ATSDR Record of Activity (AROA) Health Consultation

f V SDMS DocID 2105095

UID #: lkw9 Date: 12/ 20/ 2006 Time: am X pm

Site Name: Borit Asbestos Site: City: Ambler Cnty: Montgomery State: PA

CERCLIS #: PAD981034887 Cost Recovery #: 3'AEN Region: 3 Site Status (1) NPL X Nbn-NPL _ RCRA _ Non-Site specific _ Federal;

(2) _ Emergency Response X Removal _ Other

Activities: _ Incoming Call ._ Public Meeting* X Health Consult' _ Site Visit' _ Outgoing Call _ Other IMeeting _ Health Referral _ Info Provided-_ Conference Call X Data Review X_ Written Response _ Training _ Incoming Mail . . _ Other

Requestor and Affiliation: < (l)Charlene Creamer, SAM, EPA III Site Assessment Phone: 215-814-2145 Address: 1650 Arch Street City: Philadelphia State:PA Zip Code: 19103

Contacts and Affiliation: Jack Kelly, EPA/ATSDR R3 detailee • Lora Werner, ATSDR R3 Dr. Karl-.Markiewicz, ATSDR R3,- Dr. John . Wheeler,. ATSDR DHAC . . ,. : .

Program Areas ' _ Health Assessment _ Health Studies _ Tox Info-profile _ Worker H-lth _ Petition Assessment _ Health Survellnc_ Tox Info-Nonprofil_ Admin _ Emergency Response _ Disease Regstry _ Subs.t-Spec Resch _ Other , X Health Consultation _ Exposr Regstry _ Health Education

Narrative Summary:

EPA Region 3 SAM Creamer provided ATSDR with analytica April 2006 site assessment sampling event at the Borit Site) in Ambler, PA. EPA requested ATSDR's opinion on health threat posed by asbestos in soil, sediment, sur importantly, outside air. EPA provided analytical resu all media of concern. ATSDR provided a-verbal evaluati assisted in the drafting of an explanatory letter whic the EPA Borit Site website (http://www.epaosc.org/BoRi this request, ATSDR has assisted EPA at an October 200 helping coordinate development and implementation of a sampling program and is working with the local and Sta to address specific public health concerns.

1 data following an Asbestos Site (Borit any potential public face water and, most Its from testing of on' to EPA and h has been posted on t). Subsequent to 6 public meeting, is n air and soil te Health Department

In addition to providing ' further opinion oh the reicently collected sampling data, this ATSDR Record of Activity (AROA) Health Consultation will include summaries of (1) past sampling efforts to give the reader a sense of investigatory activities performed to date and the asbestos•concentrations

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recorded in the community and adjacent to the site (Attachment 1) and (2) the history of public health opinions for the asbestos contamination concerns in the Ambler area (Attachment 2).

Site Background

The Borit Site consists of three distinct asbestos-contaminated areas along Maple Street just,west of Butler Pike in Ambler, PA (See attachment 2). The areas were commonly referred to as the East Maple Street Pile (now called the Borit Asbestos Pile), the. West Maple Street Pile (now a 'dosed 'park known as the Whitpain Wissahickon Park), and a reservoir. These areas are located a few hundred yards northwest of the asbestos piles that became the Ambler Asbestos Piles NPL Site, remediated in 1993. Although the same companies disposed of asbestos containing waste at both the Borit Site piles and the Ambler Asbestos Site^piles across Butler Pike, a local major road, the Borit Site piles were not. included as part of the NPL Si-te. Apparently, a decision was made that the Borit Site piles would be monitored by the PADER (now PADEP) as the site had been covered with soil in the mid 1960s. ' '• -• • • .• '

Both the Borit and Ambler Asbestos Piles Sites exist as a result of disposal operations'by the former • Keasby and Mattison Company and •;.,.• •.•• succeeding companies" Certainteed Corporation and Nicolet Industries. ' : . Keasby and Mattison (K'&M) produced asbestos products, including paper,,- ' . millboard, electrical insulation, brake linings, piping, conveyor belts, high pressure packings, roofing.: shingles and cement siding, from 1897 to 1962. During World War II, the company was a leading manufacturer of asbestos products. In 1962, K&M ceased operations and Certainteed' and Nicolet purchased different portions of the K&M facility. Certainteed, primarily manufactured asbestos-cement pipe and Nicolet manufactured automobile parts, laboratory table tops and other products. Certainteed ceased operations in 1974 and Nicolet operated at least until October 1987, producing only asbestos^containing rubber gaskets, by 1987 (CDM, 1988),.

The former East Maple Street Pile (now Borit Asbestos Pile) rises approximately 20 to 30 feet above the ground and is approximately 2.5 acres in size. The estimated volume is 149,500 cubic yards. The pile appears on a 1938 aerial photograph (earliest available) and K&A reportedly began disposing of waste.there during the 1930s. Asbestos waste disposal appears to have continued until the 1960s. This area primarily received a slurry of spent magnesium and calcium carbonate a s well a s waste products from the manufacturing of asbestos pipe, insulation, sound dampeners and ceiling/roof tile. The berms around the pile appear to have been constructed of asbestos shingles and soil (CDM,, 1988) . Based on aerial photographs, by 1965 the pile looks to be covered and vegetated. The property reportedly was first fenced in approximately 1986 "and is currently fenced. For short periods, of,time in the 1980s and 1990s, portions of the pile area were used as a trash transfer station or trash .storage location and for fire department training (Gilmore & Associates, 2001). Currently, the pile is heavily vegetated although asbestos containing material (ACM)

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is visible on the surface, in several locations.

The former West Maple Street pile (now the closed and fenced Whitpain Wissahickon Park) reportedly received out-of-spec asbestos manufacturing products and other solid wastes. It is not clear when disposal first took place here but, based on aerial,photos, it was occurring as early as 1937 (EPA Aerial Photo Collection). Two"rows of what appear to be factory worker homes appear on the property, from 1938 (earliest available photo) to 1959 but are removed by 1964. Aerial photos indicate that the pile was covered soon after the homes were removed, sometime during the 1965 to 1970 period. The current park is triangular and rises a few feet above the surrounding street level and is roughly 500 feet at its widest point and approximately 1500 feet from end to end. A 1973 aerial photo shows a baseball diamond in the park. The park also is currently heavily vegetated and has been officially closed for approximately twenty years. However, localized areas of asbestos waste appear at the ground surface. The local community and other interested parties would like to see the park reopened for resident use.

The reservoir lying between the, . East Maple Street Pile and Whitpain-Wissahickon Park was used to provide process water -for facility operations. The reservoir appears in the 1937 aerial photo and likely was in place' prior to this date. It is approximately 14 acres in size-. The berm around the reservoir was made of asbestos shingles, millboard and soil. Asbestos product waste, particularly water pipe and tiles, are suspected to lie on portions of the reservoir bottom. Currently, the Wissahickon Valley Watershed Association (WVWA), a local conservation group, has plans to convert the reservoir to a waterfowl preserve.

Directly across Maple Street from the Borit Site is a former warehouse and lot reportedly once used by K&M to manufacture asbestos shingles (CDM, 1988; O'Brien & Gere 2004) . Currently, the warehouse appears to be an active commercial property. In October of 2006, minor construction activities in the form of ground, resurfacing were observed in,the former l o t . • • , ' - ,

Historical aerial photographs also show what appear to be at least two other asbestos piles located just east of Ellerslie Avenue between Ambler Road and the SEPTA RR tracks at the present.site of a large warehouse and open lot. The piles are present at least from 1942 until 1950 but seem to have been removed or paved over by the mid 1960s.

Environmental Data

Several investiga.tive reports have been prepared over the years principally addressing the nearby Ambler Asbestos NPL Site. However, due to the proximity of the two sites, the history of disposal operations in Ambler, and the selection of sampling points- during -these studies, air sampling data from these investigations may provide useful information regarding the past air quality status not .only in the neighborhood surrounding the Ambler

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Asbestos Site but also the community near' the Borit Asbestos Site.

