United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA,RODR09 83.003
June 1983
Superfund
Record of Decision:
Mountain View/Globe
Site, AZ
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TECHNICAL REPORT DATA
(Please ,ead Instfllctions on the ,evene before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO. -'-
EPA/ROD/R09-83/003
.. TITLE AND SUBTITLE 5. REPORT OATE
SUPERFUND RECORD OF DECISION 06/02/83
Mountain View/Globe Site, AZ 6. PERFORMING ORGANIZATION CODE
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO.
j. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT ~O.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Renort
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Amountain View Mobile Home Estates site is a residential subdivifil
of approximately 130 people that was built in 1974 on graded asbestos
tailings and contaminated soil at the site of the defunct Metate
Asbestos Company mill. The mill processed asbestos ore from 1953 until
it was closed in 1974 by permanent injunction of the Gila-Pinal
Counties Air Quality Control District for failure to meet air quality
standards. Residents of Mountain View Estates are exposed to asbestos
fibers from the subdivision's contaminated soil and potentially from
the fiber piles of an adjacent asbestos mill. The selected remedial
alternative includes permanent relocation of Mountain View residents,
cleaning the site and demolishing and burying on-site all of the homes
and sewage treatment plant, and site closure by capping, fencing, and
periodic inspection and maintenance.
The stimated cost of the remedial action is $4,432,000 which
includes the present worth of capitai and O&M costs for the project
life.
.
17. KEY WORDS AND DOCUMENT ANALYSIS
Ia. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Mountain View/Globe Site, AZ
Contaminated media: air, soil
Key contaminants: Asbestos
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EPA ,.,'" 2220-1 (Rn.4-n)
P"EVIOUS EDITION IS 08S0L.ETE
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Prepared in .:uoperation wllh. I lan,lallllll "f. I'''''''III~',' al ""11"'1\'11'" tI".
17. KEV WORDS AND DOCUMENT ANAL VSIS
(a) DESCRIPTORS. Seleci from the Thesaurus of t-:ngineerir.~ and Sdcnli.k Tcrm~ thl: plUpCI aUllltlrl/cJ "'1111' Ihal.cJcnllly Ihc ma)nr
concept of the research and are sufficiently ~pecil'ic and pre.:i!iC: to be: U!iC:cJ as mllc:\ cnlrie~ lor .:atalu~'nj:.
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ended terms written in descriptor form for those subjects for which no dCS4:riptor l:,.i~ls.
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endeavor, or type of physical object. The applicationls) will be crun-rc"erenced wllh se:nmdary 11~'h"( iW1I1' ~"'I="IIICllls that "".11 I'nlltl'"
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I! PA Form 2220-1 (Rn. 4-771 (Ru.,..1
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Record of Decision
Remedial Alternative Selection
Site:
Mountain View Mobile Home Estates, Globe, Arizona
Analysis Reviewed:
I have reviewed the following documents describing the need for and analysis
of the cost effectiveness of remedial alternatives at the Mountain View Mobile
Home Estates Site:
I
- Public Health Advisory for Mountain View Estates, Globe, Arizona,
Centers for Disease Control, April 4, 1983
- Final Draft Remedial Investigation/Feasibility Study, Mountain
View Mobile Home Estates, Globe, Arizona, May 6, 1983
- Staff summaries and recommendations
- Public Participation Responsiveness Summary
FE~A Determination:
Pursuant to Executive Order 12316, the Federal Emergency Management Agency
(FEMA) has determined that permanent relocation is more cost-effective
and preferable to other alternatives for protecting the public health or
welfare. That determination is attached.
Description of Selected Option:
- Permanent relocation of Mountain View residents
- On-site burial of containerized mobile homes
- Site closure by capping, fencing, and maintenance.
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan, I
have determined that the permanent relocation/site closure alternative
for the Mountain View Mobile Home Estates Site is a cost-effective remedy,
and that it effectively mitigates and minimizes damage to, and provides
adequate protection of, public health, welfare, and the environment. I
have also determined that the action being taken is appropriate when balanced
~gainst the need to use Trust Fund money at other sites.
