PHONE 215.692.3030 TElEK 83 · 2020. 12. 12. · VVE5TONWAWEST CHESTER pY« 19380 PHONE 215.692.3030 TElEK 83.5348 May 16, 1989 Hector Abreu U.S. Environmental Protection Agency 841

VVE5TONWAYWEST CHESTER p« 19380PHONE 215.692.3030TElEK 83.5348

May 16, 1989

Hector AbreuU.S. Environmental Protection Agency841 chestnut Building, 6th FloorPhiladelphia, PA 19107Project: REM II - EPA Contract No. 68-01-6939Work Assignment No.: 123-3L96Document Control No.i 223-C01-EP-HCMTSubject: Ambler Asbestos Piles Site

Summary and Review of CertainTeed EnvironmentalInvestigation Report

Dear Hector:

Enclosed is the REM II "Summary and Review of the CertainTeedEnvironmental Investigation Report". This report was prepared byApplied Geotechnical and Environmental Services Corp. (AGES) for

O t h e CertainTeed Corporation, the owners and PRP for theCertainTeed Pile Site portion of the Ambler Asbestos Piles Site.In our summary and review we have outlined some additionalrecommended RI work and suggested a course of future actionsregarding completion of RI/FS activities at this portion of thesite (now identified as Operable Unit 2).This is the final REM II deliverable under the Ambler AsbestosPiles RI/FS work assignment.It has been a pleasure working with you on this project over thepast 4+ years. As you are aware, we will be providing testimonywith you under the TSS contract at the upcoming hearings.Please contact me at any time in the future if I can be ofassistance. Thank you.

Very truly yours,

J cc: S. Del Ra (USEPA)G. Johnson (HESTON)D. Arthur (HESTON)D. Pohl (HESTON)S. Paquetta (CDN FPC)NPMO Document Control

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SUMMARY AND REVIEWOF THE

CERTAINTEED ENVIRONMENTAL INVEST/CATION REPORTFOR THE CERTAINTEED ASBEOTOS PILE

(Pipe Plant Dump - Operable l/it 2 of theAmbler Asbestos Pile/ Site)

May 1989

oWork Assignment No. 123-3L96 ^Document Control No. 223-C01-EP-HCVU

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SUMMARY AND REVIEWOF THE

CERTAINTEED ENVIRONMENTAL INVESTIGATION REPORTFOR THE CERTAINTEED ASBESTOS PILE

(Plant Pile Dump - Operable Unit 2 of theAmbler Asbestos Piles Site)

May 1989

Work Assignment No. 123-3L96Document Control No. 223-C01-EP-HCCM

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Summary/Review - CertainTeed El t̂0

1.0 INTRODUCTION

The Pipe Plant Dump, also known as the "CertainTted)/&bestos Pilesite" (as referenced in this document), is looatejjrsoutheast andadjacent to the "Nicoleti" Asbestos Piles in AmbJrer, Pennsylvania(see Figure 1-1). This site (approximately ŝ acres) is furtherbounded on the west by the Hissahickon Creekrand its floodplain,on the southeast by Church street, and on^he east by the SEPTAcommuter rail line. The CertainTeed sitjras veil as the Nicoletsite were included as a part of the ArabLer Asbestos Piles site onthe National Priorities List (NPL) on /une 10, 1986. Listing onthe NPL requires the completion of tlRemedial Investigation andFeasibility study (RI/FS) in o/ler that an EndangernentAssessment (EA) can be completed fo/ the site. The RI/FS for theNicolet site was completed and thy final report (Ambler AsbestosPiles RI/FS Report) was submit/ed to the U.S. EnvironmentalProtection Agency (USEPA) in August 1988. A Record of Decision(ROD) was completed for this site in September 1988. The Nicoletsite which includes the Locu/t Street Pile, Plant Pile, andAsbestos filter-bed lagoons hai been identified as Operable Unit1 of the Ambler Asbestos Pil/s site. The CertainTeed Pile hasbeen designated separately Is Operable Unit 2 of the AmblerAsbestos Piles site, A separate RI was to be conducted by theCertainTeed Corporation, the/Potentially Responsible Party (PRP)for the CertainTeed Pile, lased on the findings of this RI, anEndangernent Assessment (EAjf and Feasibility Study (FS) are to beprepared.

CertainTeed Corporation, as! stipulated by USEPA, has submitted tothe EPA Region 3 (Janlary 30, 1989) a report entitled"CertainTeed Environmental! Investigation" (El), The El reportwas prepared for the CertainTeed Corporation by the firm AppliedGeotechnical and Environmental Service Corp. (AGES) of ValleyForge, Pennsylvania. A tlrk plan for the El was submitted andapproved by EPA prior to commencement of field activities. The

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SITE LOCATION MAP

CERTAINTEED ASBESTOS SITE

AMBLER, PENNSYLVANIA

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Summary/Review - CertainTeed El

oEl report dated January 1989 includes a description of fieldsampling activities, a summary of analytical results, anjconclusions and recommendations section.

