United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/080
September 1989
Superfund
Record of Decision
Ambler Asbestos Piles, PA
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50272-101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R03-89/080
3. A8c:1pienI'l "CC888Ion No.
4. T1118 and SubIll8
SUPERFUND RECORD OF DECISION
Ambler Asbestos Piles, PA
Second Remedial Action - Final
7. "lIIIIor(l)
5. Report 0818
09/29/89
..
.. P8rfonnIng OrganIzrion A8pt. No.
.. P8rfonnlng Orgalnlaton NInw and AddI8M
10. ProJ8cIITlI8IIIWork UnIt No.
.
.;
11. ConIr8ct(C) or Or8nt(0) No.
(C)
12. ~ 0rganIuII0n NInw and AddI8M
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(0)
13. Type of Report . P8IIod CoWNd
800/000
14.
15. SuppI8tMntaty No...
18. Aba...ct (UmIt: 2110 word8)
The Ambler Asbestos Piles site is in the southwestern portion of the Borough of Ambler,
Montgomery County, Pennsylvania. This second operable unit for the site addresses the
CertainTeed asbestos pile portion of the Ambler Asbestos site. The CertainTeed asbestos
pile contains asbestos scrap materials and encompasses approximately 3.5 acres of a
5-acre tract. Land around the site is used for industrial, commercial, residential, and
ran sport at ion purposes. The site is bordered to the southeast by the Stuart Farm Creek
~loodplain and associated wetlands system, and to the west by the Wissahickon Creek
floodplain. The CertainTeed pile was created by the disposal of asbestos-cement scrap
Jriginating from asbestos pipe manufacturing operations at the CertainTeed plant. In
addition, aSbestos-contaminated sludge from a process water treatment settling pond was
also disposed of at the site. Asbestos waste disposal continued from 1962 until 1977
~hen the State ordered the CertainTeed pile closed. At present the pile contains
~pproximately 110,000 cubic yards of asbestos-related waste material which is covered by
approximately 22,000 cubic yards of soil. Several inorganic contaminants have also been
detected in the soil and debris of the pile as well as in surface water and sediment from
Stuart Farm Creek. Because the actual sources of the inorganic contaminants in the creek
have not been identified, a verification study will be performed to define the source of
hesecontaminants. The primary contaminant of concern affecting the soil, sediment,
debris, and surface water is asbestos. (See Attached Sheet)
17. Doc:un.It An8/y8I8 .. D88crIpIora
Record of Decision - Ambler Asbestos Piles, PA
Second Remedial Action - Final
Contaminate~ Media: soil, sw, sediments, debris
Key Contaminants: asbestos
b. 1den1l1\er8lOp8n-End8d T8f11'18
\
c. COSIo T1 FieIdIOroup
18. "vlilabilly Stlt8tn8nl
-
18. SecurIty Cia.. (Thi8 Report)
None
20. SecurIty CI... (Th18 P8ge)
None
21. No. O' P8gee
52
22. PrIce
(SH ANSl-Z38.18)
SH In.trucli~ on 118-
OPT10NAL FORM 272 (4-77)
(Form8ffy NT1S-35)
Department o' Commerce
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R GPO: 1983 0 - 381-526 (8393)
OPTIONAL FORM 272 BACK
(4-77)
~~..
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EPA/ROD/R03-89/080
Ambler Asbestos Piles, PA
Second Remedial Action - Final
16.
Abstract (continued)
The selected remedial action for the site includes regrading the pile plateau to promote
proper storm water drainage; placing a soil cover with geotextile reinforcement on
portions ~f the pile plateau and slope where the soil cover is less than two feet deep;
performing a verification study to determine the source of inorganics in Stuart Farm
Creek; installing erosion control devices to protect the toe of the pile from scouring py
Stuart Farm Creek; implementing erosion and sedimentation controls to facilitate
vegetation; restricting site access; monitoring air and surface water; and post-closure
maintenance. The estimated present worth cost for this remedial action is $753,000,
which includes annual O&M costs of $21,700 for the first 5 years and $10,200 for years
6-30.
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Declaration for the Record of Decision
Site:
Ambler Asbestos Piles
Borough of Ambler
Montgomery County, Pennsylvania
Statement of Basis and Purpose
This decision document represents the selected remedial action for the
second operable unit at the Ambler Asbestos Site, in Ambler, Pennsylvania,
developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the Superfund
Amendments and Reauthorization Act of 1986 (CERCLA), 42 U.S.C. Section 9601
et seq. and to the extent practicable the National Contingency Plan (NCP),
40 C.F.R. Part 300. This decision is dOC'lDnented in the contents of the
AdUdnistrative Record for this site. The Commonwealth of Pennsylvania has
concurred on the remedy.
Assessment of the Site
Pursuant to duly delegated authority, I hereby determine, pursuant to
Section 106 of CERCLA, 42 U.S.C. Section 9606 that actual or threatened
releases of hazardous substances from this site, as discussed in "S1.DIIIIary
.of Site Risks" on pages 14 - 18, if not addressed by implementing the
response action selected in this Record of Decision, may present an
imminent and substantial endangerment to public health, welfare or the
environment.
Description of the Selected Remedy
This Operable Unit is the second and final of two operable units
planned for the site. Both operable w1its address the potential release of
asbestos from the site by containing the asbestos-contaminated waste piles.
Operable Unit 1. addresses the Locust Street and Plant Piles on the portion
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of the site owned by Nicolet" Inc. This Operable unit addresses the Pipe.
Plant Dump (CertainTeed Pile) on the portion of the site owned by
CertainTeed Corporation.
The major components of the selected remedy are as follows:
The pile plateau will be regraded to promote proper drainage of
stormwater.
. -
A soil cover with a geotextile reinforcem2nt where necessary will
be installed on portions of the plateau and side slope areas where
the existing soil cover is less than two feet.
Additional borings will be collected in the pile plateau and side
slopes to dete~ne cover thickness and define soil
characteristics.
Perfor.mance of a verification study to dete~ne source of
inorganics in Stuart Far,m Creek.
Erosion on waste pile slopes due to stor,m events, soil creep,
freeze/thaw effects., etc. will be repaired with a geotextile
liner and additional soil cover.
Erosion control devices will be installed to protect the toe of
the pile from the scouring action of Stuart Far,m Creek.
Erosion/sedimentation controls will be implemented during remedial
activities to facilitate the establishment of vegetation.
Installation/Upgrade of fencing/locking gates and posting of
warning signs.
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Air monitoring for asbestos will occur during remedial activitie~ .
(personnel and environmental).
Post-closure inspections, monitoring, and maintenance of the pile,
and preparation of a contingency plan will be accomplished.
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 (or a waiver is justified) and is
cost-effective as set forth in Section 121(d) of CERCLA, 42 u.s.c. section
9621 and Section 300.68 of the NCP. This remedy utilizes pe~ent
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
statutory 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 of remedial action and yearly
thereafter, and this complies with the requirements for review set forth in
Section 121(c) of CERCLA, 42 u.s.c. Section 9621(c).
<1! J f /H
Date
~-~~
Edwin B. Erickson
Regional Administrator
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Table of Contents
for
Decision Summary
SECTIOO
I. Site Name, Location and Description ......................
VII.
VIII .
XI.
APPENDIX
A.
B.
II.
Site History and Enforcement Activities
..................
III.
Community participation
................................ ..
IV.
Site Characteristics
. . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . .
A.
Air Quality/Geology/Hydrology ........................
B.
Extent of Contamination..... '. . . . . . . . . . . . . . . . . . . . . . . . .
C.
Statement of Findings Regarding Wetlands
.............
V.
S\DIIDa.ry of Risks................. '. . . . . . . . . . . . . . . . . . . . . . . .
A.
B.
Exposure AssessInent ..................................
Focused Risk AssesSJnent ..............................
VI.
Remedial Action Objective ................................
Description of Alternatives ..............................
Comparative Analysis
of Alternatives .....................
IX.
'It1e Selected Relftedy' ......................................
X.
Statutory Determdnations
............................. ....
Documentation of Significant Changes .....................
Responsiveness Summary
State Letter of Concurrence
PAGE
1
1
5
5
5
9
13
14
16
17
18
19
28
31
32
39
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I.
