United States
Environmental Protection'
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R09-89/036
July 1989
SEPA
Superfund
Record of Decision:
Coalinga Asbestos Mine, CA
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50272.101
REPORT DOCUMENTATION 11. AEPORTNO. 1 2.
PAGE EPA/ROD/R09-89/036
.3. A8c1pIent'a AccM8Ion No.
4. TIlle end Subft8
SUPERFUND RECORD OF DECISION
Coalinga Asbestos Mine, CA
First Remedial Action
7. Author(a)
5. Report Da18
07/19/89
I.
"
I. P8rfomIIng 0rpniIatI0n A8pL No.
.. "-fonnlng 0rpInIzatI0n ...... ... Add!-.
10. ProjKtITlI8II/WortI unt No.
11. ConIr8ct(C) or Gr8nI(G) No.
(C)
12. ~ 0rpnIz8II0n ...... ... Add!-.
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(0)
13. Type'" Report. Pwltod CoWNd
Agency
800/000
14.
15. Suppl8m8lltary No'"
11. Ab81ract (UnlIt: 2IJO wonI8)
The Coalinga Asbestos Mine site is in Fresno County, California, and is being remediated
concurren~ly with the Atlas Asbestos Mine site. This Record of Decision (ROD) does not
address the mines, but rather a separate area in the city of Coalinga, where asbestos,
from the Atlas-Coalinga mines, was depos,ited to await handling and shipment. This
107-acre site has been designated as the first operable unit for the Atlas Asbestos Mine
and the Coalinga Asbestos Mine sites. From the 1960s to the mid-1970s extensive asbestos
mining and milling took place in areas near the site, and until 1980 the site. operated as
an asbestos milling, manufacturing, storage, and transportation center. The site consist
of four distinct areas: (1) the warehouse which was once a mining waste distribution
center and which currently houses 1,600 cubic yards of mining waste; (2) a storage yard
which contains asbestos-contaminated stacked pipes; (3) a shipping yard which was used as
an asbestos distribution center by the Coalinga Asbestos Company; and (4) the U.S.
Coalinga Company which currently stores piles of asbestos-contaminated mining waste. In
1980 a State inspection revealed elevated levels of asbestos in the nearby aqueduct which
suggested that the Coalinga Asbestos Mine and Atlas'Asbestos Mine sites were probable
pSbestos sources. Subsequent sampling programs, conducted between 1983 and 1987, reveale
that surface water and air also contained elevated levels of asbestos. (See Attached
Sheet)
17. Doc:urn8nI AneIy8I8 .. D88crIpIIIr8
Record of Decision - Coalinga Asbestos Mine, CA
First Remedial Action
Contaminated Media: soil, debris'
Key Contaminants: metals (nickel), other inorganics (asbestos~ mining wastes)
b. Identifler8/Open-Encled T-
c. COSA 11 FieIdIGroup
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1.. SecurIty CIa.. (Thla Report)
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None
21. No. 01 Pagea
116
I
22. Price
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(See ANSl-Z3'.18)
See ,...trucIiQ118 0" Re-
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(Formetty NTI~)
DepaI1menI 01 Commerce
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E~A/ROD/R09-89/036
Coalinga, CA
~~rst Remedial Action - Final
Abstract (continued)
AS a result of these findings, EPA issued an Administrative Order to a major landowner,
Southern Pacific Transportation Company (SPTC), requiring SPTC to conduct an additional
remedial investigation and a feasibility'study and to perform interim measures to
stabilize the site. Because airbprne emissions of asbestos pose the greatest threat to
neighboring residents, this remedial response will limit th~ amount of asbestos and
nickel released from the soil and emitted into the air. The primary contaminants of
concern affecting the soil and debris are metals including nickel, and other inorganics
including asbestos and mining wastes.
The selected remedial action for'this site includes excavating and consolidating 14,500
cubic yards of asbestos, chromium, and nickel-contaminated soil and building debris; ,
soil; constructing an underground waste management unit (WMU). to contain and dispose of
contaminated soil and waste onsite; capping the WMU area; regrading the excavated area;
depontamiriating debris; monitpring soil moisture content, ground water, air, and
personnel; and implementing institutional controls. The estimated present worth cost
for this action ranges between $1,500,000 to $2,500,000, which includes annual O&M costs
of $35,000.
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CITY OF COALINGA OPERABLE UNIT
OF THE
ATLAS MIME AND JOHNS-MANVILLE COALINOA ASBESTOS MINE AND MILL
NPL SITES
RBCORD OF DECISION
United States Environmental Protection Agency
Region IX - San Francisco, California
July 19, 1989
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TABLE OF CONTENTS
SECTION
~
Record of Decision
Declaration Statement
Statement ot Basis and Purpose
Assessment of the Site
Description of the Selected Remedy
Statutory Determinations
Decision Summary .
, 1.0 Site Location and Description
2.0 Site History
3.0 Enforcement
4.0 Community Relations
5.0 Scope and Role of the Operable unit
6.0 Site Characteristics
7.0 Summary of Site Risks
8.0 Description of Alternatives
9.0 Comparative Analysis of Alternatives
10.0 Applicable or Relevant and Appropriate
Requirements
11.0 The Selected Remedy
12.0 Documentation of Significant Changes
13.0 Statutory Determinations'
Administrative Record Index
i
i
i
ii
iii
1
1
3
4
5
5
6
7
9
11
16
20
23
23
Responsiveness Summary
I Introduction 1
II overview of the ROD and critical community Concerns 2
III Summary of Public Comments Received and Agency Response 3
A. Comments by Members .of the Coalinqacity..Co:uncil._.. :3 .'.' '..
B. Comments by the Interested Public 11
C. Comments by potentially Responsible Parties 12
[
I .
Appendix 1: Review of Asbestos Analytical Techniques
Appendix 2:" Central Valley RWQCB Memorandum, April 7, 1989.
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RECORD OP DBC%8%OH
DBCURAT%OH
SITE NAME AND LOCATION..
City of Coalinga Operable Unit
Fresno County, California
.STATEMENT OF BASIS AND PURPOSE
This Record of Decision ("ROD") presents the selected remedial
action for the City of Coalinga Operable Unit, in Fresno County,
California. Tbe remedy vas selected pursuant to the Comprehen-
sive Environmental Response, Ca8pensation, and Liability Act, as
amended by the'Superfund Amendments and Reauthorization Act, 42
U.S.C. Section 9601 ~~, ("CERCLA") and in accordance with
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 C.F.R. Section 300 et. sea., ("NCP")., This decision is
based on the Administrative Record for this Operable Unit. The
attached index identifies the items that comprise the Administra-
tive Record. .
The State of California has concurred in the selection of this
remedy. See Administrative Record Doc. . 1066.
THE SITE
The response action selected in this ROD addresses actual or
threatened releases: of hazardous substances from the City of
Coalinga Operable Unit 'that may present an imminent and substan-
tial endangerment to public health, welfare, or the environment.
During remedial investigations for the Atlas Mine Superfund Site
and the Johns-Manville Coalinga Mill Superfund Site (the "Atlas-
Coalinga Superfund Sites" or the "Mine and Mill Sites"), it was
discovered that asbestos had been transported from the mines and
mills to an area within the City of coalinga for eventual han-
dling and shipment.' soil sampling confirmed the presence of un-
controlled hot spots of asbestos and nickel contamination. over
the 107 acre area in Coalinga (the "Site"). An 'outline of the
Site can be found at Figure 1A. .
. ., '.
On August 24, 1987 the Environmental Protection Agency ("EPA")
issued Order No. 87-04 to the Southern Pacific Transportation
Company ("SPTC") pursuant to CERCLA Section 106. Order No. 87-04
required SPTC to take emergency containment actions at the Site
to reduce the threat to public health from nickel and asbestos
dust that could enter the air from contaminated soils. Pursuant
i
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I
Areas at the Site, including warehouses, storage yards and ship-
ping yards, contain asbestos-bearing soils, equipment and waste
piles. Analysis of soil and waste pile samples using polarized
light microscopy ("PLM") shows the asbestos levels ranging from
one area percent (the detection limit) to as high as 98 area per-
cent. Chromite ore waste and soil samples were also analyzed for
heavy metals. These analyses indicated that the Soluble
Threshold Limit Concentration ("STLC") for the heavy metal
nickel, as specified in Title 22 of the California Administrative'
Code, was exceeded in some of the samples that tested positive
for asbestos. '
Asbestos and nickel are hazardous substances as defined in 42
U.S.C. S 9601(14) and as listed in 40 C.F.R. S 302.4. Asbestos
is a known human carcinogen and has been shown to cause lung can-
cer and mesothelioma. Asbestos also causes other lung diseases,
such as asbestosis. Nickel is a potential human carcinoqen that
can affect the lungs, nasal cavities, and skin. If asbestos and
nickel remain uncontrolled at the Site, the potential for human
exposure to asbestos and nickel and the resulting increased risk
to human health, primarily through the inhalation pathway, will
remain. ' .
EPA is undertaking additional Remedial Investigations/Feasibility
Studies ("RI/FS") to evaluate remedial action alternatives for
the Mine and Hill Superfund Sites and will select remedies for
those sites in separate Record of Decision documents.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action selected for the Site in this ROD is contain-
ment of the asbestos- and nickel-contaminated materials in an un-
derground vault. This remedy entails:
1) The removal and consolidation of the asbestos- and
nickel-contaminated soils at this Site that: ' (a) exceed one area
percent asbestos using polarized light microscopy ("PLM"), (b)
display the light-grey coloring characteristics of asbestos con-
taminated ,soils and/or (c).., contain, nickel at, .levels. in ' excess ,.of. -"~ ,_..
. background. Areas displaying light-qrey coloring will be
remediated until no light grey color is visible and only light
brown soil remains, by visible inspection: confirmation will be
by 1 area p~rc~nt PLM.' ,
2) Removal and consolidation of waste materials and equip-
ment .that exceed the levels set forth in paragraph 1, immediately
above.
3) Decontamination of buildings to less than or equal to
one percent by PLH.
ii
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, 4) Construction of an underqround, on-site Waste Manaqement
Unit to bury permanently the consolidated contaminated substances
under an impermeable cap. The impermeable cap will consist of a
compacted soil foundation layer overlain by an impermeable clay
mat, covered by a second soil layer. '
, , ,
5) Use of strict dust control measures to limit the release
of asbestos fibers from the site during the Remedial Action work.
6) Confirmation' sampling to ensure achievement of the
clean-up standards.
7) Ground-water monitoring and continuous monitoring of
soil moisture content using neutron probes. '
8)
removed.
Regrading of areas where contaminated soils have been
9) Placement of deed restrictions on the Site property
where'the Waste Management Unit and soil cover exist, to prevent
the disturbance of the cap and possible rel~ase of asbestos
fibers or nickel contaminants.
The permanent buri~l of material contaminated with asbestos and
nickel in the Was~e Management Unit will minimize the release of
asbestos and nickel, thus providing long-term protection of human
health and the environment. The estimated cost of the selected
remedial action is $2,500,000.
Operation and maintenance activities will be required to ensure
the effectiveness of the response action. These activities in-
clude: (1) quarterly visual inspec~ions to ensure the integrity
of the cap for three years with annual visual inspections there-
after, and (2) any repair work necessary to maintain the in-
tegrity of the cap, including maintenance of vegetation, 3)
qround water monitoring welles), and 4) monitoring of soil mois-
ture content using neutron probes. In the event of a natural
event such as a flood or earthquake, all repairs necessary to
contain the hazardous substances will be made. EPA will perform
a review of the remedial action pursuant to CERCLA section
121(c). '
STATUTORY DETERMINATIONS
Pursuant to CERCLA section 121, 42 U.S.C. S 9621, and in accor-
dance with the. NCP, the selected remedy for the City of Coalinga
Operable Unit: (1) is protective of human health, welfare, and
the environment; (2) meets the applicable and relevant and ap-
propriate environmental requirements; and (3) is cost effective.
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this
Site. Treatment of the asbestos contamination in the City of
Coalinqa Operable Unit was determined to be impracticable based
on effectiveness, technical feasibility, implementability and
111
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cost factors. The reasons for this determination are further
elaborated herein,-and a thorough discussion of th9se factors may
be found in the Operable Unit Feasibility Study for this Site..
While treatment to reduce permanently and significantly the
mobility, toxicity and volume was found to be impracticable, the
remedy is designed to protect the public and environment on a
permanent basis through continued monitoring and, if necessary,
maintenance.
This remedy will result in hazardous substances remaining on Site
above health-based .levels. Pursuant to CERCLA Section -121, 42
-U.S.C. Section 9621, EPA will conduct a review at five year in-
tervals, beginning after commencement of remedial action, to en-
sure that the remedy continues to provide adequate protection of
human health and the environment.
(AA~~~
~~'iegional Administrator
EPA Region IX
7fl~!~
Date
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iv
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. _RECORD 01" DECISION
DECISION SUMMARY
1.0
SITE LOCATION AND DESCRIPTION
The City of Coalinga is located in Pleasant Valley near the con-
fluence of two intermittent streams, Wartban Creek and Los Gatos
Creek, which are part of the Arroyo pasajero Drainage Basin. The'
Arroyo pasajero watershed and adjacent Cantua Creek watershed are
. located on the western margin of the central San Joaquin Valley
in an area that includes the foothills of the Southern Diablo
Range Mountains to the west and a system of coalescing alluvial
fans (including the Arroyo pasajero fan and Cantua fan) to the
east. Approximately 20 miles northwest of Coalinga, in the
Diablo Range, is the New Idria Formation. This elliptically .
shaped rock formation covers approximately 48 square miles and is .
the largest known serpentine deposit in th~ Coalinga region. The
sou~heastern third of the New Idria Serpentine Mass (or New Idria
Formation) has been the locus .of significant mining and surface
mineral exploration. These activities have included successful
exploration and mining for chromite ore and chrysotile asbestos
ore as well as for other serpentine related minerals. Cattle
ranching and oil exploration and production are the other main
natural resource activities in the coalinga area. .
In September, 1984, an asbestos mine located in the New Iaria
Formation and a mill located immediately southeast of the Forma-
tion were listed on the Superfund National Priorities List as the
Atlas Mine and Superfund Site and the Johns-Manville Coalinga As-
bestos Mill Superfund Site (the "Atlas-Coalinga Sites" or the
"Mine and Mill sites"), respectively. During investigation of
these Mine and Mill Sites, it was discovered that asbestos had
been transported from the mines and mills to an area within.the
City of Coalinga for eventual handling and shipment. Soil sam-
pling confirmed the presence of uncontrolled.hot spots of asbes-
tos and nickel contamination over a 107 acre area (the "Site") in
the City of Coalinga, California. .
The Site is located in a mixed use, industrial and residential
area. The site boundary extends approximately one mile from
Fourth Street on the northern end of coalinga to its southern
border, near the intersection of Lucille Avenue and Highway 198.
The east-west borders are between Glenn and Forest Streets in the
northern section, fanning out to Highway 198 for the western bor-
der and approximately 900 feet in an easterly direction for the
eastern border. Fiqure lA is an outline of the Site boundaries:
Figure lB shows the location of the Site in relation to the Mine
and Mill Sites.
The contaminated areas at the Site connected to the Atlas Mine
Site are at the northern end of the Site, while the contaminated
areas connected to the JOhns-Manville Mill Site are at the
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FIGURE IA
SITE LOCATION
COALINGA SITE
REFERENCE:
USGS 7.5 MINUTE TOPOGRAPHIC
MAP OF COAL.INGA, CAL.IFORNIA
QUADRANGL.Eb DATED 1956
PHOTOREVISE 1979
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DRAWING BY
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FIGURE 18
COALINGA SITE
'WECT laME
SITE LOCATION
IN RELATION TO MINE SITES
. . .
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2
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southern edge of this large Site. This cleanup could have
proceeded as two separate Operable. Units; however, due to the .
need to proceed expeditiously, EPA decided to combine the cleanup
into one site cleanup, desiqnated an Operable Unit for each of
the two National Priority List Mining and Mill Sites.
The Coalinga area is semi-arid and is characterized by moderately.
low precipitation and relatively high rates of evaporation. The
mean annual precipitation and evaporation are estimated to be
189.6 millimeters (7.46 inches) and 2,253 millimeters (88.7
inches), respectively. (These values were calculated from periods
of record exceeding 15 years). The Pleasant Valley area is un-
derlain by unconsolidated sediments that range in thickness from
less than 100 feet. to several thousand feet. The sediments un-
derlying the Site consist of interbedded gravels, sands, silts
and clays. These sediments have markedly different hydraulic
conductivities and porosities. The depth to ground water in
coalinga is approximately 100 to 150 feet and the ground water is
used primarily for irrigation.. Since at least 1951, the water
quality of the aquifer in Pleasant Valley has been poor. The
sulfate concentrations in the ground water in all reported wells
near coalinga have exceeded the Maximum Contaminant Levels
(tlMCLs") under the Safe Drinking Water Act by as much as six
times the recommended concentrations. Based on the Department of
Water Resources' records of mineral analyses of ground water for
the period from 1978 to 1985, the water quality of four selected
wells in the Pleasant Valley area shows moderate to high sodium-
sulfate concentrations. The total major anion concentrations
range from 1,100 to 2,600 parts per million ("ppm") with a mean
of 1,700 ppm. Sulfate concentrations in the ground water range
from 660 to 1,900 ppm, with a mean of 1,300 ppm. The percentage
of sodium concentration relative to the major anion concentration
ranges from 45 to 53 percent witb a mean of 49 percent. Vir-
tually all of the drinking water for coalinga is drawn from the
California Aqueduct. . . .
.,.,",":.;
DescriDtion of Contaminated Structures and Areas
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The Site has been divided into the following four areas, based on
existing structures and geography (see figure 3):
1) The Marmac Warehouse: The warehouse is located on Elm
Avenue (Highway 198) in the southwest section of Coalinga. This
area was a chromite ore distribution center and currently houses
approximately 1,600 cubic yards of chromite ore waste and other
materials contaminated with asbestos.
2) The .. Storage Yard: This yard is located approximately
one mile south of the Marmac Warehouse on Elm Avenue on the east
side of the road. The storage yard contains stacked pipes that
are contaminated with asbestos.
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-------
.---.-
EX"'ANATION
"IV. ,
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8.,
CJ OA MALYTICo\&. "18U~T8
CONTIGUOU8 AIIO G"IAT&II TltAII '110
~ VI_~ I&TIIiT OP CQIIT"IIItIl"TlDII
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MARMAC
WAREHOUSE
AREA
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AREA III
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8Ut1111A11., OP CQIIT.nI.IlATiO
AIIIA8 TO II IIIIIIDI"TID
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-------
3
3) The Atlas Shipping Yard: This yard is located in the
vicinity of Glenn Avenue and 6th Street.' It was used as an as-
bestos distribution center by the Atl'a's ASbes~os Company. .
4) The u.S. Asbestos Company: This area is located at the
southern border of the Site and encompasses approximately nine
acres. Piles of raw asbestos ore are located in this area.
Because of the close proximity of residential areas to the piles
of aSbestos-containing material, it is important that the
remediation proceed as soon' as possible. '
2.0
SITE HISTORY
In the mid-1950'S, an investigation by the California Division of
Mines ,and Geoloqy indicated that the serpentine matrix of the New
Idria formation was chrysotile asbestos. Subsequent investiga-
tion in the southeastern third of the New Idria Formation
demonstrated that the asbestos ore could be mined and milled to
produce a marketable short-fiber asbestos'product. From 1959
through 1962, the coalinga and Los Gatos Creek areas experienced
an intensive land rush.for asbestos mining claims. From the
1960's through the mid-1970's, extensive asbestos mining and
milling operations were conducted in the coalinga and Los Gatos
Creek areas. From 1955 to 1980, the Site was the locus of mill- ,
ing, manufacturing, storage and transportation of'asbestos-mining
materials from the Mine and Mill Sites.
Discoverv of the Problem in Coalinaa
- ,
In early 1980, the Metropolitan Water District ("MWD") of
Southern California detected elevated levels of asbestos in water
samples from the California Aqueduct. An extensive sampling
program along the Aqueduct, conducted by the MWD in Auqust
through September of 1980, sugg~sted that the Atlas Mine and the
Johns-Manville Mill Sites were probable sources of asbestos in
the California Aqueduct. Asbestos levels of up to 2500 million
fibers per liter ("MFL") were measured.
On October 17~ 1980, the Central Valley Regional Water Quality
Control Board ("CVRWQCB") and the California Department of Health
Services C."DHS") inspected the Atlas Mine and the Johns-Manville
Mill to determine if waste discharges from these facilities were
in compliance with state requlations. The CVRWQCB concluded that
additional corrective measures should be taken to prevent mine-
and mill-generated asbestos from entering the drainage basins.
In March of 1983, the CVRWQCB collected four surface water
samples during a period of high run-off in the Arroyo pasajero
watershed. Asbestos fiber concentrations in these samples ranged,
from 80,000 to 240,000 MFL~ On June 14, 1983 the risks repre-
sented by the Atlas Mine and the Johns-Manville Coalinga Asbestos
Mill were rated using the Hazard Ranking System. The Mining and
-------
4
. .
Mill Sites were approved for listing on the National Priorities
List in September, 1984. Remedial Investigation/Feasibility
Studies ("RI/FSs").are ongoing at both. of these Sites.
During an airborne asbestos sampling proqram in 1986 and 1987
conducted as part of the Remedial Investigation and desiqned to
measure airborne emissions from the Mining and Mill Sites, high
asbestos readings were measured in the City of Coalinga. Based
on this data, a study was initiated to look for possible sources
of asbestos in Coalinga. On June ~7 and 18, 1987, EPA conducted
a limited sampling and analytical program in Coalinga. This
study showed chrysotile asbestos occurrence from less than one
(1) percent to fifty (50) percent in the area of the Site. Fur-
ther investigation revealed that a major landowner in the con-
tamin~ted area was Southern Pacific Transportation Company
. ("SPTC"). In Auqust of 1987, EPA issued an administrative order
pursuant to CERCLA Section 106 (Order No. 8~~04) to SPTC; requir-
ing SPTC to conduct a Remedial Investigation at the site (i.e.,
an intensive sampling proqram to identify and quantify sources of
mining waste contamination). As a result of the Remedial Inves-
tigation, areas contaainated with residual asbestos ore waste
have been found throughout the Site. SPTC was also ordered to
prepare an Operable Unite Feasibility Study. ("OUFS") to develop'
and evaluate remedial alternatives for the Site. EPA released
the OUFS and information concerning EPA's proposed plan for
cleanup of the Site on February 9, 1989.
In response to Order No. 87-04, SPTC also performed interim
measures to stabilize the waste materials during the more
detailed investigation. These tasks included: i) limiting ac-
cess to contaminated areas with fencing, ii) posting warning
signs, iii) spraying biodegradable sealant to control dust emis-
sions, and iv) covering waste ore piles with plastic sheeting.
These interim measures were performed in the fall of 1987: a
second spraying of sealant took place in the spring of 1988 and a
third spraying took place in June of 1989.
---".. ".
3 "0
ENFORCEMENT
. . ..- ~., ...." ,......" .
In the spring of 1988, general notice letters were sent to
several potentially Responsible Parties ("PRPs"), notifying them
of their potential liability for the cleanup of the Site. . On
February 22, 1989, EPA issued notices of negotiations to the PRPs
for the City of Coalinga Operable Unit asking for good faith of-
fers. Due to the significant risk to the public health and the
environment posed by uncontained hazardous waste in Coalinga, and
.the immediacy of the threat, EPA determined pursuant to CERCLA
Section 122 that clean-up should be completed as soon as pos-
sible, and that the discretionary special notice procedures in
CERCLA Section 122 "should not be invoked. Therefore, PRPs were
given 21 days to respond to EPA's request for good faith offers.
Negotiations to sign a consent decree are in progress. On May
-------
5
10, 1989, a general notice letter was sent to the City of
Coalinga notifying the municipality of its possible liability in
this matter. .
4.0
COMMUNITY RELATIONS
. .
The public comment period for the OUFS and the proposed plan
opened on February 9, 1989 and closed on March 24, 1989. A
public meeting was held on February 22, 1989 at the Coalinga City.
Council Chambers and was attended by approximately sixty people.
Prior to the beginning of the public comment period, EPA pub-
lished a notice in the Fresno Bee and the Coalinga Weekly
Courier. The notice briefly described the proposed plan and an-
nounced the public comment period and the public meeting. The
notice also announced the availability of the proposed plan and
the OUFS for review at the information repository established at
the Coalinga Public Library. . .
A fact sheet describing the proposed plan was delivered to the
information repository. Copies of the fact sheet were mailed to
the EPA general mailinq list for the Atlas Mine and Johns-
Manville Coalinga Asbestos Mill Sites, which included ap- .
proximately 300 members of the general public, elected officials
and media representatives. Since June, 1987, EPA personnel have
met periodically with members of the Coalinga City Council.
Several different persons designated. by the City Council to be .
the Council's contact with EPA have been kept informed about the
investigation's status. .
EPA has prepared the attached responsiveness summary, which
provides responses to the comments submitted in writing during
the public comment. period, as well as responses to comments made
by attendees at the February 22, 1989 public meeting.
5.0
SCOPE AND ROLE OF THE OPERABLE UNIT
The ~ontamination at the Site represents the first operable unit
of the Atlas Mine Site and of the Johns-Manville Coalinga Asbes-
tos Mill Sites. The principal threat posed by uncontained as-
bestos close to residential areas comes from airborne emissions.
The purpose of this response is to limit current and future air-
borne emissions from the asbestos- and nickel-contaminated soils.
The remedial action selected in this ROD addresses a problem
. specific to a popuated area. Asbestos piles in Coalinga are to
be removed, consolidated and permanently buried so that airborne
emissions of asbestos fibers are minimized. The remediation
strategy for this Site is necessarily different from the remedia-
tion strategy being considered for the Mine and Mill sites.
Those Sites contain large piles of asbestos ore tailings situated
in sparsely populated areas and surrounded by very rich sources
of naturally occurring chrysotile asbestos. These different
situations require consideratiQn of different factors. The RI/FS
for the Atlas Mine 'Site and Phase 1 of the JOhns-Manville
~
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6
Coalinqa Asbestos Mill Site (samplinq and data cOllection) were
initiated in July of 1985. The RI/FS for the work remaininqon
the RI as well as. for the complete FS for the Johns-Manville, .
Coalinqa Asbestos Mill Site was initiated in November of 1986.
The major qoal of both RIs is to identify the sources, extent,
pathways and receptors of the contaminants and to' characterize
the nature and extent of the public health and environmental
problems presented by the contamination. Major components of the .
Remedial Investiqation Reports i~clude detailed soil, water and
, air samplinq, qeoloqical and qeotechnical studies and watershed
modelinq. The Feasibility Studies for these Sites, which will
evaluate the necessity for and proposed extent of remedial ac-
tion, are expected to be completed in the fall of 1989.
6.0
SITE CHARACTERISTICS
Elevated asbestos levels in the air in coalinqa were first dis-
covered durinq the reqional airborne asbestos samplinq of 1986
and 1987. The detailed soil samplinq performed bySPTC in the
site area found levels of asbestos ranqinq from less than one
area percent to as hiqh as 98 area percent (found in raw asbestos
ore piles). The composite soil samples were analyzed usinq
Polarized Light Microscopy ("PLM") as described in Interim Method
for the determination of Asbestos in Bulk Insulation Samples
(EPA-600/M4-82-020). The less than one percent results are those
in which the contaminant was present, but was below the level at
which the concentration could be determined.
. .
FigUres 2 and 3 show the areas within the Site where asbestos
contamination was detected. The total affected area is ap-
proximately 11 acres and the depth of contamination ranqes from
several inches to several feet. Asbestos ore waste was iden-
tified in a one half acre area adjacent to the coalinqa Machine
Company. Samples fram this asbestos ore waste ranqed from two
(2) area percent asbestos to 80 area percent usinq PLK. Ap-
proximately SOOfeet south of Polk street is an area of ap-
proximately one and one half acres with recorded asbestos levels
ranqin~J from one area percent to 46 area percent~ 'On .the ,",."U'._, .
southern border of the site is an area of approximately nine
acres where piles of raw asbestos are were identified. One
sample from this area measured 98 area percent asbestos. The
fenced area'around the Marmac Warehouse contains broken pieces of
asbestos-containinq panelinq. Several piles of suspected
chromite ore waste are present within the warehouse. The
suspected chromite ore vaste in the Har.mac Warehouse was sampled
and analyzed for heavy metals and asbestos contamination. Three
samples were analyzed for asbestos and the 17 metals listed in
Title 22 of the California Administrative Code. The Title 22 To-
tal Threshold Limit Concentration ("TTLe") for asbestos was ex-
ceeded in all samples: the Soluble Threshold Limit Concentration
("STLC") for nickel was exceeded in .all samples. Additional
samples from asbestos-contaminated areas throuqhout the site were
analyzed to .see if a correlation existed between asbestos content
and elevated levels of nickel. These analyses indicate that
-------
Southern Pacific Transportation Co. Page 6
JWMU Design Report
at any one measuring point within the vadose zone beneath the WMU,
the following response will be initiated:
1. The RWQCB will be notified of test results and the
elevated area will be retested.
