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BoRit Questions & Answers - Site Management/Oversight

BoRit Questions & Answers Main Page

  1. Some of the old asbestos factory buildings are currently in use by other businesses. Did EPA ever test these buildings and surrounding grounds for residual asbestos contamination? Were these buildings ever cleaned up and are they safe? (7-3-2010)

  2. Will EPA address the pieces of asbestos containing materials along the Wissahickon Creek as part of its remedial investigation study? (6-2-2010)

  3. Is EPA doing the best possible investigation and clean up at the BoRit site? (6-2-2010)

  4. Why is EPA using the National Emissions Standards for Hazardous Air Pollutants (NESHAP) law which has not evolved as the stricter asbestos regulations have evolved? (6-2-2010)

  5. What steps is EPA taking to address the asbestos contamination? (6-2-2010)

  6. Can asbestos fibers come up through the dirt cap on the Whitpain Park? (8-13-2009)

  7. Can the water truck sufficiently wet down dust during grubbing and tree removal? (8-10-2009)

  8. How many asbestos cleanups have been done in this region and what is the role of the EPA On-Scene Coordinator (OSC) and EPA’s contractor? (9-5-2008)

  9. What does the EPA mean when they state that water will be used as dust suppression on an as-needed basis? (9-5-2008)

  10. What are the prevailing wind directions over the site? (9-5-2008)

  11. What does the EPA mean in the Pollution Report 1 when they state that "asbestos and asbestos tiles are easily seen throughout the entire site?" (1-2008)

  12. What does the Army Corps of Engineers mean when they state "Both friable and bound asbestos-containing material (pipes, rings and shingles) are visible along the banks of the three streams?" (1-2008)

  13. Why didn’t EPA use the Shaw Environmental and Infrastructure report to evaluate the BoRit site for the National Priorities List (NPL)? (1-2008)

  14. Why was the BoRit site moved from EPA’s Site Assessment Program over to EPA’s Removal Program? (1-2008)

  15. Does EPA have the expertise to implement the right cleanup for the site? (12-27-2007)

  16. Will the community be provided with status updates on the execution and monitoring phases of the encapsulation and removal process? (12-27-2007)

  17. Who will manage the removal and encapsulation actions? (12-27-2007)

  18. Does the removal action preclude the site from being listed on the National Priorities List (NPL)? (12-27-2007)

  19. Who is responsible for the contamination? (12-27-2007)

  20. What is the nature of EPA's current response to the BoRit Site? (8-8-2007)

  21. Is the BoRit Site being considered for EPA's National Priority List (NPL)? (5-1-2007)

  22. What is EPA's role at the BoRit Site? What issues and concerns will EPA address as part of the Removal Action? (3-12-2007)

  23. Does EPA have a cleanup plan or Record of Decision (ROD) for the Site? (3-12-2007)

  24. Why is EPA involved in the BoRit site and how are they addressing it? (1-24-07)

  25. Does EPA have a cleanup plan for the site? (1-24-2007)

  26. How does EPA work with contractors and what work is being done by EPA contractors (i.e., Lockheed Martin and Tetra Tech)? (1-24-2007)

  27. How often was the BoRit site inspected and by whom? (9-2006)

  28. What prompted the environmental ranking noted in the Shaw Report? (9-2006)

  29. How can the creek be considered a barrier if individuals are using that route to access the site?  (9-2006)

  30. Where did the contamination in the buildings go? How were they remediated before demolition and who mediated them?

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  1. Some of the old asbestos factory buildings are currently in use by other businesses. Did EPA ever test these buildings and surrounding grounds for residual asbestos contamination? Were these buildings ever cleaned up and are they safe? (7-3-2010)

    The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund) law 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 CERCLA 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. As previously mentioned, some of the buildings adjacent to the Ambler Asbestos Piles 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 were abandoned, the Pennsylvania Department of Environmental Protection (PADEP) became the primary enforcing agency. PADEP and EPA have been working with property owners and developers to restrict access to some of these buildings. Additionally, EPA conducted air sampling in the former Keasbey and Mattison buildings in June 2010 due to concerns raised by the community. EPA is awaiting receipt of the analytical results, and will share this information with the community.

