^iuMandm d colo* 01 condition o{ tkt · 2020-02-12 · o FEDERAL ON-SCENE COORDINATOR'S REPORT AMBLER ASBESTOS WASTE TAILINGS PILES #2, NPL SITE CERCLA/SARA REMOVAL ACTION March 6,1989

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FEDERAL ON-SCENE COORDINATOR'S REPORT

AMBLER ASBESTOSWASTE TAILINGS PILES #2, NPL SITE

CERCLA/SARA REMOVAL ACTIONMarch 6,1989 through February 20,1990

UNITED STATESENVIRONMENTAL PROTECTION AGENCY

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's Report

0 TABLE OF CONTENTS

FACTS SHEET

FOREWORD

I. INTRODUCTIONA. Initial SituationB. Location of the SiteC, Efforts to Obtain Cleanup by Potential Responsible Party

II, ROSTER OF AGENCIES, ORGANIZATIONS AND INDIVIDUALSA, Names and AddressesB. Organization of the ResponseC, Glossary of Abbreviations

III, NARRATIVE OF EVENTS

IV. RESOURCES COMMITTEDA, Initial Funding RequestB. Additional Funding RequestC, Two-Million Dollar ExemptionD. Estimated Total Cost Summary

V, EFFECTIVENESS OF THE REMOVALA, Activities of the Various Agencies

1. Potential Responsible Parties2. Federal Agencies and Special Forces3, State and Local Agenciesff. Contractors

B. Analytical SynopsisC, Disposal Methods and Quantities Removed

VI, CHRONOLOGY OF EVENTS

VII, PROBLEMS ENCOUNTERED AND RECOMMENDATIONS

VIII, APPENDICESA. Location Map and Site SketchB. Funding DocumentationC, POLREPsD. Photographic DocumentationE. Dynamac Engineering AnalysisF. Delivery Order/Procurement RequestsG. Region III Incident Notification ReportH, Site Safety Protocol AR I 00003

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REGION in PROJECT #218CEROA REMOVAL ACTION__________________________PACT SHEET

O SITE: Ambler Asbestos Waste Tailings Piles #2, NPL Site

SIZE: Two asbestos piles totaling approximately 6.2 acres on a 15-acreproperty

LOCATION: Montgomery County, Pennsylvania

APPROVAL DATE: January 27,1989

PROJECT DATES: March 6,1989 through February 20, 1990

DESCRIPTION: The Ambler Asbestos NPL Site consisted of two waste pilescontaining asbestos-bearing material which were addressed duringEPA and RP actions in 1984. Following reports of erosion andexposure of asbestos at the piles, an assessment was conducted,Observations were that the piles were in good condition, but thatsmall, patchy areas of erosion were occurring at each pile. Inaddition, the fence placed by EPA Enforcement to restrict accessappeared inadequate and was in disrepair. Actions during thisresponse activity included constructing an 8-foot, chain-link fence

O w i t h barbed wire around both piles, clearing and grading wherenecessary on the piles, covering eroded areas of both piles, coveringwith topsoil, and hydroseeding to promote re-vegetation to preventfurther erosion,

HAZARDOUS MATERIAL: Asbestos; chrysotile and amosite

QUANTITIES REMOVED: None

OSC: Philip C. Younis

REMOVAL CONTRACTOR: Environmental Health Research and Testing, Inc., Lexington, KY

DISPOSAL LOCATION: None

PROJECT CEILING: $461,113

PROJECT COST: $402,749 (Estimated)

COMMENTS:

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I. INTRODUCTION

A. Initial SituationActing on information provided by the EPA Enforcement Section concerning commentsthat had been received from local residents regarding erosion on the sides of both theLocust Street and Plant asbestos piles at the Ambler Asbestos Site, EPA Eastern ResponseSection OSC Philip C. Younis tasked the Roy F, Weston Technical Assistance Team (TAT)to investigate these reports. Such erosion would create the potential for a health hazardto the people living and working in the area from exposed asbestos.

On October 31, 1988, TAT met with Enforcement representative Hector Abreu to assessthe situation. Upon investigation, it was found that the two piles were in good conditionwith only small, patchy areas of erosion occurring at each pile. However, the fence thathad been constructed by Enforcement to prevent access appeared to be in disrepair,thereby rendering it inadequate. As a result, OSC Younis submitted an action memo-randum to address these conditions, which was approved on January 27, 1989 by theActing Regional Administrator for $93,380.

B. Site LocationThe Ambler Asbestos Waste Tailings Piles, at the time of this writing, are located on theNicolet, Inc. property within the boundaries of Upper Dublin Township, in the Boroughof Ambler, Montgomery County, Pennsylvania, The Locust Street Pile is bordered byWissahickon Creek on the south and west, by Locust Street on the north, and by theNicolet plant facility on the east, The Plant Pile is bordered by the Nicolet plant facilityon the north, the Reading railway line on the west, and by the Certainteed property andthe Wissahickon Valley Watershed Association on the south and west, respectively. Alocation map and site sketch are presented as Appendix A of this report.

C. Efforts to Obtain Cleanup by Responsible PartyThe waste piles were owned by Nicolet, Inc. of Ambler, Pennsylvania, The previousproperty owner was the Keasbey and Mattison Company, which is no longer in, business,As a result of actions taken during the initial removal action in 1984, Nicolet, Inc,accepted responsible party status by taking over stabilization efforts at the Plant Pile,

An effort was made to obtain funds from Nicolet, Inc. following the original removalaction in 1984. However, since that time, Nicolet declared bankruptcy. It becamenecessary for EPA to take Nicolet to court on August 15, 1989 for cost recovery throughthe bankruptcy proceedings. As a result, a consent decree was made that required Nicoletto reimburse $900,000 to EPA for removal actions that had been taken, to which Nicoletcomplied and made the payment. fl R I n 1 n n c

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's ReportINTRODUCTION (continued)

C. Efforts to Obtain Cleanup by Responsible Party fcontinued)Prior to these actions, on July 12, 1989, an "Agreement in Principle" was made withT&N, who were responsible for the actions of the Keasbey and Mattison Company, T&Nobtained the services of ENSR consultants to assist them in possible future remedialactions. At the time of this writing, a final agreement with T&N has not yet beenreached.

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's ReportROSTER OF AGENCIES, ORGANIZATIONS AND INDIVIDUALS (continued)

B. Organization of the Response

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'."} ROSTER OF AGENCIES, ORGANIZATIONS AND INDIVIDUALS (continued)

C. Glossary of Abbreviations

ATSDR Agency for Toxic Substances and Disease Registry

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

EHRT Environmental Health and Research Testing, Inc.

EPA United States Environmental Protection Agency

EPA HQ EPA Headquarters, Washington, DC

FAO EPA Field Administrative Officer

Mini-ERCS Local Emergency Response Cleanup Services

NCP National Oil and Hazardous Substances Contingency Plan

NPL National Priorities List

OPA EPA Office of Public Affairs

OKC EPA Office of Regional Counsel

OSC EPA Federal On-Scene Coordinator

POLREP Pollution Report (report of daily site activities)

ROD Record of Decision

RP Responsible Party

SARA Superfund Amendments and Reauthorization Act, 1984

TAT Roy F. Weston, Inc., Technical Assistance Team

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III. NARRATIVE OF EVENTS

On October 31, 1988, acting on direction of OSC Younis, TAT met with EPA Region IIIEnforcement representative Abreu to investigate the Ambler Asbestos site, Mr, Abreudiscussed the history of the site and indicated that EPA Enforcement had received reportsfrom local residents that erosion was taking place along the sides of the asbestos piles,and that the exposed asbestos was creating a health hazard for the people living andworking in the area.

The investigation revealed that the two piles were in good condition, with only small,patchy areas of erosion occurring at each pile. The vegetative cover was also in goodcondition and appeared to be thriving, However, the fence that had been constructed byEPA Enforcement was found to be inadequate as recreational vehicle tire tracks wereobserved on the asbestos pile where the fence had been damaged by persons unknown,

As a result, OSC Younis submitted an action memorandum to address these conditions,On January 27, 1989, the action memorandum for $93,380 was approved by ActingRegional Administrator Stanley Laskowski, Removal actions were set to commence onMarch 6, 1989 by EHRT, contractor under the local Mini-ERCS mechanism, The scopeof work included construction of an 8-foot high, 9-gauge chain-link fence with barbedwire around the perimeter of both the Plant and Locust Street Piles, grading and clearingwhere necessary, covering exposed areas of asbestos, and hydroseeding to promote re-vegetation to prevent further erosion. However, as the scope of work was expanded sincethe original action memorandum was prepared, it became necessary for the OSC tosubmit an additional funding request. On March 17, 1989, Acting Regional AdministratorLaskowski approved an additional $367,734, which brought the total project ceiling to$461,114,

OSC Younis directed TAT to prepare objectives for a proposed engineering analysis thatwould evaluate the hazardous conditions at the site. A copy of these objectives was sentto consulting firms as an invitation to bid on the engineering analysis. On March 29,1989, the engineering analysis contract was awarded to Dynamac Corp, Also, on March30, 1989, EHRT contracted Reese's Landscaping, Inc, to assist in sire restoration andbeautification,

On March 31, 1989, it was determined by the OSC and Regional Management that thefence should include all the filter bed lagoons and the contaminated equipment and debristhat was being stored adjacent to the lagoons, requiring an additional 600 linear feet offence. On April 1, 1989, EHRT completed installing the original fence and beganconstruction of the additional 600 linear feet, which was completed on April 5, 1989, fora total of 6,780 linear feet of 8-foot, chain-link fence that was erected,

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's ReportNARRATIVE OF EVENTS (continued)

On April 7, 1989, EHRT, with the assistance of Reese's Landscaping, completedhydroseeding the side slopes of the two piles and the area that was cleared of vegetationto allow for fence installation was re-vegetated, EHRT then constructed a culvert at thetoe of Locust Street which was completed on April 10, 1989.

EHRT received the engineering analysis from Dynamac on April 10, 1989. At that time,OSC Younis began preparing an additional funding request to reflect recommendationsin the engineering analysis, which was submitted into the Regional concurrence chain onApril 24, 1989.

On April 12, 1989, TAT collected nine samples of the surface material on the playgroundpad to confirm that it was safe to reopen the playground to the public. The results,which were received on April 26, 1989, revealed trace amounts of asbestos in one sampleand one to two percent of asbestos in another. Although it was determined that theplayground would remain open, attempts would be made to divert the surface waterrunoff from the slopes of the piles to another area on site, and to completely decontam-inate the playground pp.d.

_ On February 2, 1990, OSC and TAT performed a visual inspection of the site. On,) February 20, 1990, an inspection was conducted with the EPA Remedial Project Manager,

and at that time, the OSC determined that the removal action was successfully completedto mitigate the immediate risk of harm to human health and the environment,

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IV. RESOURCES COMMITTED

A. Initial Funding Request (Action Memorandum)Based on the preliminary assessment performed by EPA Enforcement and TAT, the OSCdetermined that an imminent and significant risk of harm to human health and theenvironment existed resulting from conditions at the Ambler asbestos tailings piles. Tomitigate these threats, an action memorandum was submitted for $93,380, which wasapproved by the Acting Regional Administrator, Stanley Laskowski, on January 27,1989.A copy of the action memorandum is presented in Appendix B of this report.

B. Additional Funding RequestAdditional investigation and an increased scope of work necessitated the preparation ofan additional funding request. On March 17,1989, a ceiling increase of $367,734 wasapt.oved by Acting Regional Administrator Laskowski to address these additional threats,The new project ceiling became $461,114. A copy of'the additional funding request is

_ included in Appendix B of this report,

C. Two-Million-DoUar ExemptionOSC Younis determined that continued removal operations would be necessary toeliminate the threat to the public health and the environment posed by direct contactwith asbestos-containing material via airborne particulates, Such continued removalactions meet NCP 300,65 criteria, as well as criteria set forth in Section 104(c)(l) ofCERCLA, Therefore, a $2-million exemption additional funding request was submitted for$4,606,416, for a total project ceiling of $6,014,200 to continue site remediation andstabilization operations. Although these additional funds were requested, all activitiesassociated with this removal activity were accomplished under the previous project ceiling.Funds approved by EPA HQ will be held in reserve for future Remedial action, Becausefunding under the $2-million exemption was not added to the project ceiling for thisremoval action, a copy has not been included as part of this report,

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Ambler Asbestos Waste Tailings Piles n, NPL Site •Federal On-Scene Coordinator's ReportRESOURCES COMMITTED (continued)

D. Estimated Total Cost Summary

1. Extramural

Mini-ERCS $365,696

TAT 8,984

NCLP 546

Extramural Subtotal $375,226

2. Intramural

EPA Direct $ 8,272

EPA Indirect 18,981**/

Intramural Subtotal $ 27,253

TOTAL ESTIMATED PROJECT COST $402,479

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V. EFFECTIVENESS OF THE REMOVAL

A. Activities of Various Agencies

1. Responsible PartyNo RP actions were taken during this removal action,

2. Federal Agencies and Special ForcesPhilip C, Younis served as the Federal On-Scene Coordinator for this project, It is theOSC's responsibility to coordinate site activities, personnel and contractors to thesuccessful completion of the project. He was assisted by FAO Rich Messimer in areasof administrative support and cost tracking.

EPA Enforcement Section negotiated with the RP in an effort to obtain a commitmentfrom the RP to stabilize conditions at the site.

EPA Office of Public Affairs assisted the OSC with media interest and local residentconcerns.

EPA Office of Regional Counsel provided the OSC with advice and guidance concerninglegal matters.

3. State and Local AgenciesThe Borough of Ambler Fire Department washed down Locust Street on several occasionsto minimize the potential for the migration of asbestos particulates.

4. ContractorsThe Roy F. Weston, Inc., Major Programs Division provided personnel from the TechnicalAssistance Team to assist the OSC with air monitoring, sampling and contractor and sitesafety monitoring.

Environmental Health Research and Testing, Inc. (EHRT) of Lexington, ICY was hired asthe cleanup contractor under the local Emergency Response Cleanup Services (Mini-ERGS) mechanism. EHRT was responsible for providing the manpower and equipmentnecessary to complete the project and for coordinating the activities of subcontractors,

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's ReportEFFECTIVENESS OF THE REMOVAL (continued)

B. Analytical SynopsisFollowing stabilization efforts, nine dust samples were collected of the playground padto determine the applicability of allowing the playground to be reopened to the public.Results indicated trace asbestos in one sample and one to two percent in another sample,Hard copies of this analytical is maintained in the site file at EPA in Philadelphia at theaddress provided in Section II, ROSTER OF AGENCIES, ORGANIZATIONS ANDINDIVIDUALS of this report, Photocopies may be obtained upon request.

C. Disposal Methods and Quantities RemovedSite stabilization activities did not include the removal of any materials from the site.Efforts centered on recovering eroded areas of the asbestos piles and hydroseeding toprovide re-vegetation and prevent further erosion.

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VI, CHRONOLOGY OF EVENTS

This section is derived from site activities documentation, such as Pollution Reports(POLREPs), site logs, photographic documentation, and site-related documentation,provides an overall view of activities. In an effort to minimize duplication of effort, thePOLREPs have not been included; however, the EPA Region III Regional Response Centermaintains the POLREP file for all sites, and copies may be obtained by request to theaddress provided in Section II, ROSTER OF AGENCIES, ORGANIZATIONS AND INDI-VIDUALS of this report.

January 27.1989An action memorandum for $93,380 was approved by the Acting Regional Administrator,Stanley Laskowski.

February 20.1989OSC Younis contacted EPA Enforcement Abreu for current status of responsible partynegotiations. At this time, no appropriate RP actions have been taken as a result of EPAEnforcement activities to mitigate the threat posed by exposed asbestos.

-'' OSC Younis notified Mini-ERCS EHRT to meet at the site on 2/27/89 to initiate siteoperations. The OSC also contacted OPA Nanci Sinclair and PA DER to inform them ofupcoming EPA actions.

February 27.1989OSC Younis, EPA Enforcement, TAT and Mini-ERCS EHRT held a meeting at the EPAoffice in Philadelphia to discuss the scope of work for the Ambler site, A site visit wasalso conducted to coordinate and finalize the scope of work. EHRT began coordinatingsubcontractors to begin site operations on 3/6/89. OSC began preparations for an addi-tional funding request to reflect the expansion of the scope of work.

March 6. 1989Mobilization to the site began, EHRT began to dismantle the existing fence along LocustStreet; however, activities were suspended due to inclement weather. As directed by theOSC, EHRT arranged for site security during off hours to prevent unauthorized access,

March 7.1989EHRT completed dismantling the fence along Locust Street and began clearing andgrading for the installing of a new fence (Photos #5 and #6). TAT assisted the OSC inpreparing the additional funding request, Children were observed sledding on the Locust

, r. Street Pile (Photo #4).

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Ambler Asbestos Waste Tailings Piles if 2, NPL SiteFederal On-Scene Coordinator's ReportCHRONOLOGY OF EVENTS (continued)

March 8,1989Per OSC request, TAT mobilized the EPA mobile command post to the site. EHRTremoved debris from dismantled fence.

March 9.1989EPA Enforcement and TAT reviewed all proposed removal actions to ensure consistencywith Remedial actions.

March 10.1989EHRT completed fence installation along Locust Street (Photo #8) and continued to clearalong the southern and northern portions of the site. Construction of a temporary stoneloading pad was begun at the end of Locust Street, EHRT also began construction of astone access road to the Locust Street Pile plateau,

March 13.1989Gates were installed on the newly constructed 8-foot fence along Locust Street, A rampwas constructed to the Locust Street Pile, and evening site security was discontinued.TAT continued to prepare objectives for the proposed engineering analysis that wouldevaluate the hazardous conditions at the site.

March 14.1989EHRT continued installing fence around the Plant Pile. Clearing, grading and fillingoperations continued along the southern end of the site. EHRT began installing fenceposts along the southwestern perimeter of the site.

March 15.1989Approximately 1,390 linear feet of fence installed to date. EHRT continued clearing,grading and filling operations, Stream crossings were constructed with stone and under-flow piping. Approximately 50 loads of soil delivered to date,

March 16.1989EHRT continued fence installation around northern and southern portions of the PlantPile. TAT completed the draft of the engineering analysis objective, Approximately 1,780linear feet of fence installed to date, EHRT contacted the Ambler Borough Fire Depart-ment to wash down the residual din on Locust Street from the fill trucks. Approximately331 tons of soil and 7 loads of various types of stone delivered to the site this date,

March 17,1989Additional funding request was approved by Acting Regional Administrator Laskowski for$367,734 for a new project ceiling of $461,114. Ambler Borough Fire Department onsite to wash down the residual dirt on Locust Street. EPA Enforcement Abreu on site toreview the engineering analysis and concurred with objectivesjoithfcsflidy. QPA Sinclair

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Ambler Asbestos Waste Tailings Piles #2, NPL SiteFederal On-Scene Coordinator's ReportCHRONOLOGY OF EVENTS (continued)

March 17. 1989 (continued)spoke with concerned residents about current removal activities, EHRT sent copies of theengineering analysis to consulting firms who were invited to bid on the work, EHRTbegan applying fill dirt to the areas of exposed asbestos. Approximately 400 loads of soilwere delivered to date, along with 17 loads of various stone. Approximately 2,886 linearfeet of fence erected to date.

March 20. 1989EHRT continued post installation around the filter bed lagoons and along the LocustStreet Pile plateau. EHRT continued applying fill dirt (Photo #13,) to exposed asbestos.Approximately 423 loads of soil delivered to date. The slope on the southeastern portionof the Plant Pile 90percent completed to date,

March 28. 1989EHRT continued fence installation and clearing, grading and filling operations. Approxi-mately 5,305 linear feet of fence erected to date, OSC, TAT and EHRT evaluated/discussed proposals from engineering consulting firms. Bids were received by EHRT forsite restoration work. Approximately 462 loads of soil delivered to date,

March 29, 1989EHRT continued fence installation along the southern portion of the Locust Street Pileand along its base nearest residences, EHRT applied soil cover to areas of exposedasbestos along the southern portion of the Locust Street Pile (Photo #10), EHRTawarded the engineering analysis contract to Dynamac Corporation, the lowest bidder.Approximately SSpercent of the fence erected to date,

March 30. 1989EHRT finalized the bid process for site restoration and beautification work. Reese'sLandscaping, Inc. was awarded the contract,

March 31. 1989EHRT resumed fence installation on the eastern portion of the Plant Pile and erected theremaining portion of fence on Locust Street, completing the western half of the site,EHRT completed application of soil cover to the southern portion of the Locust StreetPile. Approximately 600 loads of soil (about 11,000 cubic yards) of soil delivered todate, Dynamac Corp. on site to perform sampling and data collection for the engineeringanalysis, OSC Younis coordinated with EPA Enforcement Abreu for action to be takenregarding the underground storage tanks. OSC Younis discussed property/fence line withEPA Enforcement Abreu, and it was determined that the fence should include all of thefilter bed lagoons and contaminated equipment and debris being stored adjacent to thelagoons. This would increase the fencing installation by approximately 600 linear feet.

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April 1.1989Fence installation approximately 95percent completed for a total of 6,500 linear feet todate,

April 3.1989EHRT completed fence installation on the eastern portion of the Plant Pile, EHRT beganfence boring for the additional 600 linear feet around the filter bed lagoon area.

April 4.1989EHRT completed fence installation along the eastern portion of the Locust Street Pile.

April 5.1989EHRT completed installation of additional 600 linear feet of fence for a total of 6,780linear feet erected.

April 7.1989EHRT completed hydroseeding the side slopes (Photo #11) where fill had been placedover areas of exposed asbestos. Areas cleared for fence lit1' were re-vegetated withassistance from subcontractor, Reese's Landscaping, Inc.

April 8. 1989 ,Roads on site which were damaged by heavy truck traffic were repaired,

April 10.1989EHRT received the engineering analysis from Dynamac this date (Appendix E).

April 11.1989EHRT completed concrete repair work on Locust Street, including removing broken side-walk and curb concrete and pouring new concrete.