--
--,
f . ~ -' -
Lee Thomas
Acting Assistant Administrator
Office of Solid Waste &
Emergency Response
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Mountain View Mobile Home Estates Sit~ Remedial Action
Briefing Document
o
Purpose of this briefing is to obtain AA approval for the
remedial action recommended by Region 9 and the St~tE of
Arizona for the Mountain View Mobile Home Estates site.
o
Moun~ain View Mobile Home Estates is a residential subdivision
of approximately 130 people that was built in 1974 on graded
asbestos tailings and contaminated soil at the site of the
defunct Metate Asbestos Company mill. The mill processed
asbestos ore from 1953 until it was closed in 1974 by permanent
injunction of the Gila-Pinal Counties Air Quality Control
District for failure to meet air quality standards.
o
Residents of Mountain View Estates are exposeG to asbestos
fibers from the contaminated soil of the subdivision and
potentially from the fiber piles of the adjacent D.W. Jaquay's
Mining and Equipment
Corporation asbestos mill.
o
In April, 1933, EPA and FBMA agreed to temporarily relocate
Mt. View residents while a remedial investigation/ feasibility
study (RI/FS) of the site was conducted. The 4 week RI/fS
was completed in May 1983, pursuant to a State Superfund
contract, and considered the following three alternatives in
detail:
Alternative A
Site Abandonment by
Permanent Relocation
$4,432,000
Relocation of subdivision residents with
subsequent site capping, closure, and
maintenance.
Alternative B
Site Rehabilitation with
Asbestos Removal
$8,003,000
Temporary relocation of subdivision residents
while the contaminated soil is excavated and
removed, and the site is restored.
Alternative C
Site Rehabilitation with Deep Cap
$6,15l,00~
Temporary relocation of subdivision residents
while a 10-foot deep cap is placed over the
site and the subdivision is restored.
The costs noted above include the present worth cost of both
capital and 0 & M costs for the project life (varied with
alternative). Alternative A was the best alternative from
economic, technical, and environmental standpoints. Alterna-
tive C was the second best alternative, and Alternative B
ranked third.
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o
On May 16, 1983, Region 9 conducted a public meeting in Globe
to present the feasibility study report, answer questions, an8
take public comment. Approximately 125-140 people were in
attendence. The Globe community is divided between the Mountain
View residents and people who are concerned about asbestos
exposure, and a large and very vocal group who main~ain that
Gila County asbestos is not hazardous to human health. The
latter group spoke at the public meeting and maintained that
no one in Gila County had suffered adverse health effects
from exposure to asbestos and that State and Federal action
had ruined the reputation and economic health of the area.
Written comments received on the RI/FS have supported permanent
relocation as the only way to effectively mitigate the human
health threat. .
o
The voluntary temporary relocation progrm is being administered
by the Arizona Division of Emergency Services pursuant to an
agreement with FEMA. Twenty-six Mountain View Estates families
have applied for temporary relocation and physical movement of
the residents began the week of May 16. The estimated costs
for Alternative A, site abandonment by permanent relocation,
include $97,000 for approximately 4 months temporary relocation
while permanent relocation is implemented. The current
EPA-FEMA Interagency Agreement for temporary relocation must
be amended to transfer funds necessary to continue the temporary
relocation past the Record of Decision and until permanent
relocation can be effected.
o
Mountain View Mobile Home Estates was referred to the Department
of Justice on September 30, 1982. On May 13, 1983, DOJ filed
in Arizona District Court against Metate Asbestos, the
subdivision development corporation and their common officers,
and Jaquay's Mining Corporation. We understand that Jack Neal
and Geraldine Neal, officers of Metate Asbestos and Neal,
Capper, Neal Land and Development Corporation, filed a voluntary
petition in bankruptcy under Chapter 7 in February, 1983 and
that the first creditors meeting was held in April.
o
The recommended alternative includes clearing the entire site
and demolishing and burying all of the homes and the sewage
treatment plant. It was determined to be much less expensive
to bury the mobile homes than to attempt to decontaminate them.