The purpose of this document is to provide a sunuuffy/review bythe REM II tean — the authors of the Nicolet sĴ e RI/FS Report— of the results of the CertainTeed Ê and to providerecommendations regarding the completion of/the EA and FS forthis operable unit.

1.1 SITE BACKGROUND (Taken from the" REM II Ambler AsbestosPiles Site RI/FS Report, addressing the Nicolet site)

The Pipe Plant Dump or CertainTeed Vile operated as a pipe scrappile from 1962 to 1977. The two/types of manufacturing wastematerials disposed of at the site^onsisted of a 51 solids sludgeand asbestos-cement scrap. The dblids sludge was composed of 32*calcium carbonate,651 hydrated Jcement and silica, less than 2*asbestos, and approximately ii miscellaneous components. Theasbestos-cement scrap originat/d mainly fron reject pipe and pipelathe turnings fron the ftipe finishing operations. Theasbestos-cement waste consisted of a mixture of 10-201 asbestosfiber interlocked within t 80-90% calcium silicate complexmatrix. The total volune of/the CertainTeed pile is estimated tobe approxinately 110,000 culic yards.

The disposal of the wast* sludge discontinued in 1974 aftermethods for recycling the taste were adopted. The portion of thesite used for sludge disposal was then covered and vegetated.The dumping of pipe waste! was discontinued in 1977 in accordancewith the conditions of Rhe "consent order" with EPA and thePennsylvania Department If Environmental Resources (PADER). Atthis time the remaining! portion of the pile was covered andvegetated. Aerial photographs froa 1958, 1964, and 1971 (seeAmbler Asbestos Piles (AAP) RI/FS Report - Figures 1-10, 1-11,

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oand 1-12) indicate no activity at the Certainteeed Pile siteprior to 1958 and active use in 1964 and 1971. The aerial photoof the site in 1978 (AAP RI/FS Report - Figure 1-13) indicates avegetated cover was established over most of the pile by thattime.

1.2 PREVIOUS INVESTIGATIONS

on November 11, 1985, the CertainTeed Pile was inspected by U.S.EPA, PADER, HESTON and CertainTeed Corporation. The cover on thepile was found to be in relatively good condition and wellvegetated. Little evidence of erosion and scouring was observedalong the south side by the stormwater drainageway. Theobservations indicated a low potential for future pile stabilityproblems and/or cover loss. It was decided by U.S. EPA and PADER

,:Q that surface water and sediment samples of the drainageway andwater samples from the shallow aquifer under the floodplain areaadjacent to Hissahickon Creek would be taken by the EPA FIT teamto verify that no contaminants of concern were migrating fromthis source.

On May 12, 1986, the NUS FIT III team took five (5) water samplesfrom Stuart Farm Creek adjacent to and southeast of theCertainTeed site. Figure 3-8 (AAP - RI/FS Report) presents thesurface water sampling locations. The samples were analyzed byTransmission Electron Microscopy. Chrysotile asbestos fiberswere detected both upstream and downstream of the closed dump.The average concentration of two aqueous saiples both upstreanand downstrean was 42 MFL. (EPA ambient wattr quality criteriaassociated with a lifetime cancer risk of 10*) is 0.3 MFL).

Chemical analyses were also ' performed on the stream samples.•Ji Measurable anountt of calcium (60 ppm), lodiun (30 ppn),

magnesium (15 ppn), and potassium (3 ppi) were found bothupstrean and downstrean.

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2,0 REVIEW OF THE CERTAINTEED ENVIRONMENTAL INVESTICATION(January 1989)

An Environmental Investigation was conducted in/1988 for theCertainTeed Pile by AGES Corporation undenr contract withCertainTeed Corporation in accordance with tbe requirements setforth by the USEPA on August 10, 1987 for tafie PRP of this site.The scope of the CertainTeed El included surface water, sedimentand waste test pits sampling and analysis, construction ofborings and piezometers in the waste /ile, cover soil samplingand analysis, OSHA-mandated perso/nel air sampling, andpreparation of a report summarizing /he results of the field andanalytical program.

The results of the El are briefly summarized below and theconclusions/findings of the stud/ are reviewed. Potential datagaps are identified and recommendations regarding furtherRI activities are presented herein.

2.1 SUMMARY OF RESULTS OF/ENVIRONMENTAL INVESTIGATION

The results of the field anj analytical testing programs aresummarized in the following subsections.

2.2.1 Surface Hater and Sldiment Sampling Results

Two upstreai surface water end sediment samples (samples S-l,S-2), one directly adjacent (sample S-3) and two downstrean(samples S-4, s-5) where taken from Stuart Fan Creek that flowspast the southeastern perimeter of the CertainTeed Pile.Sampling procedures are outlined in sections 3.1 and 3.2 of theCertainTeed El report datedlJanuary 1989. A sample location map(Site Sampling Plan map) is presented as Figure 2-1.

