United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-89/044
September 1989
fcEPA
Superfund
Record of Decision
South Bay Asbestos Area, CA
-------
50272-101
REPORT DOCUMENTATION 1'. REPORTNO. . 12.
PAGE EPA/ROD/R09-89/044
:L A8cip1ent8 Acc888ion No.
4. T1IIe end Subft8
SUPERFUND RECORD OF DECISION
South Bay Asbestos Area, CA
Second Remedial Action - Final
. 1. Author(8'
5. Report Data
09/29/89
II.
II. PI8rformJng Orgenlza1lon R8pL No.
8. Pwfonnlng OrgalnIDlion N8m8 end ~
10. Proj8ctlTlUklWork Unt No.
11. ConIr8ct(C, 01' Grant{G) No.
(C)
(G'
12. ~ng Org8lllz8don N8m8 end Adchu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
1:L Type 01 Report . PerIod Covered
Agency
800/000
14.
15. Supplementary No-
18. Abetr8ct (Umlt: 200 _td8)
The South Bay Asbestos Area site is at the northern end of the Santa Clara Valley and
at the southern end of the San Francisco Bay, in San Jose, California. The SSO-acre
site includes the community of Alviso in the city of San Jose and neighbors a national
wildlife refuge, marshland, and wetlands which support several endangered and threatened
species. The land surrounding Alviso has been artificially raised with soil and debris
fill, some containing asbestos to offset the effects of subsidence. From 1953 to 1982
the site operated as an asbestos-cement pipe manufacturing plant with
asbestos-contaminated waste being disposed of onsite in three landfills. In 1983 the
State collected soil samples which revealed that asbestos was randomly distributed
throughout Alviso, including the Alviso Rim levee. The State also determined that the
Guadulupe River levee contained asbestos-contaminated waste debris and soil.
Contaminated soil from the levee was removed and several emergency removal actions
followed to reduce exposure to asbestos. To address the asbestos contamination at the
site, EPA divided remedial activities into two Records of Decision (ROD). The first ROD
addressed contamination at the rim levee. This second and final ROD addresses the
asbestos contamination found at the remainder of the site. The primary contaminant of
concern affecting the soil, debris, and air is asbestos. (Continued on next page)
11. DocuIwnI An8/y8Ia L DMcrIptora
Record of Decision - South Bay Asbestos
Second Remedial Action - Final
Contaminated Media: soil, debris, air
Key Contaminant: asbestos
Area, CA
b. Id8nIlfi8nlOp-..[ud8d T-
Co COSAT1 ~ .
111. AvIIiWIIIty........
11. S8cuItr CIMa (11118 A8pon)
None
20. S8cuItr CIMa (11118 ,.,
. /Ilnne
21. No. 01 P811H
33
22. PrIce
(S. ANSI-Z38.11'
"~-on.-
(4017)
(Formerly NTlS-35)
D8p8rtment 01 COllllll8l'ce
-------
EPA/ROD/R09-89/044
South Bay Asbestos, CA
16.
Abstract. (Continued)
The selected remedial action for this site includes paving approximately 128,500 square
lards of an asbestos-contaminated truck yard and industrial yard; controlling dust
emissions through monthly wet sweeping of streets; offsite disposal of
asbestos-contaminated debris; air monitoring; and implementation of deed restrictions and
other institutional controls. The estimated present worth cost for this remedial action
is $7,561,000 which includes annual O&M costs of $134,900 for 30 years.
-------
RECORD OF DECISION
SOUTH BAY ASBESTOS AREA
SUPERFUND SITE
ALVISO DISTRICT
SAN JOSE. CALIFORNIA
SEPTEMBER 29, 1989
U.S. Environmental Protection Agency
Region 9
-------
I.
II.
III.
IV. .
V.
VI.
VII.
VIII.
IX.
X.
XI.
TABLE OF CONTENTS
site Name, Location, and Description
Site History and Enforcement Activities
Community Participation
Scope and Role of Response Action
Site Characteristics
Summary of Site Risks
Applicable Or Relevant And Appropriate
Description of Alternatives
Summary of the Comparative Analysis of
The Selected Remedy
Statutory Determination
Requirement.s
Alternatives
PAGE
3
6
8
9
9
9
14
17
20
24
25
Appendix I: Asbestos Analytical Techniques 27
Problems with Using Asbestos Data in Quantifying Risk
Cleanup Goals for the South Bay Asbestos Area Site
FigUre 1
Figure 2
Table 1
A.
FIGURES
TABLES
ATTACHMENTS
Administrative Record Index
4
5
12
B.
Responsiveness Summary & Public Meeting Transcript
-------
RECORD OF DECISION
DECIARATION STATEMENT
site Name
South Bay Asbestos Area
site Location
Community of Alviso
San Jose, California
statement of Basis and Purcose
This decision document presents the selected remedial action
for asbestos contamination within the South Bay Asbestos Area
site, including the community of Alviso, located in San Jose,
California. This documen~ was developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. ii 9601 et seq.,
and with the National contingency Plan (40 C.F.R. Part 300).
This decision is based on the administrative record for this
site. The attached administrative record index (Attachment A)
identifies the documents upon which the selection of the remedial
action is based.
Assessment of The Site
Actual or threatened releases of asbestos from this site, if
not addressed by implementing the response action selected in .
this ROD, may present an imminent and substantial endangerment to
public health, welfare or the environment.
DescriDtion of Selected Remedv
The remedy described for the South Bay Asbestos Area site
addresses the source of asbestos contamination located in the
South Bay Asbestos site area. This remedy addresses those por-
tions of the site not included in the Ring Levee Operable Unit.
The Ring Levee Operable Unit was addressed in a separate Record
of Decision (# R09-88/026), dated September 29, 1988. The action
described herein is designed to control the sources of contamina-
tion by addressing the principal threats at the site through a
combination of remedial actions that will prevent emissions from
areas most likely to have heavy traffic and resulting soil dis-
turbance. The major components of the selected source control
remedy include:
1
-------
Paving contaminated truck and industrial yards with
asphalt or other suitable resurfacing material;
Control of street dust emissions through monthly wet
sweeping;
Removal of asbestos waste debris (cement pipes, etc.);
Cover requirements, inspections and deed restrictions
on landfills; and
Routine maintenance and monitoring.