April 12.1989TAT collected 9 samples of the surface of the playground pad to confirm that it was safeto reopen the playground to the public.

April 24.1989OSC Younis submitted an additional funding request to reflect recommendations presentedin the engineering analysis.

April 26.1989OSC Younis received analytical results from the 4/12/89 TAT sampling of the playgroundrevealing the presence of trace amounts of asbestos in one sample and one to two percentasbestos in another sample out of the 9 samples taken.

HRI00020

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May 1.1989OSC Younis coordinated with EPA Removal Management, OPA and ORC concerning thepositive results from samples taken at the playground, A decision was made to allow theplayground to be open; however, attempts were to be taken to divert the surface waterrunoff from the slopes of the piles to another area so the playground pad could be decon-taminated, The additional work would be performed under the current project ceiling,

May 2.1989Heavy rains made it necessary for EHRT to postpone earth work for the day, TATperformed a survey of the existing elevations at the toe area of the Locust Street Pilewhere a culvert would be constructed,

Mav 3.1989EHRT began constructing the culvert at the toe of the Locust Street Pile (Photo #14).A total of 23 truckloads of fill soil and 2 loads of stone were delivered this date.

May 4.1989TAT conducted a survey of the elevations of the culvert to ensure proper slope to divertsurface water runoff from the Locust Street Pile, A total of 16 truckloads of fill soil and5 loads of stone were delivered this date,

May 10.1989EHRT completed construction of the culvert at the toe of the Locust Street Pile adjacentto the playground,

June 26.1989The additional funding request/$2-million exemption was approved by RegionalAdministrator Erickson for $4,606,416 bringing the project ceiling to $6,014,200. Itremained to be approved by EPA HQ.

July 24.1989EPA Management and TAT held a meeting to discuss site status and evaluate alternativeactions to take during the interim between removal activities (March 1989) and theimplementation of the Record of Decision (ROD). As a result of the meeting, an ATSDRpackage would be submitted to assist EPA Management in better identifying theimmediate hazards posed by the site. TAT would perform air, soil and dust sampling,

August 11.1989TAT went to the site to perform air, soil and (lust sampling, and found that the play-ground pad had been resurfaced with blacktop, TAT sample locations included back-ground, samples on each side of the site,

i ! ARI0002I

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February 2.1990OSC and TAT visited the site to perform a visual inspection, As a result, the OSCdetermined that the potential for a short-term asbestos release was minimal and did notpose an imminent threat to public health or the environment. At this time, the removalaction was considered completed, All actions were completed within the approved projectceiling of $461,114. Additional funds under the $2-million exemption would be usedduring future Remedial actions as necessary.

Pebruatv 20.1990Per OSC direction, TAT revisited the site accompanied by EPA Remedial Program Manager(RPM) David Byro and the RP consultant ENSR. TAT pointed out areas of concern thatmay pose potential long-term health threats, which will be addressed by the RemedialProgram in the future.

Q

ARI00022

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VII. PROBLEMS ENCOUNTERED AND RECOMMENDATIONS

During removal activities, many pieces of heavy equipment were utilized. However,heavy truck traffic eroded some pavement areas creating potholes that required repair.On April 8,1989, repair work was accomplished on surrounding roads.

Unfortunately, it is very difficult to anticipate the consequences of removal operations dueto the use of heavy equipment. It is recommended that site planning and scope of workshould allow for potential situations of this nature.

Inclement weather at times constrained work efforts, It is recommended that whenplanning activities requiring favorable weather conditions, consideration be given to thetime of year, as well as checking regularly with the National Weather Service.

ARI00023

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"''

TDD Number 8902-17PCSNumber2288

AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, AMBLER,

im-V .„„ PENNSYLVANIAKM MIUI;J>'°I'. \'mi \ SITE LOCATION MAP

AMBLER, PA.UW MID HH> IM1 WWHtllC UMIH li , ' '"—*19fi6'MCimTIOM M CMIM Of Wtn PHOTOREVISED 1983

SCALE 124,000 DM* 9»M ll NW-SERIES vwio

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i; (Red)UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III' 841 Chestnut Building

Philadelphia, Pennsylvania 19107Justification foe Approval of aCERCU Removal Action at the

SUBJECT- Ambler Asbestos Tailings Site, Ambler, DATE- JAN 2 7 1989Montgomery County/ Pennsylvania •lvani

i R+*'\S

FROM: •/ffli/ttMovfflii, AC ti Regional Administrator (3DA00)*'

Dr. J. Winston Porter, Assistant AdministratorTO: Solid Waste Emergency Response (WH-552-A)

ISSUE

The attached CERCLA Funding Request pertains to theAmbler Asbestos Tailings Site, Ambler, Montgomery County,Pennsylvania.

The Removal Action is necessary to insure site securityand to eliminate the threat to public health due to directexposure of asbestos- containing material at the AmblerAsbestos Tailings Site. '

Pursuant to Delegation of Authority, which authorizes theRegional Administrator to approve CERCLA Removal Actions with atotal cost of less than $2,000,000 and approve exemptions tothe 1-year limit, I have approved the use of CERCLA funds inthe amount of $93,380 to mitigate the threat to public healthpresented by this site. '••

Attachments: Request for a Funding at the AmblerAsbestos Tailings Site, Ambler, MontgomeryCounty, PennsylvaniaLocation NapSite Sketch

ARI00026

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

641 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Request for a Removal Action ApprovalSUBJECT: at the Ambl'er Asbestos Tailings Site, Ambler POATE: ujj * 7 1989

Philip C. Younis, On Scene Coordinator,FROM: Eastern Response and Preparedness Section

Stanley L. Laskowski, Acting Regional Administrator (3RA00)

I. ISSUE

At this time, EPA Region III is requesting CERCLAFunding in the amount of $93,380 to restabilize the asbestostailings pile and repair the fence around the perimeter ofthe site at the Ambler Asbestos Tailings Piles, also known asthe Locust Street Pile and the Plant Pile.

II. BACKGROUND

A. Incident/Response History ,

" On September 15, 1983, surface sampling initiated by theEPA in and around the Nicolet Inc. tailings piles revealedthe presence of asbestos. As a result of these findings, theCenter for Disease control (CDC) issued a Public HealthAdvisory recommending the closure of the playground adjacentto the site. The OSC, Jeffrey Pike, submitted to ERD/Headquarters a Request for Emergency Funding, approved December19, 1983, to initiate actions to alleviate the health riskcaused by the piles.

On December 15, 1983, in accordance with CERCLA Sec. 104,. . • EPA determined that the site posed an imminent and substantial

danger to the public health and welfare and made the decisionto proceed with an emergency response action. The ImmediateRemoval Action of March, 1984 included closing and dismantlingof the playground equipment, and covering the Locust StreetPile side slopes and portions of the top flat area with a 6-18inch compacted soil cover stabilized with erosion controlnetting and vegetated with crown vetch grass. Nicolet Inc.,owner of the site, independently covered the plant Pile sideslopes with soil also vegetated with crown vetch.

ARI00027

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(2)

In October, 1984, the Ambler Asbestos Piles site wasproposed to be included on the EPA Superfund National PrioritiesList. The site was evaluated and is currently ranked 523 outof 703 of the original National Priorities List (NPL) and isdesignated as an enforcement site for the RI/FS. In September30, 1988 a Record of Decision was signed that calls for extensivecovering of the asbestos piles on the site. However, due tocurrent conditions at the site, interim response measures arenecessary prioc to implementation of the final remedy.

Contacts made with the Pennsylvania State SuperfundDirector in Harrisburg have made it clear that the statecannot accomplish the proposed actions at this site due tocontractual problems associated with their new Superfundprogram. (See Enforcement Confidential for enforcementstatus.)

B. Site Conditions

On October 31, 1988, EPA Region III Enforcement and theEPA's Technical Assistance Team assessed the Ambler Asbestos siteconditions. The two piles were found in good condition; however,small, patchy areas exhibited signs of erosion at each pile. Thefence around the site appeared to be inadequate to restrict siteaccess. The fence was found with complete sections missing andit lacked gates. Additionally, the fencing material had undergonesevere weathering and was in disrepair. Signs of trespassing wereevident in that recreational vehicle tire tracks were noticeablethroughout the site. This type of activity destroys the vegetationand contributes to the erosion problem at the site.

The removal action of March 21, 1984, addressed the immediateneed to significantly reduce the potential of. a release of asbestosfibers into the air from the uncovered asbestos waste piles andinto area surface waters via stormwater run-off. However, recentsite conditions have exhibited areas where a release of asbestosfibers may occur due to the eroded cover material. Moreover,because site access is insufficiently restricted, a directcontact threat to trespassers currently exists.

If re-vegetation and new fence installation operations arenot implemented, asbestos contaminated waste will remainand continue to pose a threat to human health and the environment,while posing a direct contact threat to trespassers of theunrestricted site.

ARI00028

(3)

III. PROPOSED ACTIONS

Areas on the two piles that are inadequately covered andvegetated should be addressed. Actions will include refillingthese areas, applying a geosynthetic fabric and finally hydro-seeding the fill material. The latter action will be performedduring appropriate seasonal conditions.

In order to properly restrict site access, a chain linkfence, eight feet (8') in height, with two gates will beerected around the two piles at the site (Locust St. andPlant piles).

IV. SUMMARY of COSTSEstimated Costs

ERCS Costs:

Material Costs $41,500Equipment costs 6,000Personnel Costs 12,000

Subtotal $59,500

TAT Costs: $7,850(including admin.)

EPA Costs: 13,850

Contingency 15% $12,180

PROJECT TOTAL $93,380

V. RECOMMENDATION

The conditions at the Ambler Asbestos Tailing Site meetthe criteria set forth in the National Contingency Plan,Section 300.65 for a removal. Your approval is recommendedfor this proposed removal action. The estimated removalproject cost is $93,380 of which $67,350 is extramural.

You may indicate your approval or disapproval by signingbelow.

Approve:&

Disapprove:

ARI00029

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCVREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Request for a Ceiling increase foe the Arables..._._„ Asbestos Tailings site, Ambler,SUBJECT. Montgomery County, Pennsylvania. . DATE: ui

,T» .•*"//' / ''/ *BDOU. Stanley L. LaskowskKY1, / ' '• fr "r"UMl Acting Regional Administrator (3RA00)

TQ, Jonathan Z. CannonActing Assistant AdministratorSolid Waste Emergency Response (WH-562-A)

ISSUE

The attached CERCLA funding Request pertains to theAmbler Asbestos Tailing site in Amble:, Montgomery County,Pennsylvania.

Continued Removal operations are necessary to eliminatethe threat to public health and the environment posed bydirect exposure to asbestos containing material.

pursuant to the Delegation of Authority 14-1-A (9/13/87),and Section 194 (c) (1) of the Superfund Amendments and Re-authorization Act (SARA) of 1986, which authorized the RegionalAdministrator' to approve CERCLA Removal Actions with a totalcost of less than $2,000,000 and approved exemptions to theone year limit, I have approved an additional $367,734 ofwhich $330,800 is for extramural cost to control and stabilizethis site. The total project ceiling with this increase is$461,114.

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1\

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

641 Chestnut BuildingPhiladelphia, Pennsylvania 19107 i,

Request for a Ceiling increase for theAmbler Asbestos Tailings Site, Ambler,

SUBJECTijipntaomery Ccdnty, Pennsylvania DATE: mj | 7 $89

9filVipic^SYounis, On-Scene Coordinator, (OSC)FROM: EasternNtesponse and preparedness Section (3HW22)

_fti Stanley L. LaskowskiIUl Acting Regional Administrator (3RA00)

THRU: Thomas voltaggio, Acting Director ' W./.Hazardous Haste Management Division (3HW00)

I. ISSUE

Removal actions to date performed in accordance withthe National Contingency Plan, have revealed the continuedpotential threat to human health and the environment at theAmbler Asbestos Tailings site in Ambler, Montgomery County,Pennsylvania.

A Ceiling increase of $367,734 for a total project ceilingof $461,114 is requested via this memorandum to continue theremoval action at the site.

II. BACKGROUND

A. Incident/Response History

On September 15, 1983, surface sampling initiated by the EPAin and around the (Nicolet Inc.) tailings piles revealed thepresence of asbestos. As a result of these findings, the Centerfor Disease Control (CDC) issued a Public Health Advisoryrecommending the closure of the playground adjacent to the site.The OSC, Jeffrey Pike, submitted to ERD/Headquarters a Request forEmergency Funding, approved December 19, 1983, to initiate actionsto alleviate the health risk caused by the piles.

On December 15, 1983, in accordance with CERCLA Sec. 104, EPAdetermined that the site posed an immediate and substantial dangerto the public health and welfare and made the decision to proceedwith an emergency response action. The Immediate Removal Actionof March, 1984 included closing and dismantling of the playgroundequipment, and covering the Locust Street pile side slopes andportions of the top flat area with a 6 to 18-inch compacted soilcover stabilized with erosion control netting and vegetated

''"} | with crown vetch grass.

ARI0003I

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Nicolet inc., owner of the site, independently covered thePlant Pile side slopes with soil also vegetated with crownvetch.

In October, 1984, the Ambler Asbestos Piles site was pro-posed to be included on the EPA Superfund National prioritiesList. The site was evaluated and included on July 10, 1986and is currently ranked 523 out of 703 of the original NationalPriorities List (NPL). On September 30, 1988, a Record of Decisionfor the site was issued. Remedial action is scheduled for thesite, to be performed either by EPA or by the responsible parties.EPA has filed a CERCLA Section 106 and 107 action against theresponsible parties.

B. Site Conditions

On October 31, 1988, the EPA Region III Enforcement andthe EPA's Technical Assistance Team assessed the Ambler AsbestosSite conditions. The two piles were found in good condition;however, small, patchy areas exhibited signs of erosion ateach pile. The fence around the site appeared to be in-adequate to restrict site access. The fence was found withcomplete sections missing and it lacked gates. Additionally,the fencing material had undergone severe weathering and wasin disrepair, signs of trespassing from recreational vehicletire tracks were evident throughout the site. This typeof activity destroys the vegetation and contributes to theerosion problem at the site.

The removal actions of March 21, 1984, addressed theimmediate need to significantly reduce the potential of arelease of asbestos fibers into the air from the uncoveredasbestos waste piles and into area surface waters fromstormwater run-off. However, recent site conditions haveexhibited areas where a release of asbestos fibers may occurdue to the eroded cover material. Moreover, because siteaccess is insufficiently restricted, a direct contact threatto trespassers currently exists.

If revegetation and new fence installation operationsare not implemented, asbestos-contaminated waste will remainexposed and continue to pose a threat to human health and theenvironment, while posing a direct contact threat totrespassers on the unrestricted site. Children have beenburned playing on the asbestos piles.

During a recent visit to the site by EPA, TAT, andcontractor personnel (ERCS), it was felt that funding alreadyapproved for restricting site access and for providing asoil cover at the top of the landfill is not adequate.

ARI00032

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3

During an onsite detailed discussion between EPA, TAT, ERGSrepresentatives, and EPA Enforcement, the following points werenoted:

1) During the construction of a chain-link fence around thesite, major clearing in woods and substantial grading work arenecessary for several areas for proper fence installation.These tasks were not taken into consideration when preparing thefunding request.

2) Fence work will cost considerably more than originallyanticipated. Original estimates called for 7,000 linear feetof fence with two access gates. After further review, it isnow evident that approximately 8,500 linear feet and an additionalaccess gate (three total) should be constructed to secure siteaccess.

3) Several areas on the plateau of the Locust Street asbestospile are inadequately covered, thus causing a potential healthhazard to nearby residents. A detailed engineering evaluationand cost analysis will be conducted to provide the EPA withoptions which will mitigate the associated hazards at theAmbler asbestos site.

4) A few areas along the slope of the pile have minor erosionproblems. As a temporary solution, minimum soil cover may beneeded for sufficient containment of asbestos in the erodedlocations.

As previously mentioned, an engineering consultantwill be contracted to perform a detailed engineering analysis.The objective of this analysis is to provide an evaluationof temporary remedies for mitigation of the threat at theAmbler site. All activities to date, although consistentwith proposed remedial actions, have been temporary nature inanticipation of permanent remedial measures. Presently,a specific date has not been set for the Remedial start.

III. PROPOSED ACTIONS

The bulk of the proposed ceiling increase, will addressthe clearing and installation an eight-foot high, nine-gaugechain-link fence with barbed wire to be constructed aroundthe perimeter of both the plant and Locust Street piles.Wherever necessary, the previously omitted areas should begraded and cleared prior to erecting the fence.

ARI.00033

Some additional funds will be used on several smallareas along the steep slopes of the Locust Street pile,with topsoil, 6 to 12 inches to adequately contain theasbestos until a more permanent remedy for the site isinstituted.

Continued removal actions will address the near termthreats, and enhance the completion of the proposed remedialplan of action. The examination of options to deal with thethreat posed by the top of the pile will consists of anengineering evaluation and cost analysis of both short andlong-term remedies. Funding to implement remedies to addressthe threat posed by the top of the pile will be addressed ina future action memorandum, if necessary.

IV. SUMMARY of COSTS

Current Ceilings proposed1. Extramural Costs

ERCS $ 59,500 $ 330,000TAT 7,850 25,000

Subtotal Extramural $ 67,350 $ 355,000

Contingency 15% 10,100 53,250

Total Extramural Costs $ 77,450 $ 408,250

2. Intramural CostaEPA (HQ and Region) $ 4,520 $ 15,000

EPA (Indirect) 9,332 30,969

Subtotal intramural $ 13,852 $ 45,969

Contingency 2,078 . 6,895Total Intramural Costs $ 15,930 $ 52,864

Total Project Celling $ 93,380 $461,114

ARI00031*

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V. REGIONAL RECOMMENDATION

The condition at the Ambler Asbestos Tailing Site meetthe criteria sot forth in the National Contingency plan,Section 300.65 for a removal. Your approval of this'ceilingincrease is recommended. The estimated additional projectcost is $ 367,734 of which $ 330,800 is extramural. Theseestimated costs are in addition to those approved in theoriginal CERCLA Funding Request.You may indicate your approval or disapproval by signing below.

APPROVAL: 5?^ /-• £ DATE: J-'?'

DISAPPROVAL: DATE:

J

O

' ARI00035

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To: ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered.: Tue 7-Mar-89 20:14EST Sys 163 (60)Subject: AMBLER ASBESTOS SITE POLREP #1Mail Id! IPM-163-890307-182100202POLREP KlAMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN: STEVE JARVELA AND TIM FIELDS

I. SITUATION (1700 HRS, MONDAY, 2/27/89)A. 1/27/89 - ACTION MEMO APPROVED BY THE REGIONAL ADMINISTRATOR.B. 2/20/89 - OSC YOUNIS CONTACTS EPA ENFORCEMENT (ABREU) FOR THE

RESPONSIBLE PARTIES CURRENT STATUS. EPA ENFORCEMENT VERIFIESNEGOTIATIONS WITH RP'S HAVE FAILED TO SECURE APPROPRIATEACTIONS.

C. OSC YOUNIS NOTIFIED MINI-ERCS (EHRT) TO MEET AT SITE ON2/27/89 TO INITIATE SITE OPERATIONS.

D. OSC YOUNIS CONTACTED EPA/OPA (SINCLAIR) AND PA DER TO INFORMTHEM OF ANTICIPATED EPA ACTIONS.

E. 2/27/89 - OSC, TAT, EPA ENFORCEMENT, AND MINI-ERCS (EHRT) CON-DUCTED A MEETING AT EPA OFFICE, PHILADELPHIA AT 1300 HRS. TODISCUSS THE SCOPE OF WORK AT THE AMBLER SITE. A SITE VISITW

WAS ALSO CONDUCTED TO COORDINATE AND FINALIZE THE SCOPE OFWORK.

F. PERSONNEL ON SITE: EPA - 2, TAT - 2, MINI-ERCS - 4.G. WEATHER: SUNNY AND CLEAR, WITH TEMP IN THE LOW 40'S.

II. ACTIONS TAKENA. A SITE WALK THROUGH WAS CONDUCTED, EMPHASIS WAS DIRECTED

TOWARD PLACEMENT OF THE FENCE AND GATES AROUND THE ASBESTOSPILES AT THE SITE (LOCUST ST. AND PLANT PILES). SEVERAL AREASOF EXPOSED ASBESTOS HERE OBSERVED AS NEEDING IMMEDIATEATTENTION.

B. MINI-ERCS INFORMED OSC YOUMIS THAT EARTH WORK (CLEARING ANDGRUBBING) WOULD BE NECESSARY FOR PROPER FENCE INSTALLATION.

C. OSC YOUNIS DISCUSSED THE PROPOSED EXPANDED SCOPE OF WORKWITH ASSISTANT BRANCH CHIEF 'CARNEY. AN ADDITIONAL FUNDINGREQUEST WILL PREPARED TO INCLUDE APPROPRIATE MEASURES TOSECURE AND MAINTAIN THE ASBESTOS PILES.

D. MINI-ERCS (EHRT) BEGAN SUBCONTRACTOR COORDINATION FOR SITEOPERATIONS TO BEGIN ON 3/6/B9.

III. FUTURE PLANSA. OSC YOUNIS REQUESTED TAT TO PREPARE AN ADDITIONAL FUNDING

REQUEST, BY 3/1/89 TO REFLECT THE EXPANSION OF THE EXISTINGSCOPE OF WORK WHICH DID NOT INCLUDE: REMOVAL OF TREES ANDASSOCIATED EARTH WORK INVOLVED IN THE INSTALLATION OF THEFENCE, MAINTENANCE OF THE ASBESTOS PILES, AND COVERING THEEXPOSED AREAS OF ASBESTOS.

B. OSC TO COORDINATE WITH REMEDIAL ENFORCEMENT (ABREU), A PLANFOR IMMEDIATE ACTIONS WHICH WILL SECURE AND MAINTAIN THE SITEWHILE REMAINING CONSISTENT WITH FUTURE REMEDIAL ACTIONS.

C. OSC TO CONTINUE COORDINATION EFFORTS WITH EPA/OPA AND PA DER.D. MINI-ERCS (EHRT) TO CONTINUE TO COORDINATE AND ARRANGE FOR

SCHEDULED SITE OPERATIONS.