Following the home burial, a non-woven filter fabric would be
placed over the entire site and the filter media would be
covered by 2 feet of compacted earth fill. The surface of the
earth would be sloped to drain and seeded with native grasses.
periodic inspection and maintenance of the cap would be
required. Permanent relocation of Mountain View residents
would be effected by direct government purchase of their homes
and property. Residents would then be able to purchase other
homes in the Globe area or elsewhere. Extension of the present
temporary relocation will be required until purchase prices
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were negotiated and title tranfers completed. It is not clear
whether title to the property would revert to the Federal or
State or local governments or other parties.
o
The "Record of Decision" certifies that:
.
- the selected remedial action is a cost-effective, technically
feasible, and environmentally acceptable remedy for the site.
- monies are available in the Fund to finance the remedy.
- because the selected remedy involves relocation of Mountain
View residents, the Federal Emergency Management Agency must
give final approval to the project.
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'.
I
Remedial Implementation Alternative Selection
Mountain View Mobile Home Estates
Globe, Arizona
May 24, 1983
Background
Mountain View Mobile Home Estates is located 75 miles east
of Phoenix in east-central ?rizona in Globe, Sila County. ihe
17-acre mobile home subdivision was developed ir. 1973 at the
site of the Metate Asbestos Corporation chysotile asbestos mill.
The mill processed asbestos ore for approximately 20 years until
it was found to be in violation of EPA Air Quality Standards and
ceased operations by order of the Air Quality Control District.
Before the 1973 temporary injunction of the Air District became
permanent in 1974, Jack Neal, owner of the Metate Asbestos,
obtained a rezoning of the property to residential use. Metate
Asbestos tail~ngs and contaminated soil were used as landfill
to level the site and the area was subdivided into 55 lots, 47
of which were eventually occupied by approximately 130 residents.
Asbestos contamination of tn~ soil
dis~overed in October 1979 by State and
inspecting the Mountain View wastewater
sequent sampling of air and sediment of
the presence of asbestos fiber5;
of the subd~vision was
local heaith officials
disposal system. Sub-
the subdivision confirmed
On November 30, 1979, the Arizona Department of Health
Services (ADHS) sent residents a letter apprising them of the
health hazard and recommending they take immediate measures
to minimize their personal exposure risk. On December 13,
1979, ADHS ordered Metate Asbestos and several other mills in
the Globe area, including the Jaquays Mining and Equipment
Corporation asbestos mill directly adjacent to the Mountain
View subdivision, to submit clean-up plans for their sites.
The plans were to be implemented during the spring of 1980. In
January 1980, the Assistant Surgeon General of the United States
recommended that all the residents of Mountain View Estates
be immediately evacuated. Gcvernor Bruce Babbitt declared
the site to be in a state of emergency on January 16. Two
days later a letter was sent to residents with instructions
for temporary relocation to State owned housing on a voluntary
basis. Temporary housing was provided by the Arizona Division
of Emergency Services from January through March 1980 while
resident's homes were decontaminated. Actual mitigation measures
taken during the relocation included demolition and on-site
burial of the vacant Metate mill building and the installation
of six-inch protective soil covering over portions of the site.
Following'completion of the State's emergency measures, Mr. Neal
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I
resumed the commercial sale of subdivision lots.
In the Fall of 1981. reports that the partial soil cover
at Mountain View Estates was eroding and exposing asbestos fibers
caused ADHS to look for a more permanent remedy for the
site. In July 1982. Mountain View Mobile Home Estates was
designated to be Arizona's highest priority site for purposes
of the amended Interim Priorities List.
Because Mountain View Estates was considered to be a
mining waste site. subsequent actions taken were consistent with
the Agency's mining waste policy. Mountain View Estates was
referred to the Department of Justice on September 30, 1982
and Notice Letters to potentially responsible parties followed.
In responses to the Notice Letters and to subsequent RCRA ~3007/
C£RCLA ~104 requests for information. the parties denied any
responsibility for hazardous conditions at the site and declined
to negotiate.