The selected remedy will control the release of asbestos and
will ensure the long-term protection of human health and the en-
vironment. The present worth cost of the selected remedy is
$ 7,561,000, based upon a 8 percent interest rate with a 30-year
design life. .
Declaration
I have. determined that the selected remedy for the South Bay
Asbestos Area meets the remedy selection standards in CERCLA Sec-
tion 121, 42 U.S.C. Section 9621, and the National Contingency
Plan, by being protective of human health and the environment. I
have .also determined that the selected remedy attains the Federal
and State requirements t~at are legally applicable to the hazard-
ous substance or relevant and appropriate under the circumstances
of the release or threatened release, and that the remedy is cost
effective. The selected remedy utilizes permanent solutions to
the maximum extent practicable for this site. Alternative treat-
ment technology of the asbestos contamination within the com-
munity of Alviso was determined to be impracticable based upon
effectiveness, technical feasibility, implementability, and cost
factors.
Because this remedy will result in hazardous substances
remaining on site, a review, pursuant to CERCLA Section 121, 42
U.S.C. Section 9621, will be conducted at least once every five
years after initiation of the remedial action to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
JL~~
Daniel W. McGovern ~
Regional Administrator, EPA Region IX
~ 2.~ 8 ~
Date
2
-------
RECORD OF DECISION
SUMMARY
I.
site Name. Location. and
DescriDtion
The South Bay Asbestos site is located at the northern end
of the Santa Clara Valley and at the southernmost extent of San
Francisco Bay (Figure 1). The study area, which includes the
community of Alviso, consists of a variety of residential, com-
mercial, light industrial, and agricultural land uses, comprising
an area of approximately 550 acres (Figure 2). Alviso is the
northernmost community in the City of San Jose, with about 1,900
residents. The oldest section of Alviso, located west of Gold
Street and north of the Guadalupe River, is a designated National
Register Historic District. The community is located in a quiet
section of the Silicon Valley between Highway 237 to the south,
rapidly growing Santa Clara to the west and south, and expanding
office development to the east and northeast.
The site is highly susceptible to flooding because of its
proximity to the Bay and to the Guadalupe River and coyote Creek.
Flood-producing storms occur within the area every few years, as
evidenced by historical records and newspaper accounts. Two
major streams that enter the Bay in the vicinity of the site are
the Guadalupe River west and south of Alviso and Coyote Creek to
the north and east. These rivers do not provide natural local
drainage since they are leveed to prevent overbank flooding. The
Guadalupe River was channelized in 1963 by the Santa Clara Valley
Water District (SCVWD) to provide for greater flood flow
capacity. The streams are under tidal influence and, therefore,
discharge to the Bay is impeded during high tides. Numerous salt
evaporation ponds are present between Alviso and the Bay, further
impeding natural drainage into the Bay.
The development of agriculture in the region was facilitated
by widespread ground water withdrawal from irrigation wells. Be-
tween 1934 and 1967, aquifer compaction due to over pumping
caused the ground surface of the Santa Clara Valley to subside
four to six feet, to an elevation below sea level, significantly
increasing. the potential for flooding. The land surrounding Al-
viso has been artificially raised with soil and debris fill, some
containing asbestos, to offset the effects of subsidence.
The community of Alviso is adjacent to Bay wetlands. Near
Alviso, a fragment of remaining marshland survives as the New
Chicago Marsh, a National Wildlife Refuge about 300 acres in
size. The Refuge has an active public education program through
3
-------
!
-N-
~
~
~
au
(,)
o
u
-
"'-
-
(,)
~
Q.
San Jo..
-
o 5 10
~
MILES
I
I Project No. South Bay Asbestos. Site
! 288-FS1
i Camp Oresser & McKee Inc.
REGIONAL
LOCATION MAP
Figure
1
4
-------
Salt Pond
<
~'
'.~
~~
~~
~"
.,~
-(
I
I
I I
I I
~I
.
: ALVISO
.
.
~
Wetlands
Salt Pond
.
.
.
.
.
.
.
.
.
.
, -- -.- --- ---
-
~"
Sail Pond i '-'"
, "
Marshland Lanafm ~ "
./" \
.."-- ,
,
~----~----i \
, I
I
I I
I
I
Salt Pond
LEGEND
........
Historic District Boundary
- .. ---
Landfill Boundary
Existing Ring Levee
o
r
100
.
1000
-
2000
1
!
! ----
FEET
. ProJect No.
.
i 288-F51
.
.
.
.
South Bay Asbestos Site
Camp Dresser & McKee Inc.
SITE LOCATION MAP
1 Figure I
2 I
I
I
-------
its Environmental Education Center, located about a mile north-
east of the community and administered by the U.S. Fish and
Wildlife service.
The wetlands adjacent to Alviso are a significant wildlife
habitat because they provide an interface between fresh and salt
water environments. The wetlands support several endangered or
threatened species, including the Salt Marsh Harvest Mouse
(Reithrodontomvs raviventris), California Clapper Rail (Rallus
lonairostris obsoletus), Golden Eagle (Aauila chrvsaetos), and
Peregri~e Falcon (Falco Derearinus). The Burrowing OWl is also a
protected species of special concern. Small mammals and a great
number of birds and waterfowl species use the wetlands and sur-
rounding "upland" habitats (i.e., land elevated above the water
level of the marsh).
II.
site Historv'and Enforcement Activities
Asbestos-related manufacturing began in the Alviso area in
the early 1950s. The Keasby & Mattison Company operated an
asbestos-cement pipe manufacturing plant about 4 miles south of
the site at 2885 Lafayette Street, Santa Clara, from August 1953
through June 1962. CertainTeed Corporation purchased Keasby &
Mattison company on June 1, 1962, and manufactured asbestos-
cement pressure and sewer pipe and fittings until June 9, 1982.