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oA summary of the volatile and semi-volatile compounds detected inthe surface water samples is presented in Table 2^r A review ofthe surface water data indicates that the yKy volatile andsemi-volatile organic compounds (samples Jlete analyzed for >priority pollutant volatile and semi-volatile organic compounds)detected in the downstream samples were tatrachloroethene (sampleS-3) and bis-(2-ethylhexyl)phthalate which were also detected atequal or higher concentrations in upstxeam samples. The resultsindicate that the CertainTeed Pile is/not a source of volatile orsemi-volatile organic contamination/to the adjacent Stuart FarmCreek.

Inorganic analysis results for stream samples are summarized onTable 2-2. Surface water analy/ical results are also summarizedon Table III of the CertainTeed/EI Report. (It is noted that theunits for metals concentrations in Table III should read "ppb"not "ppm"). Both copper and /inc were detected at concentrationsabove published background /levels and ambient water qualitycriteria in the furthest upgradient sample (sample s-l), thesample adjacent to the CerfainTeed Pile (sample S-3) and at afurther downstream location (sample S-5). The highestconcentrations, however, Jare detected adjacent to the Pile.Zinc was detected at elevated concentrations (3630 ug/1) at thislocation (sample S-3) indicating a potential source in this area.Nickel and silver were allo detected at levels above publishedbackground concentrations! adjacent and downstream of theCertainTeed Pile. The hig »r concentrations of copper, zinc, andnickel In surface water a<to upstrean concentratorarea. Concentration of tthowever, copper remains a

acent to the CertainTeed Pile comparedsuggest a potential source in this

se metals decrease further downstrean;ove both background and ambient water

quality criteria at the downstrean locations.0

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oThe results of the analysis of surface water for asbestosindicates upstream concentrations to be below detection levels(0.0421 MFL). Asbestos was detected in both downstream samplesat concentrations of 0.0433 MFL (sample S-4) and 0.0421 MFL(5).Asbestos was not detected in the duplicate of sample S-4 above thedetection limit. (No data sheet for sample S-4 was provided inAppendix B of the CertainTeed El Report, although a concentrationwas reported on the data summary sheet. The CertainTeed ElReport does not mention the detection of asbestos although thedata summary table and data sheet indicate it was detected at thedetection limit of 0.0421 MFL. The concentrations on the datasummary sheet in Appendix B are also incorrect for samples S-4and S-5 they should be in "ppn" not "ppb"). These resultsindicate that asbestos pipe debris from the CertainTeed Pileobserved in the stream may be a source of asbestos contamination

"} in surface water downgradient of the pile. The concentrationsdetected, however, are well below the ambient water qualitycriteria of .3 MFL.

A summary of the volatile and semi-volatile organic compoundsdetected in the sediment samples is presented in Table 2-3,Volatile and semi-volatile compounds were detected in bothupstream (sample S-l and S-2) and downstream (sample S-4)samples. No organic compounds were detected in downstreamsamples S-3 and S-5. The greatest concentration of organiccompounds were detected in upstream sample S-2 and downstreamsample S-4. Higher concentrations were detected in thedownstrean sample suggesting both off- and on-site sources. Thetotal concentration of carcinogenic polycyclic aromatichydrocarbons (PAHs) in sample S-2 was 6490 ug/kg compared to12,150 ug/kg in sample S-4. This maximum total concentrationcompares to a total maximum concentrations of 12,100 ug/kg

.} detected in the sediments of the drainageway and Hissahickon

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•0Creek during the Rl for Operable Unit 1. The totalnon-carcinogenic PAHs detected in sample S-2 was 11,120 ug/kgcompared to 22,990 ug/kg in sample S-4. This compares to a totalmaximum concentration of 32,000 ug/kg detected in sediments alongthe drainageway and Hissahickon Creek during the Rl for OperableUnit l. The sources of PAHs in the sediments sampled during theRl for Operable Unit 1 were concluded to be potentially from bothon-site and off-site sources. Potential risks associated withincidental ingestion of these maximum concentrations wereevaluated in the Endangerment Assessment for Operable Unit 1 andare summarized in Table 6-18 of the RI/FS report,

The pesticide Aroclor-1254 was detected in the furthestdownstream sample (S-5) at a concentration of 1000 ug/kg.Aroclor-1254 was also detected in a sediment sample during the Rl

) at the point where the drainageway from the filter bed lagoons,ceets Stuart Farm Creek and Hissahickon Creek. This suggests anisolated downstream presence of Aroclor -1254 however it is notconsidered site related,

A summary of the inorganic analytical results for the sedimentsamples is presented in Table 2-4. The results indicate thepresence of metals within the range and slightly above publishedbackground concentrations in both upstrean and downstreansampling locations.

