Dear REPA,
REPA has invested in another expert review and report for our beautiful community. We would like to share with you the second report dated September 1, 2019 prepared by Erskine Environmental Consulting for REPA. The report presents a technical review of recent asbestos test results as well as recommendations that would allow informed decisions and avoid potential risk for asbestos exposure to residents and more than 11,600 school children at 24 schools located near the Rockhill quarry. This report has been sent to DEP officials. It will also be distributed to our legislators and various institutions within our community, Pennsylvania and the EPA.
As we shared with you previously, on June 6, 2019, REPA submitted to DEP the first report prepared by Erskine Environmental Consulting on the Geologic Investigations Hazardous Materials Naturally Occurring Asbestos QGSSP for Rockhill Quarry. REPA shared also shared a SUMMARY of this first report with all of you on June 11, 2019. Unfortunately, we have not received any acknowledgement from DEP that either report has been received. We have only heard from other sources that the first report was received and is “being considered” by DEP, leaving us to wonder what exactly is being considered.
The September 1, 2019 report finds that methods as well as the sampling and analysis program that was implemented at the Rockhill quarry site are INADEQUATE AND DEFICIENT to assess and quantify the concentration of asbestos present in the Rockhill Quarry. Below are a few ALARMING highlights from our expert geologist’s report.
HIGHLIGHTS OF 9.1.19 REPORT
REVIEW OF ASBESTOS LABORATORY TESTING
Quarrying at the Rockhill quarry site constitutes a high-risk operation because of four factors that contribute to potential risk of exposure:
1. … asbestos particle emissions cannot easily be controlled. Fine particles cannot be captured by airborne misting methods… because the size of the water droplet is too large compared to the size of fine asbestos particles
2. During quarry operation… rock becomes a repeated emission source throughout the process – drilling, blasting, sorting and sizing, bulldozing, excavation and loading, hauling to crushing/screening operations, crushing and screening, transporting on public roads, treatment of vehicles. Emissions are not effectively captured by … systems that are not designed for fine asbestos particles, dust control measures are ineffective (sprayers only disperse the fine particles, and do not capture them), emissions are blown away by large engine cooling fans; standard wheel washes at the egress points are designed for large particles but not fine asbestos particles… recirculated water containing fine asbestos particles are tracked off site as water drips from vehicles
3. … young children are particularly at risk from asbestos exposure. Children occupying residences are located as near as 300 feet from the quarry and several schools are located within 5 miles of the site boundary (see Table 1 below).
4. Asbestos-containing soil and aggregate will be transported through residential communities … prevention measures at egress points of construction sites are not particularly effective for fine asbestos particles, and coverings on haul trucks are not designed to contain asbestos. As a result, children at locations considered to be far-source receptors become near-source receptors due to accumulated spillage from haul trucks and track out on public roads.
FINDINGS
∙ Significant concentrations of actinolite asbestos reporte
∙ Deficiencies regarding the choice of the test method and the likely under reporting of asbestos.
∙ The limit of quantitation is ten times the accepted action level. As a result, the analyses likely under reported the concentration of asbestos.
∙ The chosen test method is designed to detect asbestos in building materials and is not appropriate for Naturally Occurring Asbestos. The chosen method can severely under report the actual asbestos content because fine fibers are invisible and cannot be detected. It is likely that more asbestos is present in the samples, and the laboratory under reported asbestos because the fine particles are not visible.
∙ The chosen technique does not adequately quantify asbestos concentrations. The practice excludes fibers that meet the EPA definition of asbestos from being reported as asbestos. The laboratory apparently uses an arbitrary standard that has neither been peer reviewed nor accepted … the laboratory underestimated the concentration by a factor of 800%.
RECOMMENDATIONS
∙ To avoid a conflict of interest and produce test results that will be considered reliable, the Pennsylvania DEP should contract with a Professional Geologist and qualified testing laboratory who are not affiliated with the mining industry.
∙ The Professional Geologist should re-sample the materials that are of interest.
∙ Samples should be prepared and tested using protocols for NOA analysis.
∙ To provide additional information regarding the potential risk to residents and school children, in advance of any quarrying operation, it is recommended that an air modeling study be conducted to provide a predictive capability to airborne dust concentrations at off-site locations, and the data from the model can be used to calculate a risk-based threshold for the site perimeter program.
∙ Consider using an alternative quarry for the Turnpike Milepost A31-A38 project. At least four quarries are located at comparable distances from the turnpike project as the Rockhill quarry (see Table 3). Naceville Materials is located less than a mile from the project. Supplying aggregate and other materials from one of these quarries would significantly reduce or eliminate the potential for asbestos exposure from operations at the Rockhill quarry and along quarry hauling routes on public roads and through residential neighborhoods.
TABLE 1