Site Name, Description and Location
The CertainTeed Pile site (a portion of the Ambler Asbestos site) is
located in the southwestern portion of the Borough of Ambler, Montgomery
County , Pennsylvania (Figure 1). The site is approximately five acres in
size and is adjacent to the southeast corner of the Nicolet, Inc. Plant
pile. The si te is further bounded on the southwest by a wastewater
transmission line and easement, on the southeast by Stuart Farm Creek, and
on the east by railroad tracks (Figure 2). The CertainTeed Asbestos pile
encompasses approximately 3.5 acres.
II.
Site History and Enforcement Activities
The CertainTeed Pile site reportedly received primarily asbestos-
containing solid pipe scrap from 1962 to 1974. During the years that the
CertainTeed Pile was active, there were two types of manufacturing waste
~terial disposed at this site. The first was a 5% solids sludge, which
consisted of 32% calcitun carbonate and 65% hydrated cement and silica, less
than 2% asbestos and approximately 1% minor miscellaneous components. This
sludge, which was waste material from the process water treatment settling
ponds, was transported to the scrap pile via tank truck.
The second type of waste was Asbestos-Cement (A-C) scrap which
originated mainly from reject pipe and pipe lathe turnings generated during
the pipe finishing operation. This A-C waste consisted of a mixture of
. 10-20% asbestos fiber interlocked within a 80-90% calcium silicate complex
matrix which was created by autoclaving the mixture under a high pressure
(150 psi) saturated steam (350-370 degrees F). The resulting matrix
becomes a type of synthetic rock-like structure. The pipe scrap was hauled
to the scrap pile by Globe Trash Disposal Service. From time to time
CertainTeed hired an outside company to bulldoze the pipe in order to
crush, flatten and consolidate the waste.
The CertainTeed Pile 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
(1 )
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FIGURE
1
SITE LOCATION MAP
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/
.
.
.;
t
~
PI.,r-
~,
, 50 100
-- --
........ 'HI
FIGURE
2
PILE LOCATION HAP
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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 CertainTeed Pile rises approximately 45
feet above the natural grade.
The site is located adjacent to the 100 year floodplain of Stuart
Fa~ Creek. Stuart Fa~ Creek flows,along the southeastern side of the
CertainteedPile. The portion of Stuart Fa~ Creek adjacent to the pile
has an associated wetlands system. The wetlands system occupies an
approximately 10 - 15 foot wide band along the Creek and joins the
Wissahickon Creek flood plain approximately 300 feet downstream from the
pile.
Land use around the site includes industrial, residential,
commercial and transportation. The CertainTeed Pile site is located within
~ industrial zoned area along the southwest border of the Ambler Borough
line. Residential housing and an adjoining playground are loc~ted
approximately 300 feet east of the site. 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 of the
Ambler Asbestos si te. The CertainTeed manufacturing area and the
Southeastern Pennsylvania Transportation Authority (SEPTA) COIIIIIUter
railroad are located east-northeast of the site, 100 to 200 feet away. A
metal fabricating plant and a wastewater treatment facility are located
"approximately 200 feet to the east and southeast of the site respectively.
Starting in 1968, CertainTeed undertook an intensive program to
develop the technology to recycle the waste generated during the
manufacturing process. In early 1972, at the request of the Pennsylvania
Department of Environmental Regulations (PADER), and as required for filing
a solid waste disposal permit, a study was conducted to evaluate the impact
of sludge leachate on surface and ground waters. The results of the
studies found that the dumping procedures had little or no noticeable
impact on surface water or groundwater.
( 2)
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By 1974, the recycling program progressed to a point where all of . .
the waste sludge could be recycled back into the manufacturing process thus
eliminating the need to truck it to the waste pile. The portion of the
dump which was used for sludge dumping was then covered with dirt and
vegetated.
During this same time period, the pipe manufacturing technique was
improving and the quantity of the scrap pipe that needed to be taken to the
waste pile was continually declining. Progress also continued on the
recycling of autoclaved pipe scrap into the manufacturing process, and by
early 1977, CertainTeed had developed the ability to reuse most of this
hard waste. The dumping of pipe waste was discontinued when the
. .
CertainTeed Pile was closed in 1977 in accordance with the conditions of a
"Consent Order" with PADER in consultation with !PA. The total quantity of
asbestos-related waste material is approximately 110,000 cubic yards which
is covered with approximately 22,000 cubic yards of soil.
After the phase out of the CertainTeed Pile, whenever the pipe scrap
generated by the manufacturing process could not be totally recycled, the
excess was taken to the Montgomery County landfill. This procedure
continued until the manufacturing operations at the plant were discontinued
on January 8, 1982.
The Ambler Asbestos Site was proposed for placement on !PA's
Superfund National Priorities List in OCtober 1984 and was ranked 523 of
. 703 when promulgated on the NPL on June 6, 1986.
On November 11, 1985, the CertainTeed Pile was inspected by u.S.
!PA, PADER, WES'Im and CertainTeed Corporation. The cover on the pile was
found to be in relatively good condition and well vegetated. Evidence of
minor erosion and scouring was observed along the south side of the pile by
Stuart Farm Creek. The observations indicated a low potential for pile
stabili ty problems and/or cover loss over the short term. EPA and PADER
decided that surface water and sediment samples of the creek and water
(3 )
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samples from the shallow aquifer under the floodplain area adjacent to
Wissahickon Creek would be taken by the EPA FIT team to verify that no
contaminants of concern were migrating from this source.
on May 12, 1986 the NUS FIT III team took five (5) water samples
from Stuart Fa~ Creek adjacent to and southeast of the CertainTeed Pile.
The 5a11ples were analyzed by Transmission Electron Microscopy (TEM).
Chrysoti1e asbestos fibers were detected both upstream and downstream of
the closed site. The average concentration of two aqueous samples both
upstream and downstream was 42 MFL (million fibers per liter).
In May 1987, EPA notified CertainTeed of its potential liability for
the CertainTeed Pile, and provided it with an opportunity to perfo~ an
(RI/FS) on the CertainTeed Pile. At the same time EPA was performing an
RI/FS on the other two piles (the Nicolet Piles). Due to the scheduling of
the EPA RI/FS it was mutually agreed that CertainTeed would collect the
necessary RI data and EPA would incorporate this information into its FS.
In December, 1987, CertainTeed signed a Consent Order where they agreed to
collect said data.
During CertainTeed's 1988 investigation, asbestos was detected in
the onsite air, the CertainTeed Pile and in Stuart Farm Creek. In
addition, organic and inorganic compounds were detected in the pile and in
samples from the Stuart Farm Creek both upstream and downstream of the
..pile. The inorganic compounds including arsenic, chromi\Dll, cadmi\Dll, lead,
nickel, zinc and copper were found both in the pile and in upstream and
downstream samples from the creek. Other potential sources for these
contaminants exist adjacent to the Stuart Farm Creek upstream of the
CertainTeed Pile. Consequently, the actual source or sources of these
inorganic compounds in the creek cannot be verified at present. Therefore,
a verification study will be required prior to implementation of the chosen
alternative in order to better define the source of these inorganic
contaminants.
( 4)
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III.
Community Participation
In accordance with Section 113(k)(2) and 117 of CERCLA, on
August 16, 1989, EPA placed a quarter page advertisement in the Ambler
Gazette announcing the 30 day cOJllllent period on the Proposed Plan for the
second operable unit of the Ambler Asbestos site. Also announced was the
availabili ty of the Proposed Plan and supplemental documentation in the
Admdnistrative Record and the site repository; the Ambler Branch of the
Wissahickon Valley Public Library. In addition, the announcement provided
the opportunity for a public meeting upon request.
The public comment period began August 18, 1989 and ended September
18, 1989. There were no requests for a public meeting and no comments to
the Proposed Plan.
Site Characteristics
IV.
A. Air Quality/Geology/Hydrology
1. Ai r Quali ty
The CertainTeed Pile site is located in the Metropolitan
Philadelphia, Interstate Air Quality Control Region (U.S. !PA, July, 1987).
. This region is classified as an attainment area for all criteria pollutants
except photochemical oxidants (precursors to ozone). This Air Quality
Control Region is currently classified as secondary nonattainment for
particulate matter (TSP), primary nonattainment for carbon monoxide (CO)
and, primary nonattainment for photochemical oxidants (VOCs which are
precursors to ozone). The area, however, is currently unclassifiable or
better than national standards for sulfur oxide (S02). Locally, air
quality is potentially impacted by industrial and private sources.
(5 )
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The following potential sources of asbestos are located in Ambler
near the CertainTeed site:
o
"East and West Maple Street" Pile and berm around the Reservoir
Area.