In the Fall of 1982. the Region requested remedial inves-
tigation/feasibilit~ study (RIfFS) funds for a field investiga-
tion of the site to support the enforcement effort. $190.000
in Superfund monies were allocated in January 1983 for a 6-month
RIfFS. In March of 1983. the RIfFS was accelerated into a
3D-day investigation. The investigation commenced April 4. 1983
and a draft report was presented to Federal and State officials
May 2. The final draft RIfFS r~port was published May 6.
During the RIfFS activity. EPA and FEMA offered to tem-
porarily relocate Mountain View residents on a voluntary
basis pending a decision on the permanent remedy for the site.
$100.000 in Superfund monies were transferred to FEMA to fund
the relocation and a Cooperative Agreeement between FEMA and
the Arizona Division of Emergency Services was negotiated to
effect the voluntary relocation.
Current Status
Residents of Mountain View Mobile Home Estates continue
to be exposed to chysotile asbestos fibers both from the con-.
taminated soil on-site and also potentially from airborne fibers
from the adjacent and sporadically active Jaquay's mill. Direct
contact by children is the greatest concern because their life
expectancy exceeds the prolonged latency periods for asbestos-
related disease.
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The final draft remedial investigation/feasibility study
r e p 0 r t pub 1 ish e d bye H 2 M H ill 0 n May 6, 1 9 8 3 e val u ate dl the
following alternatives for Mountain View Mobile Home Estates:
Alternative A: Sit e abandonment by permanent $4,432,000
relocation
Alternative B : Site rehabilitation with asbestos $8,003,000
removal
Alternative C: Sit e rehabi 1 i tat ion with deep cap 56,151,000
In addition to being the most cost-effective remedial
action, Alternative A is also the superior option in terms of
protection of public health and the environment and technical
feasibility.
On May 16, 1983, Region 9 held a public meeting in Globe to
present the RI/FS report and hear public comment. The comment
period on the report opened May 9 and closed May 23. Eight
persons, three of whom are responsible parties in EPA enforcement
actions, made statements at the meeting. The universal theme
of the comments was that Gila County chrysotile asbestos is
not hazardous, that no one has suffered adverse health effects
from exposure to Gila County asbestos fibers, and that a health
study should be conducted before any remedial action is taken
at Mountain View Estates. Of the 22 written comments received
by the Region. 14 support permanent relocation at Mountain View
Estates and one letter from the San Carlos Apache Tribe requests
a study of Gila County asbestos and Apache miners and millers.
The relocation of the first Mountain View residents under
the temporary program took place May 17. 1983. The funding for
temporary relocation. transferred to FEMA through a Interagency
Agreement (IAA) with EPA. is currently scheduled to terminate
with signature of the Record of Decision (ROD). The IAA should
be amended to continue the temporary relocation program until
permanent relocation is implemented. The study's $4.4 million
cost estimate for permanent relocation includes $97.000 for 4
months temporary housing pending negotiation and property transfer
required for permanent relocation. .
On May 13. 1983. the Department of Justice filed against
Metate Asbestos Corporation, Jaquay's Mining Corporation, and the
developers of Mountain View Mobile Home Estates in United States
District Court for the District of Arizona. The complaint seeks
injunctive and other relief under CERCLA ~106 and ~107 and under
the Clean Air Act ~303.
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Recommended Alternative
I
Section 300.67(j) of the National Contingency Plan (NCP)
States that the appropriate extent of remedy shall be determined
by the lead agency's selection of the remedial alternative which
the agency determines is cost-effective (i. e., the lowest cost
alternative that is technologically feasible and reliable) and
which effectively ~itigates and minimizes damage to and provides
ad e qua t e p r ot e c t ion 0 f pub 1 i c he a 1 t h, we 1 far e, 0 r the en vir 0 n -
mente Based on our eval uati on of the cost-effect; veness of
each of the proposed alternatives, the comments received from
the public, information from earlier technical studies, and
information from the State, we recommend that the Site Abandonment
by Permanent Relocation alternative described ;n the RIfFS
report be implemented.