According to company employees, two or three truckloads of scrap
pipe, machining waste, material from settling basins, and bag
house waste were transported to local landfills daily. Several
landfills were located within the site boundaries, including the
Santos Landfill, Marshland Development corporation Landfill (also
known as the Hoxie Landfill, the Edgewater Landfill, the Leslie
Salt Landfill, or the "fill dump"), and the Sainte Claire Cor-
poration Landfill. Evidence indicates that all three landfills
received asbestos-containing wastes. It has been reported that
numerous Alviso residents used the waste asbestos-cement pipe to
drain excess water from their properties before curbs and gutters
were installed. Several areas within the Alviso site have been
filled with asbestos-containing soils to improve flood protec-
tion. Some of this fill material contained asbestos waste.
In early 1983, Alviso was flooded by coyote Creek as a
result of heavy rains. The City of San Jose constructed a levee
around the town in order to pump out the flood water. The levee
material was taken from the Raisch Quarry in southern San Jose,
and was later found to contain asbestos. .
In August of 1983, the Santa Clara Valley Water District
(SCVWD) initiated construction of an outfall structure at the
Guadalupe River levee. Excavation occurred on property owned by
6
-------
the City of San Jose and SCVWD. This activity was observed by a
California Occupational Safety and Health Administration (CAL-
OSHA) inspector. The inspector collected samples of the ex-
cavated material because he suspected the material to be asbestos
waste debris. The samples were analyzed by the Department of
Health Services (DHS) Air and Industrial Hygiene Laboratory and
they confirmed the inspector's suspicions. The samples contained
concentrations of asbestos ranging from 20 to 40 percent. CAL-
OSHA referred the situation to DHS. After confirming the
presence of asbestos in the Guadalupe River levee, DHS ordered
SCVWD to remove all the aSbestos-contaminated soil. Removal of
the contaminated soil took place between August and December
1983. .
In september 1983, DRS collected soil samples from 20 random
locations within the community of Alviso. The sample results in-
dicated that asbestos was randomly distributed throughout the
community of Alviso, including the Alviso Ring Levee. Based on
the soil results, DRS initiated California Hazardous Waste Site
Ranking procedures to include the community on the State Super-
fund list. The Community was listed loth on the State Superfund
list in December of 1983.
In June of 1984, EPA proposed the site for inclusion on the
National Priority List. The site was approved for the NPL in Oc-
tober 1984, with a score of 44.68.
In 1985 DHS initiated an Operable Unit Feasibility Study
(OUFS) for the Ring Levee (see Figure 2). DHS' OUFS was com-
pleted in April 1986 and recommended a clean soil cover for the
levee. However, later that year, DHS determined that remedial
funds were not available and referred the Ring Levee and the
remainder of the site to EPA for further investigation and pos-
sible remediation. .
EPA initiated a Remedial Investigation/Feasibility Study for
the overall South Bay Asbestos site in 1986. The RI/FS was com-
pleted in February 1989. EPA also conducted several emergency
clean up actions to immediately reduce asbestos exposure, includ-
ing paving a lot adjacent to the George Mayne School, paving an
unpaved section of Spreckles Avenue, removing an asbestos debris
pile and chip sealing the road and parking lot at the Environmen-
tal Education Center, and spraying the Ring Levee with a dust
suppressing polymer in 1986 and again in 1987. EPA accelerated
action on the Feasibility Study for the Ring Levee, separating it
from the overall investigation and releasing an Operable Unit
Feasibility Study (OUFS) April 1988.
Also in April 1988, EPA and the City of San Jose signed a
Consent Agreement which requires the City to maintain and peri-
odically reapply sealant on the ring levee, and submit a plan to
7
-------
address the contamination at the Environmental Education Center.
In July 1988, the Ring Levee was sprayed again by the City of San
Jose.
In September 1988, EPA signed a Record of Decision (ROD)
selecting a vegetated soil cover for the Ring Levee. EPA has
been negotiating with the City of San Jose and Raisch corporation
and subsequently entered into negotiations for carrying out the
remedial action for the Ring Levee Operable Unit. The City and
Raisch have proposed to remove the levee rather than cover it
with soil as was specified in the 1988 ROD. Upon conclusion of
negotiations, opportunity will be provided for public comment on
the revised plans for remediation of the levee contamination, and
a Consent Decree will be lodged in Federal Court.
EPA has identified several potentially responsible parties
(PRPs) for the South Bay Asbestos site. These PRPs include the
City of San Jose, Raisch Corporation, Certainteed Corporation,
Leslie Salt, Santos and Sainte Claire landfills and owners and
operators of various industrial yards in Alviso. These PRPs
either have provided, disposed of, transported, or arranged for
transport of asbestos material, or are owners or operators of
property where asbestos has been or is threatened to be released.
General notice letters have been provided to these parties.
III. Communitv ParticiDation
All requirements for public participation as specified in
Section 113{k) (2) (B) (i-v) and Section 117 of CERCLA have been
satisfied. The Remedial Investigation and Feasibility Study and
Proposed Plan Fact Sheet for the South Bay Asbestos Site were
made available to the public in the administrative record file
and information repositories at the EPA Docket Room in Region 9
(San Francisco), the San Jose Public Library (Alviso Branch) in
Alviso, and the Family Health Foundation in Alviso. Notices of
the availability of these documents were published in the San
Jose Mercury News and local Hispanic news publications on
February 8, 1989. The public comment periods on the Proposed
Plan was held from February 8 through April 14, 1989.
In addition, a public meeting on the Proposed Plan and
Feasibility Study (FS) was held February 15, 1989, at the Star of
the Sea Church in Alviso. At this meeting, EPA answered ques-
tions about the problems being addressed at the site and remedial
alternatives under consideration. Responses to public comments
made during the meeting, as well as to comments on the Proposed
Plan and FS are provided in the Responsiveness Summary, Attach-
ment B of this ROD.
8
-------
IV.
Scoce and Role of Res~onse Action
In evaluating the nature of the asbestos contamination
problems in Alviso, EPA divided the remediation into two parts,
addressing the ring levee as a separate operable unit apart from
the rest of the site. As previously mentioned, EPA already
signed a Record of Decision for the Ring Levee Operable Unit, and
is negotiating with potentially responsible parties for the
design and construction of a final remedy for the ring levee.
