are being used
or planned to be used as drinking water sources. These chemicals
were not, therefore, evaluated in the EA. Available data,
however, indicate that these chemicals are of relatively low
toxicity via oral route compared to the other chemicals evaluated
and most are also essential human nutrients.
ALTERNATIVE DEVELOPMENT
The overall objective of the CERCLA Feasibility Study (FS)
process is the identification of the most appropriate, cost-
effective* alternative(s) for remediation of a site the effec-
tively mitigates and minimizes threats to and provides adequate
protection of public health and the environment and that utilizes
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable
(See Section 121(b), (d) , of CERCLA, 42 U.S.C. Section 9621(b),
(d) and 40 C.F.R. Section 300.68(i)). In accordance with Sectidi
121(b) of CERCLA, emphasis in the FS for the Ambler Asbestos
Piles site was placed on remedial technologies that reduce the
toxicity, mobility, or volume of wastes and contaminated materials,
a In the legislative history to the 1986 amendments to CERCLA
Congress clarified its definition of cost-effective remedial
action (Congressional Record. October 3, 1986, page H9102) as
follows: "The term costeffective means that in determining the
appropriate level of clean-up, EPA first determines the appro-
priate level of environmental and health protection, and then
selects a cost-effective means of achieving that goal. Only
after EPA determines, by selection of applicable or relevant
and appropriate requirements (ARARs), that adequate protection
of human health and the environment will be achieved, is it
appropriate to consider cost-effectiveness."
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-33-
The General Response Section that follows identifies the
general response actions and associated remedial technologies
applicable to this site. The initial screening of potential
remedial technologies, based on RI information, is presented in
a subsequent section. The technologies are screened to eliminate
those that have limitations for specific chemical constituents
and site characteristics, or have inherent technological limita-
tions. This screening is performed in accordance with 40 C.F.R.
Section 300.68 and Section 121 of CERCLA.
GENERAL RESPONSE ACTIONS
A number of general response actions have been identified
for the Ambler Asbestos Piles site based on the information and
data presented in the RI. These response actions, the associated
remedial technologies, and the site problem areas to be addressed
are presented in Table 5. The identified response actions and
technologies include source control and management measures, as
well as "no action." The no action response alternative is used
as a base line against which other measures are evaluated.
The on-site sources of current and future public health risks
have been identified as the asbestos-containing waste materials
in the piles and surface water/sediment of the settling basins
and filter bed lagoons. As a result, remedial technologies are
considered that primarily address asbestos. The remediation of
the spent magnesium/calcium carbonate, which constitutes a
significant portion of both piles, is also considered in the
screening process.
TABLE 5
GENERAL RESPONSE ACTIONS AND ASSOCIATED REMEDIAL
TECHNOLOGIES FOR THE AMBLER ASBESTOS PILES SITE
General Potential Remedial Site Problems
Response Technologies to Primarily
Action be Screened Addressed
No action Monitoring Does not address
Upgrade Site Security site problems
except for
reducing human
and wildlife
contact of
exposed areas
areas of
the piles
and surface
water/sedi-
ment of settl-
ing basins and
filter bed lagoon
-------
- 34 -
General
Response
Action
Potential Remedial
Technologies to
be Screened
Site Problems
Primarily
Addressed
Surface Water
Management/ and
Erosion
Control/Sedi-
mentation
Measures
Capping
Complete or
Partial Removal
In Situ Treat-
ment
On-Site
Surface Water Management
- Regrading and revega-
tation
- Diversion ditches and
interception trenches
- Sedimentation ponds
and basins
Capping Techniques
- Synthetic membranes
- Low permeability soils
- Surface sealing
- Soil/bentonite
admixtures
- Asphalt/concrete
- RCRA-type multilayer
- Stabilizing cover
system
Excavation/Oredging of Sol-
ids, Pumping and Filtration
Liquids
Thermal Treatment
- In situ vitrification
Thermal Treatment
- Vitrification
solidification/
stabilization
- Cement/poozolanic
- Thermoplastic micro-
encapsulation
- Precipitation/floccu-
lation/sedimentation
- Filtration
- Evaporation
Improves drainage
patterns from
piles (tops and
side slopes
to minimize
further asbestos
exposure). Divert
runoff to mini-
mize cover erosion
on slopes
and collects runoff
to control sediment
sediment transport
off-site.
Contains asbestos
fibers in pile
waste material
and sediments in
basins and lagoons
preventing entrain-
ment of fibers
into ambient air
and surface wate
Removes source of
asbestos in surface
water sediments,
and waste piles.
Stabilizes asbestos
in order to prevent
entrainment of
asbestos fibers
into ambient air.
Reduces mobility
and/or toxicity
of asbestos
contaminants.
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-35-
TABLE 5
(continued)
GENERAL RESPONSE ACTIONS AND ASSOCIATED REMEDIAL
TECHNOLOGIES FOR THE AMBLER ASBESTOS PILES SITE
General
Response
.Action
Potential Remedial
Technologies to
be Screened
Site Problems
Primarily
Addressed
Off-Site
Treatment
Off-Site
Disposal
On-Site
Disposal
Solidification/Stabilization
- Cement/Pozzolanic
- Thermoplastic micro-
encapsulation
Physical/Chemical Treatment
- Precipitation/flocculation/
sedimentation
Stabilize asbestos
to prevent/reduce
entrainment of
asbestos into
ambient air and
transport area
surface water.
Removal of asbestos
fibers in lagoon
surface water prior
to discharge to
creek
Landfill
Landfill
Containment of
asbestos in waste
piles and lagoon
sediments.
The objective of remediation of the asbestos-containing
waste is to prevent migration into the ambient air and transport
via stormwater runoff to Wissahickon Creek. A consideration of
remediation of the magnesium/ calcium carbonate is to improve
the physical characteristics (increase strength, lower moisture
content) in order to improve the stability of the piles and/or
allow for off-site transport of this material. The objective
of remediating th« surface water in the settling basins and
filter bed lagoons is to allow for discharge to Wissahickon
Creek, or potentially to the local Ambler Wastewater Treatment
Plant.
SCREENING Of POTENTIAL REMEDIAL TECHNOLOGIES
The surface area volume of the waste piles, lagoon surface
water, and sediments containing asbestos were estimated using
pertinent surface and subsurface data.
A breakdown of the estimated volumes and surface areas are
presented below.
-------
. - 36 -
Waste Piles Volume feu, vds.l
Plant Pile 615,000
Locust Street Pile 640,000
Settling Basins/Filter Bed Lagoons
Sediments (assume 3 ft. thick) 4,500
Surface Water 1.9 x 106 gallons
Surface Area 40,500 sq. ft.
SCREENING PROCESS
The objective of this screening is to initially identify
the remedial technologies best suited for further consideration
in developing remedial alternatives for the Ambler Asbestos
Piles site. The focus of the screening process is to eliminate
technologies, based on information obtained from the RI, that
are not feasible because they may prove difficult to implement
or have severe limitations that would prevent achievement of
the remedial objectives. The technologies are considered accor-
ding to their technical feasibility in relation to site and
waste characteristics and applicability to the problem areas of
the site and cost.
Potential remedial technologies will be screened using the
following process. First, a brief description of the technology
is presented with a discussion of its potential application to
site problem areas. Then, a discussion of the technical- relia-
bility (technology development, performance, and safety) and
implementability in relation to site, waste, and technology
characteristics is represented. The technologies are also
screened for their suitability to the site according to environ-
mental, public health, and institutional considerations. A
recommendation is then made to retain or eliminate the technology
for further consideration based on the criteria described.
SUMMARY OF TECHNOLOGIES
The screening of the remedial technologies is summarized
in Table 6. The technologies that have been retained after the
screening process for use in developing remedial action alterna-
tives are listed as follows:
- No action with security upgrade and monitoring;
- Surface water management and erosion and sediment con-
trols;
- Stabilizing cover system and stabilization of existing
cover soils;
- Complete or partial removal;
-------
- 37 -
- On-site solidification/stabilization;
- On-site precipitation/flocculation and sedimentation;
i
I
- On-site filtration;
- On-site vitrification;
- Off-site disposal.
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
Remedial action alternatives have been formulated hereafter
to address the environmental issues and contaminant pathways
related to the Ambler Asbestos Piles site. These alternatives
have been developed based on the following considerations:
- The remedial alternatives were formulated using the
technologies retained from the screening process
discussed previously. The technologies considered to
be applicable to the remediation of the identified
environmental issues of the Ambler Asbestos Piles
site are summarized in Table 6.
- Techniques that are complementary and/or interrelated
were combined into alternatives. For example, in one
alternative — On-Site Closure, installation of an
improved cap on the waste piles is combined with back-
fill of the lagoon, on-site sedimentation and erosion
controls, protection against scouring along the
creek, and surface water treatment (of lagoon water).
- The alternatives were also developed to address the
remedial action objectives established for the site.
Not all of the alternatives developed will equally
satisfy the objectives or be as effective in address-
ing part or all of the site issues and contaminant
pathways.
- The purpose of the alternative development process is
to cover a range of effective remedial action alterna-
tives. (See 40 C.F.R. Section 300.68). Therefore,
the alternatives were differentiated according to
the degree of remediation they provide. Various
remediation categories under source control action
specify a range of remediation levels. These
categories are as follows:
No action: No action alternatives may include
minimal actions such as installation of fences/
gates and monitoring activities.
A number of treatment alternatives ranging from
one that would eliminate, or minimize to the
extent feasible, the need for long-term management
-------
table 6 (continual
General Response Action
Ami Associated Remedial
fechnelegtos
••(AIM* for
Alt«roative
Technical Considerations
Other Coosiderations
Recommended
Application to Site
Problem in Remedial
Alternative
Physical/chemical-: •
Precipitation/
flecculatlen and
Sedimentation
c. Physical:
filtration
Yes
Yes
d. Physical:
Evaporation
Proven technology and c
IrtataMt pro<«ss. Has »•«•
klraio^ offoctivo for roaowal of
asbostos froa Ma tor. Laboratory boncfe-
scalo or »t lot-scale testing required
to 4otoro)ino offectiweooss and eotieuo)
process oar*«tors.
Proweo technology *"< coMnnly used
treatewot process. Has been demon-
strated effective for reaoval of
asbestos fro* water. Use as first
treatment step aay result in rapid
clefging of oiicropore filters. Labora-
tory bench-scale or oi lot-scale test-
ing required to determine effective-
ness and ootieuei process parameters.
Proven technology for treatment of
various municipal and haiardous
•astes. Host effective for treatment
of wastes with high solids content;
lagoon waters may not ••Mbit desire-
able characteristics for effective
treatment. Data not available to show
process demonstrated effective for
treatment of wastes similar to those at
site, laboratory bench and pilot scale
tests would be required.
eliminates risk to public health and
environment IWissahickon Creek) duo
to off-site migration of asbestos
contaminated water. Hay require polish-
ing step to conform with discharge
permit/regulations, ly product sludge
requires disposal/treatment. Relatively
low cost; equipment readily available.
Eliminates risk to public health and
environment IMissahickon Creek) due
to off-site migration of asbestos
contaminated water. Hay require polish-
ing step to conform with discharge
permit/regulations. By product sludge
requires disposal/treatment, Relatively
low cost; equipment readily available.
•ackwash or spent filters require dis-
posal/treatment may be effective as
polishing step for other treatments.
Potential risk due to public health
from entrapment of fibers In process
vapor stream. Waste stream would
reqiuro further treatment. Permitting
not required under &AftA?yegulatery
agency approval required.
Lagoon surface
water
lagoon surface
water
Hot ftect
tnded
-------
table 6 (continued)
General Rations* Action
And Associated Remedial
technologies
Retained (or
Alternative
tt
technical Considerations
Other Considerations
Recommended
Application to Sit*
Problem in Remedial
Alternative
S. In Situ treat
t. thermal
cation
In situ vitrift- He
6. On-Sitt treatment
a. thermal: Vitrification
Ves
Developing technology tnat !»»» ooon
•uccotkfully totted on largo-tcalo
|4M to 6M tontl r«4io*ctUt tatto
MtorUlt. Vitrifiorf m»t% o»o«cta4 to
feva looffrtora ttaoility. Pilot
studio* ro^uirod ooforo i«oloownt«-
tion. Prooloo* oxy oo oncountorod duo
to kotorooonoity of tasto oatorialt.
Installation of •ItetrodeI aay oo
difficult or loyractical duo to stoop
slooos and lot* strongtn of pilos. foM
roojuiroaonts a«y oo oacossiwo duo to
nigh Moisture content of e^terials.
Potential exists for collapse of piles
during treatnont.
Developing technology demonstrated
on limited oasis on pilot-scale for
treatment of ashestos insulation
materials from abatement actions.
filet testing would ho reoulred prior
to implementation at the site. Prob-
lems could be encountered due to het-
erogeneity of the waste materials
(such as high moisture content, pres-
ence of high concentrations of calcium/
magnesium carbonatel.
Could effectively inmobiliie inorganic Not Recc
contaminants. Costs could bo restric-
tive due to high power requirements.
inded
Vitrified mass would require disposal.
Risks to public health and environment
could be eliminated; asbestos immobil-
i«ed. Potential exists to recycle
glassified product. Potential risks
associated with removal activities from
release of asbestos to air. oWgulatory
and local agencies approvals required.
Hajor potential ambient air problem
during remeidal action.
Waste piles
lagoon sediments
-------
Table 6 (continued)
General Response Action
And Associated Remedial
Technologies
Retained for
Alternative
Development
Technical Considerations
Other Considerations
Recommended
Application to Site
Problem in Remedial
Alternative
Physical/chemical:
Precipitation/
flocculation and
sedimentation
c. Physical:
Filtration
d. Physical:
Evaporation
Yes Proven technology and commonly used
treatment process. Has been demon-
strated effective for removal of
asbestos from water. Laboratory bench-
scale or pilot-scale testing required
to determine effectiveness and optii
process parameters.
Yes Proven technology and commonly used
treatment process. Has been demon-
strated effective for removal of
asbestos from water. Use as first
treatment step may result in rapid
clogging of micropore filters. Labora-
tory bench-scale or pilot-scale test-
ing required to determine effective-
ness and optimum process parameters.
No Proven technology for treatment of
various municipal and hazardous
wastes. Host effective for treatment
of wastes with high solids content;
lagoon waters may not exhibit desire-
able characteristics for effective
treatment. Data not available to show
process demonstrated effective for
treatment of wastes similar to those at
site, laboratory bench and pilot scale
tests would be required.
Eliminates risk to public health and
environment (Missahickon Creek) due
to off-site migration of asbestos
contaminated water. Hay require palish-
ing step te conform with discharge
permit/regulations. By product sludge
requires disposal/treatment. Relatively
low cost; equipment readily available.
Eliminates risk to public health and
environment (Wissahickon Creek) due
to off-site migration of asbestos
contaminated water. Hay require polish-
ing step to conform with discharge
permit/regulations. By product sludge
requires disposal/treatment. Relatively
low cost; equipment readily available.
Backwash or spent filters require dis-
posal/treatment may be effective as
polishing step for other treatments.
Potential risk due to public health
from entrainment of fibers in process
vapor stream. Waste stream would
reqiure further treatment. Permitting
not required under SARAf^regulatory
agency approval required.
Lagoon surface
water
Lagoon surface
water
Hot Recommended
-------
table 6 |continued)
General Response Action
And Associated Remedial
technologies
Retained for
Alternative
technical Considerations
Other Considerations
Recommended
Application to Site
Problem in Remedial
Alternative
Solidificatien/stabili-
tatiwi - *
Vet- • Solidification techniques not
effective in lo*f term stabilisation
' of asbestos wastes. Weathering
of solidified asbestos work can
result io future releases. Solidifi-
cation of calcium carbonate wastes
with fly asb would allow for the
removal of Ibis waste for partial
en-site or off-site disposal ,
7. Off-Site treatment technologies discussed under en-sito/off-sito disposal
8. Off-Site Disposal
Yes
•V-V
9. On-Site Disposal
No
Ibis technology involves excavation
of contaminated Materials and trans-
pert to approved off-site disposal
sites. Commercial RCRA and municipal
landfill capacity is limited and blob
volumes may not be accepted. Potential
disposal i* municipal landfill witb
special permitting.
Ibis technology involves excavation
of contaminated materials followed by
disposal in an en-site newly con-
structed landfill meeting applicable
RCRA standards. Incorporates proven
techniques and would include surface
management and infiltration control.
Site characteristics may warrant con-
struction of an abovegreund landfill.
Implementation is limited because of
•severe space limitations at the site
and high volumes of material.
Stabilisation of calcium carbonate
waste wilt allow for removal of this
waste and redisposal in a more
stabilised pile en-site or off-site
Waste piles
Materials are not treated or destroyed Waste piles
but the threat to the local environ- lagoon sedii
ment it eliminated by removing the
contaminated materials to a secure
site. Potential risks to public health
associated with removal and transport
of the asbestos duo to airborne asbestos
fibers a RCRA-approved or municipal
(with proper permitted) landfill must
be used. Applicable U.S. 001 requirements
for shipment of waste must be met.
Magnesium/calcium carbonate material may
need to be stabilised. Potential major
ambient air quality risk during remedial
action.
favorable impact to public health and Not Rec
environment due to securement of
contaminated materials. Regulatory
agency approval required, there may be
problems due to dust/airborne asbestos
from excavation activities. Nay net
•wet with public or local agency
approval.
tnts
ed
-------
(including monitoring) at a site, to one that would
use treatment as a primary component of an alterna-
tive to address the principal threats at the site.
Alternatives that involve containment of waste
with little or no treatment, but provide protec-
tion of human health and the environment by prevent-
ing potential exposure and/or by reducing the
mobility.
- The alternatives were developed to a level adequate
to apply the non-cost and cost evaluation criteria,
discussed in further detail later in this section.
The cost-effective alternative is defined as the lowest
cost alternative that is technologically feasible and reliable,
effectively mitigates or minimizes damage, and provides adequate
protection of public, welfare, and the environment (See Section
40 C.F.R. Section 300.68(i) and Section 121(b)(1) of CERCLA).
Section 121 of CERCLA, 42 U.S.C. Section 9621, adds that the
most cost-effective alternative is one that achieves results
that cannot be achieved by less costly methods.
As per CERCLA Section 121 the development of a complete
range of treatment alternatives may not be practical in some
situations. Alternatives within this range typically will
differ in the extent of treatment used and the management require
ments of treatment residual or untreated wastes. For example,
for sites such as the Ambler Asbestos Piles site with large vol-
umes of potentially low concentrated wastes, such an alternative
screened for their suitability to the site according to environ-
that eliminates the need for long-term management may not be
reasonable given site conditions, the limitations of technologies,
and extreme costs that may be involved.
With respect to the Ambler Asbestos Piles site, the remedial
action technologies that, remain after screening are generally
under the source control classification, since on-site controls
are the most appropriate to this site.
Remedial action alternatives that have been developed for
the Ambler Asbestos Piles site are presented in summarized form
in Table 7. For a given alternative, each of the areas of
concern are addressed and the associated Alternative types
from40 C.F.R. Section 300.68 (f) is identified.
EVALUATION CRITERIA
This subsection describes the criteria used for the evalu-
ation of the developed remedial alternatives. The four remedial
action alternatives formulated in Table 7 are evaluated further
based on both non-cost and cost criteria.
-------
fable 7
eMrfiat Actien Alternatives far tit*
Aitler Asbestos Sit*
ActtM
Alternative
Description of
Alternative
fretlew Areas
AMrcssetf
I. Me Actien
2. CicavatlM/lMoval -
Off-Site Disposal
3. On-Sit* VitrificatlM/
StafcilliatlM
• Sit* security le^re
ts
• N* actia*.
M *f Mask* piles a*** • tlsMsal at *ff-sit*
>. facility.
• Sit* security iaB)r*«*4.
ValiMM re4wctie« te icr*
(ea-site).
water fraai
IreataiMt *f water.
• tl«»e»al aV af'-site facility.
C*«strwcti*«/aferatl*« af
••-sit* •r*c*ssl«f
• Ireat*e«t.
• Teiicity
ability »f asbestes
r**Vic*4.
• fu*f> Mater fr*n la^ee*.
•Mit *f water.
freat-
• facavatlM ef waste piles aiMj
lateen sedlawets.
• VitrificatlM ef atMstes
•aterials lailes a/»elie'i-
fiee* Mterlals,
-------
l«ale 7
Actie*
Alternative
Oetcriatle* ef
Alternative
PreMea) Areas
AMretsee-
4. On-Site
M*t«r f
«f
M •! •*•!••! I U
• s«4t
•! IIM ll
• UsUllattM «f
••4 Mil caver awar a*a«sa4
asWsUi a« alia*.
a iMtallatta* af tcaurlnf
aralactla* ala«f Cfca crack
a4laca«t la tfce lacvst Straat
•I la.
a Upa,ra4« •'
sacuriif.
a CaaUlMMl irftli little
ar a* treatment.
a NeMltty ef asMttet CMtaarinant*
a Crastan/saa'laaiiUtlaa caatral
(far riMtaii aad maaff).
-------
- 39 -
The objectives and criteria described herein are consistent
with Section 121 of CERCLA, 42 U.S.C. Section 9621 40 C.F.R.
Section 300.68. The procedures in the NCP are specific for
hazardous substance response and are consistent with the require-
ments of the National Environmental Policy Act (NEPA).
Section 121 Of CERC1A, 42 U.S.C. of CERCLA Section 9621
requires that preference be given to remedies that permanently
and significantly reduce the mobility, toxicity, or volume of
the hazardous substances themselves. In addition, preference
is to be given to remedies using alternative treatment tech-
nologies. Off-site transport and disposal of hazardous substances
without treatment is designated the least favored alternative.
KON-C08T CRITERIA
Non-cost criteria are described in detail in the subsections
that follow and include:
- Technical Feasibility
- Institutional requirements
- Public health and environmental issues
1. Technical Feasibility - The technical feasibility cri-
teria address critical objectives in the technical evaluation
of potential remedial action alternatives. These objectives
include performance, reliability, implementation, and safety.
2. Institutional Requirements - These institutional factors
are used to evaluate the acceptability of each technology to
local, state, and Federal agencies, as well as the potential
for compliance with existing or future regulatory policies. As
an example of institutional criteria, all on-site actions gene-
rally require approved sedimentation and erosion control plans
(if major earthwork is to be performed).
3. Public Health and Environmental Issues - The remedial
action selected must adequately protect human health and the
environment. The remedial alternatives are evaluated for their
effectiveness in mitigating the existing or potential contaminant
exposure to the public. Documentation that the action adequately
controls both the longterm effects to the residual contamination
and short-term effects caused by implementation of the remedial
action, and protects the public, both during and after the
remedial action, is required. Applicable health and environ-
mental health standards are used to evaluate each alternative.
The overall goal of the selected remedial action is to mitigate
the existing environmental threats without creating additional
adverse effects.
-------
- 40 -
COST CRITERIA
According to Section 121 of CERCLA, 42 U.S.C. Section 9621,
a remedial cleanup program must be implemented and operated in
a cost-effective manner and must mitigate the environmental
concerns at the site. Section 121 of CERCLA requires ensuring
that the results of a particular alternative cannot be achieved
by less costly methods. It implies that there may be more than
one cost-effective remedy, with each remedy varying in its
environmental, human health, and institutional results. In
considering the cost-effectiveness of the various technologies,
costs are considered as follows:
- Capital costs
- Operating and maintenance costs
-. post-remediation (monitoring) costs.
Monitoring and maintenance operations can represent a substantial
portion of a remedial action strategy. Remedial strategies
should aim to minimize the added costs for these operations.
The present worth value method (1988 dollars basis) is uti-
lized to evaluate the total cost of a remedial action strategy,
including the post-closure period. The cost-effectiveness for
the various technologies is compared based on total present
worth.
EVALUATION OF ALTERNATIVE 1: MO ACTION WITH SECURITY
IMPROVEMENTS AND MONITORING
A. DESCRIPTION
The purpose of evaluating this no action alternative
is to provide a basis for comparison of existing site conditions
with the other proposed remedial action alternatives. This
alternative consists of performing no physical remediation work
to the piles or lagoon site area. Security improvements consis-
ting of new fencing, access/egress gates (with locks), and the
provision of appropriate warning/informational sign are included
in this alternative. These improvements would be designed to
meet the current EPA, NESHAPS, and PADER regulations regarding
closed solid wast* (asbestos-containing) landfills. Figure 10
graphically depicts a logical location of these fencing, gates,
and sign improvements.
In addition, visual inspections (biannual for the first five
years after implementation) and environmental ambient air moni-
toring would be performed during the following five years after
implementation in order to evaluate whether this action alone
adequately protects human health and the environment.
No other improvements or remedial measures would be under-
taken under this alternative (see Fig. 10.)
-------
S*ciMily Fwic
**> Po»t*d Wunmg and
No Ti«MM«Moa S
-------
- 41 -
B. NON-COST EVALUATION
1. Technical Considerations
t
Since no remedial actions other than site security
improvements, continued inspection, and environmental monitoring
are taken under this alternative, a detailed technical evaluation
is not directly applicable. In general, however, no affirmative
action to prevent direct contact/incidental ingestion or ambient
air inhalation exposures to on-site receptors would occur. As
mentioned in the technology screening subsection of this document,
it is most likely that even with a new fence, gate, posted
signs, and warning system, trespassers (mostly children) would
continue to access the site. The exposed, noncovered plateaus
of both piles and incomplete and eroded areas of the pile side
slopes would continue to be a major source of asbestos and
potential off-site migration of asbestos and potential off-site
migration of asbestos if disturbed.
In addition, no action to reduce the toxicity, volume,
or mobility of the contaminants would occur as stipulated within
Section 121 of CERCLA, 42 U.S.C. Section 9621.
No affirmative action toward meeting the chemical spec-
ific ARARs nor the action specific State ARARs identified in
Altenative 4 would occur. In time, surface water quality from
eroded/uncovered pile areas and the lagoon discharge would
continue to worsen with no provisions for future maintenance/
repairs. Also, the potential of future releases of asbestos
into the ambient air if the exposed areas of the pile are dis-
turbed or cover failure/ erosion continues would not be addressees
2- Institutional Considerations
The following institutional/administrative considerations
are associated with this no action alternative:
Ability to obtain approvals from other agencies
is doubtful based on no affirmative action
over the long-term.
Unfavorable community response (by residents of
Ambler Borough, adjacent communities, and
local environmental groups such as the Wissa-
hickpn Watershed Association) would be expected
due to the projected degradation of ambient
air and surface water quality.
Compliance with site-specific ARARs is not
addressed over the short- or long-term.
-------
- 42 -
3. Human Health and Environmental Considerations
This no action alternative, as previously described,
includes site security and warning sign improvements. These
measures would serve to make access to the piles and lagoon
areas more difficult to unauthorized personnel, and thereby
reduce to some degree the present and future risks via direct
contact/ incidental ingestion and inhalation of ambient air
exposures to on-site receptors. It could be realistically expec-
ted, however, that based on historical accounts, some trespassers
would access the site area and locations of exposed asbestos.