Because of its overwhelming importance as an exposure pathway, this review will primarily focus on historic air data. Unfortunately,- a host of factors makes interpretation of this historic data difficult from a public health evaluation perspective. These factors include the lack of detailed' information regarding the past sampling events (e.g. exact sample locations, other potential asbestos sources', extent of operating facility emissions, quality control measures),-and inconsistencies resulting from the several types' of air sampling techniques and analytical methods used over the years. Despite this difficulty, the information is being included as it provides some context to what earlier air readings were during facility operation when emission controls and air quality requirements were arguably less stringent. The • summarized'da:ta in Table 1 below and in- Attachment 1 may prove useful for interpretation of any health statistics evaluations conducted by the State Health Department and/or ATSDR and will hopefully help address community concerns expressed'at the recent public meeting.

Table 1. Historic Ambler Asbestos Site/Borit Site Air Sampling Investigations

Date

Nov 71 & Jan 72 •

Oct 73

Nov 7 6

Nov 7 6

Jul 77

Jul 77

Jun 8 3

Agency

EPA

EPA

PADEP

PADEP

PADEP

PADEP

EPA

Range of Cone.

Not Specified

3.1-2600 ng/m3

0.0005 - 0.066 f/cc

0.017 - 0.085 f/cc

0.0035-0.0093 f/cc

0.048-0.18 • f/cc

ND - 0.02 f/cc

Analysis

PCM?

PCM?

PCM/ TEM

TEM

PCM

TEM .

PCM

Findings/Comments Dust emissions observed; •samples positive for "asbest.os, no other info available Ten sample locations. Concentrations reported exceed urban (Philadelphia) background comparison range of 45-100 ng/m3 per 1971 Nicholson study referred to in 1988 RI/FS 75 samples from 13 locations. 4 of 75,samples detected chrysotile.

12 samples collected.

4 of 8 samples detected chrysotile. Max. concentration above current occupational standards. Only two air samples. Dust samples between 3%-35% .chrysotile led to-closure of adjacent pla.yground. EPA Removal Action initiated.

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" D a t e •

Dec.83

Apr 8 4

Sep 84

Oct 8 6

Dec 86

Jan 87

Apr 87

Apr 8 7

Apr '8 7

Mar -May 87

Aug 8 7

Agency

- EPA

EPA

EPA & CDC

EPA

EPA

EPA

EPA

EPA,

EPA

EPA/ Privat

e

EPA

Range of Cone.

ND - 0.01 f/cc •J

ND - 0.12 f/cc

None above background

• ND

0.01-0.09 f/cc

0.01-0.08 f/cc on-site

0.2-1.95 f/cc off-site

0.01-0.08 f/cc

ND-0.06 f/cc.

J

0.24-1.39 f/cc

ND- 0.01 f/cc

ND-0.02 f/cc

Analysis

.SEM

SEM & TEM •

PCM & TEM .

TEM •

TEM

TEM r

TEM

TEM

TEM

PCM?

TEM

Findings/CiDmments-Three air samples. Dust samples between 3%-35% chrysotile led to closure of adjacent playground. Removal Action initiated; •• • 5 locations over 4 days. 0.12 f/cc for sample station collected near brake repair shop. On site ND - 0.07 f/cc Dust samples from inside homes adjacent.to site. No levels above background. Limited air sampling (6 samples) just before RI. No asbestos detected. Initial RI sampling. 4 samples. Max reading was upwind sample along road with heavy traffic. 6 onsite,- 10, offsite locations. Background sample' = 0.5 f/cc (chrysotile). Highest values found on Main Street. Several confounders described in the study. . Drilling/test pit actfivity sampling. Amosite detected in waste pile. RI/FS sampling. Blank contamination detected.

3 samples collected on adjacent active site.' Cone, converted from ng/m3. Sampling effort suffered from data quality complications. See Attachment 1 for further discussion. 17 samples for personnel H&S sampling. Waste pile described as moist. 4 onsite, 11 offsite samples. Detection limit of 0.01 f/cc reported. Only

one sample exceeded DL'. "

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Date

J u l -'•

Nov 92

Summer 01

May 04

Apr 06

Agency

EPA

Privat e

Privat e

EPA •

Range of Cone.

ND-0.05 f/cc

ND.

ND - 0.004 f/cc -

0.00061-0.039 f/cc

Analysis

TEM

TEM

PCM

TEM

Findings/Comments Sampling conducted during EPA Remedial Action. Little info available. Results not deemed significant. One sample. Phase II audit of Borit Pile. No asbestos detected. Two -samples Phase I audit of reservoir. Asbestos detected.. Six samples. ,A11 six samples positive for asbestos. • •

Sources: CDM, 1988. F ina l Remedial I n v e s t i g a t i o n / F e a s i b i l i t y Study Report for .Ambler A s b e s t o s P i l e s , (Voliime 1) , CDM Federal Programs Corporation, Ambler, PA, August 1988. Contract No. 68-01-6939. Gilmore & Associates, '2001. Phase I Environmental S i t e Assessment , 6 Maple S t r e e t , Ambler, PA, August- 7, 2001 Gilmore & Associates, 2001. 6 Maple S t r e e t Phase I I S i t e C h a r a c t e r i z a t i o n B o / R i t S i t e , November'2001.' O'Brien & Gere, ,2006. January 13, 2006 Letter Report: Da ta Summary R e p o r t f o r Phase I I Sampling A c t i v i t i e s . TetraTech, 2006. Draf t Tr ip Report f o r the B o r i t Asbes tos T a i l i n g s P i l e , TetraTech EM Inc., prepared for EPA, August 2006. . .

Sampling results for soil, sediment and surface water are also summarized in Attachment 1. However, sampling data for these media are not easily interpretable with respect to assessing possible community exposures and usually require extrapolating or predicting the potential for release of fibers from these media into breathable air.

Asbestos results for potable water can be compared against health-based guidance but this pathway is not relevant at the Borit Site, as the nearest public' water intake is approximately twelve miles downstream in a separate receiving water body. .

. , , n Discussion:

Airborne Asbestos

Based on the information presented in Attachment 1, the Ambler Asbestos and Borit sites have undergone extensive investigation and mitigation activities . since the early 1970s. As reviewed in Attachment 2, public heath recommendations have focused on preventing exposure to airborne asbestos fibers through site access restrictions and adequate covering of onsite ACM.

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Although it is obvious ,that scattered areas of surface erosion at the Borit site have been consistently present over the years, there are several reasons to suspect that the site may not have served-as a significant source of fiber emissions to' community ambient air over the years. These include the soil cover placed on the site in the 1960s, the moist texture and non-friable appearance of much of the surfieial asbestos material, the subsequent growth of natural,vegetation oyer much of the site and the closure of the majority of the site to residents and potential ground disturbing activities since the mid 1980s.. The largest quantities of surface-present asbestos containing materials are. along the si.te water bodies but these materials are- heavy, likely non-friable and do not release visible particulates/dust when mildly dis.turbed (e.g. walked ,on, picked up by hand). However, this is entirely professional judgment and only air sampling data can determine the accuracy of such a statement.

As summarized in Table 1 and Attachment 1, air was regularly sampled in the site area from 1971 through 1987 (when Nicolet discontinued operations). From 1987 until the 2006 air sampling information is.very limited. The data show air levels range from no asbestos detected to as high as ~2 f/cc. The maximum onsite data do not appear to reflect the maximum offsite levels. Furthermore, the'historical information does not, distinguish mineralogy of the fibers, and does not show if total TEM fibers were counted or if PCMe data could be calculated from the counts. This makes making drawing any health conclusions from the data extremely difficult;

Even the more detailed air sampling efforts during and prior to 1987 present a confusing picture regarding the air quality in the adjacent Ambler community. Several sampling events and most sampling locations reveal insignificant asbestos readings (i.e. non-deteet or below typical urban-.area levels at the time) even when the Nicolet facility was in operation. Other sampling rounds show elevated readings at specific sampling locations (above the OSHA 0.1 fibers/c;;c standard in a few eases) . These higher results may,be the result of actual emissions from the piles or may- primarily be due to other complicating factors such as nearby auto repair shops, braking automobiles in transit, the operating Nicolet facility, other potential unknown so.urces, -or asbestos analytical .problems. The fact that numerous types- of sampling and analytical procedures were used over the years by different organizations further complicpates the ability to evaluate and compare the data sets.