2. After consulting with the RWQCB, a decision will be made
as to whether this is an anomalous reading or if a real
increase in moisture content has been detected. In the
event that the detected increase is real, the following
steps will be taken:
(a) A qualitative assessment of the monitored area will
be performed to determine the areal and vertical
extent of migration. This assessment will consist
of a detailed review of all data collected from the
vadose zone monitoring network, background data
established at the beginning of monitoring, and a
review of the geotechnical and geochemical
characteristics of the suspected soils.
(b) A drilling and soil sampling program will be
designed to collect soil samples from the affected
areas and laboratory analyses will be performed.
(c) Laboratory analyses will be performed on archived
materials from the same location as the elevated
moisture readings.
(d) Results of the laboratory analyses will be compared
for indications of contamination.
(e) Should the continued neutron probe monitoring still
indicate elevated moisture contents, a soil-pore
liquid sampler will be installed. In addition,
soil-pore liquid samplers will be installed away
from the suspect area to provide background data,
if the background soils contain sufficient moisture.
3. Upon installation of a soil-pore liquid sampler, samples
will be collected for analyses on a quarterly basis and
compared to background samples for indications of
contamination.
4. If the RWQCB determines that the results of pore fluid
sampling indicate contaminant migration which might
-------
Southern Pacific Transportation Co.
WMU Design Report .
Page 7
endanger groundwater, a monitoring plan, consisting of
one upgradient and two downgradient wells, will be
submitted to the RWQCB within 90 days. .
Comments and Recommendations:
Upon review of the report,. I have no. objections to SPTC proceeding
with the proposed project. provided. the following items are
addressed.
. 2.
3..
4.
1.
Upon completion of the WHO, . a repo~ detailing
construction should be submitted for our review. The WHO
should be inspected by staff prior to its use.
Schedule for construction and closure of the WHO, along
with a schedule for deposition of waste into the unit,
should be provided so staff can ..schedule periodic
inspections.
Al though groundwater monitoring may be minimized in favor
of vadose zone monitoring, a specific groundwater
monitoring plan including well placement and construction
details will need to be prepared, approved and thereafter
implemented. SPTC will a1so need to develop a
groundwater sampling program.
The design report does not indicate that all results from.
vadose zone monitoring will be s~mitted to our office.
The report only indicates that the RWQCB will be
contacted if a significant change in moisture content is
observed. Results of all monitoring data will' be
required ,as. soon as they are made available toSPl'C. .
I recommend that we request SPTC to address the comments and
recommendations, as outlined above, prior to construction of the
WMU. If modifications ar~ made to this design,. these changes will
also need to be submitted for our review. .
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7
samples which contain greater than one percent asbestos are posi-
tively correlated with samples that exceed the STLC for soluble
nickel. Nickel is a by-product of asbestos milling processes and
is likely to be associated with asbestos ore waste. .
Asbestos is a generic term referring to two groups of naturally-
occurring hydrated silicate minerals having a fibrous crystalline
structure. The asbestos mineral found in the New Idria Serpentine
Mass is chrysotile, a fibrous mineral with an elongated, needle- .
like structure. Chrysotile is a short-fiber asbestos mineral.
Asbestos fibers are widely used for their high tensile strength
and flexibility and for their noncombustible, nonconducting, and
chemical-resistant properties. The fibers have been used in in-
sulation, brake linings, floor tile, plastics, cement pipe, paper
products, textiles,and building products. .
7.0 .SUMMARY OF SITE RISKS
Asbestos is the primary contaminant of concern at the Site.
Major sources of asbestos at the Site are contaminated soils and'
piles of raw asbestos ore waste. Low levels of soluble nickel in
some of the asbestos tailings are of secondary concern.
Asbestos is one of the few known buaan carcinogens. Asbestos ex-
posure can also cause other lung diseases, such as asbestosis.
EPA considers carcinogens to be non-threshold in nature, that is,
any amount of a human carcinogen in the environment represents a
cancer risk to the exposed population. Asbestos has been the
subject of numerous epidemiological studies. Exposure to asbes-
tos has been positively linked to asbestosis, lung cancer, and
mesothelioma. Also associated ~with asbestos exposure in some
studies are cancers of the larynx, pharynx, gastrointestinal
tract, kidney, and ovary, as well as respiratory diseases such as
pneumonia. A full discussion of the health effects of asbestos
is found in the EPA document Airborne Asbestos Health Assessment
UDdate. June 1986.
Analytical results from air sampling conducted in August, 1986,
March, 1987 and September-october 1987, as well as results of
soil sampling conducted as part of the OUFS, form the database
that were used to qualitatively assess the health risks in
Coalinga. Further details of health risks in the Coalinga area
related to.as~estos are included in the risk assessment chapter
in the Remedial Investigations for the Mine and Mill Sites.
There are two general routes of exposure to asbestos at the Site:
inhalation and ingestion. Inhalation is the exposure pathway of
greatest concern to human health because this pathway has been
positively linked to cancer in humans. While not of primary im-
portance, ingestion exposure to asbestos may also be associated
with an increased risk of cancer. These ingestion exposures in-
clude direct ingestion of soil contaminated with asbestos and in-
direct ingestion of asbestos which has been inhaled.
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8
Individuals may inhale asbestos fibers which are present in am- .
bient air and asbestos fibers which are entrained into the air as
a result of specific activities. Ambient'concentrations of as-
bestos were detected in both on-site and off-site areas by the
air monitoring conducted in 1986 and 1987. Soil disturbing ac-
tivities such as children playing in or bicycle riding on
asbestos-contaminated soils can resuspend asbestos fibers into
the air. Vehicular traffic on unpaved areas containing asbestos
contaminated soils such as truck yards and vacant lots can
entrain significant amounts of asbestos into the air. Asbestos
fibers stirred up by truck traf:tic may be inhaled by truck yard
personnel and by persons living downwind from the site. Soil
concentrations of asbestos in the Site range from a geometric
mean of less than one area percent to 98 area percent.
Experiments conducted by the California Department of Health
Services ("DBS") in 1985 clearly show that .a pickup truck driving
on unpaved asbestos contaminated soil can produce asbestos dust
concentrations in the air that pose a potential health risk to an
individual at or nearby the activity. A detailed discussion of
this experiment is included in the Remedial Investigation Report
for the South Bay Asbestos Site, Alviso, California, 1988. The
South Bay Asbestos site Remedial Investigation Report has been
included in the Administrative Record for this Site.
When evaluating risk from asbestos in the environment, there are
sources of uncertainty associated with asbestos measurement that
make quantifying. the risk difficult. One of these sources of un-
certainty is the difficulty of obtaining accurate and precise
measurements of .asbestos concentrations in soil, air, and water.
For example, all risk assessments require an accurate and precise
measurement of contaminant concentration. When a gaseous or
soluble chemical is the contaminant of concern, the measurement
of onlv one parameter, concentration, is sufficient to establish
how much of that contaminant is present in a given sample.
However it is infinitely more complex to measure the concentra-
tion of particulates accurately and precisely, especiallyfibr~u~,... .',.. .
particulates, because many more parameters must be accounted for. .
When measuring spherical particles the following parameters must
be measured: i) the overall particle size distribution: ii) the
concentration of each individual size category: and iii) the .
change in'concentration of each size category in different parts
of a dust cloud. When measuring fibrous particulates such as as-
bestos, the parameters become exponentially more complex. The
length and diameter of each particle must be measured along with
the distribution of complex shapes (such as bundles, clusters and
matrices). The concentration of each different shape must be es-
tablished, along with the settling velocity of different fiber
shapes. Finally, there is a human component to asbestos
analysis. Because all of the sampling methods for asbestos in-
volve an individual, using an optical or electron microscope,
identifying and counting miniscule asbestos fibers, the relative
experience and fatigue of the person doing the counting can in-
fluence the ultimate accuracy and precision of a given analysis.
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9
Many of the epidemiological studies which established the link
between the inhalation of asbestos and cancer used phase contrast
microscopy ("PCM") techniques to measure asbestos concentration. .
However, PCM is considered inadequate for the analysis of a short
fiber mineral such as chrysotile. Many of these studies were
done before transmission electron microscopy ("TEM") techniques
were available. Most studies. today use TEM as the "state of the
art" analytical technique for measuring airborne asbestos con-
centrations. In the City of Coalinga, the ambient air samples
were measured using TEM while the. soil samples were measure using
polarized light microscopy ("PLM"). Limited TEM analyses of the
soils samples were used for confirmation. . To use '1'EH data in
quantitative risk assessments, one must convert TEM data to PCM
Equivalent ("PeME") data using a conversion factor. There are a
variety of ways to perform this conversion: whenever conversions
. of this type are done, the ability to describe risks quantita-
tively with accuracy is diminished. The Agency must make risk
management decisions despite the fact that the science of risk
assessment and techniques for measuring asbestos concentrations
continue to evolve.
EPA has determined that because asbestos is a known human car-
cinogen with no acceptable known threshold level for environmen-.
tal exposure, and, the potential for release of asbestos from the
'Site is high, a significant health risk exists. While a quan-
titative risk assessment is not possible because of the analyti-
cal problems associated with the measurement of asbestos, a
clean-up goal of less than or equal to ~ area percent by PLM is
consistent with CERCLA's requirements. and with past Agency deci-
sions regarding asbestos clean-up .levels at other Superfund
sites. See Appendix 1 for further discussion of this clean-up
level. The adverse human health effects from exposure to asbes-
tos are extremely serious. Therefore, remedial action is war-
ranted to mitigate the exposure to a carcinogen that is present
as a result of human activity. . .
8.0
DESCRIPTION OF ALTERNATIVES
EPA evaluated potential remedial action alternatives for the City
of Coalinga Operable Unit in accordance with CERCLA section 121,
the National Contingency Plan ("NCP"), (in particular, 40 C.F.R.
Section 300.68), and. the Interim Guidance on SUDerfund Selection
of Remedv.,.aec;:ember 24, 1986 (OSWER Directive No. 9355.0-19).
The first step in evaluating potential remedial action alterna-
tives was to'determine, based upon site characteristics, what set
of response actions and associated technologies would be con-
sidered for the Site from among all possible alternatives. An
example of this preliminary determination (or "seoping") was the
elimination of biological treatment from further consideration
because biological processes capable of detoxifying asbestos con-
taminated soil do not exist. 'section 2.1 of the OUFS discusses
the scoping process in more detail.
/.
-------
10
. .
The next step in the selection of remedy process was assembling
the remaining technologies' and/or disposal options into general
remedial action alternatives. Pursuant to OSWER Directive No.
9355.0~19, remedial action alternatives are to be developed rang-
ing from those that would eliminate the need for long-term
management (including monitoring) at the site to alternatives in-
volving treatment that would permanently reduce the mobility,
toxicity or volume of the hazardous substances(s) as their prin-
cipal element. In addition, containment options involving little
. or no treatment and a no action alternative are to be developed.
The remedial action alternatives developed in the OUP'S were:
-- No Action
Fencing of the Contaminated Areas
-- Capping .
a) Soil
b) Asphalt
c) Soil-Cement
d) Gunite
e) MUlti-Layer
On-Site Disposal
-- Treatment by Chemical Fixation
a) Plant Processing
b) Area Mixing
Thermal Vitrification
-- Removal and Off-site Disposal
I .
. . - P. ..".- -..".
The No Action alternative serves as'a basis for comparison in
analysis of the other remedial action alternatives under con-
sideration. Fencing of the contaminated area is an access
restriction alternative involving no treatment. Capping would re-
quire long term management. On-site disposal would reduce the
need for long tera .anage8ent at the Site. Off-site disposal
would eliminate the need fo~ long term 8anagement and monitoring
at the Site (although monitoring and long term management would
be required at the off-site disposal site). Chemical Fixation
and Thermal Vitrification involve .treatment.as their.. principal.....
element. .
After the initial screening, the most promising of these alterna-
tives were analyzed in greater detail in Section 2.1.2 of the .
OUFS. The five remedial alternatives that were fully analyzed
are described in the following paragraphs:
Alternative 1:
No action
This action would involve no action to treat, contain, or remove
contaminated soil, equipment, or structures. Multimedia monitor-
ing would be performed at a minimum of every five years to aid in
a reassessment of the no action alternative. .
Alternative 2: . Off-Site DisDosal at a Mine Site Near coalinqa
-------
11
This alternative would involve decontamination of the buildings
and disposal of all asbestos ore wastes and other mining wastes
at an abandoned mine near Coalinga.
Alternative 3:
~
coverina Waste with One Foot of Asbestos-Free
This alternative ,would involve decontamination of the buildings,
off-site disposal in an approved facility of waste mining'
materials stored in. ,the 'Marmac Warehouse, and covering all areas
of the site that tested positive for asbestos ore waste with one
foot of asbestos-free soil. . ,
Alternative 4:
Landfill
This alternative would involve decontamination of the buildings,
and disposal of all asbestos ore wastes and other mining material
at an approved off-site landfill.
Off-site DisDosal of Waste in an ADDroved
Alternative 5:
Construction of an On-site Waste Manaaement Unit
This alternative would involve decontamination of the buildings,
and construction of an on-site waste management unit ("WMU"). All
asbestos ore wastes and other mining material would be collected
and disposed of in the WMU. The material in the WMU would be
capped in accordance with the California Administrative Code,
Title 23, Chapter 3, subchapter 15. The conceptual design of the
WMU is included in the Design Report, found in the Administrative
Record (Doc. # 624). .
9.0
COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides an explanation of the criteria used to
select the remedy, and an analysis of the five remedial action
alternatives in light of those criteria, highlighting the ad-
vantages and disadvantages of each of the alternatives., .
Criteria
. .
The alternatives were evaluated based on the nine key criteria
which directly relate to the factors that CERCLA Section.
121(b) ((1) (A-G) mandates that the Agency assess in selecting a
remedy. These criteria are:
(1) overall protection of human health and the
environment, .
(2) short term' effectiveness in protecting human
health and the environment,
(3) long-term effectiveness and permanence in
protecting human health and the environment,
(4) compliance with ARARs (ARARs are detailed in Section
10.0), .
(5) Use of treatment to achieve a reduction in the
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12
toxicity,mobility or volume of the contaminants
(6) implementability,
(7) state acceptance, .
(8) community acceptance, and
(9) cost. .
..
. .'
Because there is no feasible treatment technology for asbestos
containing mining materials, criterion ,number five is not
directly relevant to a choice among alternatives. However, the
alternatives were compared with respect to their ability to mini-
mize the mobility (through the air or ground water pathways) of
the asbestos-containing material. criterion number six, im-
plementability, is also not a factor. in choosing among alterna-
tives. Implementability is the technical and administrative
feasibility o~ a remedy as well as the availability of services
and materials to carry out the remedy. All five alternatives are '
equally implementable. For these reasons, .neither of these.
criteria are included in the following comparison .of alterna-
tives.. .
.
Alternative 1 - Ho action Alternative
This alternative would Dot reduce present or future exposure to
hazardous substances at the Site, . and thus would not be protec-
tive of human health and the environment. The risk to human .
health and the environment would not be addressed. Although this
is the least expensive alternative, it would not achieve com-
pliance with ARARs and would not provide a permanent solution.
Alternative 2 - Removal or Wastes to the Mine sites
The environmental and public health protection provided by this
alternative is better than the no action alternative but less
than alternatives four or five. Environmental degradation is ex-
pected to increase over time. Increased exposure to the con-
taminants would occur during implementation; engineering controls
would be implemented, during the collection of contaminated soils
that would minimize this. potential for' exposure. - Transportation".""
and off-loading operations at the abandoned mine site would
result in additional exposure as compared to on-site disposal.
The lengthy amount of time needed to implement this alternative
would also result to increased risk because of the period of no
action at the Site. Contrary to the OUFS' conclusion that this
alternative would satisfy all ARARs, this alternative would not
meet the requirements of California Administrative Code, Title 22
with respect to Class B Mining wastes); it would also not meet
the NESHAP requirements at 40 C.F.R. S 61.153. This alternative
is expected to meet with community approval based on the
community's express desire to have the wastes removed from the
City. State perception of this alternative is expected to be
negative.
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-~~--~ ..
. - -. - .. - --
13
The cost of this alternative is extremely high. Costs would in-
clude the extension and/or repair of roads and utilities to the
chosen mine site. The 'cost for this' alternative is estimated' at
$7 to $9 million and is the highest of all alternatives con-
sidered. The schedule to implement this alternative is estimated
at one to two years due to the need for road construction.
A1~erna~iv. 3 - coverina .as~e wi~h Hon-con~aminate4 ~i11
The human 'health risk during implementation of this alternative
.would be moderately high. As in alternative 2, engineering con-
trols would be implemented that would minimize the exposure
during movement of .ininq wastes. Long term protectiveness of
human health and the environment would be less than that achieved
with alternatives 2, 4 or 5 because the asbestos ore waste would
remain under the clean soil cover and could be disturbed by human
activity or natural processes, such as an earthquake.' .
This alternative would meet federal ARARs for the disposal of as-
bestos waste but would not meet State ARARs for disposal of a .
classB mininq waste. The site would require long term operation
and maintenance of a .more significant nature than that required
by any of the other alternatives. . This alternative includes
leaving hazardous material on-site.. Therefore, review of the
remedial action at five year intervals would be required pursuant
to CERCLA Section 121(c), 42 U.S.C. S 9621(c). Also, deed
restrictions would be placed on a large portion of Coalinqa, thus
limiting future land use.
Alternative 3 is the least costly of the alternatives which
provide active remediation. The estimated cost is between
$600,000.00 and $800,000.00. Alternative 3 could be implemented
in approximately four months. This alternative would negatively
impact the future development in Coalinga and would leave a high
public health risk in the town. .
Al~ernative 4 - Removal of Waste to an Oft-si~e Landtill
This alternative would provide adequate protection of human
health and the environment. Short term risk to human health and
the environment would be moderate and 'would occur during the on-
site operations, transport of the contaminated ~aterial, and
placement iritne new disposal location. During these operations,
engineering controls would be implemented to minimize this risk.
This alternative would achieve compliance with all ARARs. This
alternative received favorable consideration by the community.
State perception of this alternative is expected to be negative
because valuable landfill space would be occupied.
The cost of this alternative would be high. The estimated cost
is $5.5 million, with the majority of this cost being the cost of
disposing of the material in the off-site landfill. This alter-
native could be implemented in four to six months.
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14
Alternative 5- Disoosal of Material in an on-site Landtill
This alternative would provide adequate protection of human
health and the environment.. Expos~e would occur during movement
of the wastes on-site. The short term risk to public health and
the environment from this exposure route is less than that ex-
pected with Alternative 4, because contaminated materials will be
transported a shorter distance (to the WMU site). Engineering
controls would be implemented to minimize any short term risk.
This alternative would achieve compliance with all ARARs. Long
term operation and maintenance would be required, as would a
review at five year intervals pursuant to CERCLA section 121(c) ,
42 U.S.C. S 9621(c).
This: alternative raised community concerns over the location and
visual impact of the WMU. To alleviate these concerns, EPA will
require modification of the WMD specifications to reduce the
height of the WMU crown to as. close to grade level as is techni-
cally feasible. .
The cost for thls alternative is approximately $1.5 to 2~5 mil-
lion. This alternative could be implemented in approximately
four to six months.
Further Discussion of Soecific criteria
The following discussion provides a more-detailed analysis of
several of the comparative aspects of-the five alternatives.
Overall Protection of Human Health and the Environment
Alternatives 4 and 5 provide the most- protection of human health
and the environment of all the alternatives. Alternatives 4 and
5 are essentially equal in their overall protection of human
health and the environment, except that alternative 4 involves
somewhat greater exposure during implementation. While there is
no feasible treatment technology for asbestos-contalninqmlninq-""-.
materials, alternatives 4 and 5 reduce mobility of asbestos
fibers by eliminating entrainment into the air of asbestos laden
soils and dust. Alternatives 2 and 3 are not as protective of
human health and the environment in that environmental degrada-
tion may increase over time. Alternative 2 would remove the
threat to Coalinga in the short term, but would exacerbate the.
overall regional public health and environmental risks because
the mine site would receive uncontained mining waste piles. Al-
ternative 3 would leave areas containing asbestos-contaminated
soils more readily subject to disturbance by human activities as
well as natural disasters (such as an earthquake). Alternative 1
provides no protection to human health or the environment.
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15
ComDliance with ARARS .
Alternatives 4 and 5 would achieve compliance with ARARs. Alter-
natives 2 and 3 would violate the state of California ARARs for
disposal of a class B mining waste: Alternative 2 would violate
the NESHAP ARAR found at 40 C.F.R. S 61.153.
Lena-term Effectiveness and Permanence
Alternatives 4 and 5 have the qreatest ability to maintainreli-
able protection of human health and the environment over time,
once clean-up goals have been met. The disposal of the asbestos
ore wastes and other mining waste materials in an approved
landfill or waste management unit is the best way to ensure that
asbestos fibers are not released into the air, ground water or
surface water pathways. AlternativeS will achieve long-term ef-
fectiveness and permanence as long as the cap inteqrity is main-
tained.
Alternative 2 would not be as effe~tive as alternatives 4 and 5
in the long term because, in moving the material from a populated
area to a more remote area, future releases of the material from
the remote area are not mitigated. The long term effectiveness
of alternative 3 is less than that of alternatives 2, 4 and 5 be-
cause human activity or a natural disaster could more easily dis-
turb the material.
Short Term Effectiveness
Alternative 1, No Action, would have the least short term impact
because it would not generate additional dust or impact on com-
munity life, provided access to the Site was restricted. Alter-
native 3 will generate less dust than Alternatives 2, 4 and 5 be-
cause the consolidation and removal in Alternative 3 would be
restricted to the Marmac Warehouse. Alternative 2 and 4 will be
less effective in the short term than Alternatives 3 and 5 be-
cause the transportation and off-loading operations at the off-
site locations could have an adverse impact on the health of site
personnel. Alternatives 2, 3 and 4 will disrupt traffic to some
extent because they involve trucking the waste material off-site.
Alterna:tive 5 will ,have somewhat less impact on traffic iri
Coal inga. , All of the alternatives, other than No Action, will
create some'noise during removal and construction which may be
bothersome in the short term.
Communitv AcceDtance
The community would like the clean-up to proceed as quickly as .
possible and would like the contaminants to be removed from the
Coalinga city limits. Alternative 4 received the most community
acceptance. ' . . '.
4,
. -:4 ..~:.
. .. . 0»
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16
With respect to Alternative 5, community members expressed con-
cern over the location of a WMU within the city limits, par-
ticularly if the WMU is not at or close to ground level. The
Coalinga City Council expressed concern over the technical suf-
ficiency of the WMU design. The City Council also prefers the
location of the WMU to be within the right-of-way of a future
road. EPA and State officials re-examined the WMU proposal in
light of these concerns and decided to alter the design
specifications for the WMU to require that the cap be as close to
ground level as is technically feasible. This was done in order
to minimize potential impacts on local development plans. The
re-examination also confirmed that the WMU meets all regulatory
specifications. The WMU is located in an area identified as a
future right-of-way; however, the boundaries of the WMU would ex-
tend beyond the width of the right-of-way as currently designed.
EPA is not requiring that the WMU be designed to conform to cur-
rent right-of-way plans; however, EPA is not putting restrictions
on land use in the WMU area that would preclude the area being
used as a road or a parking structure.
The community is not in favor of Alternative 3 because it would
remove too much land from future development. Community accept-
ance of Alternative 2 is expected to be favorable based on the
community's express desire to have the hazardous substances
removed from the City.
The attached Responsiveness Summary attached addresses more
specific concerns raised by members of the public during the
public comment period.
10.0 APPLICABLE QTT PET.T?VANT and APPROPRIATE REQUIREMENTS fARARs)
Under Section 121(d)(l) of CERCLA, 42 U.S.C. § (d)(l), remedial
actions must attain a degree of clean-up which assures protection
of human health and the environment. Additionally, remedial ac-
tions that leave.any hazardous substance, pollutant, or con-
taminant on-site must meet a level or standard of control that at
least attains standards, requirements, limitations, or criteria
that are "applicable or relevant and appropriate11 under the cir-
cumstances of the release. These requirements, known as "ARARs",
may be waived in certain instances, as stated in Section
121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
"Applicable" requirements are those clean-up standards, stan-
dards of control and other substantive environmental protection
requirements, criteria, or limitations promulgated under federal
or state law that specifically address a hazardous substance,
pollutant or contaminant, remedial action, location, or other
circumstance at a CERCLA site. "Relevant and appropriate1* re-
quirements are clean-up standards, standards of control and other
substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law that, while
not "applicable" to a hazardous substance, pollutant, con-
taminant, remedial action, location, or other circumstance at a
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17
CERCLA site, address problems or situations sUfficiently similar
to those encountered at the CERCLA site that their. use is well-
suited to the particular site. For example, requirements may be
relevant and appropriate if they would be "applicable" but for
jurisdictional restrictions associated with the requirement. See
the National Contingency Plan, 40 C.F.R. Section 300.6, 1986).
The determination of which requirements are "relevant and ap-
propriate" is somewhat flexible. EPA and the State may look to
the type of remedial actions contemplated, the hazardous sub-
. stances present, the waste characteristics, the physical charac-
teristics of the site, and other appropriate factors. It is pos-
sible for only part of a requirement to be considered relevant
and appropriate. Additionally, only substantive requirements
need be followed. If no ARAR covers a particular situation, or
if an ARAR is not sufficient to protect human health or the en-
vironment, then non-promulgated standards, criteria, guidance,
and advisories must be used to provide a protective remedy.
Tvoes of ARARs
There are three types of ARARs. The first type includes
"contaminant specific" require~ents. These ARARs set limits on
concentrations of specific hazardous substance, pollutants"and
contaminants in the environment. Examples of this type ofARAR
are ambient water quality criteria and drinking water standards.
The second type of ARAR includes location-specific requirements
that. set restrictions on certain types of activities based on
site characteristics. These include restriction on activities in
wetlands, floodplains, and historic sites. The third type of
ARAR includes action-specific requirements. These are
technology-based restrictions which are triggered by the type of
action under consideration. Examples of action-specific ARARs
are Resource Conservation and Recovery Act ("RCRA") regulations
for waste treatment, storage, and disposal.
ARAR Identification Process
ARARs must be identified on a site-specific basis from informa-
tion about specific chemicals at the site, specific features of
the site location, and actions that are being considered as
remedies. .
ARARs identified for the Operable Unit address emission of asbes-
tos fibers from contaminated soils, inhalation of asbestos
fibers, and disposal of asbestos contaminated soils. In addi-
tion~ ARARs for disposal of mining waste containing soluble
nickel were also identified.
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18
contaminant-SDecific ARARs For Asbestos:
1. Toxic Substances Control Act (TSCA)
EPA has promulgated several rules under TSCA to requlate'asbestos .
in the environment. The most siqnificant of these were promul-
gated pursuant to the Asbestos Hazard Emergency Response Act
, ("AHERA"), whiCh was enacted as Title II of TSCA. Under the
AHERA, EPAissued requlations related to the inspection and
management of friable asbestos in schools (52 C.F.R. S 42826
(1987». This requlation utilizes PLM as a measurement techniqUe
for detecting asbestos1 the use of this measurement technique for
asbestos is relevant and appropriate to the cleanup of the
Coalinga Site.
'. ,
2. Clean Air Act. National Emission standard for Hazardous Air
Pollutants (NESHAPs) ,
Asbestos was first desiqnated as a hazardous air pollutant under
the Clean Air Act in 1911. The National Emission Standard for
Hazardous Air Pollutants (WNESHAPsW) for asbestos found at 40
C.F.R. S 61.,152 and 40 C.F.R. S 61.156 are ARARs for the im-
plementation of the remedy at this site. 40 C.F.R. S 61.153 is
an ARAR for the completion of the remedy at the Site.
Location-SDecific ARARs:
Because the site is located in an area that contains endangered
species (i.e., the kit fox and the blunt-nosed leopard lizard),
the following requirements are ARARs for the Site:
1.
The Endanaered SDeciesAct of 1973. 16 U.S.C. ~ 1536(a} (-(d)
Generally, when a project potentially impacts an endangered
species or. critical habitat, activities carried out by Federal
agencies should not jeopardize the continued existence of an: 'eri~
dangered species or cause adverse modifications of critical
habitat.
2. USFWS Mitiaation Policy (FR 7644-7663. Vol 46. No. 15. Januarv
1981).
This policy is triqgered in accordance with the Fish and Wildlife
Act of 1956, Fish and Wildlife Coordination Act, Watershed
Protection and Flood Prevention Act and the National Environmen-
tal Policy Act. The mitigation policy defines resource
categories and establishes mitigation qoals and quidelines for
each. Guidelines to achieve the goal include avoiding or mini-
mizinq habitat loss, immediate rectification or reduction of
habitat loss or replacement of habitat in kind.
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19
Action Scecific ARARs:
1. Occucational Safety and Health Administration ("OSHA")
OSHA has set a permissible exposure limit ("PEL") for all asbes-
tos fibers at 0.2 fiber per cc for occupationally exposed workers
(51 C.F.R. S 22612 (1986)). While this standard was meant for
occupational exposure (8 hours per day, 40 hours per week, 52
weeks per year) and not for continuous ambient exposure, it
provides an upper threshold for evaluating permissible ambient
exposure limits. " In other words, a concentration of .2 PCM
fibers per cc of respirable air or less is not permissible for
ambient exposure, since this requirement is relevant and ap-
propriate for exposure during the cleanup of this Site.