The site is currently partially fenced-in and warning
signs are posted in some areas, although these structures are
not continuous or prominent, and are generally in bad repair.
Also, the gates are not continually locked.
Compliance with chemical-specific ARARs would also not
be provided relative to on- and off-site surface water quality
and ambient air asbestos fiber concentrations.
In addition, although visual and environmental moni-
toring would be provided for, the results of these activities
appear to be a "faitaccompli" in that without maintenance and
repair, the existing soil cap will most likely continue to fail
at localized side slope areas of the piles; thereby exposing
more asbestos to the environment. In this regard, no reduction
in future risks to on- or offsite receptors is provided for,
and in actuality, the situation/risks would worsen (particularly
for off-site receptors). No increase in long-term reliability
is provided for via this alternative.
It is further expected that although no current unacceptable
risks to off-site receptors resulting exclusively from this
site can be quantified (due to other existing potential asbestos
sources in the area), the situation would worsen with time
until either these other sources are remediated. Releases from
this site would increase to the degree where numerical degrada-
tion of air and surface water quality would be quantifiable,
and directly related to this site.
In summary, the non-cost-related considerations and
feasibility for long-term effectiveness of this alternative are
not favorable.
C. COST EVALUATION
Capital costs associated with this alternative include
fencing to enclose the site, installation of gates and locks,
and warning signs on the fences. The total capital cost for
Alternative 1, presented in Appendix A, Table 8 is estimated at
$165,000.
-------
- 43 -
Operating and Maintenance (O&M) costs are estimated at
$23,400/yr, as shown in Appendix A, Table 9. These costs are
incurred during long-term monitoring for.asbestos and mainte-
nance of the facility. A summary of the total costs and the
present worth analysis of each alternative are presented in
Appendix A.
EVALUATION OP ALTERNATIVE 2t EXCAVATION/REMOVAL - OFF-fllTB
DISPOSAL
A. DESCRIPTION
This alternative consists of complete excavation and
removal of the Locust Street Pile, Plant Pile, and Lagoon areas
waste materials to an off-site permitted/approved landfill.
The general major components of this alternative are
shown in Figure 11 and would include:
Piles
- Diversion of runon and construction of runoff contain*
ment/ treatment facilities;
- Complete excavation of the waste materials (asbestos
wetting and/or dewatering as applicable, as well as
calcium/magnesium carbonate dewatering) - Level C
protective measures would be required for remedial
activity for approximately 50 percent of the time;
- Continuous air and surface water monitoring;
- Bagging of asbestos wastes, physical conditioning/
solidification of interior wastes prior to loading
and transport to an approved facility;
- Transport equipment decontamination prior to site
egress;
- Soils testing for verification of cleanup criteria;
• Hauling clean soil fill and fill/regrade the site for
positive drainage;
- Revegetate.
Lagoon
- Diversion of runon and collection of runoff;
. Pump down and treatment surface water contents in
lagoon (estimated at 1.9 million gallons);
-------
FIGURE II AtTERNATIVEZ - Of F Sl« OISI»O£
-------
- 44 -
- Complete excavation/removal of lagoon materials
(sands/ sediments, ballast berms, discharge struc-
ture, etc.)/ including dewatering as applicable/
- Repair and restrict access to stone culvert adjacent
to lagoon and restrict future access;
- Bagging and loading of waste materials prior to
loading and transport;
• Air and surface water monitoring.
Decon of transport equipment prior to egress from the
site;
- Test soils to verify cleanup criteria are met;
Fill in lagoon area with clean borrow soils and
regrade for positive drainage;
- Revegetate.
EP Toxicity tests performed on the underlying calcium/mag-
nesium carbonate waste materials and cinder/slag material did
not result in leachates that exhibited hazardous waste character-
istics in terms of EP toxicity. Within this assumption, these
waste materials, as well as the other miscellaneous debris that
make up the piles and lagoon wastes, could be landfilled in a
solid/municipal waste landfill.
The results of the geotechnical boring and test pit sampling
programs performed during the RI indicate that the quantities
(in cubic yards) waste materials contained in each of the three
source areas on-site are as follows:
Waste total
Locust Street
Pile 615,000
Plant Pile 640,000
Lagoon 4,500
Total » 1.26 + million cubic yards
A detailed remedial design would need to be prepared in
order to perform this alternative safely due to the saturated
and unstable physical condition of the interior of both piles.
In addition, prior to and during construction, extensive health
and safety protocols would need to be developed and implemented
to minimize migration of asbestos-contaminated wastes into the
air and surface water after intruding into the piles and/or
-------
- 45 -
lagoon. Also, it would have to be determined where these wastes
would and/or could be taken for off-site landfilling due to the
massive quantity involved. These considerations are discussed/
evaluated later in this subsection.
B. NON-COST EVALUATION
1. Technical Considerations
This alternative would involve very extensive remedial
design and preconstruction planning work. It appears this
alternative could be feasible from a strictly technical view-
point; however/ it would be a massive construction undertaking
(particularly from geotechnical and construction safety points
of view) and would span over many years. The major advantage
to this alternative is that the waste materials would be com-
pletely removed, thereby reducing to the greatest degree possible
the permanent remedy with reference to this site (although the
wastes would be deposited elsewhere with the same volume and
toxicity characteristics). If solidification/stabilization of
the calcium/ magnesium carbonate material was performed prior
to hauling off-site, the final volume may actually be greater.
Another advantage is that future monitoring/maintenance
of the site to ensure long-term integrity would not be required.
The constructability of this alternative is somewhat
questionable at this time. Additional geotechnical testing and
stability analysis would need to be performed to evaluate the
stability of the piles, as portions of the piles were removed
for off-site disposal. Of greatest concern is the stability of
the calcium carbonate waste contained by the cinder, slag, and
solid asbestos waste berms. In many portions of the piles,
where the calcium carbonate is nearly or totally saturated, the
bearing strength of this material is too low to support its own
weight and acts as a viscous fluid. This means that the asbestos-
contaminated cinder and slag berms material could not be removed
in one phase or the interior of the piles would slump, creep,
or even collapse suddenly upon removal of its existing lateral
support.
Obviously this condition would be very dangerous to
construction workers and others who may enter the site. Also/
these waste materials would tend to slump down and consume more
ground space, which is generally not available, particularly
adjacent to the creek, existing structures, and possibly even
the commuter rail line. This condition would get even worse
during precipitation events.
Accordingly, construction would need to proceed in
phases from the middle-top of each pile and down toward the
existing ground surface. It is believed that even under this
mode of operation, the heavy equipment required could not be
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- 46 -
supported by the pile materials. Localized puncture shear
failures would occur without first stabilizing the material, as
was performed during the field investigation to access the drill
rig. The piles may not be able to support large construction
equipment, resulting in potential deep circular or other type
failure of the side slopes. The slope stability analysis of
the piles indicates the piles could support light- to medium
size equipment. Physical safety would be a major concern.
Runoff quality would be very poor, requiring treatment prior to
discharge from a chemical, pH, and total suspended solids loading
point of view. Due to the heterogeneous nature and age of the
piles, it also would not be known what other types and/or sizes
of foreign objects may be encountered inside the piles. Exten-
sive dewatering and treatment of the decant liquids would also
be required. Solidification via admixture of dry materials
would likely be necessary in order to make this material both
transportable and landfillable. Without providing some degree
of solidification, transport off-site may be a very "sloppy"
operation. Spills and leakage would be expected enroute to the
designated new landfill(s).
Removal of the asbestos process waste and the asbestos
contaminated slag and cinder berm materials presents several
problems that would also exist during remedial action. The two
most prevalent of these would likely be releases of asbestos
fibers to the ambient air and surface water during excavation
and loading and transport, along with the need to "double-bag"
these materials per current regulations for transport and
of asbestos. A mechanical system would likely need to be
designed and constructed to accomplish this without extensive
handwork that could result in direct contact and potential
inhalation of asbestos fibers by workers. Even with this type
of system, maintenance would be required, foreign objects would
likely upset the mechanical operation, and cleanup of spillage
would be required.
It could be argued that by wetting down the exposed asbestos
wastes, acute releases could be controlled. However, it was
noted during the RI drilling program that the surface of exposed
materials can dry out during prolonged hot and windy conditions.
Realistically, it is believed that migration of asbestos fibers
into the air could occur during weekends, holidays, shut-down
periods, and potential periods of worker inefficiency during
the wetting operation. Extensive monitoring would be required
on an almost continual basis.
Full-time supervision and inspection by OSHA and/or
other agencies would likely be required. Extensive transport
vehicles, decontamination, and site security policies would be
needed to ensure that asbestos is not racked/spilled offsite in
Ambler Borough, adjoining communities, and enroute to the recei-
ving landfill(s).
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- 47 -
As a rough estimate, at a rate of 40 truckloads per day
(one truck-load leaving the site each 15 minutes for a duration
of 10 hours per day); a five-day work week; and 20 cubic yards
per truck; it would take approximately 6 years of continuous
operation to remove 1.26 million cubic yards.
The contaminated lagoon sediments consist mainly of sand
and soil, with varying quantities of asbestos fibers present.
These sediments are located beneath an estimated one-half to
ten feet of water currently in the lagoon. The sediments and
other contaminated media would be removed to a depth where
sampling and testing indicated that the cleanup criteria for
asbestos-contaminated material had been met. For this reason,
the quantity of material to be removed is very difficult to
estimate. Assuming a three-foot layer of contaminated sediment
on the bottom, and when adding the volume of contaminated adja-
cent surface soils and the ballast/slag beams that were apparently
installed to filter the effluent prior to discharge, the projected
approximate quantity of asbestos-contaminated media is 9, 600
cubic yards.
Excavating the sediment from the lagoon would require that
it be drained or pumped out first, followed by the use of a
clam shell crane or dredger. Excavation would begin at approxi-
mately 10 feet below grade and extend to an undetermined depth.
Such an operation would proceed very slowly and would present
risks to on-site workers.
In summary, the technical feasibility of the alternative
is not favorable for the various reasons discussed above.
Institutional Considerations
The availability of landfill space in the somewhat local
area is also a realistic concern with this alternative. Munici-
pal/solid waste landfill capacity in the areas surrounding this
site (Pennsylvania, New Jersey, Delaware, Maryland areas) is
not abundant. Also, many of the landfills that do have capacity
are not currently permitted to accept asbestos wastes. Problems
also exist with transporting and landfilling wastes to out of
state locations, which further realistically limits available
sites for disposal.
According to conversations with PADER, the landfills
that are currently permitted to receive asbestos-contaminated
wastes (classified as "special handling municipal waste") in
.the eastern Pennsylvania area include:
- Grand Central Landfill - Located in Plainfield Town-
ship, North Hampton County, Pennsylvania. The pro-
jected capacity is 840,000 cubic yards (provided by
operator), which is planned to be filled with other
solid waste over the next two years. The distance
from Ambler is approximately 50 miles.
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- 48 -
- Pottstown Landfill - Located in Pottstown, Montgomery
County, Pennsylvania. The remaining existing capacitv
is 2,000,000 cubic yards (plus or minus). The existj|
time frame expected to fill this space with other
solid waste is approximately 2 years. It is located
approximately 40 miles from Ambler.
- Empire Sanitary Landfill - Located in Taylor Borough,
LacJcawana County, Pennsylvania. It is located approxi-
mately 100 miles from Ambler. Available remaining
capacity was not available.
In addition to potential lack of available landfill capacity,
it would take a multidisciplinary remedial action contractor
(and likely an array of subcontractors) with substantial tech-
nical, financial, and manpower resources to undertake a project
of this nature. These type of firms do exist, but are not
abundant.
Other institutional considerations involved with this
alternative include:
- Potential delays, coordination problems, and/or
disapproval by other involved agencies (state, county,
and local) due to various factors.
- A likelihood of objections by the local citizens'in
Ambler communities, communities enroute to the receial
ing landfill, and particularly the receiving communi
due to risks involved with releases of asbestos to
ambient air and environmental media the result of major
intrusions into the piles, transport problems, and
potential releases at the receiving facility.
Compliance with ambient air, surface water, and occupational
requirements may also be difficult to achieve during remedial
action under this alternative.
In summary, although some citizens and officials in
Ambler Borough would likely favor the long-term advantage of
removing the piles from the borough and "reclaiming" this land,
the overall institutional feasibility of this alternative is
not favorable. (Sea Section 121(b)(2) of CERCLA, 42 U.S.C.
Section 9621(b)(2)).
3• Public Health and Environmental Considerations
A long-term, post-remedial reduction in future risks
to on-and off-site receptors on and around this site could be
accomplished through implementation of this alternative. Long
term compliance with sitespecific ARARs and elimination of
future inspection and maintenance could also be accomplished
through this alternative.
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- 49 -
As discussed in the previous subsections, however, the
excavation of these materials could likely cause increased
releases of asbestos fibers into the ambient air and surface
waters. The health risks to workers, the adjacent community,
and environment posed by these releases have the potential to
be substantial and could be prevented with another alternative
that did not entail excavation or major disturbance of these
materials.
This alternative would entail significant potential health
and safety risks to workers, including direct contact with
great quantities of asbestos-laden materials and physical safety
hazards associated with the potentially unstable piles if major
intrusive activities were performed.
Over the "short term" (during remedial action), increases
to existing risks are assured should this alternative be selected.
Also, as previously discussed, the length of time involved to
remediate the site under this alternative is substantial.
In summary, the feasibility of this alternative with
respect to human health and environmental considerations has
some advantages over the long-term. However, the substantial
potential for increased risks to on-site and offsite receptors
during remedial action appears to outweigh the long-term advan-
tages.
C. COST EVALUATION:
The capital cost for alternative 2 is estimated at
$2,446,000, as presented in Appendix A, Table 10. Operating
and maintenance (O&M) costs are provided in Appendix A, Table
11. The O&M costs have been estimated at $30,828,000 for the
first seven years during remedial activities and $2,800 for
five years after remediation. Post-remediation costs involve
monitoring activities to verify effective cleanup.
EVALUATION OF ALTERNATIVE 3; ON-SITE
VITRIFICATION/STABILIZATION (VIA PROCESSING PLANT(8))
X. DESCRIPTION;
This alternative would involve further pilot-scale devel-
opment and analysis, and potential future construction of a
full-scale vitrification and/or vitrification and stabilization
plant(s) on the site.
Vitrification is a process wherein asbestos-contaminated
materials can be transformed by melting (at extremely high
temperatures (1,300.F)) into a nontoxic glass-like material.
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- 50 -
This process differs from the technology referred to typi-
cally as "in situ vitrification", which melts the contaminated
material through probes driven into the contaminated material.
Consequently, this process requires excavation of the asbestos
contaminated materials, hauling to the plant, and fed into the
furnace structure. Electric power construction requirements
for the vitrification process, based on reported data (supplied
by vendors), would be very large (estimated at 1,000 kw per 1
ton of asbestos waste processed). A new electric substation
would likely need to be constructed on or near the site, or
substantial revisions to the existing facilities and major
service lines than run into the site.
Vitrification in both of these forms has been, and continues
to be, an application of interest to regulatory agencies,
including EPA; and is most accurately described in its current
state of development as an "innovative technology." EPA has/is
currently evaluating these processes as part of its Superfund
Innovative Technologies (SITE) program. At least one "demonstra-
tion project" regarding vitrification via the processing plant
type of operation has been performed in the recent past. EPA
and REM II personnel visited a pilot plant version of this process
at a former glass works in Martinsburg, West Virginia, on June
29, 1987, to investigate this technology's potential applicability
for use at the Ambler Asbestos Piles site. A "trial burn"
using bagged asbestos material from abatement projects was run
through this plant; which was developed, constructed, and operated
by "Vitrifix of North America, Inc." Relatively small quantities
(with relation to the volume of asbestos-contaminated materials
that would require processing at the subject site of this
RI/FS) appeared to have been successfully transformed into glass-
type end products during this demonstration.
At the time of the pilot plant visit, only 1 ton/hour of
asbestos material was being processed with plans to increase
feed rates to 5-6 tons/ hour. These materials generally con-
tained a higher average asbestos content (45 percent asbestos)
than expected from the pile wastes and lagoon sediments that
would require processing at this site. The "feedstock" was
noted to consist mostly of previous bagged asbestos abatement
types of wastes (from building and factory cleanups); although
some lower content asbestoscontaminated materials were also
processed. The process also requires the addition of soda
lime-based glass (or other source of sodium ions for use as an
electrolyte) to maintain the electric current across the elec-
trodes that melt the asbestos wastes. Normally 20 percent of
the feedstock is glass (cullet).
From the work performed and results published to date, the
processing plant type of vitrification appears to be a viable
and potentially promising technology for asbestos transformation
and detoxification at certain types of sites and waste streams.
To our knowledge, however, no fullscale, extended runs have
been performed to date that limit current ability to totally
evaluate the technical, operational, and cost related variables
of this technology over the long-term.
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- 51 -
At this time, several vendors are apparently working on
variations of this technology for potential large-scale applica-
tion to sites of various types. Vitrifix of North America,
Inc. previously submitted a method statement (November 1986)
for applicability of their process to the Nicolet Plant Pile
Wastes which was evaluated by EPA.
With regard to the Ambler Asbestos Piles site, this techno-
logy appears most applicable to the asbestos-contaminated materials
from both piles and the lagoon sediments.
It is technically possible that this type of process can
include the calcium/magnesium carbonate wastes as part of the
cullet feedstock if sand is also added. Although the quantity
of calcium carbonate in the piles far exceeds the volume that
could be processed based on an 80 percent asbestos/20 percent
cullet feedstock ratio.
Regarding these internal materials, it is also possible and
potentially more practical to stabilize the magnesium/calcium
carbonate wastes via pozzolanic, cement-kiln dust (CKO) and/or
thermoplastic solidification/stabilization methods (although no
bench- or pilot-scale studies have been performed to our knowledge
on these materials in this regard). These technologies have
been utilized on various other types of projects, however; with
same degree of success.
In simplified form, the major components and sequence of
construction for Alternative 3 are shown in Figure 12 and are
as follows:
Research, test, analyze, and further develop the
potential vitrification and/or stabilization technolo-
gies on a bench-scale, to a greater degree with site-
specific materials leading toward possible approval
of certain pilot- and full-scale systems to "treat"
on-site the waste materials at this site (treatability
studies).
Construct full-scale on-site facility(ies). Many
significant feasibility variables such as location
and space requirements; electric and other utility
services; financial and liability agreements; environ-
mental emissions and discharge limitations; health
and safety protocols; etc., would need to be worked
out prior to start of construction.
Excavate, haul, and stockpile waste materials from
both piles and the lagoon in a sequenced manner (over
a number of years) in order to provide the feed
materials to the plant(s). Site preparation (runon
diversion, runoff control, haul roads, etc.) similar
to those previously described under Alternative 2 -
-------
I ow Ptatticiiy SiM and Clay
Cowar Soil
Giay Vary Moist Fteou* Malarial
(< 5 SO* AitttMoi Datacted)
Slag. Cindar*. SoM and Hardanad
MagnaMom/Calcium Carbonate and
Sandy Malarial (Contain* Varying
Amount ol Aabaatot)
Slag. Cmdais. Oul-ol-Spac Aabatioi
MiH Board. Shmgtat. Piping. Sandy
Malarial, and Hardanad Caloum/
MagnaaiuM Carbonate
Soil Vary Moitl Daptatad
Magrtaatum/Calciuni Carbonate
(No Aataaatoa Datectedl
Adiailo* Conummg MMWMlt Wdl FwM b« B»*»onad
FIOM Pit* and W**«J into a GUM LA* Pioducl m
an On Sit* F*c*ly and Ftmapoiited On S«*
Uo.,
FIF*al
FIGUflE 12 AtTB(NATIVE 3 ON Sift
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- 52 -
Excavation and Removal, would need to be employed
first. Substantial constructability and health and
safety concerns (releases of contaminants to ambient
air) would need to be addressed first, as previously
discussed.
A "set-aside area" would have to be constructed to
deal with large and/or foreign materials that could
not be fed into the plant. These materials would
likely ultimately require landfilling either on- or
off-site.
Extensive environmental and personnel monitoring for
workers and off-site receptors would be required in
order to quantify potential releases and the impacts
on the local ambient air. Even with required wetting
and other dust/fiber suppression controls, unaccepta-
ble releases may occur as a result of excavation and-
process activities requiring a completely enclosed,
"bubble canopy" work area. Even with these types of
systems, exhausts and emissions are imminent and
problems with current applications in other industries
are well-documented.
At best, the process would most likely require
substantial modifications and/or additions as the
project continued in order to deal with new data and
the waste materials types/consistencies encountered
during excavation.
Assuming that the estimated 1.26 million cubic yards
could be processed and/or segregated (and portions
landfilled), it is not currently known what could/
would be done with the final product. According to
vendors, although there are certain potential useful
purposes for the final product materials (i.e.,
roadbase materials, structural fill, landfill inter-
mediate cover, etc.), to our knowledge no current
reuses of these materials on a large-scale have been
documented; not to mention post-reuse monitoring/eval-
uation of final product properties. With the current
information available, it appears very likely that
the great majority of these end-product materials
would have to be relandfilled, either back on-site
in the form of "new-piles" or transported off-site
to an approved location for filling.
At the completion of processing operations the
plants(s) would need to be dismantled and removed
unless a continued use for them could be found.
The site would be backfilled and regraded for
positive drainage, and revegetated. If materials are
redeposited on-site, the material would be covered
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- 53 -
with a soil cover of a two-foot thickness. The cover
would be vegetated and graded for positive drainage.
It is not known at this time what volume reductions
of waste materials could be expected using the vitri-
fication process. Stabilization of the magnesium/cal-
cium carbonate would result in an increase in waste
volume. Space constraints and slope requirements may
limit on-site redisposal.
In general, this alternative would involve extensive pre-
design/ implementation pilot studies and construction of facility
safety and support systems. Because this treatment technology
is not a proven technique for large volumes of wastes containing
variable concentrations of asbestos, it can be estimated that
it would take several years before the feasibility of this
technique is proven. Assuming that the technologies could be
developed and would prove feasible and effective, it would
provide a potential for a permanent remedial solution for this
site. However, the potential short-term health risks associated
with the excavation and processing of asbestos material presents
a considerable risk to local residences. Further discussion of
technical, institutional, public health, and cost considerations
are provided in the following sections.
B. NON-CO8T ANALYSIS
!• Technical Considerations
*
From a purely theoretical point of view, the vitrification/
stabilization process represents a technology that could offer '
many advantages toward permanent remediation of this site. The
vitrification process has recently been recognized by EPA as a
means of transforming asbestos into a less toxic form through
"destruction" of asbestos fiber structure on a microscopic
basis. In this way, the process is capable of reducing the
toxicity and in certain ways the mobility of asbestos contami-
nants over a long-range basis. In relation to this site,
however, several major and realistics technical limitations are
involved; some have been described in greater detail earlier in
this document as follows:
The process itself has not truly been proven on a full-
scale basis for application on a site such as Ambler.
Asbestos Design requirements, construction technologies,
operational problems, and site-specific considerations
are at this time left undefined by the vitrifix Company.
The constructability of the excavation of the piles is a
major concern and could prove to be not infeasible under
under further study due to the problems and potential
physical and chemical (asbestos) dangers that exist, as
related to removing the asbestos-contaminated outer
-------
- 54 -
materials and having to deal with the saturated and
almost negligible shear strength of the underlying
interior calcium/magnesium carbonate wastes (which
compromise the majority of the interior of the piles,
as previously discussed).
During the period of remediation, it is likely that
many ARARs regarding ambient air and/or surface water
quality would not be met.
It does not appear that the vitrification process is
intended for or best-suited to "treat" the interior
pile materials. In this case, an additional stabili-
zation process (pozzolanic or thermoplastic techniques,
each of which are also currently untested with respect
to this site), would likely be determined to be required.
The methods, although possessing great advantages in
their own regard, are generally classified as more
encapsulative than destructive technologies; offering
potentially less long-term reduction in toxicity and
mobility. Also, under these techniques the volume of
the final waste product to be dealt with in actuality
increases through the addition of solid and reactive
ingredients, certain of which possess their own leachable
constituents that can affect other environmental media.
If a ratio of one-half to one mixing (additive rate) is
assumed as being required in order to bulk-up and
increase the shear strength of the internal pile mater-
ials; and further, if this mixing ratio was proven to
be required (in order to allow construction of more
stable slope configurations, etc.) an increase of approx-
imately 33 percent would occur in the final volume of
resultant stabilized waste materials.
This technology may result in contracting new piles of
even higher elevation than those that exist, and it is
not likely that this site could contain this increased
volume, necessitating transport and landfilling off-
site (unless an alternate reuse could be found).
Regarding reuse potential for both potentially vitrified
and/or stabilized wastes from this site, it is not
known of any that currently and feasibly exist on such
a large-scale basis. To our knowledge, no major local
DOT agencies or others have endorsed largescale reuse
of these products under their construction programs.
Although these potential reuse options have merit for
certain sites and specific waste streams, it is not
believed that they are realistically feasible for this
site at this time. At best, this alternative would
involve years of pilot-scale testing before becoming
potentially suitable and proven for use in such a large-
scale project.
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-55-
In summary, the technical feasibility of this alternative
does not appear to be favorable.
2. Institutional Considerations
Regarding institutional and associated considerations,
the following analysis is provided:
Because no reuse mechanism for either the vitrified
and/or stabilized materials is currently known of or
envisioned in the near future for such a large-scale
application, it is most likely that off-site landfill-
ing at an approved landfill would at least partially be
required (even if some percentage of the materials were
relandfilled on-site to a more stable configuration
after processing). As previously discussed, a potential
shortage of currently projected landfill capacity for
the regions around this site has already been evidenced,
and is a recognized substantial problem; even without
consideration of the relocation of extremely large
volumes of waste material present at this site. Proces-
sing likely requires near "around-the clock" operation
due to the major hardware investments and components to
be developed near the plant to feed it. This would
create even more potential source areas for migration
of waste constituents (particularly asbestos to the
air). Public reaction to this situation can be pro-
jected to be unfavorable due to exposure risks to off-
site receptors.
As previously discussed, transport safety concerns
and the high potential for community disapproval of
hauling wastes off-site would most likely exist.
CERCLA (October 1987) states that certain sites may
not be realistically suitable for application of
treatment technologies. A portion of this sub-
section is included below for direct reference, as
follows:
"The use of treatment technologies may not be practic-
able at some sites with large volumes of potentially
low concentrated wastes (e.g., large municipal land-
fills or mining sites). Remedies involving treatment
at such sites may be extremely expensive or difficult
to implement."
Over the long-term (after remedial action), assuming
that this alternative could become technically and
institutionally feasible (which appears remote at
this time), the sources of asbestos on-site would be
greatly, if not almost entirely removed, except for
residuals left on-site. In theory, this occurrence
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- 56 -
would seen to be advantageous. However, when
considering the potential for substantial emissions/
discharges to off-site areas during a longtenn and
extensive remediation project such as would result
from this alternative, it is believed that the
asbestos that could potentially migrate off-site in
this time frame would continue to impact the surround-
ing area (via residual contamination to ambient air
and surface water) for a period beyond the remedial
action itself. It is possible that the amount of
asbestos that could leave the site via these pathways
may be more than what would leave the site over the
long-term, even if no remediation at all beyond the
current status was attempted.