The most recent air data collected, and thus, most relevant to a discussion of,current exposure potential, , was that performed by EPA in April 2006. However,. because it was performed for a .very specific purpose, it too raises additional questions regarding, routine levels of airborne asbestos, in the surrounding community. The samples were only collected over one 24 hour period, a.time, duration insufficient to make projections about continuing airborne asbestos levels .given, the many factors that might affect the release of fibers to the air;, e.g. vegetative cover, onsite activities and ground surface disturbance, wind speed and direction,

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V

precipitation and ground moisture. Also, samples were .collected at the site perimeter but not within the community. Finally, and more an unfortunate, circumstance than a data limitation problem, four of the six air samples were found to be'overloaded with dust/particles making the analytical data, as presented,' unreliable for a.determination of health' risks or comparison to health-based standards or guidelines.

Not surprisingly, the four overloaded samples analyzed by the' •'^indirect" method recorded the highest asbestos concentrations regardless of the. sample location.' Of the two samples able to be analyzed by the "direct" transfer method, one was located-directly on top of the Borit pile, and the other was- located immediately downwind of the Borit pile, yet both of these samples recorded the lowest readings of the sampling, event.'Simply. put,- use of the indirect mettiod, although necessary when filters are overloaded, provides results which are difficult to interpret from a public health perspective and may result in values suggesting a higher exposure potential than what is.actually occurring. " -•'" ' • ' '

Currently, in an effort to- determine- if current conditions at the site are releasing airborne fibers at levels of- health concern, EPA has. initiated an air sampling program to be cbarried out over a year or more. Samples will periodically be collected over several days duration on site, at the site perimeter and within the surrounding community.. Samples are also being collected when specific activities- (e.g., walking, soil digging, grass cutting) are being performed^onsite. Sampling and analytical procedures are being discussed with EPA's Technical Review Workgroup's asbestos subcommittee in an effort to ensure' -that the work is performed with input by those most knowledgeable in asbestos'-related field sampling.

As the data from the individual air sampling rounds are completed, results will be evaluated against•asbestos public health criteria and guidelines,-typical "background" urban/suburban air concentrations-based on research studies, upwind sample locations and sample data collected at a nearby town. By this approach^ not- only can the potential health -risk posed by the site be evaluated but the risk can be'put in context of what others are routinely exposed to in areas without a long legacy of asbestos production. In its 2001 Toxicological' Profile for Asbestos (ATSDR, 2001), ATSDR reports typical urban and rural air asbestos levels based on air.sampling research studies over the 'years. However-, the dataset' is presented in "PCM equivalents" meaning that the- results are' (Converted from the specific analytical procedure used to analyze the samples in a given study (usually TEM) to values that result from the PGM method'of analyses. Considerable controversy exists regarding use of the generic•conversion factor recommended by the National Research Council in 1984 to convert TEM results to the PCM equivalent values (and vice'versa). It is referred to in the ATSDR Toxicological Profile as a "criade approximation". With this in mind, the data presented in the toxicological profile will not be referenced at this time but efforts will be made to locate studies presenting background urban and rural cioncentratioh in--TEM values as TEM results represent the majority of data presented in this'document. . - •

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Asbestos in Other Media

Attachment 1 also presents sample results for soils and surface water. The threat posed by asbestos-contaminated soils lies in the potential for soils to be disturbed mechanically (wind or other activities) and result in the release of fibers to the air. From the available surface, soil data and' visual observation, this potential exists yet the extent of any release, distance fibers might travel ancd .duration of release is unknown. The current air sampling program should address this data gap. .

At times, sampling events have shown elevated levels of asbestos concentrations•in the Wissahickon Creek but the data is fluctuating and irregular. Sampling efforts as early as the 1970s only revealed localized elevations, directly adjacent to active facility wastewater outfall location's; sample results removed, from these locations were either non-deteet or well below the drinking water standard of 7.0 MFL {EMV,1978; JRB, 1980). Yet sample results in 1987, when the outfalls were discontinued, showed levels much higher than the drinking water standard, up to 450 MFL (CDM, 1988). Samples in 2006 downstream were non-deteet for asbestos (TetraTech, 2006) . ;'Fluctuating sample results may be explained by the constant movement of water, sediment runoff periods versus sampling event times, low water versus high water periods, precipitation events, and analytical methodologies used.

Because the- nearest drinking water intake is,more than twelve miles downstream in a different and larger waterway, there is little public health concern. Furthermore, there is limited information that.drinking water containing asbestos causes health problems. In 2003, WHO concluded that "there is no consistent, convincing, evidence that ingested asbestos is hazardous to health, and it is. concluded -that, there is no need to establish a guideline for asbestos in drinking water" (WHO, 2003) . The Canadian government . concluded the same in 1989- (Canada Health, 1989) .

Conclusions/Recommendations:

Conclusion . : - , - , - . . -

1. The air sampling data collected to date pro-Ajiides a confusing picture of the health implications of. asbestos contamination at the Borit site. Much of this data is confounded by collection technique, analytical methods, and collection locations where other asbestos sources may have been prevalent. The extent of large piles of asbestos contaminated material combined with air data that indicates under certain conditions local levels of air borne asbestos may be of concern suggest, that .further investigation and examination of the site is warranted. - '

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Recommendations . . . .'

1. Sampling a. A new air sampling plan that' addresses the limitations of_

previous'sampling needs to be implemented. This should include, at a minimum: proper sampling locations; analysis with proper detection limits and determination of mineralogy and fiber size -distribution; activity-based sampling where appropriate; and background sampling. ••

b. Because of past elevated surface water levels in the Wissahickon Creek, the potential exists for flood waters to have "dropped out" fibers onto soils adja'cbent to the creek. These soils would dry out routinely after waters recede and might present an air release threat. Consideration should be given to collecting both soil' and personal air samples'in selected areas that may'be used by local citizens fbr walking, hiking, fishing, etc.

2 . Community precautions While better' characterization of the site is being implemented through a sampling and testing program the following precautions should be-put in place: " -: "• • -a. Implement mitigation efforts to cover exposed•areas of the site

that can result in the migration of asbestos fibers into ambient air.

b. Continue access restrictions at the 'site until EPA completes its-mitigation work at the site. ' '

c. At least until mitigation efforts described in (a) are complete, and for a longer duration if all materials suspected of releasing fibers cannot be adequately covered, proceed with the current air sampling program to identify if and to"what extent, the undisturbed site releases asbestos fibers to the air. Conduct human activity-based air sampling onsite to determine how potential site uses might contribute to the release of fibers.

3. Data collection and evaluation a. Provide data from each round of air sampling to ATSDR and EPA

toxicologists for public health evaluation and risk assessment. Collect data ±'n a manner that is consistent with evaluating human health impacts of e'xposure. • ' .

4. Outreach to 'community and local professionals a-. In response to community concerns expressed at the October 2006

public meeting, continue to evaluate cancer health outcome data for Ambler to determine if elevated rates exist. Continue working with the community to answer questions and address ongoing concerns. •.•-'-• .,-'

b. Conduct a professional education workshop(s) with' local ' physicians and health professionals regarding asbestos exposure

and asbestos-related health effects. Inform local health

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professionals about.site activities, and community.,health, concerns. ., ' , .

Signatures

Jack,Kelly,,EPA/ATSDR 'R3 Detailee Date:

Lora Werner, ATSDR R3 Date:,

Tina Forrester, ATSDR DRO Director Date

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ATTACHMENT 1: Past Assessment Activities at Ambler Asbestos NPL Site and Town of Ambler (Focus on Air Sampling)

Except where noted when original source documents were available, the information below is obtained from the 198 8 Remedial , .•' • • Investigation/Feasibility Study (RI/FS) for the Ambler Asbestos NPL Site performed by CDM, Inc' for EPA. It is important to review the data with the knowledge that the Certaineed facility operated until 1974 and Nicolet continued manufacturing operations until at least 1987. In addition,- the varying types of sampling and analytical techniques utilized during this period, unavailability of specific sampling event quality control data, and the evolving improvements in fiber counting techniques over the years, makes interpretation of the results quite difficult. The reader is urged to. refer to the paper A Discuss ion of Asbes tos D e t e c t i b n Techniques f o r A i r and S o i l , August 2004, to gain an understanding of the complexities involved.

November 1971 and January 1972 - Due to citizen concern's': about air and water quality as a result of operations by the Nicolet and Certainteed companies, a "field survey of effluent, air and traffic at the site(s)" was conducted. Residents complained of "a white dust settling on furniture in their homes during windy days and the tracking of white dust into their homes from the soles ' of people's shoes'". Of eight residents interviewed along Locust and Chestnut Streets, two indicated that dust blo'wing was not a problem while the remainder noted dust settling on cars and entering homes via airborne emissions and tracking on shoes (Silvasi/Mineo, 1971). An undisclosed number and location of air' samples were collected and were reported as testing positive for asbestos. Dust emissions were observed during facility loading and transport operations. No other information was provided.