Contaminant-Scecific ARARS for Soluble Heavv Metals:"
1. California Administrative Code. Title 22
Title 22, Chapter 30, section 66740 (a) of the California Ad-
ministrativeCode ,lists "...wastes which shall be classifiable as
special wastes pursuant to Section 66744 provided they meet the
criteria and requirements of Section 66742". The California
State Water Quality Control Board ("SWQCB") has classified
nickel-containing wastes such as those at the Site as Class B
mining wastes, as "described in Title 23, Chapter 3, subchapter
15, section 2571(b) (2). Under California regulations (Title 23,
Subchapter 15) a Class B mining waste must be disposed of in a
capped landfill. "This requirement "is an ARAR for the Site.
Location Scecific ARARsfor Soluble Heavv Metals:
1.
California Administrative Code
Pursuant to Title 23, Chapter 3, Subchapter 15, Article 7, Sec-
tion 2570(b), a mining waste pile, including a waste management
unit, may be exempted from the liners and leachate collection and
removal system requirements of Article 7, Section 2572, if it can
be demonstrated that leachate will not form in or escape from the
waste management unit ("WMU"). Section 2570(c) allows the RWQCB
to exempt a Group B mining waste management unit from these liner
and leachate requirements of Article 7 if a comprehensive .
hydrogeologic investigation demonstrates that: "
II (1) there are only very minor amounts of groundwater underly-
ing the area; or
(2) the discharge is in compliance with the applicable water
quality control plan; and
(3) either natural conditions or containment structures will
prevent lateral hydraulic interconnection with natural geologic
materials containing ground water suitable for agricultural,
domestic or municipal beneficial uses. There is no detectable
vertical hydraulic interconnection between the natural geologic
materials underlying the unit and natural geologic materials con-
taining such ground water." Article 7, Section 2570(c).
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20
. . .
The WMU for this site is appropriately exempted from these liner
and leachate provisions on the basis that the requirements of Ar-
ticle 7, Section 2570(c) (1), and alternatively, the requirements
of (2) and (3), are met. See the memorandum from the California
Central Valley Regional Water Quality Control Board ("CVRWQCS"),
dated April 7, 1989, Administrative Record Doc. # 1075, attached
as Appendix 2 to this ROD, and hereby incorporated by reference.
The requirements of this Appendix 2 must be met for full im-
plementation of this ROD. .
. . ,
The Class S mining waste requlations found at Title 23, Chapter
3, Subchapter 15, Section 2571, (b) (2) (A) of the California Ad-
ministrative Code are satisfied by either (1) removal of the as-
bestos ore waste and other mining waste to a capped landfill or
(2) burial of the asbestos ore waste and other mining waste in an
on-site WMU. Cap requirements are outlined in Title 23, Chapter
3, Subchapter 15. If the waste is stored in an on-site WMD, the
requlationsrequire that a groundwater monitoring be located at
the point(s) of compliance. Title 23, Chapter 3, Subchapter 15,
Section 2553. .
11.0 THE SELECTED REMEDY
Alternative 5, disposal of the asbestos ore waste and other min-
ing waste in an on-site waste management unit ("WMU"), is the
selected remedy for the City of Coalinga Operable Unit. This in-
cludes collection and on-site disposal of all asbestos ore waste
and other mining waste material as well as decontamination of all
buildings, structures and other equipment at the Site.' The ex-
cavated areas will be regraded with cl~an material, containing
less than. or equal to one area percent asbestos by PLM. The WMU
will be constructed in accordance with California Administrative
Code, Title 23, Chapter 3, Subchapter 15; the WMU is exempt from
the liner and leachate collection requirements of Article 7 of
this Subchapter. .u, .'. _. _.' '. ' ...~ "'., -... ,..". .
The wastes are'asbestos with some soluble nickel. Asbestos is
insoluble and thus poses does not pose a siqnificantthreat to
the groundwater. Any leachate movement through the unsaturated
zone to the ground water will be very slow and is unlikely to
carry asbestos in suspension. The waste does not generate acid
and therefore leachate containing soluble nickel is not likely to
be produced~ In addition, the ground water in the Coalinga area
is not potable. All of the drinking water used by the City of
Coalinga is taken from the California Aqueduct.
All contaminated soils and other similar materials will be
cleaned up to less than or equal to one area percent. asbestos by
PLM and to at or below background for nickel. A positive cor-
relation between the presence of asbestos and nickel has been es-
tablished at the site. As the asbestos-contaminated areas are
being remediated, the nickel-contaminated areas will also be
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21
remediated. The cont~inated soils and other materials occupy an
area of approximately 11, acres and total approximately 14,500
cubic yards. .
A major feature of the selected remedy is the construction of the
WMU. The WMU will measure approximately 225 feet square, have a
capacity of 25,000 cubic yards and will be designed and con-
structed to comply with all ARARs. The final cover or cap will
consist of th~ following (from bottom to top):
A two foot. foundation layer of compacted clean material
that contains less than or equal to 1 area percent asbestos by
PLM.
--,A one quarter inch impermeable bentonite mat with a per-
meability of less.than 10 E -6 em/sec.
A protective soil cover that contains less than or equal
to one area percent asbestos by PLM and is at .least one foot in
thickness. ' ".' .
. Either a four inch asphalt concrete paving or a
vegetated cover.
. .
The design will inc~ude two neutron probe access tubes to detect
increases in moisture content due to leachate migration. In ad-
dition, ground water monitoring welles) will be required within
one quarter mile of the perimete~ of the WMU.
The WMU will be constructed to prevent the ponding of water on
the cap. The cap will be situated as ,close to grade level as is
feasible. strict asbestos/dust control measures will be imple-
mented during the entire construction of the WMU and the collec-
tio~ and consolidation of the asbestos ore waste and ,other mining
material. These activities will comply with the NESHAPs ARARs.
.In addition, ambient air sampling (with associated meteorological
monitoring) and personnel monitoring will be conducted during
construction and removal activities to fulfill the following ob-
jectives:
1) Ensure that asbestos/dust control measures are effective
in containing ~ugitive contaminant emissions,
2) Ensure that the remedial activity is not affecting the
surrounding community through the spread of fugitive asbestos
fibers, and
3) Document exposure levels of site persohnel work ac-
tivities to determine compliance with appropriate levels of
protection for workers.
&:. .'''.;.'.
. .
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22
.
A verification sampling plan will be instituted to confirm that
the cleanup levels have been achieved for the soil and other
materials. The building structures will also be sampled to
verify removal of asbestos from contaminated surfaces.
operation and maintenance activities will be required to ensure
the effectiveness of the WMD. These activities include: (1)
quarterly visual inspections to ensure the inteqrity of the cap
for three years, with annual visual inspections thereafter, (2)
'any repair work necessary to maintain the inteqrity of the cap,
including maintenance of the vegetation, (3) groundwater monitor-
ing, and (4) monitoring of soil moisture content using neutron
probes. EPA will review the remedial actions effectiveness at
five year intervals, pursuant to CERCLA Section 121(c), 420.S.C.
S 9621(c). '
"
The chromite ore waste ("chromite waste") in' the Marmac Warehouse
will be disposed of in the WMD unless the chromite waste has been
removed from the site by October 16, 1989, pursuant to an EPA ap-
proved plan. Any draft plan for removal and disposition of the
chromite waste, must be submitted to EPA by Auqust 15, 1989 and
must include: '
. "..:
'1. an adequate health and safety plan that protects on-site'
personnel:' , '
2. a work plan that provides for the safe removal of the
chromite waste material from the Marmac Warehouse and transport
to a bona fide recycling/reprocessing facility for recycling
and/or reprocessing: . .
3. adequate documentation trom a bona fide
recycler/reprocessor that the chromite waste will be handled
properly upon receipt at the recycling/reprocessing facility.
This documentation must include, but is not limited to: a) copies
of all necessary permits, b) details of process to be used to ex-
tract the chromium, and c) details of how any asbestos- .
contaminated residue will be disposed of: and
4. . provisions,for, compliance with all ,applicable-laws ""'..-,--,".
regarding transport of hazardous substances
A final plan must have received EPA approval by September 15,'
1989.
The WMU design and associated monitoring activities will be in
accordance with the recommendations provided in the CVRWQCB
memorandum of April 7, 1989, attached as appendix 2. In
addition, a geologist registered by the State of California
will observe the excavation of the WHO area to ensure that no
geologic faults occur in the area of the WHO.
Using a conservative estimate of $2.5 million, the cost for dis-
posal in the WMD is estimated at $170 per cubic yard, assuming
14,500 cubic yards of contaminated material. Operation and
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I.
23
maintenance costs are estimated at $35,000/year. Total present
worth cost for the selected alternative is between 1.5 and 2.5
million dollars. .
12.0
DOCUMENTATION of SIGNIFICANT CHANGES
The selected alternative for the Site is construction of an on-
site WHO and accompanying measures, as detailed in Section 11.0,
above. At this time no significant changes from the proposed
plan have occurred.
13.0
STATUTORY DETERMINATIONS
Overall Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
minimizing exposure to asbestos- and nickel-contaminated
materials. The selected remedy also provides for clean-up to the
AHERA levels for asbestos abatement and to levels at or below
background levels for nickel. . Proper operation and maintenance
practices will ensure the integrity of the WMU.Strict dust con-
trol procedures will be followed during construction. Proper
health and safety measures, including ambient air monitoring and
personnel monitoring during implementation, will ensure that the
health of on-site workers and the local population is protected.
Cost-Effectiveness
The selected remedy is cost-effective in that it provides overall
effectiveness commensurate to its costs. The estimated costs of
the selected remedy are less than half the costs associated with
the removal of the waste to anoff-slte landfill (Alternative 4),
and yet the selected remedy and Alternative 4 are similar in
terms of the level of public health and environmental protection
provided, except that off-site disposal would involve somewhat
greater exposure risk during implementation.
ComDliance with ARARs
The selected remedy will comply with all ARARs.
are presented below.
Action~SDecific ARARs
Identified ARARs
OSHA requirements for permissible exposure limit (PEL) in 51
C.F.R. 22612 (1986), which specify a PEL for all asbestos
fibers at 0.2 fibers per cubic centimeter for occupationally
exposed workers.. .
contaminant-sDecific ARARs
PLM measurement technique~for asbestos, pursuant to AHERA
regulations.
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. '." '"....-'
24
NESHAP requirements found at in 40C.F.R. S 61.152, 40
C.F.R. S 61.153, and 40 C.F.R.
S 61.156.
Title 22, Chapter 30, Section 66740(a) of the California
Administra~ive Code, which classifies the nickel-bearing
waste as a special waste. .
Title 23, Chapter 3, Subchapter 15, Article 7, section
2571(b) (2), which classifies the waste as a class B min-
ing waste. Under Subchapter 15, class B mining wastes
must be disposed of in a capped landfill. The WMU is
exempt (pursuant to Section 2570) from the liner and
~eachate requirements found in Article 7 of this Sub-
chapter. .
Location-SDecific ARARs
Endangered Species Act of 1973, 16 U.S.C. S 1536 4(a) -
(d), regarding endangered species and critical habitat.
USFWS Mitigation POlicy establishes. guidelines for mini-
mizing habitat loss (Fa 7644-7663 Volume 46 number 15
January 1981).
Utilization of Permanent Solutions to the Maximum Extent Prac-
ticable
Currently there is no known permanent treatment or resource tech-
nology. which would control release of asbestos from the soil at
the Site. Chemical fixation and thermal vitrification were al-
ternatives identified in the Feasibility Study but they were
eliminated from further consideration due to difficulties as-
sociated wi.th implementation, uncertain long term effectiveness
and very high cost. Of those alternatives that are protective of
human health and the environment and " comply with ARARs, EPA has
determined, and "the state has concurred, that the selected "remedy"."- -
provides the best balance of the various factors that CERCLA re-
quires be considered in remedy selection. .
The select~dremedy is preferable to off-site disposal with
respect to short term effectiveness and cost. Since the selected
remedy and the off-site disposal alternative are reasonably com-
parable with respect to protection of public health and the en-
vironment, long term effectiveness, ARARs compliance, and im-
plementability, the major tradeoffs that provide a basis for this
selection decision are short term effectiveness, community ac-
ceptance, state acceptance, and cost.. The selected remedy has
better short term effectiveness, is more acceptable to the state,
and can be performed at less cost than the other alternatives: it
also can be performed in arelativ~ly short time frame compared
to some of the alternatives. It is therefore determined to be
the most appropriate solution for the contaminated soils at the
City of Coalinga Operable Unit.
-------
2S
Preference for Treatment as a Principai Element
CUrrently there is no proven treatment technology that would per-
manently and significantly reduce the mobility, toxicity or
volume of asbestos. Since no effective treatment method exists
for asbestos, the statutory preference for this type of treatment
as a principle element of the remedy cannot be satisfied. Al-
though several treatment technologies were investigated during
the feasibility study, it was determined that no technology
presently exists that would result in a permanent and,significant
decrease in the ~oxicity, mobility or volume of asbestos. Alter-
native S was found to represent the best method for addressing
the threats posed by the Site, taking into account all of the
statutory requirements and preferences.
. .
-------
....
CITY OF COALINGA
ADMINISTRATIVE RECORD INDEX
This index is arranged using the following subject categories.
Within each category the documents are arranged by the document
number found in the Index.
.'
01.
0100.15
0100.20
0100.25
05.
..
0500.01
" ," 0500.10
. . . 0500.20
0500.25
0500.30
14.
1401.01
1401.05
1401.15
1401.20
1401.25
1401. 30
1401.35
1401.40
1401.45
1401.50
1401. 52
1401.55'
1401. 57
1401.60
70.
7000.01
7000.15
7000.20
7000.50
7500.00
80.
8000.25
Site Identification
Background .
Notification/Site Discovery
PA/SI (Preliminary Assessment/Site
Reports
PRP (Potentially Responsible Party) Documents
Investigation)
Correspondence
Records of Communication
PRP-Gen$rated Reports and Data
104(e) Letters .'
General Notice and Specia~ Notice
Letters
RI/FS (Remedial ~nvestigation/Feasibi1ity Study)
Correspondence
Internal Memos
Work Plan
Sampling & Analysis Plan
Health and Safety Plan .
Site Access Letters/Orders/Litigation
Compliance Monitoring and Enforcement
Sampling and Analysis Data
Data Validation Reports
RI/FS Reports .
Comments on RI/FS Reports
Health BiskjEndangerment Assessments
Enviromnental Studies .
ARAR Information '-~'.'-' -'.." -"'''..-
. ',... "'.~_.' - .,'. ...-'.. .
. . ~.......... ,','';-''.8 ....: . ".."-'~' ;:-.. ..-
Community Involvement
Correspondence
Community Relations Plan (CRPJ
Fact Sheets, Press Releases, Public
Histories
Relocation and Evacuation
Notices, Site
Congressional Correspondence
FOIA (Freedom of Information Act) Requests and
Responses
Exemption Claims
-------
~
James T. Allen
Bruce AngiOlillo
Greg Baker
Lowell Baker
G. Dale Barnhill.
A.R. Batterman
Robert K. Behrens
Richard E. Blubaugh
Phil Bobel
Randy BOltin.
R.E. Bolton
Ronald Bowmann
Charles W. Bridges
Claude Bridges
Wayne Broome
Kevin Browne
, Garry J. Burdett
Gary Carozza
Joseph P. Carullo
Chris Chalfan
Earl Chambers
E.J. Chatfield
John D.. Clarke
Tony Coelho
David L. Coffin
Kathleen Conway
Philip M. Cook
Robert C. Cooper
Joseph Cotruvo
Frank M. Covington
Darrel S. Cowan ..
Floyd Crable (Crabell)
John E. craighead
Greg Czajkowski
J. David'Dean
Jennifer (Jenny) Decker
Michele Dermer
John DeVaney
Kelley J. Donham
Steve Drew
A.J. Eyraud
Gary .Fairbanks
Melanie Field
James Gideon
Rick Gooch
DIRECTORY OF ~S
AFFILIATION
California Dept. of Health Services
Simpson, Thatcher & Bartlett
US Environmental Protection Agency
Wests ide Trucking Co. .
International Technology Corp.
US Environmental Protection Agency
Law Offices of McInturff, Behrens &
Snyder. .
Atlas Minerals
US Environmental Protection Agency
McCrone Env. Serve
Institute of Occupation Medicine
Union Carbide .
Law Offices of Bridges & Bridges
California Minerals Corp.
Kern County Land Co.
Cape Industries Ltd.
Occupational Medicine & Hygiene
Laboratory
Fresno Dept. of Health Services
Santa Fe Energy Co.
California Regional Water Quality
Control Board - Central Valley
Region
MarmacResources Co.
Ontario Research Foundation
Asbury Oil Co.. .
US House of Representatives
US Environmental Protection Agency
US Environmental Protection Agency
US Environmental Protection Agency
University of California, Berkeley
US Environmental Protection Agency
US Environmental Protection Agency
Stanford University
Marmac Resources co.
University of Vermont
US Environmental Protection Agency
Woodward-Clyde
US Environmental Protection Agency
US Environmental Protection Agency
Atlas Asbestos
University of Iowa
US Environmental Protection Agency
Asbury Transportation Co.
PG&E . .
US Environmental Protection Agency
Engineering Control Technology
Branch, DPSE . .
Southern Pacific Transportation Co.
-------
Directory - Page 2
Michael R. Gray
Richard A. 'Griesemer
Konrad (Conrad) Harper
Donald Harvey
C.F. Harwood
Don Hawkin$
. "
Stephen B. Hayward
R. Nicholas Hazlewood
Edward Heine '
Martha Hennly
Bruce A. Hollett
Dave Howell
Larry Hunter
Scott Huntsman
Dan Hutton
Carla J. Irvine
Walter John
Eve Johnson
Richard Johnson
Sue Johnson
Jeanine Jones
Marty J. Kanarek
G.M. Kay
Sean Kennedy
Steve Kerdoon
Ronald D. lei11.
Robert (Bob) King
Kent Kitchingman
John Kraemer
Donna LaBar
Myron Levin
Nancy Lindsay
Morton Lipman
David Long
Gai 1. Louis '---"~--'---' ,".'-----.,
Jeffrey A. Lybarger
Kevin Maroff
Gary M., Marsh
Richard Martyn
Leland J. McCabe
Daniel McGovern
Michael J. McGuire
D.K. McNear
James R. Millette
L.L. Mitchell
Irving Moore
Kino Hospital
US Environmental Protection Agency
Atlas Asbestos
,Woodward-Clyde
IIT Research Institute
Agency for Toxic Substances and
Disease Registry
California Dept. of Health Services
International Technology Corp.
, Vinnell Mining & Milling Corp.
California Dept. of Health services
US Dept. of Health & Human Services
Bureau of Land Management
Marmac Resources Co.
Woodward-Clyde
Camp Dresser & McKee
Shield & S~ith '
California Depe. of Bea1.th Services
Jacobs Engineering .
California Bureau of Land
Management
Jacobs Engineering
California Dept. of Health Services
University of Wisconsin .
Canade Ministry of the Environment
Ecology & Environment
Asbury Oi 1 Co.
us. Environmental Protection Agency
City of Coalinga
US Environmental Protection Agency
PG&E
CH2M Hill
LA Times
US Environmental Protection Agency
New York University
Southern Pacific Transportation Co.
US,EnvironmentalProtectio~Agency,
Agency for Toxic Substances and
Disease Registry
Southern Pacific Transportation Co.
University of Pittsburgh
US Environmental Protection Agency
US Environmental Protection Agency/
Health Effects Research Laboratory
US Environmental Protection Agency
Metropolitan Water District of
Southern California
Southern Pacific Transportation Co.
US Environmental Protection Agency/
Health Effects Research Laboratory
US General Services Administration
Wheeler Properties '
-------
Directory - Page 3
Ruben Moreno
Penelope Morton
Brooke T. Mossman
G.L. Murdoch,
William J. Nicholson
George Nokes
David Noyes
Lalita D. Palekar '
Kusum J. Patel-Manalik
L.W. (Wayne) Pepple
Bob Perkins
Kent E. Pinkerton
Thomas J. Powers
Dean Prettyman
Kenneth B. Prindle
Malcolm Ross
Lee QuiCk' ,
Michae1 C. Richards
Charles E. Robinson
Dennis M. Robinson
George M.C. Robinson
Susan Robinson
D. Scott Rohlfs
T.C. (Thomas) Sager
,Roland A. Sanford
MarvinA. SChneiderman
Eunice E. Sigurdson
Stewart Simpson
Bhawan Singh'
David M. Smith
M.R. Smolen
David B. Stanton
Mearl F. Stanton
Eric B. Steele'
Edward L. Strohbehn
David Suder
Keith Takata
Lee M. Thomas
V. Timbrell '
Richard G. Tisch
P. Toft
...'. .
Ida Tol1.iver
Mark Unruh
Al Vargas
Richard B. Von,
Jon K. Wactor '
Lonnie Wass
Wald
Geoff Watkins
Mr. Weavers
California Regional Water Quality
Control Board - Central Valley
Region
University of Minnesota
University of Vermont,
Southern Pacific Transportaion Co.
City University of New York
California Fish & Game Commission
JOhns-Manville Corporation
Northrup Services, Inc.
Technocrats Inc.
Southern Pac,ific Transportation Co.
RTI '
Duke University
US Environmental Protection Agency
Asbury Transportation Company
Schell & Delamer
US Geological Survey
Interstate Towing Services
Camp Dresser & McKee
Levine-Fricke .
International TechnOlogy Corp.
Western Technologies Inc.
Federal Emergency Management System
City of Coalinga '
Santa Fe Pacific Realty Corp.
Woodward-Clyde
Clement Associates
Minnesota Dept. of Health
U~ Environmental Protection Agency
Universite de Montreal
Los Alamos National Lab
Union Carbide
Tenneco West,
California Dept. of Health Services
National Bureau of Standards'
MCCutcheon, Doyle, Brown & Enerson
Woodward-Clyde
US Environmental Protection Agency
OS Environmental Protection Agency
Llandough Hospital
Union Carbide
Canadian Dept. of National Health
and Welfare
US Environmental Protection Agency
International Technology Corp.
Ecology & Environment
JOhns-Manville Corporation.
US Environmental Protection Agency
California Regional Water Quality
Control Board
Jacobs Engineering
Atlas Corporation,
-------
Directory - Page 4
L.R. White Mobile Home Service
Bill Wick US Environmental Protection Agency
Robert D. Willey International Technology Corp.
John Wise US Environmental Protection Agency
Richard S. Woodhill Connecticut State Dept. of Health
Leonard O. Yamamoto International Technology Corp.
Terry F. Yosie US Environmental Protection Agency
Jeff Zelikson US Environmental Protection Agency
Amy Zimpfer us Environmental Protection Agency
R.A. ZisJcind Science Applications, Inc.
Ralph D. Zumvalde California Dept. of Health Services
-------
Page No.
02/28/89
Atlas and Johns-Manville Coalinga Superf~ Sites
City of Coalinga Operable unit
ADMINISTRATIVE RECORD INDEX'
DOCUMENT
CATEGORY'
DOCUMENT
NUMBER.
DESCRIPTlCN
SUBJECT
Faa.
TO
DOCUMENT
DATE
0100.15 566 Review: Asbestos Exposure Morton Lippnan 7/18/87
Indices
0100.15 567 Asbestos Exposure Indices Morton L\ppI8I\ 2/88
0100.15 573 LOI'III- te... Health Effects an DavId N. SIIIlth 10/28/86
Hamsters end Rat.
0100.15 574 Hea(th Effect. of Asbestos Richard A. Griesemer Lee M.' ThOllla. 7/30185
If/letter
0100.15 575 Update of SA8 ActiV11:ies . Kathleen Conway Lee M. Thomas 6/12/85
w/-
0100.15 576 Major lasues Asaociated witb selenee Advisory no date
Health Effects of Asbestos Board
0100.15 577 Semi-quantitative P.M. Coot no date
DeteMllination of Asbesttfo".
0100.15 578 Inhalation of Fibrous DusU V. TilJt)reU 12/31/65
(Arnals "Y'AS)
..
0100.15 579 Reserve Mln;ng ~ Lake no date
DUlping
01DO~15 580 Asbestos in Drinking Water - A P. Toft no date
Canadian View
0100.15 581 Adverse Health Effects 01 no date
Arsenic and Asbestos
0100.15 582 ' Environnental Effects 01 Robert H. Webb no date
Off-road Vehicles
0100.15 583 Asbestos: Propert;es, S.S. OIissick no date
Applications & Hazards, vol. 2
0100.15 584 In vi tro Approaches for Brooke T. Mossman .no date
Detennining:Mechanisms 01
Toxicity
0100.15 585 Critical Review of Gary M. Marsh 10/13/82
Epidemiologic Studies
-------
Page No.
02/28/89
2
(
AUas end Johns-Manville Coatinga S~rf&nf Sites
City of Coatinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCLICENT
CATEGORY
DOCUMEIIT
IUIBER
DESCRIPTION
SUBJECT
FROM
TO
DOCLICEIIT '
OAT!
0100.15 586 Characteristic Values for no date
Asbestos
0100.15 587 Electron Microscopy & X.ray Philip A. Russell no date
Appttcations: Chepter 11
':-; ~: :~~ 0100.15 588 Membr~-filter Gerry J. ~tt no date
Direct-transfer Technique for'
Analysis
0100.15 589 Asbestos in the Hame US Cons..-r pro4ct no date
safety CCllllli as i on
0100.15 590 Asbestos fact Book EPA 5/86
0100.15 591 Asbestos in Schools no date
(I' 0100.15 592 Methodology for the Analysis Stephen B. Hayward no date
of Asbestos in SoU.
0100.15 593 Asbestos in Buildings EP~ 7/85
0100.15 594 Asbestos in Drinking Water Kevin Browne no date
0100.15 596 Region 9 "...t- M- EPA 6/87
0100.15 ,,<. 597. , Ur re: ,Asbestos Exposure at .. . , Kenneth II. ' '. ..L.L.MitcheU ~ .. 816/84
Federal Building & Courthouse Wallingford
. .
0100.15 599 ASTOR Policy on Health 5/87
. Assessments
0100.15 601 SUperfund Public Health EPA 10/86
Evalwtion Matual'
0100.15 602 EPA: National Revised PrilllBry Federal Register, 10/5/83
Drinking Water Reg. vol. 48, no. 194
0100.15 627 Strategy for Asbestos Hazard ICF/Clement Camp Dresser & McKee 9/18/87
Identification Associates
0100.15 628 Technical Support Doc: Publ ic CA Air Resources 2/10/86
Hearing to Consider the Board
Adoption of a Reg. Amend.
-------
Page No.
02/28/89
3
Atlas and Johns-Manville Coalinga Supe~fund Sites
City of Coal inga Ope~able Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCR I PTI OIl
SUBJECT
fRCM
TO
DOClI4ENT
DATE
0100.15 629 Ad)fent \late~ Quality EPA 1978
C~fteria: ASbestos
0100.15 630 lnte~i. Method fo~ the UP EPA 12/82
Detenafnation of Asbestos in
Bulk Insulation ~l..
0100.15 631 Fede~81 Re;i.t.~ v. 50, no. 11/13/85
219: Asbestos
0100.15 632 Memo A: fU:l fo~ Asbestos in fnnlt M. Covington John \lise 11/15/83
Drinking \later
0100.15 633 G~oundwate~Newalette~ v. 12, Ronald D. IClll Richa~ Ma~tyn 12/1/83
no. 20 (Oct~ 31, 1983)
w/lette~
0100.15 634 EPA: 4D Cfll Pt. 61 NationaL federaL Register, 1,15/84
Elllllis.,on St.... fv vo\. 1,9, no. 67
Hazardous AI~ Pollutants..
Fil'll!l Rule
0100.15 635 Repo~ts on Health Effects of . Joseph A. Cotruvo Te~ry F. Yosle 1,112/85
Asbestosw/lette~
0100.15 636 Technical Comments ~e: Health Rlcha~ A. G~iesene~ Lee M. Thcmas 7130/85
Effects of Asbestos w/letter
0100.15 637 £PA Envf ~omental News I. Fact EPA 1/16/86
Sheet on Asbestos
0100.15 638 EPA: 40 CFRPt. 763: Asbestos, Federal Register, 1/29/86
.. . P~oposed Mining I. Iq:IOrt vOl..51, no. 19
Rest~lctions I. P~oposed
Manufactu~ing Iq:lOrtation I.
P~ocessing P~ohibitions
0100.15 639 Asbestos Waste Management EPA no date
Guidance
0100.15 640 EPA: Wate~ Quality Crlte~ia Fede~al Register, 11/28/80
Documents, Availability vol. 1,5, no. 231
0100.15 665 Iq:IO~tance of \lind-blown Dust EPA 1/88
in Risk Assessment
. ...
"0 - .
. ,
-------
...
Page No.
02/28/89
4
,
. ..
. ,
Atlas and Johns.Manville Coalinga Superf\ftt Sites
. City of Coalinga Operable unit
ADMINISTRATIVE RECORD INDEX
DOCUIENT
CATEGORY
Doa.t4ENT
NUMBER
DESCRIPTION
. SUBJECT
FRON
TO
DOCUCENT
DATE
0100.15 666 Appl ication of TEN to Aaf)ient Bruce A. Hollett Melanie Field V1/88
Monitoring wi letter
0100.15 667 fPA Study of EPA 2/88
Asbestos-contatning Matertal.