PHIL YOUNIS, OSCUS EPA, REGION IIIPHILADELPHIA, PA ARI 00036


From: REGION03.TAT (EPA9322) Delivered: Wed 15-Mar-89 21:55EST Sys 163 (60)Subject: AMBLER ASBESTOS SITE POLREP #2Mall Id! IPM-163-890315-197320256POLREP #2AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN: STEVE JARVELA AND TIM FIELDS

I. SITUATION (1700 HRS, TUESDAY, 3/7/89)A. 3/6/89 - SITE MOBILIZATION OPERATIONS BEGAN AT 0700 HRS.

MINI-ERCS MOBILIZED A COMMAND POST (25 FT. RV) AND TWO MINIVANS. SITE OPERATIONS WERE SUSPENDED AT NOON HOWEVER, DUE TOEARLY MORNING FREEZING RAIN WHICH TURNED INTO SNOWACCUMULATING TO APPROXIMATELY 3 INCHES. SITE OPERATIONS TORESUME AS SOON AS WEATHER PERMITS.

B. WHILE ON SITE, TAT OBSERVED NEIGHBORHOOD YOUTHS SLEDDING ONTHE LOCUST STREET ASDESTOS PILE.

C. 3/7/89 - SITE OPERATIONS RESUME. PERSONNEL ON SITE: EPA-2,TAT-3, MINI-ERCS- 5.

D. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMANDPOST BECAUSE OF THE LACK OF WORKING SPACE IN MINI-ERCS'COMMAND POST.

E. OSC YOUNIS ON SITE TO COORDINATE CONTRACTOR OPERATIONS.F. FAO MESSIMER ON SITE TO IMPLEMENT THE REMOVAL COST MANAGEMENT

SYSTEM AND ASSIST WITH ADMINISTRATIVE DUTIES.G. WEATHER: SUNNY AND CLEAR, WITH TEMPERATURE IN THE LOW 30'S.

II. ACTIONS TAKENA. 3/6/89 MINI-ERCS BEGAN DISMANTLING THE EXISTING FENCE ALONG

LOCUST STREET. LOCUST STREET IS DIRECTLY ADJACENT TORESIDENTIAL HOMES, CONSEQUENTLY EXPEDIENT FENCE INSTALLATIONIS A PRIORITY IN THIS AREA.

B. MINI-ERCS SCHEDULED SECURITY AS DIRECTED BY THE OSC TO BE ONSITE DURING OFF HOURSTO INSURE THAT NO TRESPASSING OCCURS.

C. 3/7/89 - MINI-ERCS COMPLETED DISMANTLING THE EXISTING FENCEALONG LOCUST STREET AND BEGAN INSTALLATION OF THE NEW FENCE.

D. MINI-ERCS BEGAN CLEARING AND GRADING FOR THE PROPOSED FENCE.AS A PRECAUTIONARY MEASURE, CLEAN FILL WILL BE BROUGHT IN ANDUSED TO CREATE A UNIFORM GRADIENT IN AREAS OF UNEVENELEVATION.

E. TAT DRAFTED AN ADDITIONAL FUNDING REQUEST WHICH WAS EMAILEDTO REGIONAL HEADQUARTERS FOR REVIEW.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE FENCE INSTALLATION ALONG 'LOCUST STREET.

ANTICIPATED COMPLETION OF LOCUST STREET PORTION BY 3/10/89.B. MINI-ERCS TO CONTINUE GRADING AND CLEARING IN PREPARATION FOR

THE FENCE INSTALLATION.C. TAT TO PREPARE AN OBJECTIVE FOR THE PROPOSED ENGINEERING

ANALYSIS WHICH WILL ADDRESS THE EXISTING HAZARDOUS CONDITIONSON SITE.

D. MINI-ERCS TO COORDINATE SITE SECURITY UNTIL THE FENCE ALONGTHE LOCUST STREET PILE IS ERECTED, THUS PROHIBITING ACCESS.

F. EPA ENFORCEMENT (ABREU) TO BE ON SITE 3/8/89 TO REVIEWPROPOSED REMOVAL ACTIONS.

PHIL YOUNIS, OSCUS EPA, REGION III, PHILADELPHIA, PA flft/00037

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To: ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)

11 To: REGIQN03.TAT (EPA9322)TO! RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Wed 15-Mar-89 21:56EST Sys 163 (57)Subject: AMBLER ASBESTOS SITE POLREP #3Mail Id: IPM-163-890315-197541076POLREP #3AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN: STEVE JARVELA AND TIM FIELDS

I, SITUATION (1800 HRS, THURSDAY, 3/9/89)A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND

POST.B. PERSONNEL ON SITE: EPA-2, TAT-3, MINI-ERCS- 7.C. ESTIMATED PROJECT COSTS TO DATE (C.O.B. 3/8/B9)

COSTS CEILINGSEPA (DIRECT) $ 1,690 $ 13,100

(INDIR) 2,912 22,430TAT 6,043 7,850MINI-ERCS 17,433 50,000

TOTAL $ 27,078 $ 93,380

D. FAO MESSIMER ON SITE AS EPA REPRESENTATIVE DURING OSC YOUNIS1ABSENCE. OSC YOUNIS NOT ON SITE DUE TO OTHER REGIONRESPONSIBILITIES. OSC MAINTAINED PHONE CONTACT WITH SITETHROUGHOUT THE DAY

E. EPA ENFORCEMENT (ABREU) ON SITE TO REVIEW THE PROPOSED ACTIONSINVOLVING SENSITIVE AREAS OF THE SITE.

F. WEATHER: SUNNY AND CLEAR, WITH TEMPERATURE IN THE LOW 40'S.II. ACTIONS TAKENA. 3/8/89 - MINI-ERCS CONTINUED FENCE INSTALLATION ON THE LOCUST

STREET PORTION OF THE SITE AND REMOVED THE PREVIOUSLYEXISTING FENCE MATERIAL FROM THE SITE.

B. MINI-ERCS CONTINUED CLEARING AND GRADING FOR THE PROPOSEDFENCE LINE.

C. SECURITY ON SITE DURING THE OFF HOURS TO PROHIBIT TRESPASSINGAND PROTECT CONTRACTOR EQUIPMENT.

D. 3/9/89 - MINI-ERCS CONTINUES TO INSTALL FENCE ON THE LOCUSTSTREET PORTION OF THE SITE.

E. CLEARING AND GRADING OPERATION FOR THE PROPOSED FENCE LINECONTINUES.

F. TAT AND EPA ENFORCEMENT REVIEWED ALL PROPOSED REMOVAL ACTIONSTO ENSURE CONSISTENCY WITH REMEDIAL ACTIONS.

G. SECURITY ON SITE DURING OFF HOURS.III. FUTURE PLANSA. MINI-ERCS TO CONTINUE FENCE INSTALLATION ALONG LOCUST STREET.

ANTICIPATED COMPLETION OF LOCUST STREET PORTION BY 3/10/89.B. MINI-ERCS TO CONTINUE GRADING AND CLEARING IN PREPARATION FOR



D. MINI-ERCS TO COORDINATE SITE SECURITY UNTIL THE FENCE ALONGTHE LOCUST STREET PILE IS ERECTED, THUS PROHIBITING ACCESS.

PHIL YOUNIS, OSCUS EPA, REGION IIIPHILADELPHIA, PA

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From: REGION03.TAT (EPA9322) Delivered: Mon 20-Mar-89 20:19 ESTSys 163 (50)Subject: AMBLER ASBESTOS SITE POLREP #4Mail Id: IPM-163-890320-182990632

POLREP #4AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIA

ATTN: STEVE JARVELA AND TIM FIELDS

I. SITUATION (1800 HRS, FRIDAY, 3/10/89)A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND

POST.B. PERSONNEL ON SITE: EPA-1, TAT-3, MINI-ERCS- 7.C. ESTIMATED PROJECT COSTS TO DATE (C.O.B. 3/9/89)

COSTS CEILINGSEPA (DIRECT) $ 1,995 $ 9,000

(INDIR) 3,432 17,380TAT 7,536 17,000MINI-ERCS 19,500 50,000

TOTAL $ 32,463 $ 93,380D. FAO MESSIMER ON SITE AS EPA REPRESENTATIVE DURING OSC YOUNIS1

ABSENCE. OSC YOUNIS NOT ON SITE DUE TO OTHER REGIONRESPONSIBILITIES, HOWEVER; OSC MAINTAINED PHONE CONTACTTHROUGHOUT THE DAY.

E. WEATHER: OVERCAST AND COLD, WITH TEMPERATURE IN THE LOW 40 'S.II. ACTIONS TAKENA. MINI-ERCS COMPLETED FENCE INSTALLATION ALONG LOCUST STREET.

THE GATES FOR LOCUST STREET WERE FABRICATED AT THE SHOP LATEIN THE AFTERNOON; THEREFORE, THE GATES WERE NOT INSTALLED THISDATE.

B. MINI-ERCS CONTINUED CLEARING AND GRADING ON THE SOUTHERN AKDNORTHERN PORTIONS OF THE PLANT PILE FOR THE PROPOSED FENCELINE.

C. MINI-ERCS BEGAN CONSTRUCTION OF A TEMPORARY STONE LOADING PADAT THE END OF LOCUST STREET IN ORDER TO ALLOW FILL TRUCKS TOUNLOAD THEIR CONTENTS ONTO THE SITE.

D. MINI-ERCS BEGAN CONSTRUCTION OF A STONE ACCESS ROAD TO THELOCUST STREET PILE PLATEAU. DUE TO SATURATEDED SOIL AND POORSLOPE STABILITY, TRUCKS WERE UNABLE TO DELIVER THE SOIL TO THEPLATEAU.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE GRADING AND CLEARING IN PREPARATION FOR



D. GATES TO BE INSTALLED ON LOCUST STREET ON 3/13/89.

PHIL YOUNIS, OSC 'US EPA, REGION IIIPHILADELPHIA, PA . „ .

flff/00039

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To: ERD/OERR (EPA55U)To: J.LUFFY (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Mon 20-Mar-89 20:21 ESTSys 163 (53)Subject: AMBLER ASBESTOS SITE POLREP #5Mail Id! IPM-163-890320-183190223POLREP # 5AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIA

ATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1900 HOURS, MONDAY, 3/13/89)

A. EPA FAO MESSIMER ON SITE AS EPA REPRESENTATIVE DURING OSCYOUNIS1 ABSENCE. OSC YOUNIS IS NOT ON SITE DUE TO OTHERREGIONAL RESPONSIBILTIES.

B. PERSONNEL ON SITE: EPA - 1, TAT - 2, MINI-ERCS - 7.C. ESTIMATED COSTS TO DATE: COB 3/10/89

COST TO DATE CEILINGEPA (DIRECT) $ 2,165 S 9,000EPA (INDIRECT) 3,718 17,380TAT 9,144 17,000ERCS 21,271 50,000

TOTAL 36,298 93,380D. WEATHER: OVERCAST AND COLD, TEMPERATURES IN THE UPPER

30'S.II. ACTIONS TAKEN

A. GATES INSTALLED ON LOCUST STREET FENCE, COMPLETING THATSECTION OF THE FENCE.

B. RAMP CONSISTING OF FILL DIRT AND NUMBER 4 STONECONSTRUCTED ON LOCUST STREET PILE TO ENABLE CEMENTAND FENCING TRUCKS TO GAIN ACCESS TO THE ELEVATEDWESTERN SECTION OF SITE.

C. MINI-ERCS BEGAN BORING HOLES FOR FENCE POST, ALONG SOUTHWESTERN PERIMETER OF SITE.

D. TAT CONTINUES TO PREPARE OBJECTIVES FOR THE PROPOSEDENGINEERING ANALYSIS WHICH WILL EVALUATE THE EXISTINGHAZARDOUS CONDITIONS ON SITE.

E. RAMP/PAD CONSISTING OF NUMBER 4 STONE AND FILL DIRT WASCONSTRUCTED AT THE END OF LOCUST STREET IN ORDER TOPROVIDE AN AREA OFF OF LOCUST STREET WHERE FILL DIRT COULDBE DUMPED.

F. EVENING SITE SECURITY WAS DISCONTINUED DUE TO THECOMPLETION OF THE EIGHT FOOT FENCE ALONG LOCUST STREETAND THE SNOW MELTING WHICH PREVENTED CHILDREN FROMSLEDDING.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE GRADING AND CLEARING IN PREPARATION

OF THE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND PERIMETER

OF SITE.C. TAT TO CONTINUE PREPARING A LIST OF OBJECTIVES FOR THE

, , PROPOSED ENGINEERING ANALYSIS OF HAZARDOUS CONDITIONS ON"-' SITE.

D. OSC YOUNIS TO BE ON SITE 3/15/89.

PHIL YOUNIS, OSCU.S. EPA, REGION .Til, PHILADELPHIA, PA jSRInn

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From: REGION03.TAT (EPA9322) Delivered: Mon 20-Mar-89 20:22 ESTSys 163 (SO)Subject: AMBLER ASBESTOS SITE POLREP #6Mail Id! IPM-163-890320-1B3440474


ATTN. STEVE JARVELA AND TIM FIELDS

I. SITUATION (1900 HOURS, WEDNESDAY, 3/15/89)A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND

POST.B. PERSONNEL ON SITE: EPA - 1, TAT - 2, MINI-ERCS - 7.C. ESTIMATED COSTS TO DATE: COB 3/14/89

COST TO DATE CEILINGEPA (DIRECT) $ 2,628 S 9,000EPA (INDIRECT) 4,700 17,380TAT 12,400 17,000ERCS . 42,000 50,000

TOTAL 61,728 93,380D. WEATHER: CLOUDY AND COLD, TEMPERATURES IN THE MID 40'S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.II. ACTIONS TAKEN .

A. 3/14/89 - MINI-ERCS CONTINUED FENCE INSTALLATION OPERATIONAROUND THE PLANT PILE.

B. CLEARING, GRADING, AND FILLING OPERATION CONTINUES ALONGTHE SOUTHERN END OF THE SITE.

C. MINI-ERCS BEGAN FENCE POST INSTALLATION ALONG SOUTHWESTERN PERIMETER OF SITE.

D. 3/15/89 - MINI-ERCS CONTINUES FENCE INSTALLATIONOPERATION AROUND THE PLANT PILE. APPROXIMATELY 1,390LINEAR FEET OF FENCE ERECTED TO DATE.

E. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE. APPROXIMATELY 50 LOADSOF SOIL, USED FOR GRADING AS WELL AS EXPOSED AREAS,DELIVERED THIS DATE. IN ORDER TO CONTINUE THE CLEARINGAND GRADING OPERATION, STREAM CROSSINGS WERE CONSTRUCTEDWITH STONE AND UNDERFLOW PIPING.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE CLEARING, GRADING, AND FILLING IN

PREPARATION OF THE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND THE

PERIMETER OF SITE.C. TAT TO CONTINUE PREPARING A LIST OF OBJECTIVES FOR THE

PROPOSED ENGINEERING ANALYSIS OF HAZARDOUS CONDITIONS ONSITE.

PHIL YOUNIS, OSCU. S. EPA, REGION IIIPHILADELPHIA, PA

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To: ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)To; REGION03.TAT (EPA9322)TO! RRC (EPA9374)




I. SITUATION (1900 HOURS, THURSDAY, 3/16/89)A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND


COST TO DATE CEILINGEPA (DIRECT) $ 2,900 $ 9,000EPA (INDIRECT) 5,000 17,380TAT 13,500 17,000ERCS 44,000 50,000

TOTAL 65,400 93,380D. WEATHER: SUNNY AND WARM, TEMPERATURES IN THE MID 60'S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.II. ACTIONS TAKEN

A. MINI-ERCS CONTINUES FENCE INSTALLATION OPERATION AROUNDNORTHERN AND SOUTHERN PORTIONS OF THE PLANT PILE.APPROXIMATELY 1,780 LINEAR FEET OF FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE. APPROXIMATELY 331LOADS OF SOIL DELIVERED THIS DATE. IN ADDITION TO SOIL,APPROXIMATELY 5 LOADS OF #4 STONE, 2 LOADS OF |3A MODIFIEDSTONE, AND 2 LOADS OF SURGE STONE DELIVERED TO SITE TO DATE.

C. TAT COMPLETED THE (DRAFT) ENGINEERING ANALYSIS OBJECTIVE.D. MINI-ERCS CONTRACTED THE AMBLER BOROUGH FIRE DEPARTMENT TO

WASH DOWN THE RESIDUAL DIRT ON LOCUST STREET FROM THE FILLTRUCKS.

III. FUTURE FLAMSA. MINI-ERCS TO CONTINUE CLEARING, GRADING, AND FILLING IN

PREPARATION OF THE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND THE

PERIMETER OF SITE.C. OSC TO MEET WITH EPA ENFORCEMENT TO DISCUSS THE ENGINEERING

ANALYSIS OBJECTIVE AND TO ENSURE ITS CONSISTANTANCY WITHREMEDIAL ACTIONS.

D. MINI-ERCS TO COORDINATE CONSULTING ENGINEERING FIRMS FORINVITATIONS TO BID ON THE ENGINEERING ANALYSIS.

PHIL YOUNIS, OSCu. s. EPA, REGION inPHILADELPHIA, PA

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I. SITUATION (1900 HOURS, FRIDAY, 3/17/89)A. ADDITIONAL FUNDING REQUEST APPROVED BY THE ACTING REGIONAL

ADMINISTRATOR (LASKOWSKI) .B. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND

POST.C. PERSONNEL ON SITE: EPA - 3, TAT - 2, MINI-ERCS - 7.D. ESTIMATED COSTS TO DATE: COB 3/16/89

COST TO DATE CEILINGEPA (DIRECT) $ 3,280 $ 15,000EPA (INDIRECT) 5,616 , 31,380

_ TAT 14,515 25,000j ERGS 46,540 65,000

TOTAL 69,951 136,000TOTAL PROJECT CEILING: $ 461,114

E. WEATHER: SUNNY AND COOL, TEMPERATURES IN THE UPPER 50 'S.F. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.G. THE CURRENT REMOVAL ACTIONS AT THIS SITE ARE SUBSEQUENT TO

THE START-UP ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSESECTION IN 1984. FINAL REMEDIES WILL BE INSTITUTED IN THENEAR FUTURE BY EPA'S REMEDIAL SECTION. THE AMBLER SITE ISON THE NATIONAL PRIORITIES LIST (NPL) .

II. ACTIONS TAKENA. MINI-ERCS CONTINUES FENCE INSTALLATION OPERATION AROUND

NORTHERN AND SOUTHERN PORTIONS OF THE PLANT PILE.APPROXIMATELY 2,886 LINEAR FEET OF FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE. APPROXIMATELY 400LOADS (273 TRIAXLE LOADS AND 127 TANDEM LOADS) OF SOILDELIVERED TO DATE. IN ADDITION TO SOIL, APPROXIMATELY 9LOADS OF |4 STONE, 4 LOADS OF |3A MODIFIED STONE, AND 4LOADS OF SURGE STONE DELIVERED TO SITE TO DATE.

C. THE AMBLER BOROUGH FIRE DEPARTMENT ON SITE TO WASH DOWN THERESIDUAL DIRT ON LOCUST STREET FROM THE FILL TRUCKS.

•-, D. EPA ENFORCEMENT (ABREU) ON SITE TO REVIEW THE ENGINEERING^ ANALYSIS. EPA ENFORCEMENT CONCURRED WITH THE OBJECTIVES OF

THE STUDY.

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E. EPA/OPA (SINCLAIR) ON SITE TO PARTICIPATE IN A SITE WALKTHROUGH WITH TAT AND EPA ENFORCEMENT. IN ADDITION, EPA/OPASPOKE WITH CONCERNED RESIDENTS ABOUT CURRENT REMOVALACTIVITIES.

F. MINI- ERCS "FAXED" A COPY OF THE ENGINEERING ANALYSIS SCOPEOF WORK TO THE CONSULTING FIRMS INVITED TO BID.

G. MINI-ERCS BEGAN APPLYING FILL DIRT TO THE AREAS OF EXPOSEDASBESTOS ON SITE.


PREPARATION FOR THE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND THE

PERIMETER OF SITE.C. MINI-ERCS TO REVIEW THE BIDS FOR THE ENGINEERING STUDY.

ANTICIPATED AWARD DATE, 3/22/89.D. MINI-ERCS TO CONTINUE COVERING THE AREAS OF EXPOSED

ASBESTOS ON SITE.


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To: ERD/OERR (EPA5511)TO! J.LUFFY (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)


POLREP f9AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIA


I. SITUATION (1900 HOURS, MONDAY, 3/20/89)A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND


COST TO DATE CEILINGEPA (DIRECT) $ 3,615 $ 15,000EPA (INDIRECT) 6,188 31,000TAT 15,657 25,000ERCS 77,611 • 165,000


D. WEATHER: OVERCAST AND COLD WITH TEMPERATURES IN THELOW 30'S.

E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOROPERATIONS.

F. FAO MESSIMER ON SITE TO ASSIST OSC WITH ADMINISTRATIVE •DUTIES CONCERNING CONTRACT ISSUES,

G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL SECTION IN 1984. FINALREMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL) .

H. PROCUREMENT REQUEST APPROVED FOR $ 100,000 TO INCREASEMINI-ERCS PROJECT CEILING TO $ 165,000.

II. ACTIONS TAKENA. MINI-ERCS CONTINUES FENCE POST INSTALLATION OPERATION

AROUND THE FILTER BED LAGOONS AND ALONG THE LOCUST STPILE PLATEAU.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE. APPROXIMATELY 423LOADS (292 TRIAXLE LOADS AND 131 TANDEM LOADS) OF SOILDELIVERED TO DATE.

C. SLOPE ON SOUTHEASTERN PORTION OF PLANT PILE 90 PERCENTCOMPLETE TO DATE.

D. EPA ENFORCEMENT (ABREU) CONTACTED OSC TO INFORM HIM OFTHE STATUS OF THE UNDERGROUND TANKS LOCATED IN THE REAR OFTHE PROCESS BUILDING ADJACENT TO THE PLANT PILE.