Asbestos analytical results for sediment samples are also shownin Table 2-4, Asbestos concentrations as a function ofpercentages by volume ranged fron 2 to 6 percent in both upstreanand downstrean sample locations suggesting both off-site andon-site sources of asbestos.

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Summary/Review - CertainTeed Elo2.2.2 Test Pit Sampling Results

Five waste samples were obtained from a test pit excavated on thenortheast side of the CertainTeed Pile and analyzed for prioritypollutant organic and inorganic compounds, asbestos, and EPtoxicity metals, The test pit location is shown on the attachedsampling plan (see Figure 2-1), Sampling procedures are outlinedin Section 3.5 of the CertainTeed El Report.

A summary of the organic compound analysis results is provided inTable 2-5. Several volatile and semi-volatile organic compoundswere detected in the test pit samples but not consistently and at•Concentrations below or just above EPA contract requireddetection limits (CRDL) . Di-n-butylphthalate was detected in allof the test pit samples at an average concentration of 948 ug/kg

) or less than 1 ppm. The pesticide aroclor-1260 was detected inthree of the test pit samples but at concentrations below orclose to the CRDL of 40 mg/kg.

The results of the inorganic and asbestos analysis of test pitsamples are presented on Table 2-6, The results indicate thepresence of arsenic, chromium, copper, lead, and nickel atconcentrations of twice the published background concentrationsin at least one of the five samples taken from the test pit.Metal concentration* were on the high side of backgroundconcentrations in nearly all of the samples. Arsenic andchromium were not detected in waste pile or soil samples takenduring the Rl for Operable Unit 1 and therefore, a qualitativeanalysis of the potential risks of incidental ingestion of thesemetals at the concentrations detected using available data cannotbe performed, These samples were, however, taken from wastesunder the existing soil cover. The soil cover is in good

> condition on the CertainTeed Pile and only small areas of wasteare exposed,

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EP Toxlcity Leaching Procedure was performed on two test pitsamples and analyzed for arsenic and^xrtiromium. Theconcentrations of arsenic in the leachate wrffe 0,17 mg/1 (sampleTP-1) and 0.19 mg/1 (sample TP-4). Chnmiun was detected at aconcentration of less than 0.01 mg/lr in both samples. Theseresults indicate the waste samples to not possess the hazardouscharacteristics of EP Toxicity. me results also indicate thatthe heavy metals detected in theXest pit sacples are not likelyto migrate at concentrations /f concern into the groundwaterunder the pile. Some impact /o the adjacent stream is howeversuggested by the surface wate/ data.

Asbestos was detected j/ all the test pit samples atconcentrations ranging from 0.2 to 11 percent by weight. Thepotential of accidental iigestion of asbestos containing wastesby children playing on tie pile exists for those areas of thepile that are currently Ind potentially in the future exposed.Potential asbestos inhalition exposures also exist if childrenare playing near exposld areas and the asbestos containingmaterial is disturbed, phe risks associated with ingestion ofasbestos containing soil/was assessed in the EA for the OperableUnit l. The risks assc :iated with inhalation of asbestos wasqualitatively also evalu

The conclusions thatcharacteristics of the w

ted in the EA for the Operable Unit 1.

can be made regarding the chemicalste materials contained in the pile may

not be truly representative since only five samples from a singletest pit were sent to tnp laboratory for analysis. No samplesfrom the five test borings drilled into the pile were analyzedfor chemical constituents.

2.2.3 Air Sampling Results

Personnel air sampling as mandated by OSHA for workers workingwith asbestos containing materials was performed during the test

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pit excavation for the CertainTeed El. Samples were collectedusing a portable Gillian pump, pumping at an approximate rate of2.0 1/min, Asbestos was detected on all four sample filters,The concentrations were as follows: 0.03, 0.006, 0,008, and 0.001fibers/cc. The results indicate that the concentrations detectedin the personnel air samples, were below the OSHA limit of0.2f(>5um)/cc for occupational exposure. Personnel air sampleswere analyzed using Phase Contrast Microscopy (PCIi) as requiredby OSHA. This method, however, only measures those fibersgreater than 5 urn. Most fibers found in ambient air are lessthan S urn and therefore a more sensitive method of analysis isused (Transmission Electron Microscopy) for determining ambientair concentrations.

No ambient air samples were taken as part of the scope of the~) CertainTeed El, Ambient air sampling up- and downgradient of

both Operable Units 1 and 2 was performed during the Rl forOperation Unit 1, The results of the air sampling aresummarized in Section 5,1.3 of that Rl Report. No ambient airsampling directly on exposed areas of the CertainTeed Pile(Operable Unit 2) was, however, performed.

The results of the ambient air sampling and analysis indicated nomeasurable impact on the ambient air downwind of Operable Units 1and 2. The concentration detected at the downwind locations wereeither nondetectable or below the detection limit (O.oif/cc).The concentrations in the downwind samples were comparable to theupwind concentrations.