October 1973-- EPA conducted air sampling adjacent to and' near the pileis later to be known as the Ambler Asbestos NPL Site. Sampling occurred from October 22-24 with high volume air samplers for approximately twelve hours each day at ten individual locations around the Ambler Asbestos Site piles (no additional details on sampling methodology provided). Disposal of waste was occurring at the piles during the air sampling event. Based on the sample point locations and the wind directions during the three day period, it appears that the Borit Site would not be a discernible contributing source to any positive readings. Results were presented in nanograms per cubic meter (ng/m3) and ranged from 3.1 to 2600 ng/m3. Values were compared to results from, a 1971 study conducted in Philadelphia apparently designed to look at typical urban air levels.' Reported concentrations in the Philadelphia study ranged from 45 to 100'ng/m3.

•The highest results were found near the active waste disposal sites and at one offsite location between Main Street and the,SEPTA commuter train line (the range at this location was 49 to 500 ng/m3). It was suggested that this area may have contained a small satellite asbestos pile based on a

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1971 aerial photograph (the•area.currently seems to be used for parking at an industrial or-commercial facility)-.

November 1976 - the PADEP (then PADER) - conducted an ambient, air asbestos sampling study in Ambler from November 1 to- 19, 1976(PADER, 1976). The , study focused on the Ambler Asbestos NPL Site but two to three sample locations were located.between the Ambler Asbestos NPL Site and the Borit Site. Both the Nicolet and Certainteed companies were in operation at the time. A total of 123 samples from thirteen sampling locations were collected over the nineteen day period (samples were not analyzed for each sample location on every day). Seventy-five of the filters were analyzed. Most samples were- collected onto 8-micron pore size .Millipore membrane filters over a 6 hour duration. Analyses were, performed by both Phase Contrast Microscopy (PCM) and Transmission Electron Microscopy (TEM). on all sample filters. Of-all 75 samples analyzed over the nineteen days,.the PCM analyzed samples ranged from 0.0005 fibers/cc to 0.06,6 fibers/cc; for the TEM analyzed filters, only four revealed the presence of/asbestos fibers (chrysotile). The four . detections ranged from 0.01.7 to 0.085 fibers/cc and were recorded adjacent to the Ambler Asbestos piles or-the active plant operations. TEM detection limits ranged from O.OOip to 0.0032 fibers/cc. The.study concluded that fugitive asbestos emissions from the exposed surface of the- inactive refuse pile(s) were "insignificant and infrequent."

July 1977 - PADER conducted a follow up sampling event to the November 1976 study because "the surface layer of .the inactive'pile-(s) (Ambler Asbestos NPL Site piles) remained in a semi-frozen, moist condition throughout most of the sampling period, thereby reducing the asbestos emissions" (PADER, 1977) . This sampling survey was conducted,at five nionitoring sites at.the. immediate base of the Ambler Asbestos NPL Site along fiocust Street over a three day period from July 20 to 22 (resulting in little opportunity for • determining if Borit Site emissions might contribute to filter detections);. Conditions were described as hot . (up to' 100 degrees F) , windy (velocities ranged from 6 to. 18 mph) and dry (a 0.12 rainfall event did occur on July 20) . A total of twelve samples were collected over - an approximate six hour period using the November 1976 event methodologies. Eight samples were sent off for analyses by both PCM and TEM. PCM results ranged between. 0.0035 to 0.0093 fibers/cc. For the TEM analyzed samples, asbestos was found in four of the eight samples ranging.from 0.048 to 0.18 fibers/cc. All .four positive samples contained chrysotile, one contained both chrysotile and amphibole. The sample with the highest value (0.18 fibers/cc) was collected during the windiest conditions.

I' . . ,

June-December 1983 - EPA's FIT contractor collected air,.water, surface dust and soil samples at the.Ambler Asbestos NPL Site in response to an EPA HQ Directive to assess asbestos. sites nationwide...Although the sampling- -r efforts focused on the Ambler Asbestos NPL Site piles, it appears .that , two solid samples were collected at or near the Borit Site (values were 3-4 per cent and 35 per cent chrysotile asbestos) . In June 198.3, two air samples were collected adjacent to the Locust Street Pile and- one near the operating Nicolet plant; in December 1983, one air sample was collected at

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Butler Pike and Locust Street, one at the Locust Street playground and one' at the end of Church Street near the Wissahickon Creek. The June samples .were analyzed by PCM and the December samples by SEM with confirming identification by energy dispersive X-ray microanalyses. June samples ranged from non detect (detection limit not specified) to 0.02 chrysotile-fibers/cc; December 1983 sample'results were below the detection -limit of 0.01 fibers/cc. Soil and surface dust'results led to closure of the playground adjacent' t c the Locust Street Pile and initiation of an •' immediate'removal action by EPA. ' ' .

April 1984 - EPA collected'additional air samples as part of the immediate removal action. Air samples focused on the Ambler Asbestos Site but a few locations were located between the Borit Site and the Ambler Asbestos Site. From'two to five samples were-collected each day over a course of five consecutive days;! On April 9-11, samples were analyzed by SEM; on-April 12 and 13, samples were analyzed by Transmission Electro'n Microscopy (TEM) . On all five days, the wind direction was ge'nerally from the Borit Site heading in the direction of the Ambler Asbestos' Site. For the one sample station. (Location 04 at Chestnut and Wissahickon Avenue) located between the sites-, on the first three days air results ranged from non-deteet to 0.001 total asbestos fibers/cc (chrysotile) by SEM analyses. On day four, the location was not sampled; on day five, the total asbestos fiber concentration was 0.12 fibers/cc (chrysotile) by TEM analysis. This sample station was reported to be located in the Ambler community near an automobile service station believed to be performing brake servicing. .

September 1984 - EPA, with- the support of the Centers for Disease Control (CDC) and the National Institute of'Occupational Safety and Health (NIOSH) collected dust vacuum samples from homes adjacent to the:Ambler Asbestos NPL Site and "background" homes in the Ambler community. A total of 135 samples were collected from four.adjacent-homes and five homes "within 2400 to'4500 feet of the site". All of the background homes appear to have been located northeast of the Site. One hundred samples were analyzed by PCM and 20 of these samples were additiona-lly analyzedby TEM. Although some data quality issues were identified, re-analysis efforts on a number of samples were sufficient to lead to the conclusion that results did not show asbestos present in the adjacent homes at levels that could be differentiated from the background home levels. There is no documentation indicating that corrective action was needed in any,home.

October 1986 - A limited air sampling investigation was conducted on October 2, 1986 near the Locust Street Pile of the Ambler-Asbestos Site prior to commencement of the-RI/FS. Three.samples were•collected .with 0.8 mm mixed cellulose filters (backed by a 6 m!icron pad and backing-, pad) for an approximate four hour duration. Sample locations likely were upwind of-the Borit Site and no asbestos fibers were detected using TEM confirmed by Selected Area Electron Diffraction - (SAED) and.Energy-Dispersive X-ray Spectra (EDS). Detection limits were not specified;

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December 1986 - As part of the RI/FS for the Ambler Asbestos NPL Site, an , initial air sampling investigation was conducted on December 29, 1986. Four air samples were collected using 25 mm mixed cellulose filters in .cassettes over a course of four hours. Analyses were performed by TEM (Yamate Method)' with SAED and EDS confirmation. The sample location points were generally not in areas relevant to assessing potential .emissions,from the Borit Site. Results ranged from 0.01 to 0.09 fibers/cc. Of interest, one off-site, sampling location near the Wissahickon .Creek approximately 250 feet east, of Butler Pike and Morris Road, recorded the highest concentration •( 0.20 f/cc). The location appears to have been upwind of the Ambler Asbestos NPL Site on the sampling day (although" the RI/FS report narrative indicates otherwise). The.report mentions the occurrence of heavy traffic on Butler Pike as a potential confounder.

