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BoRit Questions & Answers - Sampling and Monitoring

BoRit Questions & Answers Main Page

  1. In 2006, the EPA took air samples from the BoRit site and detected levels of asbestos in the air at the site. How was EPA able to determine that the asbestos came from the BoRit site and not from other sources? (7-3-2010)

  2. Will EPA continue to do quarterly air sampling? (8-10-2009)

  3. How does EPA determine groundwater elevations for contour maps? (8-10-2009)

  4. Why has EPA determined to use Polarized Light Microscopy (PLM) and Phase Contrast Microscopy (PCM) instead of the Transmission Electron Microscopy (TEM) analysis of the samples? (8-10-2009)

  5. How will the depth of the waste be determined? If the native soil starts at the groundwater table interface, will the boring stop? (8-10-2009)

  6. Will the grab samples being taken include the pile cover and clean materials? (8-10-2009)

  7. Will EPA install well clusters to monitor the groundwater quality in the native soil and in the asbestos waste, especially in areas where the asbestos fill extends near or into the water table? (8-10-2009)

  8. Will the geological and hydrogeological setting of the Site be required to refine the Conceptual Site Model (CSM)? (8-10-2009)

  9. How is limiting the clearing and grubbing considered a data gap? (8-10-2009)

  10. Could electrical resistivity tests on the Park be warranted to determine or rule out potential water influences under the park as well and to aid in determining the depth of waste at the Park? (8-10-2009)

  11. Should the proposed action call for continuous Photo Ionization Detector (PID) headspace readings in case a 4-foot-long Geoprobe sampler is used? (8-10-2009)

  12. If all surface water samples are collected from the bottom of the water column, how will this correlate to the evaluation of the water quality impact on the waterfowl? (8-10-2009)

  13. Is the water from Rose Valley Creek being tested before being diverted into the Wissahickon Creek?  (8-9-2009)

  14. Is EPA looking for asbestos material in the community? (8-3-2009)

  15. Why does the EPA believe that exposed asbestos does not present a potential health hazard? (9-5-2008)

  16. Are there air samplers at the park now? (9-5-2008)

  17. How long per day does EPA sample the air at the site? (9-5-2008)

  18. Can EPA explain "discrepancies" between the past and most recent results of asbestos in the Wissahikon Creek? (1-2008)

  19. Why did EPA conduct testing after wet conditions in two of the three rounds conducted this summer? (1-2008)

  20. Has EPA taken enough air samples during dusty, windy weather/soil conditions? (1-2008)

  21. Has EPA's Removal Section evaluated all Pennsylvania Department of Environmental Protection (PADEP) data relevant to the BoRit Site? (1-2008)

  22. Was the Gilmore report and Shaw report considered by EPA in this current sampling/evaluation process? (1-2008)

  23. How many samples are acceptable for the BoRit Site? (1-2008)

  24. Were the results from the April 2006 testing accurate? (1-2008)

  25. Has the EPA performed soil analysis on the BoRit portion of the 38 acre site? (1-2008)

  26. What does the EPA think is the contributing factor of the fuel oil smell as reported in the Gilmore report phase 1 performed in 2001? (1-2008)

  27. Will the EPA consider providing Whitpain, Upper Dublin and Ambler with a grant to have independent testing performed ? (1-2008)

  28. Does EPA plan to conduct monitoring during and after removal activities? (12-27-2007)

  29. Is future sampling planned? (12-27-2007)

  30. Has EPA evaluated the "worst case scenario"? (12-27-2007)

  31. Can EPA conduct independent testing and analysis of the site and the surrounding areas? (12-27-2007)

  32. Many of the documents (Gilmore, Shaw et al) refer to illegal dumping, 55 gallon drums, fuel oil smells, etc., What, if any tests can be done with regards to addressing these problems? (8-8-2007)

  33. Were any air tests conducted in April, 2007? (8-8-2007)

  34. Why is it necessary for EPA to conduct additional testing prior to taking a removal action at the Site? (5-1-2007)

  35. The Gilmore report states: "the asbestos waste material from the excavation is considered friable." The Ages report of 1984 for the Whitpain Park also notes that the asbestos waste is considered friable. Can EPA explain this? (5-1-2007)

  36. How does EPA ensure accurate sampling is being done? (3-12-2007)

  37. Why are EPA's actions at the site so data and time-intensive? (3-12-2007)

  38. How does EPA analyze samples? What is the difference between "raw data" and "validated data"? (3-12-2007)

  39. What is the status of the testing conducted by EPA in April, October and November of 2006, including the reasons for the additional testing, the length of time for EPA to release the data, the findings, and the locations selected for sampling?  (3-12-2007)

  40. Does EPA "make up" its data? (3-12-2007)

  41. Please explain the quarterly, seasonal sampling currently being conducted by EPA, including the effect of leaves and other groundcover on the fall sampling data, and EPA's choice of sampling locations. (3-12-2007)

  42. What does EPA mean when they report that "0" or "no fibers were detected" at the Site, and about the expected "background" of fibers in urban areas? (3-12-2007)

  43. What does the term "fatal error" mean on the National Asbestos Data Entry Spreadsheet (NADES)?  (3-12-2007)

  44. Why are the "analysis dates" incomplete on the National Asbestos Data Entry Spreadsheet (NADES)? (3-12-2007)

  45. Are fencing and signs sufficient at the Site, given the results of the tests performed by EPA? (1-24-2007)

  46. Is the data that EPA provides to the public complete and accurate and does the public have access to the documents during public meetings? (1-24-2007)

  47. How many tests were performed for the water and sediment during last year’s testing? (unknown date, 2007)

  48. Has there been recent sampling or is any planned? (9-2006)

  49. Is EPA concerned about the trace amounts of Amphibole fibers that were detected from this March testing event? (Unknown Date)

  50. The CAG asked EPA to work with Ambler Borough to conduct pump testing on the public water supply well to determine if groundwater beneath the site could influence the public water supply.  What was the outcome of that request?