The results of the Rl for Operable Unit 1 indicated that theCertainTeed Pile does not measurably impact the ambient airquality downgradient of the pile. The potential of inhalation

"'_) exposure of asbestos does, however, exist if exposed areas of the

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pile are disturbed resulting in the entrapment of asbestosfibers into the ambient air. This may result if children areplaying on the piles or if other persons are conductingauthorized or unauthorized activities, Evidence of trespasŝ gonto the site was observed during the Rl field program.

2.2.4 Summary of CertainTeed Environmental Investigation.

The REM II summary of the findings from the fieldr investigationconducted for the CertainTeed El of the CertyainTeed Pile ispresented below:

o concentrations of copper, zinc/ and nickel abovepublished background surface /ater concentrations,ambient water quality criteria and upstream sanple x-s.concentrations were detected if a surface water sanpletaken fron Stuart Fam dreek adjacent to theCertainTeed Pile suggesting Jpotential source in thisarea. Copper concentration! remain above publishedbackground concentrations «nd ambient water qualitycriteria at downstream campling locations, Thepotential of on-site sourcls of heavy metals and thepotential risk to the empronment should be furtherinvestigated.

o Asbestos was detected at and slightly above thrdetection Unit (.0421 MFL) at the two downstreansurface water sampling locations. Asbestos was notdetected in any of the upstream samples. These resultssuggest that the Certainieed Pile or asbestos pipingobserved in the streambel are a potential source ofasbestos. The concentration of asbestos detected ishowever well below the afebient water quality criteriaof .3 MFL.

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nThe location of the pile within the floodplain ofStuart Farm Creek poses a potential risk of increasedreleases of asbestos into area surface water if floodwater erodes the pile cover, exposing and then carryingasbestos into the stream.

o Volatile and semi-volatile organic compounds weredetected in both up- and downstream sediment samplesfor Stuart Farm Creek. The highest totalconcentrations of semi-volatiles and polycyclicaromatic hydrocarbons (PAHs) were however detected inthe downstream sanple S-4 indicating both potentialoff-site and on-site sources. The total maximumconcentration of carcinogenic and non-carcinogenic PAHsdetected in the sediments of Stuart Farn Creek are

^~) comparable to the maximum concentrations detected inthe sediments samples taken during the Rl for OperableUnit 1 (Nicolet site). Risks associated withincidental ingestion of sediments from Stuart FarnCreek containing these concentrations of PAHs can beevaluated using the risk analysis presented in the EAfor the AAP (Operable Unit 1).

o Asbestos was detected in both up- and downstreansediment samples at concentrations ranging from 2-6%(by volume) indicating both off-site and on-sitesources.

o Several volatile and semi-volatile organic compoundswere detected in the test pit samples but noneconsistently and at concentrations below or slightlyabove EPA contract required detection linits.

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Summary/Review - CertainTeed ElO

o Arsenic, chromium, copper, lead, and nickel weredetected at concentrations twice tfî publishedbackground concentrations in several of the test pitsamples. Arsenic was detected at a/concentration of1770 mg/kg in one sample (sample TPiC) and chromium wasdetected as high as 215 mg/kg (sample TP-l) (average 111mg/kg), These high concentrations Bay pose a potentialhealth risk through accidental ingestion by childrenplaying on exposed areas ofAhe piles, EP toxicityleachate testing was performed on two of the samplescontaining the highest/ arsenic and chromiumconcentrations. The material does not exhibithazardous characteristics Jof EP toxicity. The resultsindicate that the metal/detected are not likely tomigrate to the ground/ water at concentration of /-\concern. Some impact to/the strean , maybe as a resultof stormwater and strean erosion carrying contaminatedsoil to the strean, is/ suggested by the surface waterdata.

o Asbestos was detected fin all the tist pit samples atconcentrations ranginl fron 0.2 to H percent byweight. The potential of accidental ingestion ofasbestos containing wastes by children playing on thepile exists for thosfe areas of the pile that arecurrently and potentially in thi future exposed.Potential asbestos inhalation exposures also exist ifchildren are playing near exposed areas and asbestoscontaining material is disturbed. The risks associatedwith ingestion of asbestos containing soil was assessedin the EA for Operable Unit 1. The risks associatedwith inhalation of asbestos were qualitatively ,evaluated in the EA,

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Summary/Review - CertainTeed Eloo Personnel air sampling as mandated by OSHA indicated

asbestos concentrations during the test pit excavationto be below the OSHA limit of 0.2 fibers/cc foroccupational exposure. No ambient air sampling wasconducted during the Environmental Study. Ambient airsampling up and downgradient of the CertainTeed Pileduring the Rl for Operable Unit 1 indicated nomeasurable impact to the ambient air downgradient ofthe CertainTeed pile. The potential of inhalationexposure of asbestos does however exist if exposedareas of the pile are disturbed resulting inentrainment of asbestos fibers.