In summary, the public health and environmental feasibility
of this alternative is not favorable.
C. COST ANALYSIS:
The preliminary capital cost of Alternative 3: On-Site
Solidification/Vitrification, is estimated at $99,376,000, as
presented in Appendix A, Table 12. O&M costs are provided in
Table 13. It is assumed that, using the vitrification treatment
process, it will take 20 years to complete remediation of the
site. Some costs estimated for this alternative are speculative
due to the technical uncertainties that are associated with
some of the components of the alternative. Post-remediation
monitoring would be required; however, these costs have not been
included in this estimate cause of the uncertainties associated
with the length of time for completion to the vitrification
treatment process and the relative low magnitude of monitoring
costs compared to the remediation costs of this alternative.
EVALUATION OF ALTERNATIVE 4t ON-SITB CLOSURE
A. DESCRIPTIONt
Alternative 4 involves placement of a cover system on each
of the asbestos-containing waste piles and clean fill in the
existing lagoon and settling basins. The major components of
this alternative involve the following:
- Pumping of water from the lagoon and settling basins,
followed by filtration for removal of asbestos fibers.
Discharge of the treated water on-site. Placement of
filter backwash on the waste piles;
Installation of a geotextile over the lagoon and
settling basins with clean, low permeability compacted
soil (bringing the depression up to grade to promote
long-term positive drainage);
-------
- 57 -
Backfill of the lagoon and settling basins with clean
low permeability compacted soil (bringing the depres-
sion up to grade to promote long-term positive drain-
age) ;
Installation of geotextile and soil cover for the top
of the Locust Street and Plant Piles;
Repair of erosion on waste pile side slopes due to
storm events, soil creep, freeze/thaw effects, etc;
Installation of gabions or Rip-Rap for protection of
the Locust Street Pile from the scouring action of the
Wissahickon Creek;
Installation of fencing/locking gates to prevent
unauthorized access to the site and, posting of warning
signs;
Erosion/sedimentation controls during remedial activi-
ties and until vegetation establishes;
Air monitoring for asbestos during remedial activities
(personnel and environmental);
Post-closure inspections, maintenance of the piles,
lagoon, and settling basin areas, and preparation of
a contingency plan.
Figure 13 provides a graphic illustration of Alternative 4.
Implementing this alternative would first involve pumping
the water from the lagoon and settling basins and leaving the
sediments in place. A geotextile cover over the sediments
(immediately after draining to prevent drying and wind dispersion)
would be installed, followed by backfill with clean compacted
soil. The backfill and geotextile cover would protect the
buried asbestos fibers from freeze/thaw weathering and impede
their potential resurfacing.
Since previous laboratory analyses showed that the lagoon
and settling basin waters contain asbestos fibers, they must be
treated before being discharged onsite. This treatment would
include flocculation, followed by a mixed media filter in series
with a microfilter to separate the suspended sediment and asbes-
tos fibers from the water. The treated water could then be
discharged on-site. The status of the current site NPDES permit
would need to be checked and reapproved by the Commonwealth of
Pennsylvania prior to discharge. Collected sediment and asbestos
would be placed on the piles prior to cap construction.
It has been documented that asbestos fibers do not exhibit
migration potential through underlying soils into the groundwater
(U.S. EPA, Dalton, D., 1985). Therefore, infiltration and
leachate control are not a primary concern at this site.
-------
Via
Muh«» and (iiadMtu
ol Final C«p tu P
FIGURE I i ALTEHNAIIVE 4 ON Silt
-------
- 58 -
Cap construction would primarily involve covering the tops
of the piles with a to be determined depth of recompacted soil
(graded promote to drainage). The cap would consist of a geotexa.
tile fabric above which would be placed soil that exhibits low
erosion characteristics. Trees, shrubs, and grasses would be
cut down to pile level and covered with an impregnated geotextile
material to inhibit future growth prior to placement of the
geotextile and soil cap. Jute-netting would then be securely
staked in place, where required, to hold the soil until vegetation
establishes. The side slopes are already substantially covered,
and a good stand of crown vetch vegetation exists in most locations.,
Additional soil would be placed over geotextile fabric that was
cut to fit and anchored in place, then vegetated; where signif-
icant erosion has occurred to date. Drainage improvements via
channels and flumes would also be performed.
Security at the site would be increased such that new eight-
foot tall fencing with barbed-wire would be installed around
the entire perimeter of the piles and lagoon area to prevent
unauthorized access to on-site areas. Locking gates would be
provided for access to authorized persons in the future. Warning
signs would also be posted on the fences, detailing the asbestos
hazards on-site.
Inspections of the site would be biannually for the first
five years after initiation of remediation. A written report
that details the effectiveness of remediation would be submitted
at the end of five years (as required by Section 121 (c) of
CERCLA, 42 U.S.C. Section 9621(c)). An annual inspection of i
the site would be required thereafter to ensure that human
health and the environment are being adequately protected. Long
term cap maintenance such as local erosion repair, grading,
seeding, etc., will be required to promote cap integrity over
the long term. However, based on action in 1984, future main-
tenance is expected to be low.
During on-site activities, erosion and sedimentation controls
such as channels, silt fences, jute-netting, and sedimentation
ponds would be used, as needed. Finally a contingency plan
would be developed to ensure that appropriate remedial action
will be taken if local failure of the new cap were to occur.
-------
- 59 —
B. NON-COST ANALYSIS
1. Technical Considerations
The primary function of a cap that covers asbestos
material is to provide a barrier between the asbestos and the
•atmosphere, thereby preventing releases of fibers into the
ambient air. The cap must be structurally sound to prevent re-
exposure of the asbestos fibers and provide the integrity neces-
sary to ensure public health and safety at the site under existing
and potential future uses. Cap design must include considerations
for potential frost heave and/or settlement damage, as well as
erosion control so that risks of exposure to asbestos fibers is
minimized. The cap for the Ambler Asbestos Piles site should
provide protection for the cap materials and underlying wastes
against freeze/thaw effects and should provide increased stability
to the surface of the piles.
Installation of a cap on the Locust Street Pile is
complicated by the fact that a large number of mature trees and
shrubs have grown in certain areas. Over a long period of time
which could cause them to break off or fall over and uproot;
with subsequent potential release of asbestos fibers. Also, in
the summer, leaf coverage can prevent adequate growth of vegeta-
tion under trees. This increases the effects of erosion. These
trees, shrubs, and grasses would need to be cut down to pile
level and the trunks/roots left in place so that the asbestos
would remain undisturbed. In this way, the potential for future
release by uprooting is addressed. Also, vegetation would be
able to grow around the trunks and serve to minimize erosion
effects. A geotextile cover impregnated, rootgrowth discouraging
geotextile would be placed over these locations to prevent
resurfacing of major deep-rooted vegetation. These products are
now commercially available for cap applications.
The useful life and reliability of a cap is significantly
affected by the degree of maintenance it receives. Therefore,
to maximize its efficiency and the length of time the cap main-
tains its integrity, maintenance would be required (particularly
for the next 5 to 10 years after completion of remedial on-site
closure).
Installation of a cap on each of the identified waste piles
involves common construction practices and materials. However,
at the Ambler Asbestos Piles site, the use of lightweight equip-
ment is required because the piles may not be able to support
heavy duty machinery in certain locations. The geotechnical
analysis performed as part of the RI/FS has indicated a low
factor of safety for most existing external side slopes on both
piles (0.96 to 1.15 in general for critical locations). Addi-
tional detailed geotechnical analysis is recommended for the
remedial design stage of the remedial action program for this
-------
- 60 -
site to investigate in greater detail how the additional surcharge
weight of the three-foot soil cap proposed herein along with
the weight of construction equipment during remediation may
affect factors of safety for slope stability during and after
remediation at specific locations around the piles. Substantial
geotechnical effort has been expended during the RI/FS project
in order to provide profiles of the piles, soil/waste strength
data, existing condition slope stability analysis, etc. From a
qualitative point of view it is not currently believed that the
additional soil loading which would result from cap installation
or surcharges from small, light construction equipment would
realistically change the equilibrium of total driving to resisting
forces which has apparently established itself in the many
years that the main structure of the piles has existed and not
failed (based on the proportion of the pile sizes to future
additional soil loadings, and the decades over which the pile
slopes have maintained themselves without apparent slope insta-
bility and no reported slope instability problems encountered
during the 1984 emergency action); however, this needs to be
confirmed by a more detailed and specific geotechnical analysis
during remediation. The final determination in this regard is
beyond the scope of this investigation.
For purposes of this ROD it is assumed that cap placement
is feasible, with proper future analysis, safeguards, and controls
in place.
Caps similar to that discussed in the description of this
alternative have been proposed at other sites for asbes'tos
remediation. In June 1987, the EPA issued a Record of Decision
(ROD) for the Johns-Manville Superfund site in Illinois. Waste
materials primarily containing asbestos fibers had been deposited
in a variety of pits. According to the ROD, these pits were to
be closed with a soil cap consisting of 6 inches sand, 18 inches
clay, and 6 inches topsoil to be graded and vegetated.
The EPA has also taken a similar approach at a number of
Superfund sites in Nashua, New Hampshire, and surrounding vicinity.
Thirty-inch covers were installed at the Shady Lane, Pointer,
Bursey, Matarazzo, Ridge Avenue, Lowell Road, Niquette Drive,
Russell Avenue, and South Bank asbestos sites. The covers were
applied in accordance with the U. S. Army Corps of Engineers
specifications which include an application of geotextile fabric
if slopes were encountered, then bank-run gravel, then pea
gravel (if the bank-run gravel was too coarse), then topsoil.
Erosion control devices such as concrete runoff pans, drainage
ditches lined with bank-run or larger stone and vegetation
acclimated to the area also were installed. If slopes were
steep, gabion walls were erected to prevent sloughing of cover
materials applied. The state of New Hampshire cover specifi-
cations differed in the depth of the cover; a 24-inch cover was
deemed acceptable to the State. The 30-inch cover applied by
the Corps of Engineers on the past actions might be increased
to a 36-inch cover, so it is evident that there is some differ-
-------
- 61 -
ence of opinion regarding the proper depth of the cover. As a
point of reference, the Corps of Engineers unofficially designated
a 50-year life expectancy on the 30-inch cover when the cover
is applied over surface-exposed asbestos. The National Emission
Standards for Hazardous Air Pollutants (NESHAP) requirements
include a six-inch cover with vegetation as provision of ade-
quate protection to public health and the environment.
This thickness will be designed to ensure that the frost
layer does not enter the waste materials more than 10 times per
century.
By providing soil for this site, the amount of times that
the frost layer reaches the waste materials is minimized. There-
fore, the effects of freeze/thaw weathering are addressed. The
geotextile fabric also serves to reduce freeze/thaw weathering
effects by adding to the stability of the piles and cap system.
The sides of the Locust St. Piles has a soil cover that
averages 12 to 18 inches thick. This material was placed as
part of the 1984 Emergency Action at this site. This cover
thickness meets NESHAP requirements; however, it is not as
thick as the cap proposed for the top of the piles. This is
because it is anticipated that the flatter top of the piles
would be more susceptible to moisture and frost penetration.
Additional soil is not proposed to be placed on the side slopes
to attain a desired thickness as part of the alternative because
a wellestablished vegetative cover already has been noted to
exist on the great majority of the slopes on both piles currently,
and no adverse affects from freeze-thaw effects have been apparent
in the nearly four years since these soils have been in place.
Remedial action repair of the exposed side slope areas under
this alternative would include placement of cut-to-fit and
staked-in-place sections of geotextile fabric soil fill of
comparable thickness to the existing cover on the side slopes
(crown-vetch, since it has already proved successful to date at
this site).
In general, the crests would be graded with fill prior to
cap placement as to achieve a center-line crown and drain to
the edges of the tops of slopes where drainage channels and
corrugated metal flumes, combined with rip-rap would carry
flows of the toes of the slopes and offsite through/or adjacent
to the existing lagoon area. In this way, concentrated flows
would be managed more effectively than by allowing the runoff
to flow over the side slopes in a random manner (which would
increase long-term erosion potential). A result of this action
would be that the center of the pile tops would actually have
more the depth of the soil cap. For the lagoon and settling
basin remediation, sediments would have to be scraped or exca-
vated from the sidewalls and deposited toward the center of
-------
- 62 -
the depression. This action is performed so that asbestos-
containing materials do not remain near ground surface. The
geotextile fabric placed over the sediments would prohibit upward
migration of asbestos fibers and dispersion into the air before
backfilling. The additional clean compacted soil backfill
would also prohibit migration. This soil may be as thick as 10
to 15 feet in order to bring the lagoon area back up to original
grade as to promote positive drainage.
As previously noted, the water from the lagoon and settling
basins must be treated prior to discharge on-site. This treat-
ment would consist of flocculation with the addition of lime,
sedimentation, and passage through a sand filter. If needed,
the water could also be sent through a microfilter.
Dust control and worker occupational safety measures (against
potential asbestos and physical hazards) are required during reme-
dial activities as part of this alternative, however, to a
lesser degree than with alternatives involving substantial
intrusion into the piles.
Overall, this alternative appears to be the most technically fea
option to prevent future release of asbestos from the site, as well a
minimizing potential for direct contact and inhalation exposures to
asbestos during remediation.
2. Institutional Considerations
Several institutional considerations are associated with
the onsite closure alternative. In some cases, permits may not
be required for on-site remedial technologies (Section 121(e)
of CERCLA, 42 U.S.C. Section 9621(e) and 40 C.F.R. Section
300.68(a)(3)). However, all of the processes associated with
cap installation and water treatment must comply with the fol-
lowing action-specific ARARs and consider guidelines, as detailed
below:
ARAR - An erosion and Sedimentation Control Permit from the
PAOER Bureau of Water Quality Management and/or the
USDA Soil Conservation Service is not required for
sites under 25 acres in size. However, the Montgomery
County Conservation District requires that a soil erosion
control plan be written and implemented for construction
activities. This plan must be available for review on-
site.
ARAR - A Floodplain/Stream Encroachment Permit is required
by the PADER Bureau of Dams and Waterways for construc-
tion or alteration of permanent fill/structures along
or in the channel or floodway of any stream. This
regulation is directly applicable to the installation
of gabions or rip-rap along the Locust Street Pile.
-------
-63-
ARAR - A Discharge Permit from the PADER Division of Water
Quality Management must be applied for and the
expected pollutant levels identified if the potential
exists for asbestos to be present in any discharge to
surface water.
GUIDE- - The OSHA standard of 0.2 fibers/cc for asbestos would
LINE be used as a guideline for determining appropriate
safety practices. It is anticipated that during
intrusive activities into the asbestos-containing
material, Level C protection equipment will, as
defined by U.S. EPA Interim Standard Operating Safety
Guidance (January, 1983), be used.
GUIDE- - Air sampling during construction activities that
LINE include disturbance of the fibrous material would
be required under OSHA to monitor occupational
exposure.
GUIDE- - 40 C.F.R. Section 264, Subpart N -
LINE A multi-layered cap generally conforms to the RCRA
technology guidelines, which recommend a three-layered
system consisting of an upper vegetative layer,
underlain by a drainage layer over a low permeability
layer. The cap functions by diverting infiltrating
liquids from the vegetative layer through the drainage
layer and away from the underlying waste materials.
The primary function of a RCRA cap is to control
infiltration and leachate from the waste material that
may contaminate underlying groundwater. A multi-
layered cap is typically used for hazardous waste
site closures, which this site is not (based on the
RI data collected).
Accordingly, the design of the cap, need not be in accor-
dance with RCRA regulations to be protective. The purpose of a
multi-layered cap on an asbestos site is to prevent re-emergence
of the waste on the surface of the site through the processes
of wind and water erosion, freeze/thaw cycles, site use, etc.
In addition, it is desirable to maintain some moisture content
in the fibrous material to control airborne releases of asbestos
in the event of localized re-exposure. Therefore, it is protec-
tive to use innovative cap designs at this site consisting of
semipermeable materials.
ARAR - Pennsylvania Municipal Waste Regulations state that
the final slopes of a landfill cover may not exceed a
grade of 33 percent (25 PA 275.234). The side slopes
of the Ambler Asbestos Piles exceed this 33 percent
grade requirement in most locations. Alternative 4 does
not provide for modification of the slopes, therefore,
this ARAR will not be attained. Section 121(d)(4) of
CERCLA, 42 U.S.C. Section 9621(4)(1), identifies
several circumstances under which certain ARARs may be
waived. Two of the permissable circumstances are listed
-------
-64-
below with an explanation of how they may apply to the
Ambler Asbestod Piles site and Alternative 4 of this ROD-
- Compliance with this ARAR will result in a greater
risk to human health and the environment than
alternative options (See Section l21fd)MUB).
In order to achieve a side slope that does not
exceed a 33 percent grade for the waste piles,
extensive regrading would be required if the toes
of the piles were to remain in their present
position. This would mean cutting into the
asbestos waste and exposing the asbestos calcium/
magnesium carbonate contaminants below. Such
action would pose a serious risk to human health
and the environment because asbestos fibers would
likely become airborn from the disruption. The
calcium/manganese carbonate compounds would also
have to be stabilized so that they could support
a cover system.
- Compliance with this ARAR is technically
impracticable from an engineering perspective
See Section 121fdM41fCl. Constructability would
be a major concern. Some of the side slopes
could be flattened to close to 33 percent by
holding the top of slope constant and placing
soil on all sides of both slopes. This could not
be done around the piles' sides, however, without
encroaching on existing structures, the
wissahickon Creek, a portion of Locust Street,
the Sewer Authority collection system, and
potentially, the railway tracks.
3. Public Health and Environmental Issues
It appears that Alternative 4 can address the remedial
objectives, site environmental issues, and contaminant migration
pathways identified in this ROD. Capping the Piles, backfilling
the lagoon, and backfilling the settling basins can minimize,
to the greatest the threat to the environment and public health
from the contained asbestos fibers as long as the final caps
are maintained. The following public health and environmental
issues are associated with the On-Site Closure Alternative:
- Under this alternative, the asbestos-contaminated
material at the Ambler Asbestos Piles site would be
covered with geotextile and soil (waste piles,
lagoon, and settling basins). This action can be
expected to result in significant long-term reduction
of potential public health risks and environmental
impacts resulting from direct contact and migration
of asbestos fibers via sediment, surface water, and
air transport mechanisms, while minimizing major-
risks to construction workers that are likely with
other alternatives.
-------
- 65 -
Proper grading, installation, and post-closure inspec-
tion can allow the cover to remain as an adequate
barrier between fibrous material and the ground sur-
face.
- A low possibility exists for short-term public health
risks due to the limited disturbance of the asbestos
materials that would occur during cap placement or
during backfilling the lagoon and settling basins.
However, limited airborne release of asbestos fibers
to some degree may result from such actions. The
risk to public health would be minimized by implement-
ing an air monitoring program during on-site activi-
ties and by using erosion and dust control measures.
- Long-term maintenance and periodic inspections of
the site to provide cap integrity and effective site
security would need be established. A contingency
plan would also need to be developed in the event
that catastrophic cap failure occurs, thereby posing
a threat to public health and the environment (indi-
cated via the geotechnical analysis as an unlikely
event as long as no major changes in external load-
ings are or internal pile conditions occur).
- Future land use in the lagoon and waste pile area
must be restricted to surficial activities and
then, only by authorized personnel.
C. COST ANALYSIS
The capital cost of Alternative 4 is estimated at
$5,135,000, as presented in Appendix A, Table 14. Operating
and maintenance costs, including posttreatment monitoring and
maintenance, are provided in Appendix A, Table 15. Since the
asbestos is left essentially in place in a secure environment,
costs have been allocated for air and surface water monitoring
activities for a period of five years after initial remedial
actions. Long term visual inspections and maintenance would
continue for a total period of 30 years. The monitoring would
serve to ensure cap integrity and to detect an asbestos migration
from the contained areas. Under Section 121 of CERCLA, 42 U.S.C.
Section 9621, an evaluation of the remedial action undertaken
at each NPL site is required to confirm or disconfirm effective-
ness of the actions to that date.
-------
- 66 -
SELECTED ALTERNATIVE
Section 121 of CERCLA establishes cleanup standards for thel
site remediation and articulates a preference for remedial
actions in which treatment permanently and significantly reduces
the volume, toxicity, or mobility of site contaminants. The
provision notes that off-site transport and disposal of hazardous
substances without such treatment is least favored where practi-
cable treatment technologies are available. The statute mandates
selection of a remedial action "that is protective of human
health and the environment, that is cost effective, and that
utilizes permanent solutions and alternative treatment technol-
ogies or resource recovery techniques to the maximum extent
practicable.11 ,
EPA has reviewed and considered these statutory provisions
and the regulations contained in the National Contingency Plan,
40 C.F.R. Section 300, in light of the conditions present at
the Ambler Asbestos Site and concludes that Alternative 4 is
the most consistent with these requirements. This remediation
alternative offers the best combination of effectiveness,
implementability, and cost efficiency and involves the use of
what can be considered the only currently feasible remedy under
CERCLA for asbestos. This alternative meets all applicable or
relevant and appropriate requirements or a waiver is justified.
The Section on "Evaluation of Alternative 4" describes in detail
how ARARs are met or how the waiver is justified. That section
further details how the requirements of Section 121 of CERCLA, I
42 U.S.C. Section 9621, are met. The proposed cover design is
consistent with other EPA and state agency designs that have
been proposed and/or approved.
Considering cost, the No Action Alternative (Alternative 1)
is the least expensive alternative. However, it does not include
treatment, removal, or immobilization of contaminated surface
water, sediment or materials in the piles. It meets none of
the CERCLA Section 121 objectives to reduce volume, mobility,
or toxicity of the waste, and does not meet the remedial action
objectives.
Alternatives 2 and 3 (Off-Site Disposal and On-Site vitri-
fication Solidifation/Stabilization) are extremely costly to
implement, with Alternative 3 being the most expensive of all
four alternatives.
Alternative 4, On-Site Closure, presents a potential solu-
tion to future exposures to contaminants at a much lower cost
than Alternatives 2 or 3, although as previously mentioned,
some longterm ARARs may be completely met.
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-67-
Because this remedy will result in hazardous substances
remaining on-site, five year reviews, as specific by CERCLA
Section 121(c), 42 U.S.C. Section 9621(c), would be required
for the remedy, despite the full containment of contamination.
As discussed earlier, inspections will be conducted bi-annually
for the first five years after the initiation of remedial
action and yearly thereafter.
A summary of the comparison of remedial action alternatives
is presented in Appendix A, Table 16.
STATUTORY DETERMINATIONS
1. Protection of Human Health and the Environment
The selected remedy will contain the asbestos contami-
nation 'at the site, which will ensure adequate protection of
human health and the environment.
2. Attainment of ARARs
The selected remedy will effectively attain the applicable
or relevant and appropriate requirements, where practicable, as
set forth in the ARARs section of this ROD.
3. Cost-effectiveness
The selected remedy provides overall effectiveness commen-
surate to its costs such that it represents a reasonable value
for the money.
4. Utilization of permanent solutions employing alternative
technologies to the maximum extent practicable
The selected alternative is currently the most appropriate
solution for"this operable unit and represents the maximum
extent to which permanent solutions and treatment can be prac-
ticably utilized.
5. Preference for treatment as a principal element
The preference is cannot be satisfied since treatment of
the principal waste, asbestos, is not practicable. However,
the proposed alternative reduces the toxicity. mobility or
volume as a principle element (emphasis added) and also
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
-------
Table 3
Estimate of Capital Costs for Alternative 1:
No Action
Ittffl
1
2
3
4
5
Dttcription
fencing to enclose site.
installed
Warning signs
fence gates with locks
Subtotal
Mobilisation/ demobilisation.
Unit
Cost
Quantity (1)
6.000 lin ft IS/ft
60 100 ea
4 1.000 ea
Total
Cost
(S)
90.000
600
4.300
100.000
20.000
7
8
9
construction management, site
services (20%)
Technology implementation:
designs, plans, specifications,
regulatory approvals, insurance,
bonds, and permits (20%)
Overhead and profit (10%)
Contingency (15%)
Total (rounded)
20,000
10,000
1S.QQQ
165.000
-------
Table 9
Estimate of Operating and Maintenance Costs for
Alternative 1: No Action
Item Description Quantity
1
2
3
4
S
6
Long-term monitoring
• Annual analyses for asbestos
(including data validation)
• Air 8
- water 4
• Labor: sampling 120 hrs
• Labor: site inspection 20 hrs
• Labors report 60 hrs
• Expenses
r
Fence maintenance
Subtotal
Administrative (15%)
Contingency (15%)
Annual • total ( rounded )
Unit Total
Cost Cost/yr
(S) (J)
500/sample 4.000
500/sample 2,000
40/hr 4,800
40/hr 800
50/hr 3,000
Lump sun 400
Lump sum 3,000
18,000
2,700
2,700
23.400
Note: Annual cost/year required for 30-year period after remedial
action.
-------
Table 10
Estiaate of Capital Costs for Alternative 2:
Off-Site Disposal
Item Description
Unit Total
Cost Cost
Quantity (J) ($)
1. Site preparation (roads,
staging areas, etc.)
2. Lagoon water treatment (includes
Clocculation. sedimentation.
filtration units, rental,
operation, and labor)
3. Treatability study for surface
water remediation
4. Surface water diversion/
interception ditches
5. Erosion/sedimentation
control system
• Silt fences, etc.
• Sedimentation baaiaa (2)
4. Health and safety equipment/
air monitoring equipment
7. Subtotal
8. Mobilisation/
coaatxvctioa
service* (23%)
illsatioa,
it. site
9. TedamUaoy ismjlemaatatloai
deslgaa, plaaa, spaelfica-
tioaa. regmlatory apyrovala.
insurance, boada, aad permits
(10%)
?
-JA--Contingency (30M-
Lump sum
1.9 million gala Lump stai
Lump sum
5,000 lia ft 10/lin ft
2.000 days
Lumip SUB
Lueip sue
250/day
100,000
240.000
50,000
50,000
50,000
250,000
500,000
1,240,000
310.000
124.000
372*400
-------
Table
Estimate of Operating and Maintenance Costs for Alternative 2:
Off-Site Disposal
Item
1.
2.
Otseription
Field inspections, monitoring,
reporting during remedial
agencies (agencies and borough)
Excavation
• Locust Street pile
• Plant pile
• Lagoon aad settling basins
Quantity
7 years
615,000
640,000
4. 500
cu yds
cu yds
cu yds
Unit
Cost
(S)
40,000/yr
9
20 /cu yd
20/cu yd
10 /cu yd
Total
Cost/yr
<*)•
40,000
1,757,000
1,828,600
6.400
3. Soil analyses for cleanup
verification
4. Backfill excavated lagoon,
settling basins, and piles
with clean soils
S. Bagging/special loading of
asbestos wastes before off-
site transport, truck
decontamination, etc.