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  1. In 2006, the EPA took air samples from the BoRit site and detected levels of asbestos in the air at the site. How was EPA able to determine that the asbestos came from the BoRit site and not from other sources? (7-3-2010)

    In April 2006, EPA's Site Assessment Program conducted air sampling at the BoRit Asbestos Site. A preliminary review of the air samples indicated the presence of airborne asbestos. However, the results were inconclusive because four of the six air samples were overloaded with dust/particulates and a non-preferred method of analysis was used for those samples. As a result, the EPA conducted air sampling events in October/November 2006 and in March/May/June/July/August and September 2007 to determine whether airborne results would change throughout the year. During each of the sampling events, there were eight sampling locations within the boundaries of the BoRit Asbestos Site and five off-site sampling locations within 1/4 mile of the perimeter of the Site that were monitored for airborne asbestos. The wind direction from a nearby meteorological station was recorded during each sampling event. This would ensure that the proper background monitors could be selected to help determine whether any asbestos detected in the on-site monitors was coming from the BoRit Asbestos Site, as opposed to other potential off-site sources. Background samples were collected upwind of the BoRit Asbestos Site, based on the predominant wind direction identified by the weather station. The background samples did not contain asbestos fibers while the onsite samples did show asbestos demonstrating that the asbestos detected in the samples most likely came from the BoRit Asbestos Site.

    EPA began offering residents visual inspections of their properties in November 2008. To date, EPA has received, and completed three (3) residential inspections.

    Based on the visual inspections, EPA determines whether sampling is needed on the residential property to further determine whether the waste is associated with the site. It is important to note that EPA is looking for asbestos waste that may be associated with the BoRit Site, not asbestos building materials used during construction at the property (i.e. siding, shingles, insulation, etc.).

    To date, EPA has found no evidence that asbestos waste was widely distributed in this community. Nonetheless, EPA is committed to providing property inspections to any residents living near BoRit who believe asbestos waste associated with BoRit is present on their private property.

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  2. Will EPA continue to do quarterly air sampling? (8-10-2009)

    EPA's Removal Program has agreed to perform quarterly community air sampling. The Remedial Program is planning to begin their Remedial Investigation/Feasibility Study (RI/FS) Phase I investigations in mid November, which will last for approximately 2 months. Thus, while the Removal Program continues their work through the fall and winter, quarterly community air sampling will continue while both the Removal and Remedial Programs conduct their activities.

    Although not finalized yet as part of the Site Management Plan for the Site, for the RI/FS Phase I perimeter sampling, during intrusive activities (e.g., where direct-push sampling is to be conducted), EPA is planning to collect four perimeter (also referred to as stationary) air samples for the first two days of sampling. The planned asbestos analysis for these samples is PCM-NIOSH 7400 and TEM-ISO 10312. The samples will be collected in the upwind, downwind, and both cross wind directions. It is also planned that perimeter air samples will be collected daily and archived after the first two days of sampling. If meteorological data or Site conditions indicate a reason to analyze additional perimeter air samples, EPA will determine which archived perimeter air cassettes need to be submitted for analysis. If greater than two asbestos structures are found on any perimeter air sample by TEM-ISO 10312, a re-evaluation of engineering controls will be performed.

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  3. How does EPA determine groundwater elevations for contour maps? (8-10-2009)

    If soil is wet in a borehole, this will be noted on the boring log. However, this is not an accurate method to determine groundwater elevations for contour maps. Therefore, temporary piezometers will be installed on the Whitpain Park parcel, the Asbestos Pile parcel, and around the Reservoir as part of the Phase I and II activities. Groundwater elevations will be used from these piezometers to develop contour maps. In addition, groundwater monitoring wells may be installed as part of Phase II activities, which will also be used in the development of groundwater contour maps.

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  4. Why has EPA determined to use Polarized Light Microscopy (PLM) and Phase Contrast Microscopy (PCM) instead of the Transmission Electron Microscopy (TEM) analysis of the samples? (8-10-2009)

    For soil collection and analysis, the EPA Framework for Investigating Asbestos-Contaminated Superfund Sites recommends using CARB 435 PLM method. Although not finalized yet as part of the Site Management Plan for the Site, this is the method that EPA is planning to use for analysis of asbestos in soil.

    Although not finalized yet as part of the Site Management Plan for the Site, personal air monitoring for workers is planned to occur during all days of Phase I intrusive investigations. Two personal samples per day (30 minute and 8 hour Time-Weighted Average will be collected during each monitored intrusive activity. These air samples will be analyzed for asbestos by PCM-NIOSH 7400, and if the 30 minute PCM concentration is greater than 1 f/cc and/or the 8 hour TWA concentration is greater than 0.1 f/cc, then the samples will be analyzed by TEM-NIOSH 7402.

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  5. How will the depth of the waste be determined? If the native soil starts at the groundwater table interface, will the boring stop? (8-10-2009)

    Although not finalized yet as part of the Site Management Plan for the Site, EPA will continue to drill until we hit native soil regardless if we hit groundwater above, in the waste. If we encounter groundwater above native material or right at native material, we will still collect a 0-3 inch sample in the native soil. EPA wants to document the full extent of the waste and what the top of the native soil looks like (at least the first 3 inches).