2.2.4.1 CertainTeed El Geotechnical Investigations

) The geotechnical investigations of the CertainTeed El included asite survey of exposed area and cover conditions, physicaltesting of cover soils, and analysis of test boring data.

The REM II summary of results fron the geotechnical progranperformed is summarized below;

o No active scouring of the asbestos pile along thesouthern toe of slope adjacent to Stuart Farm Creek wasobserved. The pile does however, encroach onto theflood plain of the creek (see Figure 2-5 AAP RI/FS) andthe potential for scour of the stream bank along thesouthern toe of slope is likely to exist under highflow conditions. These observations are similar tothose made during the November 11, 1985 site visit byEPA, PA DER, HESTON, and CertainTeed Corporation.

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Exposed areas of the pile were identified on thenorthern most portion of the western sideslope andalong the toe of the southern side slope, /*he exposedmaterial was observed to be primarily s/rap or wholeasbestos cement pipe, Potentially asbestos containingwaste was observed in the vicinity ft an overturnedtree on the western sideslope, (Nof aerial extent orlocation map was provided in Jne CertainTeed ElReport).

Extensive tree growth was obsê Fed on the south slopeOne tree has fallen and there n a likely potential ofother trees falling that could/expose additional areasof the pile. Extensive tree /growth has also hinderedthe establishment of low lyinl vegetation on the cover. /-\(Similar observations were /made on the Locust St.Pile,) This condition may/result in erosion of thecover and potential future exposure of waste materials.

It was reported that little/ponding of surface water ontop of the pile was observed (less than one foot indiameter). Although this! observation may have beenaccurate at the time of thl survey (no date provided),aerial photographs taken iy EPIC under contract withEPA on Hay 9, 1987 indicate 8 to 10 areas of pondedwater up to fifteen feet I in length. These areas ofponded water are primarili on the western side of theplateau area of the pile.l similar to the Plant Pile,the CertainTeed Pile does not provide positive drainageof rainfall fron the top if the pile. Without positivedrainage a significant poltion of precipitation fallingon the pile will infiltrate into the waste materials, , ,Although the EP toxicity leachate samples indicated alow potential for metals leaching into the underlying

flR3f!2235Ai'i tht page iilntd in thit tnamt it not at *eadab/e..o* ttgibtt. at thit -tabtl, it it due to


groundwater, the limited sampling effort cannot beconsidered totally conclusive, shallow groundwaterunder the pile flows toward, and is discharged intoHissahickon Creek. Hater Quality in the HissahickonCreek may therefore be impacted. The Rl for OperableUnit 1 did not include metals analysis of surface watersamples from Hissahickon Creek and therefore the impactto the stream can not be evaluated with existing data.The chronic exposure limit for fresh water aquatic lifefor arsenic is ,19 mg/1 which is equal to theconcentration detected in the leachate of test pitsample TP-4 The leachate extraction procedurerepresents, however, a worst case scenario.

o Samples of the existing soil cover were collected fronthe borings and tested for grain-size distribution,plastic and liquid limits, natural moisture content,and bulk density. The results indicated that the coversoil is primarily a silty or clayey sand (SC-SM or SMaccording to Unified Soil Classification System) withsome samples possessing a "gravelly texture". Althoughno permeability testing was performed, these soilsoften are considered well draining thereby allowing forgreater infiltration than fine grained soils. Thepotential of the leaching of heavy Mtals from the pileto the shallow groundwater and eventually toHissahickon Creek as a result of precipitationinfiltration into the pile should be considered in thedevelopment of remedial alternatives.

o The results of the physical testing of cover soilsindicated further that the cover naterial waarelatively well compacted and provided competentcontainment of the underlying wastes. Littlê erosion

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Summary/Review - CertainTeed El nof the cover material was reportedly observed. Basedon these results and observations the easting coverappears adequate in providing containment of asbestoswastes. Reduction of infiltration into the pile ishowever recommended, and could be adequately addressedby regrading the flat portion ofVthe pile to promotepositive drainage. The thicknes/ of the cover overallon the plateau appears sufficiej

o No soil sampling was conducted on the side slopes ofthe pile to confirm the s/il boring sample results.Little erosion was reporte/ on the side slopes due tothe vegetative cover. On /reas of the side slopes thatare exposed or were vegetation is not well established(where trees block sunlight) erosion and possibletransport of contaminants via stormwater runoff nayoccur.

o Three piezometers werelinstalled into the CertainTeedPile at test boring locations. (No location plan orpiezometer construction logs were provided in theCertainTeed El Report,! The piezometers were reportedto be screened to the (bottom of the borings that weretaken to an average delth of 38 feet (the height of thepile is approximately 1)5 feet). No perched or shallowgroundwater was detected in any of the piezometers.Therefore, the wasti i appear to be well drainedmaterials and no percthe pile which wouldcontaminants to the s

ed water condition exists withinurther promote the migration ofallow groundwater and eventually

to Hissahickon Creek.