S.b Dewatering/stabilisation
of Ca/Mg carbonate wastes
before transport. Stockpile,
stabilize with 10\ CXS addition.
mixing, truck decontamination,
etc.
6. Transportation of asbestos-
contaminated Mtcrials
• Locust Stre«t pile
• Plant pile
• Lagoon and settling
basins (from settling
and filtering water
only)
1.000 tests
175,000 cu yds
833,500 cu yds
750/test
107,000
10.50 cu yd 262,500
5.00/cu yd 595,400
426,000* eu yds
615,000 eu yds
640,000
4,500 cu yds
15/cu yd
15/cu yd
15/cu yd
15/eu yd
912.900
1.317,900
1,371,400
9,600
-------
Table li
;continued)
Item
Description
Quantity
Unit
Cost
($)
Total
Cost/yr
($)*
7. Disposal of asbestos-
contaminated materials
• Locust Street pile
• Plant pile
• Lagoon and settling basins
3. Oust control (wetting)
9. Regrade/revegetate (hydroseed)
• Locust Street pile area
• Plant pile area
• Lagoon and settling basin
area
10. Air and surface water monitoring
during on-site activities
• Labor, laboratory analyses.
and reporting
11. Post-remediation action
monitoring
12. Subtotal
•
Years 1 through 7
Years 8 through 12
i
13. Administrative (15%)
Year* 1 through 7
Year* » through 12
615,000 cu yds
640.000 cu yds
4,500 yds
450,000 sq ft
400,000 sq ft
85,000 sq ft
5 years
14.
(25\)
15. Total (rounded)
Years 1 through 7
Years 8 through 12
75/cu yd
75/cu yd
75/cu yd
0.10/sq ft
0.10/sq ft
0.10/sq ft
Lustp sun
2,000/yr
6,589.300
6,357.100
48,200
17.100
6,400
5,700
1,200
285,70G
*•
22.020.000
2,000
3,303,000
300
5,505,000
500
30,828,000
2,800
'Based oa assumption that remedial activities will take 7 years to complete.
*•
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Table 12
Estimat* of Capital Cocts for Alternative 3;
On-Site Solidification/Vitrification
Item
Description
Quantity
Unit Total
Cost Cost
(S) (S)
1. Site preparation (roads, staging
areas, etc.)
2. Construction of electrical
substation
3. Vitrification furnace and
equipment (S tons/hr)
4. Installation of vitrification
furnace and equipment
S. Purchase of solidification plant
(100 tons/hr)
6. Installation of solidification
plant
7. Construction of a storage area
for untreatable debris
8. Mater treatment unit (include*
flocculation, sedimentation,
filtration)
9. Treatability study for surface
water repudiation
10. Treatability study for solidifi-
cation of CaCOj compounds
11. Treatability study for vitrifi-
cation of asbestos materials
1.9 million
gal*
Lump sum 200,000
Lump sum 250.000
Lump sum 2.200,000
Lump sum 5,500,000
Lump sum 1,100,000
Lump sum 2,200,000
Lump sum 50,000
Lum sum 240,000
Lump sum 50.000
Lump sum 50.000
Lump sum 50.000
•Costs are gross estimates only; vendor(s) unwilling/unable to supply
detailed information at the present time.
-------
Table 12
(continued)
Item
Description
Quantity
Unit
Coit
($)
Total
Cost
(S)
12.
13.
14.
IS.
16.
17.
18.
19.
20.
21.
22.
Pilot plant for vitrification
process (includes temporary
electrical hookup)
Shredding of oversised materials 126,000 cu
(assume IS of pile contents) yds
Setup for solidification/
stabilisation operation at
on-site loeation(s)
Lump sum 1,000,000*
50,000
50,000
Surface water diversion/
interception ditches
Erosion/sedimentation control
system
• Silt fences, etc.
• Sedimentation basin(s) (2)
Gabions for Locust Street pile,
installed
Health and safety, equipment/
air monitoring equipment
Fences (installed)
warning sign*
Fence gets* aad locks
On-sit* disposal of treated
wastes
5,000 lin ft
Lump sum 500,000
10/1in 50,000
ft
Lump sum 50", 000
Lump sum 250,000
500 lin ft
10,000 days
7,500 lin ft
75
6
1.000,000
cu yds
200/lin
ft
100,000
250/day 2,500,000
IS 113,000
100 «a 7,500
1,000 ea 6,000
20/cu yd 20,000,000
*Costs are gross estimates only; vendor(s) unwilling/unable to supply
detailed information at the present time.
-------
Table 12.
(continued)
Item
Description
Quantity
Unit
Co«t
(S)
Total
Co«t
(S)
23. Off-site disposal of treated
wastes
24. Subtotal
25. Mobilisation/demobilization.
construction management, site
services (22 V
28. Technology implementation:
designs, plane, specifications,
regulatory approvals, insurance,
bonds, permits (22%)
27. Overhead and profit (10%)
28. Contingency (25N)
29. Total (rounded)
260,000
cu yds
75/cu yd 19.500.000
55.517.000
12.214.000
12.214.000
5,552,000
13,879,000
99,376,000
•Costs are gross estimates only; vendor(s) unwilling/unable to supply
detailed information at the present ti«e.
-------
Table 13
Estimate of Operating and Maintenance Costs for Alternative 3:
On-Sitt Solidification/Vitrification
Item
1.
2.'
3.
4.
5.
Description Quantity
Health and safety equipment
(expendables) 10,000 days
Shredding of oversized materials
(assume 0.5\ of pile volumes) 6,300
Solidification of CaC03
compounds (includes labor) 426,00 cu yds
Vitrification of asbestos
materials processing costs
(includes labor)2 1,042.000 tone
Excavation/ haul ing to on-site 1,260.000 cu yds
Unit
Cost
(S)
7 50 /day
20/cu yd
100/cu yd
160/ton
20/cu yd
Total
Cost/yr1
(S)
125.000
8,000
2,130,000
8,336.000
1,260,000
vitrification unit
6. Soil analyses for cleanup
verification
7. Backfill excavated
lagoon and settling basins
and piles with clean soil
3. Placement of vitrified and
solidified product back in
pile areas
9. Backfill cloaa soil over the*
vitrified aad solidified
product pilex
10. Off-site disposal of Materials
that caaaot be backfilled
oa-cito* (includes transporta-
tion)
1,000 samples 750/sample 38,0(7
175.000 cu yds 10.50/cu yd 92.000
879,000 cu yds 4.65/cu yd 204,000
70,000 cu yds lO.SO/eu yd 37,000
376,000 cu yds 90/eu yd 1,692,000
1Based on assumption that remedial activities will take 20 years to complete.
2Includes electrical cost of 1,000 kn-hrs/ton of processed Material at S0.07/
kw-hr (maintenance costs are not well defined due to lack of vendor informa-
tion.
3Assume 30 percent must be disposed of off-site.
-------
Table 13
(continued)
Item
11.
•
12.
13.
14.
IS.
16.
Description Quantity
Regrade/revegetate (hydroseed)
• Locust Street pile area 450,000 sq ft
• Plant pile area 400,000 sq ft
• Lagoon and settling
ha«in ar«a 85.000 sq ft
• Total 935,000
Air and surface water
monitoring during
activities
• Laboratory analyses
and reporting
Subtotal
Administrative (1S\)
Contingency (25%)
Total (rounded)
Unit Total
Cost Cost/yr1
(S) (S)
0.10/sq ft
0.10/sq ft
0.10/ttj ft
0.10/sq ft 5,000
Lump sum 400,000
14,325,000
2,149,000
3,581,000
20,055,000
-------
Tablt
Estimate of Capital Costs for Alternative 4:
On-Site Closure
Item
Unit Total
Cost Cost
Description Quantity ($) ($)
1. Site preparation (roads,
storage areas, etc.)
Lump sum
water treatment unit (includes Lump sum
2.000.000 gal flocculation,
sedimentation, filtration)
Treatability study for surface Lump sum
water remediation
4. Surface water diversion
ditches
5. Erosion/sedimentation control
system
• Silt fences, rip rap,
flumes, etc.
• Sedimentation basin(s)
6. Grading of piles to create
crown for positive' drainage
(includes soil purchase)
7. Geotextile (installed)
• Locust Street pile;
• Plant pile
• Lagooa and settling basins
a. Backfill for lagooa and
settling basins (low permea-
bility soils with high
compactive effort); grade for
positive drainage
6,500
Lump sun
10/lin ft
Lump sum
2
7,500 cu yds
15/cu yds
162,000 sq ft 0.18/sq ft
198,000 sq ft 0.18/sq ft
40,500 sq ft 0.25/sq ft
17,500 cu yd* 15/cu yd
25,000
240,000
50,000
65,000
100,000
250,000
112,500
29,160
35,640
10,125
262.500
-------
Table 14
(continued)
Item
Unit Total
Cost Cost
Description Quantity (S) (S)
9. Soil cover (installed)
• Low-erosion soils (30 in)
- Locust Street pile
- Plant pile
• Topsoil (6 in)
- Locust Street pile
- Plant pile
- Lagoon and settling basins
• Hydroseed
- Locust Street pile
- Plant pile
- Lagoon and settling basins
10. Repair erosion oa pile side
slopes
• Low-erosion soils
• Topsoil
• Erosion-control netting
(including installation)
11. Tree/iamb removal (iaeludas
impre^aated geotestile
treatment)
15.000 cu yds
19,300 cu yds
3.000 cu yds
3,700 cu yds
IS.00 cu yds
18,000 sq yd
22,000 sq yd
4,500 sq yd
15.00/cu yds 225.000
15.00/cu yds 274.500
17.50/cu yds 52,500
17.50/cu yds 64,750
17.50/cu yds 26,250
1.00/sq yd 18,000
1.00/sq yd 22,000
1.00/sq yd 4.500
2,750 cu yds
1,200 cu yds
2,000 sq yd
Lump sum
35/cu yds 96,250
35/eu yds 42,000
5.00/sq yd 10,000
180,000
-------
Table 14
(continued)
Item
12.
13.
14.
IS.
16.
Description Quantity
Gabions for Locust Street
pile (installed)
Side slope Buttresses/
Reinforcement*
Fences (installed)
8 feet tall with barbed
wire 6,000 lin ft
Warning signs 60
Gates with locks 4
Unit
Cost
(S)
Lump sum
Lump sum
15.00/£t
100 ••
1,000
Total
Cost
(S)
200,000
250,000
90,000
6,000
4,000
17. Construct earthen berm
6 in. high) along Locust
Street aad hydroseed
18. Air and surface water
monitoring during
remedial activities
• Labor, laboratory
analyses and reporting
19. Health and safety equipment/
air monitoring equipment
20. Subtotal
21. Mobilisation/demobilisation,
construction Management, sit*
service* (22\)
Lump sum
200 day*
Lump sum
ISO/day
20,000
200,000
30,000
2,985,675
656,850
•Assumes remedial design geotechnical analysis work indicate* slope*
essential stable in the future with new soil cap aad construction loads,
except local area*.
-------
TaJble
(continued)
Unit Total
Cost Cost
Item Description Quantity ($) (S)
22. Technology implementation:
designs, plans/ specifica-
tions, regulatory approvals,
insurance, bonds, permits
(25N) 746,620
23. Contingency (25%) . 746,620
24. Total (rounded) 5,135,000
-------
table 15
Estimate ol Operating and Maintenance Costs for Alternative 4:
On-Site Closure
I tea
Description
Unit
Cost
Quantity ($)
Total Cost Per Year1
Remediation (1>
7-30
4.
5.
6.
7.
8.
Inspections (biannual1y first
5 years, annually afterward)
Short-term air and water
Monitoring
Maintenance
• Mowing
- locust Street pile
- Plant pile
• Erosion repair and
reseeding
Fence maintenance
Subtotal
Administrative (15X)
Contingency (251)
Total (rounded)
12 samples
Lump sum
500/sample
18.000 sq yd 0.24/sq yd
22.000 sq yd 0.24/sq yd
Lump sum
1.000 1.000 1.000 1.000 4.0002 BOO
6.000 6.000 6.000 6.000 6,000
4.300 4.300 4.300 4.300 4.300 4.300
5.300 S.300 5.300 5.300 5.300 5.300
25.000 20.000 15.000 15.00* It.OOO 10.000
3.000 3.000 3.000 3.000 3.000 3.000
44.600 39.600 34.600 34.600 32.600 23.409
?
6.700 5.900 5.200 5,200 4.900 3.500
11.200 9.900 8.700 8.700 8.2H S.9N
63.000 55.000 49.000 49.000 46.t9t tt.MO
'Present worth cost for this alternative has been estimated for a
year 6 is the annual cost from years 7 through 30.
^Includes 5-year report.
length of 30 years where the cost incurred tn
-------
fable 16
Summary and Comparison of Remedial Alternatives for
the Ambler Asbestos Piles Site
Alternative
Present yortb1
Cett ttl.Mt)
Technical Considerations (Performance/
1«1 iabllI ty/Ie»lam«Mabt 1 i ty/Safety )
Public Health and
Environmental Concerns
Institutional Requireo
Community Response
ints/
•nts
1. Mo Action
U»gra4o
Silo
Security
Nonitori«0/
Portaotor foMiofl. gatos.
sins aust bo carofully
Boos Hot address any of
the sito public health and
environmental issues iden>
tifteo* in tbo RI and CA.
Restricts access to piles
and lagoon and reduces
risks due to direct con-
tact with asbestos
Materials; and drownings
associated with lagoon.
Potential present and
future risks exist for
trespassers.
Does not address potential
future risks to public
health and environment
from airborne asbestos
fibers and migration of
asbestos fibers and migra-
tion of asbestos from
piles/lagoon via erosion
of piles and sediment
transport.
Does not meet remedial
action objectives. Public
opposition anticipated
for the no action alter-
native due to potential
future risks to on- and
off-site receptors.
Does not meet NCSHAPS
or PAOCR guidelines for
cover systems or contain-
ment requirements for
contaminants. Compliance
with other site-specific
ARARs Is not addressed
over the short- or long-
term.
Requires provisions for
periodic site inspections
and monitoring are required.
The no action
alternative
does not attain
applicable
public health
and environ-
ment*) stan-
dards.
'tased on It percent Interest rote.
-------
Table l6
(continual)
Alternative
Present' Uorth1
Cost ($I.IM)
Technical CMS iterations (Performance/
•ollamillty/Imploottotablllty/Safety)
Public Health and
Environmental Concerns
Institutional Requir
Community Rosponsa
ts/
tnti
2. Excavation/
Removal - Off-
Site Disposal
Excavation/
dredging of
waste plies
and lagoon
sediments
- Pump out/
remove
lagoon
surface
Mater
- Excavate
- Oewatering
of sedi-
»ts
IH.iSi Excavation/dredging for conven-
tional applications It feasible
On-site
treatment of
lagoon sur-
face Mater
and sediment
water using
precipitation
flocculatlon.
sedimentation.
and/or filtra-
tion processes
commonly practiced at site
remediation*. Implomentabllity
•ay bo difficult for this site.
Contingency Measures are required
for removal of largo-siied debris
from tbe Masto olios. Mould
require extensive design and pro-
construction planning due to tbo
IOM strength and stoop side slopes
of tbe piles (Inaccessible to
large/heavy equipment) and the
consistency of the calcium/magne-
sium carbonate layer of each pile.
Contingency measures are required
for silo safety duo to potential
collapse of piles during removal
operations.
Sediment control and dust
control measures are required.
Stabilliation of some of the
materials excavated from the
site may be required to alloM
for bulk transport off-site.
Special handling (such as bagging)
of asbestos-contaminated materials
is required prior to transport.
Addresses all site
environmental Issues and
contaminant pathways
identified in the ftl; all
materials Imposing
potential risk removed
from site.
It Is expected to sig-
nificantly reduce or
eliminate the potential
public health risks and
and environmental impacts
resulting from direct
contact, airborne
asbestos, and contaminant
migration via sediment
transport.
Excavation of materials
in piles presents poten-
tial substantial short-
term risks to workers.
public health, and
environment due to release
of asbestos fibers into
ambient air and collapse
of piles (direct contact
with materials in off-site
areas adjacent to site).
Air monitoring Is required.
Construction permits for
on-site excavation may bo
required to comply with
local building codes.
State erosion, sediment.
and dust control ordinances
require compliance during
excavat i on/removal
activities.
Permit and/or plan approv-
al may bo required for
on-slte point discharge of
treated surface/sediment
waters (or discharge to
POUT plant). Possibility
exists for discharge
according to current site
NPOES permit.
Hay be opposition from
local community due to
risks involved with
disturbance/removal of
the oiles. This can
result in potential
delays.
This alterna-
tive expected
to exceed
applicable
public health
and environ-
mental stan-
dards for the
site. The
ival/off-
slte is con-
sidered in
accordance with
SARA guidance
and for com-
parison with
the on-site
options.
Rased on It percent interest rate.
-------
Table 16
(continued)
Alternative
Present UorU1
Ce»l ($1.0M)
Techni
l Considerations (Performance/
tabi 1 Ity/Saf oty)
Public Health and
Environmental Concerns
Institutional Requirements/
Community Response
2. Excavation/
Removal - Off-
Site Disposal
(Continued)
lackflll. re-
grada. and
rovegetata
where necessary
futaailva atr monitoring weuld b.a
required during removal operations
ta •••wr* tartar safety fro* peten-
tUl alrhere* *sk«»Us flker».
laroo VO!«MMS of
eatoHal (a«tlMto4 •inioua of
7 year* U rooww* all materials).
Potential impacts are
associateo* witk the
transoertation oteratien.
Compliance witk OSHA require-t
mints for ambient air and
surface water may bo difficult
to achieve during removal
operation*.
Off-site
disposal
In secure
landfill
0*-sito treatment of lagoon
surface Motor is ro*uirod. Concen-
trated process streams from this
treatment process require on- or
off-site disposal. Pilot and/or
laboratory studios required prior
to implementation to determine
optimum treatment scheme. Utlllies
conventional Mostewator treatment
technle/tos.
Off-si to disposal In • secure (or
•CRA-appreved) municipal landfill
Is feasible based on MO!1-devel-
oped techniques and standard engi-
neering practtcos. Capacity Is
limited. Moods U bo determined
If waste materials can bo accepted
In municipal landfill as special
handling municipal waste.
Availability of off-site
landfill space Is questionable.
Only two landfills In south-
eastern Pennsylvania are
permitted to accept asbestos.
Opposition to disposal of largo
volumes of asbestos waste at
off-site facility by public
near off-site facility can
bo expected.
Large quantity of waste from
Ambler Asbestos Piles site
must be accepted by the land-
fill; approval must be acquired
to dispose of materials In a
municipal landfill as a •special-
handling municipal waste.
Potential of liability remains
for materials disposed of in the
municipal landfill In the event
of failure.
I
Based on 10 percent interest rate.
-------
'Table 16
(continued)
Alternative
Present Horth1
Cost ($I.MO>
Technical Considerations (Performance/
1*1labl11ty/lomlomentabiIi ty/Safaty)
Public Health and
Environmental Concerns
Institutional Requirements/
Community Response
3. On-Site Vitri- 27*.I16
fication/Solid-
ification
Process has not truly been proven
on a full-scale basis.
Design requirements, construction
technologies, operational problems.
and site-specific considerations
art undefined.
Excavation of piles is a major
concern. Problems and potential
physical and chemical dangers
related to removing asbestos
contaminated wastes. Underlying
calcium/magnesium carbonate wastes
are saturated and exhibit almost
negligible shear strength.
During remediation It Is likely
that the technology will not be
able to meet ARARs regarding
ambient air and/or surface water
quality.
Solidification techniques for
calcium/magnesium carbonate wastes
have not yet been tested.
Solidification would Increase
waste volume to the extent that
off-site landfill must be con-
sidered because there would not
be enough room at the site.
Vitrified product most likely
will have no reuse value.
Short-term risks to public
health and the environment
are likely to occur as a
result of intrusion into
the waste piles and release
of asbestos fibers.
On-slte workers will be
exposed to physical and
and chemical risks due to
excavation of the piles.
lagoon, and settling
basins.
The estimated length of
remediation Is 22-45 years.
This time period presents
potential risks due to
prolonged exposure to
site omissions.
Decontamination procedures
for workers leaving the
plant would be extensive.
Still, it is expected that
a significant amount of
asbestos fibers could be
carried off-site.
Off-site landfillIng may be
required. A potential snort-
age of landfill capacity
is currently projected for
regions around the site.
This situation would not be
conducive for the large
votumts involved at the
Ambler Asbestos Piles site.
Operations would require
intermediate stockpiles.
Public reaction to this
situation is anticipated
to be unfavorable due to
exposure risks to receptors.
Transportation safety
concerns Involved with
haulina the vitrified/
solidified product off-site
may generate unfavorable
public reaction.
Site-specific ARARs related
to air and surface water
quality would likely not be
met during remedial activi-
ties.
This alterna-
tive may not
attain all
applicable
ARARs.
on 10 percent interest rate.
-------
fable 1&
(continued)
Alternative
Present Worth1
Cast (fl.tM)
Technical CMS Herat ions (Performance/
M1t«Mmy/U»leo»ntability/S*foty)
Public Health and
Environmental Concerns
Institutional Requirements/
Community Response
•nts
3. On-Slte Vitri-
fication/Solid-
ification
(continued)
4. On-Site Closure 5.144
teetentlie and soil cover for the
waste •lies, lagoon and settling
hast* sediments will servo as leng-
tera protection of the surrounding
environment from exposure to
asbestos fthers.
Cover placement will utilise
lightweight construction equlp-
Ihe stability of the piles
may not be sufficient for heavy
duty machinery.
Three foot of soil above the goo-
text lie will provide sufficient
protection of the waste materials
from the effects of freeie/thaw
weathering.
Ambient air. occupational
air. and surface water
quality ARARs may he
exceeded at times during
remediation.
Implementing this alter-
native may cause more
Migration of ashestos
fibers to off-site loca-
tions than If no remedia-
tion beyond the current
status was attempted.
fhls alternative can be
expected to result in
significant long-term
reduction of potential
public health risks and
environmental Impacts
resulting from direct
contact and migrating
asbestos fibers via sedi-
ment, surface water, and
air transport mechanisms.
froper grading, installa-
tion, and post-closure
inspection will ensure
that the cover remains
and an adequate barrier
exists between the
asbestos materials and
the ground surface.
According to ;SAR^ guidelines,
the use of treatment tech-
nologies may not be practic-
able at some sites with
large volumes of potentially
low concentrated wastes
(e.g.. large municipal land-
fills or mining sites).
Remedies involving treat-
ment at such sites may be
extremely expensive or
difficult to Implement.
Need approval from the
Montgomery County Conser-
vation District for land
disturbance.
Sediment and erosion
control plan is required
by soil conservation
district office.
Need approval from PAOCR
for stream encroachment
and discharge of treated
waters on-stte.
Hust meet OSHA guidelines
for asbestos workers.
Cap design is consistent
with other EPA designs
that have been approved
for asbestos sites.
Alternative
potentially
attains all
applicable
requirements.
except PAOER
3H:1V
Sldeslopo
AftAR
Uastd on 16 percent interest rate.
-------
FINAL RESPONSIVENESS SUMMARY
FOR THE
AMBLER ASBESTOS FILES SHE
AMBLER, PENNSYLVANIA
The U.S. Environmental Protection Agency (EPA) established a thirty day
public comment period from May 31, 1988 through June 29, 1988 on the Remedial
Investigation/Feasibility Study (RI/FS) and the Proposed Plan for the Ambler
Asbestos Piles site in Ambler, Pennsylvania. The public comment period was
extended an additional thirty days, to July 29, 1988, at the request of the
Ambler Borough Council and Nicolet Industries, Inc. A further request from
the council to extend the comment period an additional ninety days was denied.
The PJ/FS and other site related documents utilized by the EPA to select a
preferred remedial alternative are included in the site repository and have
been available to the public since the beginning of the public comment period.
In addition, copies of the Proposed Plan were distributed at the June 16, 1988
public meeting. The purpose of this responsiveness summary is to summarize
comments on these documents as expressed by residents, local officials, and
other interested parties during the public comment period and to provide EPA's
responses to the comments. Public comments have been submitted both verbally
and in writing during the public meeting and public comment period. Written
comments are included as Appendix A in this responsiveness summary.
SUMMARY OF MAJOR COMMENTS AND EPA RESPONSES
A public meeting was held at the Ambler Borough Hall on June 16, 1988 at
7:00 p.m. on the proposed plan. Those attending the meeting included
representatives frcra EPA, the Pennsylvania Department of Environmental
Resources (PADER), and the Ambler Borough Council, as well as area news
reporters, and approximately 25 members of the general public. During the
meeting, EPA staff presented an overview of the background of the Ambler
Asbestos site, the nature and extent of contamination at the site, the
alternatives that have been considered for addressing site contamination, and
EPA's preferred alternative for remediating the sources of contamination.
Following the presentation, EPA answered questions from the citizens about the
proposed alternatives and EPA's preferred method of site remediation.
Questions, comments, and concerns received during the meeting and the
comment period are summarized below and are categorized into the following
topics: 1) Potential Health Hazards; 2) Extent of Contamination; 3)
Responsibility for Cleanup and Maintenance of the Site; 4) On-site Closure
Alternative; 5) On-site Vitrification Alternative; 6) Other Remedial
Alternatives; and 7) Miscellaneous.
Each comment is followed by EPA's response. All significant questions
and comments made during the public meeting are included in this
responsiveness summary along with written comments received during the comment
period. A complete transcript of the meeting is available for public review
as part of the Administrative Record established for this site at the Ambler
Branch, Wissahickon Valley Public Library, 209 Race Street, Ambler,
Pennsylvania.
-------
POTENTIAL HEAIHH HAZARDS
Question: A local volunteer fireman asked whether the asbestos piles would
create potential health hazards to firemen and local residents if there was. a
fire on the piles.
Response; The asbestos piles remain covered with two feet of soil that was
placed there during the removal action in 1984 and consequently, there is no
immediate threat of contact with the asbestos. The asbestos only presents a
hazard when it is inhaled and there is little danger of this occurring during
a fire as long as intrusive activities'are not performed. Also, the wetting
action that results from extinguishing would minimize asbestos. fibers from
becoming airborne.
Question; A local official stated that the Borough of Ambler also acts as a
water utility company and asked if EPA's remediation of the site would prevent
asbestos fibers from entering the groundwater and migrating into public water
supplies.
Response; EPA studies show that, due to the size of the particles, asbestos
fibers do not migrate in groundwater. The fibers are too large to move
through soil and they actually bond together and create a filter through which
groundwater can migrate and asbestos can not migrate.
Question: A resident expressed concern that, even though the asbestos does
not currently present a public health threat, it could potentially become a
problem in the future if it is left in its present place. The resident
mentioned that a natural disaster could conceivably expose the public to the
asbestos.
Response; The present situation with the asbestos piles is such that
emissions of asbestos was not found to be emitted from the piles that presents
a threat to human health and the environment were not found. The remediation
proposed by EPA will act to continue to keep potential health threats at a low
stage. The remediation also will serve to further stabilize the piles against
probable natural disasters.