January 1987 - during,the RI/FS, three- rounds of "Source and Receptor Air Sampling" were conducted. .The first,round occurred on January 9, 1987. The day was described as overcast, winds at 5 mph, with a moist partially frozen ground cover. Six sample locations were placed on the Ambler Asbestos Site piles and ten samples.were located off-site in the Nicolet plant area and the neighborhood downwind of the piles (along-Chestnut Street, Locust Street, and Main Street). Two stations, were located on Maple Street across from the current Borit Site and one background station was placed west of the Wissahickon,Creek and Borit Site at the corner of Mercer Hill Road and Betsy- Lane. Samples were collected on 25 mm mixed cellulose filters in cassettes and ran for four hours. Samples were analyzed by TEM with SAED confirmation using the Yamate Method. Due to heavy filter loading with debris,' the filters had to be ashed and then analyzed (indirect, analysis) . The debris was la.ter found to be-.gypsum fibers that were not eliminated.by the ashing procedure.

Five of the six sample on site, results ranged from 0.01 to 0.08 fibers/cc (chrysotile). The highest was 0.17 fibers/cc-collected near the site filter bed lagoons. The downwind o.ff site samples recorded the highest readings. The two stations- on Maple Street adjacent to the current reservoir and Borit Asbestos Pile contained 1.95 fibers/cc (duplicate 1.61 fibers/cc) and 0.33 fibers/cc. Three of the four stations along Main Street contained 0.32 fibers/cc (Main and Butler Pike), 0.25 fibers/cc (Main and Orange) and 0.20 fibers/cc (Main and, Bannockburn). The upwind station at Mercer Hill Road and Betsy Lane had a result of 0.5 fibers/cc.• The•two plant-situated stations revealed 0;08 and 0.01 fibers/cc. Several possible explanations were put forth for these results. On site samples may have.been low because the'ground,-, was moist and partially frozen. Main Street samples may have been high as a result of vehicular traffic, downwind location from the Nicolet Plant and filter beds and "potential off-site sources", (no clarification or further explanation provided). No reason was given for the elevated reading•at the upwind location.

|- - - •

April 1987 (Activity Based Sampling) - On April 14, 1987, four sampling locations were set up to collect samples downwind of the Ambler Asbestos

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NPL Site during borehole .drilling and test pit operations. Three samples were located downwind'on or directly adjacent'to the piles where the ' drilling occurred. One was located upwind but on the pile. The day was described as being sunny with light' winds (4 mph)- with an average-temperature of 66 degrees F.-Air samples were analyzed by TEM with SAED confirmation' using the Yamate Method.- The filters again had to be ashed ' and analyzed indirectly due to heavy particulate- 'loading (identified for the second time as gypsum fibers). Sample results ranged from less than 0.01 total asbestos fibers/cc to 0.08 fibers/cc. 'One amosite fiber was identified by the'microscopist on the filter. The report specifically notes that amosite fibers are generally less likely to become airborne due to their large size and less'friable characteristics (amosite'was found in the test pit,' however). Detected asbestos concentrations downwind of the boring activity were less than those detected earlier in the same areas when no onsite activity was occurring. This led to a preliminary conclusion that intrusive activities' did not increase' ambient air concentrations likely.due to the high moisture content of the pile contents.

April 1987 - A second round of air sampling for- the RI/FS was conducted on April 21, 198 7 . The day was described as sunny, a temperature of 66 degrees F, winds at"6 mph and the'ground moist with leaves just beginning to appear on vegetation. Six onsite and thirteen offsite sampling locations were utilized.' Offsite ..sample locations were downwind of- the Ambler Asbestos Site piles in the immediate-Ambler neighborhood.• Four upwind samples also were collected, two of which were located adjacent to the reservoir and Wissahickon Park of the Borit Site-; Samples were-collected for approximately four hours on 25 millimeter polycarbonate sample filters in cassettes (as opposed to mixed - cellulose filters in the January 1987 sampling). Samples were analyzed by TEM with SAED confirmation using the Yamate Method. Ashing of the sample filters was not needed as debris -• loading was described as light to moderate'. However, four samples were found to be.damaged and' had to be discarded and the data results -were qualified due to filter blank contamination in the two field and trip blanks (later- research determined, that polycarbonate filters have a higher frequency of contamination during manufacturing than.do mixed cellulose filters)'.

Although the sampling effort suffered from data quality complic'ations, all results appear to have been relatively low, ranging between non-deteet to 0.06 fibers/cc if one subtracts out the total concentration detected in the "sample from the' highest concentration"detected in the' blank. This includes.-samples collected near the operating Nicolet plant, those on and directly adjacent to the Ambler Asbestos' Site piles and the four upwind samples. However, the RI/FS report narrative indicates that three of the sample results located at the Nicolet plant likely eqiaaled 0.39, 0.24 and 1.39 y fibers/cc if one converts mass/volume concentrations '(nanogram/m3) to fibers/cc. This author cannot explain the disconnect between the RI/FS tabulated data for this round of sampling and the accompanying narrative discussion'.

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c March - May 1987 (Personnel Air Sampling Results): Samples were collected for PCM analyses , from on site personnel during waste pile boring activities. Seventeen samples were collected on various days during March, April and May'of 1987. OSHA procedures were followed. Results ranged from non-deteet to 0.01 fibers/cc. Detection limits appear to have been as low as approximately 0.0004 fibers/cc. The low values were attributecl to the high moisture content of the site pile materials.

August 21, 1987 - A third round of air sampling for the RI/FS occurred on August-21, 1987. The day was partly sunny, winds at 5 mph and a temperature of 84 degrees F. Conditions were, very dry but extensive vegetative growth was in place around the site piles. Four onsite .and eleven off site sampling locations were utilized. The following offsite locations were utilized: Butler Pike .and Maple Street .(downwind), Butler Pike and Main Street (downwind), Main Street and Poplar Avenue (downwind) and Main Street and Orange Street downwind). These locations were also located.downwind of the Borit Site. Four of the offsite locations were located upwind of both the Ambler Asbestos and Borit Sites. .Samples were collecte.d for roughly four hours on polycarbonate filters and analyzed by TEM with SAED and EDXS confirmation. Apparently as' ,a result of problems experienced during the April 1987 sampling, special analytical and technical procedures were instituted to ensure • a robus.t data validation process. The data validation reviewer did not qualify any of the data and concluded that it was appropriate for use even for litigation purposes.

Of all fifteen samples collected and analyze'd, only one exceeded the detection limit of 0.01 fibers/cc. This value was 0'. 02 fibers/cc collected from the exposed plateau of one of the Ambler.Asbestos Site piles.

July — November-1992 - Construction and remediation activities at the Ambler Asbestos NPL Site occurred during-this time frame. Air sampling for asbestos fibers was.conducted during the period- of construction when the piles were exposed [ 1 9 9 3 , EPA) . The number, type and location of the samples were not provided. Samples were analyzed by TEM. All results were reported as 0.05 fiber/cc.or "no unacceptable-levels'of airborne asbestos were observed".

Summer 2001 (exact date uncertain) -..a local consulting firm performed a Phase II environmental assessment of the Borit asbestos pile portion of the Borit Site ( G i l m o r e and A s s o c i a t e s , 2001) . The Phase II report states that a sample was collected following NIOSH guidelines and analyzed by.TEM. No additional information is provided on the location of the air sample and specific sampling methodology. The report indicates that the result was "non-deteet for asbestos fibers". .. \ . :

May 2004 - A local consulting- firm conducted a Phase I environmental assessment of the reservoir property at the Borit Site [ O ' B r i e n & G e r e , 2 0 0 6 ) . Two air samples were collected downwind of the reservoir on the west

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side. Samples were collected''for approximately two and: a half, hours and-were analyzed by PCM. Reported results were "approximately 0.004 fibers/cc".' No additional information was available-.

April 2006 - In April' 2006, as part of a' Site Assessment' (SA) under the' Superfund Program, EPA's START contractor•collected six air samples at-or adjacent to the Borit Site by TEM method EPA 540/2-90-005A. Samples were collected with Dawson air collection pumps over 24 hours using mixed cellulose ester filters.- Based on the day's prevailing wind direction, five of the six samples could arguably be described as downwind (one of' the five was on top of the Borit tailings portion of the site); one upwind sample was collected. Air collection volumes ranged-between 12,000 and 12,600 liters of air per sample. All samples contained detectable asbestos fiber concentrations with values ranging from 0.00061 fibers/cc to 0.039 fibers/cc. Four samples were analyzed by the indirect transfer analytical method and two by the direct transfer method. The two directly analyzed samples recorded'the lowest asbestos concentrations regardless of location (one was located directly downwind of the Borit tailings pile and the other was stationed directly 'on'top of the pile) (TetraTech, 2006).