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no Five soil borings were drilled into the pile at

locations shown on the attached location plan. Boringswere taken to final depths of 32 to 42 feet belcw theexisting ground surface, Although it is stated in thereport that continuous sampling was performed, standardpenetration resistance (SPR) values and split spoonrecovery were recorded primarily for the cover soillayer, the first few feet of waste materials and at thebottom of the boring, Split spoon sampling may havebeen discontinued once the waste materials waspenetrated due to the difficulty of obtaining sampleswhich contained asbestos-cement pipe fragments. Themethod of sampling used to define the types andstratification of wastes was not defined in theCertainTeed El Report.

o A review of the boring logs indicate the cover soil onthe plateau portion of the pile ranged in thicknessfron 3 to 20 feet. The soil cover was less than 6 feetin four of the five borings. Although the reportstates that the cover soil was 2 feet thick on the sideslopes no hand augering was performed to confirm thesestatements. The thickness of the side slope cover soilshould be verified and evaluated in terns of itslongtern integrity. Although the height of the sideslopes are less than the Locust Street and Plant Pileswhere significantly nore erosion of the cover materialshas occurred, the side slopes of the CertainTeed Pileare equally as steep (40* slope) and erosion will occurif they are not properly stabilized with a vegetativecover. An evaluation of the existing vegetative cover

, on the side slopes in tern of longtem erosion shouldbe performed by a representative of the local SoilConservation Service.

AR302237-26-

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o Additional review of the boring logs indicate the wastematerials encountered in the piles includedasbestos-cement pipe and fine and course grained grayand black waste materials, "Soft" arvas wereencountered in two of the borings at 22 anu 26 feet.No SPR values or physical testing data way provided toevaluate the effect on the stability ofXhe piles. Itwas reported by CertainTeed that a 5t /lids sludge wasdeposited in the pile. The extent of/this sludge whichcould have an impact on the stability of the pile wasnot defined. The CertainTeed pj/e differs from theLocust Street and Plant Piles /n that it does notappear to contain the significant quantities of softnearly saturated calcium/mag/esiun carbonate thatexhibit significant stabilj/y concerns especiallyregarding any remedial action/ that would disturb thesepiles, The height of the/CertainTeed Pile is alsonearly half of the height/of the Plant Pile and istherefore geometrically More stable. Although anaccurate evaluation of the/stability of the CertainTeedPile cannot be made from/the limited information, itcan be concluded that tile longtera stability and thestability of the pill during potential remedialmeasures (capping, renewal, etc.) is much less aconcern when compared /o the Locust Street and PlantPiles,

o One of the primary rlasons, besides the potential ofair-borne releases of/asbestos for recommending againstremoval and treatment! options for the Locust Street andPlant Pile was the/stability concerns and the largevolume of wastes contained in these piles. The volumeof the CertainTeecf Pile has been estimated to be

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/ considered.

132,000 cubic yards (22,000 is estimated to be coversoil), This compares to an approximately 615,000 cu.yd. and 640,000 cu. yd. for the Locust Street and PlantPiles, Although the volume of the CertainTeed Pile isstill significantly large when considering the removaland off-site disposal of the wastes of the pile (due tothe lack of available landfill space andtransportation/hauling related considerations); thevolume may not be excessive in considering possibletreatment options such as vitrification, No chemicalor asbestos analysis was performed on any boringsamples and therefore the distribution of asbestoscannot be accurately determined with the availabledata, This information will be important if atreatment technology such as vitrification is

Sloughing of the cover soils on the side slopes wasreportedly not observed, One problem that was observedwas the exposure of waste materials on the side slopeas a result of a tree overturning, The presence oftrees on the sideslope therefore pose a threat ofexposing asbestos waste and increasing the potential ofaccidental inhalation or ingestion by potentialreceptors,

J

AR302238-28-

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Summary/Re view - CertainTeed El . >».

3.0 RECOMMENDATIONS REGARD^C THE COHPLETIOH OP THE EA AND PS

o A focused EA should be conducted for the CertainTeedPile using the available data from/the CertainTeedEl and risk analysis performed four the Locust streetand Plant Piles (Operable Unit/1), A preliminaryhealth risk analysis for the/CertainTeed Pile isoutlined in Table 3-1. Both tjre types of contaminantsand the levels detected at /he CertainTeed Pile arecomparable to those found daring the Rl for OperableUnit l and therefore th/ risk analysis should besimilar. The exception is/the heavy metals detected inthe test pit samples fro/the CertainTeed Pile. If itis determined that a significant risk exists additionalsampling including sam/ling of Hissahickon Creek andadditional waste pile campling may be required,