Question; A resident wanted to know how EPA could insure the long-term safety
of residents if the ashfsfns was not removed from Ambler.
Response; The remediation proposed by EPA can successfully mitigate the
pathways through which asbestos could potentially migrate away from the site.
The soil and vegetation cap placed on the piles in 1984 provides an effective
barrier between the asbestos and the atmosphere. The capping alternative that
EPA would like to implement in this remedial action would provide a more
permanent means of containing the asbestos. The remediation .would also
include a long-term maintenance program to provide for the continued integrity
of the cap.
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EXTENT OF GCNIRMINATrCN
Question; A resident asked what percentage of the piles are composed of
and what other materials are contained in the piles.
Response: Asbestos contaminated material constitutes approximately 15 to 20%
of the piles. The piles were originally constructed from slag and cinders,
and since that time calcium and magnesium carbonate waste, and the asbestos
containing wastes were added to the piles. Some areas of the piles contain as
much as 50% asbestos at varying depths throughout the piles. The calcium
carbonate is a chalk-like material that is currently about 110 to 120%
saturated and is in a wet, plastic-like form.
Question; A local official stated that, in 1971 and 1972, the residents were
told that there were no problems associated with having asbestos in Ambler.
He further noted that it appeared to him that the same information was stated
at the public meeting in 1988. He expressed concern that he would be hearing
the same remark in 1990.
Response; EPA has never stated that there were no problems with the Ambler
Asbestos piles. EPA conducted an emergency removal action in 1984 to remove
the immediate threat of airborne and waterborne asbestos particles. The RI/FS
for the site was initiated following that, and at this time, EPA wants to more
fully close (cap) the Ambler Asbestos Piles site.
Question; A citizen asked how long it would take for the calcium carbonate
slurry in the piles to dry out and solidify.
Response; The solidification of the calcium carbonate slurry is a naturally
rring process that was discovered during the RI. It was not investigated
to the point where any predictions could be made as to whether, or when, the
slurry would completely solidify.
Question: Two citizens asfrpri if it would be possible to remove the 15 to 20%
of asbestos in the piles without having to remove the piles completely.
Response; Even though the majority of the asbestos is located toward the top
of the piles, there are significant amounts of ashpstos above the 10% level
that go as deep as 35 feet. The asbestos cannot be conveniently removed from
the piles because of stability and constructability problems. In addition, it
is likely that substantial asbestos would be released to the environment if
extensive intrusive activity was attempted.
FCR CXIBNQP AND MAINTENANCE OF THE SITE
on; A local official wanted to know if remedial actions at the site
would result in any financial costs to Ambler Borough either now, or in the
future.
-------
Response; EPA is approaching the PRPs through legal channels to seek funds
expended for remedial activities at the site. If negotiations with the PRPs
fail, Superfund monies will then be used for site clean-up. Atrbler Borough
will not have to assume any financial responsibility for the remediation of
the site.
Question; A local official asVpd if Superfund money would be available only
as long as the Superfund Bill existed.
Response; The Superfund Bill was initially passpd in 1980 with a fund of $1.6
billion. The bill was reauthorized in 1986 and the fund was raised to $8.5
billion. A future reauthorization could increase that to a higher amount,
therefore, there should not be a problem with availability of funds.
Question; A resident asked whether a new buyer of the Ambler Asbestos Piles
site would be financially liable for the remediation and maintenance of the
site.
Response; EPA considers any past or present owner of a Superfund site a PRP.
Therefore, even if a site is in the midst of a sale, the potential owners
would have to negotiate with EPA regarding the potential financial and
remedial responsibilities associated with the site.
Qjuestion; A resident wanted to know who was responsible for cutting the grasH
on the site. The resident said that the grass was not being cut often enough,
and the long grass was causing insect problems in the local neighborhood.
Response; At the present time, maintenance of the site is EPA's
responsibility. However, EPA will probably be negotiating a maintenance
agreement with either the PRPs, or with PACER, for long-term maintenance of
the site.
Question: A resident asfrpd if anything could be done to prevent site access
by children who play on the property. The resident mentioned that children
can get through the fence that surrounds the site property.
Response; It is difficult to prevent children from climbing over the fence,
but part of EPA's proposed remedy for the site includes a higher fence around
the site, which should discourage children from entering the site property.
ON-STTE CLOSURE AHEEENATIVE
Question; A resident suggested that leveling out the asbestos piles before
covering them with soil would be a viable alternative, and would diminish the
visual impact of the piles in the neighborhood.
-------
Response; Leveling the piles would require moving around large amounts of the
asbestos, which could potentially create a threat to public health through the
release of asbestos fibers into the atmosphere. Also, stability and
constructability dangers would be substantial with this type of action.
Question; A resident questioned why it was necessary to cover the asbestos
with soil, since that type of action had already been conducted at the site.
Response: Ihe soil covering placed on the piles in 1984 was done as part of
an immediate removal action to mitigate imminent public health risks caused by
the asbestos. That action was not designed to permanently address the
aghogtr« problem at the site. The on-site closure alternative would entail
more than placing additional soil on the piles. It would also include:
capping the piles with geotextile material; regrading portions of the piles;
constructing a drainage system; and building retaining walls.
Question: Two residents questioned EPA about the security fence that is
proposed as part of the on-site closure alternative. They asked if it would
be possible to install the fence further inside the site boundaries, and
whether it would be necessary to have warning signs on the fence. The
residents expressed concern about the visual impact the fence would have on
the neighborhood.
Response; EPA will investigate the possibility of placing the fence as
unobtrusively as possible. EPA will also work with the community on the
wording of the warning signs. The signs do not necessarily have to be
alarming, but EPA's main concern is to protect public health.
CM-SITE vmancancN AUEEENKFIVE
Question; A resident askpri how long the vitrification process would take to
complete, and how much it would cost if selected as the remedial alternative
for the site.
Response; The vitrification alternative would require several years of pre-
implementation testing to determine the time frame necessary for site
remediation, but EPA estimates the entire process to take approximately ten
years. Ihe estimated cost of the vitrification alternative is $270 million.
Question; A resident asked why EPA considered the vitrification alternative
as not being feasible for implementation at the Ambler Asbestos Piles site.
Response; Ihe sheer volume of the material that would have to be handled at
the site during a vitrification .process Trek*** the alternative difficult to
implement. Excavation during the process would also uncover the asbestos,
potentially exposing the community to airborne agt-»»g<-og particles.- Other
factors that make the vitrification alternative less desirable are: the
length of time required to complete the process; the constructability and
-------
stability dangers during excavation; the lack of reuse potential for the
vitrification product; the extremely nigh cost of the process, and the
likelihood that a new landfill would need to be built either on or off-site to
contain the vitrified material.
Question: A citizen agVprf how EPA had calculated the cost of vitrification
alternative.
Response; EPA contacted several firms that handle vitrification and received
cost breakdowns from them. Total cost was calculated from the cost per ton
and the number of tons per day that the firms could handle, divided into the
total tonnage that would require treatment at the site.
Question; A resident asked if EPA had considered the feasibility of ^pro-
rating the cost of a vitrification facility across several Superfund sites, if
the facility could be designed to be portable.
Response: There are a number of different vitrification process technologies
and facilities. Sane of these technologies may not have the ability to be
mobile, consequently, EPA did not factor that variable into the cost.
Question; A local official asked if EPA had considered a method such as
"tunnel and slurry" to transport material from the piles to a vitrification
facility. This method would replace excavation and prevent exposing the
asbestos to the atmosphere.
Response; This methodology would be feasible for some of the internal wet,
plastic-like materials; however, it would ultimately produce an uncontrollable
pile collapse situation.
Question; A resident asked if EPA would be willing to further investigate the
vitrification alternative and meet with a representative of Vitrifix, a
vitrification firm that has studied the asbestos piles in Ambler.
Response; EPA is willing to consider any feasible alternative for remediation
of the site. If Vitrifix has a feasible plan for vitrifying the asbestos in a
manner that is as protective of public health as the on-site closure
alternative, and is also cost-effective, EPA will consider the plan. However,
Vitrifix is not the only vitrification firm that has shown an interest in the
site and EPA will also evaluate any proposals put forward by the other firms.
OTHER REMEDIAL AIUH^NATIVES
Question; Two residents wanted to know if the four alternatives presented by
EPA for remediation of the site were the only ones that had been evaluated.
Response; The investigation, and evaluation of alternatives, at the Ambler
site has been one of the most extensive studies conducted on an asbestos site
EPA maintains close contact with agencies working on asbestos sites and has
-------
frequently exchanged information with those agencies to address every possible
remedial alternative for asbpstos. The alternatives presented by EPA for the
Ambler site are the only technical options that EPA is aware of that are
currently available for asbestos remediation.
Question: Several residents asked about the feasibility of the Excavation/
Removal, Off -site Disposal alternative.
Response; EPA would prefer not to excavate the asbestos and expose the public
to a potential health risk. There is also a land ban going into effect in
November 1988 that will prohibit EPA from disposing of any more hazardous
waste in existing landfills.
Question; A resident asked if EPA could remove the asbestos and dispose of it
in an underground location such as the Centralia, Pennsylvania mines.
Response; The land ban also includes underground locations. It is EPA's
policy not to move hazardous materials from one place to another and create
further contamination problems. EPA can only dispose of asbestos in landfills
that are licensed to accept hazardous waste. Centralia is a town where there
is an underground mine fire, and would not appear to be the most suitable as a
hazardous waste disposal site. Transportation costs also would be extremely
high.
A resident inquired whether it would be feasible to level out the
piles, cover them with soil, and use the area as a potential location
for a public housing development.
Response; Since the calcium carbonate is in an unstable wet, plastic-like
state, it could not support any construction on top of the piles in its
present form.
Question; A citizen requested information on whether the Hazard Ranking
System (a means of measuring hazardous substances and their potential impacts
for placing a site on the National Priorities List) had been used to assess
only the asbestos piles at the Ambler Asbestos Piles site, or if other
ad"MJv:t/3s piles located in the Borough of Ambler had been included.
Response; The test data results which were used by EPA to rank this site were
collected from the two on-site piles and the lagoon area.
Question; A resident expressed concern that EPA may have already decided on
the remedial alternative that would be implemented at the site.
-------
8
The purpose of the public comment period and the public meeting is.
to give the public an opportunity to make any suggestions or comments on site|
remediation. EPA will carefully consider any feasible alternatives suggested
by the public.
Question; A resident asked if EPA would extend the public comment period past
the required 21 days in order to give people more opportunity to comment on
the proposed alternatives for site remediation.
Response: EPA will extend a public comment period if a reasonable request is
made in writing to EPA prior to the end of the current public comment period.
Written comments are attached to this responsiveness summary as Appendix A.
Written comments were received from the following:
1. Borough of Ambler 7. Nicolet Industries
a. June 17, 1988 8. Vitrifix, Inc.
b. July 5, 1988 9. Peter Peschke
c. July 21, 1988 10. Michael Rittenhouse
2. Montgomery County Planning Commission 11. GeoTech Development
3. Upper Dublin Township Corporation
4. Whitemarsh Township 12. Jean Thompson
5. Frederick Griffith 13. Frank Romano
6. T & N
Many of the written comments have been responded to throughout the text of th«|
responsiveness summary. EPA received written proposals and comments from
several individuals/companies which expressed interest in remedial activities
at the site. Every letter/proposal received was responded to by EPA in letter
form. The letters and EPA's responses are attached to this Responsiveness
Summary as Appendix A. EPA met with the companies that submitted proposals
and discussed several innovative technologies which will be further examined
during the preliminary design stage.
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APPENDIX A
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APPENDIX A
-------
1
8
8
8
June 17, 1983
Mr. James M. Seif, Regional Administrator
Environmental Protection Agency.
341 Chestnut Street
Philaoelonia, ?A 19107
.Re: Amoler Asbestos Site
Remedial Investigation/Feasibility Stuay
Dear Mr. Seif:
On Thursday, June 16, 1988 at 7:00 P.M., the EPA held a ouolic
meeting to consider written and oral comments regarding remedial
alternatives to the asbestos piles in Anbler, Pennsylvania.
EPA reoresentatives conducting the meeting were Nanci Sinclair
(3PAOO), Hector Abreu - Cintron (3HWI7), and Dr. Bruce Mulholtz.
They advised the Borougn officials of tne formal extension D~oc9cure
to allow additional viable alternatives for tne treatment ana/or
removal of the asbestos piles to be presentee to EPA officials
beyond the June 29, 1988 Deadline.
At this juncture, the Borough of Ambler, Montgomery County,
Dennsylvania, hereby makes formal request to tne EPA to extend tne
June 29, 1988 deadline one (1) month so the several technical ootions
alternatives, and possible solutions, entered into the record of tne
oublic meeting, be develooea more formally and submitted to the
Environmental Protection Agency for consideration.
The major concern the residents of Ambler have at this point
is that the EPA had settled on alternative number 4, on-site closure,
the preferred alternative of EPA, and held the public meeting merely
as a formality.
Ambler Borough is asking the EPA to grant this extension so the
alternatives suggested can be given fair and objective consideration.
Celeoratmg 100 years ot community service
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I want tc take tr. is csoorrjr.ity ::
your consideration in mis sensitive
Pennsv i v.ama.
ank you in aavance fcr
ritical issue to Ambler,
Sincerely,
Anthony^. Oecsrorino
Council Presicent
AJD:jn
- Michael Heayn. Mayor
- Borougn Council
- ?.eoresentati ve' Saurran
- Congressman Cougnlin
Certif. Mail =P 7G7
243
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BOROUGH OF AMBLER
1
8
8
8
-- :-:C2 • I'S-c-o—.'il
July 5, 1988
M-.- -ec*C" Abre'j-Iiniron
nee:cnal :r-:*ect '•'inac^-
',.:. E"A - -.es-.c-r. Ill"
341 :.-.3Jtr.:.t Street .
?rr, "creionu. ?A 13107
RE: AV.3LE? ASSES'C'S SI~E
HEMEDI-L !NViSTI3ATIC,\' FEAS
STUDY TKEF.-QK A:,'S SELECTED
«i T3'.1 • — •••-
n_ I l.WM\MI . V;
Mr. AbrsL'-C'n'ror.:
Tne boroucr. c*
tns .^srcsrs of Amo'iS" Bprrucr. lounc-'l .
"C os in* unan:r,ous ooinion of tng rc
cacmenis on ins caatlor.ec reoc-: anc "r
your -.rv. tcV.or, to oo so.
e-2:r tng ccrssrsus
* *t clearr re'i'is
' '
ilcr. pursuar.
Initially, we would paint out tr.at tns Eorouor. r,ai* i reauert
for a furzr.er time oenoc of thirty .(2i) cays (ccoy enzloiec;
cjrinc wnicr. anyone could comment essential ly because cf tne
cODarint'iy distorted costs of the vitri-Tfcstior. alternafiv^. While
aavised that such an extension was irr,rosrioie to crant, the.Boroucn
has been infernally advised that the oeriod fcr conment has been
extenaed to July 13, 193S. Tne 3 c rough is -without sufficient
knowledge as 'to whether this extension is aiolicable to anyone
otner tnan the Borougn prooer, or wnether v.is extension nas peen
communicated to its citizens and otner interested carries. When,
in tnis matter (after seventeen -17} year:) did sixteen cays secome
of sucn essence!
We are n:t awa-e of j/cur "track record" as to how many times.
.your "selected preferred alternative" has not become tne final
decision. We oo aavise that we are dedicatee to dissuading you
from adonti.ng as -final your -preferred alternative to leave tne Borougo
of Ambler in essentially the conaition in.wnich you found it -
encumbered by some 23 acres of asbestos waste. Chilaren cannot
Celeorating iQO years of commumty service
-------
July 5, 1938
remain in our school buildings for periods of barely a month after
asoestcs fibres are located in said buildings; and yet they can oe
sent nome to play and sleep witnin two nuncred (200') feet of the
asoestos piles. It just does not -a*e any sense.
The memoers of Borougn Council do not pretend to be exoerts in
any of the alternatives reviewed. They ao, however, nave trie use of
tneir senses, and they have read and viewed on television some of tne
in-fact removals oraered by EPA or contracted by tnem or tneir various
State counterparts.
They are not exoert on the vitrification process, but they co
know that Dr. Roberts said that your report on that alternative was to
the extent of a half-hour teleonone conversation, and even at tnat
you distorted the effectiveness and cost of that alternative.
As to the fact that in oursuing this alternative or the alter-
native of the removal to a less densely peculated site, workers in-
volved in tne process would of necessity nave to wear protective
clothing.; what is so unusual about that?
.As a matter of fact, these are the only two actual alternatives
that were reviewed. Despite your statement that aoing notning is a
manaatory alternative for you to review, this .is hardly a viable
remedy for a site that was placed on EPA's Superfuna National Priorities
List in October, 1985.
Second to do nothing is your recommended alternative to cover
and vetch the mountains. Now really! This is what you ao to plain
old carnage and trash in enclosing a solid waste landfill, wnerein
the contents will naturally deconoose - certainly the asbestos will
not! . How many other situations on tne EPA's Superfund National Prior-
ities List have been resolved in this way?
In an AP article, by-lined by Guy Darst aooearing in the Phila-
delphia Inquirer of June 18, 1988 (copy enclosed) Mr/Darst stated"
"The Superfund clean-up program for toxic waste
dumps is largely ineffective and inefficient and aoes
not make full use of'new technologies for permanent
solutions, a congressional study said yesterday. By
choosing cheaper, impermanent solutions, the agency
may find itself having to undertake more costly solu-
tions later, said the report by the Office of Technology
Assessments."
After quoting the Office of Technology Assessment report
further to the effect:
-2-
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' .3. £?A - r.ecicn III
July 5, 13S8
"Technical evidence confirms that all too freauently,
Suoerf'jnd is not worxing environmentally the way the law
directs it to...",
Mr. Carst observed that:
"EPA officials nave sauandered billions on tra-
ditional "containment" clean-uo methods that provide
little lasting protection, it (sic-Office of Technology
Assessments) concluded.
Mr. Oarst said that the Reoort called the decisions on clean-
up methods at the ten (10) sites (studied) questionaole because:
. If different and readily available technical
information had been used, the decision would have
changed significantly.
. The range of clean-up alternatives was too narrow.
. The analysis was not comprehensive and not fair
to differenet technologies.
. The study work was not internally consistent.
. Mistakes were made in calculations and estimates.
. Critical assumptions were false.
. Conclusions were stated without analysis and docu-
mentation.
In response to the report of the Office of Technology Assessment,
Winston Porter, Assistant EPA Administrator in charge of Suoerfuna,
according to Mr. Oarst, criticized the study for a 'superficial look'.
This is precisely what the Borough of Ambler believes has hap-
pened to it.
Why is this? Well, the Borough of Ambler does not believe that
all possible technologies were thoroughly reviewed, thinks the range of
clean-up alternatives reviewed was too narrow. The analysis was not
comprehensive to all technologies* critical assumptions, particularly
as to vitrification, were false, and mistakes were made in calculations
and estimates.
Just what does the Borough of Ambler seek as a reasonable solution
to the problem? In the first instance, it does not want to become
another statistic such as those sites that were reviewed by the Office
of Technology Assessment. In the second instance, it wants whateve*-
is its due in the EPA's carrying out of its Congressional mandate.
T3-
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lu'iy :, 1923'
'.-/hat is the manaate?
We do not feel that tnis comnunicaticn need be burdened with c
review of tne total contents of the Solid Waste Disnosal Act, tre
resource Conservation and Energy Act of 1976, the Comorenenslve En-
vironmental Resoonse, Condensation and Liaoility Act of 1930, tne
Suoerfund Revenue Act of 1985, and tie Hazardous Substance Suoer-
fund Act along with the legislative history of the individual
pieces of legislation.
We also are of the coinion that certain highlights of those -:ts
should be rrentioned. In United States v. Shell Oil Co. 5o5". SUGC.
1064 '1985) a case involving an issue not cerrnain to tms communication
even if imodrtant to the ultimate recovery nerein, the Court reviewed
tne nistory of CERCLA and tnat portion of tne opinion is attached nere-
to as Aooencix "A".
We are aware tnat the legislated clean-uo standards of CERCLA
contain a directive that the Tone-term uncertainties associated with
land disoosal as well as tne potential threat to human healtn and the
environment associated with excavation, transportation, and reaisposal
are to be taken into account.
However, also to be taken into account are:
. the ootential threat to human health and the environ-
ment associated with containment;
. the goals, objectives, and retirements of the Solic
Waste Disposal Act'(42U.S.C.A. § 6901 et-seq.);
. the oersistence, toxicity, mobility, .and prooensity
to biaccumulate of sucn hazaraous substances and their con-
stituents;
. short and long-term potential for adverse health effects
from human exposure;
. long-term maintenance costs;
. the potential for future remedial action costs if the
alternative remedial action in question were to fail.
We have not heard much emphasis placed by the agency on these
six criteria that shall be taken into account at a minimum.
We have been advised of the broad definition of "removed" in
CERC.A and have seen it used at its broadest in your report when you
refer to the "removal" that has already taken place. When we use that
term we mean the physical removal of the material from the Borough.
-4-
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We passionately i-plore you not to rr.ake final your recomenc-ed
alternative. The Sorougn of Amoler cannot handle tnis prcDiem on its
own as it cannot only not -'und tie removal costs in the first -instance,
out could not even financially suooort the litigation that would be
involved, even assuring tnat the area of local nuisance law nas not teen
preemoted by tne federal ana state legislation.
You are our only hope.
Do not stand oat with a recommendation that can be defended le-
gally as being within tne minimum dictates of tne referenced legisla-
tion when a comolete solution meeting all tne mandated considerations
is available. Reconsider tne vitrification process with an coen mind,
and if that is not feasible under the circumstances, then cone down in
favor of in- fact removal of the "white mountains".
We reauest that you reconsider the exclusion from your recommendation
of what has oeen referred to as tne small pile, as asoestcs is asbestos
regardless of tne size of tne pile
We make inquiry as to the details of, and liability for, the
maintenance of tne area unaer your recommended alternative and suggest
that if covering is what Amoler must accept, then once you complete the
work and make the area safe that you remove the signs and fences and
return the park portion to the citizens of Ampler for their use.
Lastly, we request that you await Dr. Roberts' formal comments
before releasing to tne press what you believe he has concluded.
It is anticipated that Dr. Roberts' report will be here in tne next
several days. If it is addressed to the Borough, we will immediately
forward to you.
Respectfully submitted,
AM8L£R BOROUGH COUNCIL
By:
Anthony J.^3ecembrino, President
c/c - Ms. Nanci Sinclair, EPA
- Senator John Heinz
- Senator Arlen Spector
- Congressman R. Lawrence Cough!in
- Representative George E. Saurman
- Commissioner Paul B. Bartle
- Commissioner Betty B. Linker
- Commissioner Rita C.Banning
- Steven West, County Planning Commission
Certif. Mail #P 707 497 150
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o
Z
Superfimd
work called
ineffective
1 By Guy Darst' . ;
A4MEMI«a1 ^CM
WASHINGTON — The Superfund
cleanup program for toxic waste
dumps is largely ineffective and inef-
ficient and does not maxe full use of
new technologies for permanent so-
lutions, a congressional study said
yestercay.
By choosing cheaper, imperma-
nent solutions, the agency may find
itself having to undertake more cost-
ly cleanups later, said the report by
the Office of Technology Assessment.
'Technical evidence confirms that
all too frequently. Superfund is not
'working environmentally the.way
the law directs it to." the office con-
tended after a study of cleanups at 10
Snpertund sues, two of them in .New
Jersey. • • • • >•
It said the Environmental Protec-
tion Agency was not consistently ful-
filling the mandate of 1986 regula-
tions that directed it. whenever
possible, to permanently reduce the
"toxictty, mobtlilty or volume" of the
waste m question, the report said.
OTA investigators examined docu-
ments for about .100 sites affected by
the 1986 amendments to the Super-
fund act and selected for detailed
study 10 they believed to be repre-
sentative.
"Too much flexibility and lack of
central management control are
working against an effective, effi-
cient Superfund program." the re-
port said.
EPA officials have squandered bil-
lions on traditional "containment"
cleanup methods that provide little
lasting protection, it concluded. Too
often, workers simply cover up
wastes or plan them in landfills be-
cause that is generally cheaper than
incineration, biodegradation or
other new "permanent cleanup"
technologies. • •
Winston Porter, assistant EPA ad-
ministrator in charge of. Superfund,
criticized tne study (or "a superficial
look."
"They continually pressure us to
be consistent but 1 keep telling them
the communities aren't consistent.
the states aren't consistent and the
problems aren't consistent," Porter
said. The law requires EPA to con-
sider preferences of affected commu-
nities and the states.
Porter said the report made some
valid technical points, "but I dis-
(See SUPERFUND on 4-A)
Superfund
',work-called
• ineffective
-'•• • SUPERFUND. from 1-A
•• agree with the exirapoiatioas they
' naXe." • •
. The report noted that many Super-
' (and sites — the nation's worst —
' presented extremely difficult techm-
' oil problems and that puoiic expect*.
'. uons for tne program were prooaoiy
\ too tugU. •• . •
. It acknowledged too ma: "cleanup
• technology 13 a new and fast-chang-
' ing field and the workforce is reia-
• avely young and inexperienced. Re-
cent college graduates are often put
in charge of multi-million dollar
projects.... They have almost no one.
to leara from, as turnover is high.
Research papers and technical man-
,uals ... are quickly outdated."
Even so. the authors of the report
•concluded toe EPA bed achieved lit-
tle m spending more than SS billion'
since the start of the Superfund pro-
gram m late 1980. v
• The report called the decisions on
cleanup methods at me 10 sites ques-
tionable because:
• IT different and readily available'
technical information had been
used, the decision would have
changed significantly.
, • The range of cleanup alterna-
tives was too narrow.
• The analysis was not compre-
hensive and not fair to different
technologies.
• The study work was not inter-
nally consistent.
• • Mistakes were made in calcula-
tions and estimates.
• Critical assumptions were false.
• Conclusions we« stated without
T>»»»>MC
analysis and documents:;:
In five instances.
selected before
small-scale "ireataq
whether the
Documents cboosiec.
methods at eight of the 16 s
signed on Sept. y or Sen
yenr. the last day of tie fi:
and two on tae last cay cf :r,
,mg quaner.
. CMOTUO eott« «nd tn« inertc:
liv EfctMtn. Oiawfce* Carwtx
J7.4 m«tion, tjnere««n ien»«<o0y wti iwvetcQ to trcft '
tammttM sue*xr>K« toil. *rrwer-
ftmovn tenant nta t«*T M
-------
TMTKI) ?T\TK? • SHKI.l. Oil. CO.
in* •« xi< f Sunp n^4ii««i
1071
CT"*. f.ii-"fi wiih SUPS «ucit as I/n-o C':in:il.
ri'Mrly undfrstond that the mrr'- r<-jrulat.ioii
"f current land disposal would not ;\10. <>4 Suit. 27f,7 l The
House Committee on Interstate :md For-
ciirn Commerce reported that it was their
iitient m CERCI.A "to initiate and establish
,-i comprcnensive response nnd financing
mechanism to abate and control the vast
problems associated with abandoned and
inactive hazardous waste disposal sites "
(H.R.Rep. No. 96-1016. 96th Cone.. 2il
Sess. 22. rrvnntcd in 1930 U.S. Code Con?.
i RCP.A have luft im-
portant regulatory paps.