This ROD addresses the asbestos contamination found in the
remainder of the site, (i.e.: those areas not addressed in the
Ring Levee Operable unit.) The remedial objective of this ROD
is to control releases of asbestos to the atmosphere from con-
taminated soils and landfills on the site. This overall site ROD
will be the final source control response action for the site.
V.
Site Characteristics
Asbestos is the only identified hazardous substance at the
South Bay Asbestos site. soil, air, surface water, sediments,
and groundwater were sampled for asbestos as part of the site.
remedial investigation. Asbestos was determined to be present in
soil and air at levels that could pose a threat to public health
and the environment. Asbestos was detected randomly distributed
in soils throughout Alviso. Soil concentrations ranged from less
than 1 percent to 40 percent asbestos (as measured by optical
microscopy). Asbestos measured in air samples collected within
the town during a 3 month study were nearly an order of magnitude
higher than that measured in upwind samples. The measured con-
centrations of airborne asbestos were compared to wind speed and
direction, but no correlation could be made. The Remedial Inves-
tigation concluded that wind erosion alone was not a significant
mechanism for releasing asbestos from the soil. The highest
single asbestos concentration recorded during the air study was
measured at the state Street air station adjacent to industrial
yards. Atmospheric levels of asbestos were determined to have
resulted primarily from vehicular traffic on unpaved roads, truck
and industrial yards, and other activities within the town that
disturb surface soils, releasing the fibers to the air.
VI.
Summarv of site Risks
A.
Contaminant Information
Asbestos is a generic term referring to two groups of
naturally-occurring hydrated silicate materials having a fibrous
crystalline structure. Chrysotile fibers belong to the serpen-
tine group; actinolite, amosite, anthophyllite, cummingtonite,
9
-------
crocidolite, and tremolite belong to the amphibole group. Asbes-
tos fibers have been widely used because of their high tensile
strength and flexibility and their noncombustible, nonconducting,
and chemical-resistant properties. The fibers have been used in
insulation, brake linings. floor tile, plastics, cement pipe,
paper products, textiles, and building products.
Asbestos is a known human carcinogen and has been the sub-
ject of numerous epidemiological studies. There is no threshold
level of exposure below which there is no risk. The primary dis-
eases that have been associated with asbestos exposure are asbes-
tosis, lung cancer, and mesothelioma; others include cancers of
the larynx, pharYnx, gastrointestinal tract, kidney, and ovary,
as well as respiratory diseases such as pneumonia.
Lung cancer is currently responsible for the largest number
of deaths from exposure to asbestos. It has been associated with
exposure to all the principal commercial asbestos fiber "types.
Excessive lung cancer rates have been documented in groups of
workers involved with the mining and milling of asbestos and the
manufacture and use of asbestos products. Studies in which the
extent of exposure can be approximated provide evidence that lung
cancer increases linearly with both level and duration of ex-
posure.
Human studies have also shown that exposure to asbestos can
cause mesothelioma, a cancer that occurs as thick diffuse masses
in the serous membranes (mesothelia) that line body cavities.
Mesothelioma occurs in the pleura (the membrane that surrounds
the lungs and lines the lung cavity) and the peritoneum (which
surrounds the abdominal cavity). . Epidemiological studies sug-
gest that the incidence of mesothelioma is related to dose and
time from first exposure.
ASbestosis, which involves fibrosis of lung and pleural
tissues, is another serious chronic disease associated with high
levels of exposure to asbestos. A full discussion of the health
effects of asbestos is found in the EPA document Airborne Asbes-
tos Health Assessment UDdate. EPA 600/8-84-003F. June 1986.
B.
Exposure Assessment
The following exposure pathways were evaluated to determine
risks to human health and the environment:
Lifetime exposure of residents by inhalation of ambient
air;
Lifetime exposure of residents by inhalation of air-
borne asbestos generated by trucks in unpaved truck and
industrial yards;
10
-------
1-- --.
"-
Exposure of children by direct contact with and subse-
quent incidental ingestion of aSbestos-contaminated
soil in non-residential areas (i.e., vacant lots); and
Lifetime exposure of residents by incidental ingestion
of asbestos-contaminated soil during outdoor
activities.
These pathways were selected for their likelihood and fre-
quency of occurrence, and for their potential to generate asbes-
tos levels that may be of concern to human health.
The potentially exposed population includes the ap-
proximately 1,870 individuals who reside in Alviso and workers
who may be employed in the town. The Alviso population is highly
mobile; among those residing in Alviso in 1980, only 38 percent
were living in Alviso in 1975. Approximately 10 percent of the
Alviso population was under 5 years of age and 4.5 percent was
over 65 years of age. Thirty-two percent of the population in
1980 was between 5 and 20 years of age.
Risks from the pathways listed above were characterized by
first comparing information on the presence and concentrations of
asbestos in the sampled environmental media to Applicable or
Relevant and Appropriate Requirements (ARARs) identified for the
South Bay site. Because asbestos ARARs were not available for
all of the sampled environmental media, a quantitative risk
characterization was also conducted. In this evaluation, es-
timates of potential asbestos exposures through each pathway were
combined with asbestos-specific toxicity values to predict poten-
tial risks associated with the site. For each pathway, an ex-
posure scenario was developed based on assumptions about the en-
vironmental behavior and transport of asbestos, and the extent,
frequency and duration of exposures. These factors were used to
predict potential risks from exposure to asbestos in both average
and maximum plausible exposure cases.
Excess lifetime cancer risks are determined by mUltiplying
the intake level with the cancer potency factor. These risks are
probabilities6that are generally expressed in scientific notation
(e.~. 1 x 10- or 1E-6). An excess lifetime cancer risk of 1 X
10- indicates that, as a plausible upper bound," an individual
has a one in one million chance of developing cancer as a result
of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site~
As shown in Table 1, tge averaie case risks for the EPA on-
site sampling stations (fO- to 10- ) w5re slightly higher than
tho~e at either the upwind (10-6 to 10- ) or downwind (10-6 to
10- ) sampling locations. Because of many uncertainties, these
11
-------
0"
TABLE
1
SUK~Y OF EXCESS INDIVIDUAL LIFETIKI CANCER RISKS FOR
EXPOSURE TO ASBESTOS AT THE SOUTH BAY SITE
: posure Pathway.