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  6. Will the grab samples being taken include the pile cover and clean materials? (8-10-2009)

    Although not finalized yet as part of the Site Management Plan for the Site, five randomly determined grab samples will be collected from the 0 to 3 inches in cover material and will be analyzed for asbestos. Three randomly determined grab samples will be collected from 0 to 3 inches in cover material and analyzed for Volatile Organic Compounds, Semi-Volatile Organic Compound, Pest/Polychlorinated Biphenyls, and metals. All of these samples may include clean material added during the removal process. Additional soil samples will be collected within the cover/waste interface, waste layer, and native soil. All of the samples will be used in determining the nature and extent of contamination.

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  7. Will EPA install well clusters to monitor the groundwater quality in the native soil and in the asbestos waste, especially in areas where the asbestos fill extends near or into the water table? (8-10-2009)

    Information collected from the Remedial Investigation/Feasibility Study (RI/FS) Phase I activities will be used to determine if and where groundwater monitoring wells will be installed as part of Phase II RI/FS activities. EPA will consider this comment when evaluating the need and placement of groundwater monitoring wells as part of the Phase II RI/FS activities.

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  8. Will the geological and hydrogeological setting of the Site be required to refine the Conceptual Site Model (CSM)? (8-10-2009)

    EPA recognizes this comment and will consider it in the development of the CSM.

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  9. How is limiting the clearing and grubbing considered a data gap? (8-10-2009)

    The purpose of the Remedial Investigation/Feasibility Study  is to characterize the Site and determine the nature and extent of contamination. However, there will likely be areas that we just will not be able to access. For instance, we may have access issues due to the steepness and stability of the Asbestos Pile. In addition, minimizing the clearing and grubbing may also limit us from certain sampling locations. However, we will move these locations to the extent possible to characterize the waste.

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  10. Could electrical resistivity tests on the Park be warranted to determine or rule out potential water influences under the park as well and to aid in determining the depth of waste at the Park? (8-10-2009)

    For the Remedial Investigation/Feasibility Study Phase I investigation, EPA is not planning to do an electrical resistivity (ER) survey on any of the parcels. EPA will be evaluating the ER survey performed by Gilmore and Associates in 2001 once we have boring log information from the Phase I investigation to see if the previous survey is adequate. Once we have done this evaluation, we will also evaluate whether there is a need to do an ER survey on any or all of the parcels.

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  11. Should the proposed action call for continuous Photo Ionization Detector (PID) headspace readings in case a 4-foot-long Geoprobe sampler is used? (8-10-2009)

    EPA will assume there needs to be clarification regarding how PID readings will be taken. The geoprobe sleeves are 4 feet in length but EPA is planning to do PID headspace every 2 feet so each sleeve will have two headspace readings for the top 2 feet and bottom feet (therefore, it is continuous).

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  12. If all surface water samples are collected from the bottom of the water column, how will this correlate to the evaluation of the water quality impact on the waterfowl? (8-10-2009)

    The sampling strategy was based on the assumption that the sediments/material at the bottom of the reservoir are going to be the source of any asbestos we see in the water column. Based on the nature of asbestos and the location of the source materials, we expect to find the highest concentrations of any asbestos to be lower in the water column. The sample results are anticipated to represent a worse case exposure scenario, and we will utilize that to conservatively evaluate waterfowl exposure and potential risk.

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  13. Is the water from Rose Valley Creek being tested before being diverted into the Wissahickon Creek?  (8-9-2009)

    No, the water being diverted in Rose Valley Creek is not being tested. There is no need to test the water, as it is the same water that has been flowing through the creek.

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  14. Is EPA looking for asbestos material in the community? (8-3-2009)

    EPA has offered to conduct visual inspections of private properties for the presence of asbestos-containing material (ACM). EPA is concerned with the presence of ACM on private property that may be associated with the site, not asbestos materials that were construction materials on the property (siding, shingles, tiles, concrete, etc.). EPA will only conduct these inspections if the property owner has requested such an inspection.

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  15. Why does the EPA believe that exposed asbestos does not present a potential health hazard? (9-5-2008)

    EPA is conducting particulate air monitoring and asbestos air sampling while field activities are being conducted. Based on the air monitoring data and air sampling results, we believe that the work being conducted does not present an unacceptable or significant health risk.
     
    Asbestos air sample results from 14 samples collected between July 10 - 11 detected one asbestos fiber (chrysotile) in one sample. The analytical result for the sample with the chrysotile fiber was less than 0.0003 f/cc, which is comparable to the non-activity-based results obtained off-site and on-site previously. All other results, including the ones located along the McDonald's back-parking lot, were non-detect for asbestos. The sample with the chrysotile fiber was collected from a location opposite the fence (across West Maple) where a portion of the pile was inadvertently uncovered during preparatory activities.

    PCMe values were not reported but since the single fiber meets the PCMe criteria (≥5 micron length/≥0.25 micron width) we estimated a hypothetical cancer risk. As such, exposure to 0.0003 f/cc would result in EPA acceptable cancer risk estimates (less than 1 in a million or 1.0 x 10-06) for a maintenance worker (4 hrs/day for 39 days/yr for 25 yrs), a recreational receptor (4 hrs/day for 143 days/yr for 18 yrs), and a resident (24 hrs/day for 350 days/yr for 30 years).