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  2. Will EPA address the pieces of asbestos containing materials along the Wissahickon Creek as part of its remedial investigation study? (6-2-2010)

    To mitigate public exposure from the debris along the creek, beginning this summer, when water levels are expected to be low (shallow), EPA is planning to remove waste material along the Wissahlckon Creek, beginning at Mt. Pleasant Avenue and moving downstream. Furthermore, EPA is planning on conducting stationary and activity-based sampling at the area downstream of Butler Pike (near the Wissahickon Valley Watershed Association offices), where asbestos-containing material has deposited, to determine if the waste there poses current or future risk to human health, or the environment.

    As part of our evaluation of the BoRit Site, EPA is conducting a Remedial Investigation (RI) to determine the full nature and extent of contamination. Currently, EPA has just finished Phase I of the RI, which included soil, waste, surface water, and sediment sampling (with some nearby flood plain samples). EPA is currently in the process of putting together a report summarizing this information.  EPA has just begun scoping the extent of the Phase II investigation and is hoping to conduct this sampling in late summer/early fall 2010.

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  3. Is EPA doing the best possible investigation and clean up at the BoRit site? (6-2-2010)

    EPA is using Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) authority to address the conditions at the BoRit Site. We are using Removal authority to deal with the imminent risks that have been identified, and we are conducting a Remedial Investigation to evaluate the long-term threats. Our efforts are intended to move quickly to address the imminent risks.

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  4. Why is EPA using the National Emissions Standards for Hazardous Air Pollutants (NESHAP) law which has not evolved as the stricter asbestos regulations have evolved? (6-2-2010)

    EPA acknowledges that some states' asbestos regulations may be more strict than the federal requirements. The Pennsylvania Department of Environmental Protection has adopted the EPA regulations as set forth in the NESHAPs. Regarding the comment that "EPA is posturing to keep this pollution here," EPA Region 3 has explained that the Superfund remedial process requires that EPA review different options for addressing the site during a Feasibility Study (FS), and publish the final agency decision in a Record of Decision, after considering public comments. EPA has not yet performed a FS at the Site, but when it does, EPA will carefully review, and explain its rationale for choosing or rejecting, each alternative.

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  5. What steps is EPA taking to address the asbestos contamination? (6-2-2010)

    Since July 2008, EPA has been conducting a removal action at the Site. Activities have included stabilizing the creek banks, with clean fill, to prevent further erosion and potential migration of asbestos into adjacent waterways. Areas on the BoRit Site in which asbestos-containing material (ACM) pieces were washed out have been addressed.

    EPA and the Agency for Toxic Substances and Disease Registry are aware that pieces of asbestos containing waste material (such as pieces of old pipes) are present in scattered areas offsite. Exposure to asbestos is a concern if you inhale the tiny fibers. The ACM on the ground is not a concern unless the fibers become airborne. To date, air monitoring in the community has not shown levels of concern related to asbestos. However, to mitigate public exposure from the debris along the creek, beginning this summer, when water levels are expected to be low (shallow), EPA is planning to remove waste material along the Wissahickon Creek, beginning at Mt. Pleasant Avenue and moving downstream. Furthermore, EPA is planning on conducting stationary and activity-based sampling at the area downstream of Butler Pike (near the Wissahickon Valley Water Association offices), where ACM has deposited, to determine if the waste there poses current or future risk to human health or the environment.