CertainTeed Plant Area.
Nicolet Plant Area.
Nicolet Piles and Lagoon Area.
Other background asbestos near
the site.
o
o
o
o
2.
Geology
The site study area is underlain by bedrock of the Stockton
Formation of Triassic age. The Stockton Formation is descriOOd by
Barksdale (1958) as consisting of light-colored, coarse-qrained, arkosic
sandstone and conglomerate; red to reddish arkosic units are the most
characteristic of the Formation, especially the lower m2mbers of the
Stockton Formation that underlie the- site. Individual layers within thQ
Stockton Formation commonly pinch out or grade into beds of different
texture or mineralogy, and rarely can be traced for any significant
distance. Sequences of beds, however, may persist for several miles.
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 planes
commonly show ripple marks, mud, cracks, raindrop impressions, cross
bedding, and pinch and well structures. The thickness of the unit ranges
from 1,000 to 5,000 f~et 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 loarns of variable thickness that form an undulating
topography of moderately low relief. Valleys are typically eroded into the
(6 )
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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 und~r the Locust Street Pile (Johnson and Schroder; 1977)
3.
Hydrology
a.
Groundwater Hydrology
Groundwater flows in the Stockton Formation through both primary
intergranular openings as well as secondary joints and faults. Flow
direction is locally quite variable and hydrologic boundaries are frequent.
In "general, regional groundwater flow is either along the strike of the
formation or down dip. To a great extent, the occurrence and movement of
groundwater 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, groundwater flow is expected to be toward Wissahickon Creek.
Shallow flow is likely to be unconfined while deeper groundwater is under
artesian or semiartesian conditions. The depth to groundwater has been
reported to be less than 5 feet in this site area.
Aquifer tests in the Stockton Formation (semiartesian deeper ground
,water) indicate that the unit is one of the best sources of ground water in
southeastern Pennsylvania. Transmissability ranges from 1,000 to 35,000
gallons per day per foot (gpd/ft) with typical values between 5,000 and
9,000 gpq/ft. The storage coefficient ranges from 0.0001 to 0.000001
indicating a range of condi tions from semiartesian 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 ~ft with a
median value of about 6 gpm;ft (Barksdale et al., 1958; R. E. Wright
Associates, Inc., 1982).
(7 )
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Water quality in the Stockton Formation is generally good but highly'
.. .
variable depending on local hydrogeologic and land use conditions: Typical
values of water quality parameters are: iron, 0.10 mg!l; manganese, 0.04
mg!l; bicarbonate, 84 mg!l; nitrate, 10 mg/1; sulfate, 24 mg!l; total
dissolved solids, 150 mg/l; 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 of 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 site is
approximately 0.4 miles east of the CertainTeed Pile. This well is 500
feet deep, and pumps roughly 100 gpn (NUS, 1983). The nearest known
. .
private (residential drinking water) well is the Burke well.
Groundwater is not expected to be a significant migration pathway
for asbestos at this si te. This is due to two factors; 1) the si te' 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 groundwater transport of asbestos
particles (Dalton, u.s. EPA, 1985).
b.
Surface Water Hydrology
There are two bodies of water in the vicinity of the site:- Stuart
Far.m Creek and Wissahickon Creek. As described previously, Stuart Far.m
Creek is a small feeder stream which flows in a south-southwest direction
to the Wissahickon. Neither of these creeks are used as a source of
drinking water.
(8 )
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The Wissahickon Creek runs along the west side of the Nicolet
property, and is approximately 300 feet from CertainTeed's site. The creek.
flows southeast at a gradient of approximately 22 feet per mile and
contributes to the Schuylkill River. A public water supply is located on
the Schuylkill approximately 12 miles downstream from the site.
Surface drainage from the CertainTeed Pile is unrestricted at
present, with the majority of runoff flowing towards either Stuart Farm
Creek or the floodplain for the Wissahickon Creek.
The flood plain of Wissahickon Creek is a groundwater 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.
Extent of Contamination
B.
1.
Contamination Problem, '
The main contaminant of concern is asbestos. The source of
contamination associated with this operable unit is the CertainTeed
Asbestos Pile. The routes of asbestos exposure are inhalation via ambient
air and ingestion which may result from the ingestion of soil or surface
water containing asbestos. Dermal contact is not an exposure route of
concern since asbestos is not likely to be absorbed through the skin.
Sampling events on and near the CertainTeed Pile site have
demonstrated that asbestos fibers may have migrated offsite from the pile
into the surrounding ambient air and adjacent surface water. At present,
the pile's plateau and slopes are covered with a layer of topsoil up to
twenty feet thick. However, broken pieces of asbestos-cement pipe are
noticeable on some areas of the pile, possibly due to slope erosion. In
addition, trees and other large vegetation have taken root along the slopes
of the pile. If this vegetation should be uprooted, a release of asbestos
to the ambient air could result.
(9 )
-------
In addition, organic and inorganic compounds were detected in the
pile and in samples from the Stuart Farm Creek both upstream and downstr~am
of the pile. The ino~ganic compounds including arsenic, chromium, cadadum,
lead, nickel, zinc and copper were found both in the pile and in upstream
~ downstre~ samples from the creek. Other potential sources for these
contaminants exist adjacent to the Stuart Far.m Creek upstream of the
. CertainTeed Pile. Consequently, the actual source or sources of these
inorganic compounds in the creek cannot be verified at present. Therefore,
a verification study will be required prior to implem2ntation of the chosen
alternative in order to better define the source of these inorganic
contaminants.
2.
Field Investigation and Analytical Program
The field investigation and analytical program was designed to
deter.mine if potential public health risks and environm2ntal impacts still
exist at the CertainTeed Pile site and if remadial action is needed in
accordance with 40 C.F.R. Section 300.68 of the NCP.
a.
Investigation Results
on August 10, 1987, !fA required that a focused Environm2ntal
Investigation (£1) be conducted at the CertainTeed Pile. In response to
this requirement, CertainTeed engaged the firm AGES, of Valley Forge,
.' PeMsylvania to conduct the focused £1.
The scope of the AGES EI included surface water, sediment and test
pit sampling and analysis (see Figure 3); construction of borings and
piez0m2ters in the waste pile; cover soil sampling and analysis; OSHA
mandated parsoMel air sampling; and preparation of a report summarizing
the results of the field and analytical program. The inorganic sample
results are presented in Tables 1, 2 and 3.
A summary of the results from the field investigation conducted by
AGES is presented below:
(10)
-------
"
, ,
,
-'. "--'-"-'----'---.
"- -, - - - -. - """
--~ ---
t
,
,
, .
, '.
, \\
'\,'"
"" .,
'\ ~...
, " ,
" \ \
. ,
, "
\ "
\ '
-~
Stuart Fan. Creek
. ,
'. "',
'.1t\
'.' "'-
'. """-....
",.C--<\
',::---,) \.
" '-, \
Not to Scale
" "
"
FIGURE
3
SAMPLE LOCATION HAP
-------
TABLE 1
It«)RGANIC DATA SUMMARY 'TABLE
FOR 5mIMENr SAMPLES OF
5'lUART FARM CREEK
SAMPLE LOCATIOO 5-1 5-2 5-3 5-4 5-4 5-5
Duplicate
DATE COLLECTED 8/2/88 1/25/88 1/25/88 1/25/88 1/25/88 8/2/88
CONCENTRATIOO PIlI ppn ppn ppn ppn ppn
UNIT
ASBESroS* 2-3 4-6 ND 2-3 3-5 3-5
ARSENIC 5.1 ND 1.1 ND ND 9.3
CADMIUM 1.0 1.1(8) ND .19(8) ND 2.3
CHROMIUM 1.4 ND 14.4 36.4 19.5 24.1
COPPER 10.8 41.1 12.0 82.1 15.9 21.9
LEAD 50.0 64.1 6.0 ND 11.1 36.6
NICKEL 5.8(8) 20.6 13..0 21.0 11.5 18.6
ZINC 161 289 31.6 201 148 146
NOTES: * Concentration given in total percentage by volume.
ND = Not detected.
B = Analyte was found in blank as well as in sample.
-------
TABLE 2
IOORGANIC MTA SUMMARY TABLE
FOR SURFACE WATER SAMPLES OF
S'lUART FARM CREEK
SAMPLE LOCATIOO 5-1 5-2 5-3 5-4 5-4 5-5 BLANK BLANK
Duplicate
DATE COLLECTED 8/2/88 7/25/88 7/25/88 7/25/88 7/25/88 7/25/88 7/25/88 8/2/88.
