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BoRit Questions & Answers - History and Background

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  1. During the US EPA investigation and cleanup of the Ambler Asbestos Piles from 1972 to 1995, EPA documented the Ambler Asbestos Piles Superfund Site, the East and West Maple Street piles, now known as the BoRit Asbestos Superfund Site, and all the asbestos manufacturing buildings to be a potential source of asbestos contamination and pollution, yet EPA only re-mediated the Ambler Asbestos Piles. Why didn’t EPA address all the asbestos contamination from the asbestos manufacturing of the Keasbey and Mattison, CertainTeed, and Nicolet Industries? (7-3-2010)

  2. Why was all the asbestos contamination not addressed in the 1980's during the original EPA investigation of asbestos? (6-2-2010)

  3. Why did the EPA place the Nicolett Plant Pile and the Locust Street Pile on the National Priorities List (NPL)? (1-2008)

  4. Why was the Whitpain Park closed since buried asbestos, for the most part, is not a health hazard? (1-2008)

  5. Who remediated the Gravers Road pile and when? (1-2008)

  6. Why did the Pennsylvania Department of Environmental Protection (PADEP) commission the evaluation by Shaw? (1-2008)

  7. When was this asbestos material dumped and why was it allowed? (9-2006)

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  1. During the US EPA investigation and cleanup of the Ambler Asbestos Piles from 1972 to 1995, EPA documented the Ambler Asbestos Piles Superfund Site, the East and West Maple Street piles, now known as the BoRit Asbestos Superfund Site, and all the asbestos manufacturing buildings to be a potential source of asbestos contamination and pollution, yet EPA only re-mediated the Ambler Asbestos Piles. Why didn’t EPA address all the asbestos contamination from the asbestos manufacturing of the Keasbey and Mattison, CertainTeed, and Nicolet Industries? (7-3-2010)

    Near the Ambler Asbestos Piles Superfund Site, there are other areas that were also used for waste disposal by the Keasbey & Mattison Company, the original asbestos products manufacturer in Ambler. The West Maple Street Pile (now designated the BoRit Pile), the East Maple Street Pile (now designated Whitpain Park), and the reservoir between them were not dealt with as part of the Ambler Asbestos Piles Site, because, as stated in the Remedial Investigation Report for the Ambler Asbestos Piles Site, "The Maple Avenue Piles were covered and vegetated by the Pennsylvania Department of Environmental Resources (PADER), which is currently the Department of Environmental Protection (PADEP), in the mid-1970s and are currently monitored by PADER." As early as 1984, and several times thereafter, EPA evaluated the BoRit Pile and Whitpain Park. Each time, EPA determined they did not warrant Superfund action. It was not until the most recent assessment by EPA's Removal Program conducted during the time period of October 2006 through September 2007, with a focus on the site's deteriorating conditions, and a more advanced evaluative approach to asbestos sites, that the decision was made to initiate a Removal Action and subsequent evaluation for proposal to the Superfund list. The three areas were considered together as one site and finalized on the Superfund list as the BoRit Asbestos Site.

    At the time when most of the waste disposal occurred in Ambler, there were no laws prohibiting such disposal activities, and EPA was not in existence to handle such problems. PADER and EPA became actively involved in 1971 after receiving a complaint from the Wissahickon Valley Watershed Association concerning the possible contamination of air and water from the operations of the Nicolet and CertainTeed companies in Ambler. These two companies owned and operated the three waste piles that make up the Ambler Asbestos Piles Superfund Site. Investigations showed visible emissions and substantial dust concentrations at the Site, and the owners were ordered to stop dumping on the piles. The Superfund law was enacted in 1980, and the Ambler Asbestos Piles Site was formally evaluated by EPA's Superfund Removal Program which conducted an assessment and several response actions to stabilize the massive piles which were then commonly known as the "White Mountains" because of the visible waste on the uncovered side slopes. Subsequently, the Site was placed on the National Priorities List (NPL or Superfund list) and, after a full evaluation of remedial alternatives; the capping remedy was selected and implemented by EPA's Remedial Program.

    Sites evaluated in the 1980s, including the Ambler Asbestos Piles Site, EPA's Superfund program did not investigate or clean up hazardous waste inside factory buildings. In accordance with the EPA's 1983 Guidance for Controlling Friable Asbestos Containing Materials in Buildings, if a determination was made that the buildings could be secured, and the hazardous substances inside were unlikely to be released to the environment and pose a significant threat to public health, then the building would not be included in a Superfund action. As stated in the guidance, "The decision whether to take action and the selection among different courses of action are the responsibilities of individual building owners." There are instances where conditions led to the inclusion of buildings in Superfund actions, but that determination was not made at the Ambler Asbestos Piles Site. Also, portions of the Ambler Asbestos facility were in operation until 1987, in which case the Occupational Safety and Health Administration would have been the regulatory agency enforcing the proper handling of hazardous materials within the buildings. When the facilities became abandoned, PADEP became the primary enforcing agency. PADEP and EPA have worked with property owners and developers to restrict access to the buildings.

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  2. Why was all the asbestos contamination not addressed in the 1980's during the original EPA investigation of asbestos? (6-2-2010)

    At the time when most of the contamination occurred, there were no laws prohibiting such disposal activities, and the EPA was not in existence to handle such problems. The Superfund law was enacted in 1980. The Ambler Asbestos Piles Site was first evaluated in the early 1980's by EPA's Superfund Removal Program which conducted an assessment and several response actions to stabilize the massive piles. Subsequently, the Site, which was defined as the piles (i.e., CertainTeed Pile, Locust Street Pile, and the Plant Pile) was placed on the National Priorities List (NPL or Superfund List) and, after an evaluation of alternatives, the capping remedy was selected and implemented by EPA's Remedial Program.