Past Assessment Activities at Borit Site (Soil, Sediment, Surface Water):

Asbestos Pile Portion

In December 1983, the Pennsylvania Department of Environmental Resources (PADER, now PADEP) and EPA's Field Investigation Team (FIT) 3, collected a sample from the asbestos pile portion of the Borit site and found that it contained 3-4 per cent chrysotile asbestos. The reason for the,sampling could not be determined from available file information. In May 1984, PADEP 'collected a sample which also revealed a^positive result for - asbestos. In August 1984, the PADEP issued a notice of violation to Nicolet, Inc., the site owner, because no warnings signs were, posted on the property. In response to these findings, Nicolet constructed a,fence along the eastern portion of the property to control access. Observations recorded in the Summer of 1984 indicate that the site was "entirely covered with vegetation" but "a white, outcropping approximatel.y 7', by 5'" was observed during the Spring. (Memo,- JPike, to CWalters, 1984) .

In October 1987, the FIT 3 team'conducted a Site Inspection (SI) of the asbestos pile. Seven soil samples were collected from the asbestos pile and surrounding area, three aqueous samples were collected from the intermittent tributary (currently known as Tannery Run) along the southern border of the site, and two aqueous samples were collected from Wissahickon Creek. . The soil samples contained up to 22 percent total asbestos. The aqueous samples collected from the tributary and Wissahickon Creek were "•: reported as non-deteet to 2.5 million fibers per liter (MFL). These .values were described as insignificant (NUS 1988). .

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Observations made during the SI indicated that people were gaining access to the asbestos pile for unauthorized disposal of household wastes. In addition, although the asbestos pile was described as "95 to 99 percent covered with heavy vegetation",, three small areas were devoid of vegetation and six abandoned vehicles were located on site. Runoff was noted i entering Tannery Run from the southwest, portion of the- pile. The pil'e measured approximately 2.0 acres and was 20 to 30 feet high. '. Four empty , 55-gallon drums were located in the reservoir north of the pile, and. \ asbestos shingles were observed .on the ground throughout the property (NUS 1988),.. • ,- .,,-. . , • ' . , - ,

Summer 2001 (exact date uncertain) - a local consulting firm performed, a Phase I and II Environmental Assessment (EA) of the Borit asbestos pile portion,of the Borit Site {Gi lmore and A s s o c i a t e s , 2 0 0 1 ) . Although the vast majority of the property was heavily vegeta.ted, photographs taken during the Phase I assessment reveal, ACM exposed by burrowing animals, waste asbestos shingles on the surface of the western end of the property, and ACM at the surface at the southern end especially along Tannery Run. Eleven test pits were excavated during-the Phase ILEA, six of which were ,. located between the waste pile and the fence along Maple Street. Lenses of ACM waste were, present in these excavated areas. Samples collected from seven of the test pits revealed asbestos percentages ranging from less than 1 per cent to 35 per cent. The volume of the pile was estimated at 149,500 cubic yards. . , ' ,,

April 2006 - During the 2006 Site Assessment, EPA collected two soil samples and two waste samples for asbestos analyses from or directly adjacent to the Borit asbestos pile. All samples were analyzed by the TEM Modified Elutriator Method and results were reported, in structures of asbestos per gram of soil (in contrast to percent asbestos content). All sample results were positive for chrysotile asbestos and two samples were positive for amphibole asbestos. 'Values ranged from 2E+06 to 4E+09 structures/gram; two background samples collected from Montgomery Count-y . "Open Space" grounds just west of the Wissahickon Creek were negative for asbestos (TetraTech, 2006) . . . . , - -

Reservoir

In June 2004, a Phase I Environmental Assessment (EA) was conducted by.a local consulting firm for the WVWA at" the 15-acre water reservoir area (O'Brien & Gere, 2004). The EA identified non-friable ACM along the banks of the water reservoir, which were constructed of asbestos shingles, millboard, and soil. ACM was also observed within the reservoir. Cement-asbestos, pipe sections and ACM were scattered around the reservoir, along Rose Valley Creek, and along and in' Wissahickon Creek. ACM., observed near the reservoir' was described astransite, a mixture of cement and asbestos. The transite, generally considered non-friable, was beginning to degrade

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and become friable at the weathered ends of the material (O'Brien & Gere 2004) .

The Phase I EA included the collection of three- reservoir water and '•• sediment samples, waste samples from the banks of the reservoir,"and soil .samples'. The reservoir water and sediment samples were analyzed for metals, volatile organic compounds, and semivolatile compounds. ' The samples were not analyzed for asbestos. The EA -concluded that the surface water and sediment concentrations were 'either below screening values or representative of that found in urban areas. 'Gray-white soil or- soil-like material in 5- to 10-square-foot patches was observed on the east side of the reservoir. One sample of this material was' collected and found to ' contain 30 percent chrysotile asbestos. This same material was observed below the- vegetation around the reservoir. - Three samples of this transite' material were collected and contained 20 to 2'5 per'cbeht' chrysotile asbestos.

In March 2005, a Phase, II EA was conducted to collect additional samples for analyses (2006) . Three surface soil- samples'were collected from beneath a pole-mounted transformer - located heair the southernmost corner-of the water reservoir and analyzed for polychlorinated biphenyls (PCB). No PCBs were detected. Three surface soil samples were'collected from near a discarded metal storage tank and analyzed for polycyclic 'aromatic hydrocarbons (PAH). Numerous PAHs were detected in the single digit milligrams per kilogram [mg/kg] ) range-; Three- sed-iment-samples were collected from the bottom of the water reservoir near suspected ACM and analyzed for asbestos, and one sediment sample was collected from the outflow of the reservoir for asbestos analysis. Asbestos was not detected in the sediment samples using the TEM Modified Elutriator Method.

During EPA's April 2006 Site"Assessment, a surface water sample was collected from the northeast and southwest sides of the reservoir. 'The southwest sample location was found to have" 110 million fibers/liter of chrysotile asbestos; the northwest sample was non detect fbr asbestos-.

Park

EPA's FIT 3 collected four soil samples from the park'in December 1983. Samples revealed chrysotile asbestos ranging from 5 to 35 per cent chrysotile asbestos using PLM analyses. One of the five samples also revealed crocidolite asbestos (amount not specified). In October 1984, EPA collected twenty-four surface soil samples from the park and three adjacent to the park. Based on PLM/DS analyses, five of the park samples contained, approximately 1 per cent chrysotile•asbestos .and one contained "less than 1 per cent". ' One of the three offsite'samples contained 1 per cent asbestos. No asbestos fibers were observed in the other twenty samples (Memo, SIG Chief to CWalters, 1985) . • ' . ' , •

In December 1984, EPA collected seven onsite vacuum samples from the park surface. No fibers were found using PCM analyses. In addition, soil core, surface soil and vacuum samples were collected, from seven nearby yards or

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roads adjacent to nearby yards and, for comparison, from two locations in Fort Washington State Park. Four core samples (two from residential yards and two in the State Park) were analyzed by PLM and did .not reveal asbestos fibers. Ten surface soil composite samples (eight from residential properties and two from the State Park) also were analyzed by PLM and all were found to be negative for asbestos fibers. Eighteen vacuum samples were collected, fourteen from residential properties and four from the State Park. Thirteen of the residential samples,were•analyzed by ;PCM and one by TEM. Two of the background samples were analyzed by PCM and two by TEM (Memo, BMoran to JPike, 1985). Despite some difficulty interpreting results from the two types of analyses employed, public health officials concluded that the asbestos levels present in the yards could not be differentiated from background area locations and extensive migration.of asbestos fibers' from the park was not evident. . . .

In July 1996, EPA and PADEP collected'ninety-three or more subsurface (down to 14 inches below grade) and surface samples from the park. Results revealed asbestos in all but six samples (using PLM and TEM analyses). Amosite asbestos was detected in six samples and chrysotile in eighty-six samples. Values ranged from "trace" to 15 per cent with most in the 1 to 3 per cent range. Generally, the higher percentage values were found at depth (Misc. data tables and map, .1996).

In April,.2006, Tetra Tech collected two surface soil and one waste sample from the park for asbestos analyses using the Modified Elutriator Method. All three samples revealed chrysotile asbestos'with values ranging from 6E-f06 to 6.4E-f08 structures/gram (TetraTech, 2006).