.," 0100.15 668 Toxilogical Profile for 1/16188
':":."~:;': ATSOR
" .. lIickel. Draft
0100.15 669 Microscopical lmovations for John Gustav Delly 4/87
Asbestos Analysi.
0100.15 670 AsbestffOl'8l Fibere; lIational Research 8/1/84
Nonoccupattonat Health Risks Counc il
0100.15 671 Asbestos in aui ldings: EPA 5/88
Technical Bulletin
( '0100.15 672 Airborne Levels of Mineral Villi.. J. Nicholson no date
Fibre
0100.15 673 Environnental Asbestos: Jennifer A. Decker no date
."- Problems Associated with PLM
..~ Soil Analysts
0100.15 708 Minerals and ftea\!b; The Malcolm Ross no date
. ...' .. "1. .-.. . .."' . -~ ... ..., '.- .4.~.'-'-,,,,7'. ,-",""-'-."""-' ,''''- .. - .,....,." .'....r~"
~s'tIestos torOblelll
0100.15 709 Asbestos: TOII8rd a Perspective H. Vesley Peirce 1983
0100.15 710 ' CC8Iiercial Lab0r'8tories with Research Triangle 8/87
Polarhl8d Upt ,"croscope Institute
0100.15 711 Ban of Consuner Patch i ng 16 CFR Chapter 11 1/1/85
C~
0100.15 712 Chrysotile Asbestos in a Science, vol. 206 11/9119
California Recreation Area
0100.15 713 EPA: 40 CFR Pt 763: Federal Register, 10130/87
Asbestos'containing Materials vol. 52, ,no. 210
in Schools, Final rule and
Notice
I
,
-------
Page 110.
02/28/89
5
Atlas and Johns-Manville Coal inga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FRC»t
TO
DOCtI4ENT
DATE
0100.15 714 OSHA, 29CFR Pt. 1910 and 1926 Federal Register, 6/20/86
OcC\4)8tional Exposure to vol. 51, no. 119
Asbestos... Finial Rules
0100.15 715 Asbestos in "ater S~l les of James R. Millette no date
the U.S.
0100.15 716 Asbestos (c&EII) Panela S. Zurer/~II 3/4/85
0100.15 717 Fact Sheet: Asbestos In 3/1/83
Drinking "ater
0100.15 734 Ltr re: Occurrences of Special Stephen (illeglble)1 Donna La Bar 11/8/83
Ani-ls end Plants CA Dept. of Fish end
Game
0100.15 735 Map: California lIatural CA Dept. of Fish end 10/83
Diversity Data Base Game
0100.15 834 Properties of Fine Particles Penelope Morton 1/85
Which Govern Their Biological
Activity
0100.15 835 Asbestos Bunker Hill SCR no elate
0100.15 836 Ltr re: Comments on Asbest8s Ralph D. Zunwalde James Gideon 4/24/85
Abatement Techniques
0100.15 837 Asbestos 7110/85
0100.15 838 Fil ter Blenk Contamination in Thomas J. Powers 4/24/86
Asbestos Abatement
0100.15 839 Characterization of Three !Cent E. Pinkerton 1983
Types of Chrysotlle Asbestos
0100.15 840 Correlation of In Vitro And David L. Coffin 1983
Vivo Methods
0100.15 841 Asbestos Analysis Case History Michael J. McGuire 9/82
0100.15 842 Asbestos Analysis Case History Michael J. McGuire 1218/81
0100.15 843 Asbestos Standards National Bureau of 1011/80
Standards
~:. .48';1.
~
-------
Page No. 6
. ..," 02/28/89
Attas and Johns.HanYftte Coatinge SuperfU1d Sites
City of Coatinga Operable Unit
ADMINISTRAtiVE RECORD INDEX
." DOCU4ENT DOCUMENT DESCRIPTION FROM TO DOCU4EIIT
CATEGORY M.l48ER SUBJECT DATE
0100.15 844 Concentration & Size of James R. Millette 2/80
Asbestos In Vater
0100.15 845 Chrysotfle.Asbestos In a W.C. Cooper 1119179
Callfomla Recreational Area
0100.15 846 Exposure to Aabe8tos fN8 J88eI R. Millette 8179
Drinking water In the u.S.
0100.15 847 Decont8lineting Lake Superior Richard ,. SdIIIIltt 5m'
of Asbestos Fibers
0100.15 848 SyqIOSiuaon Fugitive Research Corp. of 51117fl6
f,8iasl- New Engtand
0100.15 849 Experllllentat Detenllination of Watter John 1fl6
the NlIIDtr 1 Size of Asbestos
( Fibers
0100.15 850 Asbestiform Amph;bo\e Winerals Ph ill p M. Coole 9fl4
0100.15 851 Asbeste6 In Drink',. Vater G.M. Kay 9fl4
0100.15 852 Serpentine Flows on Joaquin Oarrel S. Cowan 9/70
Ridge
'0100.15--. .--.' 853 Minaret & Wetat' Resources of. .' .. _." '..--~ . . 1966~'
Cat Homia
0100.15 854 Cal Homla Asbestos Industry Sat- J. Rice 9/63
0100.15 855 Ambient Air Concentrations of 8hawan Singh 3/5/84
Asbestos fibers
0100.15 856 Dredging to Reduce Asbestos Jeanine Jones 2187
Concentrations
0100.15 857 Accuracy of Transmission Eric 8. Steel 1/85
Etectron Microscopy
0100.15 858 Field Monitoring of Chrysotlle Steven I. Hayward 3/84
Asbestos
0100.15 859 Membrane-filter, Direct Garry J. Burdett 1983
Transfer Technique for the
Analysis of Asbestos
-------
Page No.
02/28/89
7
Atlas and Johns-Manville Coalinga Super-fwd Sites
City of Coal i nga aper-8bl e Uni t
ADMINISTRATIVE RECCRD INDEX
DOCLMENT
CATEGORY
OOClJ4ENT
II\J4BER
DESCRIPTION
SUBJECT
FROM
TO
DOClJ4ENT
DATE
0100.15 860 Measurement. of Asbestos Fibre Er-ic J. Chatfield 5/83
CGnCentr-ati ans
0100.15 861 Asbestos in Califor-nia Wet.r-. Stephen I. Hayward 7/83
Dr-aft
0100.15 .881 Major- Issues with Health EPA . Science no date
Effects of Asbestos ."letter- Advisor-y Board
0100.15 882 Memo: Site Char-acterizatlon Chris Chalfany R~ Mor-eno 8129/88
0100.15 886 Ltr roe: City' Construction Robert Willey l.W. Pepple 5/2/88
0100.15 887 Article: Asbestos ..: £nviramental 11/9/84
1tepwter
0100.15 898 Fact Sheet: Asbestos Westem Institute 1981
Substitute Mater-iala & for Oc~tional &
Pr-ockJcers EnvirOl'lllental
Sciences
0100.15 9Ql. Envi ronnental Mews Fact Sheet EPA 10/11/85
0100.15 908 CLipping: tl.-.-.p at New It~ JGsetIb 9/13/83
England bbestos Durp Shows
Costs Can Offset Health...
0100.15 909 Art;c\e re: Asbestos Environnental 7184
Engineering Newa
0100.15 922 Cl ipping: Asbestos in the Jeanine Jonesl 7188
Western San Joaquin Valley California Geology
0100.15 923 Cl ipping: 1987 Cal ifor-nia ta\ifornia Geologyl 10/88
Mining Review John Burnett
0100.15 92' Environnental News Fact Sheet EPA 1/23/86
re: Phase OUt Asbestos Use
0100.15 989 Draft Excerpt re: Asbestos Charles E. Robinson Jenni fer- Decker 8/11/88
Analytical Methods
0100.15 998 Percent by Are.. Diagrams Randy Sol tin Jenni e Decker 8/9/88
-------
hge 110.
02128/89
(
DOC1.MEIIT
CATEGORY
0100.15
0100.15
. .
0100.15
0100.15
0100.15
0100.15
(
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
8
DOCUMENT
NIJ48ER
1001
1002
1003
1004
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
Atlas and Johns-Manville Coalinga SUperf&n:t Sites
City of CoaUnga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Cancer and Asbestos in
Drinking Water.
Airborne Asbestos Health
Assessment Update
Chronic Hazard Advisory Panel
Characterizatfon & Control of
Asbestos Emissions
Determinants of Cancer and
Cardiovascular Oisease
Mortality
Study of the probl. of
Asbestos in Yater
Health Aspects of Asbestos in
Drinking Yater
Exposure to Asbestos "bel'S in
Yater Distribution Systems
SollIe u,.ects on the D_i_try
of the Carcinogenic P81ency---.
Asbestos: Yaming, Dangerous
to Health
Ingested Mineral Fibers
Health Effects & Prevalence of
Asbestos Fibers
Asbestos: Expedience, Exposure
& Human Experience
Preperation of Extrapulmonary
Tissues
Effects of Long.term Ingestion
of Asbestos
FROM
\lest Coast Cancer
FOU'Idat i on
EPA
us ConIuIer Pro4;ct
Safety CaIIIlulon
C.F. Harwood
R.A. Zistind
American Yater Yorks
Association
Robert C. Cooper
Richard S. WoocIa\\\
freidrich Pott
. . ", ,_...-..- .
....... ""',
PhHfp M. Coole
Leland J. McCabe
Michael R. Gray
Phil ip M. Cook
Kelley J. Donh-
10
-.-.'.«.. ......".
" . ..., .: '.'~'.';. '" < "..,
OOCtJEN1
DATE
3/27/8IJ
6/86
7113
9n4
no date
9174
6/75
5/8/77
12/78"
-. ." '.- .'.
12178
4/79
6/21./79
no date
12/''/79
1980
-------
Page 110.
02/28/89
9
Atlas and Johns-Manville Coalinga ~rfinf Sites
City of Coal inga Operable Unit"
ADMINISTRATIVE RECORD 11100
Doc:tMEIiT
CATEGORY
Doc:tMEliT
"NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOaJ4EIIT
DATE
0100.15 1017 Evidence of Migration of ICUSUII J. 1980
Ingested Asbestos Patel-Jtanaliit
0100.15 1018 Asbestos in Drinking Water & Merty S. bnarett 1980
Cancer Incidence
0100.15 .1019 Pathological Effects of R.E. Bolton 1982
Prolonged Asbest41S Ingestion
0100.15 1020 Cancer C8\JSing Chemicals. 1981
Asbestos
0100.15 1021 AssesS8el'lt of R I sits Posed by NMvin A. 4/81
Exposure Sdlne I del'llln
0100.15 1022 Cancer Morbidity EW'lice E. Sigurdson 1981
Investigations
0100.15 1023 Detenainetion of Mineral Fiber A.R. Battennan 4/24/81
Concentrations in Fish
0100.15 1024 Mineral Fiber Contamination of Phil ip M. Cook 1/6/81
Western lake Superior
0100.15 1025 Pol Icy Problems Associated Michael Sheehan 4/81
with Waterborne Asbestos
0100.15 " 1026 Relation wi Particle Dimension Mearl F. Stanton 11/81
to Carcinogenicitr
0100.15 1027 Interpretation of the Ph il ip M. Cook 2/17/82
Carcinogenicity of AmoIjte
0100.15 1028 Pathogenesis of John E. Craighead 6/17/82
Asbestos-Associated Diseases
0100.15 1029 Public Health Aspectl of Water CA Dept. of Water 12/31/82
Supplies Resources
0100.15 1030 Short and Thin Mineral Fibers E.J. Chatfield no date
0100.15 1031 Asbestos Drinking Water: A Joseph A. Cotruno 1983
Status Report
" "
...
-------
Page No.
02/2B/89
10
Atlas and Johns.Manvllle Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMJNISTRATIVE RECORD JNDEX
1IOCUM£NT
CATEGORY
DOQJoC£NT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE,
0100.15 1032 Drinking.Water and Health. lIatlonel Research 1983
wl. 5 Comel l
01DD.15 1033 In Vitro Effects of Mineral Lalita D. Palekar 1983
F I bera
0100.15 1034 Review of P\b\ tatled Studies on Ph f\lp M. Cook 1983
Gut Penetration
0100.15 1035 Blb\ lographles frOll Online 8/4/83
C~er Databases
0100.15 1036 $&8181')': Workshop on Jngested 10/13/83
Asbestos
0100.15 1037 Groundwater Newsletter 10/31/83
( 0100.15 1038 Groundwater News 2/84
.
0100.20 608 Reconalssanee Report: Soil & AI YM'9ft Ir Seen oIenni fer Decker 5/6187
Air Sampling Strategy ternedy
0100.20 609 Memo re: Retaining FIT Jemy Decker IIIay Z ia.,fer 4/13/87
I Contractors for Sampling Event
wi.. arwI Photos
. 0100.20. ,. . -. 6U ...... re:.SoIL.SaaIp1ing.tian..._,..... .Stewart SIIIIpSOn &. -'~'-" Jemifer Oecte!:.. -.-. . 6112187.
"/attached Memo Gr~ CZajkowskf
0100.20 612 List of S8q)le LocationS 717187
0100.20 652 CERCLA Soi l Sampl irw fll.. Sean Kemedy EPA 6/5/87
0100.20 654 Sol l Sampling Plan Approval Stewart SlqJSon and Jennifer Detker 6/12/87
Greg Czajkowski
0100.25 603 4 Aerial Photos. 2 Photos of no date
Building
0100.25 605 Aerial Photo no date
0100.25 653 Sample Documentation Report Ecology & EPA 911187
Environnent
-------
Page No.
02/28/89
11
Atlas and Johns-Manville Coatinga SuperfU'ld Sites
City of Coatinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCU4.ENT
CATEGORY
DOCU4.ENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUI4ENT
DATE
0500.01 651 Atlas and Coalinga PRP.Mailing no date
List
0500.01 661 Ltr re: Asbestos Clellr"q) David V. Long Scott Rahlfa/Cfty 5/4/8B
Manager
0500.01 754 Ltr re: Other PRP'a. Attached: Davfd V. Long EPA 12/28/87
9114/87 Letter
0500.01 756 Ltr re: Advice Regardi,.. Jemifeo Decker Carl. J. Irvine 9/20/8B
D i -8i"i- StaM
0500.01 761 Ltr re: Request for Further Davfd B. Stanton Jemifer Dedter 11/1/8B
Infonllltion
0500.01 762 Ltr re: Request for Dorothy G. Jemi fer Decker 7/5/8B .
Information - ""'eele.. .Bc.n:e/Reno, NY
Properties
0500.01 764 Ltr re: Property Ownership Bob J. llharpton "emi fer Decker 7J718B
0500.01 765 Ltr re: lespon.sibit ity 'or John". Johns Jenni fer Decker 6130188
Asbesw Remova(
0500.01 766 Ltr re: Asbury Transportation Dean Prettyman Jemi fer Declter 6/21/8B
Co. L iabit ity
0500.01 767 Ltr re: Calff~;a Minerals Claude ". Bridges Jemlfer Decker 6/21/88
COrp.
0500.01 768 Ltr re: Potential L I abit ity Richard E. Blubaugh jemi fer Decker 6/24/88
0500.01 769 Ltr re: Kern County Land Co. David B. Stanton Jemifer Decker 5/23/88
0500.01 770 Ltr re: "estside Trucking Henry T. Leclcman Jemi fer Decker 6/29188
0500.01 771 Ltr re: Marmac Carla J. Irvine Jenn i fer Decker 8/918B
0500.01 m Ltr re: "illingness to Richard E. Blubaugh Jemifer Decker 7/22/88
Participate in Response
Activities
0500.01 m Ltr re: Notice Letter David B. Stanton Jennifer Decker 71 1918B
- '!.
-------
P8ge No.
02/28/89
12
Atlas and Johns-Manville Coal inga Superfu-d Sites
. City of Coal inga Operable Unit .
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FRCIe
TO
DOCUtENT
DATE
0500.01 774 Ltr re: Notice Letter Robert IC. Behrens .I_i fer Decker 819188
. 0500.01 T75 Ltr re: 1t"811$p01't of Material John D. Clarke 5/27/88
0500.01 797 Ltr re: Other PRP'. David W. Long EPA 9114~7
0500.01 805 Ltr re: Response to 106(8) D8vid W. Long EPA 812B187 .
':;':'.::. Regarding Ownership
..
0500.01 943 Response to Notice Letter Claude W. Iridges Jerw\l fer Decker 6/21188
0500.01 944 Ltr re: Not'ce Letter John W. Johna Jami fer Decker 6130/88
0500.01 945 Ltr re: Extension of Response David E. Noyes .IemUer Oecker 5/16/88
Date
0500.01 946 Ltr re: Participation in David E. Noyes Jami fer Decker 6/23/88
( Response Activities
0500.01 947 L tr re: Correction to Previous David E. Noyes Jamifer Decker 7/8/88
letter
0500.01 948 I~ponse to Iotlce Letter Bob J. H~tonl Jamifer Decker 717188
Coal inga, Ca
0500.01 949 Ltr re: Briefing Meeting Phil ip L. Fitzwater Jami fer Decker 8/26/88
. -'--'.,-".",-.
0500.01 950. Response to Notice Letter David E. Noyes Jamifer Decker. 717188
0500.01 951 Ltr re: BrieUng George M. C. JemHer Decker 9/22/88
Robi nson
0500.01 952 Response to Notice Letter David B. St~on Jamifer Decker 6/20/88
0500.01 953 Response to EPA Letter of Dean Prett~n J.,..,i fer 1>ecker 6/21/88
6/13/88
0500.01 992 ltr re: Potential Lf abil ity; Richard E. Blubaugh Jemi fer Decker 6/2"88
0500.10 728 Telecommunication re: David long Bill Wick 8/26/87
CCIq)l iance w/Section 106 Order
0500.10 729 Telecommunication re: Lewis Mitani David Long 8/26/87
CCIq)liance ,,/Section 106 Order
-------
Page No.
02128/89
13
Atlas and .Iohns-Hanville Coalinga Superfu.f Sites
City of Coalinga Operable IM1lt
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCtJ4ENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCtJ4ENT
DATE
0500.20 619 Ltr re: Answer to 104 Letter David W. Long Jeff Zelitaon 4129/88
wi insurance Pol icies, Haps,
Property Ownership Rees
0500.20 620 Ltr with Accompanying Maps, Richard Bl~ .Iemi fer Decker 613188
Figures re:. EPA Request for
I nfonnat ion
0500.20 808 Ltr re: Financial & Insurance Richard E. Bl~ .Iemi fer Decker 515/82
Coverage Inforlllttion
w/attachments
". Ltr: Response to 104(e) Letter
0500.20 833 lCemeth B. Prindle EPA 5/6/88
w/s~rt Docunents
0500.20 862 Ltr re: Request for Bob .I. H8q)ton .Iemi fer Decker 4/19/88
Informetion & Real E.tlte
Purchase Contract
0500.20 863 . Response to 101.(e) Letter Claude W. Bridges .Iemifer Decker 4/19/88
w/exhibit A
0500.20 865 Response to .101.(e) Letter "ohn II. JaMs .Iemifer Decker 4/29/88
0500.20 866 Responsa to 104(e) Letter David E. Noyes .Iemifer Decker 6/22/88
w/annual Report & Transmittal
Letter
0500.20 867 Response to .101.(e) Letter Lee Quick .Iemi fer Decker 4/18/88
0500.20 868 Response to 101.Ce) Letur Lowell Baker .Iemi fer Decker 4/25/88
0500.20 869 .., Respanse to 101.(e) Letter A.J. Eyraud .Iemi fer Decker 4/6/88
0500.20 871 Response to 101.(8) Letter David B. Stanton Jemifer Decker 5/23/88
0500.20 872 Response to 101.(e) Letter David B. Stanton Jenni fer Decker 4/8/88
0500.20 873 Ltr re: Request for T.C. Sager Jeff Zellbon 5/10/88
Infonnation v/annual Report
0500.20 874 Ltr re: Request for Richard G. Tisch Jenni fer Decker 5/16/88
Information
-------
Page No.
03/a9189,
14
Attas and Johns-Manvi He Coat inga S!4)erf'-Rf SI tes
, Ci ty of Coal inga Operable Unl t
ADMINISTRATIVE RECORD INDEX
DOCIJENT
CATEGORY
DOCIJENT
NlICBER
DESCRIPTICII
SUBJECT
FRO.
TO
DOC1I4ENT '
DATE
0500.20 875 Ltr re:' Denial of Connection Joseph P. Cerullo Jemi fer Decker 4/19/88
with Coalinga Asbestos
0500.20 1041 Ltr re: Respopnse to,104(e) Dorothy G. lkn:eJ Jemi fer Decker, 7/5/88
Letter Reno, IV
0500.25 641 Certified Mell Receipt Jemlfer Deeter Robert "IIIIJ)ton 4/6IU
M/letter and Envelope
0500.25 757 I.tr re: Section 104 PIP Sue Johnson David L~ 8/4/88'
Responses
0500.25 758 Ltr re: PRP 104(e) Responses Eve Johnson lCevln Maroff 8/4/88
0500.25 776 104(e) Letter Jeff lellkson David W. Long 3/18/88
0500.25 m 104(e) Letter Jeff leliitson Floyd Crable 3/18/88
0500.25 T78 104(e) Letter Jeff leligon Wayne BrOOllle 3/18/88
0500.25 779 104(e) Letter Jeff leligon Ronald Bowmam 3/18/88
0500.25 780 104(e) Letter Jeff lellgon Charles ~ire 3/18/88
0500.25 781 , 104(e) Letter Jeff lei 'bon Lowelt Baker 3/18/88
0500.25 782 ' 104(8) Letter.", , ...tf lel ibon -'" -" , - Edward Heine ". ,,-, - 3/18188
0500.25 783 1~(e) Letter Jeff letlk.on Claude Bridges 3/18/88
0500.25 784 '" 104(e) Letter Jeff lellkson Richard Johnson 3/18/88
0500.25 785 104(e) Letter Jeff let ikson Al Eyraud 3/18/88
0500.25 786 104(e) Letter Jeff lelikson Steve lCerdom 5/Z/88
0500.25 790 104(e) Letter Jeff letikson Lee Quic:k 3118/88
0500.25 791 104(e) Letter Jeff lelikson Robert H8q)ton - 3/18/88
O5OO.Z5 79Z 101.(e) Letter Jeff lelikson John Johns 3/18/88
0500.25 815 101.(e) Letter Jeff lellkson Weavers 3/18/88
-------
Page »0.
02/28/89
15
Atlas and Johns-Manville Coalinga SuperfWld Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
Dcx:uMENT
NUMBER
DEScRIPTION
SUBJECT
fROM
TO
Dcx:uMENT
DATE
0500.25 824 104(e) Letter . Jeff Zelfkson Rfdlard B. Yon Wald 3/18/88
0500.25 830 104(e) Letter Jeff Zelfkson Earl Chantlera 3/18/88
0500.25 831 104(e) Letter Jeff Zel fuon Irving Moore 5/12/88
0500.25 939 Ltr re: Correctfon to PrevfOUl Jemf'er Decker Robert H~ton 5/24/88
letter
0500.30 759 Signed Order Dlrecth1Q SPTC to EPA D.I:. MeMear 8/21/87
Take Actfon :
0500.30 804 ltr re: PTe. f.ClllpU~ o-id W. lcqJ EPA 8/27/87
0500.30 806 Conments by SPTC on EPA Order David W. Long 9/4/87
. 87-04
0500.30 820 Ltr re: Potential liability to Jeff Zel ikson £dard Heine 1,/28/88
the Site
0500.30 821 Ltr re: Potential liability to Jeff Ze\ I kson Earl Chanbers 4/28/88
the Site
0500.30 822 ltr re: Potential Liability.to Jeff Zelikson Weavers 4/28/88
. the Site
0500.30 823 Ltr re: poterytial Liability to Jeff Zelikson Wayne Broome 4128/88
the Site
0500.30 9S4 Ltr re: Potential Liabil ity Jeff Zelikson A. Eyraud 6113/88 .
0500.30 955 Ltr re: poten.tial Lfabjli\~ Jeit zemes... Edward Heine 6113/88
0500.30 956 Ltr re: Potential liability Jeff Zelikson Charles Squirel 6/13188
Burbank, CA
0500.30 957 Ltr re: Potential liability Jeff Zel ibon Wayne Broome 6/13/88
0500.30 958 Ltr re: Potential Liability Jeff Zelibon John Johns 6113/88
0500.30 959 Ltr re: Potential Liability Jeff Zetikson Lowell Baker 6/13/88
0500.30 960 Ltr re: Potential Liability 7 Jeff Zelikson Irving Moore 6/13/88
... - .
.:- "
';'. .
-------
Page 'o~
02/28/89
16
Atlas 8nd Johns'Manville Coal inp ~rfund Sites
. City of coalinga Operable ""it
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGOIty
DOCUMENT
NlJ48ER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DAlE
0500.30 961 Ltr re: Potential Liability Jeff leliltson Richard G. Tisch 6/23/88
0500.30 962 Ltr re: Potential Liability Jeff ll'titson David loyes 6/23/88
0500.30 . 963 Ltr re: Potential Liability Jeff leliteon Mr. ,,"vel' 6/23/88
0500.30 964 Ltr re: Potential Liability Jeff leliteon I rvl", Moore 6123188
,','
0500.30' 965 Ltr re: Potential Liability Jeff Zeliltson" E. Heine 6123/88 ..
0500.30 966 Ltr re: Potential Liability Jeff Zelikson Earl Chaa.rs 6123/81J
0500.30 967 Ltr re: Potential Lieb\lity Jeff ZeHkson Uayne Br- 6/23/88
0500.30 968 Ltr re: Potential Liability Jeff '1e\lkson David Noyes 6/13/88
0500.30 969 Ltr re: Potential Liability Jeff Zeliitson Lee Qui ck 6/13/88
( 0500.30 970 Ltr re: Potential Liability Jeff Zeliltson Robert H~ton 6/13/88
0500.30 971 Ltr re: Potential Liability Jeff leUtaan Claude Bridges 6/13/88
0500.30 9n Ltr re: Potential Liability Jeff Zeliltson Mr. Weavers 6/13/88
0500.30 973 Ur 1'8: Potewtial LlabU fry Jeff lellbon Claude Bridges 6/23/88
QSOO.3O 974... Ltr .re: htllN.;8\ Liability.. Jeff"ZeHkson . Earl Chaa.rs 6/13/88
., ..' ..
1401.01 559 Ltr re: R8IIIOY8l Action Jennifer Declter L.U. Pepple 9/26/88
CcncU:red By SPTC
.1'01.01 561 Lt,. re: lteriftl of "unba Jeff Zeliitson L.U. Pepple 9/21/88
~tance Cont8;lI8ent Report
1401.01 570 Cover ltr: RIIFS Documents Jerrli fer Decker Gary Carozza no date
"01.01 571 Cover ltr: RIIFS Document Jennifer Decker Martha Hennly 9/16/87
1401.01 5n Cover ltr: RIIFS Documents Jemi fer Decker Lonnie Uass 3/1/87
1401.01 613 Ltr re: Project Coordinator Jennifer A. Decker L.U. Pepple 8/31/87
Position
1401.01 614 Revi sed Conments on Hazardous Jemi fer A. Decker L.U. Pepple 9/15/87
Substance Containnent Plan
w/letter
-------
Page No.
02i28/89
17
Atlas and Johns-Manville Coalinga Sl4M!rfl61d Sites
, City of Coal tnga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCtJ4ENT
IMIBER
DESCRIPTION
SUBJECT
FRON
TO
DOCUM£NT
DATE
1401.01 615 ltr re: Sample Community Jennifer Decker L.W. Pepple 9/15/87
Relations Fact Sheet
1401.01 616 Tr8nS8ittal Ltr: Sample Jenni fer Decker L.W. Pepple 9/17/87
Docunentatlon Reports
1401.01 617 Ltr re: S_is.ion of EPA's Jennifer Decker L.W. Pepple 12/8/87
Final Review of Analytical
Data
1401.01 658 Cover letter: Airborne Jennifer Decker L.W. Pepple 7/11188
Asbestos Sampling Data Report
1401.01 659 Ltr re: Conduct a Biota Survey Robert O. Willey Jennt fer Decker 2/19/88
& Construct an ,an-site Vault
1401.01 660 Ltr re: Field Trip to Collect Robert D. Willey Jenni fer Decker 5/10/88
Data
1401.01 664 Landfill Design with Fax Cover Leonard O. Yamamoto ATEC Environmental 8/16/88
Page Consultants
1401.01 690 Cover Letter for, RIIFS Jennifer Decker Jeanine Jones 9/16/87
Docunents
1401.01 737 Ltr re: Airborne Asbestos Jeanine Jones Jenni ferA. Decker 1/27/88
'Sampling Data Report
1401.01 T38 Memo: Risk Assessment Jeanine Jones Jennifer A. Decker 10/26/87
Procedures w/letter
1401.01 795 Ltr re: Addendum to IT!SPTC Robert D. Willey EPA 12/8/87
Hazardous Substance
. Containnent 'Plan
1401.01 796 Meeting Notes: Conmentson L.W. Pepple EPA 9/8/87
Field Investigation Report
1401.01 799 Ltr re: Events on Site G.L. Murdock EPA 9/24/87
w/distributlon List
1401.01 800 Ltr re: Hazardous SUbstance Robert O. Willey EPA 1/15/87
Containnent Plan AdderO.Ia II
-------
page 110.