Average Case
MaxillWII Case
l halation. Ambient Air
Station 1 (off. site/upwind)
Stations 2-4 (on.site)
Seation 5 (off..ite/downwind)
1 x 10.' . 3 x 10-~
8 x 10-' . 2 x 10-'
1 x 10-' . 5 x 10-~
7 x 10.' . 2 x 10.'
6 x 10.~ . 2 X 10.3
9 x 10.' . 3 x 10.'
r~ha1at10n . Activity Cenerated Airborne
uck Traffic on Unpaved Surfaces
Residents Inhaling:
Dust froll Truckyards
Dust from Unpaved Roadways
Sereet Dust from Paved Roadways
Asbestos
NC
NC
NC
>3 x 10.3
>3 x 10.3
>3 x 10.3
'-gestion of Soil
Children Playing on
Non.Residential Areas
(i.e.. vacant loes)
NC
3 X 10.'
Lifetime Exposure from:
Alviso Yards
Trailer Park Yards
NC
NC
5 x 10.~
6 x 10-'
- Not calculated because geometric .ean 80il level vas below t~e detection limit.
The potential size of the populations exposed are estimated to be: <560-1,870 for
inhalation of asbestos in allbienc air and ingestion exposure to asbestos in loil;
<150-600 for children/teenager exposure pathways; <100-1,000 for adult gardening
8cenarios; <56001,870 for inhabtien of vehicle- generated dusts by residents. The
potential .ize of the worker population is not known.
.12
-------
risk results should be interpreted as order of magnitude es-
timates. (See Appendix I for a full discussion of uncertainties
involved with asbestos measurement and risk quantification.)
For comparison, a different study evaluating lifetime in-
halation risks associated with exposure to airborne asbestos at
other locations in California was examined (Ambient Asbestos Con-
centrations in California: Science Applications Inc. (SAI),
1983). The excess lifetime cancer risks in ihese ot~er Califor-
nia locations were predicted to be in the 10- to 10- range.
There are uncertainties associated with these risk estimates as
well, and they too should be interpreted with caution. For ex-
ample, the conversion factor between analytical techniques adds
an element of uncertainty to the risk calculation.
Experiments conducted by DHS (1986) were used to evaluate
risks associated with inhalation of vehicle-generated dusts.
Only a few experimental sample data values were available, thus,
there are uncertainties associated with these pathways of ex-
posure. Based on the DHS data, the excess lifetime cancer risks
for maxim~ case scenarios of exposure were all estimated to
exceed 10-. This risk level is the highest value presented in
EPA's Health Risk Table (Table 1).
Ingestion risks were predicted for children playing in soil
and residents contacting soil in yards. {he inges5ion risk for
the maximum ca~e scenario. was between 10- and 10- for children
and in the 10- range for adult residents.
The inhalation of airborne asbestos from physical distur-
bance of soils was found to be the exposure pathway presenting
the most significant risk to human health. Therefore, remedial
alternatives were developed to focus on contaminated areas with
the highest potential for disturbance. For lack of a health-
based standard for asbestos in soils, EPA has established a
remediation goal of 1 area percent as determined by Polarized
Light Microscopy (PLM). Remediation will be required for tar-
geted areas with high potential for soil disturbance, which are
found to contain greater than 1 area percent asbestos by PLM.
This cleanup goal is consistent with remedial action taken at
similar Superfund sites. A detailed explanation of the rationale
for this cleanup goal is provided in Appendix I.
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this ROD may present an imminent and substantial en-
dangerment to the public health, welfare or environment. Based
on the fact that asbestos is a known human carcinogen with no
known threshold, asbestos exists randomly in soils throughout Al-
viso and physical activity can release asbestos into the air, and
13
-------
that on-site risk has been demonstrated to be greater than im-
mediately off-site, EPA has determined that remediation is ap-
propriate.
VII.
ADDlicable or Relevant and ADDrocriate Requirements lARARS)
Under Section 121(d) of the Comprehensive Environmental
Response, compensation and Liability Act (CERCLA), 42 U.S.C. i
121 (d), remedial actions must attain a degree of clean-up which
assures protection of human health and the environment. Addi-
tionally, remedial actions that leave any hazardous substance,
pollutant, or contaminant on-site must meet a level or standard
of control that at least attains federal and more stringent state
standards, requirements, limitations, or criteria that are
"applicable or relevant and appropriate" under the circumstances
of the release. These requirements, known as "ARARs", may be
waived in certain instances. Additionally, only substantive (in
contrast to administrative) federal and state requirements need
to be followed.
"Applicable" requirements are those c::lean-up standards, en-
vironmental 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
appropriate" requirements are clean-up standards, environmental
protection requirements, criteria, or limitations promulgated un-
der federal or state law that, while not directly "applicable" to
a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a CERCLA site, address
problems or situations sufficiently similar to those encountered
at the CERCLA site such that their use is well-suited to the par-
ticular site. For example, requirements may be relevant and ap-
propriate if they would be "applicable" but for jurisdictional
restrictions associated with the requirement.
The determination of which requirements are "relevant and
appropriate" is somewhat flexible. EPA and the State may con-
sider the type of remedial actions contemplated, the hazardous
substances present, the waste characteristics, the physical
characteristics of the .site, and other appropriate factors in
identifying ARARs. It is possible for only part of a requirement
to be considered relevant and appropriate.
Tyoes of ARARS
There are three types of ARARs. The first type includes
contaminant-specific requirements. These ARARs set limits on
concentrations of specific hazardous substances, pollutants, and
contaminants in the environment. Examples of this type of ARAR
14
-------
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 restrictions 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 considerationo Examples of action-specific ARARs
are Resource Conservation and Recovery Act (RCRA) regulations for
waste treatment, storage and disposal.
ARARs must be identified on a site-specific basis from in-
formation about specific contaminants at the site, specific fea-
tures of the site location, and actions that are being considered
as remedies. EPA has continued to refine the identification of
applicable or relevant and appropriate requirements (ARARs) for
the proposed remedial alternatives. The list of ARARs below is
more expansive than described in the Feasibility study Report.
