Asbestos vermiculite conditions present a substantial threat to public health

As a result of an actual and/or threatened release, the threat of exposure to current employees at the Site, the work force population in the immediate vicinity, and nearby residents, exists through direct contact and subsequent inhalation of amphibole asbestos fibers.

The conditions at the Site present an imminent and substantial threat to human health and the environment and meet the criteria for initiating a removal action under Section 300.415(b)(2) of the NCP. The following factors from §300.415(b)(2) of the NCP form the basis for EPA's determination of the threat presented, and the appropriate action to be taken:

(i) Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants. The high concentrations of asbestos found in both surface and subsurface soils indicate that the human exposure pathway exists. The immediate surrounding area is an industrial setting with nearby residential communities within approximately 0.25-0.40 miles. Air dispersion of asbestos fibers could potentially impact both the immediate industrial community and the adjacent residential communities.

(ii) High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate; Vermiculite, in both the expanded and unexpanded forms is readily visible at the surface on this property and the adjacent "Millham yard" property. Surface and subsurface soils contain high measured asbestos levels scattered widely throughout both of the properties. There are several pathways by which these asbestos fibers can become entrained in air leading to inhalation exposures. Contaminated soils can easily be tracked into buildings or off the contaminated properties by truck, automobile, or pedestrian traffic; and then through wind dispersion become respirable dust. Wind, particularly in dry summer months, can lead to the migration of fine asbestos fibers from contaminated surface soils. Heavy rainfall and snow melt would also tend to wash the fibers from the surface soils onto the adjacent downstream properties where they could also become airborne during the dry seasons.