The proposed remedial action includes a 4 month temporary
relocation, permanent relocation of Mountain View residents by
pur c has e 0 f the i r lot san d h om e s, bur i a 1 0 f the con tam i n ate d
mob i 1 e h om e son - sit e, and sub s e que n t sit e cap p; 11 g, c 1 0 sur e ,
and maintenance.
Tot ale a pit ale 0 s t s are at t a c h e d. Pre s en t val u e 0 f 0 &M
and Capital Replacements Expense calculated at a 10% discount
rate is $99,000.
Proposed Action
We request your approval 01 site abandonment by permanent
relocation as the remedial implementation option for the Mountain
Vie w Mob i 1 e H om e Est ate s Sit e.
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Responsiveness Summary
Mountain View Mobile Home Estates
Remedial Investigation/Feasibility Study Final Draft
1-
Background
Mountain view Mobile Home Estates in Globe, Arizona appeared on
the EPA's expanded Interim priorities List in July 1982 as
Arizona's highest priority site and is included on the pro- .
posed National priorities List of Superfund sites published in
December 1982.
In April 1983, E~A'S zone contractor, CH2M Hill, began a four
week remedial investigation/feasibility study (RI/FS) of the
Mountain View Mobile Home Estates subdivision. The remedial
investigation, which included soil sam?ling to determine the
extent of asbestos contamination of the soil and an assessment
to determine the approximate value of the homes and property,
was conducted to provide information necessary to evaluate
remedial alternatives for the site. The feasibility study
evaluated three options for remedial action:
Alternative A - Site abandonment by permanent relocation;
-Alternative B - Site rehabilitation by removal of contamin-
ated soil; and
Alternative C - Site rehabilitation by deep cap.
The study concluded that permanent relocation was the most cost-
effective, technically feasible, and environmentally acceptable
remedial action.
On April 7, 1983, the Region met with local officials, concerned
citizens, and Mountain View Estates residents in Globe to explain
the RI/FS. The on-site field work by CH2M Hill commenced the
following day and was completed April 15. The final draft RI/FS
report was released to the public on May 9. Copies were dis-
tributed to Federal, State, and local officials, and several
copies were sent to Mountain View Estates for distribution
among the residents. Four repositories were established for
public review of the report: the Globe City Hall: the Globe
Public Library: the Arizona Department of Health Services
Library in Phoenix: and the EPA Region 9 Library in San Francisco.
A Press Release issued by the Region on May 6 announced the
availability of the report, the repository locations, the
public comment period of May 9 through May 23, and the public
meeting on the report scheduled by EPA for May 16. Notice of
the repository locations, the two-week comment period, and the
May 16 public meeting were also included in cover letters
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."
accompanying the RI/FS report and in a letter sent to each of the
residents of Mountain View Estates (copies attached).
Comments
The Region received a total of 30 sets of comments on tte report
and the recommended remedial alternative of permanent relocation.
Eight individuals made oral statements which were recorded
at the public meeting held May 16. The remaining sets of
comments were letters or written statements transmitted to
the Region 9 office. A list of commentors, copies of written
statements, a transcript of the public meeting, and a list
of individuals who filled out cards at the public meeting
requesting that they be added to the EPA mailing list are
attached.
Generally, the comments received on the RI/FS report and the
recommended remedial action fall into two categories:
Persons who support permanent relocatior. of Mountain View
Estates residents and urge SPA to i~plement relocation
as soon as possible; and
Persons who believe that Gila County asbestos is unique,
is not hazardous to health, and has not caused any
adverse health effects in Gila County. These commentors
urge EPA and the State to delay implementation of
remedial action at Mountain View Estates until a health
study of Gila County is conducted. Several persons felt
that the governmental action was precipitated by emotional
rather than scientific decision-making and were concerned
about the negative impact of the government action on the
economy of Gila County. They felt that no remedial activity
should take place at Mountain View Estates.