COOCENTRATIOO ppb ppb ppb ppb ppb ppb ppb ppb
UNIT
ASBESTOS. NO ND NO .0421 ND .0421
,
ARSENIC NO ND ND ND ND ND ND NO
CADMIUM 8.6 ND NO ND ND ND ND 5.3
CHROMIUM 19.2 ND 17.7 ND ND 7.3(B) ND NO
COPPER 47.3 ND 112 10.4(B) ND 39.0 ND 27.2
LEAD 21.9 29.5 12.8 23.0 7.7 ND ND 48.6
NICKEL 17.8(B) ND 76.5 ND ND 49.0 ND 13 (B)
ZINC 130 61.8 3630 85 174 51.1 ND 80
00l'ES: * Concentration given in million fibers per liter (MFL).
ND ~ Not detected.
B ~ Analyte was found in blank as well as in sample.
-------
TABLE 3
DATA SUMMARY TABLE FOR
TEST PIT SAMPLES OF
THE CERTAINTEED PILE
SAMPLE .LOCATIOO TP-1 TP-2 TP-3 TP-4 TP-5 OBSERVED
DATE COLLECTED 8/4/88 8/4/88 8/4/88 8/4/88 8/4/88 RANGE 1
COOCENTRATIOO ppD ppn ppn AD ppD (ppn) .
UNIT
ASBESroS* 3 11 2 4 .2
ARSE2H C 13.3 49.9 42.7 1770 43.0 0.1-73
CADMIUM ND 1.4 ND ND .72(B)
CHRa1IUM 215 83.6 108 88.1 61.1 1-1000
COPPER 29.2 27.0 75.4 24.9 27.3 1-700
LEAD 18.7 31.2 53.1 43.7 37.5 <10-300
NICKEL 535 137 174 168 89.4 <5-700
ZINC 80.7 99.4 102 94.2 82.8 <5-2900
EP roXICITY
ARSENI C .17 .19
BARIUM .05 .09
NOTES: * Concentration given in percentage by weight.
ND >2 Not detected.
B = Analyte was found in blank as well as in sample.
1 = Shacklette (1984); Element concentrations in soils, Contermdnous
United States. These concentrations represent ranges within the
Eastern u.s.
-------
o
Concentrations of co~per (112 ppb), zinc (3,630 ppb), and nickel
(76.5 ppb), detected in a surface water sample taken from 5tuart
Fa~ Creek adjacent to the CertainTeed Pile (5-3), were all above
upstream concentrations (47 ppb, 130 ppb, and "not detectable",
respectively) .
o
The upstream and downstream sediment samples exhibited heaVy metal
concentrations of similar magnitude.
-0 A test pit sample yielded a high concentration of arsenic (1,770
pPm). The remaining levels of heavy metals within the test pit were
within the observed range for soils in the eastern U.5. No
background soil samples were analyzed during this investigation.
Two samples exhibi ting elevated heavy metal concentrations were
analyzed using the Extraction Procedure (EP) TOxicity test. The
results were below the regulatory limits defining a waste as
hazardous under RCRA, listed in 40 CFR 261.24.
o Asbestos was detected using the transmission electron microscopy
(TEM) in the two downstream surface water samples (5-4 and 5-5), at
a concentration of .0421 MFL. A duplicate sample was collected at
location 5-4. Asbestos was not detected in the duplicate. Asbestos
was also not detected in the upstream samples. (The detection limit
for this analytical procedure was .0421 MFL.)
o Asbestos was detected using the polarized light microscopy (PUt)
analytical procedure in both upstream and downstream sediment
samples at concentrations ranging from 2 to 6 percent by volume.
o Asbestos was detected using TEM, in all of the test pit samples at
concentrations ranging from 0.2 to 11 percent by weight.
o Exposed areas of the pile were identified on the northern most
portion of the western side slope and along the toe of the southern
side slope. Portions of the pile and side slopes have experienced
extensive tree growth.
(11 )
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o
A portion of the southeast slope of the CertainTeed Pile is located
within the floodplain of stuart Fa~ Creek.
o Cover soil on both the piles slopes and plateau consist primarily of
a silty or clayey sand.
o No perched or shallow groundwater was detected in any of the three
piezometers installed in the pile.
o '!be cover soil on the plateau portion of the pile ranges in
thickness from 1 to 20 feet. '!be angle of the side slopes averages
40% (2.5H: 1.0 V).
b.
Conclusions from the Investigation
'!be analysis for asbestos fibers in ambient air during the test pit
and test boring investigations indicate that any gross
disturbance of the in-place materials will likely cause a significant
degradation of the ambient air quality. In addition, these conclusions are
presented:
o The potential of onsite sources of heavy metals and the consequent
risk to the environment should be further investigated.
o
Surface water samples suggest that the CertainTeed Pile is a
potential source of asbestos.
o The location of the pile within the floodplain of Stuart
poses a potential risk of increased releases of asbestos
surface waters if flood conditions occur.
Farm Creek
into area
o Asbestos detected in both upstream and downstream sediment samples
indicate both offsite and onsite sources.
(12)
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o Potential asbestos inhalation exposures also exist if a person or
persons are playing on or near exposed areas and asbestos containing
material is disturbed.
o The potential of
expos~ areas of
asbestos.
inhalation exposure of asbestos does exist if
the pile are disturbed resulting in entrainment of
o Extensi ve tree growth along the south slope has hindered the
establishment of low lying veqetation, which is necessary in
controlling erosion along the slopes.
o Historical photos indicate that surface water ponding is occurring
on the plateau area of the pile. Excessive infiltration of
rainwater into the pile must be controlled via stormwater drainage
and collection methods.
C.
Statement of Findings Regarding Wetlands
Based on a Wetland Delineation, EPA has determined that wetlands
occur adjacent to this site along Stuart Farm Creek and within the
Wissahickon Creek flood plain.
The Stuart Farm Creek Wetlands occupy an approximately 10-15 foot
wide band along Stuart Farm Creek at the southern foot of the CertainTeed
Pile. Dominant vegetation is forested and includes sycamore, box elder and
. willow. Soils are the Hydric Bowmansville silt loam and the hydrology is
provided by both surface runoff and a high groundwater table. This wetland
system joins the Wissahickon Creek flood plain, a large wooded flood plain
with inclusions of jurisdictional wetlands along the stream courses.
During site investigations, levels of inorganic contaminants were
detected in Stuart Farm Creek above Federal Ambient Water Quality Criteria
(Quality Criteria for Water 1986; 51 Fed. Reg. 43665; u.s. EPA, 1986).
These contaminants may pose a potential threat to the environment. Other
potential sources of these contaminants exist adjacent to the Stuart Farm
(13 )
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Creek upstream of the site. Consequently, a verification study will be
performed prior to implementation of the selected remedy to determdne the'
source of stream contaminatlon. Depending on the results of this study, .
further remedial activity associated with the Stuart Farm Creek may be
required.
Regardless of the results of the verification study, the selected
remedy to contain the asbestos waste pile will also serve to contain any
inorganic contaminants within the pile. Since the pile is located within
the flood plain of Stuart Farm Creek, erosion control devices will be
installed upland of the existing wetland to protect the toe of the pile.
This action will serve to minimize potential harm and adverse effects to
the ~tlands in accordance with Executive Order 11990 (Protection of
wetlands) found at 40 C.F.R. Part 6 Appendix A.
v.
Summary of Site Risks
The EndanqerD12nt Assessment (FA) addresses the potential human
health and environmental impacts associated with the CertainTeed Pile site
under the no-action alternative, that is, in the absence of rem2dial
corrective action.
The results of sampling performed during the investigations, in
soil, surface water, sediment, and air were reviewed to identify chemicals
to be evaluated in this FA. 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 si te..
The contaminant of concern at the CertainTeed Pile is asbestos; in
particular, the potential for asbestos to be released to the ambient air.
Asbestos is a recognized human carcinogen, causing lung cancer and
mesothelioma, a form of neoplasm of the lining of the thoracic and
abdominal cavities, in workers exposed by inhalation. The association
between asbestos exposure by inhalation and lung cancer was first reported
in 1935.
(14 )
-------
There is also evidence that oral exposure of humans to asbestos may
be associated with an increased incidence of cancer of the gastrointestin~l.
tract. Exposures have been. through drinking contaminated water, either.
from contact with asbestos deposits or transmission through
asbestos-containing cement water mains. The evidence is considered
equivocal at this time.