o The ARARs presented /n the RI/FS for Operable Unit lare generally applicable to the CertainTeed Pile andshould be used to evaluate potential RemedialAlternatives (see station 7.2 of AAP Nicolet site FS).The one Action-Splcific ARAR that nay not be asapplicable is the 9ARA guidance on sites consisting oflarge volumes of snent process waste. SARA calls forthe development If a complete range of treatmenttechnologies when I developing and evaluating remedialalternatives. SARA does, however, state that this maynot be practicable at some sites with large volumes oflow concentrated! wastes (e.g., large municipallandfills or minilg sites). This nay be true for theLocust Street anl Plant Piles in which nost of thewast* is spent iagnesium/calciua carbonate, but theCertainTeed Pile Ac on* twelfth of the contained volume

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of these piles, and also is composed of primarilyasbestos process waste and asbestos-cement pipe. Theexact distribution of asbestos in the CertainTeed Pilecannot be accurately determined based on the availabledata. Historical data suggest a greater asbestoscontent in the CertainTeed Pile than the contentencountered in the Locust Street and Plant Piles. Apreliminary cost analysis based on available datashould be performed as well an assessment of thepotential risk to the public if the pile was disturbedbefore further sampling and testing is done todetermine the feasibility of the treatment option.

A location specific ARAR important to the CertainTeedPile is the Protection of Floodplains, 40 CFR 6,Appendix A which requires action to avoid adverseeffects, minimize potential ham, and restore andpreserve natural and beneficial values. The southernslope of the CertainTeed Pile are within the 100 yearfloodplain of Stuart Farn Creek.

A Focused Feasibility Study for the CertainTeed Pileshould be performed consisting of an evaluation of thefive options presented in the CertainTeed El. Theremedial objective should be based on the results ofthe focused EA and the evaluation of similaralternatives in the AAP (Nicolet site) FS. It isrecommended that regrading of the top of the pile toprovide positive drainage be added to the remedialmeasures under Option 3 of the certainTeed El.Although Option 3 appears to be the most cost effectiveoption that addresses the risks listed in Table 3-1,further consideration of the vitrification treatment

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IAIII M

WtllHIIIAItt HEALTH HISS ANAITIII

N • «o •iiurtblt rlik iiioclttid ulf cn-iltt lourci.T • TM, i rlik tuliti.T* • E«ptct*d to Incriiit thi Milt

Ooti Hullhftlik (Kill

Sourcn :< Aibtitoi Trintpcrt NKlnnlm/Eiipaiurt Pithvty fjfSnllil Mciptcri to Htciptor

CUMINf

o currwt toc-itd inn o Cntrilraml of iitxitot flbtri fr/ o TrnpMiira,of thi pl.t Mpmd inn of thi pill vli

Into mtlini tlf/lndilitloo. o Dowwlnd rnlotncn,

a Entnlmnt of iibntM f l b t l n t o o Trnpuiin.thi "tltot ilr fron nfottof tht pllt vli phytlcil dturbinctof plli by irnptiitri/loMtitlcflind tccldmtil Ingnllon

o Trtmport of itbtitot fmri vli • Itcrtitlomlitore nltr nnoff, frii inpoitd «od tquitlc lift,irtii tnd iccurlng tlm icuthirnildt itopt if pi It t/ltuort FinCrMt/Mddmtil In/itlcn.

ruruiio Addltloni, t*poiid irtu o Intrilnwit of idkiiM (Ibtri fr« o Trttpwiirt,

of (hi pi.• it i mull tddltloml mpciH irni of Ihiof ovtrtimlni cf tritt pi It «li ulnd /to wtltnt ilr/ e Ootmlnd rnlatncn,md imlon of covtr IrtiilMlon,•tiirt nttiitlon It not•til aucllthtdon o Intrilramt if iibtiiot flbtn Into o TritpMiirt,ildi ilocvt. thi •bltnt fir fra mpoiid irtu

of thi glliAli phyilcil dliturlumof plli byirtipiiiiri/lrtiititlcn•nd Kclcmil Injtitlon.

o Trnporf if iibntM flbiri vli a Itcriitlonil ivlimri/iiidiriitem iJfir nnoff, fro* oupottd *nd iquiilc lift,iriH 4i nowlr» il«n louthimildt tic* if pi I* to Itwrt rimCrntfccldtntil Ingiitlon,

O

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ik-iii,J,


options should be given due to the smaller volume ofwaste to be treated and the more stable condition ofthe pile. Both cost and potential public health risksassociated with disturbance of the pile should bestrongly considered under this option.

0

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Documents

PHONE 215.692.3030 TElEK 83 · 2020. 12. 12. · VVE5TONWAWEST CHESTER pY« 19380 PHONE 215.692.3030 TElEK 83.5348 May 16, 1989 Hector Abreu U.S. Environmental Protection Agency 841