Response
It is the recommendation of EPA Region 9, the Honorable Bruce
Babbitt, Governor of Arizona, and the Arizona Department of Health
Services, that site abandonment by permanent relocation of
Mountain View residents be selected as the permanent remedy for
Mountain View Mobile Home Estates. This option was selected
because it is the most cost-effective and technically feasible
alternative and it provides the greatest protection to public
health. The estimated relative cost for site abandonment by
permanent relocation and site stabilization is $4,432,000 compared
to $8,003,000 for site rehabilitation by removal of contaminated
soil and $6,151,000 for site rehabilitation by deep cap. Per-
manent relocation is also the most easily accomplished alternative
from a technical perspective. The site rehabilitation options
would both require that the mobile homes be transported and dis-
posed of off-site and once implemented, would involve long-term,
continuous monitoring of airborne asbestos concentrations at
Mountain View Mobile Home Estates from potential off-site sources.
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Site rehabilitation would also require re-installation of
utilites, streets, foundations, and landscaping. Most impor-
tantly, permanent relocation offers the greatest protection
for public health. While all three alternatives would protect
subdivision residents from exposure to asbestos from hOfes
and soil, the permanent relocation option would protect
residents from exposure to airborne asbestos blown on-site
from surround ing contaminated land.
In situations involving public health assessments, EPA relies on
the Department of Health and Human Services, Public Health
Service, Centers for Disease Control (CDC) for professional
guidance. The role of CDC in the Superfund program is established
by the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, Executive Order 12316, and the National
Contingency Plan.
A memorandum titled "Community Asbestos Exposure in Globe, Arizona"
prepared by the CDC Chronic Exposure Division in August 1981 states:
Both human anj animal studies have shown that chrysotile
asbestos, the form present in Globe, is fibrogenic and
carcinogenic. This conclusion has been reviewed and
supported in official publications of the World Health
Organization's International A~ency for Research on
Cancer, 1976...; NIOSH/CDC in its Revised Recommended
Standard for Occupational Exposure to Asbestos, 1976...;
and the Asbestos Advisory Committee, Health and Safety
Commission, United Kingdom, 1979... Although review of the
epidemiologic literature suggests that there are differences
in the degree of fibrogeni~ity and carcinogenicity of the
various asbestos fibers...(the new British standard, for
example, is more stringent for crocidolite and amosite
asbestos fibers than for chrysotile), there is no reason
to minimize the health risks posed by chrysoti1e asbestos.
Recent reports of experimental animal studies...and human
epidemiologic studies...continue to show a positive
correlation between exposure to chrysotile asbestos and
disease, including asbestosis, lung cancer, and mesotheli-
oma.
In the particular situation of this housing subdivision
in Globe, there was heightened concern because of the
ready availabilty of asbestos to children and other
residents, the high respirability of the milled fibers,
and the continuing environmental contamination from
the mill sources. Children are of particular concern,
because they were observed playing directly with tailings
and because their long life expectancy exceeds the pro-
longed latent periods for asbestos-related disease.
Information provided by commentors that Gila Country chrysotile
asbestos has not caused adverse health effects was reviewed by
~
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and CDC Medical Epidemiologist.
The review states:
The conclusions based on studies of small groups of
living workers are...misleading, as studies of this
type are flawed by low statistical power and sele~tion
bias. The proper way to evaluate cancer mortality is
to identify all former and current workers of an
industry, and then ascertain their morbidity or mor-
tality experience through pathology reports or death
certificates. Morbidity and mortality data can then
be compared to national rates adjusted for age and
person-years at risk. A study of currently employed
workers would not identify those workers who had died
of cancer already, or those who had to leave work
because of this disease. For all epidemiologic studies
of occupational groups, the statistical power of the
analysis must be spacified, for there may be a strong
chance of getting negative results even though an
elevation in disease rate has been caused by exposure
to a human carcinogen...
The review also states that cancer mortality data for a single
year cannot be cited as evidence that chrysotile asbestos is
not related to disease:
...This argument is misleading for a number of reasons.
County-wide mortality may dilute specific disease increases
that occurs in small groups within the country. Likewise,
. deaths from all cancer may disguise the increase of
cancer from a single site. The reporting of mortality
data for a single year is also misleading, as a definite
trend toward increase or decrease in mortality may be
occurring, but could not be detected by data for a single
year.