Surface Waters

Sampling of the Wissahickon Creek has.occurred since the early to mid 1970s when Certainteed and Nicolet were actively discharging wastewater. Two comprehensive EPA sampling events in 1978 and 1979 generally indicated that asbestos concentrations were at or near detection limits using TEM and SEM analyses (0.08 to 0.16 million fibers/liter (MFL)) except at outfall points. Outfall point values ranged from non-deteet up to 1060 MFL. Samples were collected from just upstream of Whitpain Park at the Mount Pleasant Avenue bridge down to the City of Philadelphia's Belmont water intake on the Schuylkill river below its confluence with the Wissahickon (EMV Associates, 1978 and JRB Associates, 1980).

In June 1983, EPA's FIT contractor collected two water samples from the Wissahickon Creek for TEM analyses. One sample was located at the Butler Pike bridge over the Wissahickon and the other at an undisclosed distance downstream from Church Street. The bridge sample revealed 39 MFL total asbestos fibers (18 MFL chrysotile) and the downstream sample 310 MFL total asbestos fibers (260 MFL chrysotile) (CDM, 1988).

In October 1986, EPA's FIT contractor collected three surface water samples from the Wissahickon Creek. Sample points were at the Butler Pike bridge.

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approximately 300 feet below the bridge and just below Church Street- in Ambler. Samples were analyzed, by TEM 'and all were found to be negative for asbestos fibers (CDM, 1988). '

During the Ambler Asbestos NPL Site RI/FS, three surface water sampleis were collected in March 1987 from the Wissahickon Creek and analyzed by TEM. Following are the locations and results: approximately 250 feet downgradient of the Butler Pike bridge (52 MFL chrysotile fibers), about 800 feet downstream of the above location (450 MFL chrysotile) and across-' from Church Street (199 "MFL chrysotile)'. The three sediment samples collected from the Wissahickon adjacent to the surface water sampling points were non-deteet for asbestos fibers. In addition to Wissahickon Creek samples, one Water sample was collected from Tannery Run and-one from Rose Valley Creek which run through the Borit site. Sample results were 8700 MFL and 4500 MFL chrysotile fibers, respectively. Sediment samples for asbestos at these locations were the highest found for sediments during the RI (5 pe'fcent and 40 percent, chrysotile, respectively) .

During the Site Assessment in April 2006, two surface water samples were ' collected from the Wissahickon Creek and one from the reservoir within the Borit site. The surface water sample' points were located at the'Mount Pleasant Avenue bridge upstream of the site, approximately 100 feet downstream of Tannery Run below the site and at the southernmost point of the onsite reservoir. Samples were analyzed by TEM. The Wissahickon Creek samples were non-deteet for asbestos fibers. The reservoir sample was reported to be 110 MFL chrysotile. Asbestos fibers were also defected via the Modified Elutriator Method in both the upstream and downstream sediment samples collected from Wissahickon Creek. The upstream sample result was 2.9E+06 chrysotile ' structures/gram and the downstream result was 8.9E+06 structures/gram. A sediment sample was not collected from the .reservoir. - -

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ATTACHMENT 2: History of Public Health Agency Involvement

The Pennsylvania Department of Health (PADOH) and CDC/ATSDR have provided health opinions and/or health outcome data reviews at various times for the Ambler Asbestos NPL and Borit sites,. including a Public Health Advisory focusing on the Ambler Asbestos NPL Site area in 1983. The following provides a historical summary of these efforts.-

In August 1975, the PADOH completed a report entitled "Possible Health Hazards of Asbestos Waste Pile:. Ambler, Pennsylvania" (G Tokuhata et al, 1975). This study analyzed mortality rates for the years 1968 to 1973,' comparing- rates for Ambler and five surrounding.townships with the State of Pennsylvania as a whole. The study evaluated death rates for fifteen different causes of death including diseases of the respiratory system (mesothelioma, a rare cancer associa.ted with asbestos exposure, could not be specifically singled out due to the small population of Ambler). Except for one cause of death where the rate in Ambler was statistically lower than the State as a whole, the report concludes that there were no significant differences in mortality rates between Ambler and Pennsylvania. The report acknowledged that-morbidity.data would have presented a more complete evaluation of conditions but, concluded that the mortality findings clearly did not indicate a need for such a costly and time-consuming endeavor. .,.-.- . : . .,

In a November 21, 1983 memorandum, CDC evaluated EPA environmental sampling information for what was referred to as two Nicolet Asbestos tailings sites in Ambler, PA (later to become the Ambler Asbestos NPL Site). Based on this review, CDC issued a Public Health Advisory for theses-sites. CDC concluded that the. Nicolet asbestos tailings sites constituted a hazard to the community. Large, uncontained quantities of, asbestos were present adjacent to residential areas, and were susceptible to dispersion by wind and water. Offsite migration was confirmed by sampling, performed at the Locust Street playground. CDC recommended that: (1) due to the close proximity of residential areas to the sites, offsite migration of asbestos fibers must be eliminated to prevent continued exposure; (2) residents should avoid contact with all asbestos contamination, particularly during the cleanup action, and wipe or vacuum samples should be collected and analyzed before and after cleanup in the adjacent homes with' appropriate follow-up based on the results; and (3) the Locust Street playground should be closed and access to this contaminated area prevented until it is

- > • - •

cleaned up. . . . .

In a March 16, 1984 memorandum, CDC noted that playground equipment being removed from- the Locust Street playgro.und could be relocated to a new site if the equipment was first decontaminated with .water and mechanical 'washing.

In a June 11, 1984 memorandum, CDC reviewed the April 9-13, 1984 ambient air sampling-results provided by the EPA during, emergency cleanup actions at the .Nicolet Asbestos piles. CDC concluded that the results obtained

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indicated that the work'practices at the site were sufficient to prevent off-site migration of asbestos on the days tested, and that monitoring should continue. CDC recommended that one of the sample locations should be replaced to 'a site more representative of the Ambler community. Further, CDC recommended that homes near the site as well as'control homes should still be sampled (preferably in' the next 4-6 months) using the EPA ERT settled dust method, and that the sampling-should be performed after containment of the exposed asbestos on the pile.

In an October 29, 1984 memorandum, ,CDC reviewed two asbestos samples collected by the EPA from Wissahickon Park. CDC recommended that (1) every effort should be made to prevent human exposure to the asbestos identified on site, and that it was particularly desirable to prevent the possible re-suspension of the'fibers as a result of play activities at the park; (2) a series of samples for asbestos should be collected'from the yards abutting the site; and (3) consideration should be given to providing temporary covering for the obvious asbestos outcroppings observed at the site.

In a November 8, 1984 memorandum, CDC reviewed information for the Borit tailings pile and the Wissahickon Park/Whitpa'in- Township Park. CDC concluded that the presence of exposed friable asbestos-containing material to be an unnecessary public health risk and a potential chronic public health hazard to persons near the site. The memo notes that the suspens'ion of asbestos fibers would be partially restricted by vegetative ground cover but complete prevention could not be expected. CDC recommended (1) further documentation of onsite and offsite asbestos contamination (including -soil samples from the yards'adjacent to the' sites, and wipe samples from the' interior of the nearby homes); (2) restriction of publ'ic access to the sites, including posting of warning signs; (3) elimination'of offsite migration of asbestos fibers to prevent human exposure to airborne or waterborne asbestos fibers, including possibly following the creeks to determine the fate of waterborne fibers; and (4) coordination with State or county health departments to advise the community of the situation so that private physicians can provide informed guidance and care to their patients who may have been exposed to asbestos as a result of entering or residing near the site. ' ' '

In a January 18, 1985 Memorandum, CDC' reviewed bulk soil sampling results from the Wissahickon/Whitpain Township Park taken' after the park was closed to the public. CDC stated that any sampling strategy also needed to include soil samples from adjacent residential yards, and that the site required sufficient containment of asbestos materials to prevent resuspension of fibers and to prevent offsite migration. CDC recommended that a' plan be.developed and implemented to ensure'against further disturbance of the ground cover at this site.

