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Valley Forge National Historic Park
EPA Region 3 (Mid-Atlantic)
EPA ID# PA9141733080
13th Congressional District
Last Update: June 2006
Current Site StatusThe National Park Service (NPS) requested money for both an emergency removal and the for remedial investigation and feasibility study (RI/FS). A portion of the park was previously occupied by an asbestos plant which operated between 1937 and 1997. The NPS negotiated with the Commonwealth of Pennsylvania Dept. of Conservation in an effort to get the Dept. to investigate and cleanup the site as a responsible party. The agreement was signed the Fall/Winter of 1999. The investigation and cleanup is expected to take several years to complete. The Pennsylvania Department of Environmental Protection issued the Draft Final Primary Work Plan to NPS in July 2001. NPS initiated dispute resolution procedures on August 24, 2001 because the work plan did not determine the nature and extent of contamination at the site. The dispute was resolved when the NPS accepted the RI Work plan submitted by PADEP's Contractor with the stipulation that additional work may be required. As a result, field work began in June 2002. PADEP is the lead regulator for this site and overseeing the remedial action.
Valley Forge National Historic Park (VFNHP) is located in Montgomery County, Valley Forge, Pennsylvania, a suburb approximately 18 miles northwest of Philadelphia, PA. The park today encompasses 3,600-acres and receives approximately 7 million visitors a year. The Schuylkill River traverses the northern portion of VFNHP. The park is frequently used by area residents for jogging, and walking. There are 85 to 95 employees at the park depending upon the season. Several employees live in the park in housing provided by the National Park Service (NPS).
VFNHP is historically significant because of the role it played during the Revolutionary War. There are five abandoned historical limestone quarries within the park. The quarries operated during the 1800s. Today a portion of VFNHP is the area where an asbestos plant operated. The former asbestos plant is located near an old limestone quarry next to the original Valley Forge Military Park. The asbestos plant began operations around 1939. Slurry pipelines were constructed around the park to dispose of waste in the quarries. Kneene Asbestos operated the plant prior to 1997. During this time, the park was managed by the Commonwealth of Pennsylvania.
Later in 1977, the U.S. Department of Interior (DOI) purchased the asbestos plant property and a cleanup began under the supervision of the Pennsylvania Department of Environmental Resources (PADER) now the Pennsylvania Department of Environmental Protection (PADEP). In July of 1980, the original contractor was found in default due to the lack of proper equipment. Perkins Run Blasting Company was hired as the new contractor. The contractor was instructed to comply with 40 CFR Section 61.20 the National Emission Standards for Asbestos and Title 25 of the Pennsylvania Code, Chapter 123, Standards of Contaminants of the Dept. of Environmental Resources.
PADER approved the disposal of all insulated pipes with asbestos material in an approved landfill. In addition, PADER approved the proposal to demolish the existing plant structures and to dispose the demolition waste and material from the process waste piles containing asbestos in the dry quarry pit next to the limestone quarry. In 1981, PADER gave permission to the NPS to dispose of silicaceous limestone and asbestos free demolition material in the second quarry pit, a wet quarry at the park.
The park was transferred to the federal government in 1976 administered by the NPS. Asbestos wastes were covered in a majority of the cases by soil. However, erosion over time has exposed the asbestos waste.
- Site Responsibility
- This site is being addressed through Federal actions.
- NPL Listing History
- This site is not listed on the NPL.
Threats and ContaminantsThe contaminant at VFNHP is asbestos. Areas of asbestos have been documented throughout the park. Asbestos may migrate via surface water run-off and wind. Direct contact by humans (visitors and park personnel) and the environment may result in an exposure.
Contaminant descriptions and risk factors are available from the Agency for Toxic Substances and Disease Registry, an arm of the CDC.
As a result of an anonymous tip, EPA activated $200,000 to initiate an emergency removal to limit human exposure to asbestos containing material (ACM) at the park. EPA in consultation with ATSDR did the following: 1) fenced off and posted areas of contamination, 2) capped exposed ACM with soil, 3) sprayed encapsulant on exposed ACM where soil covering was impracticable, 4) wet exposed ACM to reduce air borne asbestos fibers, and 5) conducted air monitoring and soil sampling. The emergency removal was deemed complete on or about July 4, 1997.
The emergency removal activities were actions necessary to temporarily stabilize site conditions until the NPS could acquire funding and implement its plan to mitigate the potential long-term threat to human health and/or the environment. Unfortunately, the majority of the encapsulant has degraded by Spring 1998. Most of the ACM is exposed. As a result the NPS has restricted access to areas with ACM. Snow fence and warning signs were posted installed. The Agency for Toxic Substances and Disease Registry (ATSDR) and the National Institute for Occupational Safety and Health (NIOSH) were consulted. Both agencies prepared a health consultation for park personnel, visitors and the nearby community. A public availability session was held in early January 1998. A majority of the concerns were presented by the park personnel. The health consultations will be available for public comment by early spring 1999.
The NPS initiated emergency removal authority and conducted temporary mitigation measures. Some areas were covered with temporary soil cover while other areas still have restricted access. VFNHP requested funds to conduct a preliminary assessment and site inspection (PA/SI) at the site. The PA/SI was completed May 22, 1998. By December 1999, VFNHP and the Commonwealth signed an agreement for the Commonwealth to perform the investigation. The NPS initiated dispute resolution of the remedial investigation and feasibility study (RI/FS) work plan. Meetings were held in October and November 2001, and in February 2002. The NPS resolved the dispute by accepting the work plan in May 2002. EPA received the work plan in July after the field investigation began. EPA review of the final work plan accepted by VFNHP determined that the document lacks a quality assurance project plan (QAPP) that meets EPA Region III's requirements. In addition, the investigation into the Schuylkill River and ground water investigation may not characterize the nature and extent of the contamination at and around the park. As a result, EPA suggested that the NPS not accept the final work plan due to a deficient QAPP and for other technical reasons. VFNHP chose to accept the work plan so that the remedial investigation (RI) could begin. The Pennsylvania Department of Environmental Protection (PADEP) and its contractor initiated work in 2002. PADEP submitted he draft RI in May to the NPS. EPA received the draft RI report in July 2003, and the draft FS in September. EPA was not originally provided a copy to review. EPA completed it review of the draft RI and draft FS reports in January 2004. EPA provided the NPS with significant technical comments and it outlined deficiencies in the reports and provided recommended to the NPS to salvage the reports. EPA also restated that the NPS coordinate with the PA Department of Transportation (PenDOT) since it plans improve the transportation structures in the area. PenDOT has plans to reconstruct the Betzwood Bridge and improve the intersection along RT 13 at the park EPA recommended that the NPS remediate the area prior to construction by PenDOT to ensure that no release of asbestos occurs. If both efforts are not properly coordinated, a release could occur. EPA also recommended that additional characterization and laboratory analyses be conducted since the analytical methods used to evaluate asbestos risk will be changed in the near future. This could significantly impact the investigation and remediation at the site. It is now the responsibility for the NPS as the lead agency to determine how it plans to complete the RI and FS, coordinate with the public and PenDOT on these issues and how it plans to remediate the site for asbestos and other contaminants as well.