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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                              -2-

     - 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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                             -3-
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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                              -2-

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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                             - 5 -

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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                               -3-
     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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                              -4-

     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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                              -6-

     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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                              - 7 -

      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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                              -  8  -

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).

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         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.

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            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-

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                             - 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.

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                              -  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.

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                             - 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.

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                               -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.

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                                                        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
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                                                      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.

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                              -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.

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                                        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

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                              -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

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                                   -  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.

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                            . - 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

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                                                            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

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                                                            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

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                                                            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.)

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                   S*ciMily Fwic
       **> Po»t*d Wunmg and
       No Ti«MM«Moa S
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                              -  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.

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                              -  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.

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                             - 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);

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FIGURE II  AtTERNATIVEZ - Of F Sl« OISI»O£

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                             - 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

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                              -  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 -

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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

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                      -  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);

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                             -  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.

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                      Via
                      Muh«» and (iiadMtu
                      ol Final C«p tu P
FIGURE I i  ALTEHNAIIVE 4  ON Silt

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                              -  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.

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                             - 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

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                             - 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-

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                              -  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

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                             -  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.

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                                -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

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                              -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.

-------
                               -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.
*•

-------
                                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

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                                                                    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.

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                                                                    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.

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                                                                    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.

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                         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.

-------
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

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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.

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                                      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

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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
                                    -e.-

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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


                                  -5-

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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

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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

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    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

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          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

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       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.

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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.

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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

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           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.

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    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

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 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.

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                       -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

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 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

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 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

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 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

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 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

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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

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                                          July  29,  1988
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KCNNCTM L. SAMKIN
TMOMA* I. SMCMIOAN BZ
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                                                           STCWAUT W. *ICHAMOS

                                                               I I»OJ •'•»•!
       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.

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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

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(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.

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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

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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

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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

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\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

-------
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

-------
        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,

-------
                               (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

-------
 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.

-------

       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»

-------
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

-------
"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.

-------

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,

-------
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.

-------

-------
    '° •*>,   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

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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-

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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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