ARIOOOl*5

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E. OSC CONTACTED PA DER REPRESENTATIVE (GAMBITA) TO INFORMAND UPDATE HER ON EPA REMOVAL ACTIVITY.

F. MINI-ERCS BEGAN APPLYING FILL DIRT TO THE AREAS OF EXPOSEDASBESTOS ON SITE.

III. FUTURE PLANSA. KINI-ERCS TO CONTINUE CLEARING, GRADING, AND FILLING IN



ANTICIPATED AWARD DATE, 3/22/89.D. TAT TO PERFORM AIR MONITORING IN AND AROUND THE UNDERGROUND

STORAGE TANK AREA.


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To: ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)To: REGION03.TAT (EPA9322)TO! RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Mon 27-Mar-89 20:24 ESTSya 163 (51)Subject: AMBLER ASBESTOS SITE POLREP #10Mail Id: IPM-163-890327-183680224POLREP H10AMBLER ASBESTOS .TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1900 HOURS, TUESDAY, 3/21/89)

A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA .MOBILE COMMANDPOST.

B. PERSONNEL ON SITE: EPA - 2, TAT - 2, MINI-ERCS - 5.C. ESTIMATED COSTS TO DATE: COB 3/20/89

COST TO DATE CEILINGEPA (DIRECT) $ 4,265 $ 15,000EPA (INDIRECT) 7,306 31,000TAT 17,000 25,000ERGS 96,221 165,000


D. WEATHER: EARLY MORNING RAINS, HEAVY AT TIMES; TEMPERATURESIN THE LOW 40'S.

E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOROPERATIONS.

F. FAO MESSIMER ON SITE TO ASSIST OSC WITH ADMINISTRATIVEDUTIES CONCERNING CONTRACT ISSUES.

G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. DUE TO THE WET CONDITIONS AROUND SITE, THE FENCE

INSTALLATION, FILLING AND GRADING OPERATIONS HAVE BEENSUSPENDED TODAY.

B. MINI-ERCS CONTINUED CLEARING AND COLLECTING DEBRIS AROUNDTHE SITE.

C. MINI-ERCS PLACED "NO TRESPASSING" SIGNS ON THE ERECTEDFENCE AROUND THE SITE.

III. FUTURE PLANSA. MINI-ERCS TO RESUME CLEARING, GRADING, AND FILLING IN

PREPARATION FOR THE FENCE INSTALLATION.B. MINI-ERCS TO RESUME FENCE INSTALLATION AROUND THE


ANTICIPATED AWARD DATE, 3/22/89.D. TAT TO PERFORM AIR MONITORING IN AND AROUND THE UNDERGROUND

STORAGE TANK AREA.


ARIOOOU

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From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:25 EOT Sy163 (53)Subject: AMBLER ASBESTOS SITE POLREP #11Mail Id: IPM-163-890403-192790261

POLREP #11AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1900 HOURS, WEDNESDAY, 3/22/89)

A. AS PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMANDPOST.

B. PERSONNEL ON SITE: EPA-2, TAT-2, MINI-ERCS-5.C. ESTIMATED COST TO DATE: COB 3/21/89

COST TO DATE CEILINGEPA (DIRECT) $ 4,765 $ 15,000

(INDIRECT) 8,170 31,000TAT 17,920 25,000ERCS 121,730 165,000

TOTAL $ 152,585 $ 236,000TOTAL PROJECT CEILING: $461,114 ,

D. WEATHER: SUNNY, TEMPERATURES IN THE MID 60' S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.F. FAO MESSIMER ON SITE TO ASSIST OSC WITH ADMINISTRATIVE

DUTIES CONCERNING CONTRACT ISSUES.G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984 . FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST(NPL) .


AROUND THE FILTER BED LAGOONS AND ALONG THE LOCUSTST. PILE PLATEAU.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION.

C. CONCRETE TRUCK ON SITE TO FILL FENCE POST HOLES ALONG THELOCUST STREET PILE PLATEAU AND THE STAIRS AT THE FILTERBED LAGOONS.

D. MINI-ERCS RECEIVED TWO BIDS FOR THE ENGINEERING STUDY.,MINI-ERCS ANTICIPATES RECEIVING A THIRD BID BY 3/23/89.

E. TAT LOCATED THREE UNDERGROUND STORAGE TANKS BEHIND THEPLANT BUILDING ADJACENT TO THE PLANT PILE.


PREPARATION FOR THE FENCE INSTALLATION.B. MINI-ERCS TO CONTINUE FENCE POST INSTALLATION AROUND THE

PERIMETER OF SITE.C. TAT TO PERFORM AIR MONITORING IN AND AROUND THE UNDERGROUND

STORAGE TANK AREA BEHIND THE PLANT BUILDING.

PHIL YOUNIS, OSC ARI00048U.S EPA, REGION III

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From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:26 EOT Sy163 (62)Subject: AMBLER ASBESTOS SITE POLREP #12Mail Id! IPM-163-890403-193010763POLREP #12AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1700 HOURS, THURSDAY, 3/23/89)

A. PER OSC'S REQUEST, TAT MOBILIZED THE EPA MOBILE COMMAND POST.B. PERSONNEL ON SITE: EPA-2, TAT-2, MINI-ERCS-5.C. ESTIMATED COST TO DATE: COB 3/23/89



TOTAL $ 181,467 $ 236,000TOTAL PROJECT CEILING: $461,114

D. WEATHER: SUNNY, TEMPERATURES IN THE LOW 60'S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR


DUTIES CONCERNING CONTRACT ISSUES. ,G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THE NPL.


AROUND THE FILTER BED LAGOONS AND ALONG THE LOCUST ST. PILEPLATEAU. APPROX. 3,550 LINEAR FEET FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION.

C. TAT SAMPLED THE VENT PIPES OF THE UNDERGROUND STORAGE TANKSLOCATED BEHIND THE PLANT BUILDING ADJACENT TO THE PLANTPILE. TWO OF THE THREE EXHAUST PIPES EXHIBITED POSITIVEDEFLECTIONS ON THE ORGANIC VAPOR ANALYZER; EXHAUST #2 YIELDEDAPPROXIMATELY 5,000 UNITS AND EXHAUST PIPE #3 YIELDEDAPPROXIMATELY 1,500 UNITS. UPON INVESTIGATION TAT SUSPECTS1,000 TO 2,000 GALLONS OF VOLATILE ORGANIC LIQUID TO BECONTAINED IN THE TANK(S).

D. MINI-ERCS BEGAN TREE CUTTING ON THE SOUTHERN PORTION OF THELOCUST STREET PILE WHERE AREAS OF EXPOSED ASBESTOS ARE TOBE COVERED.



PERIMETER OF SITE.C. MINI-ERCS TO BEGIN APPLYING SOIL COVER TO EXPOSED ASBESTOS

ON SOUTHERN PORTION OF THE LOCUST STREET PILE.D. OSC AND TAT TO CONTACT REMEDIAL ENFORCEMENT IN REFERENCE TO

UNDERGROUND STORAGE TANKS.

PHIL YOUNIS, OSC • n I fl D D !• QU.S EPA, REGION III, PHILADELPHIA, PA H R I U U U 4 3

H tht page filmed in thiA inamt it not at *eadabl.e..o* legible.** thitlabel, 4.t it due to AubAto.nda.nd colon on condition o\ tht oniginal page.


From: REGION03.TAT (EPA9322) Delivered; Mon 3-Apr-89 21:28 EDT Sy163 (56)Subject: AMBLER ASBESTOS SITE POLREP #13Mail Id: IPM-163-890403-193250260

POLREP #13AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1700 HOURS, MONDAY, 3/27/89)


B. PERSONNEL ON SITE: EPA-2, TAT-2, MINI-ERCS-4.C. ESTIMATED COST TO DATE: COB 3/23/89

COST TO DATE CEILINGEPA (DIRECT) S 5,630 ? 15,000

(INDIRECT) 9,646 31,000TAT 20,600 25,000ERGS 157,200 165,000


D. WEATHER: SUNNY AND CLEAR, TEMPERATURES IN THE MID 60'S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR


DUTIES CONCERNING CONTRACT ISSUES.G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST(NPL).

II. ACTIONS TAKENA. MINI-ERCS CONTINUED FENCE INSTALLATION AROUND THE FILTER

BED LAGOONS AND ALONG THE LOCUST ST. PILE PLATEAU.APPROXIMATELY 4,210 LINEAR FEET OF FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE.

C. MINI-ERCS BEGAN APPLYING SOIL COVER TO THE SOUTHERN PORTIONOF THE LOCUST STREET PILE WHERE AREAS OF EXPOSED ASBESTOSARE TO BE COVERED.



PERIMETER OF SITE.C. MINI-ERCS TO CONTINUE APPLYING SOIL COVER TO EXPOSED

ASBESTOS ON SOUTHERN PORTION OF THE LOCUST STREET PILE.D. MINI-ERCS TO AWARD THE ENGINEERING ANALYSIS ON 3/29/89.

MINI-ERCS ENCOUNTERED DIFFICULTIES ACQUIRING THE THIRD BIDWHICH DELAYED THE AWARD PROCEDURE.

E. MINI-ERCS TO SEEK BIDS FOR SITE RESTORATION WORK (HYDRO-SEEDING AND CONCRETE REPAIR WORK ON THE ROADS ENTERING THESITE).

PHIL YOUNIS, OSCU.S. EPA, REGION III . nPHILADELPHIA, PA HR

'/ifcf»'"'!;*fl5 w*W* iH ij> i***!il 'U Mt "* *«« <«. o<«fl l*,.«A.<ikI» lE.,-.label, 4.t 4.4 due to AubAtandand colon on condition oi tfte o*iginal page.


From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:29 EOT Sy•">, 163 (54)

- Subject: AMBLER ASBESTOS SITE POLREP #14Mail Id: IPM-163-890403-193451172

POLREP #14AMBLER ASBESTOS TAILINGS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1500 HOURS, TUESDAY, 3/28/89)


B. PERSONNEL ON SITE: EPA-1, TAT-2, MINI-ERCS-5.C. ESTIMATED COST TO DATE: COB 3/27/89.

COST TO DATE CEILINGEPA (DIRECT) $ 6,200 ? 15,000


TOTAL $ 197,200 $ 236,000TOTAL PROJECT CEILING: $ 461,114

D. WEATHER: SUNNY AND WARM, TEMPERATURES IN THE MID 70'S.E. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.F. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL),

II. ACTIONS TAKENA. MINI-ERCS CONTINUES FENCE INSTALLATION AROUND THE FILTER

BED LAGOONS AND ALONG THE LOCUST ST. PILE PLATEAU.APPROXIMATELY 5,305 LINEAR FEET OF FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUES CLEARING, GRADING, AND FILLINGOPERATION FOR PROPOSED FENCE LINE. APPROXIMATELY 462 LOADS(343 TRIAXLE LOADS AND 119 TANDEM LOADS) OF SOIL DELIVEREDTO DATE.

C. MINI-ERCS CONTINUES APPLYING SOIL COVER TO THE SOUTHERNPORTION OF THE LOCUST ST. PILE WHERE AREAS OF EXPOSEDASBESTOS ARE TO BE COVERED.

D. OSC, TAT, AND MINI-ERCS EVALUATE/DISCUSS ENGINEERINGCONSULTANT PROPOSALS.

E. MINI-ERCS RECEIVED BIDS FOR SITE RESTORATION WORK (HYDRO-SEEDING AND CONCRETE REPAIR WORK).



PERIMETER OF SITE.C. MINI-ERCG TO AWARD THE ENGINEERING ANALYSIS ON 3/29/89.D. MINI-ERCS TO SCHEDULE/FINALIZE THE RESTORATION WORK FOR THE

SITE.

PHIL YOUNIS OSCU.S. EPA, REGION III AR I 0005PHILADELPHIA, PA

. . ... , .......... ..„,..,„„.„ -...-.. ..tni. r,. M"<, »- ' v., --- ». ^ ytff r

li\\tht page filmed in tni.4 inamt iA not a4 ntadabitôn, legible a* t-label, *t it due to AubAtandand colon on condition oi tht original page.


From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:31 EDT Sy163 (52)Subject: AMBLER ASBESTOS SITE POLREP #15Mail Id: IPM-163-890403-.193670774

POLREP #15AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDS •I. SITUATION (1700 HOURS, WEDNESDAY, 3/29/89)

A. PERSONNEL ON SITE: EPA-0, TAT-1, MINI-ERCS-5.B. OSC YOUNIS OFFSITE DUE TO OTHER REGIONAL COMMITMENTS.

HOWEVER, OSC IN CONTACT THROUGHOUT THE DAY VIA TELEPHONE.C. ESTIMATED COST TO DATE: COB 3/23/89

COST TO DATE CEILINGF?A (DIRECT) $ 6,500 $ 15,000



D. WEATHER: PARTLY CLOUDY AND WARM, TEMPERATURES IN THE MIDTO UPPER 70'S.

E. PURCHASE REQUEST OF AN ADDITIONAL $ 150,000 APPROVED THISDATE.

F. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. MINI-ERCS CONTINUED FENCE INSTALLATION ALONG THE SOUTHERN

PORTION OF THE LOCUST STREET PILE AND ALONG THE BASE OF THELOCUS ST. PILE NEAREST THE RESIDENTS HOMES. APPROXIMATELY85 PERCENT OF FENCE ERECTED TO DATE.

B. MINI-ERCS CONTINUED APPLYING SOIL COVER TO THE SOUTHERNPORTION OF THE LOCUST ST. PILE WHERE AREAS OF EXPOSED

, ASBESTOS ARE TO BE COVERED.C. MINI-ERCS AWARDED THE ENGINEERING ANALYSIS THE LOWEST

BIDDER, DYNAMAC CORP. THIS DATE.III. FUTURE PLANS

A. MINI-ERCS TO CONTINUE APPLYING FILL MATERIAL TO THE EXPOSEDAREAS OF ASBESTOS AROUND THE SITE.

B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND THEPERIMETER OF SITE,

C. ENGINEERING CONSULTANTS FROM DYNAMAC CORP. TO BE ON SITE3/31/89 TO BEGIN THE ENGINEERING ANALYSIS.

D. MINI-ERCS TO SCHEDULE/ FINALIZE THE RESTORATION WORK FORTHE SITE.

PHIL YOUNIS osc iiDinnncoU.S. EPA, REGION III AR I 00052PHILADELPHIA, PA

"*H*"H tht page <il«ed in thiA ina*t it not at ntadablnjin. *.v*H..t. •«. »*4.w,k,.label, 4.t 4.A due to ûb4tanda«d colo* on condition oi tht oniginal\pagt.

To: ERD/OERR (EPA5511)'.' To: J.LUFFY (EPA9314)

To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

r^. From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:32 EOT Sy-•• 163 (52)

Subject: AMBLER ASBESTOS SITE POLREP #16Mail Id! IPM-163-890403-193871125

POLREP #16AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1700 HOURS, THURSDAY/ 3/30/89)

A. PERSONNEL ON SITE: EPA-0, TAT-1, MINI-ERCS-5.B. OSC YOUNIS OFFSITE DUE TO OTHER REGIONAL COMMITMENTS.

HOWEVER, OSC IN CONTACT THROUGHOUT THE DAY VIA TELEPHONE.C. ESTIMATED COST TO DATE: COB 3/24/89




D. WEATHER: PARTLY CLOUDY WITH RAIN IN THE LATE AFTERNOON,TEMPERATURES IN THE MID TO UPPER 70'S. IN THE AFTERNOONSITE WORK WAS HAMPERED DUE TO RAIN.

E. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA REMEDIAL SECTION. THE AMBLER SITE IS ON THE NATIONALPRIORITIES LIST (NPL).

II. ACTIONS TAKENA. MINI-ERCS CONTINUED FENCE INSTALLATION ALONG THE SOUTHERN

PORTION OF THE LOCUST STREET PILE AND ALONG THE BASE OF THELOCUST STREET PILE NEAREST THE RESIDENTS' HOMES.

B. MINI-ERCS CONTINUED APPLYING SOIL COVER TO THE SOUTHERNPORTION OF THE LOCUST ST. PILE WHERE AREAS OF EXPOSEDASBESTOS ARE TO BE COVERED.

C, MINI-ERCS FINALIZED THE BID PROCESS FOR SITE RESTORATIONAND BEAUTIFICATION (HYDROSEEDING) WORK.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE APPLYING FILL MATERIAL TO THE EXPOSED

AREAS OF ASBESTOS AROUND THE SITE, WEATHER PERMITTED.HEAVY RAINS ARE PREDICTED FOR LATE 3/30/89 INTO 3/31/89.

B. MINI-ERCS TO CONTINUE FENCE INSTALLATION AROUND THE •PERIMETER OF SITE.

C. ENGINEERING CONSULTANTS (DYNAMAC CORP.) TO BE ON SITE3/31/89 TO BEGIN THE ENGINEERING ANALYSIS.

D. HYDROSEEDING CONTRACTOR TO BE ON SITE 4/1/89, WEATHERPERMITTING, TO SEED THE LOCUST STREET PILE AREAS.

E. ROAD AND SIDEWALK REPAIR WORK SCHEDULED FOR 4/4/89.

G ———-——-PHIL YOUNIS OSCU.S. EPA, REGION IIIPHILADELPHIA, PA AR I 00053

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label, 4.t 4.4 due to AubAtandand colon on condition oi tht oniginal page.

To: ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)To; REGION03.TAT (EPA9322)TO! RRC (EPA9374)

From; REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:34 EDT Sy163 (76)Subject; AMBLER ASBESTOS SITE POLREP #17Mail Id! IPM-163-890403-194150855

POLREP #17AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (2000 HOURS, FRIDAY, 3/31/89)

;.. PERSONNEL ON SITE: EPA-2, TAT-1, MINI-ERCS-5.B. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR

OPERATIONS.C. FAO MESSIMER ON SITE TO ASSIST OSC WITH ADMINISTRATIVE

DUTIES CONCERNING CONTRACT ISSUES.D. ESTIMATED COST TO DATE: COB 3/30/89




E. WEATHER: RAIN IN LATE MORNING, AND THROUGHOUT THE DAY KITHLATE AFTERNOON THUNDERSTORMS, TEMPERATURES IN THE MID TOUPPER 40'S.

F. WEATHER CONDITIONS SEVERELY HAMPERED SITE ACTIVITY THISDATE. EXTENSIVE EARTH WORK AND SITE RESTORATION ACTIVITIESWILL RESUME THE WEEK OF 4/3/89.

G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. MINI-ERCS RESUMED FENCE INSTALLATION ON THE EASTERN PORTION

OF THE PLANT PILE AND ERECTED THE REMAINING PORTION OFFENCE ON LOCUST STREET, COMPLETING THE WESTERN HALF OF THESITE

B. MINI-ERCS COMPLETED APPLICATION OF SOIL COVER TO THESOUTHERN PORTION OF THE LOCUST ST. PILE WHERE AREAS OFEXPOSED ASBESTOS WERE COVERED. APPROXIMATELY 600 LOADS OFSOIL, FOR A TOTAL OF ABOUT 11,000 CUBIC YARDS, HAVE BEENDELIVERED TO DATE.

C. ENGINEERING CONSULTANT (DYNAMAC CORP.) ON SITE TO PERFORMSAMPLING AND DATA COLLECTION FOR THE ENGINEERING ANALYSIS.

D. OSC YOUNIS COORDINATED WITH EPA ENFORCEMENT (ABREU) FORACTION TO BE TAKEN CONCERNING THE UNDERGROUND STORAGETANKS.

E. OSC YOUNIS MET WITH PRP (ROSE) CONCERNING EPA'S PROPERTY/FENCE LINE. OSC YOUNIS SPOKE WITH EPA ENFORCEMENT (ABREU)ABOUT THE PROPERTY LINE; IT WAS DETERMINED THAT THE FENCESHOULD INCLUDE ALL OF, THE FILTER BED LAGOONS AND THECONTAMINATED EQUIPMENT AND DEBRIS STORED ADJACENT TO THELAGOONS. AN ADDITIONAL 600 LINEAR FEET OF FENCE WfflLRHAVE TO BE ERECTED. "

*«5* U not " *tadablt.on. Itgibltat.due to AubAtandand colon on condition oi tht oniginal page.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE APPLYING FILL MATERIAL TO THE EXPOSED

AREAS OF ASBESTOS AROUND THE SITE, WEATHER PERMITTING.HEAVY RAINS ARE STILL ANTICIPATED CREATING WET CONDITIONSAROUND THE SITE.

' B. MINI-ERCS TO COMPLETE FENCE INSTALLATION ON THE EASTERNPORTION OF THE PLANT PILE AND TO SCHEDULE ADDITIONAL FENCEWORK AROUND THE FILTER BED LAGOON AREA.

C. HYDROSEEDING CONTRACTOR TO BE ON SITE WEEK OF 4/3/89 TOSEED THE LOCUST STREET PILE AREA.

D. ENGINEERING ANALYSIS TO BE COMPLETED BY 4/10/89 IN ORDER TOPROVIDE EPA ENFORCEMENT WITH A TECHNICAL RECOMMENDATION,ASSOCIATED WITH CURRENT SITE CONDITIONS, FOR NEGOTIATIONWITH THE PRP.

E. CONCRETE CONTRACTOR TO BE ON 'SITE WEEK OF 4/3/89 FOR REPAIRWORK.

PHIL YOUNIS OSCU.S. EPA, REGION IIIPHILADELPHIA, PA

G

ARI00055

- . * " - . -4.t due to 4ub4tanda«d colo* o* condition o< tne original page.

To; ERD/OERR (EPA5511)To: J.LUFFY (EPA9314) iiTo: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Mon 3-Apr-89 21:35 EOT Sy163 (53)Subject; AMBLER ASBESTOS SITE POLREP #18Mail Id: IPM-163-890403-194381150

POLREP #18AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDS 'I. SITUATION (2000 HOURS, SATURDAY, 4/1/89)

A. PERSONNEL ON SITE: EPA-2, TAT-1, MINI-ERCS-5.B. OSC YOUNIS ON SITE TO COORDINATE AND OVERSEE CONTRACTOR





TOTAL $ 342,100 < $ 386,000_ TOTAL PROJECT CEILING: $461,114) E. WEATHER: PARTLY CLOUDY AND COLD, TEMP. IN THE MID 40'S.