Long-term exposure to asbestos fibers and contaminated dust also
causes asbestosis, a progressive and irreversible lung disease
characterized by diffuse interstitial fibrosis. Symptoms include shortness
of breath, cough rales, clubbing of the fingers, and weight loss.
Pulmonary changes occur more rapidly in more severely exposed individuals.
Groundwater 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 groundwater transport of asbestos
particles (Dalton, u.S. EPA, 1985).
The surface water pathway for asbestos exposure is also of little
concern since neither the Stuart Farm or Wissahickon Creeks are sources of
drinking water. In addition, existing studies and evidence regarding the
toxicity potential of asbestos to aquatic life is limited.
Other reported contamination in the pile is of little or no
consequence because of low reported levels or because of their presence in
deep areas of the pile. In addition, the inorganic contaminants detected
in the pile are not likely to be mobile based on the reported results of
the EP toxicity test and the expected high pH of the waste material. Some
of the inorganic concentrations detected in surface water and sediments of
the Stuart Farm Creek are above Ambient Water Quality Criteria and
therefore are of potential concern to aquatic life. However, pending the
(15)
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results of the source verification study, these contaminants cannot be
definitely attributed to the site, and therefore were not evaluated further
for the purpose of this EA.
A.
Exposure Assessment
1.
Routes of Exposure
There are two general routes through which individuals may be
expo'sed to contaminants at the CertainTeed Pile: inhalation and ingestion.
Darmal contact and subsequent absorption of asbestos is not an exposure
route of concern since asbestos is not likely to be absorbed through the
skin.
For the inhalation pathway, individuals may breathe asb2stos fib2rs
which are present in ambient air and asbestos fibers which are present due
to spacific activities which stir up fibers. Although fenced, the site is
accessible to trespassers (e.g., children riding bikes, playing on piles
etc.). Activity on site may entrain asbestos fibers into the ambient air.
Trees which have grown on the pile's slopes and plateau may overturn
potentially exposing asbestos contaminated soil to the environment. The
proliferation of trees onsite has also served to reduce lowlying vegetation
(grass, weeds, etc.). Without this vegetation, potential for soil erosion
.. is increased and contaminated soil may become exposed. In addition,
several areas of the pile have pieces of piping and other asbestos-related
material exposed to the ambient air. Entrainment of asbestos fibers may
occur via wind or physical disturbance of these exposed areas.
Ingestion exposure may occur as a result of ingestion of soil
containing asbestos. Indirect ingestion of asbestos which has been inhaled
is another fonn of ingestion exposure. Individuals may directly contact
and inadvertently ingest contaminants present in soil on the pile which may
adhere to hands, toys, tools, etc.
(16)
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2.
Potential Receptors
There are a number of potential receptors within the vicinity of the
site. The nearest residence is approximately 300 feet east of the
CertainTeed Pile. In addition, an estimated 6,000 people live within a
half-mile of the site.
Finally, the metal fabricating and wastewater treatment facilities
are located to the east and southeast of the site, while the Central
Business District of Ambler is located approximately one-half mile north of
the site.
B.
Focused Risk Assessment
The primary hazard associated with the CertainTeed Pile is the
potential for contact with asbesto~ contamdnated media.
Risks from the pathways of inhalation and ingestion were
characterized by first comparing concentrations of chemicals in the sampled
environmental media to Applicable or Relevant and Appropriate Requirements
(ARARs) identified for the site. For asbestos, based on the comparison to
the chemical-specific ARARs listed in Section IX, it was concluded that
under present conditions the criteria related to air quality is not
currently being exceeded. In the future, however, increased erosion and
,weathering of the piles could increase the potential exceeding the
regulatory limits. In addition, these limits would likely be exceeded if
the site were disturbed by vehicular activities. Such activities would
most likely occur as part of a remedial action involving excavation and
removal of the soil from the site. These activities could elevate
concentrations of asbestos within local surface waters.
It was concluded that potential releases of asbestos to ambient air
from the CertainTeed 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.
(17 )
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Potential asbestos inhalation exposures during specific types of
activities that can stir up asbestos fibers, such as children playing in
soil on the pile, were also qualitatively evaluated. under present site
use conditions, activities that could stir up asbestos fibers include
. . .
playing and biking on the pile by children or other trespassers. It was
. concluded that these and other activities could continue to occur in the
absence of site remcliation (Le., under the no-action alternative). Among
subpopulations who may repeatedly engage in these types of activities,
cumul.tive asbestos exposures of concern to human health could potentially
resu! t. Gi ven the above, the si te thus presents an imminent and
substantial endanger.ment to public health as set forth in Section 106 of
CERCLA, 42 U.S.C. Section 9606.
VI.
Rem2dial Action Objectives
Rem2dial action objectives consist of medi~specific or oparable
unit-specific goals for protecting human health and the environm2nt.
Re~ial action objectives aimed at protecting human health and the
environmsnt should specify:
The contaminant(s) of concern
Exposure route(s) and receptor(s)
An acceptable contaminant level or range of levels for each
exposures route (1. e., a preliminary remadiation goal)
The overall objective of the remedial action program for the
CertainTeed Pile is to remcliate the sources and/or pathways for migration
of asbastos, which ware identified through the AGES EI report, and the EI
review. This action is required so that potential present and future
exposures will be within acceptable limits and, that site related ARARs are
met. In addition, the development of remedial action objectives for the
CertainTeed Pile should be consistent with those objectives outlined for
operable unit number one.
The specific remedial action objectives that have been developed for
this site are as follows:
(18)
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VII.
o
Effectively restrict access to unauthorized persons. These
persons would consist primarily of trespassers, mostly children
who have frequently accessed the site, based on historical
reports. This objective would no longer be relevant, however,
should a complete removal action be implemented.
o
Effectively remove, stabilize, or contain the asbestos
contandnated media onsite so that potential direct
contact/incidental ingestion exposures to onsite receptors are
minimized, and potential releases of asbestos to ambient air and
potential releases of asbestos to adjacent surface waters are
not prevalent in concentrations which would create unacceptable
risks to on and offsite receptors.
Description of Alternatives
This section summarizes the candidate remedial action alternatives.
These alternatives have been developed based on the following
considerations:
o
Those technologies outlined, defined as applicable to the
CertainTeed Pile site.
o
Technologies that are complementary or interrelated were
combined into alternatives. For example, one remedial
alternative - excavation/offsite disposal combines the
technologies of complete removal, surface water
management/erosion controls and offsite disposal.
o
The alternatives were developed to address the remedial action
objectives established for the site. However, not all of the
alternatives developed and evaluated will equally satisfy the
objectives or be as effective in addressing part or all of the
site issues and contaminant pathways.
(19)
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o
The alternative development process should cover a range of
remediation levels. These categories include:
1) No action: A no action alternative may include minimal
actions such as installation of fences/gates and monitoring
activities.
2) Treatment alternatives ranging from one that would eliminate
or minimize, to the extent feasible, the need for long-term
JDanagemgnt (including monitoring) at a site, to one that would
use treatment as a primary component of an alternative to
address the principal threats at the site.
3) Alternatives which involve contairut\2nt of waste with little or
no treatment, but provides protection of human health and the
envirorut\2nt by preventing potential exposure and/or by
reducing mobility.
wi th respect to the CertainTeed Pile, the remdial action
technologies that remained after screening were generally under the source
control classification, since onsite controls are the most appropriate to
this site.
A. Alternative 1:
and Monitoring
No Action with Securi ty Improvements
The purpose of evaluating the 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 rem2diation work to the pile. Security improvements consisting of
new fencing, access/egress gates (with locks), and appropriate warning and
informational signs are included in this alternative. These improvements
would be designed to meet the current EPA, NESHAPS, and PADER regulations
regarding closed solid waste (asbestos-containing) landfills.
(20)
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In addition, visual inspections and environmental ambient air
monitoring 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 undertaken under
this alternative.
Capital costs associated with this alternative include fencing to
complete. site enclosure, installation of gates and locks, and warning signs
on the fences. The total capital cost for Alternative 1 is estimated at
$23,000.
Operating and Maintenance (O&M) costs are estimated at $21,000;year.
'!hese costs are incurred during long-term meni toring for asbestos and
maintenance of the facility.
AssUDdng an annual interest rate of 10%, the present worth costs for
this alternative over a 30-year period is approximately $222,000.