However, the addition of ARARs to this list does not sig-
nificantly alter the scope, performance or cost of the remedy.
Accordingly, this is a minor change from the earlier remedy
selection documentation. .
The ARARs identified for this Record of Decision are the
substantive provisions of the following:
Contaminant-SDecific ARARs
1. Clean Air Act, National Emission standards for Hazardous Air
Pollutants (NESHAPs) regulations (40 C.F.R. -ii 61.153 and
61.147); California Bay Area Air Quality Management District
(BAAQMD) regulations (Reg. 11, rule 2, 305.3.1).
NESHAPS, and similar BAAQMD regulations, require either "no
visible emissions", specified cover requirements, or alternative
approved control methods for inactive asbestos disposal sites;
these requirements are ARARs for the completion of the remedy at
the Site. The NESHAPs requirement for adequate wetting of asbes-
tos materials for emissions control and dust suppression is an
ARAR for the implementation of the remedy at the Site.
2. Toxic Substances Control Act (TSCA) and Asbestos Hazard Emer-
gency Response Act (AHERA) regulations, 40 C.F.R. 763.
EPA has promulgated regulations under TSCA and AHERA
(Subchapter II of TSCA) related to the inspection and management
of asbestos-containing material in schools. These regulations
utilize polarized light microscopy (PLM) as a measurement tech-
nique for detecting asbestos; the use of this measurement tech-
nique for asbestos is relevant and appropriate to the cleanup of
the South Bay Asbestos Area site.
15
-------
Location-Sgecific ARARs
3. National Historic Preservation Act, 16 U.S.C. i470f: Historic
Sites Act, 16 U.S.C. 00461 et seq.: Archaeological and Historic
Preservation Act, 16 U.S.C. 00469 et. seq.: Executive Order
(E.O.) 11593 (Protection and Enhancement of the CUltural Environ-
ment, May 13, 1971): 40 C.F.R. 16.301; and 36 C.F.R Part 800)
Federal Agencies are required to consider the effects of
their actions upo~ designated or potential historic, architec-
tural, archaeological, and cultural sites and natural landmarks.
The older section of Alviso is listed in the National Register of
Historic Places. To the extent that remedial activities may im-
pact this section and other potentially protected areas of the
Site, the substantive requirements of these statutes, orders, and
regulations are ARARs.
4. McAteer-Petris Act and regulations (California Government
Code, Title 7.2, ii 66600 et. seq.: California Administrative
Code (CAC). Title 14, Div. 5, Sec. 10110 et. seq.)
The McAteer-Petris Act established the San Francisco Bay
Conservation and Development Commission (BCDC), which regulates
activities adjacent to the Bay through the San Francisco Bay Plan.
document and permit requirements. Although remedial activities
conducted onsite are exempted from permits (CERCLA 0 121(e) (1),
42 U.S.C. i 9621(e) (1», the substantive requirements of the Bay
Plan are ARARs, to the extent that a BCDC permit would otherwise
be required.
5. Endangered Species Act and regulations (16 U.S.C. 0 1531 et
seq.: 40 C.F.R. 0 6.302(h);50 C.F.R Parts 17 and 402.
Section 7 of the Endangered Species Act, 16 U.S.C. i 1536,
requires Federal agencies to insure that their actions are not
likely to jeopardize the continued existence of any endangered
species or cause adverse modifications of critical habitat. En-
dangered species (including Salt Marsh Harvest Mouse and Califor-
nia Clapper Rail) have been identified in wetland habitat ad-
jacent to the Site. Section 7 and related regulatory require-
ments are therefore ARARs.
6. U.S. Fish and Wildlife Service Mitigation POlicy, 46 Fed.
Reg. 7644-7663 (Jan. 23, 1981).
This policy defines' four resource categories of impacted.
habitats, and establishes mitigation goals and guidelines for'
each category. According to USFWS, the mitigation goal for any
losses of habitat values for the wetlands near Alviso is no net
loss of in-kind habitat values.
16
-------
7. Clean Water Act, Section 404 (33 U.S.C. I 1344) and regula-
tions, 40 C.F.R. 230 et. seq.; Executive Orders 11988 (Floodplain
Management) and 11988 (Protection of Wetlands), May 24, 1977; 40
C.F.R. 6.302 (a) and (b) and 40 C.F.R. Part 6, Appendix A.
These ARARs address wetlands protection and floodplain
management. The site is located in a floodplain and adjacent to
wetlands. Federal agencies are required to avoid, to the extent
possible, adverse impacts from destruction of wetlands, and avoid
support of new construction in wetlands if a practicable alterna-
tive exists. section 404 and regulations mandate that dredged or
fill material should not be discharged into aquatic ecosystems
(in this case wetlands) unnecessarily.
Action-SDecific ARARs
8. Occupational Safety and Health Act (OSHA) regulations, 29
C.F.R. 1910.1000 and 1910.1001.
OSHA has set a Permissible Exposure Limit (PEL) for asbestos
fibers at .2 fibers per cc for occupationally exposed workers.
The PEL was intended for workplace exposures (8 hours per day, 40
hours per week, 52 weeks per year) and not for continuous- ambient
exposures. The PEL is an ARAR as an upper limit for all ex-
posures, but would not be protective for the exposure scenarios
used in the risk assessment. The selected remedy will ensure
that actual ambient exposure levels are lower than the limit es-
tablished by this ARAR, and protective of human health and the
environment. This ARAR could also be categorized as a
contaminant-specific ARAR, since it is asbestos-specific.
VIII.
DescriDtion of Alternatives
The analysis of remedial technologies, presented in
feasibility study report, resulted in the development of
ternatives for site remediation. These alternatives are
marized below..
the
four al-
sum-
Alternative No.1 - No Action
The no action alternative serves as a baseline for comparing
all other alternatives. Under the No Action alternative, no
cover or removal activity would occur to reduce or prevent emis-
sions of soil containing asbestos. Risk to the community would
remain unabated. The only site activities which would occur un-
der No Action would be site air monitoring and soil sampling, and
revision of the Public Health Evaluation (PHE). These activities
17
-------
would occur at 5-year intervals as required under CERCLA A 121
(c) (42 U.S.C. section 9621(c», since wastes would be left on
site.