II. ACTIONS TAKENA. MINI-ERCS CONTINUED FENCE INSTALLATION ON THE EASTERN

PORTION OF THE PLANT PILE. APPROXIMATELY 6,500 LINEAR FEETOF FENCE ERECTED TO DATE WITH INSTALLATION APPROXIMATELY95* COMPLETE.

B. MINI-ERCS SCHEDULED THE ADDITIONAL FENCE INSTALLATION FOR4/3/89.

C. MINI-ERCS CLEARED DEBRIS AND PREPARED THE AREA AROUND THEFILTER BED LAGOONS FOR THE FENCE INSTALLATION.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE THE FENCE INSTALLATION; ANTICIPATED

COMPLETION 4/5/89.B. HYDROSEEDING CONTRACTOR TO BE ON SITE WEEK OF 4/3/89 TO

SEED THE LOCUST STREET PILE AREAS, WEATHER PERMITTING.C. ENGINEERING ANALYSIS TO BE COMPLETED BY 4/10/89 IN ORDER TO

PROVIDE EPA ENFORCEMENT WITH A TECHNICAL RECOMMENDATION,ASSOCIATED WITH CURRENT SITE CONDITIONS, FOR NEGOTIATIONWITH THE PRP.

D. CONCRETE CONTRACTOR TO BE ON SITE WEEK OF 4/3/89 FOR REPAIRQ WORK.

PHIL YOUNIS, OSCu.s. EPA, REGION in dDiPHILADELPHIA, PA fl R I

. ,. _ . ,.•.,.. _„___.„....,„„_ „,_____„__,,,... •—--.. u*.*.nn>ft""r-"m*,-, r, .. .if» .~* ~~.~ .™ .,:"j'..-, .ir/ff,"y"™Ii'7U tht page lued in tni.» inamt it not at ntadablt.j>n...legible, a*. /label, 4.t it due to 4ub4tanda«d colo* o* condition oi tht oniginal page.

To; ERD/OERR (EPA5511)To: J.LUFFY (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Sun 9-Apr-89 12:30 EDT Sya163 (48)Subject: AMBLER ASBESTOS SITE POLREP #19Mail Id: IPM-163-890409-112530603

POLREP #19AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1800 HOURS, MONDAY, 4/3/89)





(INDIRECT) 13,650 28,000TAT 25,450 30,000ERGS 302,258 > 315,000


E. WEATHER: MORNING RAINS CLEARING LATE IN THE AFTERNOON,TEMP. IN THE MID TO HIGH 50'S.


II. ACTIONS TAKENA. MINI-ERCS COMPLETED FENCE INSTALLATION ON THE EASTERN

PORTION OF THE PLANT PILE.B. MINI-ERCS BEGAN FENCE POST HOLE BORING FOR THE INSTALLATION

OF THE ADDITIONAL 600 LINEAR FEET OF FENCE AROUND THEFILTER BED LAGOON AREA.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE THE FENCE INSTALLATION; ANTICIPATED

COMPLETION 4/5/89.B. HYDROSEEDING CONTRACTOR TO BE ON SITE WEEK OF 4/3/89 TO

SEED THE LOCUST STREET PILE AREAS, WEATHER PERMITTING.C. ENGINEERING ANALYSIS TO BE COMPLETED BY 4/10/89.D. CONCRETE CONTRACTOR TO BE ON SITE WEEK OF 4/3/89 FOR REPAIR

WORK.

PHIL YOUNIS, OSCU.S. EPA, REGION IIIPHILADELPHIA, PA

ARI00057

IJ tht page filmed in thiA inamt it not at ntadablt..on Itgiblt.at -label, it iA due to AubAtandand colon on condition oi tht oniginal page.


From: REGION03.TAT (EPA9322) Delivered: Sun 9-Apr-89 12:36 EDT Sys163 (49)Subject: AMBLER ASBESTOS SITE POLREP #20Mail Id: IPM-163-890409-U340H67

POLREP #20AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1600 HOURS, WEDNESDAY, 4/5/89)


OPERATIONS.D. ESTIMATED COST TO DATE: COB 4/4/89



TOTAL $ 353,725 ' $ 386,000TOTAL PROJECT CEILING: $461,114

E. WEATHER: OVERCAST AND WARM, TEMP IN THE MID 60'S.F. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. 4/4/89 - MINI-ERCS COMPLETED THE FENCE INSTALLATION OPERATION

ON THE EASTERN PORTION OF THE LOCUST STREET PILE ANDCONTINUED THE INSTALLATION OF THE ADDITIONAL FENCE AROUND THEFILTER BED LAGOONS.

B. 4/5/89 - MINI-ERCS COMPLETED THE INSTALLATION OF THEADDITIONAL 600 LINEAR FEET OF FENCE AROUND THEFILTER BED LAGOON AREA. TOTAL FENCE ERECTED: 6,780 LINEARFEET.

III. FUTURE PLANSA. HYDROSEEDING CONTRACTOR TO BE ON SITE 4/7/89, WEATHER

PERMITTING.B. ENGINEERING ANALYSIS TO BE COMPLETED BY 4/10/89.C. CONCRETE CONTRACTOR TO BE ON SITE 4/7/89 FOR REPAIR

WORK, WEATHER PERMITTING.D. MINI-ERCS TO FINALIZE THE FENCE INSTALLATION WITH THE

MODIFICATION OF THE GATES ON LOCUST STREET. THE MODIFICATIONCONSISTS OF EXTENSIONS WHICH WILL BE FABRICATED ON 4/7/89.

PHIL YOUNIS, OSCU.S. EPA, REGION III

*»««.» JRI00058'

„ . ,,,,, sssH«iiliip«ltgiblt,,at. kit &E;.;':.

it it due1 to 4ub4tanda*d colo* o* condition oi tht oniginalagY.


From: REGION03.TAT (EPA9322) Delivered: Tue ll-Apr-89 15:51EOT Sys 163 (47)Subject: AMBLER ASBESTOS SITE POLREP #21Mail Id: IPM-163-890411-142651144

POLREP #21AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1600 HOURS, FRIDAY, 4/8/89)

A. 4/6/89 - NO WORK PERFORMED AT THE SITE THIS DATE.B. 4/7/89 - PERSONNEL ON SITE: TAT-1, MINI-ERCS-1.C. 4/8/89 - PERSONNEL ON SITE: TAT-1, MINI-ERCS-1.D. OSC YOUNIS NOT ON SITE DUE TO OTHER REGIONAL COMMITMENTS.

OSC MAINTAINED TELEPHONE CONTACT WITH THE SITE THROUGH THEDAY (4/7S8/89) TO DIRECT THE RESTORATION ACTIVITIES.

E. ESTIMATED COST TO DATE: COB 4/4/89COST TO DATE CEILING

EPA (DIRECT) $ 8,222 $ 13,000(INDIRECT) 13,988 28,000

TAT 25,881 30,000ERGS 305,644 315,000


F. WEATHER: OVERCAST AND COOL, TEMP IN THE MID 40'S.G. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP


II. ACTIONS TAKENA. 4/7/89 - MINI-ERCS COMPLETED HYDROSEEDING OF THE SIDE SLOPES

WHERE FILL MATERIAL HAS BEEN APPLIED TO EXPOSED AREAS OFASBESTOS. IN ADDITION AREAS CLEARED OF VEGETATION, FOR THEFENCE LINE, HAVE BEEN RE-VEGETATED.

B. FENCE INSTALLATION FINALIZED WITH THE MODIFICATION OF THEGATES ON LOCUST STREET.

C. 4/8/89 - ROADS ON SITE WHICH WERE IMPACTED DUE TO THE HEAVYTRUCK TRAFFIC WERE REPAIRED THIS DATE.

III. FUTURE PLANSA. ENGINEERING ANALYSIS TO BE COMPLETED BY 4/10/89.B. CONCRETE CONTRACTOR TO BE ON SITE 4/11/89 FOR REPAIR

WORK ON LOCUST STREET, WEATHER PERMITTING.


ARI00059

.label, 4.t 4.4 due to 4ub4tanda«d colo* o* condition oi the original page.

To: ERD/OERR (EPA5511)To: J.V.INISKI (EPA9314) iTo: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Tue 2-May-89 21:34EDT Sys 163 (56)Subject: AMBLER ASBESTOS SITE POLREP #22Mail Id: IPM-163-890502-194140809

POLREP #22AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVKLA AND TIM FIELDSI. SITUATION (1500 HOURS, MONDAY', 5/1/89)

A. OSC COORDINATED WITH EPA/REMOVAL MANAGEMENT, EPA/OPA, ANDEPA/REGIONAL COUNCIL CONCERNING THE POSITIVE SAMPLE RESULTSOF THE PLAYGROUND. A DECISION WAS MADE TO KEEP THEPLAYGROUND OPEN; HOWEVER, ATTEMPTS WILL BE MADE TO DIVERT THESURFACE WATER RUNOFF FROM THE SLOPES TO ANOTHER AREA ON SITEAND TO DECONTAMINATE THE PLAYGROUND PAD. THE ADDITIONAL WORKWILL PERFORMED UNDER THE CURRENT PROJECT CEILING.

B. ESTIMATED COST TO DATE: COB 4/4/89COST TO DATE CEILING

EPA (DIRECT) $ 9,222 $ 13,000(INDIRECT) 14,988 28,000

TAT 23,881 30,000ERGS 325,644 315,000


C. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UPACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES WILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. 4/10/89 - MINI-ERCS RECEIVED THE ENGINEERING ANALYSIS

THIS DATE.B. 4/11/89 - MINI-ERCS COMPLETED THE CONCRETE REPAIR WORK ON

LOCUST ST. THIS DATE. THE REPAIR WORK INCLUDED REMOVINGBROKEN SIDE-WALK AND CURB CONCRETE AND RE-POURING NEWCONCRETE.

C. 4/12/89 - TAT CONDUCTED SAMPLING OF THE SURFACE MATERIAL ONTHE PLAYGROUND PAD (ASPHALT) TO CONFIRM THE SAFETY OF RE-OPENING IT TO THE PUBLIC.

D. 4/24/89 - OSC YOUNIS SUBMITTED AN ADDITIONAL FUNDING REQUEST,REFLECTING THE RECOMMENDATIONS OF THE ENGINEERING ANALYSIS,INTO THE CHAIN OF CONCURRENCE FOR APPROVAL.

E. 4/26/89 - OSC RECEIVED RESULTS FROM THE SAMPLING EFFORT OF4/12/89 THIS DATE. THE RESULTS REVEALED THE PRESENCE OFTRACE AMOUNTS OF ASBESTOS IN ONE (1) OF THE SAMPLES AND 1-2%ASBESTOS IN ANOTHER (1) OF THE SAMPLES OF THE NINE (9)SAMPLES TAKEN.

III. FUTURE PLANSA. MINI-ERCS TO BEGIN THE CONSTRUCTION OF A CULVERT AT THE BASE

OF THE LOCUST ST. PILE TO DIVERT THE SURFACE WATER AWAY FROMTHE PLAYGROUND AREA.

PHIL YOUNIS, OSC AR I 000 60U.S. EPA, REGION IIIPHILADELPHIA, PA

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To: ERD/OERR (EPA5511)To: J.VINISKI (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered,: Mon 8-May-89 7:15EDT Sys 163 (53)Subject; AMBLER ASBESTOS SITE POLREP #23Mail Id: IPM-163-890508-065260710

POLREP #23AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1500 HOURS, THURSDAY, 5/4/89)

A. OSC YOUNIS NOT ON SITE DUE TO OTHER REGIONAL COMMITMENTS.OSC MAINTAINED TELEPHONE CONTACT THROUGHOUT THE WEEK.

B. PERSONNEL ON SITE: 1-TAT, 1-MINI-ERCSC. ESTIMATED COST TO DATE: COB 5/2/89




D. WEATHER: SUNNY AND CLEAR WITH TEMPERATURES IN THE LOW 70'S.E. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP

ACTIONS UNDERTAKEN BY EPA'S REMOVAL RESPONSE SECTION IN1984. FINAL REMEDIES HILL BE INSTITUTED IN THE NEAR FUTUREBY EPA'S REMEDIAL SECTION. THE AMBLER SITE IS ON THENATIONAL PRIORITIES LIST (NPL).

II. ACTIONS TAKENA. 5/2/89 - MINI-ERCS POSTPONED EARTHWORK THIS DATE DUE TO HEAVY

RAINS THROUGHOUT THE MORNING. EARTHWORK TO RESUME TOMORROWWEATHER PERMITTING.

B. TAT PERFORMED A SURVEY OF THE EXISTING ELEVATIONS AT THE TOEAREA OF THE LOCUST ST. PILE WHERE THE CULVERT WILL BECONSTRUCTED.

C. 5/3/89 - MINI-ERCS BEGAN THE CONSTRUCTION OF THE CULVERT ATTHE TOE OF THE LOCUST ST. PILE. A TOTAL OF 23 TRUCK LOADS(17-TANDEM AND 6-TRIAXLE) OF FILL SOIL AND 2 LOADS OF STONEWERE DELIVERED TO SITE THIS DATE.

D. 5/4/89 - MINI-ERCS CONTINUED THE CONSTRUCTION OF THE CULVERTAT THE TOE OF THE LOCUST ST. PILE. A TOTAL OF 16 TRUCK LOADS(8-TANDEM AND 8-TRIAXLE) OF FILL SOIL AND 5 LOADS OF STONEWERE DELIVERED TO SITE THIS DATE.

E. TAT CONDUCTED A SURVEY OF THE ELEVATIONS OF THE CULVERT TOENSURE PROPER SLOPE TO DIVERT SURFACE WATER RUN-OFF FROM THELOCUST ST. PILE.

III. FUTURE PLANSA. MINI-ERCS TO CONTINUE THE CONSTRUCTION OF A CULVERT AT THE

BASE OF THE LOCUST ST. PILE TO DIVERT THE SURFACE WATER AWAY.fj FROM THE PLAYGROUND AREA.


ARI0006I

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TO! ERD/OERR (EPA5511)To: J.VINISKI (EPA9314)To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered: Thu ll-May-89 8:36 EOTSys 163 (42) .Subject; AMBLER ASBESTOS SITE POLREP #24Mail Id: IPM-163-890511-077480356

POLREP #24AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN. STEVE JARVELA AND TIM FIELDSI. SITUATION (1600 HOURS, WEDNESDAY, 5/10/89)

A. OSC YOUNIS NOT ON SITE DUE TO OTHER REGIONAL COMMITMENTS.OSC MAINTAINED TELEPHONE CONTACT WITH THE SITE THROUGHOUT THEDAY.

B. PERSONNEL ON SITE: 1-TAT, 1-MINI-ERCSC. ESTIMATED COST TO DATE: COB 5/8/89




C. WEATHER: RAINS, HEAVY AT TIMES, WITH TEMP. IN THE UPPER 40'S.D. THE CURRENT REMOVAL ACTIONS ARE SUBSEQUENT TO THE START-UP


II. ACTIONS TAKENA. 5/8/89 - MINI-ERCS CONTINUED THE CONSTRUCTION OF THE CULViJRT

AT THE TOE OF THE LOCUST ST. PILE ADJACENT TO THE PLAYGROUND.FIVE (5) LOADS OF STONE DELIVERED THIS DATE.

B. 5/10/89 - MINI-ERCS COMPLETED THE CONSTRUCTION OF THE CULVERTAT THE TOE OF THE LOCUST ST. PILE THIS DATE.

III. FUTURE PLANSA. MINI-ERCS TO SEEK BIDS FOR DECONTAMINATING AND RESURFACING

THE BLACKTOP OF THE PLAYGROUND.B. OSC YOUNIS TO COORDINATE WITH EPA MANAGEMENT TO EXPEDITE THE

APPROVAL OF THE ADDITIONAL FUNDING REQUEST THROUGH THE CHAINOF CONCURRENCE.


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To: REGION03.TAT (EPA9322)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered; Tue 6-Mar-90 9:49 ESTSys 163 (48)Subject: AMBLER ASBESTOS SITE POLREP #25Mail Id: IPM-163-9Q0306-08846Q577

POLREP #25AMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN, STEVE JARVELA AND TIM FIELDS

I. SITUATION (1700 HOURS, THUSDAY, 8/11/B9)A. 7/12/89 - EPA REACHED AN "AGREEMENT IN PRINCIPLE" WITH

T&N pic (A SUBCIDIARY OF NICOLET) ON THE SITE.B. 7/24/89 - EPA MANAGEMENT AND TAT HELD A MEETING TO DISCUSS

THE STATUS OF THE SITE AND EVALUATE THE ALTERNATIVE ACTIONSTO TAKE DURING THE INTERIM BETWEEN THE EMERGENCY RESPONSEACTIVITIES (MARCH '89) AND THE IMPLEMENTATION OF THE RECORDOF DECISION (ROD). AS A RESULT OF THE MEETING, AN ATSDRPACKAGE WILL BE SUBMITTED BY TAT TO ASSIST EPA MANAGEMENTIN BETTER IDENTIFYING THE IMMEDIATE HAZARDS AT THE SITE.AS PART OF THE ATSDR PACKAGE TAT WILL PERFORM AIR, SOIL,AND DUST SAMPLING AT THE SITE.IN ATTENDANCE WERE ASSISTANT BRANCH CHIEF: DENNISCARNEY, WR&OP SECTION CHIEF: CHARLES KLEEMAN, ERP SECTIONCHIEF! GREGG CRYSTAL, OSC PHIL YOUNIS AND TAT LEADERMICHEAL ZICKLER AND TAT MEMBER CAMIL COSTA.

C. 8/11/89 WEATHER: SUNNY AND COOL, TEMP. IN THE LOW 70'S.D. AT TAT'S ARRIVAL ON SITE, THEY FOUND THAT THE PLAYGROUND

BLACKTOP HAD BEEN RESURFACED. ACCORDING TO EPA OPA, THEAMBLER BOROUGH COUNCIL HAD THE RESURFACING PERFORMED FORTHE NEIGHBORHOOD CHILDREN. THEY WILL ALSO PROVIDEPLAYGROUND EQUIPMENT IN THE FUTURE.

II. ACTIONS TAKENA. 8/11/89 - TAT PERFORMED SOIL AND DUST SAMPLING AT 19

LOCATIONS AROUND THE SITE. LOCATIONS INCLUDED BACKGROUNDSAMPLES NORTH, SOUTH, EAST, AND WEST OF THE SITE. THEANALYSIS WILL INCLUDE BOTH T.. ELECTRON MICROSCOPE ANDLIQUID EMULSION.

III. FUTURE PLANSA. TAT TO SECURE A LAB FOR THE ANALYSIS OF ASBESTOS SAMPLES.B. TAT TO INCORPORATE THE ANALYTICAL RESULTS INTO THE ATSDR

PACKAGE FOR SUBMISSION.C. TAT TO PERFORM AIR MONITORING AT THE SITE THE FIRST •

OPPORTUNITY THAT WEATHER PERMITS.

D. OSC TO CONTINUE TO EVALUATE FURTHERING EMERGENCYACTIVITIES AT THE SITE.


ARI00063

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To: G.CRYSTALL (EPA93028)To: REGION03.TAT (EPA9322)To: C.KLEEMAN (EPA9340)To: RRC (EPA9374)

From: REGION03.TAT (EPA9322) Delivered; Mon 5-Mar-90 9:21 ESTSys 163 (81)Subject: POLRE FINAL #26 AMBLERMail Id: IPM-163-900305-084250622POLREP #26 AND FINALAMBLER ASBESTOS SITEMONTGOMERY COUNTY, PENNSYLVANIAATTN: GREGG CRYSTALL, CHARLIE KLEEMAN, AND HANS CRUMPWEISNERI. SITUATION (1700 HOURS FRIDAY 3/02/90)

A. BASED ON RECENT VISITS TO THE SITE, THE OSC HAS DECIDED THATIT IS NO LONGER POSES AN IMMINENT OR SUBSTANTIAL THREAT TOTHE PUBLIC HEALTH OR THE ENVIRONMENT.

B. THE AMBLER SITE IS ON THE NATIONAL PRIORITIES LIST (NPL) ANDA RECORD OF DECISION (ROD) HAS BEEN SIGNED.

C. THE REMEDIAL PROJECT MANAGER (RPM) HAS NEGOTIATED ANAGREEMENT IN PRINCIPAL WITH TURNER AND NEWELL TO PERFORMREMEDIAL ACTIVITIES WHICH ADDRESS THE LONG TERM STABILIZATIONOBJECTIVES STATED IN THE ROD.

D. ESTIMATED COST TO DATE: COB 3/02/90COST TO DATE CEILING

EPA (DIRECT) $ 13,000 $ 13,000EPA (INDIRECT) 20,000 28,000TAT 30,000 > 30,000ERCS 365,000 365,000

TOTAL $ 428,000 $ 436,000TOTAL PROJECT CEILING: $ 461,114(NOTE: THE 1984 REMOVAL ACTION COST WAS $ 901,220)

II. ACTIONS TAKENA. 02/08/90-OSC AND TAT VISITED THE SITE TO PERFORM A VISUAL

INSPECTION. THE PLAYGROUND AREAS LOCATED NEAR THE DIVERSIONDITCH BUILT DURING THE LAST REMOVAL, APPEARED TO BE IN GOODWORKING CONDITION. LITTLE OR NO ENCROACHMENT WAS NOTICED ATTHE FOOT OF THE PILES AND INTO THE WISSAHICKON CREEK. LITTLEUPROOTING OF BRUSH AND SMALL TREES WAS NOTICED. MINOR EXPOSEDAREAS OF ASBESTOS WERE NOTED SPORADICALLY ALONG THE SLOPE ANDPLATEAU AREAS. THESE AREAS OF EXPOSURE ARE SMALL IN MAGNITUDEAND DO NOT POSE ANY IMMINENT THREAT. THE HYDROSEEDING ANDSTABILIZATION OF THE LAST REMOVAL (SPRING 1989) ARE STILLEFFECTIVE. AS A RESULT OF THIS VISIT, THE OSC DETERMINED THATTHE POTENTIAL FOR SHORT-TERM ASBESTOS RELEASE IS MINIMAL ANDDOES NOT POSE ANY IMMINENT THREAT. HENCE, THE SITE SHOULD BECLOSED OUT FROM THE REMOVAL PROGKAM.