B. Alternative 2:
ExcavationjRemoval - Offsite Disposal
'!his alternative consists of complete excavation and removal of the
CertainTeed Pile waste materials to an offsite permdtted;approved landfill.
The major components of this alternative include:
o
Complete excavation of the waste materials, Level C activity for
approximately an estimated 50 percent of the time, spe~ial
precautions adjacent to Stuart Fa~ Creek to address surface
water runoff.
o
Diversion of runon and construction of runoff containment/
treatment facilities during excavation.
\
o
Continuous air and surface water monitoring.
(21)
-------
o
Transport equipment decontamination prior to site egress.
o
Soil testing for verification of cleanup criteria.
o
Hauling of clean soil fill to site and filling/regrading the
site for positive drainage.
o
Revegetation and establishmsnt of stormwater manageJn2nt
controls.
It' is estimated that the pile contains approximately 110,000 cubic
yards of asbestos related waste materials, and is covered by approximately
22,000 cubic yards of vegetated soils.
A detailed reJt12dial design with soil stability analyses would need
to be prepared in order to perform this ,alternative safely due to the
potentially unstable physical conditions of the interior of the pile. 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 following
excavation into the pile. Also, it would have to be determined where these
wastes would and/or could be taken for relandfilling due to the quantity
involved.
The capital cost for Alternative 2 is estimated at $27,980,000.
Operating and maintenance (O&M) costs are estimated at $38,300 per year
during re~ial activities (approximately 2 years) and $10,400 per year
following rem2diation. Post-remediation costs involve monitoring
activities to verify effective cleanup (e.g., water and soil analysis, site
maintenance) .
Assumdng an annual interest rate of 10% and a post-remediation
timeframe of 30 years, the present worth cost of this alternative would be
approximately $28,145,000.
(22)
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C. Alternative 3:
onsite Vitrification via Processing Plant
This alternative would involve further pilot-scale development and
analysis, and potential future construction of a full-scale vitrification
'plant onsi te..
Vitrification is a process wherein asbestos-contamdnated materials
can be transfo~ by melting (at extremely high temperatures (1,3000r))
into a nontoxic glass-like material. This process differs from the
technology referred to typically as "in situ vitrification", which melts
the contamdnated material in-place using high charges of electricity
transfers to the material through probes driven into the contandnated
material. Consequently, this process requires excavation of the
asbestos-contaminated material, transferring the material to the treatment
facility, and feeding the material into the furnace structure.
In simplified for.m, the major components and sequence of
construction for this alternative are as follows:
o
Research, test, analyze, and further develop the potential
vitrification technology 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" onsite the
waste materials at this site (treatability studies).
o
Construct a full-scale onsite facility. Many significant
feasibility variables such as location and space requirements;
electric and other utility services; financial and liability
agreements; environmental emissions and discharge limitations;
health and safety protocols; etc., would need to be worked out
prior to start of construction. Electric power consumption
requirements for the vitrification plant, 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
(23)
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substation would likely need to be constructed on or near the .
site, or substantial revisions to existing facilities and major
service lines run to the site.
o
Excavate, haul, and stockpile waste materials from the pile in a
sequenced manner (over a nlDllbar of years) in order to provide
the feed material to the plant. Site preparation (runon
diversion, runoff control, haul roads, etc.) sindlar to those
previously described under Alternative 2 - Excavation and
. Removal, would need to ba employed first. Substantial soil
excavation and health and safety concerns (releases of
contaminants to ambient ai r or surface water) would need to ba
addressed first, as previously discussed.
o
A "set-aside area" would have to ba constructed to deal with
large and/or foreign materials that could not ba fed into tho
plant. These materials would likely require landfilling eithor
on or offsite.
o
Extensive environmental and personnel monitoring for workers and
offsite receptors would ba required in order to quantify
potential releases and the impacts on the local ambient air.
Even with requi red wetting and other dust/fiber suppression
controls, unacceptable releases may occur as a result of
excavation and process activities may require the construction
of an enclosed work area. Even with this type of system,
exhaust and endssions are imndnent.
o
The process would most likely require substantial modi~ications
and/or additions as the project continued in order to deal with
new data and the waste materials types/consistencies encountered
during excavation.
o
Assuming that the estimated 132,000 cubic yards could be
processed and/or segregated (and portions landfilled), it is not
currently known what couldjwould be done with the final product.
(24)
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There may be certain potential useful purposes for the final
product materials (i.e., roadbase materials, structural fill,
landfill intermediate cover, etc.), however, no current reuses
of these materials on a large-scale have been documented; not to
mention post-reuse monitoring/evaluation 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 landfilled, either back onsite in the
form of a "new pile" or transported offsi te to an approved
location for filling.
o
At the completion of processing operations the plant would need
to be dismantled and removed unless a continued use for it could
be found.
o
The site would be backfilled and regraded for positive drainage,
and revegetated. If materials are redeposited onsite, the
material would be covered 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 vitrification
process. Space constraints and slope requi rements may limi t
onsite redisposal.
The preliminary capital cost of Al ternati ve 3: Onsi te
Vitrification, is estimated at $17,257,000. Operation and maintenance
(O&M) costs are estimated as follows: $5,948,000 per year during remedial
activity, and $21,000 per year the 30 years following remediation. It is
assumed that, using the vitrification treatment process, it will take
approximately 7 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. The total present worth cost of this alternative, assuming a
10% interest rate, is $46,412,000.
(25)
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D.
Al ternati ve 4:
onsite Closure
. .
Alternative 4 involves placement of a cover system on the CertainTeed Pile.
The major components' of this alternative involve the following:
o
Removal of large vegetation, installation of stormwater/sediment
control devices, and regrading plateau, where necessary, to
assure proper drainage and cover thickness (a minimum of two
feet of clean, compacted fill).
o
Repair of any erosion or exposed areas on ~ste pile side slopes
with a geotextile liner and low erosion/low perm2ability soil
cover. Soil cover on slopes should also achieve a minimum two
foot thickness of clean, compacted fill.
o
Installation of erosion control devices for protection of the
southeast slope from the potential scouring action of Stuart
Farm Creek.
o
Revegetating site, where required, and installing erosion;
sedimentation controls during remedial activities until
vegetation establishes.
o
Performance of a verification study to determdne source of
inorganics in Stuart Farm Creek.
o
Air and surface water monitoring for asbestos during remedial
activities .(personnel and environmental).
o
Post-closure inspections, maintenance of the pile, and
preparation of a contingency plan.
o
Restricting future land use to surficial activities by
authorized personnel.
Initial remedial action performed during the 1970's involved the
placing of clean fill across the plateau and slopes of the pile. Borings
of the plateau and slopes have indicated an existing cover thickness
ranging from two to twenty feet. Since this time, substantial vegetation
(26)
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growth (e.g., trees, bushes, grasses, etc.) has been established across tne
entire site. Therefore, initial preparation of the site would involve
removing trees and large shrubs to pile level and regrading the plateau and
slopes, where necessary, to assure proper drainage and a consistent cover
of compacted soil. Geotextile material would be placed over exposed areas
of the plateau and slope, followed by a layer of low-permeability topsoil
and vegetated cover.
In addition, erosion control devices will be installed on the bottom
part of the slope adjacent to Stuart ra~ Creek to control against
potential erosion or scouring of the pile.
Security at the site would be increased with improvements to the
existing fencing onsite and installation of additional fencing to assure
the site is completely fenced in. Locking gates would also be provided for
access to authorized persons in the future. Warning signs would be posted
on the fence, related to asbestos hazards onsite.
Inspections of the site would occur biannually for the first five
years after remediation. A written report that details the effectiveness
of remediation would be submitted at the end of every five years (as
required by Section 121(c) of CERCLA, 42 U.S.C. Section 9621). Annual
inspections of the site will be required after the first five years to
ensure that human health and the environment are being adequately
. . protected. If the potential for asbestos release is noted during
inspection, air monitoring will be performed to elevate ambient asbestos
levels in air. Long-te~ cap maintenance such as local erosion repair,
grading, seeding, etc., is required to promote cap integrity over the
long-term.
During onsite activities, erosion and sedimentation controls such as
channels, silt fences, and jute-netting 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.
(27)
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The capital cost of Alternative 4 is estimated at $579,000.