(1) The Act is prnsrifctivr and applies
to past sites only to the extent that they
are posine an imminent hazard. Even
there the Act is of no nelp if a financially
responsible owner of the site cannot ue
locaiea." (Empnasis added.)
House Report at 22. 1980 U.S.Code Cong.
SL Ad.News at 6125.
The Senate Report from the Committee
on Environment and Public Works, accom-
panying S.U80, also recognizes that RCRA
was not the final solution to the hazardous
waste problem. IS.Rep. No. 96-848. 96th
Cong.. 2d Sess. (1950) (hereafter "Senate
Report").) After recounting a number of
environmental disasters, including Love Ca-
nal, the report concluded:
"There is limited authority to solve
these problems. Regulations promulgat-
ed in May under subtitle C of the Solid
Waste Disposal Act [RCRA], wmch im-
pose tough new standards for operating
toxic waste disposal facilities, are expect-
ed to greatly upgrade the Nation s active
toxic waste disposal sites. But the regu-
lations do not address those situations
where an owner is unknown or is unable
to pay the cleanup costs, nor do they
address the clean up of spills, illegal
dumping, or releases generally." (Em-
phasis added.)
Senate Report at 10-11.1
United States v. A A F Materials Comoanv. Inc..
571 F.Supp 1249. 1252 (S.D.tll. !9«4): United
States v. Pnee. 577 F.Supp. 1103. 1109 (O.N.J.
1983): Untied States v. Rtillv Tar & Chemical
"n'
-------
It)?!! *»"• FT.DKK.Vt. -M '{•(•!. KMKNT
Tims. ui;iir IT1'-' "r'.lK '!. \ i.'.u i-milii t"-»
••••ft' Mirinrr >...;inu»n fmni •;• < ••n\\<'i».\n-
H ;i«u-« it foiiiii (•": ••ff«iii'.". >M'. ai..i!r ; •!••
M'llT'mn.' "nv:ri'nni'';::;»i in-ii-r»ir:'r inn ri-vuii-
;iilT frt»m- w:i«li'S ui.n-ti h;ui \»-i-i-. m\n\\u-<\ m
'.••f j-nst i"r!!i('!..\ ••••MS ftr.ii ;•••: •'. .imir"»^
;i,i-«ic iipnivliTTIS !' i» I", i!'- -i '•,' r::ilnrv
!'.i"K«Mrii ii'iimriL' M.nu ••!* >lu luiiictn.
iiCL" tll.V. have '•:tiiv«>.i TI,,. |>iii|iiii»n :ur":ic\
CIIC-TIIC:H nrtio-oink uri- :i( il>«»ir
unrk MrrMni: 'ir>;ir>if ir- o
force? into inc futurt-
"Die fiectsion was mndo in CP)RCLA to
clean up tuese inactive n.nr.nrdnus VI-HSI*>
sites. The next question was «.-no snould
pay for tne cieanuo. Coneress assigned to
the caterones of persons listed in * KlTuj
the liability for all costs mcurrt-ti in clean-
me up h.ir.aroous waste sues. Tins liaoility
screme was enacted to xssure 4>.na; ttiose
responsible for any damaee. environmentil
harm, or injury from chemical i"ii^ori< i»?.Tr
the costs of their notions." (.Scnau- Hni»ort
at IS. i
"(Sji)Ciety should not iy a cenerator. trans-
porter. consumer, or dumpsite owner or
operator who has profited or otherwise
(Hjnefited from commerce mvoivinp these
substances and now wishes to be insulat-
ed from any continuing responsibilities
for th« present hazards to society that
have been created." Senate Report at
98.
See State of Ohio cs rel Brotcit i: Gear-
geo/f, 562 F.Supp. 1300.. 1312 (N.D.Ohio
1983) (citing additional legislative history
and concluding that "there is little doubt
that Congress intended for those individu-
als who were responsible for creating the
hazards from these wastes to bear the cost
of clean uo."l -
y
-------
1
8
8
8
BOROUGH OF AMBLER
31 £. Sutler Ave. • Amoier Pa. 19002 • 215-646-1000
1
9
8
8
Kr. Hector Abreu-Cintron (3HW17)
Regional Project Manager
U.S. EPA - Region III
341 Chestnut Street
Philadelphia, PA 19107
July 21.1988
RE: AHBLER ASBESTOS SITE
REMEDIAL INVESTIGATION
FEASIBILITY STUDY THEREON AND
SELECTED PREFERRED ALTERNATIVE
Dear Mr. Abreu-Cintron,
The Borough of Ambler encloses herewith a copy of the
report by the Hazardous Waste Treatment Council et al
entitled "Right Train, Wrong Track: Failed Leadership In
the Super!und Cleanup Program*, dated June 20. 1988, by vay
of an addendum to it» response at July 9, 1988 to your
recommended alternative regarding the Ambler Asbestos Site.
Further, the Borough is meeting on July 23, 1988 with
Dr. Edgar Berkey of the Center for Hazardous Material
Research at the University of Pittsburgh in order to
determine whether his services and those of his associates
will be retained by the Borough to reviev your report.
If the outcome- of that meeting results in the
contracting of Dr. Berkey's services, he will be in contact
with your offices directly.
Sincerely
Anthony J. Decembrino
President Ambler Borough Council
Enclosure with ribbon copy only because of bulk.
cc: Hs. Nanci Sinclair, EPA
Senator John Heinz
Senator Arlen Specter
Cong. R. Lawrence Coughlln
Rep. George E. Saurman
Commissioner Paul Bartle
Commissioner Betty Linker
Commissioner Rita Banning
Steven West, County
Planning Commission
-------
UP
T)ublin
PATRICK J. ZOLLO
President
E LENZ
Vice President
801 LOCH ALSH AVENUE
FORT WASHINGTON, PA. 19034
Phone: (215)643-1600
July 13, 1988
NORTON A. FREEDMAN
JUDY HEROLO
RICHARD R. RULON
JAMES B. BOCKIUS
CHARLES M. Bouo
GREGORY N. KLEMICK
Manager
RAYMOND JENKINS
Solicitor
Mr. James M. Self
Regional Administrator
Environmental Protection Agency
841 Chestnut Street
Philadelphia, PA 19107 .
re: Borough of Ambler, Montgomery County,
Pennsylvania Asbestos Site - Remedial
Investigation/Feasibility Study
Dear Mr. Self:
I reference a letter dated July 5, 1988 from
Mr. Anthony J. Decembrino, President of Ambler Borough
Council, to Mr. Hector Abreu-Cintron, Regional Project
Manager of your agency, pertaining to the Ambler Asbestos
Site Remedial Investigation/Feasibility Study. In that
letter, Ambler Borough, in detail, documented and explained
its strong opposition to your agency's recommendation of
"on-site closure" of the asbestos piles in the Borough
resulting from the Remedial Investigation/Feasibility
Study. Ambler Borough has made a formal request to you
to reconsider the selection of that alternative and in
turn broaden your consideration to an alternative tech-
nology of disposal such as "vitrification" or the removal
and disposal of the asbestos at an alternative site.
AC the July 12, 1988 monthly meeting of the Upper
Dublin Township Board of Commissioners, this matter vas
publicly discussed, and the Board of Commissioners
unanimously voiced their strong support of Ambler Borough's
position that you reconsider the alternative of on-site
closure of the asbestos.
Upper Dublin Township, in our review of the recent
Office of Technology assessment report regarding the
Superfund Cleanup Program, finds that cheir cocments are
very persuasive with regard to the criticism that the
choice of cheaper, less permanent solutions, while in the
short run may save money, in the long run may prove more
costly. Of more importance, however, Upper Dublin Township
-------
COMMISSIONERS OF UPPER DUBLIN TOWNSHIP
Mr. James M. Self
July 14, 1988
Page 2
shares in the grave concern chat the alternative selected may by its nature in-
crease the potential threat to human health and safety as well as endanger
the environment.
While Upper Dublin Township stands behind the Borough of Ambler's position
because we feel it is a correct and very defensible one, ve are expressing our -
opinion and opposition to your preferred alternative to correct this problem as .
a municipality directly impacted by the asbestos. We have several acres of che
asbestos piles within the borders of our Township immediately adjacent to the
Borough of Ambler.
In summary, I wish to state again our unequivocal support of the Borough
of Ambler in this matter, and I respectfully request that you reconsider
your position and broaden the scope of alternatives chat you will consider to
eliminate this very serious problem.
We appreciate the opportunity to provide our input and comments on this
study and would appreciate a timely response to all the concerns that we
identified.
Very truly yours,
/I.
Gregory N. Klemick
Township Manager
GNK:jjs
cc Board of Commissioners
Mr. Anthony J. Decembrino, Ambler Borough Council President
Mr. Donald Colosimo, Ambler Borough Manager
Mr. Heccer Abreu-Cintron, EPA
Ms. Nancy Sinclair, EPA
Senator John Heinz
Senator Arlen Specter
Congressman R. Lawrence Coughlin
Representative George E. Saurman
Commissioner Paul B. Bartle
Cotxissioner Betty B. Linker
Cocmissioner Rita C. Banning
Mr. Stephen West, MCPC
-------
MONTGOMERY COUNTY PLANNING COMMISSION
court house • norristown. Pennsylvania 19404 • (215) 278-3722
offices: one montgomery plaza, swede and airy streets, norristown
July 13, 1988
Ms. Nanci Sinclair (3PA 00)
Community Relations Coordinator
U. S. EPA Region III
341 Chestnut Street
Philadelphia, Pennsylvania 19107
Re-. Ambler Asbestos Piles
Remedial Investigation
Feasibility Study (RI/FS)
Dear Ms. Sinclair:
We have reviewed the Superfund Program fact sheet for the Ambler Asbestos
Piles (May, 1988) and portions of the full Remedial
Investigation/Feasibility Study {RI/FS) document on file at the Vissa-
hickon Valley Public Library - Ambler Branch. Please consider the follow-
ing comments and questions belov as the result of our preliminary review
of the proposed alternatives for cleaning up the Ambler site.
1. The Ambler asbestos pile area under consideration in the RI/FS
involves only a portion of the potential asbestos sources within
Ambler. It is noted in the RI/FS that potential sources of
asbestos are contained in the two Maple Avenue piles, the berm
around the reservoir near Maple Avenue and the Nicolet Facility
itself, all of which are not contained in the Superfund remedia-
tion area. Due to this fact, any proposed remediation action at
the Superfund site will not totally control potential asbestos
health hazards within Ambler. Logically, similar remediation
actions should occur at all possible asbestos waste areas within
the Borough in a coordinated manner to provide uniform health and
safety benefits to the residents.
2. Though the proposed alternative, site encapsulation, is supposed
to provide a sufficient long term isolation of the asbestos from
the community, little detailed information is provided regarding
long term maintenance, liability, and enforcement measures. This
issue is particularly critical given the fact that the site
owner, Nicolet Industries, Inc., has filed bankruptcy under Chap-
ter 11. Ve feel that a detailed plan for site maintenance, lia-
bility, and enforcement should be provided for each remediation
alternative before one is chosen.
-------
Ms. Nanci Sinclair -2- July 13, 1988
3. It is understood that as part of the Chapter 11 proceedings for
Nicolet Industries, Inc., the subdivision and subsequent sale and
re-use of the Superfund site and surrounding properties may take
place. Ambler Borough will have to review any proposed subdivi-
sion and land development plans in accordance with their existing
subdivision and zoning regulations. Critical issues, regarding
health and safety pertaining to asbestos waste contamination of
the proposed property to be subdivided and structures to be
re-used, are not part of the Borough ordinances, nor is the
Borough or Montgomery County Planning Staff fully qualified to
judge the potential health and safety impact pertaining to var-
ious subdivision and land development schemes for the Nicolet
property. Due to the lack of performance criteria related to
contamination in the existing ordinances and qualified staff, we
look toward EPA or their contractors to provide guidance regard-
ing: the feasibility of subdivision; the appropriateness of var-
ious adjoining land uses; various design and performance stand-
ards such as building set back from waste piles; necessary inves-
tigations to certify the reusabilty of portions of the Nicolet
plant; various access easement requirements for the Superfund
site; and other considerations.
4. The RI/FS does not address whether or not the waste pile site
could be re-used if the encapsulation technique is chosen. After
remedial actions are completed will the site's use be restricted
by EPA or will it be up to Ambler Borough and Upper Dublin Town- .
ship to provide use restrictions under zoning powers? EPA site
• use control would appear preferable, since actions taken to fully
restrict site usage by a municipality under zoning could be met
with a challenge of inverse condemnation.
5. In assessing various remediation alternatives, on-site vitrifica-
tion and stabilization was examined. The technical review of
this alternative provided on pages 9-39 gave only a brief mention
of the potential for re-use of the waste piles which are pri-
marily calcium/magnesium wastes that contain asbestos. During
November of 1987, Ambler Borough gave zoning approval to the
BO-RIT Corporation to construct temporary buildings for three
years to manufacture pre-cast concrete products out of the Maple
Avenue asbestos waste piles. Though little is known about the
feasibility of the BO-RIT process, it should be thoroughly
examined along with other possible vitrification/solidification
re-use processes. Since the Ambler Superfund site has already
undergone temporary stabilization which provides adjoining resi-
dents with health and safety protection, the appropriate time
should be taken by EPA to thoroughly investigate the feasibility
of waste pile material re-use prior to selecting any remediation
alternative. Such a feasibility investigation might include
actual bench testing of various waste material re-use processes.
-------
Ma. Nanci Sinclair -3- July 13, 1988
Please consider our above comments in finalizing the RI/FS. Overall, we
feel that the selected alternative for site remediation should be one
which fully addresses health and safety concerns of area residents. Ve
would prefer a remediation alternative that removes some if not all of the
waste piles from the site; therefore, we ask that you reexamine various
vitrification/solidification processes that could produce usable
by-products from the waste materials. Ve also ask for your help in eval-
uating critical land use issues at and adjoining the site.
Please keep us informed of any future actions at this site. If you have
any questions, please call me at 278-3729.
Si-ncerely,
Michael Stokes
Chief Environmental Planner
MS/jr
cc: Ambler Borough Manager
Ambler Borough Planning Commission
Upper Dublin Manager
Steve Vest, MCPC
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*il704lt
4021 JOSHUA ROAD
LAFAYETTE HILL. PA.
19444-1498
(825-3535)
TOWNSHIP
July 21, 1988
Mr. Hector Abreu-Cintron
Regional Project Manager
U.S. EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
Regarding: Ambler Asbestos Site Remedial Investigation Feasibility Study/
Selected Preferred Alternative
Dear Mr. Abreu-Cintron:
Whitemarsh Township has reviewed a letter from Anthony J. Decembrino,
President of the Ambler Borough Council, with regards to the proposal for
handling the final disposition of the .Ambler asbestos piles.
Unfortunately, we were not aware of the public hearing that was held
in Ambler with regards to the recent meeting held in Ambler on this matter.
However, we would like to go on record in support of .Ambler Borough's
position that further time be given to consider the vitrification alterna-
tive. This process anpears to hold hotie for a final removal of the asbestos
material from the area under question, and not just an abatement process
such as the proposed alternative of covering and vetching the piles.
We hope that EPA will give Ambler Borough the additional time and
consideration that is needed in order to evaluate a process to eliminate
the oroblem from the community once and for all.
Very truly yours,
•KRENCE J
Township M
LJG:ae
cc: Board of Supervisors
Donald A. Colosimo, Borough Manager, Ambler Borough
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION HI
841 Chestnut Building
Phil«d«lphl«, Pennsylvania 19107
Mr. Anthony J. Decembrino, President
Ambler Borough Council **&*
Borough of Ambler SEP 28 $83
31 E. Butler Avenue ***
Ambler, PA 19002
Dear Mr. Decembrino:
This letter is in response to your letter dated July 5,
1988 concerning the Ambler Asbestos Site Remedial Investigation
and Feasibility Study (RI/FS). We would initially like to
thank you for submitting your comments to EPA and for giving
us 'the opportunity to respond to them.
As you are aware on September 22, 1988, Mr. Bruce Smith,
Ms. Nanci Sinclair and I met with the Council to discuss the
Ambler Asbestos Record of Decision (ROD). Many of the questions
posed in your letter were fully addressed at the meeting and
during a previous phone conversation, but we will respond to
them again here for your records.
Your initial request for an extension to the comment perio1
was formally submitted in a letter sent to the Agency dated"
June 17, 1988. On June 29, 1988, EPA granted the extension
until July 13, 1988. On July 5, 1988 you again requested an
extension until July 31, 1988, this request was also granted.
While we are required to give as little as 21 days for public
comment of a proposed remedial action, we have granted the
Borough a total of 60 days. Accordingly, we believe we have
been extremely accommodating to your request. Further extensions
will only delay the necessary work at the Site and will not
benefit any of the Borough residents.
Your suggestion of removing the piles to a less density
populated site was considered during the RI/FS and it was
determined that the threat of exposure during only removal
operation was too great to consider the alternative further.
In addition, the off-site disposal of the tremendous volume of
material was not feasible as the availability of landfill
space is a prohibitive factor. Finally, CERCLA discourages
against the off-site transport of hazardous materials as a
remedial action and promotes practicable treatment when possible.
The practicable treatment for the remediation of the asbestos
piles at this time is containment.
-------
Regarding your comment "children (being) sent home to
play and sleep within two hundred feet of the asbestos
pile" and that it posing a threat to them, you have only to
read the RI/FS to see that it has been scientifically proven
that the piles are not a source of asbestos, emissions. In
their current state, there is no evidence of any asbestos
being emitted from the site. It is very important that you
understand this. If there was any evidence whatsoever of
potentially dangerous asbestos emission problems coming
from the site, EPA would take immediate action to protect
public health and the environment. Based on'data collected
to date no such threat exist in Ambler.
In response to your recommendation to further consider
the Vitrification process, you should be aware that we met
with Dr. Roberts on June 23, 1988 and discussed the appli-
cability of Vitrofix at the Ambler site at length. Our
analysis of his proposal revealed an inadequacy in the
funding and construction that would be necessary for the
success of the process. The costs of constructing and
operating the plant as well as plans for the disposal of
the end product were not included in the proposal and
therefore was removed from our further consideration.
Our review of the"No' Action" Alternative should not
cause you any concern as we are required to consider "No
Action" in a comparative analysis with the other alternatives.
The "No Action" alternative is rarely selected as it does
not alleviate the human health and environmental problems
that enabled the site to be classified a National Priority.
Your concern regarding the effectiveness of the preferred
alternative is not warranted, as the selected remedy is
fully protective of public health and the environment, at-
tains Federal and State requirement that are applicable or
relevant and appropriate to this remedial action and is cost-
effective as set forth in Section 121 CERCLA, 42 (J.S.C.
Section 9021(b) and Section 300.68 of the NCP. This remedy
satisfies the statutory preference for remedies that employ
treatment that reduce toxicity, mobility or volume of hazar-
dous substances, pollutants or contaminants (emphasis added).
It should be noted that, since asbestos cannot be combusted
and is essentially chemically inert, a permanent remedy, as
such, cannot at this time, be effectively implemented at
this site.
-------
As we have explained and as will be reflected in the
ROD, we will be looking into other alternative technologies
that have been presented since the finalization of the RI/FS.
These technologies will be analyzed in detail in accordance
with the National Contingency Plan and with respect to the
studies that have been conducted at the site. Of course we
will be in contact with you regarding our findings.
If you have any further questions, please contact me at
(215) 597-8751.
Sincerely,
Karen M. Wolper, CJUef
SARA Special Sites Section
-------
July 11, 1988
Mr. Hector Abreu-Centron
Regional Project Manager
3H1W7 U.S.E.P.A.
Region 0 3
841 Chestnut Street
Philadelphia, Pa. 19107
Sir,
The exposed asbestos waste problem of Ambler, Pa. can be
eliminated, permanently, with heavy moleaic compounds. In
utilizing ray 22 years of experience in structural composites,
I have developed a proprietary formulation which locks the
asbestos fibers into a non corruptible matrix of thermo-
setting resins. I have every confidence that, given the success
of my process demonstrated to date, the "whi-te mountains" of
Ambler can be made safe. This method of encapsulation results
in a "perma-cast", non bio-degradable material which may then
be used for curbs, highway barriers, drainage systems, railroad
ties and a host of other community uses. The process will turn
a hazard into an asset.
I propose using catalized resins to turn the asbestos to stone,
injecting the compounds with a machine of my own design to
saturate the asbestos waste wherever it is located. This special
technology allows for a multi-faceted approach to immobilizing
the asbestos depending upon the ultimate method of disposition.
Molding the resultant asbestos/resins material into useful
products is a system which would create jobs in Ambler, though
if the intent is to bury the now safe asbestos in blocks, we
would employ a much less sophisticated procedure. Either way,
the danger has been removed.
It is my understanding that your office is soon to make a
decision as to the manner in which the asbestos will be rendered
harmless. My idea is an extremely cost effective solution, and
one which I would ask that you allow me to prove. The highly
stable, extremely predictable use of resins is a socially and
economically acceptable method of rendering the asbestos in
Ambler, and elsewhere, of no environmental impact. Please give
me the chance to prove my claims.
-------
-2-
I have retained the firm of O'Halloran and Holt, Attorneys
to represent me in establishing a corporate vehicle to
market ray idea. James F. O'Brien, Esq. is well versed in
the asbestos industry, having acted as counsel to a company
actively engaged in asbestos removal. Should you find my
ideas to
with Mr.
be of interest,
0'Brien at:
I would ask that you communicate
Sincerely,
O'Halloran and Holt. & Associates
Attorneys at Law
310 Broadway
Bayonne, New Jersey 07002.
Griffith
cc: Ms. Nancy Sinclair
3H1W7 U.S.E.P.A.
Region #3
841 Chestnut Street
Philadelphia, Pa. 19107
Hon. George Saurman
Pennsylvania State Representative
Mattison Avenue
Ambler, Pa. 19002
Mr. Anthony Decembrino
President
Ambler Borough Council
Ambler Borough Municipal Bldg.
Butler Avenue
Ambler, Pa. 19002
Michael Smith, Esq.
Jenkins, Tarquini and Jenkins
140 E. Butler Avenue
Ambler, Pa. 19002
-------
THE PKOBT.EM
We have reviewed the exhaustive,, highly detailed Remedial
Investigation/Feasibility Study Report for the Ambler Asbestos
Piles, Volumes 1 through 3, as well as the Appendices and
Toxicity Profiles. The comments in the Executive Summary,
Section 1.0 clearly establish the carcinogenicity of asbestos in.
humans, and-notes that the most significant route of exposure is
via inhalation. Additionally, "ingestion of asbestos can occur
either directly (e.g. drinking water) or indirectly following
inhalation." These comments, and others throughout the Report,
are especially troublesome in light of the E.P.A.'s existing
proposal for remedial action, which calls for capping in place.
Completely aside from the issues of the volume of wastes to be
buried, the effect of wind and water erosion and the degree of
future costly maintenance, is the fact that to adequately apply a
geotextile and soil cover for the waste piles, lagoons and
settling basins will require extraordinary vehicular and human
traffic on the piles themselves, churning up asbestos fibers and
severely polluting the environment. How is it possible to cover
22.3 acres of waste with a geotextile cover and three feet of
soil and not disturb the very problem being addressed?
In Volume 3 of the Report, Section No. 10, Revision No. 1, page
9, it is clearly stated that compliance with applicable or
relevant and appropriate requirements (ARAR's) is "technically
impracticable from an engineering perspective." The ARAR is a
state requirement which calls for side slopes of no greater than
33% grade, a regulation which we believe was written to insure
that the primary function of a cap, to provide a barrier between
the asbestos and the atmosphere, is not completely negated by
normal erosion. Section No. 9, pages 9-54 through 9-59 of Column
3 consistently waivers between extolling the virtues of a cap
system, and stating how close to untenable the very idea is.
The point here, of course, is that disturbing the piles by
capping them with three feet of soil is almost guaranteed.
Lightweight construction equipment would be called for, as the
report cites in Subsection 5.3 that a low factor of safety for
most existing external side slopes has been indicated. Further,
pages 9-58 of Section No. 9, Revision No. 1 states that
"additional soil Is not proposed to be placed on the side
slopes", meaning that the three foot cap is only for the top of
the piles, which were not addressed in the 1984 remedial action.
In sum, there will be no 33X grading of the side slopes,
lightweight construction equipment will be moving incredible
amounts of topsoil on the top of the piles, exposing the now
uncovered asbestos to the vehicular and human traffic, and
additional remedial measures to insure elope stability will not
be undertaken, as "final determinations in this regard are beyond
the scope of this investigation", (Section 9, Revision No. 1,
pages 9-56, Volume 3).
The potential for increased future migration of exposed asbestos
during the capping remediation is clear. The "upper bench" of
-------
the Locust Street Pile is uncapped, aa iff the top surface of the
Plant Pile. Given the effects of continuing erosion/weathering
of all side slopes (which will not be covered in the capping
proposal), it would appear that the present E.P.A. plan is not
altogether feasible.
Disposal of manufacturing wastes, being pharmaceutical and
asbestos waetesl. may have begun at the Locust Street Pile as
early as the 1890's, and in fact the Locust Street Pile may
actually be an elevation above the rim of a quarry. Of
particular note to us is the magnesium carbonate, a raw material
used in the production of asbestos cement piping and shingles,
which was dumped in the quarry at the rate of 30 to 40 tons of
carbonate waste a day, (Section 1, Volume 1, pages 1-15).
Magnesium and calcium carbonate are considered essential human
nutrients, and are not considered to be a toxic threat. However.
the carbonate slurry which underpins the piles would appear
especially susceptible to degradation after the introduction of
the weight of three feet of topsoil. Ironically, these materials
are one of the major components in our alternative use of the
existing waste materials.
THE SOr.rTTTDN
Section 9, Revision No. 1, page 6 of the Remedial
Investigation/Feasibility Study Report lists the technical
feasibility criteria for a potential remedial action
alternative. These objectives include performance, reliability,
implementation and safety. Paraphrasing the report's
definitions, the technical goals are:
* Performance - judged by the degree of effectiveness and
useful life.
* Reliability - proven, demonstrable and dependable record
of use.
* Implamentation - actual application, ease of application
and the time required to achieve a given level of
response.
* Safety - to the community, environment and workers of
this, and future, generations.
Thermosetting polyesters meet, and exceed, the above cited
requirements. These reactive mixtures of complex viscous
polymers are the foundation for the fiberglass industry, and have
been supplied to the industry by chemical manufacturers for
decades.