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  6. Can asbestos fibers come up through the dirt cap on the Whitpain Park? (8-13-2009)

    The physical properties of asbestos are the reason that asbestos is not expected to move through soil. It is a mineral (i.e. rock) and dense, having a specific gravity typically reported as ranging between 2.0 and 3.5 (two to three times heavier than water) depending on the mineral variety. Asbestos is made up of fibers and although the fibers and fiber fragments can be microscopic, these particles are still large, complex molecules in the microscopic environment. The fibers are not soluble and therefore can not be transported in a water solution like other, smaller contaminant molecules and ionic species. The particles are also too large to be transported preferentially by other physical-chemical processes like diffusion. Therefore, asbestos fibers tend to remain stationary within the soil matrix. In other words, in a natural soil setting asbestos fibers do not move through the soil.
     
    An analysis published by EPA in April 1977, Movement of Selected Metals, Asbestos, and cyanide in soil: Applications to waste disposal Problems, EPA Publication Number EPA-600/2-77-020, describes the potential for asbestos movement through soil. Although the author, Dr. Wallace H. Fuller, recognizes the paucity of data specific to asbestos, he argues that asbestos is reasonable expected to behave like similarly sized clay particles, which have been extensively studied.

    "Although there are no data on mobility of asbestos in soil, predictions about its behavior can be made with reasonable confidence. Since the weathering products of asbestos are the common nonhazardous salts of Ca, Mg, and Si, physical transport is the only mode of movement in soil which is of significance. The extensive data on movement of clay-sized (<2u diameter) particles by strictly physical processes provide a convenient yardstick for gauging the probable behavior of asbestos in soil. Clay particles 0.1 to 2.0 uin diameter are estimated to move at a rate of 1 to 10 cm per 3,000 to 40,000 years, depending on the soil texture (Berkland, 1974). There is no reason to expect that asbestos particles of similar size would move differently from this. Consequently asbestos migration through soil will not be a problem of any significance."

    It can be added that larger particles (i.e. the longer fibers of the asbestos minerals) are expected to be even more resistant to movement due to physical impedance.

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  7. Can the water truck sufficiently wet down dust during grubbing and tree removal? (8-10-2009)

    The dust suppression efforts during the clearing and grubbing activities were effective, as is evident in the air monitoring and sampling data. Please visit the EPA website at http://www.epaosc.org/borit for all air monitoring and sampling data.

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  8. How many asbestos cleanups have been done in this region and what is the role of the EPA On-Scene Coordinator (OSC) and EPA’s contractor? (9-5-2008)

    The only remediation of a large asbestos pile conducted in EPA Region III was done years ago. The job of the OSC is to coordinate site activities and coordinate efforts with other Federal, State, and Local agencies. The OSC relies on the expertise of the Site team when making any determination.  At the BoRit Site, the team includes representatives from EPA's Environmental Response Team and their contractor, the Agency for Toxic Substances and Disease Registry, the Army Corps of Engineers, the Pennsylvania Department of Environmental Protection (PADEP), the Pennsylvania Department of Health, Montgomery County Health Department and our technical support (START) and cleanup (ERRS) contractors.

    EPA's cleanup contractor has over 25 years experience in performing consulting and contracting services relating to non-friable and friable asbestos-containing materials. This experience includes preparation of building, facility and roof ­asbestos surveys, asbestos abatement, asbestos abatement project monitoring and transportation and disposal of asbestos-containing materials on hundreds of projects in various states throughout the United States.

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  9. What does the EPA mean when they state that water will be used as dust suppression on an as-needed basis? (9-5-2008)

    The water truck is on-site and used during dry weather conditions. During wet conditions (on and off rain, thunderstorms) there is no need to use the water truck. The idea of the water suppression is to keep the dust to a minimum, not to create mud.

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  10. What are the prevailing wind directions over the site? (9-5-2008)

    Most of the time, the wind comes from either the SW or the NW, sometimes out of the SE.
    We have a weather station on-site running 24/7. It gives us precipitation, relative humidity, wind direction and wind velocity. All the wind roses are posted in the documents section of the website.