    Based on these results, EPA, the Agency for Toxic Substances and Disease Registry and the Pennsylvania Department of Health conclude that off-site exposure does not pose a public health threat and that it is safe to walk near the site and/or visit the nearby businesses (e.g., McDonalds, SEPTA).

    Any interested persons are invited to stop by the EPA Command Post on Maple Street to see the real-time remote monitoring setup.

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  16. Are there air samplers at the park now? (9-5-2008)

    EPA is conducting particulate monitoring during each workday and air sampling two consecutive days per week.

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  17. How long per day does EPA sample the air at the site? (9-5-2008)

    The Datarams (for particulate monitoring) are deployed each day before field activities begin in the morning and are picked up at the end of the same day after field activities conclude.

    Asbestos sampling is conducted for two consecutive days each week. Like the Datarams, the samplers are deployed before field activities begin in the morning and are picked up at the end of the same day after field activities conclude. Each sampler collects approximately 4,800 liters of air during each sampling period. At the end of the second day they are shipped to the laboratory for analysis.

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  18. Can EPA explain "discrepancies" between the past and most recent results of asbestos in the Wissahikon Creek? (1-2008)

    Part of the Removal Investigation conducted was devoted to study of potential water borne asbestos and engineering controls to mitigate any potential threat. Any differences are most likely due to variations in weather and vegetation at the time of sampling. Of course the primary difference is the amount of time which has passed between the various sampling events.

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  19. Why did EPA conduct testing after wet conditions in two of the three rounds conducted this summer? (1-2008)

    The air sampling was conducted by the EPA's Environmental Response Team Contractors (i.e., REAC). REAC does the asbestos sampling all over the country, including Libby, MT and all other asbestos sites in the west coast. Therefore, we had to schedule the sampling events in advance…it is very hard to predict weather a month prior to any scheduled activity. We tried to do our best to work around the weather. We canceled if it was raining the day of sampling. We conducted eight rounds of ambient air sampling. We are confident that we got good representation of Site conditions over time. In addition, it has been found (i.e., current asbestos sampling being conducted in the west coasts) that sometimes even wet conditions can produce high results; it all depends on the circumstances.

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  20. Has EPA taken enough air samples during dusty, windy weather/soil conditions? (1-2008)

    Our purpose in evaluating this site was to develop a picture of the site over time and under all conditions not just dry/windy conditions. We have tried to plan our sampling during dry/windy conditions but several times over the last year Mother Nature simply has not been cooperative. We think that we have adequately characterized the site during different weather conditions.

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  21. Has EPA's Removal Section evaluated all Pennsylvania Department of Environmental Protection (PADEP) data relevant to the BoRit Site? (1-2008)

    Yes. Along with the Agency for Toxic Substances and Disease Registry.

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  22. Was the Gilmore report and Shaw report considered by EPA in this current sampling/evaluation process? (1-2008)

    No.

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  23. How many samples are acceptable for the BoRit Site? (1-2008)

    It is not so much a question of how many samples are acceptable as how many samples are required to produce a usable picture of the site and what it is doing.

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  24. Were the results from the April 2006 testing accurate? (1-2008)

    The air results from the April 2006 round of sampling were taken using a less effective method and therefore we could not use that data for Risk Assessment purposes. A positive outcome of the April sampling was that it prompted the EPA to conduct more in depth testing.

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  25. Has the EPA performed soil analysis on the BoRit portion of the 38 acre site? (1-2008)

    Soil samples were collected at the site during the April 2006 sampling event. The sampling results detected asbestos; however, there are presently no health or risk-based soil guidelines for comparison purposes.

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  26. What does the EPA think is the contributing factor of the fuel oil smell as reported in the Gilmore report phase 1 performed in 2001? (1-2008)

    During the April 2006 sampling event, elevated levels of polycyclic aromatic hydrocarbons were detected within the former fire training area. This was an isolated occurrence and therefore presents a limited likelihood of exposure. As a result, the risk is relatively low.
    It is documented that local fire departments did use sections of the BoRit Site for firefighter training.  The fuel oil smell most likely came from accelerants used during those activities.

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  27. Will the EPA consider providing Whitpain, Upper Dublin and Ambler with a grant to have independent testing performed ? (1-2008)

    No grants for this purpose are available from EPA. However, local colleges or universities have environmental science/engineering programs which may be able to provide assistance to communities.

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  28. Does EPA plan to conduct monitoring during and after removal activities? (12-27-2007)
     
    EPA plans to conduct monitoring while construction is ongoing at the site.

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  29. Is future sampling planned? (12-27-2007)

    EPA plans to evaluate the need for additional sampling. EPA will plan to take additional samples, if needed.

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  30. Has EPA evaluated the "worst case scenario"? (12-27-2007)

    In an attempt to simulate worst-case conditions, EPA did collect activity-based air samples from locations where asbestos levels in surface soil were thought to be high (like at the base of the on-site asbestos pile).

    EPA tried to capture extreme weather conditions at the site by sampling throughout the year, including summer. However, because sampling events must be planned in advance and because the weather can be unpredictable, controlling variables such as dry and windy conditions is difficult.

    Collecting air samples in areas where asbestos in surface soil was believed to be abundant (as explained in the first sentence) and assuming that the maximum detected air concentrations at these locations represent long-term conditions for residents, recreational receptors or maintenance workers results in an upper-bound estimate of exposure.

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  31. Can EPA conduct independent testing and analysis of the site and the surrounding areas? (12-27-2007)

    Any independent testing and analysis would have to be done by or in cooperation with the property owners.