The basis for our idea is to utilize the reinforcing capacity of
asbestos fibers by completely immobilizing them in a
thermo-setting matrix of polyester resins. I have spent the last
22 years of my life in the plastics and fiberglass industry, and
my knowledge of the chemical makeup of polyester resins has
-------
enabled me to identify a complex mixture which, upon saturating
the asbestos in situ, will allow us to safely remove sections of
treated material from the site, and mold a product of great
intrinsic use to the community.
Improved fiber reinforced polymers and similar advanced materials
have become the staple of the fiberglass and plastics industry.
These high performance, lightweight plastics have found a number
of socially acceptable uses, and each one requires structural
enhancement. The irony of the Ambler asbestos problem, and by
extension every such asbestos contaminated waste site, is that
the natural fiber itself is one of the foremost bonding additives
ever discovered. The original combination of a magnesia
suspension and asbestos is very relevant to our proposed
solution, and Dr. Royal Mattison's only mistake would appear to
have been that the use of magnesia did not forever lock the
dangerous asbestos fibers into a non-corruptible matrix.
Within the engineering industry today, magnesium carbonate is an
extremely desirable yet prohibitively expensive additive to
plastic materials. It appears" very clear that the bulk of the
Ambler piles are magnesium carbonate, with asbestos fibers being
the majority remaining waste. Imagine the combination of all of
the best properties of magnesium, as a plastics filler, and
asbestos, as a bonding fiber, in a plastic product of HMC's which
would not be subject to deterioration. In addition, the analysis
of the site defines a substantial concentration of aluminum,
highly desirable as a fire retardant, and barium, which is a
smoke suppressant with little modification. The molded products
from the Ambler site, after we have treated the hazardous wastes
with our resins, would therefore be of great strength (tensile or
flexural, depending on the end use of the product), fire
.retardant and smoke resistant. In addition, the other minerals
or heavy metals discovered in the analysis, including calcium,
maganese, potassium, copper, iron, and lead are not a liability
in achieving full catalizatlon of our resins. In fact, some of
them hold chemical properties which would be an enhancement to
the product.
To our knowledge, there exist over 2500 polyester formulations,
(each performs differently) and reflect the specific goal of the
end product, but all formulas have one thing in common. A
dramatic change occurs in the physical characteristics of the
polyester compound, from an easily handled liquid to a super
hardened substance which is not prone to damage by fire, water or
wind. The compounds, once having accomplished their
"cross-linking" of long chain polyesters by catalization through
heat, chemicals or ultrasonic means, and in combination with the
reinforcing fibers and fillers, become virtually indestructible.
Of particular note is that, once locked in the resins, the
asbestos fibers will never again be susceptible to migration,
either in the air, through the soil or in the water, because they
have become the integral binding fiber in the plastic. Even when
cut, the resultant saw dust is a plastic with reinforcement, not
an asbestos in plastic. In our concept, the liquid absorbed will
-------
be a catalyzed HMC, which will completely1 capture the fibers.
The reactive polymer mixture is of extreme molecular weight, and
it's absorption by the asbestos fibers and other site materials
will trigger no evaporation. Thus the dry, or hydroscopic
materials are locked into the compound and are completely
non-friable, and will remain that way.
These high molecular weight "backbone" polymers are diluted with
low viscosity monomers such as styrene to achieve the final
formative reaction or "cross-linking" of the long chain
polyesters. The specific blend of these primary components, and
additives, determines many of the in-process properties of the
resins, such as its:
* reactivity
* volatility
* reinforcement wetting characteristics
* compatibility between polyester "backbone" and monomer
systems
* cost
* exotherm in reaction
* cure rate
* curing shrinkage
* resistance to surface crazing
The particular catalyst/promoter system will be chosen for the
specific nature of the manufactured part (shape, thickness, use
and coating, if any) and of the molding method (as required,
either fast or slow cure times) with or without the use of
external heating.
To negate the impact of styrene, we plan to introduce zeolites or
other mole sieves to the compound, which will absorb the styrene
during the curing process. Also, the inclusion of aluma
trihydrate or site substitutes have a dramatic effect on styrene
emissions of all HMC"a. All of these components, and the
composition of the wastes, will be tailored to produce a product
with such properties aa:
* high heat resistance
* weathering resistance
„ * light (0V) stability
* elastic modulus
* flexural strength
* tensile strength
* flame resistance
* smoke suppression
* water insolubility
* chemical resistance
* community and environmental safety
The viscous HMC'a that we will introduce into the Ambler asbestos
waste piles will harden, or cure, only upon the addition of the
catalyst. We do not anticipate introducing the catalyst until
-------
the slurry of reaina and asbeatoa ia extracted from the site, at
which time the catalyst will be added in the mold, or closed
system. Once formed, the polymer can no longer be melted, nor
the reinforcing fibers separated from the matrix. The HMC
is a chemical product of reactions occurring by design, to
fabricate a product of great permanence.
REMEDIL ACTION
Section 7, Revision 1, page 8 of the Remedial Investigation
Feasibility Report defines the specific remedial action
objectives for Ambler aa being:
* "Effectively restrict access . . . This objective would no
longer be relevant however, should a complete removal
action be implemented" .
* "Effectively remove, stabilize or contain the asbestos
contaminated media, on site so that potential direct
contact/incidental ingestion exposures to on site
receptors are minimized, and potential releases of
asbestos to ambient air and adjacent surface waters are
not prevalent in concentrations which would create
unacceptable risks to on and off-site receptors".
He propose to eliminate the potential of exposure to asbestos
fibers by:
* Utilizing the top most layers of asbestos on the top and
sides to create a crust of sufficient strength to
support, without stirring the asbestos waste, vehicular
and human traffic. This crust would be impenetrable to
the elements, and would allow us to continue work on
specific site areas from the top.
* By sealing the pile with a strong, UV stable cap, we
will begin to dry out the underlying layers of
asbestos. At specific intervals in the surface,
filtered relief valves will allow for evaporation of
ground water by eolar heating.
* In sect lone, and after analysis of the makeup of each
such area, we will introduce the viscous HMC's to
thoroughly saturate the asbestos, but will not catalyze
in situ unless that option of permanently fossilizing
the waste piles is elected.
* After the "wet period" of saturation, the slurry mixture
will be extracted from the site and catalyzed in a mold
or closed system, creating the product to be utilized or
marketed. The longer the transition period from viscous
state to solid, the better the saturation of the site
materials.
It is anticipated that the existing factory structures could be
6
-------
utilized to recast the asbestos waste, and we would propose a
plan to pay to the current owner (which we understand to be
Nicolet Inc., in Chapter' 11 bankruptcy) a fee based upon sales of
the recast product as rental for the buildings and any other of
the facilities. Again, this would appear to be a method of
assisting the B.P.A. in recovering its costs, as the rental or
lease payments to Nicolet would be subject to the control of the
Bankruptcy Court. Similarly, the actual ownership of the waste
piles themselves could become of economic interest.
THE COST
The costs identified for the HMC solution to the Ambler asbestos
waste problem must be viewed within the context of the
fabrication of usable products which, when utilized by the
community, the State or the Federal government, would have at
least an imputed value. For commercial distribution, obviously,
the recoupment of monies expended would be a function of
marketability.
DESCRIPTION ESTIMATED COST
Site preparation (roads, re-
moval of trees and shrubbery,
identification of specific
treatment areas, preparation
of surface for HMC cap) $ 385,000
Site equipment (including cranes
for tree and shrub removal, dis-
pensing machines, trucks, air monitor
equipment, filter masks and pro-
tective clothing) . 325,000
Security monitors and fences 200,000
Renovation of existing plant facility 1,400,000
Reclamation of existing rail track 275,000
Surface water conduits, surface water
control systems 175,000
•
Treatment studies (Locust Street pile,
plant pile, lagoons, etc.) 185,000
Purchase of pilot plant equipment
(including mold equipment) 4,500,000 .
Purchase of pure polyester resins to
treat 1.5 million cubic yards of waste 20,820,000
Distribution requirements for marketing l.SOQ.QQO
Subtotal $29,765,000
-------
Administration (15%) $6,566,000
Contingency (25%) 9.860.000 S16.426.OOP
TOTAL $16,191,000
We have every confidence that.these costs can be met through a
sales/community usage of the finished product of the combination
of HMC's and asbestos. In fact, the calcium/magnesium carbonate
wastes found in quantities which surpass the amount of asbestos
in the Ambler piles will be an important additive to the final
product, and will be available at no cost.
As you may be aware, we met with Mr. Abreu-Cintron on Thursday of
last week, and visited the site that afternoon, for the first
time. This proposal is our attempt to quantify for the E.P.A.
what we feel will be entailed in addressing this hazardous waste
program with the resins and dispensing technology which I have
developed. This proposal contemplates supplying a solution to
the approximate 1.5 million cubic yards of waste as identified in
the Remedial Investigation/Feasibility Study, but obviously
reflects our best estimations and is not meant to flatly state
that the process has a certifiable cost. Further, we would of
necessity work closely with the S.P.A. in examining the recast
materials for safety, and in exploring through an extensive
marketing campaign the potential uses and markets for the HMC
materials.
We realize that we have arrived on the scene only of late, and
that your investigations and studies have been ongoing for a long
period of time. Yet we would ask that you carefully consider our
idea before electing to pursue the topsoil capping. It is our
belief that the HMC proposal will solve the asbestos risk, and
that the products which could be manufactured at the site will
not only pay for the cleanup process, but eventually result in
the physical removal of the "White Mountains".
Frederic.
8
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cc: Ma. Nancy Sinclair
3H1W7 E.P.A.
Region »3
841 Chestnut Street
Philadelphia, Pa. 19107
Hon. George Saurman
Pennsylvania State Representative
Mattison Avenue
Ambler, Pa. 19002
Michael Smith, Esq.
Jenkins, Tarquini and Jenkins
140 E. Butler Avenue
Ambler, Pa. 19002
Mr. Hector Abreu-Cintron
Regional Project Manager
Region 83
841 Chestnut Street
Philadelphia, Pa. 19107
Mr. Anthony Decembrino
President
Ambler Borough Council
Ambler Borough Municipal
Building
Butler Avenue
Ambler, Pa. 19002
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
SEP 28 1988
Mr. Frederick Griffith
21 East 37th Street
New York, New York 10016
Dear Mr. Griffith:
This letter is in response ' to your July 27, 1988 letter
'that followed our July 21, 1988 meeting in reference to the
Ambler Asbestos Site.
After our meeting, your proposal for utilizing heavy moleaic
compounds was analyzed more thoroughly and we believe that more
information is needed before EPA can make a final determination
as to the feasibility of process. We recognize your need to
study the situation further and have decided to include youc
remedy as one of the two potential alternatives that needs to
be looked into further.
You will be contacted by this office as to how you are
proceed. If there are any questions, please call at
597-8751.
Sincerely,
5^c?Mt^-^
Karen H. Wolper, Cnief
SARA Special Sites Section
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RICHARDS & O'NEIL
85 THIRD AVENUE
NEW YORK. N.Y. I0022-48O2
212 / ao?-iaoo
CABLE: RICHONCIL
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WRITER'S DIRECT DIAL
(212) 207-1342
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Mr. Hector Abreu-Cintron
Project Manager, Ambler Asbestos Site
U.S. EPA Region III
841 Chestnut Street
Sixth Floor
Philadelphia, PA 19107
Re: Ambler Asbestos ("Nicolef) Site - RI/FS
Dear Mr.-Abreu-Cintroh:
As you know from your recent deposition in United
States v. Nicolet, Inc. v. Turner & Newall PLC, Civil Action No.
85-3060 (E.D. Pa.), this firm and the firm of Dechert Price &
Rhoads represent T&N pic in that CERCLA cost-recovery case. In
that capacity, we respectfully submit this letter and the
enclosed comments on the Remedial Investigation/Feasibility Study
Report ("RI/FS") issued by the Government for the Nicolet site.
In submitting comments on the RI/FS, we are not
admitting any liability for any costs already incurred or to be
incurred by the Government relating to the Nicolet site, nor are
we waiving any defenses to the claims being made by the
Government against T&N.
Furthermore/ we are not conceding the accuracy of the
factual information contained in the RI/FS. For example, the
RI/FS, already revised because of my comments at the June 16,
1988 so-called public hearing, still mischaracterizes the
relationship of T&N to the Keasbey & Mattison Company and the
Nicolet site. .T&N did not purchase Keasbey or the Nicolet site.
Instead, T&N merely acquired ownership of Keasbey stock. T&N
also did not manufacture any products, let alone asbestos-
containing products, at the Nicolet site. Only Keasbey and
Nicolet did so.
-------
RICHARDS s. O'NEIL
Mr. Hector Abreu-Cintron
July 29, 1988
Page 2
Additionally, we cannot confirm either the propriety of
the testing methodologies used or the accuracy of the test
results obtained for the Nicolet site because the Government
deprived TSN of a meaningful opportunity to participate in and
perform the remedial investigation.
Very truly yours,
/
Jon Schuyler Brooks
JSB:MM
Enclosure
cc: John P. Mason, Esq.
Virginia Gibson-Mason, Esq.
Lydia Isales, Esq.
Joel Schneider, Esq.
D:S078053JSB
-------
(m,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i REGION III
3
f 841 Chestnut Building
Philadelphia. Pennsylvania 19107
SE? 3 0
Mr. Jon Schuyler Brooks
Richards and O'Neil
885 Third Avenue
New York, New York 10022-4802
Dear Mr. Brooks:
This letter is in response to your letter dated July 29,
19'88 in reference to the Ambler Asbestos Site Remedial Investi-
gation and Feasibility Study (RI/FS). Also included with the
letter was the report entitled "Comments on the Remedial Investi-
gation/Feasibility Study for the Ambler Asbestos Piles Site,
Ambler Pennsylvania" by ERT.
After reviewing the report it is the Agency's understanding
that ERT concludes that the final proposed remedial action is
too excessive and a less involved alternative should be considered.
A major concern that was stated was the extent of the cap EPA
has proposed. The depth as well as the aereal extent are open
in discussion. Utilizing examples from other regions on the
extent of cap dimensions to mitigate the freeze/thaw effect,
the agency feels that the recommended dimensions are reasonable.
Another concern you state is the contention that the endangerment
assessment does not document an imminent and substantial threat.
ERT directly cites the RI/FS as saying that the purpose of this
endangerment assessment, as stated on page 6-1, is to "properly
document and justify its assertion that, an imminent and
substantial endangerment to the public health or welfare or the
environment resulting from an actual or threatened release of a
hazardous substance may exist." It is important to note that
"imminent" does not mean immediate harm; rather, it means an
impending risk of harm. Sufficient justification for determina-
tion of an imminent endangerment may exist if harm is threatened;
no actual injury need have occurred or be occurring. Similarly,
"endangerment11 means something less than actual harm. There is
a real potential for imminent harm in the Ambler Site. There
were also various detailed criticisms of the report which could
be better discussed at our meeting on September 30, 1988.
It is the agency's firm belief that the proposed remedy is
the most acceptable alternative of all the options presented in
the report. It adequately addressed all potential human health
and environmental threats and provides the best protection
utilizing the current CERCLA and NCP guidelines.
-------
It is ray understanding that you. have been in contact wil
Ms. Virginia Gibson-Mason, Esq., Ms. Lydia Isales, Esq., and
Mr. Hector M. Abreu Cintron to discuss the possibility of further
evaluating the comments presented in the ERT Report by holding
a meeting. We are looking forward to our meeting and the
Agency believe it will be beneficial for both parties. Specific
details can be discussed about the CRT Report.
If you have any questions, please call Hector Abreu Cintron
at (215) 597-9562.
Sincerely/
(L
Karen M. Wolper , Chief
SARA Special Sites Sectio
-------
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Virginia Gibson-Mason, Esquire
U.S. Department of Justice
3310 U.S. Courthouse
601 Market Street
Philadelphia, PA 19106
Lydia Isales, Esquire
Office of Regional Counsel
U.S. - EPA
841 Chestnut Building
Philadelphia, PA 19107
Re: U.S. v. Nicolet, Inc, et al.
Our File Not PR1000-2
Dear Virginia and Lydia:
This letter, with attachments, shall serve as Nicolet's
comments on the RI/FS. As previously noted, Nicolet objects to the
arbitrary and haphazard manner in which the government decided when
these comments would be due.
Attached to this letter is the original and .one (1) copy of
the report of Nicolet's consultant - Environmental Resources
Management. The original report is being delivered to Lydia and a
copy to Virginia. As the attached curriculum vitaes indicate, ERM
has extensive experience in this area and their opinions are
entitled to great deference. Our comments can be summarized as
follows:
1. We agree that on-site containment is the most
appropriate option at the Nicolet site. Off-site disposal and
vitrification .may create more problems than those which they seek
to remove. Moreover, vitrification is an unproven remedy.
2. In view of the lack of any present danger at the
site, and the lack of proof of any significant future danger or
risk, it is inappropriate and unnecessary to perform the extensive
remedial work that is proposed. We believe that some relatively
minor items need to be addressed but that the extensive work that
is proposed should not be done. Site monitoring can be conducted
to assure that conditions at the site do not deteriorate.
-------
MANTA AND WELGE
Virginia Gibson-Mason, Esquire
Lydia Isales, Esquire
July 29, 1988
Page 2
3. The RI/FS is based on data and inspections which do
not accurately reflect the current conditions at the site. As the
attached photographs and slides evidence, there is substantial
vegetation on the piles. This vegetation substantially reduces the
remote possibility of any release from the piles.
4. The contractor's cost estimates are excessive.
5. ERM essentially proposes patching of some minor bare
areas, trimming of some vegetation and the use of riprap instead
of gabions. In addition, it is unnecessary and dangerous to put a
36" cover over the plateau of the piles.
In addition to ERM's report Nicolet submits the following
comments:
1. THE RI/FS IS BASED ON AN INADEQUATE AND ONE-SIDED
HISTORICAL PRESENTATION OF THE FACTS REGARDING THE PILES.
The RI/FS recognizes at page 3-1 that historical information
concerning the piles is important to the current evaulation. The
report states:
These data [important historical
information] for the uncovered piles
are important for the assessment of
the long-term environmental and
public health concerns discussed in
subsection 5.4.2 (Contamination
Assessment Long Term Condition) and
Section 7.0 (Risk Assessment).
•
Nevertheless, the RI/FS ignores important historical information
regarding the.pile that supports Nicolet's position that there has
been and is no danger or risk associated with the site.
Attached is a copy of Bruce Potoka deposition exhibits 11, 12
and 13 wherein it is indicated, inter alia, that the Nicolet sitei
is not a health hazard. Also attached is a copy of the EFA's own"
June, 1979 document which delists the Nicolet site from the EPA
active list of hazardous waste site. Therein it is noted that it
has been determined that the wastes are relatively immobile in the
environment and do not present a serious health and environmental
-------
MANTA AND WELGE
Virginia Gibson-Mason, Esquire
Lydia Isales, Esquire
July 29, 1988
Page 3
situation. The RI/FS also fails to discuss in detail the results
of the Equitable Environmental Health Air Asbestos Monitoring which
took place in March and June of 1977 and which are included as
items 4 and 5 in the government's "Administrative Record". The
March, 1977 report notes on page 29:
The implication of the results of
the previous study, together with
the most recent sampling data,
suggests that fugitive asbestos
emissions from the exposed surfaces
of the inactive pile are
insignificant and infrequent.
Furthermore, the results indicate
that measurable asbestos levels in
the vicinity of the inactive pile,
in some cases, may be independent of
the condition of the pile. .
The October, 1977 report (June, 1977 sampling) confirms the
earlier testing and states, "it still appears that the non-
occupational level of exposure for . residents in the nearby
community is extremely low."
In view of the above, and Weston's admission that
historical information is important to properly evaluate the
current and future site conditions, it is evident that the
opinions expressed in the RI/FS are based upon an incomplete
record untainted by available evidence which supports Nicolet's
position.
2. THE PROPOSED USE OF 36" OF FILL MATERIAL
IS INAPPROPRIATE FOR THESE PILES.
As indicated in ERM's report, it is not necessary to cover
any areas of the piles with a 36" cover. The Plant and Locust
Street piles were covered with material less than half this
thickness. ERM recognizes the efficacy of this thickness by not
proposing that additional cover material be added. Moreover, in
-------
MANTA AND WELGE
Virginia Gibson-Mason, Esquire
Lydia Isales, Esquire
July 29, 1988
Page 4
determining the appropriate cover material for the piles Weston
ignore other relevant sites. For example, the Gravers Road site in
Plymouth Township, Montgomery County, is substantially similar to
the Nicolet site. When that response action took place Nicolet is
under the impression that only a 6" soil cover was used. In
addition, we understand that with regard to the Globe, Arizona and
Tyler, Texas asbestos sites, cover material substantially less
than 36" was used. Weston also did not consider the thickness of
the Maple Avenue pile which is performing satisfactorily at this
time.
3. THE RI/FS DEMONSTRATES THAT THERE IS AN
INSUFFICIENT RISK OF HARM IN THE FUTURE
TO JUSTIFY THE SUBSTANTIAL REMEDIAL ACTIONS
THAT ARE PROPOSED.
After an extensive analysis, the RI/FS does not reveal any
significant risks which will occur in the future. Instead to
justify the wasteful expenditure of millions of dollars, Weston
engages in speculation such as:
The results do indicate, however,
the presence of potential asbestos
sources in the site area which might
affect ambient air quality, (p. 6-
49, emphasis supplied.)
The RI/FS also states:
"[F]uture pile cover deterioration
and in addition, lagoon discharges
during large storms could
T potentially create measurable
risks..." (p. 7-3, emphasis
supplied)
-------
MANTA AND WELGE
Virginia Gibson-Mason, Esquire
Lydia Isales, Esquire
July 29, 1988
Page 5 .
This type of guesswork is inappropriate in light of statements such
as:
[N]o existing unacceptable risks
which are directly attributable to
this site were found as related to
inhalation of asbestos contaminated
ambient air. (p. 7-1)
The decision of whether or not to take substantial remedial
action at the Nicolet site must be based on the results of the RI.
The RI does not indicate that substantial risks are expected in
the future or exist at the present time. If the government is
concerned about future problems at the site they can be addressed
by an appropriate inspection and maintenance program. It is
contrary to the dictates of the National Contingency Plan and
Section 121 of CERCLA to spend millions of dollars to address
speculative risks which the data indicates will not arise in the
future.
4. THE RI/FS DOES NOT TAKE INTO CONSIDERATION THE
SUBSTANTIAL VEGETATION AT THE SITE THAT HAS
DEVELOPED SINCE THE RI.
As ERM's photographs and slides graphically demonstrate,
there is substantial vegetation at the Nicolet site at the present
time. It does not appear that when the RI was performed that this
extensive vegetation was present. This substantial cover material
reduces the potential for releases from the site. The RI/FS does
not properly take into consideration the increased vegetation that
will occur in -the future.
5. NUMEROUS ERRORS IN THE RI/FS NEED TO BE ADDRESSED.
There are numerous errors in the RI/FS that need to be
addressed. Some of the most important items are as follows:
-------
MANTA AND WELGE
Virginia Gibson-Mason, Esquire
Lydia Isales, Esquire
July 29, 1988
Page 6
1. Page 1-2 refers to the June, 1983 test results
which Bruce Potoka testified were not reliable since no QA/QC was
done.
2. Page 1-5 states that nesotheliomas have been
identified in individuals living near asbestos plants without any
references. The report does not discuss or mention Dr. Rodman's
affidavit (attached) which indicates that the Nicolet piles did
not even present a danger before the initial response action.
3. Page 1-37 of the report notes that Nicolet would
not comply with the specific terms of cleanup outlined by the EPA.
Nicolet disputes this statement and as it has previously stated it
was prepared to conduct the response action requested by the
government.
4. Page 1-36 of the report discussing the history
regarding actions at the site fails to mention that the negativ^
publicity regarding the Globe, Arizona site led the EPA to
investigate the Nicolet condition.
5. Page 3-41 states that the samples showed a
"measurable accumulation" of asbestos. The statement is denied. In
addition, the RI/FS implies that the asbestos came from the piles
when there is no evidence to this effect. Bruce Potoka and Jeff
Pike both testified to the numerous potential sources of asbestos
in the area. The RI/FS is also replete with references to ambient
asbestos.
Thank you for your attention to this matter. We sincerely
hope the government will reevaluate the proposal set forth in the
RI/FS and agree with us that only minimal work is appropriate in
view of the complete absence of any information to indicate
substantial present or future risks at the site.
Sincerely,
MANTA AND WZLGE
JS/smp
Lr-.
/Joel Schneider
-------
\SSZi
*° n«>, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
SEP 30
Mr. Joel Schneider
Manta and Welge
One Commerce Square
2005 Market Street
Philadelphia, PA 19103
Dear Mr. Schneider:
This letter is in response to your letter dated July 29,
1988 in reference to the Ambler Asbestos Site Remedial Investi-
gation and Feasibility Study (RI/FS) . Also included with the
letter was the report entitled "Review comments on Nicolet Site
RI/FS Report" by Environmental Resources Management (ERM) .
After reviewing the report, it is the Agency's understanding
that ERM agrees with the proposed remedial action of the RI/FS.
On page 7-1, it states the following: "ERM recommends a closure
method consisting of riprap along the Wissahickon Creek, patching
of bare spots on the top and slope areas of the piles, surface
water control measures (e.g., swales, flumes, ditches and settling
basins) , and security measures (e.g. , a complete fence surrounding
the piles and lagoons and gates with locks) . In addition, a
post-closure inspection and maintenance program should be
provided."
AO't
With the exception of your "'addressing the settling ponds
contamination, your suggestion is equivalent to the preferred
remedy selected by EPA. There are specific comments that are
stated by ERM however that should be discussed. Your statement
that no potential exists for the release of asbestos in the
future is unsubstantiated. The unchecked erosion would definitely
affect the stability of the site. Most of your observations
(slides) seem to have been made from the air (a plane, helicopter,
etc.) . A closer inspection would supply you with better information
on the potential for future erosion problems.
-------
If you wish to discuss the specific comments of the report/
we could arrange a meeting. If you have any comments, please
call Mr. Hector Abreu Cintron at (215) 597-9562.
Sincerely,
Karen M. Wolper, Chief
SARA Special Sites Section
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Pecer H. Peschke
235 Tulip Tree Court
Blue Bell, PA 19422
(215) 646-4674
June 24, 1988
Mr. Hector Abreu-Cintron (3HW17)
Remedial Project Manager
U. S. EPA - Region III
841 Chestnut Street
Philadelphia, PA 19107
Subject: Ambler Asbestos Piles Site
Dear Mr. Abreu-Cintron:
After having attended the June 16, 1988 meeting on the above subject
at the Ambler Borough Hall and reviewed the various proposals, I am
finally convinced that the best long-range solution is Alternative 2:
Excavation/Removal Off -Site Disposal, both from an economic and safety
as well as aestetic standpoint.
Consequently and based on a preliminary review of the data and my
method of disposal, the cost of Alternative 2 should not exceed 525
million based on the following:
Volume: not to exceed 1.3 million cubic yards.
Duration: Maximum 3 years.
My other conditions for this site are:
1. Transfer of ownership of the site to my organization
with 1/3 of Che area to be dedicated to the Borough
of Ambler for township facilities (Borough Hall, Police,
Maintenance, etc.)