02J2S/89
18
Atlas and JOhns'Manvllle'Coallnga SUperfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMEIIT
CATEGORY
DOCUMENT
NltIBER
DESCRIPTION
'SUBJECT
FROM
TO
DOCUMENT
D~TE
1401.01 802 FAX ClNer I tr: Senate BUI Bob WUlev Jenny Decker 9/11/87
2572
1401.01 807 Cover ltr: Hazardous David U. Long UA 9/4/87
SWlstene.. Contal.-nt Plan
1401.01 897 Chain of Title of sp' Gary '.1..-.. . Jflf'l1P/ Decker 3/4/88
.". '.." Right-of-w.y wi letter
1401.01 982 U,. re: Plemlng of \lint.. Air $coU R. JUtr.." Jemi fer Decker 2!ZJ/87
, S-.at ing Plan
1401.01 986 Transmittal ltr: E~ Air Miehael C. Rieflards Nancy l;nds8y 8/17/87
SAP
1401.01 1039 Inspection Report RIben Moreno Dave Howell 7129/88
w/Transmlttal Lett.r
( 1401.01 1040 Inspect;cn IepJrt RIben Moreno ThCIIIBs Sager 7129/88
w/transmittal Letter
1401.05 703 Emergency Response Action Brad Shipt., Jem; fer Decker 6/6/88
Summary with 2 Photos
1401.05 747 Memo: SPTt Ir Machine Shop Am ~eml fer Decker Greg Baker 4/25/88
1401.15" 618 Hazardous Slbstance Dennis Robinson EPA 9/18/87
, " .. ,. .. "..."., ,,,..
Containment Plan wi letter.
Draft
1401.15 794 ,U~: C41m8\ts on Hazardous Dennis M. Robinson EPA 9/28/87
Slbst~ Cont.;nment Plan
1401.15 1005 Draft: Hazardous Substance ATEC Environmental 12/88
Removal Plan Consultants
1401.20 704 Memo re: Re-analysfs of Sean Kennedy Kent Kitchingman 1113/87
Coalinga soil 811111)\e
1401.20 809 Standard Operating Procedures Dennis Robi nson Jenni fer Decker 9/11/87
of Asbestos Soi I S~les
"/attachments
"0'.20 976 Qual i ty Assurance Project Plan Roland A. Sanford 5/8/86
-------
Page No.
02/28/89
19
Atlas and Johns-ICanville Coalinga SUperfw-d Sites
City of Coalinga Operable Unit
ADICINISTRATIVE RECORD INDEX.
DoaJIENT
CATEGORY
DCXUICENT
IMCBER
DESCRIPTION
SUBJECT
FROM
TO
DOClJIENT
.DATE
1401.20 971 Air Monitoring S~ling Plan. J. OayidOean 8/19/85
Draft
1401.20 978 Draft .Air Sampling & Analysis Woodward-C l yde 1/15/86
Plan
1401.20 97'9 Ltr re: Equipaent for :Afr J. Dayfd Dean Dan Hutton 10/1/85
$aq)lfng
1401.20 980 #.dI:Idenct.ft to Draft Ai r SAP UOcdward-Clyde 11/20/85
1401.20 981 Draft Equipment L1st no date
1401.20 984 Ltr re: Additional Airborne Dayid Suder Jemifer Decker 5/21/87
Asbestos Data
1401.20 985 ICemo: Approval of SAP Al Vargas Kent IC. Cftchlngman 9/21/87
1401.20 987 Expanded Air S~lfng & Woodward-Clyde 8/11/87
Analysfs Project PLan
1401.20 988 Memo: AdderQa 1.0 Air S~ling AL Vargas Jer8'li fer Decker 7/22/87
PLan
1401.20 990 Memo: Revision Df Air Dayid Suder Dona\d Hal"Vey 1129/86
IConitoring Program
11.01.20 991 ICemo: Amended Air SAP III/letter Scott R. Huntsman Jemi fer Decker 7/15/87
1401.20 996 OutL lne of Expanded Air Scott Huntsman Jemi fer Decker 5/12/87
S~ling Program ",/Letter
1401.20 997 Amendnents to Air SAP Scott Huntsman Jemi fer Decker 3/5/87
11.01.25 595 Interim Health & Safety EPA 5/87
GuideLines .for EPA Asbestos
Inspectors
1401.25 705 Site Safety PLan Geoff Watkin Jemifer Decker 11/25/87
1401.30 674 Ltr re: Pennission for EPA to EPA 12/14/88
taKe Soil Samples
1401.30 760 Ltr re: Permission to Take Jemi fer Decker Keith Scriyener/ 12/11./88
Soil S~les Coa II nga
-------
Page 10.
02/'U/89
20
Atlas and Johns-Manville Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
. .
DOCtJ4ENT
CATEGORY
DOCUMENT
NIJIIBER
DESCRIPTION
SUBJECT
FROM
TO
DOaJIIENT
DAtE
1401_30 935 Ltr rei: Req.Jest to S8q)le SOil Jemi fer Decker Keith Scrivner 12/14/88
1401_30 936 Ltr re: Request to sample Data Jemi fer Decll.er Robert Hampton 12/14/88
1401.35 . 691 Attachlllent8 to O\I'8raight of Jac0b8 Engineering EPA 12/81 .
., Responsible Party Activiti..
1401.35 706 O\I'8raight of Responsible 'arty Jee0b8 Engineering EPA 12/81
Activiti..
1401.35 101 Cover letter: OYersight of SUe Johnson . Jemi fer Decker 12/21/81
Responsible Parties
1401.40 999 Meteorological Data Report Woodward-Clyde 1/15/88
Consultants
1401.40 1000 Airborne Asbestos ~ling Woodward-Clyde 613/88
( Data Report Consultant.
1401.45 675 Quality Assurance Report 9/15/88
wI letter
1401.50 622 Site CharacterizaUon Mark Unruh 8/88
1401.50 623 Hazardous Satance IT Corponltion 118/88
tant8innent Report
. '. ..,...' .,". .. . ...0."'" ." ..~.,.. ,-",". ',.. . . u, '. '."._..".-,.. . ."--. .~. ~,,'~ .., .,... -,,""'. . ......,... . . ,".
1401.50 624 Design Report: Asbestos Waste G. Dale Barnhill R\ben Moreno 1/89
Management Unit w/transmittal
Letter
1401.50 625 Hazardous SUbstance A TEC Envi ronnentat 8/88
Containment Report, vol. I Consul tants
1401.50 626 Hazardous SUbstance ATEC Env. 8/88
Containment Report. vol. II of Consultants
II
"0'.50 798 Draft Hazardous SUbstance SPTC 9/18/87
Containment 'lan
1401.50 801 Revised Hazardous Substance SPTC 9/28/87
Containment Plan
-------
'Page No.
01/26/89
21
Atlas and Johns'Manville eoalinp ~rf~ Sites
City of Coalinga Operable unit
ADMINISTRATIVE RECORD INDEX
DOCU4ENT
CATEGORY
DOCUMENT
IUCBER
DESCRIPTION
SUBJECT
fROC
TO
DOCUMENT
DATE
1401.50 1042 FS Report: OUFS/Hazardous ATEC Envlron8ental 02/89
Substance Remedial Plan Consultant.
1401.52 600 Ltr re: CoaIDent. on SPTC Jennifer Decker L.W. Pepple 2/W88
Hazardous Substance
Contalr--.t Plan
1401.55 . 686 ~ P\blic Health Aa.es--.t Jennl fer Decker Don. Hawkins 4/22/87
f I"CIII A TSOR end CCIIIIU'Ii tv
Meet I 1111
1401.55 687 Mem: Thank You for the Jeff Zelftaan Jeffrey A. Lybarger 5/22/87
Presentation
1401.55 688 Nem: Update on COIIIII. - Zilllpfer Jeffrey A Lybarger 9/11/87
Relations and Request for
Epidemiological Study
1401.55 736 Ltr re: P\blfc Health Issues James T. Allen Keith Takata 7/2/87
1401.55 876 Review: Draft Evaluation of Office of Health Don Hawkins 4/30/87
Potential Relative Risks Aasess8ent
Associated with Airborne...
1401.55 877 'Mew: Ik'.tt £".'U8tfon of Office of Health ATSDR 5/4/87
Potential Relative .,wts I.sMa.s8nt
Associated with Airborne..-
1401.55 878 Ltr re: Epidemiological Study Gail Louis Don Hawkins 11/5/87
1401.55 879 Hem: Epidemiological Study Lybar9f¥" ATSDR Region 9 12/11/87
Request
1401.55 880 " Pre\i.inary Health Assessment ATSOR/Von Al linen EPAlCl ifforcl 11/3/88
wi letter
1401.55 885 Health Consultation Memorandum Office of Health Don Hawk.ins 4/22/87
w/attachtnents Assessment
1401.57 621 Endangered Species Survey IT Corp 4/88
w/cover Letter
1401.57 656 Ltr re: Biota Survey Greg Baker Gail Kabetich 2/5/88
. - .
-------
Page No.
07/26/89
22
AtLas and .IaIms-ManvILLe CoaUnp Superfwd Sites
City of CoaL inga Oper8bLe unit
ADMINISTRATIVE RECORD IIIDEX
DOCUMENT
CATEGORY
DOCUMEIIT
NUMBER
DESat1PTl011
SUBJECT
FReM
TO
DOCUMENT
DATE
1401.57 883 Ur re: Endangered Species. George Notes Robert ICing 6/8/87
W/attedlllents
'_40'.57 884 Ltr re: Endangered Species Dept. of FI- & EPA 2I29/8B
WlLdl if.
1401.60 568 Ur: Design 8nd Construction lciIIrt D. WILley .I. ZeUkaon 4/12/8B
of a Waste Disposal unit
-.
.. ...
1401.60 569 Ltr: Request Guidance to I. Nichols Ha~elwood Lamie Wus 4/11/8B
Design a DisposaL unit
1401.60 689 Ltr: Detailed Identification PhIL Sobel .I... AL len 4/18/8B
of CA AlAR
1401.60 692 SF Tr8nsportatlon ~ R~ Moreno R. Nichola. 5/24/8B
Hazelwood
1401.60 693 letter Jeenine Jones JemUer Deeker 5/4/8B
1401.60 732 Memo re: AlAR's James T. Allen Phil SobeL 5/11/8B
1401.60 733 Memo re: ARAR$ - R~ JIoreno Mark Unnll 8J29/8B
1401.60 739 Report: Identification of .1- T. AU., relth Takata 8/21/87
asbestos with Letter
-. .... - 7UOO.01. -678 . MaHtngllsn: Vlletter ---- -." ToryiPete/'Son &--' -. -- CA- Dept_ot Vater -- - 6175JtJ5 _..-
SUgaNr Resourc:es
7000.01 679 Ur re: Neighborhood HeaLth Rose Hess GaiL Louis 7/22/U.
- - -. ProbLm
7000.01 680 Ur re: Cttizen Coneerns ti/EPA MoUe Jemi fer Deeker 4/5/8B
Response
7000.01 681 FOIA Request Robert Hernando GaIL Louis 8/21./87
7000.01 682 FOIA Request Nonaa Chew Ida ToLLiver 2/7/8B
7000.01 683 Ltr re: Citizen Coneerns About Vincent MoUe .IemUer Deeker 1J8/8B
the Site
7000.01 896 Ltr re: Lack of CLeanup at the D. Scott Rohlfs David Long 1./13/88
Site
-------
pege NO.
071211/89
23
Atlas and Johns-Manville Coalinga SUperfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
OOCU4ENT
CATEGORY
DoaJENT
IlUMBER
DESCRIPTION
SUBJECT
fROM
TO
DOCUMENT
DATE
7000.01 925 Ltr re: Asbestos & Health Steve Drew Henry 3/21/84
Leca.rvCoal inga
7000.01 926 Tr8nS8ittal Ltr: RI/FS Work Scott IIU'It-. Myron Levin 9/16/86
Plan
7000.01 921 Mailing List .net Th-* Tou Steve Dr... Distribution 3/1/84
Notes
7000.01 928 Ltr re: Correspondence II/santa Michele Derwer Myron Levin 9/15/86
Fe Pacific Realty Corp.
7000.01 929 Ltr re: MeethlSl to Develcp atp Gail Louis Scri-r no date
7000.01 930 Ltr re: Trans8ittal of Reports GaU Loui s Bob ICing/Coal inga 11130/88
7000.01 931 Ltr re: Infonaation Repos. Gail Louis ICay Anthony 11130/88
Update
7000.01 932 Ltr re: Infonaation Repos. . Gail Lout. lCay Ant~ony 4/14/88
Update
7000.01 933 Transmi ttal Ltr: CIP Gan \.ouis '"fIeople" 3/18/88
1000.01 934 Ltr re: City Council Meeting Gail Louis Vincent Motte 1/20/88
1000.15 676 Revised Drsft cap wec 3/38
7000.20 888 Cl iJPiIW: EPA and Other UPI 1/29/85
Stua;es A$besws
7000.20 889 Cl ipping: CCU\ty Plans lIoll ;1Jter Free-Lance 11/1'/83
Asbestos Tests
1000.20 890 tl'pping~ Costa Will Visit Fresno.ee 5/10/83
Arena 1
7000.20 892 Cl ipptng: Asbestos Plant Opens Mineral Infonnation 12/64
Service
7000.20 893 C\ ipping: Residents Receive Coa\ inga Record 7/22/87
EPA Letter
7000.20 894 Cl ipping: EPA Studying Coal ingaRecord 11/18/87
Coal il1ga Asbestos Situat ion
d::
.'~ ";:,
-------
{,-,:('o',
.:;~~
'~'.~~1J
~-'.~
.~,"'.
Pate 110.
07/26/89
24
Atlas and JOhns-Manvill. CoIllnga Superfund Sites
City of Coalinga Oper8ble unit
ADMINISTRATIVE RECXIRD INDEX
OOCUMENT
CATEGORY
DOCUMENT
Nll48ER
DESCRIPTION
SUBJECT
FItCM
TO
OOC\I4EIIT
DATE
7000.20 895 Clipping: GrOUld Rupture, M.C. JrilnlHart 8/83
CoIl i nga Earthqullke of 1983
7000.20 899 ct ipplng: Huron Chief Responds Coat I nga Courier 11/17/87
~; to lUring ContrcHersy Story
.
',' '.
.",',,'.. 7000.20 900 ct Ipping: Asbeston Fibers no date
:. .."-.
. ,-,' - FCU1d in Drinking Water.
Supplies
7000.20 901 ct ipplng: L~I Ifftr to Stew Anthonyl no date
Explore Asbestos Fiber ctear&.lp Mottister Free-lanc.
7000.20 902 ct ipping: Plbt Ie Is Excluded no date
frCII Envirom8'ltal Agency
Meeting He~e
7000.20 903 Clipping: Proposal for Clear Fresno Bee 10130/85
Creek Ar.a Outlined
7000.20 905 ct Ipping: Asbestos FCU1d in Russell Cl.ingsl 917185
Streams Fresno Bee
7000.20 907 ct Ipping: Asbestos in ~t Robert Jones/LA 2/9/84
WOrries State TIlleS
7000.20 910 Envi rOr.eniai" ii. -Fert"'sheet. ..- . '....:...o.-,u ..'J..r'~.- '_........';..' . _: ',"'... '/85
7000.20 911 Fact "eet: Colt Inga Asbestos 7/16/85
..
7000.20 912 Superfund Update: RIIFS EPA 6/87
7000 .20 914 Meeting Packet w/agenda EPA 1/7/88
7000.20 915 Asbestos Fact Sheet no date
7000.20 916 Meeting OYerhelld Slides no date
7000.20 917 Press. Release: City of EPA Ann Zawlla/KFO Radio 113D/89
Coal inga Proposed PI."
7000.20 918 SuperfU"d Update: Expected EPA 4/88
Schedule for Removat
-------
Page 10.
01/26/89
2S
Atlas and Johns.Manville Coalinga ~rf&nt Sites
City of Coal inga Operable Unit
ADMINISTRATIVE RECORD IIIDEX
DOC1JEIIT
CATEGalY
DOC1JMEIIT
N,-"BER
DESCRIPTION
SUBJECT
FRCM
TO
DOCLttENT
DATE
7000.20 919 Cl ipping: Asbestos FrOlll Sludge AIBI Ku.er Naj/W811 11/9/88
Used in Fertfl izen May Be Street Journel
Collecting on Fal'1l18l1d
7000.20 920 Clipping: F.-ily Stick With S8I .lose 1IIercury 11/1/88
Asbestos.ridden HOII8 lews
7000.20 921 Cl ipping: Asbest.os Can CMae San Jose Mercury 11/1/88
C8ncet' by Tr_porting DNA News
7000.50 657 Ltr re: R..t for 1te\OC8t\on SUsan Robinson Jerw\ifer Decker no date
F\RIs
7000.50 662 Ltr re: Relocate Mobile HOllIe G.L. Murdock l&by Goo I sby 10/11/88
7000.50 663 Estimate to Rem0Y8 Mobile Hame L.R. White R&by Goolsby 8/15188
7000.50 684 Ltr re: ownership Certificate Gai I Lewi. David W. Long "12/88
for Ruth Goolsby's Trailer
7000.50 685 Ltr ne: MINing Ruth Goolsby'. Gail Lewis David W. Long 9/23188
Yrai ler
7000.50 1" ROC re: Ruby Goolsby's trailer US EPA Carolyn McFarland 3/15/88
1000.50 143 ROC Re: Ruth Goolsby's Trailer Gail Louis Susan Robi nson 4/6188
7500.00 677 Ltr: Explain the Delay of Site Daniel McGoYem Tony Coelho 9/13/88
Cleanup v/attachment.
8000.25 . 755 Ltr re: Confidentiality Clai. Jeff Zelikson Carla J. Irvine 9/28/88
~.
-------
Page No.
07/19/89
Atlas and Johns-Manville' Coalinga Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No.1
DATE
AI,
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
01/01/84 Al1 Roger SChoU ~l inga tal ifomia Earthquake of
James St,..Ua May 2, 1983 . Reconnaissance Rpt
Editors (Document Date 1/84)
08121/81 AR2 Jefrff Decker Mello: CQlllLftiC8tion StratIfY. 106
Envir~tal Order SPTC 87.04
: .' Protection Agency,
Region IX, S.f.
02122/88 AR3 Sue JobnsM CoIIIIIents on IT Corp's Hazardous
Jacobs Engineri"l ~tance ContaiRllent Rpt W/TL to
Group Inc. Jefrff Decker 3/15/88
05/06/88 Al4 Earl Ch8llbers Jefrff,Decter Ltr: Response to 104(e) Ltr .
Mannac Resources Envi ronaental General ~- of Operations,
CCIq)Bn)' Protection Agency, Coni,,..;,,, Ext_ian to SU:inlit
Region IX, $.f. furtM1" Information
06/16/88 Al5 Jefrff Decker Lee Quick ROC: Notice Ltr, Addresses "ixed Up
Environaental Interstate Towing
Protection Agency,
Region 11., ~F.
01130/89 Al6 Mark unrU'i Scott lobUs Ltr: Connents on Design Rpt for
International Coal i,.. City Asbestos Waste Management Unit
Technology Manager
Corporation """'...,. . . ._~----. - .'." -'.. ~.. . '- . ""-""'''."
02101/89 Al7 Mark Group Proposed SpecifiC8tions For Ma.--c:
warehouse ChrOllite Ore Body R_al
and Transportation (Document Date
2/89)
02/01/89 ARB Fact Sheet. Asbestos Cleanup in
Envi ronnental Coal inga (Doc:unent Date 2/89)
Protection Agency,
Region IX, $.f.
02/10/89 AR9 Sue Johnson Jefrff Decker Ltr: COIIIIIents on Asbestos Waste
Jacobs Enginering Envlror'8ental Management unit w/Attachments
Group Inc. Protection Agency.
Region IX, S.f.
-------
Page No.
07/19/89
2
Atlas and Johns-Nanville Coalinga ~rfU'ld Site
City of Coal inga Operable unit '
Ac:binistrative Record File Index
Supplement No.1
DATE
AR'
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
OZ/13/89 AR10 Carla Fel.... Dan Meer ROC: special Notice Ltr. Chl"Olllfte
Shield & 58ith. EIWirGr8lental ore in Warehouse
Representing NaI'l8lJC Prowetion ~.
ResoUrces CoIIIpany R8tiiaa lX. $.F.
I
,0Z/11189 AI 11 Greg Bater Dan Nc:GoYem ~: Briefing on City of Coalinga
EnvirGr8l!ntal Envi rGr8l!ntal aJ ~rfU'ld Ita)
Protection Agency. Protection Agency.
Region IX. $.'. ,Region IX. $.'.
OZ/Z2J89 AR12 Transcription of CcIImu'\ity Meeting -
Envir~tal ' Asbestos Cle~ Proposed Plan
Protection Agency. w/Agenda
Region IX. S.F.
02/24/89 AR13 Barry Lee Jenny Decter Ltr: Atlas Request for Extensions
Dinlcelspiel. Donovan Envir~tal
& Reder. Protection Agency.
Representing Atlas Region D. $.'.
Ninerals. Division
of Atlas Corporation
02/24/89 AR14 Jenny Decter Carla Felcban aoc: Nannac Warehouse Clean-""
Envj,.~tal Jerry Andes
Prot~;on. Agency. ' Shield & SIIIith.
Region IX. S.,. Representing MarlmC
Resources CoqMIny
03/01/89 AR1S Blair King: Jenny Decter Ltr: Confirming Extension of P\blic
Assistant City Environnental Revi ew and COIIIIIent Per i od
Nanager of Coal inga Protection Agency.
Region IX. S.F.
03/01/89 AR16 PaUl Dezurict Jenny Decter Ltr: Concern with the Number of PRPs
Grah8111 & James Environnental Participating
Protection Agency.
Region IX. S.,.
03/07/89 AR17 Dan Neer Richard Tisch ROC: FOllow-Up to Notice Ltr
Environnental union Carbide
Protection Agency.
Region IX. S.F.
"
4.
-------
'-- ------
Page No.
07119/89
3
Atlas and Johns-Manvitle Coalinga ~rf~ Site
City of Coal fnga Operable unit
Acbinistrative Record File Index
Supplement 10. ,
DATE
AI'
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
03/08189 AR18 SUe Johnson . Jemy Decker Ltr: CoIIIIIenta on proposed
Jacobs Enginering Envlr~al SpeclflC8tions Fw MaI"8C Wllrehouse
Gf"CK4) 1 nc. Protection Agency, ChrG8fte R-.al
Region IX, S.F.
03/f19189 AR19 Den Meer It\ben Moreno ROC: ClUFS - UIIter 8o8rd UH I
Envl~t81 ClllIfwnia Regional ~Ider E..I", Slope Restriction on
,-
1.<>;'.' Protection Agency, Water Quality Landt III
Region IX, S.F. Cont~l Board -
Central Valley
.Region
03/13/89 ARlO SUe Johnson Jemy Decker Ltr: Conmenta on Proposed
Jacobs Enginering ~""""l specifications for Mar88C Warehouse
GrCll4) Inc. 1»rotectfon Agency, ChrG8ite '--1
Region IX, S.F.
03/15/89 AR21 Jemy Decker Meeting Agend8, List of Attendees,
Envf I'OnDI!I'Ital and Not.. Re City COU1CIl Concerns
Protection Agency, with \HI/CUFS
Region IX, S.F.
03/16/89 Al22 John Loomi s .M:my 1)fder Ltr: Ccanents of ManIIIC to ClUFS/HSRP
Shield & Smith, Jon Wactor
lepreMnt'"' Kannac Envi~tat '
hRlurc:es COII'f)II¥ Protection Agency,
Region IX, S.F.
. '.. _."-C' -'~".~ ,- ..'. ..01."....-. ".'-"... ...
03/17/89 AR23 Jemy Decker R"*-' Moreno ROC: Conference Call . \oMU Design
et al Mich_l Mangold Specs
Envir~\ £:al ifomla Regional
Protection Agency, Vater Quali ty
Region IX. $.F. Control loard .
Central Valley
Region
03/17/89 AR24 John Zikoponlos Jemy Decker ROC: Conments on CUFS
Westem TechnolOlJies Envi I'OnDI!I'Ita I
Protection Agency,
Region IX, S.F.
03/21/89 AR25 Greg Baker Scott Rohl fs ROC: latest on Asbestos Cleanup -
Envi ronnental Coalinga City City Counc: il Pos i t i on on Proposed
Protection Agency, Manager Plan
Region IX. S.F.
-------
Page No.
07/19/89
,
Atlas and Johns-Manville Coalinga S~,.fW1d Site
. City of Coalinga Ope,.able unit
Achinist,.ative Reco,.d File Index
Supplement No.1
DATE
AR'
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
03123/89 AR26 Keith SC,.ivner Jenny Dec:ke,. ltr: Official Response to EPA
Mayo,. of Coal inga Envir-onnental C l ean&4I" I» l an
Protectlcn AtenCY.
RetiOft ,.., S.F.
.03123/89 Al27 Jenny Decker Bob Vi l ley' ROC: Putting &HI Under a Road
Envircll'881tal ATEC Environlental
Protection AsIency, Ccnsultanta
legion IX, S.F.
03123/89 AR28 Conard HarPer Jon vector ltr: CoaIIIenta I. Questions on
SiqJSOn Thacher I. Environnental PnIpCIINId Asbestos Containnent Plan
Bartl en, ~ection Agency, 1110 1he City of Coa li nga
Representing Atlas legion IX. $.1.
Minerala. Division
of Atlas Corporation
03/24/89 AR29 Robe,.t Thonpson ltr: COaments on CXJF$ on Behalf of
G,.8h- a. .I... Envi,.onnental Vimell Mining
P,.otection Agency.
Region IX. S~F.
rr3/24189 AR30 ?bi\\ip fit~ate,. ltr: Technical Review ccaments on
Haroding lawson £nvi,.onnental CXJF$ Halardous Substance Remedial
Associates, P,.otection Agency. Plan on Behalf of Vimell Mining
Rep,.esenting Vimell Region IX. S.F.
Mining I. Minerals
Corpo,.ation
04/01/89 AR31 Preparation of a US EPA Region 9
Erwirar--.ta\ ~le Plan for EPA'lead ~rfU"ld-
P,.cn:ection Agerqr. Projects (Oocunent date -4/89)
l!iegi- IX.. S-1.
04/01/89 IoR32 Mic:taae\ ~ango\d 1h.ben Mo,.eno MeIIIO: Review of Design apt Asbestos
Califo,."ia Regional Califo,."ia Regional ~aste Management Unit w/TL to L V
"ate,. Quality "ate,. Quality Pepple 1./1/89
Cont,.ol Board - Cont,.ol Board -
Central Va,lley Central Valley
Region Region
04/13/89 IoR33 Ed ea"gile Dan Mee,. ROC: Proposed Plan Technically
Cal Homia Envi,.onnental SoW1d. Must Re'evaluate if Location
Pepa,.tment of Health Protection Ageney. Moved
Sevices Region IX. S.F.
...
4:.' ;.~.;:.
.
~
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Page 110.
07119/89
5
Atlas and JOhns.Manville Coalinga Superfund Site
City of Coalinga Operable Unit
Adalinistratiw Record file Index
Supplement 110. 1
DATE
AR'
AUTHOR
RECIPIEIIT
DESCRIPTION/SUBJECT
04/19/89 AIt34 Oen Meer lab WUley . ROC: City Will lot Alree to Liner
EnvirGn.ental ATEC Envf~tal.
Protection Agency, Consultmta
hgian IX~ S.F.
OS/fB189 AR3S Om Mer ....Jacobson ROC: Aabestoa Rocta Feutd at Slat
EnVf rGr8ental toe I '''' .PIIbt k 'F~taf"
Protection Agency, Worb ~.t
Regian IX, S.F.
OS/03/89 AR36 . Om Meer Ed Cargite Ltr: Tr8f'lSllittai of Proposed Plan &
Environaental Calltomla Request for CoaDents
Protection Agency, Oepar~t of Health
Region IX, S.F. 5evica
05/10/89 AR37 Jerry Cli fford Scott ROh\ fs Ltr: General IIotfce w/Certlfled Mail
Envi rClr'lllet\~.\ Coalinga City 1teceipt, Oc8estic aeturn Receipt and
Protection Agency, Manager COncurrenc:es
Regian IX, 5.F.
05/19/89 AR38 Oan Meer Scott ROh I fa ROC: Coal inga'. Reaction to General
Environnental Coal I,.. City lIotice Ltr
Protection Agency, Jar\8ger
Region IX, 5.F.
OS/22189 AR39 c:.\a h\.a.n Dan ....r ltr: Inqu;ry into Status of Plan
Stlield & 51111th, Environnental SWlDitted on Behalf of MaI'lllBC for
Represent i ~ Manaac: Protection Agency, .. Resaovalof Chra.fte
Resources CcIq)any Region 11. 5.f.
05/25/89 AR40 Laurie "nth- John lOOlli. Ltr: COIIIIIentS on Nannac:'s Proposed
. Em; ronnental Shield & SIIith, Cl~a~ Plen ../Appendix A . Detai led
Protection Agency, Representing MaI'8C Ccmnent.