B. 02/20/90-AS TASKED BY OSC, TAT VISITED THE SITE AGAIN WITHRPM (DAVID BYRO) AND THE RP CONSULTANT (ENSR) . TAT SHOWEDTHE AREAS OF CONCERN THAT MAY POSE POTENTIAL LONG-TERM HEALTHTHREATS. TAT ALSO GAVE SITE KEYS TO RPM BYRO FOR FUTURE USE.

III. FUTURE PLANSA. SITE IS CLOSED NOW FROM THE REMOVAL PROGRAM AND LONG TERM

(CHRONIC) THREATS WILL BE ADDRESSED BY THE REMEDIAL PROGAM.

PHIL YOUNISREGION 3PHILADELPHIA, PA. A R I 0 0 0 6 4

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SITE INVESTIGATION REPORTFOR

AMBLER ASBESTOS PILES SITEAmbler,, Pennsylvania

pnpandfor ,Environmental Health and Research Testing Corporation

2369 Gieniward RoadWarrlnjton, PA 18976

pnpandbyDynamac Corporation2 Executive DriveFort Lee, NJ 07614

April 1989

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INTRODUCTION AND SITE BACKGROUNDThe Ambler Asbestos Piles site is located in the Borough of Ambler,

Montgomery County, Pennsylvania. Beginning in the early 1900s and throughthe late 1970s, thf, site was the location of asbestos productsmanufacturing. During this period, wastes generated from the productionoperations were disposed of in two piles on the company property next tothe manufacturing facility, as well as at other areas in Ambler. Theprimary wastes generated and disposed of in the two piles (designated asthe Locust Street pile and the Plant pile) were spent magnesium/calciumcarbonates, asbestos and asbestos cement wastes, and out-of-spec asbestosproducts.

In response to public complaints alleging air and water contaminationand amid increasing national concern about asbestos and its potentialhealth effects, the EPA placed the Ambler site on a list of NationalEmission Standards for Hazardous Air Pollutants (NESHAP) regulated asbestossites in November 1978. An initial site assessment was conducted bypersonnel from the EPA Emergency Response Team (ERT), the PennsylvaniaDepartment of Environmental Resources (PADER) and the Technical AssistanceTeam (TAT) in September 1983. Samples taken from the Locust Street andPlant piles indicated the presence of significant levels of asbestosfibers. Wipe samples taken during the site investigation from the publicplayground adjacent to the toe of the Locust Street pile also testedpositive for asbestos.

As a result of these findings, the Centers for Disease Control (CDC)issued a Public Health Advisory recommending the closure of the playgroundbased upon the determination that the site had the potential to causeimmediate risk to public health and the environment. In October 1984, thesite was also proposed to be included on EPA's Superfund NationalPriorities List (NPL). Based upon the 1983 CDC advisory and evidence ofair transport of asbestos fibers from the piles to areas of potentialcontact with human receptors, the EPA recommended and began implementing aCERCLA Immediate Removal Action which concluded in 1985. The emergencyresponse actions at the site included:

• Closing and dismantling of the playground• Removal of the equipment• Partial covering of the Locust Street pile with 6-18" of compacted

fail cover stabilized with geotextile netting and vegetated withcrown vetch

• Installation of a drainage system for the Locust Street pile• Installation of a fence around the siteThe EPA emergency response actions addressed the immediate need to

significantly reduce the potential for release of asbestos fibers from theLocust Street pile. The owner of the site also independently covered thePlant pile's side slopes with a soil cover vegetated with crown vetch.While these actions have apparently mitigated the potential for healthrisks to some degree, there are still potential concerns remainingregarding the long-term stability and integrity of the cover materials and

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the potential for the ongoing and/or future release of asbestos fibers.Correspondingly, in October 1988, teams from EPA Region in reassessed thecondition of the Ambler asbestos site. At that time, the piles were foundto be in generally good structural condition; however, several areas ofcover erosion and slippage were visible. The fence around the site alsohad failed, for a number of reasons, to restrict access; signs oftrespassing were evident throughout the site. Accordingly, EPA determinedthat additional emergency response measures were necessary to protectpublic health and the environment from imminent hazards at the Amblersite. As pan of this emergency response, an eight foot high, nine-gaugechain link fence was constructed to replace the old fence around theperimeter of both the Locust Street and Plant piles to further restrictsite access.

Additionally, EPA requested that an independent assessment beperformed to identify any remaining asbestos-related hazardous conditionsat the site and to identify potential short-term mitigative measures. Inthis context, a hazardous condition was defined as any area at whichasbestos is, or could be, exposed over the next few years via erosion,cover slippage, etc. Consequently, Dynamac was retained by EHRT to performthe latter evaluation.

METHODOLOGY

A field investigation team from Dynamac consisting of a seniorhydrogeologist and an engineer performed a site inspection of the LocustStreet and Plant piles on March 31, 1989. The objectives of the siteinvestigation were to:

• Perform a visual inspection to assess potential slope stabilityproblems and to identify areas of exposed asbestos-contaminatedwaste,

• Collect bulk samples for asbestos analysis,• Excavate test holes on each pile to assess the adequacy of the

cover material.More specifically, in support of these objectives, the following field

activities were conducted;• A visual survey was completed by walking around the perimeter and

up and down the slopes of each pile. In addition, a series ofphotographs was taken to record significant observations during thevisual inspections.

• A total of 10 bulk samples, from randomly selected locations atwhich suspected asbestos-containing materials were exposed, werecollected for asbestos analysis at Dynamac's laboratory inRockville, Maryland.

• A waste pile cover thickness survey was performed by excavating 13holes, using hand digging tools, at randomly selected locations onthe plateaus and along the slopes of the piles.

ARI00067

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Tables 1 and 2 provide a list of the excavation and sampling locationsrespectively. Figure 1 provides a schematic representation of theselocations. Table 3 presents the results of the bulk asbestos samplinganalyses.

OBSERVATIONSLocust Street Pile

• Approximately 70% of the side slopes are covered with .0-24" ofsoil cover and are well vegetated with crown vetch. The remaining30% of the side slopes (especially up slope from the access road)are for the most part uncovered, but generally vegetated. Grayfibrous material was observed on the surface along the perimeter ofthis slope. Results of the sampling analysis confirm that theexposed material is asbestos. Evidence of extensive burrowing bysmall animals was also noticed in many areas along the slopes.

• The highest and largest plateau areas (Plateaus 1 and 2 from Figure1) are largely uncovered. The areas are, however, vegetated withPhragmites and trees. At some locations, a very thin covermaterial, which appeared to be cinder and fly ash, was noted.

• The side slopes of the pile below and around the access roadappeared in good condition and there was no obvious evidence oflarge-scale slope failure; however, several localized areas ofcover failure were noted.

• There was evidence of uprooted trees lying along the slopes of thepile with suspected asbestos materials attached to • the roots. Atlocations where the trees were uprooted, shallow holes were left inthe cover materials.

• The surface materials at the top of the pile appear to have agenerally low bearing strength.

• Surface drainage appears to be occurring via infiltration throughthe top of the piles and by surface runoff on the side slopes.

Plant Pile

The side slopes of the pile appeared to be in good condition andwere covered with 12-18" of soil cover well vegetated with crownvetch.There was no obvious evidence of large-scale slope failure;however, a localized shallow shear failure was observed at theeastern corner of the pile. Failure apparently occurred within thehardened (dried-out) calcium carbonate material under the cover.The underlying area of waste material that is exposed at thislocation is approximately 8' x Iff. The sample analysis from thislocation (S9) confirmed that the exposed materials are notasbestos-containing materials.

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TABLE 1

EXCAVATION DATA

Date: 301-89Site: Ambler, PALocation! Locust Street Pile

Depth toHole Location Asbestos Waste Description/Remarks

HI 70 ft S of entrance 10" Approximately halfway betweengate PC-flat surface the access road and Plateau 2

H2 Near fence post H 24" Approximately halfway betweenthe access road and the footof the slope

H3 Around the eastern 12* Approximately halfway betweenbend the access road and Plateau 1

H4 Flat area on the 6"NWside

H5 Slope -south side 18* Approximately half waybetween the pathway and thefoot of the slope

H6 Top surface of 6" Very thin coven excavatedPlateau 1 material appeared in cinder

ash, fly ash, etc. and notsoil

H7 Top surface of 6" Very thin cover; excavatedPlateau 1 material appeared in cinder

ash, fly ash, etc. and notsoil

H8 Top surface of 6* Very thin cover; excavatedPlateau 1 material appeared in cinder

ash, fly ash, etc, and notsoil

H9 Top of Plateau 2 6" Very thin coven excavatedmaterial appeared in cinderash, fly ash, etc. and notsoil

H10 Approximately 2" Very thin coven excavatedcenter of material appeared in cinderPlateau 2 ash, fly ash, etc. and not

soil; same location from1 ' , which sample S6 was collected

.4. A R I O O O B 9

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TABLE 1 (continued)

Datei 34149Site: Ambler, PALocation: Plant Pile

Depth toLocation Asbestos Waste Description/Remarks

Hll NOB slope 12" , Down slope from access road -cinder ash detected in covermaterial

H12 Top (plateau) of 0 Very soft material, Noplant pile significant cover. Waste

appears to be exposed at orvery near this surface.

H13 Along the top of 18" Excavated material wasthe dike granular, mostly cinder ash

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TABLE2

/-> BULK SAMPLING DATA

Date:Site: Ambler, PALocation: Plant Pile

Sample Location Description/Remarks

SI 73'S of entrance gate (FG) Base of slope from pathwayS2 Behind playground Foot of Locust Street pileS3 Slope Groundhog hole near the top

of the pileS4 Pathway Exposed at embankment along

the pathway. Approximately1/3 of the way between thefoot and the top of thelocust pile.

SS Down slope from Plateau 1 Granular material beneathexposed asbestos sheets,tiles, and composite wastematerial

S6 Approximately center of Plateau 2 Top flat surface of pileof Locust St. pile

S7 Pile plateau No cover over the wastematerial; appears dried •solidified sludge. Somevegetation rooted in wastematrix

S8 Pile plateau same as aboveS9 Slope Patch of exposiu material

behind large solidifiedboulder-like material whichslumped away from the face ofthe slope

S10 Slope Exposed patch of wastematerial

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TABLESBULK ASBESTOS SAMPLING

Sample Analyte

S-l Chrysotile2-S%S-2 Trace Chrysotile (< 1%)S-3 Chrysotile 10-15% Trace Amosite (< 1%)S4 Chrysotile 15-20%S-5 Chrysotile 2-5%S-6 Chrysotile 2-5% Trace Amosite (< 1%)S-7 Chrysotile 15-20%S-8 Chrysotile 25-30% • :S-9 ND ,S-10 ND

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The plateau of this pita is uncovered. Extensive growth of treesand crown vetch has occurred on the plateau in some areas whileother areas are sparsely vegetated. A combination of moist blackgrained and gray fibrous material (semi-dried sludge) is exposed atthe surface in several areas.

HAZARD IDENTIFICATIONAs noted, a hazardous condition was deemed to exist in areas at which

asbestos-contaminated waste was either exposed or at risk of beingexposed. Based on this definition, ,the following potentially hazardousconditions appeared to exist:Locust Street Pile

- Approximately 200,000 sq.ft. of this pile up slope from the accessroad, including the plateaus, are exposed. Any disturbance ofthese areas via wind, brush fire, and trespassing could result inthe entrainment of asbestos fibers.

• The growth of tall trees along the side slopes increases thepotential for asbestos exposure. The uprooting along the slopesthreatens the integrity and stability of the slopes and the soilcover.

• Due to further deterioration of the existing soil cover over theslopes, there is potential for increased asbestos release risk.

-• While field observations indicated that cover slippage has beenlimited to date, regular monitoring is necessary to minimize thepotential for additional cover slippage and asbe&tos exposure.

Plant Pile

• The plateau of the Plant pile (approximately 170,000 sq.ft.) isuncovered and poses the potential for asbestos fiber release.

POTENTIAL SHORT-TERM MITIGATION MEASURESWith reference to the potentially hazardous conditions at the site as

identified in the preceding section, a number of short-term mitigationmeasures are available that would substantially reduce the potential forthe release of asbestos fibers. In general, these mitigation measuresconsist of a variety of cover and/or capping approaches designed to preventthe release of asbestos fibers via wind and/or water erosion, direct humancontact, etc. More specifically, this report considered the followingalternatives:Alternative 1

' Tree grubbing to ground surface along the slopes, of both piles.Stumps should be coated with a growth inhibiting material.

• Stabilization of areas where cover slippage has occurred with anadequately compacted low erosion 6" soil cover.

-8- AR 100071*..... .

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Installation of a 6" permeable soil cover over the Plateaus ofLocust Street pile and the Plant pile, and a 6" erosion-resistantsoil cover along the slopes over areas of uncovered asbestos withor without vegetation. This includes areas up slope from theaccess road and around the perimeter (Plateaus 1 and 2) of theLocust Street pile.Hydroseeding all areas of freshly applied soil cover with crownvetch and rye grass sealed with an application of a hydromulch.

Alternative 2

' Tree grubbing to ground surface along the slopes of both piles.Stumps should DC coated with a growth inhibiting material.

• Stabilization of areas where cover slippage has occurred with anadequately compacted low erosion 6" soil cover.

• Installation of a 6" low erosion soil cover along the slopes overall areas of uncovered asbestos without vegetation and a 6"permeable soil cover on the areas of plateaus not covered byvegetation.

• Hydroseeding all areas of freshly applied soil cover with crownvetch and rye grass sealed with an application of a hydromulch.

Alternative 3

• Tree grubbing to ground surface along the slopes of both piles.Stumps could be coated with growth inhibiting material.

• Stabilization of the soil cover along the slopes with a geotextilenetting anchored into the waste in those areas where cover slippagehas occurred. A minimum 6" low erosion soil cover vegetated withcrown vetch and hydromulched, would also be installed.

* All exposed areas (including the Plateau of the Plant pile andPlateau 2 of Locust Street pile) would be covered with a 6* soilcover vegetated with crown vetch.

Alternative 4

• Tree grubbing to ground surface along the slope of both piles.Stumps should t» coated with a growth inhibiting material.

• Repair locally the areas of soil cover showing signs of slidingwith a cut-in-place and anchored geotextile netting topped with alow erosion 6" soil cover as in Alternative 2.

• Installation of a spray-on chemical liner using a penetrant andpolymer combination over all exposed asbestos materials on theslopes (up slope from the access road), Plateau 2 of Locust Streetpile and the plateau of the Plant pile. Several proprietaryspray-on liner chemicals are potentially available for thispurpose.

ARI00075

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Table 4 presents a summary of the relative advantages anddisadvantages of the proposed alternatives and a preliminary estimate of

_. the cost and time to implement each alternative. A oreakdown of the items"' included in the estimated costs for each alternative is provided in

Appendix A.

RECOMMENDED ALTERNATIVEBased on the findings of the site inspection, the interim nature of

the proposed response action, and expected costs, Dynamac recommends theimplementation of Alternative 2 for the Locust Street and Plant piles atthe site. Alternative 2 is technologically feasible and is the mostcost-effective short-term remedy. It also minimizes potential health andsafety risks to pn-site workers and potential off-site -receptors due todisturbance of existing asbestos-containing materials.

.10- ARI00076

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a M m

ARI00077

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,• UNiriDITATNINVIRONM(NTAI.PnOTIClr.4 AGENCYWASHINGTON, DC »WO

DELIVERY ORDER FOR EMERGENCY RESPONSE CLEANUP SERVICES

1, DATE OF ODDER

2.1, ft?4)J, CONTRACT NUMIIR 3, OflDIR NUMBER

0010-02-00004, TIME OF INI B, DEUVERY ORDER CEIUNQ AMOUNT

QAM«. ACCOUNTING AND APPROPRIATION DATAAnnoptlillon Numlnf Docum«m Control No. Actoum Numbtf Oblici Clm

7i, ISSUED TO: CONTRACTOR (Nimi, AMnit, indllP Crti/ Bi, ISSUED BY: ORDERING OFFICE (Hum, AiUnu, imlZlf Cob)

Hfl-T

71), PROGRAM MANAGER {Himi indPhaa Numbtl 8b. EPA REOioN/uaea BUTRierinr

Be. ZONE

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>'i: A- '9, RESPONSE LOCATIONS fV«n««lcy»/t<«f«ll«Hi/ff>Co*/ 10, CONTRACTOR REQUIREO«MM/0«t im«r/mtj

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11, REQUIRED WORK COMPLETION DATE

12. STATEMENT OF WORKThi Contrictor thill lurnlih iht ntcnury ptiionnil, miiiriili, Mrvlcit, (Klllllii, ind oihtrwlM do ill thlngintciiMry lor or Incldini to iht ptrf otrrnnct ol Iht work w lonh twlow:

EMF«m1BOO,lt|1Ml| „ /r,,,,uuu,u CONTRACTING OFFICER

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REGION III INCIDENT NOTIFICATION REPORT/*"**' .Jj * J T f7 O \ H "*iI' nnrtnftflri1 f/rvnitW v) ^n C^ I **PI 13» llfiru;

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,-n UNITED STATES ENVIRONHHKTAL PROTECTION AGENCYI REOXON mBITE flAfBTY PLAN

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Date: IflMUl (* .Project Name; _

frERCS Delivery Order f:TAT Technical Direction Document f:U.S. EPA Site I.D.f: ________

Adopted By: ' s g p .. gs Data:—— ^- ' wad TAT Menber

SSP:

Adopted By: _____________________ Date:ERCS Response Manager

Adopted By: _______________ ___ _ Data:U.S. EPA On-Scene Coordinator

Adopted By: ____________________ Date:ERCS Safety Officer

Adopted By: _____________________ Date:Heston safety Officer

Adopted By: ___________________ Date:U.S. EPA safety Officer

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TABLE Of CONTENTS

EASEINTRODUCTION AND SITE ENTRY REQUIREMENTS U

1.0 SITE BACKGROUND AND SCOPE OF WORK "J

1.1 Roles and Responsibilities1.2 Key Personnel1,3 Site Background1.4 Scope of Work for ERCS contractor

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2.0 TASK SAFETY AND HEALTH RISK ANALYSES

2.1 Activity Specific Hazards and SOPs2.2 General site Hazards

3.0 PERSONAL PROTECTIVE EQUIPMENT

3.1 Level D3.2 Level Modified D

4.0 AIR MONITORING AND ACTION LEVELS

4.1 Routine Air Monitoring Requirements __4.2 Site Specific Air Monitoring Requirements ——

5.0 SITE CONTROL AND STANDARD OPERATING PROCEDURES /£,

S.I Work Zones5.2 Field Safety and Standard Operating Procedures

6.0 DECONTAMINATION PROCEDURES

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TABU OF CONTENTS (CONTINUED)

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7.0 EMERGENCY RESPONSE CONTINGENCY PLAN %Q

7.1 Emergency Contacts7.2 Additional Emergency Nuobers7.3 Emergency Equipment Available On-Site7.4 Personnel Responsibilities7.5 Medical Emergencies7.6 Fire or Explosion

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MANDATORY ATTACHMENTS

0 ATTACHMENT A - SITE SAFETY PLAN AMENDMENTS

0 ATTACHMENT B - SITE MAPS

0 ATTACHMENT C - COLD STRESS

0 ATTACHMENT Z - SITE SAFETY PLAN ACKNOWLEDGMENT FORM

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GLOSSARY Or ACRONYMS

ANSI - AMERICAN NATIONAL STANDARDS INSTITUTEAPR - AIR PURIFYING RESPIRATORACGIH - AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL

HYGIENISTSCFR - CODE OF FEDERAL REGULATIONSCGI - COMBUSTIBLE GAS INDICATORCLEAN ZONE - SUPPORT ZONECSEP - CONFINED SPACE ENTRY PERMITDECON - DECONTAMINATIONERCS - EMERGENCY RESPONSE CLEAN-UP SERVICESHNU-PID - HNU PHOTOIONIZATION DETECTORHOT ZONE - EXCLUSION ZONEIDLH - IMMEDIATELY DANGEROUS TO LIFE & HEALTHMREM/hr - MILLI-ROENTGENS EQUIVALENT IN MAN PER HOURNIOSH - NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY & HEALTHOSC - ON-SCENE COORDINATOROSHA - OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION LIMITOVA - ORGANIC VAPOR ANALYZERPEL - PERMISSIBLE EXPOSURE LIMITPPM - PARTS PER MILLIONRM - RESPONSE MANAGERSCBA - SELF-CONTAINED BREATHING APPARATUSSOP - STANDARD OPERATING PROCEDURESPCC - SPILL PREVENTION CONTROLS t COUNTERMEASURESTAT - TECHNICAL ASSISTANCE TEAMTLV - THRESHOLD LIMIT VALUETHA - TIME WEIGHTED AVERAGEU.S. EPA - U.S. ENVIRONMENTAL PROTECTION AGENCY

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INTRODUCTION AND SITE ENTRY REQUIREMENTS

This document describes the health and safety guidelinesdeveloped for the Ambler Asbestos site, to protecton-site personnel, visitors, and the public from physical harmand exposure to hazardous materials or wastes. The proceduresand guidelines contained herein were based upon the best avail-able information at the time of the plan's preparation. Specificrequirements will be revised when new information is received orconditions change. A written amendment will document all changesmade to the plan. Any amendments to this plan will be includedin Attachment A. Where appropriate, specific OSHA standards orother guidance will be cited and applied.