Alternative No.2 - Pavinq Truck and Industrial Yards/Wet Sweec-
ina of Streets/ Off-site Discosal of Waste Material as Reauired/
Institutional Controls
Alternative No.2 involves (1) paving asbestos contaminated
truck and industrial yards comprising a maximum estimated area of
approximately 128,500 square yards: (2) wet sweeping of Alviso
streets on a monthly bas~s, using a conventional street sweeper
preceded by a water truck: (3) locating and removing obvious as-
bestos sources such as pipes, and disposing of them in an off-
site landfill: (4) placing of deed restrictions on landfill sub-
units, after verifying NESHAPs cover thickness: and (5) estab-
lishing institutional controls to ensure maintenance of the
remediation. The long-term effectiveness of this alternative
would be high because paving the truck and industrial yards and
sweeping of streets would eliminate two primary sources of air-
borne asbestos. .Potential risks from soil disruption during
paving will be minimized by employing dust control. This remedy
is anticipated to take 1 to 2 years to complete.
. Alternative 2, as originally proposed, called for.a one time
vacuum sweeping of Alviso streets to remove debris generated by
paving construction. street sweeping was abandoned in Alviso
due to the asbestos problem, and a considerable amount of dust
had accumulated in the streets. In response to comments received
during the public comment period, the City of San Jose is con-
ducting monthly street sweeping with a conventional street
sweeper preceded by a water truck. This has demonstrated to ef-
fectively remove debris while emitting a minimal amount of dust.
EPA considers regular wet sweeping on a monthly basis to be more
practical and beneficial than one-time vacuum sweeping. This
change does not significantly alter the scope, cost or perfor-
mance of the remedy as originally proposed.
Prior to resurfacing, all identified truck and industrial
yards and other contaminated unpaved areas subject to heavy
vehicular traffic will be sampled extensively to determine more
specific paving requirements. To date, only random samples have
been collected from a select number of yards, which identified an
asbestos problem in these areas. Paving will be required on lots
where asbestos is found in levels exceeding 1 area percent by
PLM, which also receive or have future potential to receive heavy
vehicular traffic. The specific areas to be remediated will be
delineated during the design phase of the project.
18
-------
Alternative No.3 - pavina Truck and Industrial Yards. Sainte
Claire Landfill. and 50% of Alviso UnDaved Parkina Lots: Soil
Cover on 50% of Residential Yards and Vacant Lots/ Wet SweeDina
of Streets/ Off-Site DisDosal of Waste Materials/ Institutional
Controls
Alternative No.3 involves all cover and removal activities
as described for Alternative NO.2, plus the placement of addi-
tional cover on low to medium risk areas. These areas include
vacant lots, landfills, yards, gardens, and businesses with ex-
posed soil or debris. The alternative would involve resurfacing
50 percent of asbestos contaminated parking lots, driveways, un-
paved roadways between Marshland Landfill and Gold Street, and
the Sainte Claire Landfill. Approximately 50 percent of vacant
lots, yards, and gardens would be covered with a vegetated soil
cover. Institutional controls such as long-term maintenance
agreements would be implemented to ensure long-term integrity of
asphalt and soil covers. The effectiveness of Alternative No.3
in reducing asbestos exposure would be slightly better than Al-
ternative No. .2, because of the additional asphalt and soil
cover. The increase in effectiveness cannot be quantified and is
considered marginal in terms of reducing exposure to Alviso resi-
dents. Moreover, because of the larger areas involved, this al-
ternative is much more costly than Alternative No.2. This al-
ternative is anticipated to take 3-1/2 to 5 years to complete.
Alternative No.4 - Paving Truck and Industrial Yards. Sainte
Claire Landfill. and 100 % of UnDaved Parking Lots/ Soil Cover on
100% of Residential Yards and Vacant Lots/ Wet SweeDina of
Streets I Off-Site DisDosal of Waste Materiall Institutional Con-
trols
Alternative No.4 is identical to Alternative No.3 except
that No.4 would remediate 100 percent of all areas with detec-
table asbestos. Due to the larger areas targeted for covering,
Alternative No.4 is the most costly of the four proposed alter-
natives, but may not represent a significant increase in effec-
tiveness (exposure reduction) over Alternative No.2. This al-
ternative is anticipated to take 6 to 7 years to complete.
Minor Chanaes
1. As explained above in the description of Alternative 2,
monthly wet sweeping of Alviso streets has replaced the
originally proposed one-time vacuum sweeping.
2. EPA has continued to refine the identification of ap-
plicable or relevant and appropriate requirements (ARARs) for the
proposed remedial alternatives. The list of ARARs in Section VII
for the alternatives is more expansive than described in the
Feasibility Study Report. The newly identified ARARs do not sig-
19
-------
nificantly alter the scope, performance or cost of the remedy.
Accordingly, this is a minor change from the earlier remedy
selection documentation.
IX .
SummarY of the Comoarative Analvsis of Alternatives
This section presents a comparison of alternatives using
nine component criteria. These criteria, which are listed below,
are derived from requirements contained in the National Contin-
gency Plan and CERCLA Sections 121(b) and 121(c).
1.
Protection of human health and the environment.
2.
Compliance with ARARs.
Reduction of toxicity, mobility, or volume through treatment.
J.
4.
Long-term effectiveness or permanence.
5.
Short-term effectiveness.
6.
Implementability.
7.
Cost.
8. State Acceptance.
9.
Community Acceptance.
1.
Protection of Human Health and the Environment
The truck and industrial yards represent only a portion of
the estimated total contaminated area, but present the greatest
health risk due to frequent vehicular activities that release as-
bestos into the air. Alternative No.2 would eliminate asbestos
emissions from the truck and industrial yards (assuming main-
tenance of the asphalt cover) and remove asbestos laden dust from
the streets. These actions would reduce site-wide risk and
provide a considerable measure of overall protection. Because
soil with low levels of asbestos contamination would remain in
other areas of the site, risks from asbestos exposure would not
be completely eliminated. The remaining incremental risk would
depend on the degree to which these other areas remain undis-
turbed. Institutional controls, in the form of routine main-
tenance and deed restrictions, will be implemented on the areas
targeted for remediation to ensure protectiveness. Five year
20
-------
reviews will be conducted to evaluate the need for further action
should other unpaved areas come into a use that is incompatible
with protection of human health and the environment.