In February 28 and April 23, 1985 memoranda, CDC responded to EPA's request to review environmental sampling data for residential yards neighboring Wissahickon' Park, as well as some additional' onsite environmental sampling data from the park. CDC concluded that (1) the results of the onsi£e

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sampling generally, indicated that there were.no exposed fibers on the surface of the- soil in the areas.sampled; (2) the TEM residential vacuum sampling, results did not appear to show asbestos present in the yards of homes adjacent to Wissahickon Park in quantities tha-t could be differentiated from the background areas sampled (inferring that extensive migration of asbestos fibers had not occurred- from Wissahickon Park to the adjacent residential areas); and (3) the core residential soil samples and composite surface soil s.amples also did not appear to show asbestos present in the yards of adjacent houses in quantities that could be differentiated, from background areas sampled. Background samples were collected from Fort Washington State Park in nearby Fort • Was.hington, PA... . . . .

In a May 2, 1985 memorandum, CDC reviewed the September 18-19, 1984 residential sampling in homes adjacent to the Locust Street Asbestos Pile (See the Air Sampling Section of this document) .- .CDC cooperated with EPA,. ERT, and NIOSH to develop the residential sampling protocol. CDC concluded that the results did not show the presence of asbestos inside the homes adjacent to the Locust Street asbestos pile in quantities that could be differentiated fr.om the background homes . sampled. ,

A June 26, 1985 CDC memo reiterated the need to sufficiently contain waste materials at Wissahickon Park before reopening of the park could be reconsidered. CDC recommended that the. fence be maintained and that the area remain closed to the public until adequate, containment could be achieved.

On October 31, 1988, ATSDR published a; Public Health Assessment,for the Ambler Asbestos Piles NPL site in Ambler, PA (ATSDR, 1988). ATSDR concluded that the site.was a potential public -health concern, based on the fact that human exposure to asbestos may be ocicurring and may have occurred in the past via inhalation and ingestion. ATSDR recommended the following: 1) the soil and grass caps of the. piles.should be maintained and protected-.against erosion, and measures should be implemented to prevent "the release of asbestos fibers from the settling basins, filter bed lagoons, or waste piles to surface water runoff or ambient air (EPA commenced a removal action in March 1989 addressing several of these recommendations); (2) consideration should be given to determining whether the single groundwater sample taken from one residential well is representative of the local groundwater quality; and (3) raw and finished Water samples from the water treatment plan located downstream of the site should be tested-for asbestos fibers. Although ATSDR concluded that there was indication that human exposure to on-site/off-site contaminants may have occurred, the site was not considered for follow-up health studies at that time because no test was deemed available to evaluate past exposure to asbestos. Additionally, it was not clear at that time whether a pathway of exposure was still present.

On September 13, 1989, ATSDR published an Addendum to the 1988 Public Health Assessment to address an EPA request for ATSDR to evaluate additional environmental sampling results from March through August 1989

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(ATSDR, 1989). ATSDR concluded that the site remained of public health concern because of the risk of asbestos fiber release from the-two piles. Without recent ambient and indoor air sampling, ATSDR concluded that- past or present community e'xposure to asbestos at this site could not be determined. ATSDR further concluded that past removal actions at the site did not eliminate the potential for asbestos release, because a large portion of the piles remained uncovered. ATSDR recommended that (1) remedial action should begin at the Locust Street and Plant piles at the earliest opportunity; (2) during remedial activities,'steps should be taken to prevent the release of fugitive asbestos fibers into the ambient air; . and (3) ambient air monitoring should be performed to assess the potential impact on human health.

On'August 27', 1993, following completion of-the Superfund remedial action by EPA, ATSDR's cooperative agreement partners at PADOH prepared a Site. Review and Update report for the Ambler Asbestos NPL site. ATSDR/PADOH concluded that exposure'to asbestos ' fibe'rs at levels of public health concern may have occurred in the past via inhalation of contaminated ambient air (ATSDR, 1993). ATSDR/PADOH further concluded that exposure to site-related contaminants through ambient air was eliminated or reduced by the site remediation activities' conducted by EPA- to date. ATSDR/PADOH recommended that long-term inspection of the site occur to ensure that' the integrity of the cover is maintained. - '

In June 1995, in response to citizen concerns, the PADOH began to evaluate cancer incidence rates for zip code 19002- for the years 1996 through 2002 and, more specifically, mesothelioma rates for the years 1985 to 2002 in an effort to determine if rates were elevated in comparison to expected rates. Preliminary numbers do'not suggest unusual'elevations but the PADOH continues to refine its work to take -into account the small population at issue, limited State-wide mesothelioma rates and zip code data complications.- --• - - - - .

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REFERENCES

ATSDR, 1988. H e a l t h A s s e s s m e n t f o r Ambler A s b e s t o s P i l e s NPL S i t e , . O c t o b e r 31, 1988.

ATSDR, 1989. Addendum t o H e a l t h A s s e s s m e n t f o r Ambler . A s b e s t o s NPL S i t e , September 13, 1989.

ATSDR/PADOH, 1993. Site Review a n d U p d a t e : Ambler A s b e s t o s P i l e s , August 27, 1993.

ATSDR, 2001. T o x i c o l o g i c a l P r o f i l e f o r A s b e s t o s ( U p d a t e ) , September 2001.

CDM, 1988. F i n a l R e m e d i a l I n v e s t i g a t i o n / F e a s i b i l i t y S t u d y R e p o r t f o r Ambler A s b e s t o s P i l e s (Volume 1 ) , CDM Federal Programs Corporation, Ambler, PA, August 1988. Contract No. 68-01-6939.

EPA Aerial Photo Collection for Borit Site and surroundings, 1937 through 1985.

Gilmore & Associates, 2001. P h a s e I E n v i r o n m e n t a l S i t e A s s e s s m e n t , 6 Maple S t r e e t , Ambler, PA, August 7, 2001

Gilmore & Associates, 2001. 6 Maple S t r e e t P h a s e I I S i t e C h a r a c t e r i z a t i o n B o / R i t S i t e , November 2001.

Health Canada, 1989. Water Q u a l i t y G u i d e l i n e f o r A s b e s t o s (in Health Canada's Environmental & Workplace Health website www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/doc)

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Memorandum, JPike, EPA to CWalters, CDC Liaison, July 27, 1984. Subject: Soil Sample Locations at Whitpain Township Park. 0

Memorandum, SIG Chief, CDC PHS to CWalters, Public Health Advisor, February 5, 1985. Subject: Twenty-Seven Soil Samples Results for Whitpain Township Park.

Miscellaneous Data Table and Map for "Wissahickon- Park Sampling Project", July 1 and 2, 1996 (no additional descriptive information available).

NUS, 1988. S i t e I n s p e c t i o n R e p o r t f o r B o r i t A s b e s t o s T a i l i n g s P i l e , NUS Corporation, September 2, 1988. -

O'Brien & Gere, 2006. January 13, 2006 Letter Report: Da ta Summary R e p o r t f o r P h a s e I I S a m p l i n g A c t i v i t i e s .

O ' B r i e n & G e r e , 2 0 0 4 . P h a s e I E n v i r o n m e n t a l S i t e A s s e s s m e n t / L i m i t e d

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Sampling, 15 Acre Reservoir Property, Upper Dublin and Whitpain Townships, PA, July 2004. ^ • • ' • . • :

PADER, 1976. The Results of an Ambient Air Asbestos Monitoring program in the Vicinity of an Inactive Refuse Pile in Ambler, Pennsylvania, Equitable Environmental Health, Inc. for PADER, March 1977.

PADER, 1977. The Results of an Ambient Air Asbestos Monitoring Program in the Vicinity of an Inactive Refuse Pile in Ambler, Pennsylvania (July 1977 Sampling Survey) , Equitable Environmental Health, Inc~. for PADER, October 1977. -'' " ' . . " . . .

PerryA, 2004. A Discussion of Asbestos Detection Techniques for Air and S o i l , Anthony Perry for EPA, August 2004.

Silvasi/Mineo, 1971.'Summary of Results of Interviews with Residents Adjacent to Nicolet Plant and Piles, December 16, 1971.

TetraTech, 2006. Draft Trip Report for the Borit Asbestos Tailings Pile, TetraTech EM Inc., prepared for EPA, August 2006.

TokuhataG, SmithM, RamaswamyK, MannL, P o s s i b l e H e a l t h H a z a r d s o f A s b e s t o s . Waste Pi le : Ambler, Pennsylvania, August 1975.

WHO, 2003. Asbestos in Drinking Water: Background Document for Development of WHO Guidelines fo'r Drinking Water Quality, World Health Organization, 2 0 0 3 . ' • -

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