Operating and maintenance (O&M) costs, including post-treatment monitoring
and maintenance, are estimated to be $21,700 per year during the first five
years and $10,200 per year following that. Assuming a 10% interest rate
and post-remsdiation monitoring time of 30 years, the present worth cost of
the alternative is estimated to be $753,000. 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 serve to ensure cap integrity and to detect any asbestos
migration from the contained areas.
VIII. Comparative Analysis of Alternatives
This section summarizes the comparative analysis of alternatives
performed in the FFS. As outlined in the EPA RI/FS Guidance Manual -
Interim Final (October, 1988) nine evaluation criteria have been developed
to address CERCLA requirements and technical and policy considerations
which have proven to be important for selecting a remedial alternative (see
also the NCP at 40 CFR Section 300.68 (h)). The nine criteria are
summarized below:
o Compliance with ARARs
o Overall protection of human health and the environment
o Short-term effectiveness
o Long-term effectiveness and permanence
o Reduction of toxicity, mobility or volume
o Implementability
o Cost
o State acceptance
o Community acceptance
Each alternative is evaluated below with respect to these nine
criteria.
(28)
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No Action Alternative
Although this alternative would be easily implemented at minimal
capital and O&M costs, it has serious shortcomings. A No Action
alternative would not comply with the CERCLA Section 121 objective to
reduce volume, mobility, or toxicity of the waste. In addition, this
alternative does not meet the remedial action objectives for the site which
require the alternative to minimize the potential for direct contact or
incidental ingestion of asbestos from the site. Therefore, the criterion
addressing the overall protection of human health and the environment would
not be met. In addition, employing a no-action alternative will provide
neither short or long-term effectiveness since neither the source or the
pathways of risk would be reduced or eliminated. Finally, this alternative
will not meet any ARMs in the long term. As a result, it is anticipated
that both state and community acceptance of this alternative would be
unfavorable.
ExcavationjRemoval with Offsite Disposal
The alternative of excavating and removing the waste to an offsite
disposal source would provide excellent results with respect to the
criterion of long-term effectiveness. In addition, over the long-term, the
criteria of reduction of toxicity, mobility, or volume and protection of
human health/environment would also be satisfied since the source of the
.. asbestos would be permanently removed. However, these two criteria would
not be met with respect to short-term effectiveness, since the potential
for release of asbestos to the ambient air and surface water would be quite
high during the excavation and removal period (estimated to last 10
months). As a result, on a short-term basis, compliance with all chemical
and location-specific ARARs would not be satisfied (except for the PADER
requirement for a flood plain and stream encroachment permit). Finally,
the implementation and cost of this alternative would be excessive (8
hrs/day - 5 days/Week for 18 months at a total project cost of nearly
$23,000,000).
(29)
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Onsite Vitrification
The results of the evaluation of this alternative are similar to
those presented for the excavation/removal alternatives. The reduction of
t'oxi city/mobility or volume and protection of human/environmental health
would be satisfied on a long-term basis. However, these two criteria on a
short-term basis would not be met. The same concerns noted above are also
present with respect to short-term compliance of the ARARs criteria.
Finally, the implementation and total cost of this alternative are
very unfavorable with the project lasting approximately 7 years (including
treatability, and pilot studies, and site closeout) and costing
approximately $46,000,000.
Onsite Closure
Onsite closure via capping with a low permeability cover and
vegetation employs a proven technology which can be readily implemented.
Although it would not reduce the volume of material onsite, capping the
site would significantly reduce the potential for asbestos and inorganic
material to be released to the ambient air and surface water by containing
the pile within a semi-permeable cover. The short-term effectiveness of
this alternative would be very favorable since remedial activity would be
performed with limited disturbance to the waste material. Long-term
effectiveness would also be met via a maintenance and monitoring program.
All Federal chemical specific ARARS are expected to be met even on the
short-term since no intrusive work would occur during capping construction.
State ARARfi involving landfill cover requirements would also be addressed.
Finally, the time-frame of implementation and project costs are very
favorable (approximately 11-13 months and $750,000 respectively).
(30)
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IX.
The Selected Remedy
Section 121 of CERCLA establishes cleanup standards for the site'
remediation and articulates a preference for remedial actions in which
treatment per.manently and significantly reduces the volume, toxicity, or
~bility of site contaminants. The provision notes that offsite transport
.and disposal of hazardous substances without such treatment is least
favored where practicable 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
per.manent solutions and alternative treatment technologies or resource
recOvery techniques to the maximum extent practicable."
EPA has reviewed and considered these statutory provisions and the
r~gulations contained in the National Contingency Plan, 40 CF.R Section 300,
in light of the conditions present at the CertainTeed Site and concludes
that Alternative 4 - onsite Closure is the most consistent with these
requirements. This remediation alternative offers the best combination of
effectiveness, implementabi1ity, and cost efficiency and involves the use
of what can be considered the most feasible remedy under CERCLA for
asbestos. This alternative meets all Federal ARARS and all but one
State-related ARAR (slope requirement) for which a waiver is appropriate
under Section 121(d)(4) of CERCLA, 42 U.S.C. Section 9621(d)(4). In
addition, the proposed cover design is consistent with other EPA and state
agency designs that have been proposed and/or approved.
The majority of the site is presently covered with clean fill up to
twenty feet in some areas. In addition, substantial vegetation is present
across the entire site. Therefore, for those areas of the pile which
exhibit acceptable cover depth, vegetation and drainage patterns no further
work will be required to have them conform to the selected remed~al action.
Because this remedy will result in hazardous substances remaining
onsite, five year reviews, as specified 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
(31)
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conducted bi-annually for the first five years after initiation of remedial
action and yearly thereafter.
X. Statutory Determinations
EPA's primary responsibility at Superfund site is to undertake
remedial actions that achieve adequate protection of human health and the
environment. In addition, section 121 of CERCXA establishes several other
statutory requirements and preferences. These include compliance with
applicable or relevant and appropriate environmental standards established
under Federal and State environmental laws unless a statutory waiver is
justified. The selected remedy also must bs cost-effective and utilize
permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections
discuss how the selected remedy meets these statutory requirenents.
A. Protection of Human Health and the Environment
The selected remedy will contain the asbestos contamination at the
site, which will ensure adequate protection of human health and the
environment. This action can be expected to result in significant
long-term reduction of potential public health risks and environmental
impacts resulting from the direct contact and migration of asbestos fibers
via sediment, surface water, and air transport mechanisms, while
minimizing short-term risks to onsite workers and the environment that are
likely with other alternatives.
B. Cost-Effectiveness
The selected remedy is the most cost-effective alternative that can
provide adequate short and long-term protection of human health and the
envi ronment.
(32)
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C.
Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy of onsite closure will effectively attain all
applicable or relevant and appropriate requirements (ARARs) except the
~ction-speci~ic State ARAR noted below.
A summary of the existinq asbestos requlatory liDdts or qoals is
presented in C .1. below. Most of the requlatory effort to date has been
focused on oCCUPational exposures in industrial and educational settinqs.
The development of quidelines for the qeneral population has moved less
rapidly due to the complexity of samplinq, analyzinq and interpretinq
asbestos concentrations in ambient air. The existinq requlations and
occupational health studies can however be used as a quideline in
evaluatinq the quality of ambient air and water at the Ambler site.
The Rev. requlation for cap desiqn is not an applicable requirement
for this site, because asbestos is not a hazardous waste. EPA has further
deterDdned that Rev. cap desiqn requirements are not relevant or
appropriate requirements for this site, for reasons set forth below.
A multi-layered cap qenerally conforms to the Rev. technoloqy
quidelines found under 40 CFR Section 264, which recOllll\end a three-layered
system consistinq of an upper veqetative layer over a low permeability
layer. The cap functions by divertinq infiltratinq liquids from the
. veqetative layer throuqh the drainaqe layer and away from the underlyinq
waste materials. The primary function of a Rev. cap is to control
infiltration and leachate from the waste material that may contaminate
underlyinq qroundwater. A multilayered cap is typically used for hazardous
waste site closures, which this site is not (based on the data collected).
Accordinqly, the desiqn of the cap need not be in accordance with
RCRA requlations 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
(33)
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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
protective to use innovative cap designs at this site consisting of semi-
permeable materials.
(34)
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1. Chemical/Contaminant-Specific ARARs
REGULATICJi
LIMIT/STANDARD
40 CFR 61.153 (Clean Air Act)
Specifies standards for
inactive asbestos waste
disposal sites.