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  32. Many of the documents (Gilmore, Shaw et al) refer to illegal dumping, 55 gallon drums, fuel oil smells, etc., What, if any tests can be done with regards to addressing these problems? (8-8-2007)

    The April 2006 assessment tested for many contaminants and only asbestos was identified as a contaminant of concern.

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  33. Were any air tests conducted in April, 2007? (8-8-2007)

    No, we did not sample in April. We were going to sample the same week Site Assessment sampled last year, but it was not possible due to weather conditions (the local news reported that April 2007 was the second wettest in history, in our area).

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  34. Why is it necessary for EPA to conduct additional testing prior to taking a removal action at the Site? (5-1-2007)

    Unfortunately, EPA cannot rely on visual information alone. The presence of asbestos or asbestos-containing-material does not automatically translate into a public health threat. In order to spend resources to remove potential contamination, we are required to rely on scientifically sound data to justify our actions at removal sites. At BoRit, EPA is taking samples that will give us that information. In addition, good quality data helps the health agencies make better health recommendations for the community.

    To date, our site investigation has given us very important information. For example, for the most part, we are not dealing with friable (i.e., when dry, can be crumbled, pulverized, or reduced to powder by hand pressure) asbestos. Therefore, it does not become airborne readily. Off-site migration of asbestos is not evident upon EPA's review of the October and November 2006 sampling data.

    EPA's sample results also tell us that an individual could be exposed to levels of airborne asbestos at the Site that might pose an unacceptable or significant health risk by directly disturbing the on-site soils (as simulated by the activity-based sampling). Right now, the Site is fenced and signs are posted to deter individuals from entering.

    EPA did detect low concentrations of asbestos in a few sediment samples taken from the Wissahickon Creek. However, it is difficult to accurately distinguish whether it came from the Site (i.e., the asbestos was detected in sample locations both upstream and downstream from the Site) or is a result of the area's history of asbestos manufacturing, or from other sources. In addition, EPA and the Pennsylvania Department of Environmental Protection’s ecological staff have not expressed any concerns regarding health threats to aquatic life.
     
    Based on the October and November 2006 ambient air sampling results collected to date, residents in the vicinity of the BoRit Site are not being exposed to asbestos fibers from the Site at levels that pose an unacceptable or significant health risk. As previously stated, when EPA has completed all the sampling from the Removal Assessment, we may take some action, refer the Site for further evaluation (i.e., National Priorities List consideration) or determine that no further action is necessary.

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  35. The Gilmore report states: "the asbestos waste material from the excavation is considered friable." The Ages report of 1984 for the Whitpain Park also notes that the asbestos waste is considered friable. Can EPA explain this? (5-1-2007)

    Both of the statements above are correct. EPA has stated that for the most part, we are not dealing with friable asbestos. To clarify, EPA, for the most part, is not dealing with friable asbestos on surface soils. EPA is aware of what the Gilmore and Ages reports state. However, most of what may be considered friable asbestos waste is buried. The only asbestos waste which may become airborne is the waste on the surface soils.

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  36. How does EPA ensure accurate sampling is being done? (3-12-2007)

    EPA is providing accurate scientific analysis of the Site and consulted with national experts on asbestos sampling (i.e., EPA Emergency Response Team, EPA's National Asbestos Technical Review Workgroup, and the Agency for Toxic Substances and Disease Registry toxicologists) before the quarterly sampling events to give the greatest assurance that we are conducting sampling and analyses in accordance with the current guidance.

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  37. Why are EPA's actions at the site so data and time-intensive? (3-12-2007)

    EPA understands that the time it takes to study a site can be frustrating for the community. However, good science leads to good cleanup decisions, and good cleanup decisions lead to better protection of human health and the environment. EPA must also be accountable to the public and its elected representatives (i.e., Congress) for spending Federal dollars responsibly. When we collect sound data at the beginning of a project, it can often help save us time and resources later.

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  38. How does EPA analyze samples? What is the difference between "raw data" and "validated data"? (3-12-2007)

    Raw Data:  Raw data is data of unknown quality. Raw data routinely includes information about how the samples were analyzed (e.g., instrument, voltage, magnification, grid opening area, name of the analyst, date and time of analysis, scale, filter size, mineral type, dimensions, etc.) so that we can double-check the results before the data becomes final, or validated.
     
    Validated Data: Validated data is data that has been put through all the checks and balances to make sure that it is accurate and that it can be reproduced using the same analytical steps. Validated data is what EPA uses to make cleanup and health decisions at all our sites, including BoRit.

    Using an analogy, the numbers you write into your checkbook as checks are written are the "raw data." The "validation" is the act of balancing your checkbook by reviewing the numbers you entered into the checkbook against the bank's numbers. The "validated data" is the final result compared and corrected against the bank's balance.

    All EPA samples are analyzed using approved standards and methods. The air samples for the site were analyzed using the International Standards Organization Method 10312 Ambient Air - Determination of Asbestos Fibers - ­Direct-Transfer Transmission Electron Microscopy Method.

    The analytical process also includes a very strict quality control step that ensures that the final results have been double-checked and meet all of the standards required by EPA.

    To further ensure that asbestos project data quality objectives are met, EPA has developed a spreadsheet (i.e., National Asbestos Data Entry Spreadsheet) with internal Quality Control (QC) verification that insures specific QC requirements for performing analyses are met and insure that the required data package is complete. The data package is the mechanism through which the laboratory provides documentation that the proper analytical method was performed.