Region IX, 5.F. Resources Coa\:NInY
06/05/89 AI41 Dan Meer Michael Mangold ROC: 5TLC and TTlC For Nickel at
Environnental Cal ffomia Regional Coal inga aJ
Protection Agency, Vater Quality
Region IX, 5.F. Control Board .
Central Valley
Region
06/08/89 AR42 Dan Meer Ed Cargile ROC: DHS Concurrence with Proposed
Environnental Calffomia Plan
Protection Agency, Department of Health
Region IX, S.f. Sevices
-------
Page "0.
07/19/89
6 .
'At,las and Johns-Manville Coalinga S~rfU1d Site
City of Coalinga Operable Unit
Ac:binistrative Record Fi le Index
SuppleDent No.1
DATE
AR'
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
06/09/89 AR43 Den Meer Leonard Y8III88Oto ROC: Earthquake Stability of the Y4U
EnvirGr*ntal International in Coal inga
Protection Agency, Technology
Region IX, S.F. Corporation
06/12/89 AR44 Den Meer Leonard Y~to ROC: Detail. of Y4U Design, Left
Envi rcrw:nta\ International Message For Y~to
Protection Agency, Technology
Region IX, S.f. Corporation
06/13/89 AR45 Den Meer Bill Marstaall ROC: Grade Requirements on Landfill
Environlll!ntal Cal ifomi. Regional Caps
.Pro~ion ~ency, \later aa.lity
Region IX, S.f. Control Board
06/110/89 ARIo6 Bob \lilley Dan Meer ROC: Spraying in Coal inga, Qlanges
ATEC Environmental Environnental to OJFS
Consultants Protection Agency,
Region IX, S.F.
06/14/89 AR47 Dan Meer . Ed Carsi le ROC: Clean'Up Level For Nickel
Environmental Cal ifomia
Protection Agency, Department'of Health
Region 'X, S.f. Sevices
06/27/89 AR48 Anthony Landi s Dan Meer Ltr: Concurrence on Proposed Plan
Cal ifomia Envir~al
Department of Health Protection Agency,
levi ces Region IX, S.F.
06/30/89 AR49 Draft fact Sheet: final Rule Banning
Et'N;r~tal Mamfacture, Processing, IlIp)rtation
Pro(~tion Agency, & Distribution in Conmerce of Most
. \1.1"9\'" O.C. ~Sbes~os Products w/Attachment
07/06/89 AR50 H Josef Herbert News Cl ipping: US Bans Almost All
Associated Press' Asbestos
Article from San
Francisco Examiner
07/01189 AR51 Ph il i P Shabecoft News Clipping: EPA to Ban Virtually
New York Times All Asbestos Products by '96
..-:.
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Page 110.
07/19/89
7
Atlas end Johns-Manville Coalinga SUperfund Site
City of Coalinga Operable Unit
Adainistrative Record FHe Index
S"Wleillent 110. 1
DATE
AR'
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
07/07189 AR52 .... Clipping: Most Uses of Asbestos
San FrencllCO to Be Banned by EPA
Chronicle
07107189 AR53 DM Meer Nichol.. U.18h ROC: DOT R~f~t. for Shipping
En'ti~t.l US Dep8~t of H.z.rdous Meterl.ls
oJ,,:;,. Protection AeercY, Tr.-port.ti on
..
lesion IX, S.,.
07/17/89 AR54 Den Meer Clari. ..,d\ Roe: Cap Design for COalfnsJ8 .....
Erwlr~t.l Jacoba Enginerfng
Protection Agency. GrCXJP Inc.
RegiCll\ IX, $.f.
/ / ARSS Greg Baker Jerrrf Decker Memo: Analytical Methods Being Used
Erwir~t.l Nancy Woo and Progr- Consistency
Protection Agency, Erwir~t.1
Resion IX, S.F. Protect iC8t Ageltcy.
Resion or. $-'-
/ / ARS6 Notice of Public Comment Period &
Erwir~i Publ ie Meeting on Proposed Cle~
Protecti.. Agency. Plan
Resion IX, S.F.
1 1 ARS7 Jemy Decker Russ Cl.ings ROC: City of Coal inge Cle~ -
Erwi~t.l Fresno Bee OUFS/Proposed Plen
Protection Agency.
Region IX, $.f.
/ / ARS8 list of Guidance Docunents
ErwlrCll'llltf'lt.\ (Oocunents Aval lable at EPA Region 9
Protection Agency SUperfund Records Center)
/ 1 AR59 Toxicity Profile for Asbestos
/ / AR60 Bibliography for the Review of Site
Risk
/ / AR61 Dan Meer Review of Site Risk
Envi ronnental
Protection Agency,
Region IX, S.F.
-------
Page No.
07/19/89
DATE
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Atlas and Johns-H_i He Coal inga SUperfU'1d Site
City of Coalinga Operable Unit
Acininistrative Record File Index
SUpplMent No.1
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
Draft RI/FS Rpt SOUth Bey Asbestos
Area (D~t Available at EPA
Regfon 9 Superfwd Recorda Center)
Baselfne Risk Assess8ent for the
Atl8S Hlne S&4*'Nw:t Site
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C:ITY 01' COAL:IRGA OPERABLB mr:IT USPORS:IVB1fBSS S01IKARY
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OPERABLB mr:IT 1'BA8:IB:IL:ITY STUDY AHD PROPOSED PLAH
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,IIB1ITS OH TBB PROPOSBD PLAH I'OR TBB C:In 01' ,COAL:IRGA OPBRABLB maT
01' TBB ATLAS UD ~ JODS-JlAHV:ILLB COAL:IRGA ASBIIS'fOS II:ILL SO-
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The United states Environmental Protection Agency (EPA) held a
public comment period from February 9 through March 24, 1989 on
EPA's Operable Unit Feasibility study (OUPS)' and Proposed Plan
for the asbestos and nickel contamination at the City of coalinqa
Operable Unit in Coalinga, California. The purpose of the public
comment period was to provide interested parties with the oppor-
tunity to comment on the OUFS and Proposed Plan. Durinq the
public comment period, a public meeting was held in Coalinqa on
February 22, 1989 to discuss the results and alternatives
presented in the OUFS. Public concerns and comments on site ac-
tivities and EPA's preferred clean up' plan were formally recorded
for the public record. The OUFS was made available on February
9, 1989: the complete Administrative Record was delivered to the
Coalinga Public Library on February'23, 1989. The original
public comment period was scheduled to close on March 2, 1989.
This abbreviated public comment period was desiqned to expedite
the clean up process. However, at the public meeting, members of
,the community as well as representatives for the Potentially
Responsible Parties (PRPs) requested more time to review the
OUFS and the Administrative Record. EPA then extended the
public comment period to March 24, 1989.
On February 9, 1989, copies of the OUFS were delivered to the,
Coalinga Public Library, the desiqnated information repository,
for the Atlas Mine and Johns-Manville Coalinga Asbestos Mill Su-
perfund Sites. By February 9, 1989, tact sheets containing EPA's
Proposed Plan.had been mailed to all interested parties.
Notification of the upc~minq public meetinq was published in
Coalinga and ,Fresno area newspapers. .
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Section 113(k) (2) (B) (iv) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) requires that
EPA respond to each of the siqnificant comments on EPA's Proposed
Plan. This responsiveness summary provides a review and summary
of community concerns about the site and siqnificant public com-
ments on the OUFS and the Proposed Plan.' In addition to sum-
marizing siqnificant citizen concerns and questions, the Respon-
siveness Summary presents EPA's responses to those concerns.
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II. OVBRnn 01' TJIB ItBCOJU) 01' DBCISIOB AHD CRITICAL COMKUBITY
COHCBlUfS
The Agency's selected remedy is the consolidation and burial of
asbestos and nickel contaminated material in an on-site Waste
Management unit (WMU). Other alternatives fully analyzed in the
OUFS included: i) no action: ii) covering the contaminated waste
in-place with one foot of clean soil: iii) removal of con-
taminated material to an abandoned mine site in the surrounding
mountains: and iv) removal of the contaminated material to an ap-
proved, off-site landfill.
The community favored removal of the contaminated material from
the City and opposed covering the contaminated waste in-place
with one foot of clean soil.
This WMU will have an impermeable cap as required by Title 23,
Subchapter 15 of the California Administrative Code. The
original design included a four percent grade' on the WMU. The
four percent grade for drainage meant that the crown of the WMU
would be six to eight fee"c above ground level.. This was greeted.
with universal disapproval by the community. The WMU was'
described at the public meeting as a "visual blight" or an
"asphalt dome" which would lower property values in the area,
discourage development and negatively impact Coalinga's economy.
With these community. concerns in mind, EPA asked the ~alifornia
Regional Water Quality Control Board (RWQCB) if it would be pos-
sible to reduce the grade of the cap in this case and lower the
cap to as close to ground level as is feasible. The RWQCB agreed
that the crown for this particular WMt1 could be lowered. The
RWQCB decision was communicated to the coalinga City Council by
EPA representatives at a City Council meeting on April 6, 1989.
Mr. Ruben Moreno of the RWQCB was present at this meeting.
Another design change made at coalinga's request was to allow for
the possibility of a vegetated surface.
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III.
StJMKARY 01'. PUBL:rC COJOlBJI'1'S RBCB:rvBD AJID AGBlfCY DSMBSBS
This section includes EPA's response to significant public com-
ments on the OUFS and the Proposed Plan received during the
public comment period. The public comments included letters sent.
to the EPA and comments/questions presented during the February
22, 1989 public meeting. A complete transcript of the public
meeting has been entered into the Administrative Record.
EPA has categorized the comments and responses to those comments
as follows:
.A. Comments made by members of the Coalinga City Council.
. . B. Comments made by the interested public.
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C. Comments made by potentially responsible parties (PRPs).
The comments responded to herein have been summarized or
paraphrased as appropriate.
A.
COJOlBJI'1'S BY JlBJlBBRB 01', TBB COAL:rBca c:rn COmrC:rL
A.1 Letter from the Mayor of Coalinga, Mr. Keith Scrivner, dated
March 23, 1989. Mr. Scrivner's letter reiterates many comments
made by members of the Coalinga City Council at the public meet-
ing, as follows: ..
A.1.1. Comment: Even though the municipality is the entity on
which EPA's decision regarding the site will have the greatest
impact, the City of Coalinga has very little influence on that
decision.
A.l.1. ReSDonse: Community acceptance is one of nine criteria by
which EPA evaluates a remedy. . The modification. of the proposed. .
plan to accommodate the community's concern regarding the height
of the WHO crown and insertion of a flexible requirement for
either a vegetative or asphalt cap are examples of the EPA using
that criterion in remedy selection.
A.l.2. Comment: The City has not been kept informed of the
project status or been involved with design and engineering deci-
sions regarding the WHO. In the last six months, communication
between the EPA and the Coalinga community has been inadequate.
.A.1.2. ResDonse: In an effort to choose a remedy consistent with
community desires and concerns, EPA has communicated and held
meetings with representatives of the City of Coalinga frequently
throughout the project, specifically since July, 1985. The EPA
remedial project manager and community relations coordinator com-
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municated with representatives of coalinqa by letter and fact
sheet, and made trips to Coalinqa to coordinate the community
relations plan with the community and to update the community on
the project status. The trips to coalinqa included meetinqswith .
City representatives Mr. Bob Kinq and Mr. Bob Semple (both former
city planners of Coalinqa). These activities occurred between
July of 1985 and April of 1989. In April of 1988 the Director of
Reqion IX's Hazardous Waste Manaqement Division, Mr. Jeff Zelik-
son, attended a City Council meetinq to discuss the status of the
clean up plan for the City of Coalinga Operable ~nit. In Novem-
ber, 1988, representatives of the City of Coalinga, Mr. King (the
City Planner) and Scott Rohlfs (the City Manaqer) met with a rep-
. resentative of ATEC (the consultinq firm hired by Southern
Pacific Transportation Company (SPTC) to oversee preparation of
the WHO desiqn plans) to discuss the desiqn and location of an
on-site waste manaqement unit (WMD).
During 1988 several members of the Coaling community and the
Coalinga City Council requested that the clean up be completed as
quickly as possible. EPA representatives attempted to expedite
completion of the proposed plan so that clean up could begin. As
noted above, community concerns and needs have been a factor in
modification of the desiqn of the WHO.
A.1.3. Comment: Members of the Coalinqa City Council believed
that the WMU would be located under a road right-of-way. They
believe that such a location would be the best possible one, if
the WMU, must be located within the City limits.
A.1.3. Res~onse: EPA found that there was no technical or en- ,
vironmental basis for requirinq the'WMU to be located under a
road riqht-of-way. EPA determined that the additional cost for
such a WHO was excessive. The ultimate, compatible use for the
land above the WMU remains to be determined.
A.1.4. comment: With hundreds of square miles of open land in
the area, why does the waste have to be buried within the City
limits?
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A.1.4. Res~onse: EPA guidance implicitly recoqnizes that only a
limited number of alternatives for the remediation of each site
can be studied in depth. EPA guidance requires identification of
one or more alternatives that involve containment with little or
no treatment. . Guidance For Conductina Remedial Investiaations
and Feasibilitv Studies Under CERCLA (October 1988), p. 2-9. Be-
cause no feasible treatment exists for asbestos, EPA studied a
total ,of five alternatives in depth, four of which involved con-
tainment and not treatment. Two of these alternatives involved
takinq the waste off-site: (1) disposinq of the waste at a per-
mitted landfill and (2)placinq the waste in an ,abandoned mine
approximately 20 miles from the Site. At the time that the al-
ternatives to be studied in depth were selected, it was EPA's un-
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derstanding that the community agreed that an on-site WMU was an
acceptable alternative. In response to community input, EPA
decided to study anon-site WMU location as close to the edge of
the City as feasible. In light of the fact that two off-site
containment alternatives were already being studied, EPA did not
elect to study any additional off-site alternatives. . The bases
for rejection of the two off-site alternatives studied are
.described in the ROD.
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A.1. S. Comment: Mayor Scrivner and members of the City Council
believe that the WMD design should include a liner, to ensure the
maximum protection for the community. .
A.1.S: Resoonse: EPA and the California Regional Water Quality
Control Board (RWQCB) have determined that - liner i. ~ot needed
to assure that the WMD effectively protects public health and the
environment. See RWQCB Memora~dum, dated Apri~ 7, 1989, attached
as Appendix 2 to the ROD. The cap and drainage system for the
unit along with the natural conditions at the $ite will provide
adequate protection against migration of contaminants. Asbestos
is not soluble in water and does not migrate once it has been
capped. While the nickel in the material. to be buried is solu-
able, EPA and the RWQCB determined that the presence of this
nickel did not justify requiring a liner for the WMD for the fol-
lowing reasons. Coalinga has only approximately seven inches of
rainfall per year. There is no detectable vertical hydraulic in-
terconnection between the natural geologic materials underlying
the proposed unit and the upper aquifer. A detailed
hydrogeologic study of the Site area was performed in August,
1988 by the IT corporation. This study found that the local
groundwater is very deep in this area (greater than 100 feet) and
that several impermeable clay layers are present between the sur-
face and the water. table in the Site vicinity. In addition, the
local ground water in its natural state is not potable. It ex-
ceeds the EPA Drinking Water Regulations and the California
Department of Health Services (DBS) Drinking Water Standards for.
sulfate concentrations. The ground water also exceeds the EPA
Drinking Water Regulations and the California DBS Recommended
Drinking Water Standards tor chloride concentrations. As a
.result this. groundwater could not be used for drinking water
without s~stantial treatment.
As an additional safeguard, the Proposed Plan includes monitorinq
for moisture using neutron probes. Any failure of the cap and/or
drainage system will be indicated by moisture detected by the
probes and will alert EPA to the necessity of repairing the cap
and/or altering the drainage system.
The plan as proposed meets all applicable or relevant and ap-
propriate federal and State requirements (ARARs). Federal
regulations require asbestos waste to be capped but do not re-
quire asbestos to be placed in a lined vault or a lined landfill
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(40 C.F.R. Sections 61.153 and 61.156). Asbestos ore waste that
is contaminated with nickel has been classified as a class B min-
ing waste by the State of California. Title 23, Chapter 3, Sub- .
chapter 15, Sectio~ 2570 (b) of the California Administrative
Code states that "[a] regional board may exempt a mining waste
pile from the liners and leachate collection and removal systems
required in this article if the discharger can clearly
demonstrate. to the regional board that the leachate will not form
in or escape from the waste management unit.- Section 2570 (c)
provides that regional boards may exempt a mining waste manage-
ment unit from certain requirements if a comprehensive
. hydroqeoloqic investigation demonstrates that -i) there are only
very minor amounts of ground water in the area: or ii) the dis-
charge is in compliance with the applicable water quality control
plan: and iii) either natural conditions or containment struc-
tures will prevent lateral hydraulic interconnection with ...
municipal beneficial uses.- As explained in the Record of Deci-
sion (ROD) and the RWQCB's Memorandum of April 7, ~989, the WMD
to be built on the Site has been exempted from these liner and
leachate requirements, pursuant to cal. Admin. Code Tile 23~
Chapter 3, Section 2570. .
~.1.6. Comment: An elevated crown on the WMU will have a nega-
tive economic impact on coalinga because it will be a "visual
blight" which will discourage development in the Site area.
A.l.6. ReSDonse: The Record of Decision has modified the
Proposed Plan to require that the WMU cap be as close to grade
as is feasible. This should minimize any negative visual impact.
A.1.7. Comment:
is a Potentially
the City had not
PRP. .
The City of Coalinga questioned whether the city
Responsible Party (PRP). As of March 23, 1989,
received any formal notification that it was a
A.1.7. ResDonse: EPA has notified the City of Coalinga of its
status as a PRP pu~suant to Section 107(a) of CERCLA in a general
notice letter dated May 10, 1989.
A.1.8. Comment The City of Coalinga would like any decision
which assigns future liability to ensure that Coalinga do~s not
inherit liability by default if there are no PRPs in existence at
some time in ~e future.
A.l.8. ReSDonse: EPA will deal with the issue of
the enforcement process. If the City of Coalinga
to be a responsible party, it will be jointly and
able for all costs associated with the clean up.
liability in
is determined
severally li-
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A.l.9. Comment: The City is concerned that if land owned by
Coalinga is used by SPTC to stockpile waste material during con-
struction of theWKU, the City may have liability if SPTC sud-
denly quits work in the middle of the project.
A.l.9. ReSDonse: The land owned by the City of coalinga in the
proposed stockpile area contains raw asbestos waste piles that
contain up to 98 area percent asbestos by PLM. As was noted in
the response to comment A.l.8 above, if the City of Coalinga is
determined to be a responsible party, it will be jointly and
severally liable for all costs associated with the clean up.
Therefore, Coalinga's liability will not change if this area is
used to stockpile contaminated soil. The ROD does not specify
where contaminated material is to be stockpiled. That decision
will. be part of 1:11e remedial desiqn.
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A.l.10. Comment: The Mayor and City Council members stated that
EPA has attempted to pressure the City into accepting the
Proposed Plan by suggesting that making changes in the plan might
delay the start of construction. The City representatives indi-
cated that this would penalize the City for making legitimate re-
quests. .
A.l.10. ReSDonse: EPA has indicated to the city that making
changes to the Proposed Plan could cause delays in the start of
construction. It was not the Agency's intent, however, to penal-
ize the city in any way, but merely to alert City representatives
to the procedures and delays involved in altering the Plan. The
WHU desiqn in the Record of Decision has been modified to some
extent in accordance with requests by the City. For example, the
modifications requested by coalinga relating to the above ground
height of the WHU required a specific waiver by the RWQCB. The
process of obtaining this waiver necessarilY led to some delay in
initiating clean up. .
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A.l.ll. Comment: In response to EPA~s comment during the public
meeting that the clean up might be delayed by summer heat, the
Mayor noted that work could be performed at night and that sWIIJDer..
heat should not be an excuse to delay the start of the clean up.
A.l.ll. ReSDonse: Delays in the issuance of the Record of Deci-
sion have made it likely that the work on the remedy will begin
in the fall and that summer heat will not be a factor in delaying
the clean up. It should be noted, however, that working with
respirator protection in very hot weather can be dangerous for
on-site workers. In addition, the limited visibility available
when using a respirator may make it dangerous to operate heavy
equipment at night. If the clean up were to be performed during
the summer months, the need for an expedited clean up to protect
public health would have to be balanced against the need to
protect the health and safety. of on-site workers.
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A.1.12. Comment: The Mayor suggested that because the OUTS was
prepared by a contractor employed by the Southern Pacific
Transportation Company (SPTC), that not all of the feasible al- .
ternatives were fully explored. . The Mayor was concerned that .the
contractor tried to mitigate the economic impact on SPTC, thereby
"casting a considerable cloud on the process."
A.1.12. ResDonse: As required by law, the OUTS was conducted
under EPA oversight in accordance with EPA regulations and
guidance. Careful oversight by EPA ensured proper preparation of
the OUFS. EPA has determined that the alternatives were ade-
quately evaluated in the OUFS.
A.1.I3. Comment: The Mayor requested a fifteen (15) day advance
notice of any final decisions regarding the site.
A.l.13. ReSDonse: EPA does not provide formal notice of the
Record of Decision for public comment. Bowever, EPA has con-
tinued and will continue to communicate with City representatives
.on a regular basis concerning the site and any decisions concern-
ing the Site remedy.
COIIJIENTS BY CXTY COUIICXL IIBJIBBRS AT TJIB PUBLXC JlBBTXIIG 011
~BBRUARY 22, 1'.'
A.2.1. Comment: City representatives stated that the City of
Coalinga will need some technical advice from an environmental
attorney or an environmental consultant and that they do not
believe that the City should have to pay for that.cost.
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A.2.1. ReSDonse: If Coalinga decides to hire an attorney or a
consultant, the City will have to bear that cost. There is no
mechanism for EPA to pay that cost. Although EPA does offer
technical assistance grants (TAG) of up to $50,000.00 to com-
munity groups in areas near Superfund sites, the TAG is not
available to municipalities (40 C.F.R. Section 35.4030(a) (4»or
potentially responsible parties (40 C.F.R. section
34.4030(a)(1», such as the City.
A.2.2. Comment: The public agencies seem to be more concerned.
with protecting endangered species, protecting non-potable ground
water and protecting the health of on-site workers than they are
with protecting the health of the people of Coalinga. It doesn't
seem right that clean-up should be delayed so that more studies
can be done about endangered species when people are breathing
asbestos-laden air.
A.2.2. ResDonse: Under its emergency removal authority
provided by CERCLA Section 106(a), EPA was able to require spray-
ing of salient on the asbestos piles and restrictions on access,
thereby substantially reducing the immediate hazards at the Site.
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CERCLA section 106 authorizes EPA to require such actions quickly
to respond to situations posinq an imminent and substantial en-
danqerment. Lonq term remedial response actions, however, must
meet applicable federal and State requirements, such as the En-
danqered Species Act and the Occupational Health and Safety Act,
in accordance with CERCLA Section 121(d). Compliance with these
. applicable or relevant and appropriate laws can require time con-
suminq studies and planninq.
A.2.3.
Comment:. Is a 21 day public comment period leqa11
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A.2.3. ReSDonse: CERCLA Section 117 requires a reasonable op-
portunity for public co_ent on the proposecl plan. . EPA initially
decided to use a 21 day public comment period in order to ex-
pedite the cleanup process. In response to public concern that
this time period was inadequate, the comment period was extended
for an additional 22 days, for a total public comment period of
43 days. .
A.2.4. Comment: What, if any, land use restrictions will be im-
posed on properties adjacent to the WMU?
A.2.4. ReSDonse: EPA will require all land use restrictions.
necessary to protect the inteqrity of the cap and drainaqe system
of the WMU, in order to.protect public health and the environ-
ment. Land use restrictions will apply to the area of the cap.
A.2.S. Comment: The public comment period did not allow ade-
quate time to examine documen.ts. The oaFS was not available in
the repository for review when public comment period opened. .
A.2.S. ResDonse: As mentioned previously, the public comment
period was extended from March 2, 1989 to March 24, 1989 to allow
additional time to examine the oaFS, the Proposed Plan and the
Administrative Record. Several copies of the OUFS were mailed by
Federal Express to the Coalinqa Public Library on February 8,
1989. To the best of EPA's knowledqe, the OUFS was available in
the coalinqa Public Library on February 9, 1989 as scheduled. As
noted above, however, the full Administrative Record was not
available at the Coalinqa Public Library until February 23, 1989.
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A.2.6. Comment: If the City Council cateqorically
option of locatinq the WMU within the City limits,
other options? The City of Coalinqa should not be
for.the clean up.
A.2.6. ResDonse:.. Community acceptance is one of nine criteria
on which EPA evaluates alternative remedies under CERCLA. As
discussed above in ReSDonse A.1.4 the oaFS for the City of
Coalinqa Operable Unit contained detailed evaluations of five al-
ternative remedies. Four of these alternatives did not involve
disposal in an on-site WHO. As was noted in ReSDonse A.1.4; the
rejects the
what are the
responsible.
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ROD describes the bases for EPA's determination that an on-site
WHO is the best remedy ~der t4e circumstances. If it is deter-
mined that the City of Coalinqa is a responsible party, the City
will be jointly and severally liable for the costs associated
with the selected 'remedy.
A.2 . 7 . Comment: what is the earthquake ratinq of the vault?
What did the qeotechnical studies show about the location of
Holocene faults in relation to the proposed vault location?
A.2.7. Response: ,The WHO is desiqned to be stable in the event
, of the maximum credible earthquake expected in the Coalinqa area.
The earthquake experienced in the Coalinqa-area in May of 1983
had a maximum peak qround acceleration of .54 q. The WMU is
desiqned to be stable at a qround acceleration qreater than or
equal to '.7 g. The Holocene faults which were active during the
1983 earthquake were not expressed at the surface in the City of
Coalinqa. No holocene faults have been documented at or near the
WHO Site. A qeoloqist reqistered by the State of California will
be present at the Site durinq excavation of the WMU area to con~
firm that no faults- exist in this area'. ' '
A.2.8. Comment: EPA standards for asbestos may chanqe in the
future. If less than or equal to 1 area percent asbestos by PLM
is no lonqer considered clean in the future, what will happen to
the Site? '
A.2.8. ReSDonse: If new studies of the effects of asbestos
revealed that the bealth based performance level relied upon in
the ROD was not protective of public health or the environment,
EPA would, reevaluate the situation and take appropriate action.
A.2.9. Comment: Is the WMU classified as a Clas~ 1 hazardous
waste landfill? Who owns the land where the WMU is qoinq to be
located? Are SPTC and SPLC the same company? '
A.2.9. ReSDonse: The WMU is not classified as a Class 1 haz-
ardous waste landfill and the waste at the Site is not a Class 1
waste. ' SPTC owns the property where the WMU will be located. ,
SPTC and SPLC were previously part of the same company; they are
currently separate corporate entities.
A.2.10. ,Comment: The closinq of Polk Street and the transport
of contaminated material to the WMU area must be done usinq
strict, asbestos handlinq protocol.
A.2.10. ReSDonse: EPA will oversee every phase of WMU con-
struction and transport of contaminated material. State and
federal requlations reqardinq transport of asbestos contaminated
material will be complied with when material is transported to
the stockpile area. This includes wettinq down the material,
coverinq the trucks, and ensurinqthat no spillaqe occurs. The
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route that the trucks take while transportinq the contaminated
material is a detail of the plan that will be resolved durinq the
desiqn phase. '
A.2.11. Comment: City Council members want to ensure that
drainaqe off of the WHO is carefully controlled to avoid floodinq
problems.
A.2.11., ReSDonse: EPA will insure that the desiqn of the WHO
includes ~dequate drainaqe.,' '
A.2.12. Comment: Can asbestos be compacted to a consistency so
that .a parkinq structure can be built on the vault?
A.2.12. ReSDonse: Because much of the asbestos is mixed in
wi th soil, there should be no probl- with compactinq the
material to reduce its volume by 95'. This should allow a park-
inq structure to be built on the vault if the City would like to
do so. '
A.2.13. Comment: Contaminated material is qoinq to be'ex-
cavated from ce~ain areas in the Site and then replaced with
fill material. Will this fill material be clean or will it be l'
contaminated? What are the requirements for compaction of the
fill material?
A.2.13. ReSDonse: The fill material will have less, than or
equal to 1 area percent asbestos, which is the detection limit by
the EPA-approved testinq method (i.e., PUt); this is the selected
clean up level for the site. Compacti~n requirements have not
been ascertained; those requirements will be a part of the
detailed desiqn plan. '
B.
COJDlBtrr8 BY TJIB II1'1'B1UI8TBD PUBLIC AT TJIB .PUBLIC JlBBTIBG
B.1. Comment: If removal and transport costs are low, why is
the cost of shippinq the material to the Kettleman landfill so
much more than the construction of a WHO? '
B.l. ResDonse: The major increased cost associated with ,the
Kettleman option is the charqe (per ton. of material) to put
material into the landfill. The current cost to dispose of as-
bestos at Kettleman is $200/ton. There are estimated to be ap-
proximately 20,000 tons of contaminated material on the Site.
Hence it would cost approximately $4 million to deposit the con-
taminated material at Kettleman. Transportation costs would also
be hiqher to take the contaminated material to Kettleman than to
place it in an on~site WHO.