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  11. What does the EPA mean in the Pollution Report 1 when they state that "asbestos and asbestos tiles are easily seen throughout the entire site?" (1-2008)

    It means that there is visible evidence of asbestos-containing materials on-site.

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  12. What does the Army Corps of Engineers mean when they state "Both friable and bound asbestos-containing material (pipes, rings and shingles) are visible along the banks of the three streams?" (1-2008)

    The statement means that the Corps observed friable (easily crumbled) asbestos as well as asbestos bound up in other materials like those mentioned.

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  13. Why didn’t EPA use the Shaw Environmental and Infrastructure report to evaluate the BoRit site for the National Priorities List (NPL)? (1-2008)

    There are 2 reasons why the Shaw report is not a viable tool for evaluating the site for the NPL listing.
    1. The Shaw report is based entirely on projected or possible release potential, not on actual test data or sampling.
    2. The scoring system used by Shaw, PA Score, was superseded in 1995 by QuickScore. PA Score was rendered obsolete because it was deemed an ineffective tool which artificially inflated potential NPL scores.

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  14. Why was the BoRit site moved from EPA’s Site Assessment Program over to EPA’s Removal Program? (1-2008)

    EPA’s Site Assessment Program requested that the Removal Program investigate the site. The Site Assessment Manager felt that more information was required and that the Removal Program had the best means of providing the needed sampling and technical expertise.

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  15. Does EPA have the expertise to implement the right cleanup for the site? (12-27-2007)

    Yes. EPA has the expertise to ensure that appropriate engineering controls will be employed to protect human health and the environment.

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  16. Will the community be provided with status updates on the execution and monitoring phases of the encapsulation and removal process? (12-27-2007)

    EPA plans to post updates of the actions on its website. In addition, there will be a Community Involvement Coordinator on-site on a regular basis to answer any questions the community may have. EPA also plans to keep the Community Advisory Group informed of our progress.

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  17. Who will manage the removal and encapsulation actions? (12-27-2007)

    The overall management of the removal work falls on the On-Scene Coordinator assigned to the site.

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  18. Does the removal action preclude the site from being listed on the National Priorities List (NPL)? (12-27-2007)

    The removal action does not preclude the site from being evaluated for listing on the NPL and the process of NPL listing continues parallel to the removal process.

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  19. Who is responsible for the contamination? (12-27-2007)

    EPA intends to thoroughly evaluate all Potential Responsible Parties at this Site, and their viability.

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  20. What is the nature of EPA's current response to the BoRit Site? (8-8-2007)

    EPA is currently conducting a removal assessment to determine if the site, in its current state, poses a health threat to the community. So far, based on the October/November 2006 and March/May 2007 air sampling results, and our current evaluation of the potential for human exposure, the Site does not. When EPA initiated the response action in August 2006, we believed that erosion from the banks of the pile could pose a potential threat to public health. Subsequent evaluation has led us to take a more deliberate approach to determining the need for mitigative measures at the Site. We have expanded our sampling and analysis to support this approach.

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  21. Is the BoRit Site being considered for EPA's National Priority List (NPL)? (5-1-2007)

    Currently, EPA's Removal Program is gathering additional data to be used for determining if there is a release associated with the Site. The results of the sampling events will also be reviewed by EPA's toxicologists and personnel from the the Agency for Toxic Substances and Disease Registry. After completion of the sampling events, the Site will be reviewed for placement on the NPL, if appropriate.

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  22. What is EPA's role at the BoRit Site? What issues and concerns will EPA address as part of the Removal Action? (3-12-2007)

    EPA's primary concern at this Site is to ascertain whether the community is being exposed to asbestos at levels that present an unacceptable health risk, and if so, to take appropriate action. To do this, EPA is using its authority under the Removal Program to take samples that will help determine if an actual threat exists.
     