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  39. What is the status of the testing conducted by EPA in April, October and November of 2006, including the reasons for the additional testing, the length of time for EPA to release the data, the findings, and the locations selected for sampling?  (3-12-2007)

    EPA is testing the air, and has tested soil, water and sediments to determine whether there is a need for a response action at the Site. Based on the October and November 2006 sample results collected, the community is not being exposed to levels that pose an unacceptable or significant health risk. However, EPA still has more tests to conduct before a final decision is made.

    Because we are testing for asbestos, EPA needs to look at all the ways that asbestos could travel off-site and potentially cause health problems. To do this, EPA is testing for asbestos in different locations at and around the Site, in different seasons, and under different weather conditions. Once we know how the asbestos behaves in each of these situations, we will have a more complete picture of the risk to human health.

    EPA has made all validated test results available to the public on the BoRit website, along with maps showing the sampling locations.

    April 2006 Sampling: The air results of the April 2006 sampling event were inconclusive because of the method used to analyze the samples (i.e., indirect vs. direct). The results ranged from 0.00061 to 0.039 f/cc (i.e., cubic centimeter of air). Those results included the samples analyzed using the indirect method (i.e., generally biased high). Therefore, it was decided to conduct a more comprehensive sampling program.

    October 2006 Sampling: EPA collected samples over four days. We collected samples from eight locations within the boundaries of the Site. We also collected samples from five locations within a 1/4 mile of the perimeter of the Site. In addition, there was a remote location in a nearby town used as a background or reference sample.

    EPA also conducted activity-based air sampling (i.e., personnel wearing personal air sampling pumps while performing different physical tasks) in the park to simulate the possibility of being exposed to asbestos while doing routine activities, such as maintenance work (i.e., lawn mowing). EPA also collected soil samples from the park.

    Validated results of the October 2006 data are available on EPA's BoRit website.

    November 2006 Sampling: EPA collected additional air samples in November so that we could get more data. EPA conducted more activity-based air sampling that included hiking scenarios all through the Site and stream banks and raking scenarios (i.e., continuously raked a specific location for one hour, allowing for the appearance of asbestos-containing material on the ground surface) at the park, the pile and stream bank by the park. EPA collected samples from eight locations on the Site, five locations in the community and the remote location in a nearby town used as a background or reference sample. We also collected samples from surface water, sediment and flood prone soil.

    Validated results of the November 2006 are available on EPA's BoRit website.
     
    Off-site air monitors do not show any migration of airborne asbestos fibers. The background sampling in the nearby town does not indicate higher background asbestos than normal. On-site monitoring did not detect any airborne asbestos fibers at levels that might pose an unacceptable or significant health risk. The only sampling or monitoring which showed any airborne asbestos at levels that might pose an unacceptable or significant health risk were the activity-based air samples coming from air pumps worn by the contractors as they deliberately disturbed the soil by raking.

    As mentioned above, EPA did detect low concentrations of asbestos in a few sediment samples taken from the Wissahickon Creek. However, it is difficult to accurately distinguish whether it came from the Site (i.e., the asbestos was detected in sample locations both upstream and downstream from the Site) or is a result of the area's history of asbestos manufacturing, or from other sources. In addition, EPA and the Pennsylvania Department of Environmental Protection (PADEP) ecological staff have not expressed any concerns regarding health threats to aquatic life.

    Sampling Method: EPA Region III has consulted with asbestos sampling experts (i.e., EPA Emergency Response Team, EPA's National Asbestos Technical Review Workgroup, and the Agency for Toxic Substances and Disease Registry (ATSDR) toxicologists) and they have assured us that we are conducting sampling and analyses in accordance with the current guidance.

    The method used to analyze for asbestos during the April 2006 sampling event was an approved EPA method using Transmission Electron Microscopy (TEM), which is considered the most sensitive method for analyzing asbestos air samples. All six of the air samples were analyzed by TEM. Counting fibers directly from the filter (i.e., direct preparation) is the preferred technique. Of the six air samples collected, four had too much dust/particulates to count directly so an indirect sample preparation technique had to be used for analysis of those four samples. EPA believes the filters were overloaded because the 24-hour sampling duration and sample flow volume may have been too excessive. To prevent that from happening again, the volume and duration has been reduced and the frequency of sampling has been increased for the quarterly sampling.

    Indirect and direct techniques define how the sample filters are transferred to a grid for fiber counting in the laboratory. When a sample is overloaded, it must be broken down to remove excess material on the filter to measure the asbestos sample. The direct technique is preferred when conducting human health evaluations for asbestos. However, in cases where the sample is overloaded, the indirect method can be used to interpret the sample results. Risk assessors have less confidence interpreting positive indirect results for health exposure purposes because the indirect transfer method tends to break up clusters and bundles potentially resulting in increased structure counts over the direct preparation method. Therefore, the results are reported, generally, as biased higher than what actually may be present in the sample.

    Seasonal Sampling

    The sampling events were scheduled to be seasonal, with more on-site air sampling locations and with locations in the community (there were none during the April 2006 event), activity-based sampling, and dual sample collection stations for a more comprehensive assessment of the Site.
    During the current air sampling program, we have eight sampling locations on-site and five sampling locations in the community, plus one in a nearby town used as a background or reference sample. Because air is a dynamic media, the locations of our on-site pumps are not the exact same locations as the April 2006 sampling event. However, they are in the same general area and are expected to be representative of the Site. It is more important to set samplers downwind than to be in the same exact location. During all our rounds (i.e., fall, winter, spring, summer), on-site sample locations will be based on wind direction. Community stations are permanent but weighted toward the prevailing wind direction.
     