DAILY SAFETY MEETINGS

Daily safety meetings will be held at the start of each shift toensure that all personnel understand site conditions andoperating procedures, to ensure that personal protective equip-ment is being used correctly and to address worker health andsafety concerns.

RITE SAFETY PLAN ACCEPTANCE ACKNOWLEDGMENT

The OSC or designated representative shall be responsible forinforming all individuals entering the exclusion zone or decon-tamination zone of the contents of this plan and ensuring thateach person signs the Safety Plan Acknowledgment Fora in Attach-ment Z. By signing the Safety Plan Acknowledgment Form, individ-uals are recognizing the hazards present on-site and the policiesand procedures required to minimize exposure or adverse effectsof these hazards.

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1.0 SITE BACKGROUND AND SCOPE OF WORK,

1.1 ROLES AND RESPONSIBILITIES

On-Scene Coordinator (OSC1:

The OSC, as the representative of the U.S. EPA, is responsiblefor overall project administration and for coordinating healthand safety standards for all individuals on-site at all times.All U.S. EPA health and safety guidelines and requirements aswell as all applicable OSHA standards shall be applied. However,each contractor (as an employer under OSHA) is also responsiblefor the health and safety of its employees. If there is anydispute with regards to health and safety, the following proce-dures shall be followed:

1) Attempt to resolve the issue on-site; and,2) If the issue cannot be resolved, on-site personnel shall

consult off-site supervisors for assistance and thespecific task operation in dispute shall be discontinueduntil the issue is resolved.

Response Manager (RM1: *The Response Manager, as the field representative for the ERCSclean-up contractor, has the responsibility for fulfilling theterms of the delivery order. The RM must oversee the project andensure that all technical, regulatory and safety requirements aremet. It is the RM's responsibility to communicate with the OSCas frequently as dictated by the OSC, but at least daily, regard-ing site clean-up progress and any problems encountered.Technical Assistance Team fTATlt

The Technical Assistance Team is responsible for providing theOSC with assistance and support in regards to all technical,regulatory and safety aspects of site activity. The TAT is alsoavailable to advise the OSC on matters relating to sampling,treatment, packaging, labeling, transport, and disposal of haz-ardous materials, but is not limited to the above-mentioned.Other;

Any persons who observe safety problems should immediately reportobservations/concerns to appropriate key personnel listed on thefollowing page.

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1,2 Kev Personnel,

U.S. EPA On-Scenecoordinator (OSC): _Phil Younis_

_Rich Messimer will be the__EPA representative during_Phil's absence_______

Alternate OSCs: __________

Principle ERCS Contractor:

Response Manager (RM):Subcontractors:

Site Health & Safety Officer: oscAlt. Health t safety Officer: __Technical Assistance Team (TAT): Roy F. Weston. Inc..____

53 Haddonfield P.d.. Suite 306~Cherry Hill. NJ OB002609-482-0222

TAT Representatives: _Joseph A. DeAngelis__Clay Mulllean_Chuck Fisher_____

other: __ ____

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1,3 Site Background

The Keasbey and mattison Company owned the project site from thelate 1800s to 19,13. The company initially operated as apharmaceutical company until the early 1900s. During world warI, however, the Keasbey-Hattison plant became one of the leadingproducers of asbestos products. During the period when asbestoswas manufactured, waste from asbestos production was disposed ofin two piles on the company property next to the manufacturingfacility ( the Locust Street and Plant piles), and also in otherareas of ambler. These other locations are currently beingstudied by PA DER.

In 1933, Turner-Newall Ltd. purchased the site and manufacturingoperations but retained the Keasbey and Mattison Company name.The piles continued to be utilized for disposal. In 1962,Certainteed Corporation, a manufacturer of asbestos and cementpipes, purchased a portion of the site and plant facilities fromTurner-Newall Ltd., including the pipe manufacturing plant andthe pipe plant dump. Nicolet Industries , Inc., a manufacturerof building and automobile supplies, purchased the remainingplant facilities along with the Locust Street Pile, the PlantPile, and the asbestos filter bed lagoons. After purchasing theproperties, both companies added their wastes to the piles.In November 1978, amid increasing national concern about asbestosand other industrial wastes, the EPA placed the Ambler site on alist of NESHAPS regulated asbestos sites.On September 27, 1983, the initial site assessment was conductedby personnel from the EPA Emergency Response Team (ERT), thePennsylvania Department of Environmental Resources (PA DER), andthe Technical Assistance Team (TAT). Air samples, bulk surfacesamples, and wipe samples from the PLAYGROUND equipment adjacentto the asbestos waste piles were collected. The samples- wereanalyzed for asbestos and tested positive in both the bulk andwipe samples. As a result of these findings, the centers for

.. disease control (CDC) issued a Public Health Advisoryrecommending the closure of the playground among other things.The oso submitted a request for emergency funding to initiateactions to alleviate the health risk cauned by the piles.The EPA proceeded to implement the emergency response actions atthe site, which included:

o Covering the Locust street Pile with up to six inches ofsoil, including, within the limits of the removal action,the slopes along the Wissahickon Creek.

o Hydroseeding the Locust Street Pile to minimize erosion.o Installing a drainage system for the Locust Street Pile.o Placing a geotextile netting on the north and northeastern

. slopes of the Locust street Pile.

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On October 31, 1988, EPA Region III Enforcement and the EPA'aTechnical Assistance Team assessed the Ambler Asbestos siteconditions, The two piles were found in good condition; however,small, patchy areas exhibited signs of erosion at each pile. Thefence around the site appeared to be inadequate to restrict siteaccess, The fence was found with complete sections missing and itlacked gates. Additionally, the fencing material had undergonesevere weathering and was in disrepair. Signs of trespassing wereevident in that recreational vehicle tire tracks were noticeablethroughout the site. This type of activity destroys the vegetationand contributes to the erosion problem at the site.

The removal actions of March 21, 1984 addressed the immediateneed to significantly reduce the potential of a release of asbestosfibers into the air from the uncovered asbestos waste piles andinto area surface waters via stormwater run-off. However, recentsite conditions have exhibited areas where a release of asbestosfibers may occur due to the eroded cover material. Moreoverbecause site access is insufficiently restricted, a direct contactthreat to trespassers currently exists.

1.4 Scope of Work for ERCS Contractor

An eight-foot high, nine gauge chain-link fence with barbed wireis to be constructed around the perimeter of both the Plant andLocust Street piles. Wherever necessary, the previously omittedareas should be graded and cleared prior to erecting the fence,Several small areas along the steep slopes of the Locuststreet pile will be addressed with topsoil, (6" to 12") toadequately contain the asbestos until a more permanent remedy forthe site is instituted.

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2.0 TASK SAFETY AND HEALTH RISK ANALYSIS

This Hazard Assessment identifies the general hazards associatedwith specific site operations and presents an analysis of doc-umented, or potential hazards that exist at the site.Every uffort must fcs made to reduce or eliminate these hazards.Those which cannot be eliminated must be guarded against by useof engineering controls and/or personal protective equipment.

2.1 Activity Specific Hazards

2.2.1 Waste Disposed of at site

The contaminant of primary concern is asbestos. Asbestos is aCERCLA (Comprehensive Environmental Response, Compensation, andLiability Act) designated hazardous substance. Asbestos is thecommon name for a group of natural minerals (silicates) thatseparates into thin but strong fibers. Chrysotile and amositeare among the most frequently found asbestos minerals.The durability of asbestos fibers and their small size andfibrous shape make asbestos an unusual environmental contaminant.Asbestos fibers range from one to one thousand microns in length,and diameters may be less than 0.5 microns. The aize and shapeof these fibers permit them to remain airborne for long periodsof time. Fibers that settle can easily be stirred up into theair. When fibers have entered the air, individuals can beexposed and inhale these fibers. Although most fibers will notremain in the lungs, those that are retained will stayindefinitely. Asbestos fibers also remain waterborne for longperiods of time. The fate of ingested fibers however, is notadequately documented.Other potential contaminants of concern include organics(solvents) and components of bottom ash such as arsenic,selenium, chlorides, and magnesium (depending on the type ofcoal). Sampling and analysis of these potential contaminants hasnot been performed to date.2.2.2 Toxicity of Contaminants - AsbestosAsbestos is a collective term applied to numerous fibroushydrated manorial silicates. There are two major forms ofasbestos: serpentine (Chrysotile) and amphibole (amoaite,crocidolite, anthophyllite, tremolita, and actinolita). Thnchemical and physical characteriatica of the different asbestosfibers vary wildly. Amphibole-type asbestos fibers, aa anexample, tend to accumulate more readily than do Chrysotilefibers following inhalation exposure. Asbestos is stable and isnot prone to significant chemical or biological degradation inthe environment. Once inhaled, a large fraction of asbeatoafibers are cleared from the lungs by mucociliary action. Somefibera however, will remain in the lunga for decades after

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inhalation exposure,The severity of the health effects of asbestos depends on thefiber length and diameter, the number of fibers, fiberdegradation and retention, and the type of asbestos present.Although the relative toxicity of different types of asbestosvariea somewhat with the fiber type, all asbestos producesadverse health effects and, therefore, it is generally considereda single entity.

Asbestos is a recognized human carcinogen, causing lung cancerand mesothelioma, a form of neoplasm of the lining of thethoracic and abdominal cavities, in workers exposed byinhalation. The association between asbestos exposure byinhalation and lung cancer was first reported in 1935.Mesothelioma has been identified in individuals 'living nearasbestos plants. Cancer of the gastrointestinal tract and larynxare also associated with inhalation exposure, cigarette smokingpotentiates the risk of lung cancer in individuals exposed toasbestos,

There is also evidence that oral exposure of humans to asbestosmay be associated with an increased incidence of cancer ofthe gastrointestinal tract. Exposures have been through drinkingcontaminated water, either from contact with asbestos deposits ortransmission through asbestos-containing cement water mains. Theevidence is considered equivocal at this time.long-term exposure to asbentos fibers and contaminated dust alsocauses asbestosis, a progressive and irreversible lung diseasecharacterized by diffuse interstitial fibrosis, Symptoms includeweight loss. Pulmonary changes occur more rapidly in moreseverely exposed individuals.

2.2 General Site Hazards '

Lighting - Work areas must have adequate lighting for employeesto see to work and identify hazards (5-foot candles minimum com-parable to a single 75-100 watt bulb) . Personnel should carryflashlights in all normally dark areas for use in the event, of apower failure. Applicable OSHA standards for lighting - 29 CFR1910.120 (m) - shall apply.Electrical Power - All electrical power munt have a ground faultcircuit interrupter as part of the circuit. All equipment mustbe suitable and approved for the class of hazard. ApplicableOSHA standards for electrical - 29 CFR 1926 Subpart "K" shallapply.Wfflkways. etc. - Damaged and deteriorated buildings often containunguarded walkways, doors, etc. where a fall potential exists.TI.ese must be guarded and/or posted to prevent employee use or

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passage. Areas where work will not be performed will be closedoff and posted, Applicable OSHA standard* for walkways, stair-ways, etc. - 29 CFR 1926.500 shall apply.Hjah or Elevated Work - Elevated work where a fall potentialexists will be performed using appropriate ladders and/or fallprotection (i.e. body harness and lifeline).Drum Handling - The movement and opening of drums will be done inaccordance with 29 CFR 1910.120 ,(j).cold stress - When the temperature falls below 40°F, cold stressprotocol shall be followed. Employees must be supplied withadequate clothing to maintain core temperature. Cold stress isdiscussed in detail in Attachment ___.Heat stress - When the temperature exceeds 70°F and personnel arewearing protective clothing, a heat stress monitoring programshall be implemented as appropriate. Employeea shall have accessto break periods and drinking water as necessary. Heat stress isdiacusaed in detail in Attachment ___.Eye Wash Protection^ - All operations involving the potential foreye injury, splash, etc., must have approved eye wash unitslocally available as per 29 CFR 1910.151 (c).Fire Protection/Fire Prevention^ - Operations involving the poten-tial for fire hazards shall be conducted in a manner as to mini-mize the risk. Non-sparking tools and fire extinguishers shallbe used or available as appropriate, Sources of ignition shallbe removed. When necessary, explosion-proof instruments and/orbonding and grounding will be used to prevent fire or explosion.utilities - Overhead and underground utility hazards shall beidentified and or inspected prior to conducting operationsinvolving potential contact.

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3,0 HlBflCML Hi)lU.'H[VB

Oha follcwinj la a kri*f descziptitn of the perscnal protectiveequipment vJuch my be raqdied during various [frees of thiproject, One U.S. Bft tarmlnctoy ftc pstectiva eqolpsnt willbe used; levria A, B, c, and itortlflad D.Reepixatccy pntective eqoipait dull be NXHHRzoved and usestall OTfam to CQtV 29 OR ftut 1910.134 Rajdiwarts. Eachentflcyo: diall raintaln a written reepixabcr txcgram detailingaaloiiai, use, cleaning, nainteranca and stocaga of reepiiatcryprotective aqoiptBrt.

3.1 IfMtQ. D Ptotectitn Shall

o The aluu%iiBre ccntains no Xnowi hazaid; and,o Work functions preclude splashes, imnarsion or the

potential for unmpecbad irtialaticn of, or contact with,hszanccus

3,1.1 LM! D Ftotection t 'jnnant at a Mlninun SMi ITpdat of!

o Stardazd vodt witam or owstalla;o Safety-toe wad; bcotn;o Glows as neadad;o SaMy glassw as naedad;o EfOarti dildd as needed; art,o HuCHttt.

3.2 laiA Uriified D ftotaetlm &j(lJ ft» iflt of;

o All level D rBjdrawrts witii tha additicn of paper Tywk suitsand a asbestos particulata filter raft.

OARI00099

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4.0

Aooaxllng to 29 CFR 1910.120 (h) Air Mxitoing shall to used toidentify and quantity aiitana levels etf hazardous sitetanes endhealth hazards in enter to determine tin (.ptcpriate IsvttL of•qflcyes pntacdcn naedad en-site.4.1 Ftautlna Air ffriiteriig

Upon initial cntzy to rule out HIH onditkns;possibility of an EIH bonditioi cc flamnhle

o Vhen work begins en a different pettier of the site;o ocntadrants other than those ixwiaaly identified an

being nsnUad;o A different type of qperaticn is initiated;o Employees are handling leekin. dnns or ccntainzB or

Mxking in areas with ctvioa liquid ootaniratlcn; and,o During ccnf Ined space vox.

Air mmitoring will ccniat at a minlnn of tte odtaria listedbelow. All air smitcclng data will be documtad and atoittalto the CSC and available In tht ccnand peat site f llea firrwiw by all interested penm. Air mcnitcring Instxmtawill be calibrated and maintained in accordance with thenrufhctuEV's qpsdficoticns.4.2 Sjtff Stffcmz Air Hrdterjm

o Mtlodate sznplirg of the wbiant air will be ocrtuctadperiodically,

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5.0 fiTIK ommjL flp SEBNEBBD CHSKPDC/~s miiiii5.1 WttkZcnea

Oha prinary purpose tor site ccntzcOs Is to establish thatazarthcus area periraber, to rectoo migntlcn of uitfliiliiaiits Intodean anas and to pa/at access cc ttfcaam to hazardous mater-ials by tnauttxrized person. At the erri of each wxteky, thesite should be secured or guarded, to psvent wuthcrlzed entry.Site week zcraa will Include:5.1.1 Clean Zcna/Suxcrt Zcna

This inxntaniratad ojffact zero or clean zcns will be the anaoutside the adusicn and darntaninatioi zcnes and within thegeographic peeinetera of the site. Ihis area la used fix stagingof ratarials, paddng of vehicles, office and labontccy fidli-ties, sanitaticn fiidlitlm, and receipt of delivBriea. Fencn-nal entering this zcne ray include delivery personal, viaitora,security guards, etc., vto will net necgasarily be pmaittod Inthe oclusicn zone. All pencmd. arriving In the stfpcct zcnewill HOT arrival, report to the oamand post and si t tin sitecntxy/odt log. Then will be era ortrolled oiby/odt pointfccm the dm zcne to the deuiiUnlnstlQi ton.5.1.2One deccntaninaticn zone will pxwida a Icoatkn fcr raooval ofocntaninsted poacnal pxibective tqiipott and final decaittmdna-tiai of panonal end eqjiptmt. All psncmal and equipgoitehould odt via the deccn ana, A separate daocntaninsticn anawill be established far haovy ecjiipnent.5.1.3 Bodusien Zena/tfat Zcna

Ohe eicduslcn zcne will be the "hot-zene" er ontaminated anainside the site psrioebsr. &itry to and exit fron thla acne will

rpguliBd to slcti thft hot zcne cntav/cocit log lor tcd at the dsscnana, flmmlate Mtnlnj algns to Identify the ndusicn zcnadMUJdJB pQJtad (i.e. "BWZR - WHREH) EEFSCtUEL OJU","HonnnvE HHIWENT RQQJIRED HWJD THIS pann*1, etc.) odtfron the eicludm zone nust be ftrmrpmind by pecscmal andequipoent dsoattnlnBtlcn as described in Secdcn 8.0,A rap of tin wcric zcnes fcr thla site follow.

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/IRIOOI02

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5i2 ftnfftll FJmfld ftfatv flnd ffi ffrilfd CPBttttir

o It la our policy to jnctioB addnistzatto hazard ocn-trol fer all site anaa ty natrictlng entrance toocliaitn zcraa to essential personal and ky usingcpKatlcnal sen,

o Oha "bxtry systan" wiU be ussd at all times ty allfield personnel In the hotzene. No era Is to perfcrmfield wtk alcra. Mdntaln visual, voice or radio coa-nnicBtlcn at all tinea.

o Wawer possible, ovoid contact with ccntaminatad (orpotentially ontsninsted) surftoai, Hhlk azcuxl (notthrou i) puMLes and discolond surfeoes. Da not kneelen the ground cr set equlpnent en the grand. Stay awayten any vasta druas uileas necnsary. Protect ecpip-nnt tan ocntaminsticn by Lajjiiij.

o Esting, drinking, or auking la pnrndttari cnly in deolg-nsbid anaa In the sifpcct zcra.

o Hands and face nst be thxognly ws*ed ipn leavingthe diocn ana.

o Baarch or otter fidal hair that inbsrferes with tegplr-atcr fit will pnolvde actaiasioi to the h* zcra.

o All eqaipsnt oust be daacntaninbed er diflcarded ifoicodt ten the •cluslcn zcra, as dtteonlned ky the OSC

All peCTOtiel exiting the coclwlcn zcra not go throrfcthe daoartarainatiai pxneckna deaoibed In Secticn 8.0.Safety Equipaant described in Section 4.0 will be

far all field perscrral.

10100103ji

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6,0

In gararal, ewythlng that enbera the eodwkn zcra at thlasits, mat either be deacntandrated or pccperly discarded HOTexit tan the cDeluakn zcra. All peracmel, Including any stateand local officials gust cnttr and eodt the hot zero through thedaocn ana. Prior to flmrhlHmtlm, ccnbninated egiipnnt willbe dBccntznlnated ml Inspected ky the OBC cr OSC dealgnstebefixe it la moved Into the dean zcra. Any material that lagenerated ty deoartaninsticn procedures will be stand In adeaigratid area In the Bclusioi zcra wtii disposal au.aii.am itsare rade.All peraonl mast sign the 'KIT ZCNE Bflft DOT ICG" thm enter-ing and codting the eclusicn zcra.NCOE; Oha type of deantaminsticn nnhtim to be used Is depend-ent en the type of chanicnl hazards. The daooitaainatiai solu-tiai far this site is aenfed voter. Deaontanlratlcn nrtlxiticn will be changed daily (at aminium) and nnllectfld and stored en-site uitil disposal aaatjaaita an finalized.

Dila deantan.'tnation pCDcadm TfH"1 to peLauiiel at thla sitewiaring level apdifiad D frottcticn. Base an the minima acnpb-

Station 1; Outer Bxt arri Outer Glova VeA art RJrea

Scat) outer boots, outer glims an4/cr splaeh suit withdaocntaminaticn solut±n cr detergent votar. Rinse off

wing vator. Hawve and stem if not dtiyomhle.

O

SSP: ____________________ DATE: ________ PAGE 18 OP 26

H tkt pagt filmed in tni4 .<r,««e ,U not aA ntadabltjin. Itgiblt.at thitlabel, it it due to AubAtandi.nd. colo* on condition oi tkt oniginal paar~

o

Rasove pancral protactiw clothing after rinsing and depositin the container fix disposal,

Remove hard-hat, fin-pins, and U applicable, depcait SCB\en a clean surfine. APR oartriajee will be discarded asan&HrJaai. When and rinai respirator at least daily.Wipe off and store napiratoEy geeor In a claen, dry loca-tion.

Statlai 4; Brer Glove Ranoval

Hanove Inner glowa. Deposit In ccntainer Car dieposal.Statkn 5; Fie

lands and face with soap and wetter. Stawaras ascn as possible.

flRlOO-105 l! \\88P:___________________ DATE:________ PAGE 19 OF 26

• H1

...irtfce pagt .ilmd i n tfci4 inamt i t n o t a t . . .label, *t 4.t due to 4ub4tanda.d colo* on condition oi /tkt oniginal pagt i

•" -' ' "'

~ 7,0 BMRgNCg RESBaSE CtMEMaC- MN

If. la mart In! that sits pttaaral be prepared in the evat ofan aaaojny, BnecgeredM on tate nany ftra; illnesasa orinjuries, cnadcal opoaun, fins, oplosiois, spills, leata,nlaaaai et harafUl ocntzBdnnta, or sudfen changes in thewetimc. The following saobiera outUne tht general proddinaftr mni,ijn.ciaai RiHHjHcy InftoiBticn enould be

7,1 BiHtmicy Ontzcta tor

alia:

OMadcBl ttaaa

Ralacn Qjitcca otnberi

tan Site to Hoeital (See Up in Sectkn 9,4) :

M31E; HfB end dincticra to the hoepital wiU be posted in theoffloa, deocn teaiiers and deacntaminaticn ana.Ihe route to the hoepital \m wrifled fcy: ________en . Distance fin site to hoepital la '

"5lving tin la ___ ____ . The. ___ ____fin, pcOloa, and hoapital wen ratified of site cperatlcra by________ on

fallowing indivttala haw bean trained in OR and First Aid:

^ „

8S"—————(nrtwoP™1——— PAGE 20 OF"•!•;,-• i:n "i-*»-ipi ",r,l'!>"Ti'"'.'/i _ 1

I< tfce page .ilned in thiA inamt it not at'ntadablitôn .,.,label, it it due to 4ub4tanrfa«d colo« on condition oi tkt oniginal page., ,'j

7.2 Aiiitlcral Emasrcr Haters

Nation! Fttpcrae OBrter 800-424-6802

Center ftr Diaaaae Qntrca 404-488-4100 (24 hr)

U.S. HA Region V 312-353-2318 (24 hr)

XKF (BqalflsivB- mfcranticn) 8MM24-9555Offline 800-424-9300

State Ihvinnnental Agercy ___ __ _

(EEfrfiPH)(Outside niinjis)

ObrpXBte 312-957-7600

Oiioago Division 312-709-0333

Michigan Diviaioi 616 91-9273

Etui cantm, Dtncbor of Safety 312-652-7367 (tarn)Jl 312-957-8171 (Qfc.)

ftv F. WMtm. DC.