...The evaluation of cancer mortality based on insurance
claims is not a scientifically acceptable technique,
and could lead to gross errors. Many workers are unaware
of the exposures that may cause cancer, and state laws
often require compensation cases to be filed within one
year of leaving a job - a regulation that would minimize
compensation for all asbestos-related disease.
The attempt to establish a causal relationship between an
environmental exposure and a disease is very difficult,
utilizing county mortality data, or data from small groups
of exposed workers. These types of data can only be used
with confidence where extremely large segments of the
population are exposed to an agent that has a strong
influence on mortality from specific causes: or where a
large sample of expsosed workers can be adequately studied.
Neither of these criteria can even be met for the area
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around Globe, Arizona. In this case, epidemiologists
prefer to use data from well-designed occupational and
environmental studies to infer risks for disease.
The review specifically addresses conditions at Mounta.n View
Estates:
From a public health standpoint, one is concerned about
worst case exposure conditions. That is, conditions under
which a person may receive the greatest exposure and thus
be at risk for disease. The comparison of average
atmospheric asbestos concentrations at Mountain View
Estates to those of cities in other areas may therefore
be inappropriate, as unless there is a defininte source
of asbestos with variable input into the environment,
the average conditions of other locations will differ
little from maximum conditions. At Mountain View Estates,
however, certain conditions could cause substantial
elevations above the average.
Asbestos exposure at Mountain View Estates is also unique
in that residents are now exposed to bULied tailings for
much longer period of time than are people who frequent
businesses or other publi~ places on a less regular basis.
Likewise, the fact that children reside in this community
and may be subject ot elevated exposure through recreational
activities and long residence periods also is an additional
cause for concern.
The argument that the exposure levels for Mountain View
Estates are too low to result in disease is also to be
questioned. In the first place, there are no adequate
data for the establisr~ent of a dose-response relation-
ship in the low dose range. The documentation of disease
in family contacts of asbestos workers and the detection
of mesotheliomas in workers with short asbestos-related
work histories both support a cautious approach toward
protection of the public from exposures of this sort.
The information on chrysotile asbestos provided by the Centers
for Disease Control had led EPA to the conclusion that a serious
public health risk exists at Mountain View Mobile Home Estates and
that a study of Gila County asbestos would not provide significant
new information to warrent a delay of the implementation of a per-
manent remedy for the site. ..
Specific Comments and Responses
In addition to the major comments reviewed above, other comments
were received as follows:
o A resident of Mountain View Estates was concerned that the
government reimbursement for their homes and property would
not be sufficent t9 permit them to find acceptable housing
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elsewhere.
The actual determination of reimbursement will be
negotiated between the residents and the Arizona Division of
Emergency Services and the Federal Emergency Mana~ment Agency.
The relocation will be conducted pursuant to the Relocation
Assistance and Real Property Acquisition Policy Act of 1970,
Public Law 91-646. In addition to a fair market reimbursement
to be negotiated between the parties, guidelines for imple-
mentation of the Act provide for a relocation allowance to
assist relocated families to secure housing.
o An attorney contacting the Agency on behalf of a client stated
that burial of the trailers on-site would be wasteful and
offered to purchase the trailers for $100.00 each. The homes
would be decontaminated and "...sold only to persons over
seventy years of age or persons who are presently terminally
ill."
The mobile homes are to buried on-site because it was deter-
mined that decontamination would be labor-intensive, time-
consuming, and more expensive than purchasing new mobile
homes. Further, because the permanent relocation process will
transfer ownership of the homes to the State or Federal
governments, it is doubtful that liability considerat:ons
would permit re-sale.
o Attorneys representing 27 Mountain View Estates families
commented that the report does not address "...the costs of
epidemiological studies, development and maintenance of a
registry of persons exposed to the asbestos to allow for the-
long-term health effects studies, and...diagnostic or other
services to monitor the health of residents and of the
subdivision."
Health monitoring programs would be conducted by the Centers
for Disease Control. CDC is currently considering long-term
monitoring of Mountain View residents.
o Attorneys were also concerned that provision be made for
decontamination of personal items or reimbursement or replac~-
ment of those items which cannot be decontaminated or moved
with the residents.