B.2. Comment: Compare the amount of asbestos waste present to
the amount of nickel waste present.
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B.2. ReSDonse: Asbestos and nickel are measured by different
methods using different units on different scales. Asbestos is
measured using a variety of different units depending on the .
medium being sampled (i.e. air, soil, water, insulation material,
etc.). Nickel is measured in milligrams (mg) per liter or mg.
per kilogram. In addition, while sampling performed at the Site
has found a range of levels of each contaminant, there has been
no measurement of the total volume of either contaminant at the
Site. As a result, a direct comparison of the amount of asbestos
and nickel waste present is not possible.
B.3. Comment: Who pays for the EPA time on this Site and the
cost of operation and maintenance?
B.3. ReSDonse: As noted above, EPA-will deal with the issue of
liability in the enforcement process. Those PRPs who are deter-
mined to be liable for the clean up will be responsible for all
costs associated with remediation of the Site, including EPA's
costs and operatio~ and maintenance costs.
B.4. Comment: The New Idria Serpentine Mass-, one of the largest
asbestos deposits in the world, is located near coalinga in the
mountains. Asbestos from this formation washes down throughout
the whole area, so isn't there greater than one percent asbestos
allover the place in Coalinga?
. B.4. ReSDonse: Naturally occurring asbestos is present in the
coalinga area.' EPA is not able to address any hazard which may
be posed by this naturally occurring material and is limited to
cleaning up asbestos which is present at the Site as a result of
human activities. EPA has determined that the large volume of
asbestos that is present at the Site was deposited there asa
result of the milling, mining and transport of asbestos. The
Operable unit site was a major shipping depot for asbestos. As-
bestos ore and other mining materials were brought in from the
mines to Coalinga and then shipped out by train and truck. EPA
has determined that the high concentrations of asbestos at the
Site are the result of improper disposal and handling of asbestos
containing material during these activities. These facts bring
the substances at the Site within the purview of CERCLA and a
clean up of the asbestos at the Site to health based levels is
therefore .. a~pr.opriate.
B.S. Comment: Is the chromite ore in the Marmac warehouse ad-
dressed in the clean up plan? Is the chromite ore considered a
mining waste? The chromite ore should be considered a resource
and not a.wast~~
B.S. ResDonse: The Proposed Plan provides that the chromite ore
in the Marmac warehouse will be disposed of in the WMU unless a
plan for its recycling or reprocessing is approved by September
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15, 1989 and the material is removed for recycling or reprocess-
ing by october 16, 1989. Analysis of the chromite ore indicate
that the chromium content is too low for it to be considered a
hazardous waste by the state of California. However, because the
chromite ore is contaminated with asbestos at levels exceeding
one area percent by PLM, it is a hazardous substance under
CERCLA .
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B.6. Comment: One community member suggested that the waste be
put in the pit at the Granite Rock Company quarry.
B.6. Res~onse: The Granite Rock Company has no connection with
the asbestos waste in the City of coalinga.. It is unlikely that
a company with no liability for the site would allow contaminated
material to be placed on its land. Further, it would violate
State and federal laws to dispose of the material in such a
fashion. For example, this action would violate Cal. Admin. Code
Title. 23, Chapter 3, Subchapter 15, which requires Class B min-
ing wastes to be disposed of in a WHO with an impermeable cap.
C. COMIIBJIT8 DDB BY PU. DJ LBftBRS TO IIPA AJtD IB COIIIDDII'!8
DURIBG TJIII PUBLIC DIITIBG
C.1. Comment: The public comment period did not allow the PRPs
adequate time to examine documents, develop a response and/or
make a good faith offer.
C.1. ReSDonse: Eighteen PRPs were notified of the~r potential
liability in letters from EPA sent in the spring of 1988: the
City of Coalinga was notified of its status as a PRP in a letter
dated Kay 10, 1989. PRPs were also provided-with notice of the
public comment period on the OUFS and Proposed Plan which began
on February 9, 1989, and of the extension of that comment period
until Karch 24, 1989.
, Eighteen PRPs were notified in a letter dated February 22, 1989
that they would have until Karch 28 to make a good faith offer to
perform the remedial action. While this period is substantially
shorter than the sixty days provided for under the special notice
procedur~sof CERCLA Section 122(a), the use of those procedures
is discretionary. In this case, EPA chose not to employ those
procedures because of the immediate nature of the hazard at the
Site. While preliminary steps have been taken to address the
hazard, EPA determined that the clean up of this site should be
expedited in light of the significant remaining risk to the
public health and the environment.
C.2. Comment: What are the EPA costs to date on the City of
Coalinga Operable Unit project?
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C.2. Res'Donse:
of $89,000.00.
SP'l'C to conduct
Plan ~ .
EPA costs as of February 2, 1989, were in excess
This amount does not include costs incurred by .
the feasibility study and draft the Proposed
C.3. Comment: Marmac Resources, Inc. questioned the profes-
sional credibility ot IT corporation (the contractor for SP'l'C
which performed the feasibility study), inferrinq that because IT .
stands to benefit from hiqh enouqh readinqs to require cleanup,
and since its measurements are open to some 'subjective
adjustments', self interest may have been a factor in its
reports. . .
C.3. Res'Donse: All samplinq and analyses have been conducted
under strict EPA oversiqht usinq Aqency procedures, includinq ,
quality control/quality assurance and chain of custody proce-
dures. . .
C.4. Comment: The OUFS does not specifically address the poten-
tial risk to public health and the environment from short fiber
chrysotile asbestos and nickel contaminated soil. No risk as-
sessment was performed and therefore the OUFS cannot be con- .
sidered complete. ' Without a complete OUFS, adequate evaluation
of alternatives cannot be done.
C.4. Res'Donse: The ROD and other documents in the Administra-
tive Record analyze the risk at the site and the ability of the
different remedial alternatives to address this risk. EPA's
. quidance explicitly recoqnizes that the level of effort ap-
propriate to,performinqa risk assessment at a qiven site depends
on many factors, includinq the concentration and identity of sub-
stances, the number of exposure pathways, the likelihood that the
"no action" alternative will be chosen (it it is likely that the
no action alternative will be chosen, a more thorouqh risk as-
sessment is necessary). Draft RI/FS Guidance, March 1988, at
3-36 to 3-37. Chrysotile asbestos contamination of soils and the
presence of asbestos ore waste and nickel-contaminated waste at
the Site have been con~irmed by extensive samplinq. Asbestos is
one of the few-known human carcinoqens. One pathway is of most
concern: inhalation. The uncontained asbestos-contaminated
materials are located very close to a population center: without
remediation, t~e receptor population, which includes younq .
children, may be subjected to daily exposure. The OUFS and the
supportinq Administrative Record clearly establish that an im-
minent and substantial risk to the public health is present at
the City of Coalinqa Operable Unit. Given all of these factors,
it was extremely unlikely that the no action alternative would be
chosen. Considerinq all relevant factors, the analysis of site
risk contained in the Administrative Record meets both the terms
and the spirit ot EPA's requirements.
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Based on extensive experience at numerous other asbestos- '
contaminated Sites, EPA determined that accurately quantifying
baseline risks and the reduction in risk at asbestos-contaminated
Sites due to various alternatives is beyond the present
capabilities of environmental science. A risk assessment has
been conducted for the Atlas and Johns-Manville Superfund sites
to fulfill NCP requirements, which is in part applicable to this
operable unit and will be added to the Administrative Record.
However, EPA deemed it inadvisable to unnecessarily delay the
release of the OOFS and Proposed Plan while awaiting the release
of this risk assessment, as it is peripheral to our understanding
of the situation in the City of Coalinga and the best way to ad-
dress it. ' '
C.5. CODDDent: The evidence linking ingestion of ,asbestos with
adverse human health effects is weak.
C.5. ReSDonse: EPA is most concerned about the risk to human.
health from inhalation of asbestos at this Site, these risks have
been widely documented. EPA has also concluded that there is
evidence that ingestion of asbestos may also pose a significant
risk to human health. Results of studies investigating the link
between ingestion of asbestos and cancer have been less con-
clusive. However, in a National Toxicology Program (1984) bioas-
say, male rats ingesting intermediate range chrysotile fibers had
a significant increase in benign, epithelial neoplasms in the
large intestine. EPA considers evidence that a substance causes
benign tumors as an indication that the substance is a possible
carcinogen. ' '
C.6. Comment: Marmac Resources commented that cleanup. of the
warehouse area will not solve the airborne asbestos problem in
Coalinga.
C.6. ResDonse: EPA has determined that although there is
naturally occurring asbestos in the Coalinga area, that the as-
bestos in the warehouse area of the site was deposited there as a
result of human activity. Therefore a clean up of this hazard is
appropriate, as explained in Response 8.4. above.
C.7., Comment: Marmac Resources commented that the asbestos in
the warehouse area was brought there by natural environmental
forces or by other PRPs.
C.7. ResDonse: See Response 8.4. above regarding human
transport of the asbestos found at the site. The issue of
transport of asbestos to the Site by other PRPs as opposed to
Marmac Resources will be dealt with in the enforcement process
and is irrelevant to EPA's selection of the remedy for the Site. '
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C. 8. Comment: Marmac Resources commented that the chromi te ore
in the warehouse area of the Site presents no hazard, or imminent
and substantial endangerment to human beings.
C.8. ReSDonse: Testing of the chromite ore revealed that.
chromium content was sUfficiently low that the presence of that
metal did not pose a hazard. However, sampling also demonstrated
that the chromiteore was contaminated with asbestos. It is the
asbestos content which is the basis for EPA's determination that'
the chromite ore must be handled as a hazardous substance.
C.9. Comment:. Marmac
waste in the warehouse
properly be classified
and should be excluded
Resources commented that the chromite ore
is a strategic mineral which could.
as an exempt non-hazardous mining waste
from the Proposed Plan.
C.9.0ResDonse: Three companies were contacted by ATEC
(consultants to SPTC) regarding disposal of the chromite ore,
during the Hazardous Substances containment Study. Analyses of
samples from the chromite ore pile indicated that metal con-
centrations were too low to be ofoany commercial use. None of
the companies contacted could use the chromite ore. However, the
ROD does allow for the possibility of recycling or reprocessing
of this material. See also Response C.8., above.
C.ll. Comment: Vinnell Mining and Minerals corporation (VMMC)
stated that the sealing of asbestos contaminated material to tem-
porarily'suppress dust on the Site should be considered as a
remedial action al ternati ve.' .
C.ll. ReSDonse: The spraying of biodegradable sealant on the
asbestos-contaminated material was an interim action. designed to
reduce airborne asbestos during the detailed Site investigation.
It was not considered as a possible remedial action alternative
for the following reasons. Selection of this remedy would vio-
late ARARs and, therefore, would not comply with CERCLA section
121. The National Contingency Plan also contains a strong bias
towards long-term solutions. Spraying with a sealant which has
to be reapplied on an annual basis does not meet this criteria.
Second, spraying with sealant to contain the asbestos would also
require significant land use restrictions on large areas °
throughout the Site. The community has indicated that it does
not favor a remedy that would result in such land use restric-
tions. '.
C.12. Comment: VMMCcommentedthat without air monitoring in
coalinga after the spraying of the sealant, it is not possible to
judge whether the spraying has had the desired effect of reducing
airborne asbestos in the Coalinga railway corridor. If the
sealant spraying has not.reduced airborne asbestos, then it fol-
lows that the source of asbestos in coalinga must be other nearby
or regional sources. .
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C.12. Res~onse: As men~ioned previously, sealan~ spraying was a
temporary action to s~abilize the asbes~os contamina~ed areas
whileevalua~ing feasible remedial alternatives. Sealan~ spray-
ing was never in~ended to be the final remedial action: there-
fore there was no need to conduct post-spraying air monitoring. .
Even if such air monitoring had been conducted, it woul~ not
yield conclusive data due to the many environmental variables in-
volved. The RQD includes extensive confirmation soil sampling to
ensure that the clean up mee~& the specified goals.
C.13. Commen~: Represen~a~ives for VMMC believe tha~ the Asbes-
tos ~azard Emergency Response Act (AHERA) has been misapplied.
The OUPS applies the one percen~ AHERA criterion to all samples
as opposed ~o ~ulk sample.. - - -
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C. 13. ResoOnse: In the ROD, EPA de~ermined tha~ le8& than or
equal to 1 percent by PLM is -an appropriate, health-based cleanup
level for this Site regardless of the AHERA standard. EPA relies -
on the AHERA ARAR only for the use of PLM a& an appropriate
method of measuring asbestos area percent. The OUPS was incor-
rect in this regard. The PLM method, as contained in AHERA, is
the only EPA-approved _thod for measuring asbestos levels in
bulk samples, i.e. bulk samples of friable insulation materials,
as distinguished from air or water samples.
C.14. Comment: VMMC commented that details of the regional air
modeling should be included in the OUPS or be made available as
separate technical memoranda.
C.14. ReSDonse: The regional air modeling is part of the ongoing
Remedial Investigation at the Atlas Mine and Johns-Manville -
Coalinga Mill Super~und Sites. Details of this modeling will be
presented in the JU for those sites. EPA did not rely on the
details of the regional air monitoring in selecting a remedy for
the City of coalinga Site. - -.- - --..--
C.1S. Comment: VMMC commented that the screening of feasible al-
ternatives'in the OUPS was incomplete.
C.lS. ResDonse: EPA has de~ermined tha~ the OUFS presen~s a
thorough evaluation of the feasible alternatives. The al~erna-
tives and the factors used to evaluate them are described in the
ROD. See also ReSDonse A.l~4.
C.16. Comment: VMMC commented that detailed design work on the
WMU has been proceeding before public comments on the OUPS were
received.
C.16. Res~onse: The ROD is a conceptual document that describes
a remedial alternative in general terms. A PRP remains free to
begin design work at their own expense and risk at any point. As
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of the date of ROD siqnature, no agreement has been entered into
between EP~ and any PRP which authorizes work on the remedial
desiqn.
C.17. Comment: Atlas Minerals corporation commented that it was
interested in participating in the process of cleaning up asbes-
tos and nickel contaminated material in Coalinga.
C.17. ReSDonse: EPA will deal with the issue of PRP participa-
. tion in the clean up process in the enforcement process. Par-
. ticipation is not relevant to selection of. remedy.
C.18. Comment: Atlas Minerals asked how many PRPs had entered
into Consent Agreements concerning this site and which ones were
involved in preparation of the OUPS. .
C.18. ReSDonse: To date no parties have entered into any aqree-
ments with with EPA regarding the Site. EPA has sent letters to
eighteen PRPs invitinq them to present good faith offers to and
negotiate settlements with EPA. Negotiations are ongoing at this
time. SPTC conducted a Site Characterization and prepared the
OUPS for the Site with EPA oversight, pursuant to an Administra-
tive Order issued to them by EPA. . .
C.19. Atlas Mineral Division of Atlas Corporation raised the
following questions in a 24 page letter, from Konrad W. Harper of
Simpson Thacher to Jon K. Wactor of EPA, dated March 23, 1989:
C.19.a. Comment: Do the data, within analytical and sampling er-
ror, demonstrate that the 210 West Glenn Street property cur-
rently is contaminated with asbestos generated by historical
warehouse activities.
C.19.a. ReSDonse: The Administrative Record contains data which
demonstrates that the West Glenn Street property is contaminated
with asbestos in excess of 1 area' and up to 80 area' by PLM.
The history of the:Site indicates that the asbestos contamination
at the Site is a result of human activity, includinq activity at
the historic Atlas warehouse and distribution center.
C.19.b. Comment: Is the Glenn Street property posing an unaccep-
table asbestos health risk?
C.19.b. ReSDonse: Yes. The high levels of asbestos present on
the property post an unacceptable health risk, especially through
the inhalation pathway. The ROD and other documents in. the Ad-
.ministrative Record elaborate on the nature of this risk.
C.19.c. Comment: Is remediation of the Glenn Street property
necessary?
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C.19.c..ResDonse: Yes. Remediation of the contamination at the
property is necessary to protect human health and the environ-
ment. .
C.19.d. Comment: Is remediation of the Glenn street property
cost-effective?
C.19.d. ReSDonse: CERCLA Section 121(a) requires that. the
response action be cost-effective. The cost-effectiveness
remedy selected for this Site is documented in. the ROD and
Administrative Record.
of the
the
C.19.e. Comment: Could the asbestos detected at the Site be as-
bestos wind-blown from other locations or asbestos resulting from
activities at the Site since 1966?
. .
C.19.e. ReSDonse: Evidence collected by EPA and contained in the
.Administrative Record indicates that it is extremely unlikely
that the asbestos at the Site could have been blown there from
other locations. Samples were taken at the'site with concentra-
tions of asbestos as high as 98 area' by PLM. On the Glenn
Street property concentrations as hiqh as 80 area' by PLM were
found. Activities subsequent to 1966 may have contributed to
some of the contamination in some parts of the Site.
C.19. f. Comment: Why is the WMU desiqned above grade?
. .
C.19.f. ReSDonse: The WMU was oriqinally desiqned to be above
grade in order to maximize drainage. The ROD requires the WMU to
be constructed to be as close to grade as is feasible.
C.19.g. Comment: Is the WMU containment structure, as desiqned,
necessary?
C.19.g. ReSDonse: Yes. Some of the desiqn criteria are required
by ARARs. The technical bases for other desiqn criteria can be
found in the Administrative' Record. ' See correspondence with the ..
Regional Water Quality Control Board throughout the Administra-
ti ve Record. ' '
C.19.h. Commen~: Why is the WMU containment structure not located
in existing riqhts of way
C.19.h. ReSDonse: See Response A.l.3.
C.19.i. Comment: Why did EPA not discuss the preferred alterna-
tive prior to the public meetinq?
C.19.i. ReSDonse: EPA did discuss the preferred alternative (i.e.
the proposed plan) in the fact sheet that it distributed 13 days
prior to the public meeting to all parties who had expressed an
interest in the Site. Furthermore, this alternative was dis-
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cussed in detail with many of the members of the Coalinga city
Counsel, at previous City Counsel meetings, and in meetings vith
all known PRPs, including representatives of Atlas, prior to the
start of the public comment period.
C.19.j. Comment: Why is the public comment period extremely
limited?
C.19.j. ResDonse: The original public comment period vas limited
to expedite final clean up of a substantial endangerment to
public health. EPA extended the public comment period to 43
days, which is longer than that provided at many other sites. The
43 day period provided a reasonable opportunity for public co.- .
mente
C.19.k.. Comment: What is meant by the short and long term effec-
tiveness of the preferred alternative as discussed?
C.19.k. Res~onse: The meaning of short and long term effective-
ness of a remedy is discussed in A Guide to Develo~ina Su~erfund
Records of Decision (July 1988). "Short term effectiveness ad-
dresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may .be
posed during the construction and implementation period, until.
cleanup goals are. achieved." P.3 "Long term effectiveness and
permanence refers to the ability of .a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup goals have been met." P.3.
C.19.l. Comment: What are the current regional and site-specific
human and environmental risks, and can they be quantified?
C.19.l. Res~onse: The risks at the site and the problems with
quantifying them are accurately are discussed in the ROD, includ-
ing Appendix 1, and the Administrative Record. See also,
Res~onse C.4.
C.19.m. COln!!tent: After implementing the preferred alternative
plan, what reduction in human and environmental risks would be
realized?
C.19.m. Res~onse: The risks at the Site and the problems with
accurately quantifying any .reduction in risk as a result of the
remedy are discussed in the ROD and Administrative Recqrd. The
risk associated with potential exposure to extremely rich asbes-
tos ore waste will be significantly reduced. See also Res~onse
C.4.
C.19.n. Comment: What environmental and human benefits will be
achieved with the implementation of the preferred alternative?
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C.19.n. ResDonse:The preferred alternative will contain the haz-
ardous substances under an impermeable cap. Human health and the
environment will be protected from further contact with the con-
taminants.
C.19.0.' Comment: After the preferred alternative is implemented,
what quantifiable and effective reduction in toxicity risk or
" mobility of contaminants will be achieved?"
..:: .
., ...
C.19.0. ReSDonse: See ReSDonses C.19.m and C.19.n, above,
reqardinq the difficulty of quantifyinq risks at the Site. The
remedy will not use treatment to reduce toxicity or mObility but
the ~elected remedy does effectively reduce the mobility of the
contaminants throuqh containment. The risk of exposure to haz-
ardous substances is also effectively reduced by the selected
remedy. ."
C.19.p. Comment: What are the itemized costs associated with
implementinq each of the evaluated alternatives?
C.19.p. ReSDonse: The estimated costs for the evaluated alter-
natives are as follows:
a) no action: neqliqible
b) :Removal of waste to an abandoned mine site: $9 million
c) Soil cover in place: $600,000 to $800,000
d) Disposal at an off-site landfill: $5.5 million
e) Disposal at an on-site landfill: $2.5 million
The hiqh cost of removal of the waste to an abandoned mine site
is due to the cost of buildinq roads to the mine site. The hiqh
cost of disposal at an off-site landfill is a result of the fees
for disposal at such landfil~s. The cost for disposal at an on-
site landfill is for construction, includinq labor, and operation
and maintenance. See also, ReSDonses C.19.ccc and C.19.s. "
C.19.r.Comment:. What are the detailed plans for implementinq"...
the preferred alternative?
C.19.r. ResDonse: A conceptual desiqn is included in Desiqn
Report, Asbestos Waste Manaqement Unit, SPTC, Administrative
Record Doc. I 624. Final Desiqn will be approved by EPA in the
future context of this case.
C.19.s. Comment: What criteria were used to estimate the costs
to implement the preferred remediation plan?
C.19.s. ReSDonse: Specific criteria included the costs of meet-
inq ARARs, local labor rates, materials for construction of the
WHO, labor rates for workers in level C protection, water rates,
and costs of water trucks and enclosed trucks. Guidance For Con-
ductinaRemedial Investiaations and Feasibilitv Studies Under
CERCLA (October, 1988), Evaluatina Cover Systems for Solid and
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Hazardous Wastes (September 1982), SW-867 (EPA-D-03), and Desian.
Construction and Maintenance of Cover Systems for Hazardous
Wastes: An Enaineerina Guidance Document, (EPA 600-2-87-039)~
C.19.t.Comment:What are the itemized costs for conducting the
technical studies by EPA and SPTCo?'
C.19.t. ResDonse: The itemization of these costs is not
relevant to EPA's selection of the remedy at this Site. The
cern of this PRP with respect to specific past costs will be
dealt with in the enforcement context, as is appropriate.
C.19.u. Comment: Atlas states that the literature tends to sup-
port the conclusions that the health risks of short fiber asbes-
tos are less than those of long fiber asbestos and that such
risks are less for chrysotile asbestos than for other forms of
asbestos.' .'
con-
C.19.u. ResDonse:EPA considers short fiber asbestos and long
fiber asbestos to be equally carcinogenic: ample evidence in the
Administrative Record supports this view. EPA disagrees that the
literature supports an opposite view. The recent Asbestos Ban
Rule specifically supports EPA's position in this regard. See Ad-
ministrative Record Document 11105.
C.19.v.
Comment:
What are the regional asbestos health issues?
C.19.v. ReSDonse: The ROD and documents in the Administrative
Record explain the relationship between the regional health
issues and the site. The Remedial Investigation for the Atlas
Mine Site further addresses these issues: a complete understand-
ing of all region-wide issues is not necessary to select a remedy
to address the immediate health risk at this Operable Unit. .
C.19.w. Comment: What are the asbestos regional and local back-
ground concentration levels? .
C.19.w~ ResDonse: Background concentration levels vary depend-
ing on. proximity to the New Idria Serpentine Mass, meteorological
conditions, human dust generation activities, and other factors.
Regional air monitoring indicated elevated levels of asbestos in
ambient air samples collected in Coalinga compared to background
levels collected in Hanford, California. The detailed data on
these levels are contained in the Administrative Record.
C.19.x. Comment: What health risks are associated
fiber asbestos? Does the chrysotile asbestos found
Coalinga region induce an unacceptable health risk?
chrysotile asbestos carcinogenic?
with short-
in the
Is the
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C.19.x. ReSDonse: Asbestos is a known human carcinoqen. Al-
though there is substantial disagreement in the scientific.com-
munity over which forms of asbestos are the most hazardous and
carcinogenic, EPA has determined, based on the best available
evidence, that the asbestos at the Site presents an imminent and
substantial endangerment to human health and the environment that.
requires remediation. See also, ReSDonse C.19.u.
C.19.y. Comment: Are short asbestos fibers less of a health
risk than long asbestos fibers, and if so, what health risk has
been introduced by historical warehouse activities in the City of
Coalinga? .
I.
, '-.".
C.19~y. ReSDonse: See ReSDonses C.19.u and C.19.x. for the
answer to the first part of this question. The apportionment of
responsibility among Potentially Responsible Parties is not
directly relevant to EPA's selection of the remedy~ EPA will ad-
dress these enforcement related concerns in the enforcement con-
text. See also, ReSDonse C.19.jjj.
C.19.z. Comment: What are the historical and current asbestos
health risks in the City of Coalinga?
C.19.z. ReSDonse:See ReSDonses C.19.y, C.19.x, C.19.u, and
C.4, as well as Appendix 1 to the ROD.
C.19.aa. Comment: What exposure and health risks associated with
the asbestos are found within the study area?
C.19.aa. ReSDonse: The main pathway of exposure to asbestos at
the Site is through inhalation, although ingestion also repre-
sents some risk. To the best of EPA's knowledge, epidemioloqical
surveys have not been performed in the .Coalinga area. . .
C.19.bb. Comment: Does the preferred remediation plan mitigate
asbestos exposure as. well. as unacceptable ~ea.lth risks?
C.19.cc. ReSDonse: The proposed plan mitigates unacceptable
health risks by mitigating exposure to asbestos.
. .; '. 4
C.19.dd. Comment: Can a cost-effective remediation plan be
implemented, and can the plan be justified?
C.19.dd. ReSDonse: Yes. The proposed plan is fully implement-
able from a technical standpoint. As determined in the ROD, the
plan meets all the requirements of CERCLA and the National Con-
tingency Plan, including cost-effectiveness.
C.19.ee.
Comment:
What is the background nickel concentration?
23
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24
C. 19.ee. Response : Background concentrations of nickel in Han-
ford, California were measured at 70 ppm, using the TTLC Wet Ex-
traction Test. Western soils have been documented to contain 16
ppm nickel. Background levels vary depending on proximity to the
New Idria Serpentine Mass, meteorological conditions, human dust
generation activities, and other factors.
C.19.ff. ?9Fff ?nt * Is nickel an environmental health risk in the
City of Coalinga?
C.19.ff. Response : Yes. The major environmental health risk from
nickel in the City of Coalinga is from inhalation of nickel-laden
dust. See also, Toxological Profile for Nickel, Admin. Record
Doc. I 668.
C.19.gg.
-------
25
C.19.kk. Comment: Does the nickel concentration pose an unac-
ceptable human health and environmental risk?
C.19.kk.
ResDonse: .
Yes.
C.19.ll. Comment: If the preferred plan is implemented, will
health risks be cost-effectively reduced?
. C.19.ll. ResDonse: Yes. CERCLA section 121 requires that the
selected response action be cost-effective and protective of
public health and the environment. In the ROD, the Reqional Ad-
ministrator determined, based on the Administrative Record, that
the selected alternative is a cost-effective means to protect
publi~ health and the environment.
C.19.mm. Comment: What are the health risk exposures/pathways
related to nickel concentrations?
C.19.mm. ResDonse: At the Site, exposure via inqestion and in-
halation of nickel dust are the exposure pathways of concern.
. C.19~nn. Comment: Are hiqh nickel releases related to chromite
ore warehouse activities?
C.19.nn. ReSDonse: EPA is aware of no evidence that this is the
case.
C.19.00. Comment: Was a chemical pathway data analysis per-
formed?
C.19.oo. ReSDonse: See ReSDonses A.1.S, A.1.6, C.2, and C.4.
C.19.pp. Comment: Was a contaminant/leachate water balance
analysis performed which demonstrated percolation throuqh the im-
permeable asbestos? If so, did the results show an unacceptable
human health or environmental risk?
.. -'..
C.19.pp. ResDonse: No, a contaminant/leachate water balance
analysis was not performed. However, a detailed hydroloqic study
was done to assess vertical conductivity between the surface and
the upperaqui~er. This included data on .
precipitation/evaporation rates, permeability of individual sub-
surface layers and characteristics of fluid movement in soils.
This study concluded that even without an impermeable cap, the
potential for movement of fluid from the impounded waste to the
upper aquifer was remote. Asbestos is not impermeable. Asbestos
is not soluble in water and is not expected to move out of the
WMU into the subsurface. The concern of the EPA and the RWQCB .
with respect to subsurface contamination is the possibility of
movement of soluble nickel in percolated water. The impermeable
cap will prevent water from enterinq the impounded waste, makinq
the formation of nickel containinq leachate unlikely. Further,
25
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<~, ~
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26
EPA and RWQCB are contident that the WMU is adequately isolated
from the upper aquifer by several impermeable clay layers in the
subsurface.' , .
C.19.qq. Comment: What toxicoloqical evaluations have been per-
formed, and what were the conclusions?
C.19.qq. ReSDonse: See ReSDonse C.4. and the nickel and asbes-
tos toxicity profiles in the Administrative Record.