2. Ten years exemption from local and county real estate taxes
for Che remaining 2/3 of the area from start of contract.
3. Flexible commercial/institutional/residential zoning for
the remaining 2/3 of the area.
4. 20? royalty /management /administration fee to clear all
other asbestos piles in the USA using my method of disposal.
5. Execution of an appropriate confidentiality agreement with
all concerned parties before details of my method of disposal
can be discussed.
RECEIVED
JUN 2 8 1988
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I would appreciate it if you could arrange a preliminary meeting be-
tween us and/or other interested parties as well as a site inspection
as soon as possible.
Sincerely,
'i. '
Peter H. Peschke
CC: Mr. Michael Heayn, Mayor of Ambler
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1 "••>, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
"^ . REGION III
' 841 Chestnut Building
Philadelphia, Pennsylvania 19107
»r. P.t.r P..chk. SEP 28 1988
235 Tulip Tree Court
Blue Bell, PA 19422
Dear Mr. Peschke:
This letter is in response to your letter dated July 28, 1988
that followed our July 26, 1988 meeting in reference to the
Ambler Asbestos Site.
After our meeting, your proposal for off-site disposal was
analyzed thoroughly and it was concluded that your alternative
can not be considered further for remediation the Ambler Asbestos
Site for the following reasons:
1. Off-site transportation - Our previous review of off-site
transportation of the asbestos convinced us that the threat of
exposure during any removal operation was too great to consider
the alternative further. In addition, the Comprehensive
Environmental Response Compensation and Liability Act discourages
against the off-site transport of hazardous materials as a
remedial action and promotes practicable treatment when possible.
We have determined that the practicable treatment remediation
of the asbestos piles is containment.
2. Waste Volume - The tremendous volume of waste in the Ambler
Asbestos Site would require an extensive period of excavation
and as a result, a severe long term exposure of asbestos to
the city of Ambler.
3. Selection of Disposal Site - The proposal was inadequate in
that it did not provide for an disposal site for the asbestos.
An exceptable landfill would have to be found that would and
can accept this type of waste. Any asbestos landfill requires
necessary State permitting approval.
4. Costs - Your requirements pursuant to the costs that would
be incurred are not reasonable and simply out of our jurisdiction.
Further, we do not have the authority to transfer the property
to anyone, as the owner of the property is still Nicolet Inc. and
who ever acquires the site will be responsible for it's maintenance,
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(2)
Local tax exemptions are also out of EPA's jurisdiction, as
this would be more properly addressed to the county or Borough.
Finally, the royalty/management administration fee for your method
is your right and it cannot be granted by EPA.
In conclusion, the Agency believes that your method of
removal would not be applicable to the remediation at the
Ambler Asbestos Site.
If you would like us to return your proposal to you, or
if you have any question 'please call me at (215) 597-8751.
Sincerely,
Karen M. Wolper, Chief
SARA Special Sites Section
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BO KIT CORPORATION
601 WASHINGTON STREET
CONSHOHOCKEN. PA 19428 r&& & 6 MAPLE STREET
(215) 825-8410 AMBLER. PA 19002
JUK21 1983
Hector Abreu - Cintron June 17,1988
Remedial Project Manager
U.S. E.P.A. Region III
841 Chestnut Street
Phila., Pa. 19107
RE: Nickolet Asbestos Piles
Ambler, Pa.
Dear Hector,
I am glad we had a chance to meet you Thursday evening
at the-Ambler Borough meeting.
As we had discussed, I am enclosing for your review a
copy of our application to the PA. D. E. R. to process cement
block made from sludge containing asbestos.
I feel the information in this packet should fill you in
on how our process will work, and what steps we will take to
secure the asbestos from being airborne.
If you should need any further information or if you
have any questions please call.
Sincerely,
BO KIT CORPORATION ^
Michael J. Rittenhouse
Encs.
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n vxmcn source is located
X. NEW _ EXISTING
Application No. _
Plant Cart* ,.
Date Received
OFFICIAL
Unit
USE ONLY
ID
Potential Emissions (TPY)
PM , SO.
MOX
Actual Emissions
PM
NOX
Change in Actual
PM
NOX
if source is new. does >t replace another source _ YES X NO
Describe source replaced)
CO
iTPY)
SO.
CO
Emissions (• or -I
SO.
CO
i
i
voc
Qth«f
VOC
Qthur
VOC ,,, '
IE. Expected date of completion
1-30-91
2A. Owner of source
BO RIT CORPORATION
28. Employer i.D. No. (Pederii iRS No.)
2 -3~ J. J-4-8.8.-£. 5
3A. Owners designation of source and/or punt if any
38. Location of source Political Subdivision
(Street address or Route No.] (Townsmp. etc.)
6 MAPLE AVENUE AMBLER
County
MONTGOMERY
1C. Mailing address (Street or P 0. Box. City. Zip Codtl
601 WASHINGTON STREET, CONSHOHOCKEN, PA 19428
30. Telephone No.
i
(215) 825-8410
-A. Person to contact regarding tfiis Aoolication i *8. Mailing address (Street or P.O. Son. City. State. Zip Code)
(name and title) i
JOHN S. RITTENHOUSE
*C. Teleonone No.
i
' 601 WASHINGTON ST., CONSHQHOCKEN,PA (215) 825-8410
5. Official signing application must Oe an agent of the Company having primary responsibilities for operation of tne facility to wrticn tms applica-
tion applies. Aithougn he may not have participated in the design of tne facility he should be resoonsioie for approval of the. design.
AFFIDAVIT
I _——______———»_»_____ . being duly sworn according to law deoose and say that I am
:he official having primary responsibility for tht design and operation of the facilities to which this application applies
that the information included in the foregoing application is true to the best of my knowledge, information and belief.
jworn to and subscribed before me this ^ day
if Cfcd/t/r^ra-'-v-. /•""
Notary Pueiic
Signature
Tine
-------
16: FUv.
Pag*
of
Section B General Source Information
I SOUHCE
A. 1yp« Some*
|D«tciib«l
SI.UOGK CONTAINING
20% ASBESTOS ...
B. M*nuficli«««
ol Some*
KBASBY-HADISQN
C. Model
No.
N/A
o
Cap icily
ISpccity uniltl
_ N/A._
E Iyp« ol
Pioc«»*d
ASBESTOS
1 f SIIMAIEO FUEL USAGE ISpcclly Untltt
B Typ* Fuel
N/A
C. Avcicg*
Houily
Moiuly
Rile
f. Pnccnl
Sullui
F. Pticent
G. IU«ling
V.lu.
J NOHMAL PROCESS OPIHAIING SCMEUUIE
A Amount
Pioc*tl«d/yi.
ISp*clly unllil
N/A
B
hi/d«y
N/A_
c
To(*l
tx/yi
D. % Ihiupul/Uuwui
Ul 2nd 3td 4lh
N//V
N//I
4 ANNUAL FUEL USAGE
A Annu»l
Amount*
B.
Av*t*g*
tw/dcy
C
lout
h«/yi
D. % Ihlupul/QuaiUi
Ul 2nd 3id 4ih
tMll AMI Allarli flow 3 jntinr It
-------
3 4
_iu-'6 a«v 235 "age of
Section B Source Information Continued
5. Sescnae fully trie fac-.»t:es provtoed to monitor a
-------
: 36
Section E Miscellaneous Information
1. Cescr.se ?unv 'acmues to monitor ana 'ecsra trie emission of air contaminants. P'ovioe aetaueo information to snovv tnat tne 'acuities
are aaeauate. include cost ana maintenance information. Periodic maintenance feooas are to oe suommea to tne Oeoartment.
G Ooacrjy monitor
G SOi monitor
£ ntn.r MICRO MAX I
if checxea srovide manufacturer name, mocel no. and pertinent technical soec:fications.
ASBESTOS CONTROL TECHNOLOGY INC.
MICRO MAX I SER. *07638
AIR FLOW RANGE FOR SAMPLING
5-15 LITERS PER MINUTE (018-0.53 CU.FT. PER MINUTE)
PUMP POWER 1/6 HP (Ol'lKW)
2. Anacn Air Pollution Eouooe Strategy uf applicable)
N/A
3. The following requirements are aooiicaoie only to construction only to construction of a new source.
t. Briefly aescnbe tne nature of tne area m wniclt tne orooosed source is located. Anacn a'coov of tne aoorooriate oortion of tne
map i7'/>' scale) Duoiisnea Oy. tne U.S. Geological Survey and identity tne location of proposed source.
N/A
b. Demonstrate tnat tne estaoitsnmem of tne new source is justifiable as a result of necessary economic or local development.
N/A
4. if tne source is subject to Section 127.63 (sotcial permit requirements)
a. Demonstrate tne availability of emission offset (if applicable)
N/A
•
b. Provide in analysis of alternate srtea. size*, production processes and environmental control techniques demonstrating that the benefits
of tne proposed sourca) owrweign tM environmental and social costs.
N/A
?
5. Anacn calculations and any additional information necessary to thoroughly evaluate compliance wrtn all the applicable requirements of Aaicie
III of tne rules and regulations of tfie Oeoartment of Environmental Resources and those requirements promulgated by trie Administrator of the
United States Environmental Protection Agency pursuant to the provisions of the Clean Air Act.
N/A
6. List all attachments made to this Application.
1 - LITERATURE ON MICRO MAX I AIR SAMPLING PU*r»
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PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
1875 New Hope Street
Norristown, PA 19401
215 270-1920
January 11, 1988
BoRit Corporation
601 Washington Street
Conshohocken, PA 19428
Attention: Mr. Michael J. Rittenhbuse
Vice-President
Gentlemen:
Please be advised that, additional information is needed by the Department in
order to process your Plan Approval Application for modifying a process where
asbestos incapsxrlated cement is produced from sludge containing 20%, asbestos at
your facility in Ambler Borough, Montgomery County which we received on
January 4, 1988. /
This additional information is:
a. latitude of your facility,
b. longitude of your facility,
c. estimate of total acreage of your facility.
Further processing of your application must await receipt by us of your answers
to the above needed information.
Should you have any questions on this matter, please contact me.
Very truly
MES P.
Pollution Control
Re 30 (SMC)11.5
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"BO'RIT CORPORATION
601 WASHINGTON STREET
CONSHOHOCKEN. PA 19428
(21S)82S-S410
PLANT:
6 MAPLE STREET
AMBLER. PA 19002
January 19, 1988
CoiTuT.cnwealth of Pennsylvania
Dept. of Environmental Resources
1875 New Hope Street
Norristown, PA 19401
Attn: James P. Donnelly, P.E.
RE: 6 Maple Ave. Ambler
Y/F: 30 (SMC) 11.5
Dear .Mr. Donnelly:
As per your letter dated January 11, 1988, listed
below is the information you requested:
Latitude:
Longitude
Acres:
40° 9'
75° 13'
6+
13" North
40" West
Enclosed please find a copy of the location map of
the facility.
call.
If you have any questions please do not hesitate to
Sincerely,
BO RIT CORPORATION
Michael J. Rittenhouse
MJR:rr
Enc.
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J9MI TO t»'C»C»'*»Gt
NQtHflSTQWN
-------
BO KIT CORPORATION
601 WASHINGTON STREET . PLANT-
CONSHOHOCKEN. PA 19428 6 MAPIE STRE£T
(215)825-8410 AMBLER. PA 19002
U.S. E.P.A.
Region III
841 Chestnut Street
Philadelphia, PA 19107
Attn: Hector Abreu-Cintron
Remedial Project Manager
RE: Nicolet's Asbestos Piles
Ambler, PA
Dear Hector:
This letter is a formal request for an extension for your
considering alternative measures at Nicolet's Asbestos
Mounds.
We would-like you to consider our process, as per our letter
dated June 17, 1988, to make concrete blocks to encapsulate
Nicolet's Piles.
Your attention on this matter would be greatly appreciated. '
If you have any questions, please contact the undersigned.
Sincerely,
Michael J. Rittenhouse
MJR:rr
RECEIVED
JUN301988
A,Sp*
ETA,
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BO KIT CORPORATION
601 WASHINGTON STREET . _
CONSHOHOCKEN. PA 19428 \ .
AMBLER PA'9002
July 29, 1988
Environmental Protection Agency
Region III
841 Chestnut Street
Philadelphia, PA 19107
Attn: Hector Abreu-Cintron
Remedial Proj. Mgr.
RE: Nicolet Super Fund Site
Ambler, PA
Dear Hector:
The following is a brief outline and scope of work to be
done in order to encapsulate the above material.
(1) Concrete blocks will be manufactured as outlined iry
the application to the D.E.R., dated January 4, 1988.
During manufacturing, all D.E.R., E.P.A. and Osha require-
ments concerning the handling of Asbestos material will be
observed in order to insure safety and integrity of surrounding
humans, land, air and water.
(2) A poured concrete footing measuring 6 feet in width
and around the perimeter of Nicolet 's asbestos mounds, measur-
ing 7,000 feet.
(3) The concrete blocks will construst a wall 4 feet
thick, and 40 -feet high. (Drawing enclosed)
(4) Voids between the present mounds and walls will be
filled by displacement of present material or the addition of
clean fill.
(5) The top will be covered with 2 feet of clean fill
put in place by conveyor and then covered with single ply
vulcanized rubber roofing. The roof will be pitched so that
all water will be drained into proper gutters and directed to
a central location for analysis and monitoring.
(con't.)
-------
\j. j. Rittenhouse
Pg. 2
E.P.A.
Attn: Hector Abreu-Cintron
(6) The walls will then be coated with a poly vinyl
acetate that will be imperious to rain. The walls will have
architectual design to present an eye appealing environment.
The approximate cost of the project is S3.8 million
dollars.
If you have any questions or comments, please call.
Sincerely,
BO HIT CORPORATION
Michael Rittenhouse
MJR:rr
Enc.
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'° •*>, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia, Pennsylvania 19107 £P? 3 0 1338
Mr. Michael J. Rittenhouse
Bo-Rit Corporation
601 Washington Street
Conshohocken, PA 19428
Dear Mr. Rittenhouse:
This letter is in response to your letter dated June 17,
1988 that followed our July 22, 1988 meeting in reference
to the Ambler Asbestos Site.
After our meeting, your proposal for was analyzed
thoroughly and it was concluded that you alternative cannot
be applied to the Ambler Asbestos Site for the following
reasons:
1. Waste Volume - The tremendous volume of waste in the
Ambler Asbestos Site would require an extensive time period for
iis implementation and would expose the city of Ambler to
long-term contamination problems from asbestos emissions.
2. Integrity of blocks - The integrity of the blocks
cannot be guaranteed unless the blocks are individually
covered with a protective plastic lining. The large calcium
carbonate content of the piles would produce a very basic
(as opposed to acidic) material thus the potential for erosion
and leaching due to the environmental elements is great.
3. Use of blocks - Though it has been suggested that
the blocks can be used around the toe of the piles or to
build a large wall by itself, the final product is not usable.
In general the Agency feels that your technology is very
sound for specific cases and innovative in its approach to
asbestos contamination. The possibility of applying it to
the Maple Avenue Piles is great. This conclusion is based
upon the suspected composition of your pile, and the volume
of the waste present. As stated in our meeting, we feel
-------
that you would need to collect more data on the internal
characteristics of your pile (either through borings or
trenching).
If you have any questions on how you can collect the
data (methodology/ etc.) or on this letter, please call me
at (215) 597-9562.
tector Abreu-Cintron
/Environmental Officer
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DEVELOPMENT CORPORATION
August 2, 1988
Mr. Hector M. Abreu Cintrcn
U.S. ENVIRONMENTAL PRCTECTICN AGENCY
841 Chestnut Bldg.
Philadelphia, PA 19107
Dear Hsctor:
We enjoyed our meeting with you and Frank Finger at Weston's offices
on the 28th. We feel that the fusion process we described at that
time offers several significant advantages as problematic waste de-
struction method.
Since electrode and power input configuration uses the materials'
resistivity to raise the terrperature up to and above the fusion point
with a sufficient dwell time to completely destroy any crystallinity
that the materials may have, the resulting glass is non-leachable and
non-biodegradable.
While there is no appreciable change in material mass, there is a sig-
nificant volume reduction. In the case of municipal solid waste ash,
this volume reduction is on the order of ten to one. Asbestos con-
taining materials may be as much as four to one. Thus, unlike
"vitrification" that actually adds to the final volume and mass of the
materials, there is a reduction in final materials' volume using direct
fusion. I have enclosed a copy of our Research Description for your
review.
I appreciate your advice about the EPA site program headquartered at
MST in Washington. I am asking that you forward a copy of this tram
mittal to the appropriate individual there. If you could let me knov
who that is, I will follow up with them.
Thanks again for your time.
Very truly yours,
t1r)CH DEVELOPMENT CORPORATION
,._. RECEIVED
R. Tata
V.F. Marketing & Sales
Enclosure
630 Valley Forge Plaza Bldg. • King of Prussia, PA 19406 •Telepnon«: (215) 337-8515
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(Research Description)
DESCRIPTION OF INCINERATOR-ASH VITRIFICATION PROCESSES
Suhngrged Electrode Furnace (W5V)
Source of Technology: Geotech Development Corporation
630 Valley Force Plaza Bldg.
King of Prussia, PA 19406
(215) 337-8515
Contact: Mr. T.R. Tate
System Description
The heart of the system is the water cooled double wall steel
vessel with submerged electrode resistance melting. The vessel
is bottom pour and designed to pour continuously. The real
• advantage is the electrical balance we can achieve in our
system to feed, melt and pour in a stabilized and balanced
condition. Ash or residue is fed automatically or manually
depending on the volume.
Facility Requirements
ASH
The entire system for a plant processing 100 tons of dry ash
to glass per day will occupy a plant floor area of approximately
24,500 ft.2, 126' x 194'. This area does not include ware-
housing of finished products. Warehouse size will depend on
product mix and marketing strategies.
Energy requirement is 460 KWH per ton of melt. This is
3680 IWH per eight hour shift per ton; 24 hours of continuous
production to melt 100 tons of ash will consume 46,000 KWH.
The size of furnace is designed, therefore, for a continuous
pour rate of over 8000 Ihs./hour.
Feed is handled by slew rotating continuous non-dusting auto-
matic feeder. Raw material from bins or silos can be mechan-
ically or by means of air conveyed to automatic feeder. The
product fron spinning downline will proceed synchronously via
Geotech designed Collector, Needier, Ovens and finishing end
if vitreous fiher is being made. If glass beprfs or block are
the production desired* then casting or g?n<^ ^i<~aj*'fjQ" chamber
is used.'
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ASBESTOS AND ASBESTOS CONTAINING .MATERIALS
Double plastic bags containing asbestos residue are charged
through charge doors and ramp. The furnace cover contains
negative pressure to the dust collection system.
The enclosed furnace is further enclosed in a filtered air
conditioned room that is slightly positively pressurized.
Energy requirements for asbestos containing material is es-
timated at 620' KWH per ton. This is 4960 KWH per eight hour
shift per ton. Since the furnace will operate 24 hours per
day on a continuous basis, a daily power usage will be
31,000 KWH per day for a 50 ton unit.
Energy Recovery
If the melt is cooled and fractured by water quench, there will
not be provision for energy recovery. If the melt is spun into
glass wool, all of the sensible heat will be available for
space-heating. There is no feasible opportunity for other
energy recovery.
Final Product-Options, Descriptions, Potential Marketability
The glass melt will solidify and can be recovered as granular
non-porous solids 3/8" and down. It will contain no water
but will be water quenched in order to fracture to sizes re-
quired. There is little or no dust. It is possible to cast
glassy block to 300 Ihs. Larger sizes would require more
expensive and' sophisticated slow cool molds.
The following is a list of potential products and markets:
Classification Petti tization Fiberization
Shore erosion Block Blast Cleaning Grit Ceramic Fibers
Decorative Tile , Road Bed Fill Mineral Wool Fibers
Non-leach randfill Grog for Refractories Vac. Formed Products
Future Mineral Bank Cement Additive Wall board
Abrasive Surface Ceramic Tile
Non-leach T^nri-p-t 11 Textile Fibers
Fireproof Cloth
(Asbestos Free)
High and Low Temp.
Industrial Furnace
Linings
-2-
-------
Tvoical Current Market Prices
Metallics equivalent to No. 1 sera? $100/ton.
Grit (either removed from bottom ash) or finer particles
from fracturing glass - $50/ton.
Mineral wool $390 to $740/ton depending on product and
product mix.
Current Facilities: Operating History and Peliability
Czechoslovakia - operating since 1982
800 Ibs./hr. - approx. 10 T/day
W. Germany - operating sines 1983
France - operating since 1982
Italy - conmissioned July 1986
Canada - shipped April 1986
Japan - conmissioned Sept. 1986
Niagara Falls, NY - full sized facility used for R & D
and sales since 1980
Life Cycle Cost
For a 100 T/day system to fuse fly ash or bottom ash pour
and cast (glassification only).
$3,150,000 Furnace and Controls
1,800,000 Technology
120,000 Supervision on Site
$5,070,000
Additional Capital
For a 100 T/day system to fuse, pour and spin mineral vool then
collect, fabricate and package dry mineral vrool products.
$1,000,000 Spinner and Controls
680,000 Collection chamber and equipment
68,000 Conveyors
136,000 Bagger and conveyor
28,000 Motor control center
$1.912,000
Estimated Cost - m^s Beads or Block
Director T-ahn-p .002
Power Consunption .014
Raw Material (.006)
Operating Maintenance .005
Utilities (other than prod, power) .001
Insurance .001
Depreciation .002
Interest .005
0.024
-3-
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PRELIMINARY PRO FORMA
Incinerator Residue Fusion 30QT/Day = 100,000 T/Year
Best Case Mbrst Case
Capital Investment $8,000,000 $ 8,000,000
Revenues @ $150/Ton $16,500,000 11,000,000 @ $100/Ton
Direct Costs
Manpower 8 $30,000 Yr. $ 600,000 $ 600,000
Power Cost 9 $.04 KWH 2,200,000 2,200,000
Electrode & Orifice Costs 300,000 , 300,000
General Maintenance 250,000 250,000
Other Utilities 225,000 225,000
(heat, light, water)
Insurance 36,000 36,000
Depreciation 800,000 800,000
Contingency 250,000 250,000
Estimated Operating Cost $ 4,661,000 $ 4,661,000
Estimated Pre-tax Gross $11,839,000 $ 6,339,000
No allowance shown for products converted and sold.
No charges are included for products sent to sumpsite.
-4-
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
\ma^r Philadelphia, Pennsylvania 19107
Mr. Thomas R. Tate, Vice President SEP 28 1988
Marketing and Sales
Geo Tech Development Corporation
630 Valley Forge Plaza Building
King of Prussia, PA 19406
Dear Mr. Tate:
This letter is in response to your August 2, 1988 letter
that followed our meeting on September 28, 1988 in reference
to the Ambler Asbestos Site.
After our meeting, your proposed remedy for the Geo-Tech
process was analyzed more thoroughly. We believe that more
information is needed before EPA can make a final deter-
mination as to the Feasibility of the Geo-Tech process.
Understanding your need also to study the situation further
EPA has decided to include your remedy as one of the two
potential alternatives that will be further evaluated during
the design studies. •
We will contact you for any additional information that we
may require. If there are any questions, please call at
(215) 597-8751.
Sincerely,
Karen M. Wolper, Chief
SARA Special Sites Section
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VITRIFIX OF NORTH AMERICA, INC. 1321 DUKE STREET.. ALEXANDRIA, VA 22314 (703) 684-1090 FAX (703) 684-3385
July 28. 1988
Mr. Hector M. Abreu Cintron
Project Manager
Hazardous Waste Enforcement Branch
U. S. Environmental Protection Agency
Sixth Floor
841 Chestnut Building
Philadelphia. PA 19107
Dear Mr. Abreu Cintron:
Vitrifix of North America has developed the enclosed documents
based on the June 16. 1988 public hearing at Ambler. PA. our
meeting on June 23. 1988 and the RI/FS for the Ambler Asbestos
Piles. We have endeavored to provide clarification of relevant
concerns pertaining to the Vitrifix technology and its
application as well as correct the record regarding specific
issues about, the Vitrifix Process. A detailed review of RI/FS
made it clear there were more points to be addressed than were
initially apparent at the public hearing; hence the length of
this transmittal.
Vitrifix submits this information so that the Hazardous Waste
Enforcement Branch of the U. S. Environmental Protection Agency
will have an increased and more accurate understanding of the
Vitrifix Process and its capabilities for remediating asbestos
contaminated sites. If I may answer any questions or provide
additional information, please do not hesitate to contact me.
Best regar
David Roberts
Executive Vice President
DR:km
Enclosures
A COMPANY CONCERNED WITH THE FUTURE OF OUR ENVIRONMENT...
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FR PESIDENT
Hector Abreu 6-18-88
E.P.A. Manager
As of 6-16-88 meeting. My comment is a problem with the
fence that's about 200 ft. from our hones on Locust. We as
residents of Locust St. would like for the fence to be moved
farther back at the bottom of the slope. The fence being so
close to our homes is a terrible eye sore. I hope you will
take this in consideration.
Concerned Resident
Jean Thompson
Letter retyped due to reproduction difficulties
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•AMBLER LABORATORIES
AMBLER. PA.
CHCMICAI. MITCHCLU 8.IO37 «»»-87S7
SAcrcftiai.aaic.ti. June 23, 1983
Nanci Sinclair
Community Relations
EPA
841 Chestnut St.
Philadelphia, Pa. 19107
I will call this the "Romano Alternative" re the Locust Stree:
"White Mountain" dump.
This alternative accomplishes what must be done at minimun
cost, and a short time namely,
(1) it safely neutralizes the health hazard which trans-
location and Vitrifix will not do.
(2) it removes the objectionable vista of a hazardous dump
even from the standpoint of the visual eyesore it is
. during seven dormant-vegetation months of the year.
(3) It makes the area useable as parks, gardens, baseball
fields, or even some housing.
In so doing it utilizes EPA's earth cover idea to imoblize
the asbestos mixture, and provides the benefit of total trans-
location and Vitri-fix's claim that it removes the material to.make
the land, useable.
The principle of the Romano Alternative is to simply construct
a 'stone and concrete wall (a sort of bottom-less box) or a rectangu-
lar-like shape enclosing the dump and of a size sufficient to be
filled by leveling the dump using dust controlled quick bulldozing
and the addition of a 3 foot earth cover.
The height of the box is made the key dimension (approximately
12 to 15 feet). Then the width and length is made sufficient to
permit a vloume equal to the volume of the dump material with three
feet of earth to cover it. There is sufficient flat area on both
sides of the present dump to accomodate the "box", in particular on
west side of the dump.
FOR EXAMPLE;
A "box" of 700 feet in length, 500 feet average width and, for
example 15 feet high could accomodate a volume of 700X500X12
cubic feet, that is 5,250,000 cubic feet.
The Romano alternative would eliminate the hazard and eyesore,
make the land area available , create a more pleasant image of Ambler
It will quickly accomplish this at least expense, and wi.thin one
years time.
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