    As early as 1984, and several times thereafter, EPA evaluated the East and West Maple Street piles and the berm around the reservoir which is now defined as the BoRit Superfund Site. Historically, those areas did not pose a threat to human health and the environment, and, therefore, did not warrant Superfund action. The vegetative cover on much of the area likely contributed to this determination. It was not until the more recent assessment in 2006 and 2007 by EPA's Removal Program, with a focus on the Site's deteriorating conditions, and a more advanced approach to the evaluation of asbestos sites, that the decision was made to pursue a Removal Action and evaluation of the Site for the NPL.
     
    Superfund was established to address abandoned hazardous waste sites and conduct response actions that permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances to the environment. Responses to releases inside buildings is not the primary focus of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) unless there is a release or threat of release to the environment, and the release poses a hazard to public health, welfare, or the environment. EPA, State, and/or local authorities often work with the property owner to ensure the hazardous substances inside buildings are properly addressed. There are instances where site specific conditions led to the inclusion of buildings in Superfund actions, but that determination was not made at the Ambler Asbestos Site. Also, buildings adjacent to the Ambler Asbestos Superfund Site were in operation until 1987, in which case the Occupational Safety and Health Administration would be the regulatory agency enforcing the proper handling of hazardous materials within the buildings. When the facilities became abandoned, the Pennsylvania Department of Environmental Protection (PADEP) became the primary enforcing agency. PADEP has worked with property owners and developers to restrict access to the buildings.

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  3. Why did the EPA place the Nicolett Plant Pile and the Locust Street Pile on the National Priorities List (NPL)? (1-2008)

    The cleanup of this Site was accomplished through the following actions: In 1974, the State denied permit applications for continued disposal and ordered both companies to stop dumping and to stabilize and cover the piles. Remedial Investigations were conducted on both parcels to determine the degree and extent of contamination. EPA found asbestos in the soil, in the filter bed lagoon sludges and on equipment in the Locust Street playground, adjacent to the Locust Street Pile. As an early response to these findings, the contaminated playground equipment was removed, the sides of the piles were reinforced and security fencing was constructed around the site. Additional cleanup actions were selected and described in EPA-issued Records of Decisions in 1988 and 1989. These cleanup actions consisted of regrading and capping the pile plateaus; reinforcing the soil cover; installing erosion and sedimentation control devices; draining and backfilling the lagoons with clean soil; installing or upgrading the fencing/locking gates; posting warning signs; and monitoring the air. Where the piles bordered surface water, they were reinforced against erosion. These actions were completed and mitigate the threats of release of asbestos and exposure of the surrounding community.

    Two parties entered into separate Consent Decrees to design and implement the remedies. CertainTeed Corporation, as the current owner, conducted the work for Operable Unit 2 detailed in the November 1990 Consent Decree. T&N Industries, Inc., as the parent corporation of a previous owner, conducted the work for Operable Unit 1 under a May, 1991 Consent Decree. The remedies were implemented and on-site physical construction was completed in October 1992; EPA accepted the construction reports in April 1993.

    The construction of all remedies, along with all approvals and documentation, at the Ambler Asbestos Piles Superfund site was completed August 30, 1993 and the site was deleted from the NPL on December 27, 1996. Maintenance of the remedies constructed at this Site is conducted as part of an ongoing Operation and Maintenance Program. Two five-year reviews of the remedy were completed May 27, 1997 and September 25, 2002. Both reviews certified that the cleanup of the site continues to be protective of human health and the environment.

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  4. Why was the Whitpain Park closed since buried asbestos, for the most part, is not a health hazard? (1-2008)

    The site as it exists was designated as an Asbestos Disposal Site per the National Emission Standards for Hazardous Air Pollutants. As such, the owners of the property were required by law to conform to those regulations. This included fencing off the property and maintaining controls on the site.

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  5. Who remediated the Gravers Road pile and when? (1-2008)

    Blue Bell Associates, who purchased the site in 1999 from the Smith Land Improvement Corporation. The remedial investigation final report is dated December 1999, with a cleanup plan final report submitted September 2004, with a related addendum dated September 2005.
     
    During development preparation for this 40+-acre property, slurry material from the pile was removed and mixed with clean soil from off-site. The slurry/soil mix was used to level and grade the wooded low-lying area. Following the grading, a geotextile membrane was placed over the impacted area and covered with a minimum of two feet with clean soil. Much of the property will be further covered with asphalted parking areas, asphalt access roads and slab-on-grade buildings. Prior to installing the geotextile membrane and soil cover utility excavations were installed. Additionally, a deed notice will be placed on the property to provide for post-remediation care.

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  6. Why did the Pennsylvania Department of Environmental Protection (PADEP) commission the evaluation by Shaw? (1-2008)

    In March 2003, the PADEP commissioned Shaw Environmental to assist in determining the need for involvement by our agency at the BoRit Site, which had been deemed "no further action required" by EPA in September 1988. This was a draft document, one which PADEP did not review in-depth or comment on, as agency review stopped once the property was purchased by a private entity.

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  7. When was this asbestos material dumped and why was it allowed? (9-2006)

    The waste asbestos containing material and asbestos shingles found at these sites were deposited by Keasby & Mattison and Nicolet Industries from the 1930s until the 1970s. Unfortunately at that time, there were no environmental regulations regarding the disposal of asbestos. The Solid Waste Management Act of 1988 requires that asbestos and asbestos containing material now be disposed of at permitted landfills.

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