C.19.rr. Comment:' What desiqn components ot the WMU are at- ,
tributable to the disposal of nickel, and what are the associated
costs? '
C.19~rr. ReSDonse: The low permeability ot the cap and the
neutron probes to detect moisture within the the impounded waste
are desiqn components attributable to the presenceot nickel.
The exact costs attributable to these desiqn components cannot be
determined until final desiqn is approved bY EPA.
C.19.ss. Comment: Atlas comments that a waiver from ARARs
should have been considered, and that more data should have been
, collected to justify such a waiver.
C.19.ss. ReSDonse: EPA determined that a waiver from ARARs was
not appropriate for this Site. Atlas does not indicate why a
waiver would be appropriate or even what waiver miqht be ap-
propriate, so EPA is constrained from replyinq in any more
detail. .
C.19.tt. Comment: Why are asbestos and nickel relationships not
adequately discussed?
C.l9.tt. ReSDonse:The relationship between asbestos and nickel
is adequately discussed in the OUFS for purposes of remedy selec-
tion. A positive correlation between the asbestos contamination
and the presence of nickel at the site is demonstrated by the
data contained and discussed in the Hazardous Substance contain-
ment Report which is included in the Administrative Record.
C.19.uu. Comment: In addition to backqround concentratiQns,
what are the other sources for nickel levels found in the soils?
C.19.uu. ReSDonse: EPA has determined that nickel levels in ex-
cess of backqround at the Site are a by-product of the asbestos
millinq process. .
C.19.vv.
suppl ies,?
Comment:
will nickel have an impact on drinkinq water
26
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"27
C.19.vv. ResDonse: The City of Coalinga qets its drinkinq water
from the California Aqueduct: nickel is not expected to impact .
drinkinq water supplies. See ReSDonse A.1.5. However, the
nickel could have a neqative impact on other beneficial uses of
the aquifer, includinq irriqation. See correspondence with the
Reqional Water Quality Control Board throuqhout the Administra-
tive Record.
C.19.ww. Comment: Will nickel have an adverse impact on the
water quality in the uppermost aquifer?
C.19.ww.
ReSDonse:
See ReSDonses A.1.5. and C.19.vv.
C.19.xx. Comment: What are the cost-effective attributes as-
sociated" with the design of the preferred mitigation plan?
C. 19 . xx. ResDonse: The OtJFS and the ROD both" describe the
cost-effectiveness of the proposed plan. .
C.19.yy. Comment: What chemical pathways of nickel have been
demonstrated that will result in quantifiable contamination to
the environment and a quantifiable health risk?
C.19.yy. ReSDonse: It is unclear what is meant by chemical
pathways of nickel in this context. EPA assumed that the com-
menter meant to refer to exposure pathways. The exposure path-
ways of concern are inhalation of nick~l-laden dust and soils,
inqestion of nickel-laden dust and soils, and ingestion of
nickel-laden qround water. The proposed plan will mitigate ex-
posure through all of these potential exposure pathways.
C.19.zz. Comment: What is the chemical fate of nickel in the
existinq environment?
C.19.zz. ReSDonse: It is unclear what is meant by chemical fate
of nickel in this context. The concerns regardinq nickel at this
-Site include leaching of soluble nickel into the ground water and
entrainment of nickel contaminated dust and soil into the air.
C.19.aaa. Comment: The Administrative Record does not show
technical comments and acceptance of the RIfFS and OUFS by the
State of California.
C.19.aaa. ReSDonse: The State has concurred in the selected
remedy." See Admin. Record Doc. , 1094.
C.19.bbb. Comment: Atlas comments that the City of Coalinqa has
not approved or accepted the preferred containment plan, and al-
leqes that "[t]he City of Coalinqa, as represented by its
citizenry and public officials at the February 22, 1989 public
meetinq, disapproved the EPA administrative and technical
processes used to prepare the preferred containment plan."
27
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C.lS.bbb. Response; Community acceptance of the remedy is not a
threshold or primary balancing criteria, rather it is a modifying
criteria. See A Guide to Developing Superfund records of Deci-
sion (July 1988) page 3. EPA's consideration of community con-
cerns is described in the ROD. The procedures followed by EPA in
selecting the remedy for this Site were in full compliance with
CERCLA Section 117'a requirements regarding public participation.
EPA also consulted with the City throughout the process of study-
ing the Site and selecting a remedy, beyond the minimum require-
ments set forth in Section 117.
C.19.CCC. Comment; Atlas alleges that the following information
is "missing" from the RI/FS Administrative Record:
1) Detailed description of the data which define con-
taminant sources and their pathways of migration, as well as
potential sources of contaminants.
2) A risk assessment which determines the contaminants of
concern, their toxicity, potential exposure levels affecting
potential receptors, mechanisms of exposure, and potential ef-
fects.
3) Detailed costs for all evaluated remediation alterna-
tives .
4) Detailed listing of all PRPs and the justification for
including each of them.
5) Detailed itemization of all existing landowners and the
records regarding historical ownership.
6) Detailed itemization of all existing tenants and the
records regarding historical tenancy.
7) Detailed itemization of study costs.
C.19.ccc. Response; For a response to the issues raised by Sub-
parts l and 2 of this Comment, see Response C.4. With respect to
Subpart 3 of this Comment, the total cost of each alternative is
what is considered in determining cost-effectiveness, rather than
a detailed cost breakdown. Subparts 4 through 7 of this Comment
are not appropriately raised in this context because they do not
relate to the basis for selection of the remedy at this Site.
The Administrative Record was prepared pursuant to CERCLA Section
113(k)(2) and contains the information "on which the President
[or the President's delegatee, EPA] will base the selection of
removal actions and on which judicial review of removal actions
will be based." CERCLA Section 113(k)(2)(A). The opportunity to
comment, provided pursuant to CERCLA Section 113(k)(2)(B)(ii) is
an "opportunity to comment and provide information regarding the
plan." The questions raised by this portion of the Comment are
all enforcement related and are more appropriately dealt with in
the enforcement context, not in comments on the proposed plan.
28
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]-
I
29
C.19.ddd. Comment: The only copies of the Administrative Record
readily available to Atlas were located in the EPA Region IX
library and in the public library for the City of Coalinga. At-
las did not receive a copy until March 1989.
C.19.ddd. Res90nse: Pursuant to section 113(k) (1) of CERCLA, EPA
is required to keep a copy of the "Administrative Record at or
near the Site. EPA not only complied with this statutory re-
quirement, but also made a copy of the Administrative Record
available at the EPA Regional Office. Furthermore, EPA staff
supplied copies of many of the principle documents, as well as
much of the relevant information, to Atlas' representatives in
meetings prior to the start of the public comment period.
" "
C.19.eee. Comment: Atlas alleges that EPA "refused access" to
technical data used by EPA, and refers to a Freedom of Informa-
tion Act ("FOIA") they "filed. . . with EPA on July 3, 1988."
Atlas also states that EPA failed to provide it with a copy of
the transcript of the February 22, 1989 public meeting.
C.19.eee. ReSDonse: Atlas granted EPA extensions on the time to
comply with the FOIA request. Also, Atlas has specific rights
under FOIA, including appeal rights, to protect any concerns that
it had or has about Region 9's response to FOIA requests or other
requests for documents. Furthermore, EPA staff supplied copies
of many of the principle documents, as well as much of the
relevant information, to Atlas' representatives in meetings prior
to the start of the public comment period. Without further
elaboration by Atlas regarding its concerns about access to data,
EPA cannot give a more specific response to this comment. EPA
complied with CERCLA section 117's requirements regarding par-
ticipation by the public, including Potentially Responsible
Parties. See ReSDonses C.19.ddd., and C.19.j.
C.19.fff. Comment: Atlas alleges that "[t]he technical data"
used to generate EPA's . . . RIfFS have been collected over the
last ten years." (page two of Atlas' letter): "Atlas comments"
that it was not given an opportunity to participate in EPA's data
collection activities.
" "
C. 19 . fff. "Ih!s~onse: It is unclear what document Atlas is refer-
ring to in this comment. The RIfFS for the Atlas Mine Site is
still ongoing. The data for the Operable Unit Feasibility Study
for this Site was generated over the last two years. Not until
the public meeting of March 22, 1989 did Atlas offer to perform
or take part in response actions at the Site. Atlas was notified
of its status as a Potentially Responsible Party in March of
1988. Prior to the PRPsearch activities, the whereabouts of At-
las were unknown to EPA. .
29
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30 . '.
C.19.ggg. Comment:. Atlas alleges that it was not given an op-
portunity to participate in the design of a cost-effective
remediation 'plan.
C.19.ggg. ResDonse: Atlas was notified of its status as a PRP
in March of 1988. At a minimum, Atlas has had an opportunity to
participate in the selection of a cost-effective remedy through
the submission of its 24 page comment letter; this opportunity
was provided pursuant to Section 113(k) (2) (B) of CERCLA.
C.19.hhh. Comment:., Atlas alleges that in the 1980s EPA conducted
an investigation of the asbestos issues in the City of Coalinga
and determined that ,asbestos must be removed. .
C.19.hhh. ReSDonse: This comment misstates the facts. Regional
air monitoring in the Coalinga area in 1986 and 1987 indicated
elevated levels of airborne asbestos in the City of Coalinga.
Based on this information, EPA initiated an investigation in the
City of Coalinga to determine if localized sources were respon-
sible for these elevated ambient air levels. During the course
of this investigation, several hot spots of asbestos contamina-
tion were identified in the area of the Site. EPA did not decide
to do a complete remedy at the Site until this investigation was
completed. .
C.19.iii. Comment: Atlas alleges that asbestos concentrations
are less than 1 area' in most samples for the Glenn Street por-
tion of the Site, and that only one quality assurance sample
showed an asbestos concentration as high as 2 'TEM. Atlas fur-
ther alleged that the initial results showed less that 1 area'
concentration within the immediate area of the Atlas warehouse.
C.19.iii. ReSDonse: The detailed site investigation indicated
that the Glenn Street portion of the Site is contaminated with
asbestos at levels exceeding two area percent and up to 80 area
percent by PLM. These data are included in the Hazardous Sub-
stance Containment Report which is in the Administrative Record.
The levels of asbestos contamination found in the initial site
investigation were high enough to require further study, which
indicated dangerously high levels of asbestos present. The Glenn
Street Property is the portion of the Site closest to residential
areas.
C.19.jjj. 'Co~ent: Beginning in the middle of page 21 of their
letter and continu~ng up to the concluding paragraph on page 24,
Atlas includes a discussion and questions which are entirely en-
, forcement related.
C.19.jjj. ReSDonse: These comments do not address the bases for
EPA's remedy selection.As explained in Response C.19.ccc above,
the purpose of this public comment period is to provide an oppor-
tunity for interested members of the public to comment and
30
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31
provide information regarding the proposed plan. See CERCLA Sec-
tion 113(k) (2) (B) (ii). This is an inappropriate context for a
PRP to seek information regarding enforcement-related topics.
. ..
.. .
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31
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REVIEW OF ASBESTOS AN1\LYTICALMETHODS
I.
Asbestos Analvtical Techniaues
There are three commonly accepted analytical methods used to
measure asbestos.' They are:
1) Phase Contrast Microscopy ("PCM"):
useful in examining minute particles.
An optical technique
2) Polarized Light Microscopy ("PLM"): An optical tech-
nique that uses polarized light to identify minerals.
3) Transmission Electron Microscopy ("TEM"): A technique
using excitation of electrons to achieve extremely high resolu-
tion of asbestos fibers too'small to be resolved using optical
methods.
A brief description, including the advantages and 'disadvantages
of each technique~ is presented below. "
A.
Phase Contrast Microscocv
Phase contrast microscopy ("PCM") is a method of optical micros-
copy that is commonly used to analyze air samples collected in
the work place (e;g. in enclosed spaces). PCM translates dif-
ferences in the phase of light transmitted or reflected by the
object into differences of intensity in the image. The method is
better suited to analysis of work place air than ambient air be-
cause in the work place one encounters a relatively large con-
centration of large bundles of asbestos fibers. Most of the
available medical ,studies of asbestos diseases have measured as-
bestos using PCM. This is because PCM was the only technique'
available when most of 'the occupational studies were done.
The PCM technique has two major limitations concerning its use in
the ambient environment. The method cannot detect fibers with
diameters of less than 0.2 micrometers. Many fibers in the en-
vironment are much smaller than this. Also, PCM does not distin-
guish between asbestos fibers and other types of fibers. Ther~-
fore, in the environmect, the PCM fiber count may be completely
unrelated to the asbestos fiber content. For these reasons, it
is widely accepted that the PCM method is totally unsuitable for
measurement of asbestos fibers in ambient atmospheres.
The major'~dvantages of PCM are: i) it is relatively inexpensive
and; ii) it is easy to use PCM data to calculate health-based
risk in an occupational environment using the models established
in the older studies.
APPENDIX 1
.. - .
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2
B.
Polarized Liaht MicroscoDv
POlarized Light Microscopy ("PLM") is the EPA-approved method of
analysis for bulk insulation samples. The PLM technique is rela-
tively quick (1/2 hour/sample) and provides a reliable method to:
(1) identify all asbestos types, (2) distinguish between asbestos'
and other fibrous and non-fibrous minerals and (3) identify most
. non-asbestos components of samples. The resolution capacity of
PLM is 200x to 400x magnification. Another advantage of PLM is
that it can be performed for a relatively low cost.
..
There are two ways to do PLM analysis, .the point counting method
and the field comparison method. The point counting method uses
a superimposed grid (gravicule) with 100 points. The operator
counts the points where asbestos is preserit~ The method (point
count) involves the preparation of eight slides, each of which
can be viewed at 100 possible points, to establish the presence
or absence of asbestos at 50 points on each slide. The result
is recorded and reported as area percent based on the number of
positive points. The following format is used for determination:
Area percent = a/n (100)
where:
a = number of points with asbestos fibers present
n = number of non-empty points counted.
The field comparison method, also called "visual estimation" or
the 2-minute method with the stereobinocular light microscope, is
used to quantify a large sample (e.g., I ounce) using the micro-
scope at 30-40x. The operator estimates the homogeneity of the
mixture and estimates the percentage of each individual fibrous
component.
The disadvantages associated with PLM include:
o
Asbestos content determination is usually done by visual
estimate (field comparison) or point counting, and is
thus 'qualitative or at best,' semi-quantitive: concentra-
tion is expressed as the ratio of asbestos to non
-asbestos particles or percent by area.
Small fiber identification is difficult because certain
optical properties (birefringence and the angle of ex-
tinction) are hard to determine in small fibers.
o
o
The smallest fibers that can be observed are ap-
proximately 0.34 micron in diameter: fibers this small,
though observable, cannot usually be identified for
mineral type.
o . Highly skilled analysts are required, particularly in
view of the subjective nature of the determinations.
o
The quantitative limit of detection is 1 area percent.
-------
,v.;- 'I',~I ""\: .;;:;: :~:.....
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Using PLM to identify asbestos in soils can be difficult because
soilS are subjected to erosion and weathering; asbestos bundles
become separated and broken into 'smaller, possibly sub-optical,
sizes much more quickly. than fiber bundles in relatively undis-
turbed insulating materials. Asbestos fibers may also be dis-
persed'by wind and by seasonal flooding. Therefore, a sizeable
fraction of the asbestos fibers in soil could be below optical
resolution. on the other hand. PLM is the only method of measur-
ina asbestos with an EPAaDDroved methodoloav for samDlina and .
analysis. Therefore. it is the one analytical method that can be
adeauately controlled in a auality assurance/auality control
Dlan. Also it is significantly less expensive than TEM analysis.
c.
Transmission Electron MicroscoDY
Transmission electron microscopy ("TEM") is the most powerful
analytical method available for measuring asbestos. TEM can be
used for air, water, or soil analysis. . It.is the preferred in-
strumental technique for measuring asbestos in ambient atmosphere
since it incorpor~tes the most powerful combinations of iden-
tification methods. TEM analysis uses electron microscopy, at
magnifications of 10,000 to 50,000 times, to detect asbestos to
the single fibril level. Fibers as small as 0.2 nanometers in
diameters can be identified. Besides the transmission electron
microscope, which allows the operator to locate very small
.fibers, this technique can also utilize two mineral identifica-
tion tools. These are Selected Area Electron Diffraction
("SAED")and Energy Dispersive X-ray Analyzer ("EDXA"). Using
these tools, the'operator can identify the mineral type from a
single point on the specimen.
The disadvantages associated with TEM include the following:,
o
No widely accepted TEM method is available for the
analysis of asbestos in soils~ making it difficult to
correlate interlaboratory data. Sample preparation
methods are not standard among workers, making the
comparison of results between sites or laboratories
very difficult or meaningless.
Analysis .requiresa minimum of 6 .to 8 hours over 2 to 3
days. Highly skilled analysts are required and large
'differences in results' can. occur due to 'operator
variance. TEM analysis is extremely expensive, over 20
times the per sample cost of optical methods.
o
o
Sample size is very small. . Therefore, data must be
extrapolated to a great extent to adequately
character~ze a large site.
o 'Typically, total fibers are counted. Sample preparation
. (i.e., grinding) destroys the fiber size distribution.
- . .
. .
,.
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"
r ..3:: '.
4
I
I
>
-
TEM sample preparation alters the soil matrix. This is sig-
nificant because the sample is dispersed into very fine particles
before it .is put onto a filter for analysis. Since asbestos oc-
curs in clusters and bundles as well as fibers, the sample
preparation process (in the case of soil) can destroy the struc-
ture of those forms and produce a very large number of individual
fibers of small size. Although total fibers are counted as part
of the TEM analysis, these results must be converted to weight.
percent, uSing data on length, width, and density. This conver-
sion to mass is necessary due to the sample preparation grinding
process, which artificially increases the fiber count. How the
TEM weight percent compares with air emissions and risk tables
has not been standardized by government or industry. There~ore,
interpretation of soil data results relative to air samples
and/~r risk charts is very difficult, at best.
I
I'
II.
Problems with Usina Asbestos Data in OUantifvina Risk
Although the role of asbestos as a cause of cancer is clear, the
.ways in which fibers cause disease are not well understood, and
this has complicated efforts to measure asbestos successfully.
Asbestos researchers have not agreed upon which attributes of as-
bestos are important to measure to assess risk, including size
and shape of individual fibers, number of fibers, total mass of
fibers, inclusion of asbestos bundles, clusters, and matrix
debris in the fiber count., and asbestos mineralogical type. . For
.example, most researchers think that longer, thinner asbestos
fibers (those longer than 5 microns in length with an aspect
ratio greater than 3 to 1) are more car~inogenic, i.e., The
"Stanton Hypothesis". However, other researchers question this
approach, suggesting that both long and short fibers may be
biologically active. In addition to fiber dimension, surface
chemistry of the asbestos fibers may playa role in causing dis-
ease. Further, there is disagreement whether mineral type is a
factor in disease causation. Some would argue that chrysotile
asbestos may partially dissolve in weakly acidic environments,
facilitating fiber clearance from the lung. However. EPA's view
is that all asbestos mineral tvnes are eauallv carcinoaenic.
To compound the problem, analysis of ambient samples for asbestos
is much more,difficult than occupational or work place samples,
because the concentration of asbestos in the environment is much
iower. Asbestos fibers found in ambient air are typically too
short and thin to be detected by conventional microscopes, and
may 'be agglomerated with other particulate matter so that they
are masked or hidden. Further, although EPA has attempted to
standardize asbestos analytical techniques, differences in sample
handling, preparation, instrument capabilities, operator
proficiency, and counting procedures make it extremely difficult
to compare results from different laboratories. In short, ac-
curate measurement of asbestos is impeded by many factors,
greatly complicating any estimates of environmental risk. ~
this reason clean UP levels have been establishedusina the best
-------
5
available analYtical methods for which an annroved methodoloav
exists. The following discussion summarizes the rationale behind
choosing the one area percent by PLM clean up level.
III.
Clean Un Goals for the City of Coalinaa Qnerable Unit
Problems with asbestos analytical techniques make establishing
health-based clean up levels very difficult. As mentioned abovec
the clean up level of one area percent by PLM has been chosen be-
cause it is the best available analytical technique for which
there is an EPA approved protocol. This is further evidenced by
the fact that EPA chose to utilize PLM as an analytical method
under the Asbestos Hazard Emergency Response Act ("AHERA").
EPA has chosen the one area percent clean up level for the City
of Coalinga Operable Unit because one area percent is the
generally accepted detection limit for asbestos in soil using
PLM. one area percent by PLM has also been used. in the past as
an action level in emergency response situations. This level
will provide protection to public health and the environment.
'.. -7
~
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..,. .
'ha 0 :n 0 r (I It c. u :.1
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD .CENTRAL VALLEY REGION
3614 E. Ashlan, SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116
Fresno, CA 93726-6905 State lease Line: 421-5116
TO:
Ruben Moreno
Senior Engineer
FROM:
Michael R. Mangold
Staff Engineer
,DATE: 7 April 1989
SIGNATURE: ~~~.}.. e. O"'-.,hL
SUBJECT: , DESIGN REPORT, ,ASBESTOS WASTE, MANAGEMENT UNIT, SOUTHERN
PACIFIC TRANSPORTATION CO~ANY, COALINGA, FRESNO COUNTY
, ,
.. ,
I have reviewed the subj sct, design report as
C~rporation for Southern Pacific Transportation
SP'I'C proposes to construct a waste management
disposal ot Group B mining waste.
prepared by IT
Company (SP'l'C). '
unit (WMU) for
Backaround
SPTC is working wi th the Environmental Protection Agency (EPA)
~nder a Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) order for a mining waste site (approximately
107 acres in area) located in the City of Coalinga. Cleanup of the
site will include excavation and removal of an estimated 20,000 ft3
of asbestos ore and contaminated soils. This waste has been
classified as Group B mining waste and will be disposed into an
appropriate waste management unit as delineated in Section 2572,
Title 23 of the California Code of Regulations (Subchapter'15).
International ~echnoloqy (IT) Corporation prepared a report
characterizing- local hydroloqyand geology for SPTC to "be used as""
the basis for design of the proposed asbestos WHO. The report.s
objective was to provide information necessary to: '
1.
Determine whether the wastes. should be disposed of as
Group A or B mining wastes.
Provide a basis for design of the disposal facility.
2.
3.
Determine the level of monitoring necessary to satisfy
Subchapter 15 requirements.
Following staff's review
determinations ,were made.
of
the
report,
the
following
1.
The mining waste is classified as Group B waste.
Clay liner and leachate collection system may be exempted
for the proposed unit.
2.
"\
APPENDIX 2
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Southern Pacific Transportation Co.
WMU Design Report
Page 2
,3.
Groundwater monitoring could be minimized in tavor of a
vadose zone monitoring network that incorporates neutron'
probe technoloqy to detect potential discharges trom the
WMU.' " , .
Excavation of the WMtJ should bemoni tored to assure that
the WMU r~mains in compliance with Subchapter 15 siting
requirements.
Based upon the site characterization and. statt's review ot
. applicable or relevant and approprJa'te requirements (ARARs), the
following items were requested..
4.
1.
A preconstruct ion report including construction details
and quality assurance and quality control procedures for
the excavation, filling, and capping of the proposed WHO.
'A water quality monitoring plan for the proposed vadose
zone monitoring network including locations and details
of monitoring points and a plan for implementation of
groundwater monitoring.
2.
'1'0 this end, snc has submitted this report.
Desicm
The WMU will have a desiqn capacity of 25,000 ft3. Top surface
area of the WHt7 will be 272 ft. by 222 ft., with a bottom elevation
of 671.5 ft. or 20 ft. below the existing ground surface. Side
slopes will be constructed' at a 3:1 ratio. A 20-foot wide
. embankment will be constructed around the unit to raise the top
level of the WMU to adjacent topography following removal of the
contaminated soil in that location. The embankment will have a 2
percent slope to promote runoff away from the WHO.
Closure Plan
Final cover o~ thelan~~ill will consist of the following (from
bottom to top): .
*A two-foot foundation layer consisting of waste materials
o~ clean fill compacted to 95 percent of maximum dry
density. This layer will be graded at 4 percent slope.
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Southern Pacific Transportation Co.
WHO Design Report
Page 3
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*A 1/4-inch thick bentonite mat (Claymax, or an equivalent)
placed on top ot the toundation layer. The report. indicates
that this mat is an engineered alternative to the prescriptive
standard of a one-foot layer ot compacted clay having a.
p~rmeability ot lxlO.' em/s or less. "
*A minimum ot one toot of soil ccver plac~d on top of the mat.
This layer will be compacted to obtain 95' of maximum dry
density., . '
*A tinal' layer consisting ot.4 inches of concrete asphalt:
compacted to 92' of :the average densit.y of the Maximum
Theoretical Specific Gravity. The report st.ates that. grading
will be at 4 percent. to tacilitate runoff from the WHO;
however, from recent discussions with the EPA, a smaller slope
may be used.
Indications are, the area above the ~ might be used as a parking
lot or as a long-term storage facility. '
As mentioned previously, the report indicates the bentonite mat is
an engineered alternative to ,the prescript.ive standard of a layer
of compacted clay. Section 2510 (b) of Subchapter 15 states that,
"unless otherwise specified, alternatives to construction or
prescriptive standards contained in this subchapter may be
considered. Alternatives shall only be approved where the
discharger demonstrate that.:
1.
The construCtion or prescriptive st.andard is not. feasible' "',
as provided in subsection (c) of this section.
There is a specific engineering alternative that.
2.
(A)
is consistent with the performance qoal
addressed by the 'particular const.ruction or
prescript.ive st.andard and
affords equivalent protection against water
quality impairment.."
(B)
Subsection (c) states that., "To est.ablish that compliance with
prescriptive standards in this subchapter is not teasible for the
purposes of subsection (b) of this section, the discharger shall
demonstrate that compliance with a prescriptive standard:
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Southern Pacific Transportation Co.
WMU Desiqn Report
Page 4
1.
Is unreasonably and unnecessarily burdensome and will
cost substantially more than alternatives which meet the
criteri~in subsection (b) of this section; or
Is impractical and will not promote attainment of
applicable performance standards.
2.
Feasibilitv Issue
The report indicates'that a compacted clay layer is not practical,
for the following ,reasons:
'2.
'..,
1.
Investigations performed in the area showed that a source
of clay is available at 20 feet below existing grade.
However, costs for obtaining the clay would be'
exorbitcs.nt.
Cost of obtaining the borrow clay from other sources are
also extremely expensive, due to high transportation
costs. '
3.
Quality of borrow clay tram outside sources is
questionable and may not be obtainable within the time
frame o~ ,the project.
Enaineerina Alternative Issue
The consultant believes that the bentonite mat (ClaYmax) is
consistent with the performance goals addressed by the prescriptive
clay liner and provides equivalent protection against water quality
impairment. The following reasoning was provided to support this
pos~i~. ' ,
*Permeability tests performed on Claymax by Geoservices Inc.,
(an independent lab) bave demonstrated ~ permeability of
2 x' 1'0"0. em/s. ','
*Based on equivalent seepage velocity, Claymax of 1/4-inch
thickness' is equal to an infinite thickness of compacted clay
liner with a permeability of 1 x 10" em/s. ' '
*Based on equivalent breakthrough time, the 1/4-inch Claymax
is equal to at least 2 feet of compacted clay with a
permeability of 1 x 10" em/s.' ,
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Southern Pacific'Transportation Co.
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WMU Design Report. .
Page 5
*The Claymax is more flexible than a compacted clay liner an
can handle large deformation without causing cracking.
I'
. .
The report further states that Claymax is manufactured under
'controlled conditions and is readily available to the site.
Furthermore, handling and installation of Claymax is easier and
faster than compacted clay.
Information on comparison studies (performed by Geoservices, Inc.)
between Claymax and a compacted clay liner are, ,included in
Appendix F and G'of the design report.
Vados_zone Konitorina
Vadose zone monitoring will exist beneath the site to provide an
early detection system for possible migrating contaminants
emanating from the landfill. Neutron probes were selected to
detect any changes in moisture content directly beneath the site.
Vadose zone monitoring will consist of pulling the probes through
two access tubes installed beneath the site. The locations and
spacing of the access tubes are illustrated in Drawing No.2 of the
design report. The tubes will be spaced 85 feet apart and will be
placed.2 feet beneath the bottom of the NMO.
Soils samples will be extracted every 5 feet along the access tube
trenches and will be laboratory tested to determine native moisture
contents prior to actual installation of the tubes. The locations
tor the soil samples will coincide with intervals to be used tor
monitoring with the neutron probes. ,Prior to any discharge ot
waste into the WMtT, background data vill be generated by monitoring
with the neutron. probe each week for four weeks. Atter this data
is obtained, the moni torh\q frequency vill be decreased to
quarterly for a period of one year. If no siqnificant changes in
the moisture content are observed aftaT a period of one year, the
monitoring frequency will be again decreased to semiannually.
The design report indicates that results from each monitoring event
will be compared with results from previous vadose zone monitoring
and background data. . The report states that in the event that a
significant change in moisture content is observed, an assessment
of the situation will be initiated and the Regional Water Quality
Control Board (RWQCB) will be notified. The report further states
that in the event. that moisture content increases above 5 percent
Hazardous V\)
Information r
US EPA Reg' .
P h 'I '0
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