    The only difference between the October and November 2006 sampling events was the type of activity-based sampling conducted (i.e., brush cutting and soil sampling vs. hiking and raking).

    Findings
    EPA and the public are equally interested in determining whether asbestos is being released into the environment at the Site and determining the associated health risk. Although asbestos-containing material is present on-site, the data collected thus far indicates that asbestos fibers are not getting into the environment at levels that pose an unacceptable or significant health risk to the public.

    Regarding the length of time it took EPA to provide the laboratory results of the April 2006 sampling, the analysis was performed by EPA's Ft. Meade laboratory, which performs most of the lab work for EPA Region III. After receiving the validated results from the lab, the different programs within EPA, PADEP, ATSDR, and the Montgomery County Health Department met initially to discuss the next steps for the Site. After the initial discussion, a meeting with the interested residents within the community and the surrounding area was scheduled to discuss the sampling results and the available options for the Site. Please note that since there are many agencies involved with the Site, EPA Site Assessment Office had to coordinate and confirm the availability of the involved agencies' schedules.

    Data presentation
    The results presented in the National Asbestos Data Entry Spreadsheet (NADES) are the actual test results. The NADES is a compilation of the validated results by individual sample. Technical Review Workgroup developed the NADES spreadsheet to standardize data entry and provide an electronic quality control check on data entry. The accredited lab analyzed the samples and then placed the site-specific sample results into the NADES, using the raw data. NADES is a tool to compile and capture important data from asbestos sites nationwide, in order to attain consistency.

    For a list of accredited laboratories, please go to http://ts.nist.gov/Standards/scopes/plmtm.htm

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  40. Does EPA "make up" its data? (3-12-2007)
     
    No. "Making up" or falsifying data is a criminal offense. EPA takes every possible precaution to ensure that all data is properly managed and reported to the public. Sound, scientific data is the best way EPA has to make sure that public health and the environment are protected.

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  41. Please explain the quarterly, seasonal sampling currently being conducted by EPA, including the effect of leaves and other groundcover on the fall sampling data, and EPA's choice of sampling locations. (3-12-2007)

    Seasonal sampling is done to study the effect that climate has on the ability of asbestos to become airborne. EPA is taking samples during all four seasons to help answer this question. EPA also plans to take samples under different weather conditions, such as dry, breezy days, to determine if asbestos becomes airborne. If one of the quarterly sampling rounds cannot be scheduled during dry, breezy conditions, another round of sampling will be conducted in an attempt to sample during such condition.

    The type and amount of groundcover, such as leaves, snow, vegetation, and frozen soil, are factors that can affect the opportunity for fibers to become airborne. Generally, such conditions provide protection from fiber release. When sampling, we note conditions but take no measures to remove groundcover, except minimally during activity-based sampling.

    EPA plans to take a year's worth of seasonal samples (the first one was conducted in October of 2006). There will be a minimum of two additional full (on-site and off-site) quarterly sampling rounds (spring, summer). The winter round was conducted during the week of March 5th. There will also be a round between either the winter and spring seasons or the spring and summer seasons, likely the latter. During that event between seasons, only the community sampling locations will be conducted as we are trying to determine if airborne asbestos fibers can migrate off-site into the community under the current "non-use" status of the Site.

    Fall 2006: Fall samples were taken the week of October 22, 2006.

    Winter 2007: Winter samples were taken the week of March 5, 2006. Validated results are expected sometime in May.

    Spring 2007: One round of samples will be taken in the spring. EPA will try to duplicate the April 2006 sampling event. Therefore, the spring round will be conducted the same week it was conducted last year (i.e., last week in April).

    Summer 2007: One round of samples will be taken in the summer.

    Sampling Locations: The on-site air sampling locations are selected depending on the wind direction the day of sampling, with the goal of determining what could be getting off-site. The community sampling locations were selected by dividing the Site in four quadrants; with two locations downwind from prevailing wind. They will all be fixed locations during the duration of the sampling program. EPA's goal is to determine if asbestos fibers are airborne and migrating off-site into the community. Community sampling sites which are not located downwind will provide background ambient information and will address any wind shifts during sampling.

    Soil sampling was not conducted at the pile because EPA knows the Site was used to dispose of asbestos-containing materials and past tests confirm the presence of asbestos in soils.
     
    EPA conducted soil sampling at the park to find out if there was a vegetative cover as some of the historical documents suggest. Results of samples taken from the top three inches (i.e., most likely to become airborne) suggest there is likely some kind of cover in place.

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  42. What does EPA mean when they report that "0" or "no fibers were detected" at the Site, and about the expected "background" of fibers in urban areas? (3-12-2007)

    The "0s" and "non-detected" results can be thought of this way: the laboratory that measures the levels of asbestos cannot detect asbestos below a certain amount, also known as a detection limit. Thus, if a result is "0" or "non-detect," it means the amount of asbestos was below the detection limit of the laboratory instrumentation.

    Nationwide studies (e.g., Agency for Toxic Substances and Disease Registry 2001 toxicological profile for asbestos) have shown that background rural air levels are about 0.00001 fibers/cc and background urban air levels about 0.0001 fibers/cc. Before sampling was done in the fall of 2006, EPA toxicologists set an ambient air sample detection limit of 0.0005 fibers/cc and a personal air sample detection limit of 0.003 fibers/cc for the Site. EPA considers these levels sufficient to make public health and risk decisions. The levels that registered as "0" or "non-detect" were below these detection limits.