    The Removal Program allows EPA to take immediate actions in response to a release, or threat of release of a hazardous substance, pollutant or contaminant that may present an imminent and substantial danger to the public health or welfare. For more detailed information about EPA's Removal Program, go to http://www.epa.gov/superfund/resources/emer_res.htm.

    At the BoRit Site, the Removal Program is conducting a Removal Assessment to determine what next steps, if any, are warranted based on the sampling results being collected. Thus far, the ambient air sampling results from October and November 2006 indicate that 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. Nonetheless, we plan to continue the quarterly air sampling program, at least through the summer of 2007, to investigate whether changes due to seasonal variations are occurring. 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 Priority Listing consideration) or determine that no further action is necessary. (At the time this question was asked, the Site was not on the NPL.  It has since been added to the NPL).

    Based on the April 2006 validated results, EPA believed that stabilization of the banks and covering some bare portions of the Site was an immediate necessary action to prevent erosion into Wissahickon Creek. However, based on the recent validated results (i.e., October and November 2006) no off-site asbestos migration has been found at levels that might pose an unacceptable or significant health risk. EPA continues to look into different alternatives (e.g., applying some sort of stabilizing agent to the banks that appeared to be eroding into the stream). To date, EPA has not identified an agent that would be suitable for the Site. In addition, EPA is currently reviewing the different long­ term stabilization alternatives the U.S. Army Corps of Engineers recommended for the Site. The report is posted on EPA's BoRit website.

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  23. Does EPA have a cleanup plan or Record of Decision (ROD) for the Site? (3-12-2007)

    EPA has not prepared a cleanup plan because we are still in the assessment phase of the project. If a cleanup is needed, EPA will prepare a cleanup plan which will be presented to the community.  EPA expects to make a decision after all the sampling is complete. We expect to complete the sampling this summer.

    EPA did prepare sampling plans for testing the air, water, sediments and soil and those plans are available on its BoRit website.

    A ROD is the legal document that memorializes EPA's final cleanup plan for all Superfund sites listed on the National Priorities List (NPL). The BoRit Site is not listed on the NPL; therefore a ROD would not be issued for the Site. (At the time this question was asked, the Site was not on the NPL.  It has since been added to the NPL).

    For more information about the NPL process, please go to http://www.epa.gov/superfund/sites/npl/npl_hrs.htm

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  24. Why is EPA involved in the BoRit site and how are they addressing it? (1-24-07)

    It is EPA's mission to protect human health and the environment. In the Removal Program, EPA takes actions in response to a release or threat of release of a hazardous substance or of a pollutant or contaminant that may present an imminent and substantial danger to the public health or welfare.

    When notified of a release or threat of release that may require a removal action, EPA conducts a removal site evaluation to determine the source and nature of the release, the threat to public health and the environment, and whether an appropriate response has been initiated. A removal site evaluation could be completed in minutes or months, depending on the specific incident and the information available to determine the need for a removal action. When the removal site evaluation is completed, EPA reviews the results and other factors to determine the appropriate extent of a removal action. At any point in this process, EPA may refer the site for further evaluation or determine that no further action is necessary. When it concludes that a removal action is required, the EPA undertakes an appropriate response to minimize or eliminate the threat.

    EPA presently is still in the removal evaluation part of the process at BoRit; EPA is trying to determine if the Site poses a health risk to the community "as is." EPA intends to finish the sampling program and then make a determination as to what actions, if any, are needed.

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  25. Does EPA have a cleanup plan for the site? (1-24-2007)

    EPA did prepare a written plan to evaluate the air, water, and soil and will prepare a remediation plan should it be necessary. EPA will not make a final determination about that until it finishes the sampling program which will continue through the summer of 2007.

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  26. How does EPA work with contractors and what work is being done by EPA contractors (i.e., Lockheed Martin and Tetra Tech)? (1-24-2007)

    EPA awards regional and national contracts every five years or so. EPA then uses these contractors for work at individual sites. EPA works with these contractors to develop a scope of work to be performed at each site.