This concern is currently being addressed by the Federal
Emergency Management Agency.
o Attorneys requested that provision be made for payment of
resident's legal fees associated with pending litigation
against responsible parties and claims made pursuant to
CERCLA.
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It should be noted that the administration and legal expense
to which reference is made in Table 5-1 at page 32 of the
study refer to the expenses incurred by the government.
In addition, review of CERCLA and it's legislativi history
fail to establish that the Act was intended to provide for
payment from the Fund of private parties attorney's fees.
o An attorney representing 17 Mountain View residents suggested
various changes to the wording of the report to clarify
certain points.
While we will not be revising the report, the comments
are attached and have been considered.
Attachments
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List of Comrnentors
Written Statements:
*Letter from the Honorable Bruce Babbitt, Governor Df Arizona,
dated May 11, 1983, received by Region 9 May 13, 1983.
*Letter from Irene Burrington, dated May 11, 1983, received
by Region 9 May 16, 1983.
*Letter from Thomas W. Henderson, Baskin and Sears, P.C.,
dated May 13, 1983, received by Region 9 May 16, 1983.
Statement of John R. Ycedro, undated, hand-delivered to
Region 9 at public meeting in Globe on May 16, 1983.
*Letter from Mr. and Mrs. James Iannello, dated May 10, 1983,
received by Region 9 May 17, 1983.
Letter from Anthony D. Terry representing E. F. Doyle,
dated May 17, 1983, received by Region 9 May 19, 1983.
*Letter from Carroll E. and Carolyn G. Hounshell, undated
received by Region 9 May 19, 1983.
*Letter from Dr. James Sarn, Director, Arizona Department of
Health Services, dated May 18, 1983, received by Region 9
May 20, 1983.
*Letter from John and Elaine Insalaco, dated May 18, 1983,
received by Region 9 May 20, 1983.
*Letter from Verne and Irene Burrington, dated May 18, 1983,
received by Region 9 May 20, 1983.
*Letter from Mr. and Mrs. Robert L. Dobbs, dated May 18, 1983,
received by Region 9 May 20, 1983.
**Letter from Hutch K. Noline, peridot District Councilman,
San Carlos Apache Tribe, dated May 20, 1983, received
by Region 9 May 23, 1983.
*Letter from Kevin T. Tehan, Sparks and Siler, P.C., dated
May 20, 1983, received by Region 9 May 23, 1983.
*Letter from Orval L. Williams, dated May 17,1983, received'
by Region 9 May 23, 1983.
Letter from H. Wesley Peirce, dated May 20, 1983, received
by Region 9 May 23, 1983.
*Letter from Abe M. Rodriguez, dated May 20, 1983, received
by Region 9 May 23, 1983.
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Letter from Bonnie C. Gordon"," Harrison and Lerch, P.C.,
dated May 20, 1983, received by Region 9 May 23, 1983.
"Letter from Catherine Scott, dated May 20, 1983, received
by Region 9 May 23, 1983.
f
*Letter from Dorothy 0. Gooch, dated May 19, 1983, received
by Region 9 May 23, 1983.
**Letter from Alvin W. Gerhardt, dated May 20, 1983, received
by Region 9 May 24, 1983.
**Letter from Frances F. Gerhardt, dated May 20, 1983, received
by Region 9 May 24, 1983.
**Letter from Marion N. Wood, dated May 18, 1983, received by
Region 9 May 25, 1983.
Oral Statements made at the Public Meeting held in Globe May 16, 1983
**James J. Querns
**Alvin Gerhardt
**Mike Wood
Jacqueline F. Querns
**Earl Jackson
Jack Neal
**Geraldine Neal
Eubley Clark
*Supports permanent relocation of Mountain View Mobile Home
Estates residents.
**Generally believes that Gila Country chrysotile asbestos is
not hazardous, does not support a remedial action at Mountain
View Mobile Home Estates, and/or requests study of Gila
County asbestos to determine if it does cause adverse health
effects.
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