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  43. What does the term "fatal error" mean on the National Asbestos Data Entry Spreadsheet (NADES)?  (3-12-2007)

    The term "fatal error" appears on the NADES because the laboratory identified structures in the sample that were non-asbestos material. In the raw data, these entries are coded as non-asbestos material (NAM), and additional identification of the material was provided (e.g. gypsum). The laboratory did not include the fiber dimensions of the NAM, therefore the NADES classified the missing fiber dimensions as "fatal error."

    EPA emphasizes that although the term "fatal error" sounds like a problem occurred, on the NADES for this sampling it means only that NAM was detected in the sample. The spreadsheet is working properly to exclude these entries in the concentration values.

    NADES was developed as an internal EPA and laboratory tool and not initially intended for public use. EPA is currently working to clarify this information in NADES for future sampling events.

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  44. Why are the "analysis dates" incomplete on the National Asbestos Data Entry Spreadsheet (NADES)? (3-12-2007)

    The NADES is an Excel spreadsheet. One of the quirks of Excel is that it fills in truncated numbers with "#s" rather than show you the actual value which might be truncated due to insufficient column width to show the whole number.

    This issue can be resolved by increasing the column width in the analysis date column or decreasing the font size. EPA is currently working to correct this information in NADES.

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  45. Are fencing and signs sufficient at the Site, given the results of the tests performed by EPA? (1-24-2007)

    To date, EPA has based its health risk evaluations for the Site on tests performed using validated results from an accredited lab. Based on the existing results, the fence and posted signs may suffice to prevent exposure. All the results showed that there is no off­-site migration of airborne asbestos and that to be exposed you would have to get on-site and start disturbing the soils. The fence and signs are there to deter trespassers and prevent that from happening.

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  46. Is the data that EPA provides to the public complete and accurate and does the public have access to the documents during public meetings? (1-24-2007)

    Yes. EPA bases its decisions upon validated data, and EPA's general policy is to release validated data to the public. EPA considers validated data to be the "complete" data for a given sampling event.

    EPA is providing accurate scientific analysis of the Site and consulted with national experts on asbestos sampling (i.e., EPA (Environmental Response Team, National Technical Review Workgroup, Agency for Toxic Substances and Disease Registry toxicologist) before the quarterly sampling events to give the greatest assurance that we are conducting sampling and analyses in accordance with the current guidance.
     
    In some cases, such as the case with the October and November 2006 results at this Site, it is not practical to provide a printed copy of large documents to the public. However, EPA makes them available to the public on its website and upon request through the Freedom of Information Act request. Our practice is to provide such documents to citizens at their request, subject to limited exceptions including business confidentiality and privacy concerns.

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  47. How many tests were performed for the water and sediment during last year’s testing? (unknown date, 2007)

    6 surface water samples were taken on. April 27, 2006.
    9 surface water samples were taken on November 30, 2006.
    All results for these tests and the maps mentioned are freely available on the BoRit Website. (www.epaosc.org/borit) and have been publicly released for some time.

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  48. Has there been recent sampling or is any planned? (9-2006)

    Yes, EPA and the Pennsylvania Department of Environmental Protection (PADEP) are working together to conduct sampling of the area and plan to stabilize some of the eroded stream bank areas to prevent migration of asbestos containing material. Initial sampling was conducted in April 2006, however air-monitoring results were inconclusive. Additional sampling is planned while the stabilization work is completed. A public meeting to discuss this planned activity is scheduled for October 5, 2006 from 6-9:30 p.m. at the Wissahickon Middle School, 500 Houston Street in Ambler.

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  49. Is EPA concerned about the trace amounts of Amphibole fibers that were detected from this March testing event? (Unknown Date)

    EPA is primarily interested in the fibers identified by the PCME counting method as that method identifies fibers used for conducting health risk assessments. We are looking for all types of asbestos fibers including chrysotile, amphibole and other types. The website for the BoRit Site provides an explanation of the analytical techniques used.

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  50. The CAG asked EPA to work with Ambler Borough to conduct pump testing on the public water supply well to determine if groundwater beneath the site could influence the public water supply.  What was the outcome of that request?

    EPA received a request from the CAG to conduct a pump test. For the following reasons EPA does not plan to perform a pump test between the on-site groundwater monitoring wells and a water supply well.

    The current information on groundwater does not provide EPA with evidence that groundwater at the site is influenced by a local public water supply program that would require additional investigation. The information EPA has gathered indicates that the water supply well is up-gradient; at a significant depth; operates occasionally; and pumps at a low rate.

    EPA has followed a step-wise approach to evaluating the groundwater at the BoRit site.  EPA's groundwater evaluation established the depth and levels of groundwater; the direction of groundwater flow; and characterized the quality of the groundwater at the BoRit site.

    As part of the Remedial Investigation at the BoRit site EPA installed six groundwater wells and tested the groundwater for a comprehensive list of parameters (volatile organic compounds, semi-volatile organic compounds, PCBs, pesticides, metals, and asbestos). The groundwater sampled at BoRit is in a shallow bedrock zone. EPA did not identify a plume of groundwater contamination, but generally isolated groundwater detections. The groundwater and surface water levels were measured five times over a year and the water levels remained at consistent levels. Additionally, based on these water level measurements the groundwater flows in a north to south direction or from Maple Street to the Wissahickon Creek.

    EPA is planning additional groundwater work as part of the Remedial Investigation. EPA plans to sample the six on-site groundwater monitoring wells three more times. EPA plans to install a groundwater well off-site and sample it to establish groundwater quality for comparison purposes. EPA will also measure the level of groundwater and surface water.  EPA will include the results from the groundwater investigation in the RI Report.

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