    The scope of work EPA prepared for air sampling for this Site is contained in the Quality Assurance Project Plan Sampling Plan, dated October 19, 2006. The scope of work for the soil, sediment and surface water sampling is contained in the Sampling and Analysis Plan, dated December 11, 2006. Both documents are posted on the EPA's website.

    Lockheed Martin (LM) is EPA Environmental Response Team’s contractor and Tetra Tech is EPA Region III contractor. As our contractors, they subcontract the laboratories to perform the analysis for EPA in accordance with the scope of work. EPA does not provide a scope of work directly to subcontractors such as the laboratories used at this Site.

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  27. How often was the BoRit site inspected and by whom? (9-2006)

    The Pennsylvania Department of Environmental Protection (PADEP) has been inspecting these sites on a yearly basis at minimum, with more frequent routine site visits in response to citizen concerns.

    The BoRit and Reservoir sites were inspected together approximately 17 times during the years 2000-2005, with eight of these inspections conducted in 2005. Violations outlined in notices of violations dated February 2001 and April 2002 have been corrected. More recently, a notice of violation dated December 29, 2005 was issued to Kane Core for a section of fencing in disrepair on the BoRit Site. On January 27, 2006, PADEP issued a notice of violation to the Reservoir site owner since the Maple Street entrance gate was observed lying on the ground during a site visit the previous week. These violations have not been corrected as of early February 2006.

    The Wissahickon Park (a.k.a. Whitpain Park) site was inspected by PADEP approximately 23 times during the years 2000-2005, with eight site visits conducted in 2005. No violations or notices were issued for this site.
     
    In addition to PADEP Air Quality staff, these sites have been inspected by PADEP's Environmental Cleanup Program staff and by representatives of EPA. In April 2005, a large-scale multi-agency inspection was conducted at the BoRit Site. No visible emissions were noted, although we did confirm that many of the warning signs had been removed from the perimeter fencing. To prevent future removal of these signs and correct the problem, the property owner reposted warning signs on poles inside the fence area, which PADEP noted have been removed again by vandals in September 2006. EPA advised Kane Core on Sept. 15, 2006 that additional warning signs were needed along the Maple Street side of the property and is following up on this matter.

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  28. What prompted the environmental ranking noted in the Shaw Report? (9-2006)

    In March 2003, the Pennsylvania Department of Environmental Protection (PADEP) commissioned Shaw Environmental, an environmental contractor, 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. The calculated score or ranking is a tool utilized in the Preliminary Assessment (PA Score) process. At that time, the PA Score was the first step in the process leading to the development of the Hazard Ranking System (HRS) package. In calculating this preliminary score for the BoRit Site, the contractor made assumptions, some of which may not have been supported at that time or reflect the present status of the site. This was a draft document, one which PADEP did not get the chance to review in-depth or comment upon, as our agency review stopped once the previous property owner, DEAP, purchased the site with interest in remediation using private funds through Pennsylvania's Act 2 process. Since that time, there have been consistent efforts by private individuals to remediate and reuse the site.

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  29. How can the creek be considered a barrier if individuals are using that route to access the site?  (9-2006)

    The federal regulations allow natural barriers to be used in lieu of fences. By "deter," it's meant the barrier should discourage access to the site. We acknowledge that most of the Ambler sites can be accessed, even with fencing in place if an individual is intent on gaining access. We may revisit the barrier issue at some point in the future, but ask in the meantime that people be mindful that these sites are private property. To gain access through the fencing or by way of the creek bed is considered illegal trespass.

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  30. Where did the contamination in the buildings go? How were they remediated before demolition and who mediated them?

    All of the regulated ACM was removed from the buildings prior to demolition.  This waste was then shipped to landfills licensed to accept this type of waste (Minerva Enterprises in Waynesburg Ohio and Chester County Landfill in Honeybrook PA).

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