Qlicugo OXF 312-993-1067

OflWland IKT 216-526-2484

Cdndnrati Uff 513-772-3444

DetooitlM 313-961-1880

HBstcn Medkal Etargency Servio* 513-421-3063HBBtcn 24-hour Hoblira 215-524-1925, 1926

HI. Inc. Qrtacta

RX Zcra KogrnHngaant Office 1-800-372-3727(HEWFCS)

SSP. l PAGE 21 OF 26

, . - . . . . r .li the page filmed in thiA inamt it not at ntadabUôn Itgiblt.label, it it due to 4ub4tanda«d colo< on condition oi tht oniginal pagt.

7.3 HPEBfy TlffffBTT BWIBMB Cfrprc'- OBHmnioaticra EJjuJptBt Icoaticn

O

Btbile Telqixras:'B*rt*y Radios:Bnargercy Alam/Hstra:

First Aid Kto:

Inepectkn Date:

Owen:Safety aowar:

Bile Bctinguidvrsi

Oy.J»a±«nt:

Jhapection Dabs: _______ Ey:Other:

Bail

SSPl________________^__ DATE!, .no PAGE 22 OF 26

H tkt pagt filmed in t*i* inanttTt not a* *eadaW« fl*,.,_„___.___„,,.....label, it iA due to 4ub4tanda*d colon on condition oi tkt oniginal page;;

OMCOB ooanwccR (cac)As the attainistratcr of the project, the OSC has pcirary nepcnraibility fir nopcrriing to end emoting cnergmcy situaticra.Ihe OSC will:

o TOa amstiiata measures to protect personal inclid-ing: withdrawal tan the ociusiai zcra, total aaatrtioi and securing of thi site cr vp-gndinj cr ton-grading the level of pxtective clothing and ropiratoyprotection.

o Mca afprqriata neasures to protect the public and thaenvixcnat including isolating and securing the site,preventing run-off to surface wotara and ending cr ccn-trolling the eonrgercy to the extent possible.

o Ensure that anzcpriate fladeral, state and local agm-daa an Inftnad, and cncgency itwfi:rae plans ancoodlmtad. In thi evnt of fin cr •qalceioi, thalocal firs Oepartaat ehxOd be auncrad limadiately.In the ennt of an air relaaae of tadc mtottdal*, theIfTHl outhcritifla ahould be inftmd in ccdcr to atMaa

,-_ tha mid fbr eveoaticn. m thi ewnt of a qpill, mni.-. tary diftricta and drinking v*tor system nry rail to fie

alntad.

Baun that afpccpriata deocn UvaLuuit cr tasting farcr injured peraonal la obtained)

o Determine the cause of the incident and makencomendsticn to (twuit the ncuncnoe; and,

o Ensure that all required reports have been {npand.

Ihe _M nuat Imadiately repot anzgency situation to tha OSC,tato enxcpdota measures to pxtect site persoral and aaalatthe CSC as nsoaaauy in rwpotiing to and mitigating tha «no>gercy situatioi.

(ran

O

Ihe TK mist Innadiately zepcrt aaajeay aituatloa to the OSC,tate BfpcofcUot nasuna to ii,iXaut site pencmel and assistthi OSC as nransaiy.

A R I O O I 0 9SSP:____________________ DATE:________ PAGE 23 OF 26

U tkt pagt jilted in tkit ina'mt it not at ntadablt^cn legible,,.O4.th< 4label, 4.t 44 due to AubAtandand colon on condition oi tkt oniginal

7.5

Any paraoi *to bnraa ill or Injund in the aMdvaioi za» outbe dsaontantntad to the Btodan wbrnt pnsaibLa. If thi injurycr tiff la miner, full dtccntaninotlcin dvuld be "TflHi andfixat aid acbinlatnd prior to traraport, If tta pstiant'socnditioi la aorkus, at least partial daontminatkn eteuld beoxplotsd (i.e., ooqplete diarcbin? of thi victim and ndnssingin dean coveralls cr wrapping in a blanket.) First aid Aouldbe adninistend while awaiting an wfcularce or paranoias, Allinjuries and illneaaes nust imtediataly be reported to the OSC.Any petscn tranaporting an insureyexposed paraai to a Hnig crhaepital fir treatment ehould tato with them directions to thahoepital and inftxaatlcn en tha chaakal(s) they nay have beenexposed to. ihla infbajatioi la inclxrfcd in Table 2.3.Any vehicle uMd to faamnt cxntamlnated perscmea, will becleaned cr deoaitandnstad aa neaessary.7,6

Bi tta awnt of a fin cr «_>lcekn, thi local fin dEpartaant*ould be oumcrad inndkbaly. Upon their arrival the OSC ordiaipstid altamate will advise tha fin cramfcr of thi loca-tion, natun and identifkntien of thi hazardaua ntmriala en-

If it is sate to do so, aita peraaral nety:o UM fin fitting ecpipmt available en site; cr,

iaplatt f|*"ffHMff CT* qthmrvhirii Toy ccntriluta to tha fin.

88P: ____ ; ______________ DATE; P*OE 24 OP 26DATE; flfl |QQ[ | Q

H tkt pagt .ilMed in thi4 inautt it not at .label, it it due to 4ub4tanda.d colot on condition oi tkt oniginal page.

xnxmHT__OHDBHBBB

8SP:____________________ DATHfl|QQ[ [ | PAGE 28 OF 30

page filmed in.tfci* .«ame it not at ntadablt on lt»ibtt.fat tkl '&:'''''''''M.' * J . J... + - ...L.J.-..J., . •••»«•«• W1l»-lJf !•»-»»•«»»»,••.CH4.

label, *t it due to 4ub4tanda4d colo« o* condition oi tkt oniginat

SITE SAFETY PROTOCOLATTACH' 'NT

SITE SAFETY PROTOCOLATTACHMENT

COLD STRESSa. COLD VZATHCT STRESS CAUSED FROM HYPOTHERMIA AND FROSTBITEt>, RECOGNIZING, PREVENTING. AMD TREATING HYPOTHERMIA AND FROSTBITE,

1, IN THE COMING MONTHS OF COLD WEATHER PERSONNEL SHOULD BEAWARE OF THE THREAT OF .COLD WEATHER STRESS WHICH MAT EXIST, THEFOLLOWING PARAGRAPHS WILL DETAIL WHAT is NEEDED TO RECOGNIZEAND PREVENT THE THREAT OF COLD WEATHER STRESS,

2, COLD STRESS: LOW TEMPERATURES NOT ONLY CAUSE PHYSICALDISCOMFORT BUT CAN ALSO CAUSE COLD INJURIES; SYSTEMICHYPOTHERMIA IS THE GENERALIZED PROGRESSIVE COOLING OF THE BODYTHAT OCCURS WHEN THE BODY'S CORE TEMPERATURE FALLS BELOW 95DEGREE'S IF! AND THE BODY'S TEMPERATURE CONTROL MECHANISM ISOVERWHELMED AND UNABLE TO RE WARM THE BODY UNASSISTED,EACH PERSON'S NORMAL BODY TEMPERATURE IS 95.6 DEGREES F. THIS KEEPSALL OUR VITAL INTERNAL ORGANS WORKING PROPERLY, PARTICULARLYOUR HEART AND BRAIN PERSONNEL WORKING OUTSIDE IN COLD WEATHERCONDITIONS FOR LONG PERIODS OF TIME RUN THE RISK OF ENDANGERINGTHIS DELICATE TEMPERATURE BALANCE BY OVER EXPOSURE TO COLDCONDITIONS, FACING THE POSSIBLE DANGER OF HYPOTHERMIA.3, HYPOTHERMIA RESULTS WHEN THERE IS A DROP IN THE SOW CORETEMPERATURE CAUSED BY EXPOSURE TO COLD, WIND, AND OR RAIN OR B?IMMERSION IN COLD WATER. UNDER THESE CONDITIONS, WHICH MAYEASILY OCCUR WHEN OUTSIDE TEMPERATURES ARE WELL At WE FREEZING,THE BODY BEGINS TO LOSE !TS ESSENTIAL HEAT MORE RAPIDLY THAN IT ISABLE TO REPLACE IT, IF SUCH CONDITIONS ARE NOT SOON REVERSED ANDBODY CORE TEMPERATURE !f NOT RETURNED TO NORMAL, THE BODY'SCHEMICAL REACTIONS WILL BE SLOWED AND SERIOUS IMPAIRMENT ORDEATH MAY RESULT. HYPOTHERMIA IS TERMED M! LD TO MODERATE ATBODY CORE TEMPERATURES BETWEEN 91 AND 95 DEGREES !F|, BELOW 6$DEGREES HOWEVER, THE PATIENT IS IRRATIONAL AND MAY BECOMECOMATOSE,HYPOTHERMIA IS USUALLY DUE TO A COMBINATION OF T*'0 OR MOREHAZARDOUS CONDITION SUCH AS;a, AIR TEMPERATURE: THE COOLING OF THE BODY CORE CAN OCCUR ATTEMPERATURES WELL ABOVE FREEZING

flRIOO||2

H tht pagt filmed in thiA inamt iA not aA ntadable. on legible at thiAlabel, it iA due to AubAtandand colon on condition oi tht oniginal pagt.

SITE SAFETY PROTOCOLATTACK JNT., WATER: WATER CONDUCTS HEAT AWAY FROM THE BODY AT A RATEAPPROXIMATELY 25 TO 40 TIMES FASTEN THAN AIR TEMPERATURESCONDITIONS COULD EXIST TO SITUATIONS IH WHICH PERSPIRATION, RAIN,AND MIST ARE TRAPPED AGAINST THE BODY BY CLOTHING OR FOOT WEAR,C, WIND; THE WIND ACTS TO INCREASE THE CHILLING EFFECT OF THETEMPERATURE B? ELIMINATING THE LAYER OF INSULATION BETWEEN THESKIM AND AMBIENT AIR ;THUS, AS THE TEMPERATURE FALLS, THE WINDHAS AN INCREASINGLY GREATER EFFECT ON LOWERING THE SODY'SRELATIVE SENSE OF COLD,_, CLOTHING: PROPER CI/JTHIN3 CAN PREVENT THS PENETSATIOH OF COLD,WIND, AND RAIN SY MINIMIZING HEAT LOSS. THE MOST EFFECTIVE WAYTO DRESS TO AVOID EXPOSURE TO COLD IS IN LAYERS OF RELATIVELYLIGHT CLOTHING, THE UPPERMOST LAYER WHICH SHOULD BE WATERPROOFAND ALL OF WHICH CAN BE EASILY DONNED OF. REMOVED DURING THE DAYTO KEEP THE BODY AT A COMFORTABLE TEMPERATURE,«, BODY TYPE: SURVIVAL TIME MAY BE AFFECTED POSITIVELY ORNEGATIVELY BY BODY TYPE SUCH AS SIZE, .-.TTITUDE/.ND PHYSICALCONDITION, THIS CAN PLAY AN IMPORTANT ROLE OF SURVIVAL TOWITHSTAND COLD WEATHER STRESS AND CONDITIONS.f, EXPOSURE: EVEN THOUGH TEMPERATURES CAN DROP TO THE ,0'S ANDMAY NOT DAMAGE YOUR KEAD.HANDS ,OR FEET IT IS IMPORTANT TO COVERTHESE PARTS BECAUSE THE HIGH LOSS RATE OF HEAT, MORE THAN HALF OFYOUR BODY'S HEAT IS LOST VIA THE HEAD,g, FUEL: A BALANCED DIET INCREASES YOUR STAMINA FOR HEAT LOSS BYKEEPING A PERSON FROM TIRING DURING THE WORKDAY, ALCOHOL ANDDRUGS, WHICH Dl LUTE THE BLOOD AND HUMS THH SENSES LOWER THEBODY'S RESISTANCE TO COLD AND CONSEQUENTLY INCREASE THE RISE OFHYPOTHERMIA.h MENTAL ATTITUDE' MENTAL ATTITUDE PLAYS Af! IMPORTANT P.C'LEIN ANY COLD STRESS SITUATION. IMPERATIVE TO SVRVi'.'AL i: APOSITIVE ATTITUDE INCLUDING THOUGHT AND PREPARATION TO PREVENTHYPOTHERMIA All UNDERSTANDING OF THE WARNKW SIGN: OFHYPOTHERMIA, AIID KNOWLEDGE OF POSSIBLEHA2ARWUS WEATHEP.CONDITIONS,

«. SYMPTOMS OF HYPOTHERMIA:a. POOR COORDINATIONb, STUMBLING AND SLURRED SPEECH.C, MENTAL CONFUSIONd. SEVERE SHIVERING*. MUSCLE RIGIDITY

5. PREVENTATIVE MEASURES FOR HYPOTHERMIA:

flRIOOI!3

U tht pagt .ilmed in tni,4 inamt it not at'ntadablt..on legible a* thit-label, it it due to Aub^tand«*d colo* o* condition oi tht on4.g4.nal pagt

SITE SAFETY PROTOCOLATTACH} ITa, KEEPING DRYb, WEARING SEVERAL LAYERS OF INSULATED CLOTHING,

INCLUDING A HATc, REMAND BALANCED EATING HABITS4. WATCH WEATHER CONDITIONS*. MAINTAIN A POSITIVE ATTITUDE IN THE EVENT OF AN EMERGENCY1 BEING AWARE OF SIGNS OF HYPOTHERMIA BOTH IN YOURSELF AND

IN OTHERS,6 FROSTBITE; IS THE FREEZING OF LIVING TISSUES WITH A RESULTANTBREAKDOWN OF CELL STRUCTURE, IF EXPOSURE OCCURS IN

TEMPERATURES WHICH ARE BELOW FREEZING <JO DEGREES F ORBELOW/, FROSTBITE OR TRENCH FOOT (IMMERSION FOOT) MAYACCOMPANY OP, COMPLICATE THE SYMPTOMS OF HYPOTHERMIA,INJURIES DUE TO FROSTBITE MAY RANGE FROM SUPERFICIAL REDNESSOF THE SKIN, SLIGHT NUMBNESS AND BLISTERS,FROSTBITE MAY OCCUR IF THE SKIN COMES JHTO CONTACT WITHOBJECTS WHOSE SURFACE TEMPERATURE IS BELOW FREEZING, SUCHAS METAL.TRENCH FOOT IS CAUSED BY CONTINUOUS EXPOSURE TO COLD COM-BINED WITH PERSISTENT DAMPNESS OR IMMERSION IN WATER.SOME OF THE SIGNS OF FROSTBITE ARE A SENSATION OF COLDNESSFOLLOWED .7 NUMBNESS, ACHING, TINGLING, OR STINGING. MOSTCOMMON AREA'S EFFECTED FINGERS, TOES, EARS.NOSE, LIPS AND EYELIDS.PRECAUTIONS WHICH CAN BE TAKEN TO HELP PREVENT FROSTBITETO THESE SENSITIVE AREAS ARE: COVERING HANDS WITH WELLINSULATED GLOVES (ALSO WATER PROOF).WATER PROOF INSULATEDBOOTS, SKI MASK TO PROTECT THE FACE FROM WIND DAMAGE, ANDEYE PROTECTION FOR THE DIRECT WIND AND CHILL.

7. TREATMENT OF HYPOTHERMIA AND FROSTBITEA HYPOTHERMIA.1. GIVE ARTIFICIAL RESPIRATION AND STOP ANY BLEEDING IFNECESSARY

2, BRING VICTIM TO A WARM ROOM OR SHELTER.3. IF VICTIM CAN NOT BE MOVED BECAUSE OF SPINAL INJURY,PUCE DRY MEW! PAPERS.BLANKETS OR SOME OTHER INSULATIONBETWEEN HIM AND THE GROUND.

i REMOVE ALL WET CLOTHING5, PROVIDE *N EXTERNAL HEAT SOURCE, m THE BODY CANNOT

GENERATE ITS OWN HEAT, WRAP THE VICTIM IN PREWARMEDBLANKET, PLACE HIM OR HER IN THE LINER OF A PORTABLE

.ARIOOIIIf

H tht pagt iilntd in thiA inamt it not at ntadablt..on legible at thit 'label, it iA due to AubAtandand colon on condition oi tht oniginal pagt.

SI TESAFF* PROTOCOLATTACHM .T

HYPOTHERMIA TREATMENT UNIT, PUT THE TORSO (NOT THEEXTREMITIES) INTO A TUB OF WARM WATER OR USE BODY-TO-BODY CONTACT TO REWARM THE BODY CORE, THESE MEASURESWILL SLOWLY REOPEN THE PERIPHERAL CIRCULATION,(STAGNATED BLOOD FROM THE LIMBS TO THE HEART), WHICH MAYOTHERWISE CAUSE VENTRICULAR FIBRILLATION,CARDIACARREST OR DEATH,

f>. DO NOT ALLOW THE VICTIM TO SLEEP,7. GIVE WARM, SWEET DRINKS, NO ALCOHOL OR PAIN RELIEVERSe.DQNOTRUBNUMB.SKJN.9 GET MEDICAL HELP AS SOON AS POSSIBLE.10, FOR PATIENTS WITH SEVERE HYPOTHERMIA, REWARMINO IN THE

FIELD CAN BE DANGEROUS, TO TREAT THE SEVERELY H7POTHERMICPATIENT, STABILIZE THE BODY TEMPERATURE, AND AVOIDFURTHER HEAT LOSS BY INSULATING WITH BLANKETS ANDHANDLE THE PATIENT GENTLY. PROMPT TRANSPORTATION TO THEEMERGENCY ROOM IS REQUIRED, SPECIAL TECHNIQUES WILL HAVETO BE USED TO REWARM THE PATIENT

B, FROSTBITE

1. WRAP THE VICTIM IN WOQ.EN CLOTH AND KEEP DRY UNTIL HEOR .HE CAN BE BROUGHT INSIDE,

2. W NOT RUB, CHAFE OR MANIPULATE FROZEN PARTS,3. .RING VICTIM IS DOORS.f DO NOT USE HOT WATER BOTTLES OF. A HEAT LAMP, AND DO' NOT PLACE THE VICTIM NEAP. A HOT STOVE.5. DO NOT ALLOW VICTIM TO WALK IF HIS OR HER FEET ARE

AFFECTED.6, HAVE THE VICTIM GENTLY EXERCISE THE AFFECTED PARTS ONCE

THEY ARE THA WED,7, SEEK MEDICAL AID FOR THAWING OF SERIOUS FROSTBITE;

BECAUSE THE PAIN WILL BE INTENSE AND TISSUE DAMAGEWILL BE EXTENSIVE,

WIND CHILL CHART: SEE PAGE 5

O• »

flRIOOIIS';)' *

U tht pagt .ilwed in tni4 <*a*e i* not aA ntadabl.t..on ltgiblt.,at thitlabel, it it due to 4ub4tanda«d colo* o* cond*t*on oi tht ontgtnal pagt.

Cooling Power of Wind on Exposed Flesh Expressed .3 Equivalent Temperature( under CilmwndHloni)

Estimated ACTUAL TEMPERATURE DEGREES |F|windSpeed(in mph

calm510152025303540

VMiperi

»h«40iriph wtt(Mttioml

50 40 30 20 10 0 •10 -20 -30 -40) ——————————————

EQUIVALENT CHILL TEMPERATURE (Fl

50 40 30 2048 37 27 1640 28 16 436 22 9 -532 18 4 -JO30 16 0 -IS28 13 -2 -1927 11 -4 -2026 10 -6 -21

LITTLE DANGER

Mixwgm dwjtr offllw MW of jKwty

10 06 -5-9 -24_•IB |-32-25 -39-29 -44-33-43-35-51-37 -53

•!0•1")-33-45•53•59-63'-67•69

-20|'•5.'-46-56•67-74-79-82-85

INCREASING DANGER

txpotrtfltrivlttrinm

50 -60

•JO -40 -50 -60-36 -47 fS? -fifl-sa -70•72 |-85-82 -96 --68 -104 --94 -109 --98 -113 --100 -116 -

-63 -95-99 -112110 -12118 -133

125 -140129 -145132 -148

GREAT DANGERFlwhnuyfrwwvfltm

TMMhfoot v,4 imwf iw M m* «wr it wy Mint or, «hfe rfurt

IN CONCLUSION; ANYTIME THE TEMPERATURE FALLS BELOW 40DEGREES F COLD STRESS MONITORING SHOULD BEGIN. EACH INDIVIDUALSHOULD BE RESPONSIBLE FOR MONITORING THEMSELVES AS WELL AS THOSEAROUND THEM. THERE SHOULD BE MEDICAL MONITORING (EMT) PERSONNELSTANDING BY SHOULD AN INJURY OCCUR,

A R I O O I I 6

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^iuMandm d colo* 01 condition o{ tkt · 2020-02-12 · o FEDERAL ON-SCENE COORDINATOR'S REPORT AMBLER ASBESTOS WASTE TAILINGS PILES #2, NPL SITE CERCLA/SARA REMOVAL ACTION March 6,1989