40 CFR 763 (Toxic Substances Control Act)
Subpart G
2 fibers per cubic centimeter
(f/cc) by phase contrast
microscopy (POt) (8-hr time
weighted average) for asbestos
abatement worker exposure.
Subpart E
0.02 f/cc' by TEM performance
standard for the remediation in
schools.
29 CFR 1910.120 or 54 FR 9294
(Occupational Health and Safety Act)
Health and safety standards for
emplOYees engaged in hazardous
waste operations.
29 CFR 1910
and
29 CFR 1926 (Occupational Health and
Safety Act)
0.2 f/cc by PCM (8-h time
weighted average) for
industrial and construction
worker exposure.
(35)
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2. Action-Specific ARARs
a. A Discharg~ Permit from the PeMsylvania Department of
Envirol'1m2ntal Resources (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.
b. The Montgomery County Conservation District requires
erosion control plan be written and implemented for construction
activities. This plan must be available for review onsite.
that a soil
c. Asbestos is a solid waste as defined under PeMsylvania's
Managemnt Act, of July 7, 1980, Act No. 1980-97, 35 P.S. Section 691.1 et
!!!C. Disposal of asbestos and asbestos containing waste at an lU1p2rmi tted
facility in PeMsylvania is unlawful. Permitted facilities must c03lply
with the Dapartm2nt's rules and. regulations governing solid waste
management facilities. The Commonwealth consistently requires that
asbestos and asbestos containing wastes be disposed at permitted solid
waste managemnt facilities subject to the above Act and the Department's
rules and regulations governing solid waste management facilities.
Relevant and appropriate requirements related to slope design,
vegetative cover, and surface water control are found in 25 PA Section 273.
However, the requirement of a I-foot clay cap and drainage layer found
..under 25 PA 273.234 is not an appropriate and relevant requirement. The
use of a low permeability clay cap is not appropriate for the same reasons
that a RCRA cap is not appropriate for the CertainTeed Pile site.
Semipermeable cover material provides more effective protection from
potential airborne releases of asbestos by maintaining some moisture
content in the waste material.
25 PA 273.234 requires that the
may not exceed a grade of 33 percent. The
CertainTeed Pile average 40 percent grade.
for modification of the slopes, therefore,
final slopes of a landfill cover
angle of the side slopes of the
Alternative 4 does not provide
this ARAR will not be attained.
(36)
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Section 121(d)(4) of CERCLA, 42 U.S.C. Section 9621 (d)(4), identifies
several circumstances under which certain ARARs may be waived. Two of the
permissible circumstances are listed below with an explanation of how they
apply to the selected remedy.
- Compliance with this ARAR will result in a greater risk to
human health and the environment than alternative options
(See Section 121(d)(4)(B). In order to achieve a side slope
that does not exceed a 33 percent grade for the waste pile,
extensive regrading would be required if the toes of the pile
were to remain in their present position. '111is would mean
cutting into the asbestos waste and exposing the asbestos
contaminants below. Such action would pose a serious risk to
human health and the environment because asbestos fibers
would likely become airborne from the disruption.
- Compliance with this ARM is technically impracticable from
an engineering perspective (See Section 121~
Construction would be a major concern. '!be angle of the side.
slopes could be lessened to close to 33 percent by holding
the top of the slope constant and placing a soil wedge
(thereby expanding the "footprint" of the piles at the bottom
of the slopes). However, this could not be performed wi thout
encroaching on existing structures, including Stuart Fa~
Creek, the Sewer Authority collection system, and potentially
the railway tracks.
3.
Location-Specific ARMs
'!be location-specific ARMs for the CertainTeed Pile basically
involve consideration of the Stuart Farm Creek flood plain and accompanying
wetlands. As shown in Figure 2, the southeastern slope of the CertainTeed
Pile abuts Stuart Farm Creek.
(37)
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o
Executive Order 11988 (Floodplain Management) and Executive
Order 11990 (Protection of Wetlands) found at 40 CFR Part 6,
Appendix A 'require that actions be taken to avoid adverse
effects, minimize potential harm, and restore and preserve
na~ural and beneficial values of wetlands and floodplains.
o
A Flood Plain/Stream Encroachm2nt Permit is required by the
PADER Bureau of Dams and Waterways for construction or
alteration of permanent fill/structures along or in the channel
or floodway of any stream. This regulation may be applicable to
the installation of erosion control systems along the southeast
slope of the pile.
D. Utilization of Permanent Solutions and Alternative
Technologies to the Maximum Extent Practicable
The selected alternative is current~y the most appropriate solution
for this operable unit and represents the maximum extent to which pa~nt
solutions and treatment can be practicably utilized.
Of the alternatives that are protective of human health and the
environment, the selected remedy is the easiest to implement within the
shortest tima-frame, is most cost-effective and provides the highest level
of short-term effectiveness.
Excavation/offsite disposal and onsite vitrification provide a
higher degree of reduction in toxici ty, mobili ty, or volume and long-term
effectiveness and parmanence. However, the short-term risks for these
alternatives are unacceptable since the potential for release of asbestos
would be quite high during the lengthy intrusive activity required for each
of the alternatives.
(38)
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E.
Preference for Treatment as a Principal Element
The selected remedy does not accomplish the statutory preference for
treatment as a principle element of the remedy. Since asbestos cannot be
cClllbusted and is chemically inert, a permanent remedy as such cannot be
effectively implemented at this site.
XI.
Documentation of Significant Changes
The proposed plan for the CertainTeed Pile site was released for
public cOlllllent on August 18, 1989. The selected remedy, Alternative 4 -
Onsi te Closure, was identified in the Proposed Plan as the preferred
alternative. No written or verbal coaments to the Proposed Plan were
submitted to EPA during the cOlllllent period. Therefore, no significant
~hanges to the remedy preferred in the Proposed Plan were necessary.
(39)
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APPENDIX A
RESPONSIVENESS SUMMARY FOR THE
AMBLER ASBES'roS PILES SITE
(SEcam OPERABLE UNIT)
AMBLER, PmNSYLVANIA
In accordance with Section 113(k)(2) and 117 of CERCLA, the U.S.
Environmntal Protection Agency (EPA) established a 30 day comment period
from August 18, 1989 through September 18, 1989 on the Proposed Plan and
other site related documents for the Ambler Asbestos Pile (CertainTeed
Pile) in Ambler, Pennsylvania.
An advertisellt!!nt was placed in the Ambler Gazette on August 16, 1989
announcing the availability of the Proposed Plan and the dates.. of the 30
day c01ltm2nt period. The advertise1ll2nt also announced' that requests were
being accepted for a public meeting.
EPA contacted Ambler Borough officials before the advertisem2nt was
published .
During the 30 day conanent period EPA received no wri tten or verbal
. comments from the public. In the past, residents were highly interested in
the Locust Street pile (first operable unit) and interest remains high.
However, the lack of comments for this operable unit may be due to the fact
that the Locust Street Pile is visible to the public eye, and the
CertainTeed Pile is not visible from the residential area.
(40)
..
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APPENDIX B
MMNSYIVANIA
Doputy f*er»t*ry f or
Environmental Protection
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
POM OfflM lox 2063
Hanfeburg, Penrwyivanla 17120
September 29, 1989
717-787-5028
Mr. Edwin •. Brickson
Regional Administrator
USBPA Region ZZZ
841 Chestnut Building
Philadelphia, PA 19107
Res Ambler Asbestos Superfund Site
Operable Unit 1, CertainTeed Pile
draft Record Of Decision (ROD)
Dear Mr. Brickiont
The draft Record of Decition (ai received September 18,
1989) for the A&bler Asbestos, Operable Unit 2, has been reviewed
by the Department. It it ay understanding that this Record of
Decision will be submitted to you for your approval.
The proposed remedy for the Operable Unit 2,
CertainTeed Pile, would include regrading the plateau, repairing
erosion damage, installing erosion control devices, and post
closure monitoring.
Z hereby concur with the IPX's proposed remedy, with
the following conditionsi
* EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DBR design specific
ARARS.
* The Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
* The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state and federal law.
-------
Mr. Idw1n B. Irick.on
Regional Adm!ni.trator
September 29,
- 2 -
*
Th18 concurrence with the ..lected r888dlal action i.
,not intended to provide any a..uranc.. pu:.uant to SARA
Sectlon 104(c)(3).
If you have any que.tion. reqardLng thi8 utt.r plea..
do not h..ltat8 to contact ..~
JiiJ!~IJt-
.. Deputy Secretary
"
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