Alternative No.3 would remediate about half of the addi-
tional contaminated areas. Significant reduction in risk from
inhalation and ingestion would be achieved. Asbestos emissions
would be eliminated from all high and medium activity areas with
detectable asbestos. Risk would still remain at unremediated
locations, but because of the low activity and soil contamination
in these areas, the remaining risk would be low and would not
significantly impact the site-wide risk.
Alternative No.4 would be the most protective alternative
because all contaminated soil areas would be covered or removed.
The No Action alternative would provide no protectiveness or
risk reduction. Risks would 3emain similar to levels estimated
in the Risk Ass~ssment or 10- at the truck and industrial yards
and 10-4 to 10- in the community.
2.
ComDliance with ARARs
The ARARs pertinent to Alternatives 2 - 4 are set forth in
Section VII, above. With stringent dust control and responsible
construction practices, all ARARs would be attained by Alterna-
tives NO.2, 3, and 4. The No Action alternative would not at-
tain all ARARs or provide grounds for a waiver, as asbestos emis-
sions would remain uncontrolled.
3.
Reduction of Toxicitv. Mobilitv. or Volume
Because there is no feasible treatment technology for asbes-
tos, no remedial alternative for this site utilizes treatment.
Therefore, the selected alternative is consistent with the
statutory preference for selecting remedies "that have as a prin-
cipal element treatment which permanently and significantly
reduces the toxicity, mobility, or volume of the hazardous sub-
stances, to the extent that such remedies exist.
4.
Lonq-Term Effectiveness and Permanence
Alternatives 2, 3 and 4 involve placement of resurfacing
material over contaminated soil as a means of containment, which
will reduce the mobility of the contaminant. The long-term ef-
fectiveness of such actions is dependent on proper maintenance of
the pavement. If properly maintained, the long-term effective-
ness of this remedy is high. Since the remedies involve contain-
21
-------
ment rather than treatment or removal, a quinquennial inspection
will be required to assure the continued effectiveness of the
containment measures.
Under Alternative No.2, an asphalt cover that is maintained
would be an effective control measure for asbestos emissions from
the truck and industrial yards. This action, coupled with wet
sweeping of street dust and removal of debris, would provide a
high level of long-term human health protection, by remediating
the high risk units at the site. Adjacent unremediated areas
could potentially contribute to airborne emissions, but contribu-
tion of these sources is considered to be minimal due to their
low potential for disturbance. Most of the asbestos sources
would be contained on site or be transported to an off-site
landfill. Long-term effectiveness would be insured by the main-
tenance of covers and institutional controls.
Alternative 3 and 4 would provide a similar level of long
term effectiveness and permanence as Alternative 2, applied over
wider areas of coverage as previously described. However, sig-
nificant risk reduction beyond that already provided by alterna-
tive 2 may not be achieved.
5.
Short-Term Effectiveness
In the short-term, implementation of Alternative No.2 may
potentially generate visible dust during remediation. Dust con-
trol measures would be included to reduce the associated inhala-
tion risk. Construction workers would be protected through com-
pliance with OSHA regulations. Exposures during sweeping will be
low since water will be used to reduce dust emissions. Overall,
the short-term effectiveness for Alternative No.2 would be high
provided that dust mitigation measures are strictly enforced.
Implementation of Alternative No.3 would disturb a con-
siderable area with the potential for emissions of asbestos-laden
dust. The use of dust suppressants during soil excavation and
grading would be necessary to minimize this risk. Dust control
for alternatives 3 and 4 would be more difficult than for Alter-
native 2 since remediation would occur over a larger portion of
the site and in less accessible areas such as private yards.
The short term effectiveness of Alternative No.4 is rated
low to moderate because it would take nearly six years to com-
plete. The alternative involves disturbance of presently undis-
turbed soil and therefore poses a greater risk of airborne asbes-
tos production during remediation than Alternative 2. Area-wide
soil disturbance over longer periods of time may increase the
risk to public health over the short term.
22
-------
6.
ImD1ementabi1itv
Pavinq, for all alternatives would be implemented utilizinq
conventional construction techniques and equipment, with special
provisions for dust suppression. Pavinq in qeneral poses no im-
plementation problems; however, site access and preparation may
present some problems due to the number of property owners and
amount of accumulated construction equipment and debris on the
sites that may need to be moved or disposed of. Also, it will be
necessary to consider the elevations of existinq buildinqs and
driveways in the pavinq desiqns. Implementability of sweepinq is
related to availability of street sweepers, which is not an- .
ticipated to be a problem; obtaininq water durinq drouqht condi-
tions for wet sweepinq may be difficult, althouqh reclaimed water
sources may be available. Excavation and removal of debris is
easy to implement, with the only limitation beinq landfill
capacity.
Alternatives No.3 and 4 are more difficult to implement
than Alternative 2. Remedial work in many of the residential
areas would present siqnificant and potentially insurmountable
obstacles such as obtaininq access to h~ndreds of private yards.
Pavinq and constructinq soil covers in confined areas miqht re-
quire intensive manual labor, as many residential yards may be
too small to allow entry of conventional equipment.
7.
Cost
The present worth cost of Alternative No.2 is estimated to
be $7,561,000 or an equivalent unit cost of $18/square yard for
remediation of 128,500 square yards of truck and industrial
yards. The estimated total cost includes the fo1lowinq: Capital
cost is estimated to be $5,135,000. Yearly maintenance cost is
estimated to be $134,900 and includes yearly inspection and
repair/replacement of 5 percent of the asphalt cover. The re-
quired 5-year re-evaluation is estimated at $15,000 each, for a
total of $90,000 durinq the 30-year desiqn life.
The present worth cost of Alternative No.3 is estimated at
$30,789,000, or an equivalent unit cost of $44/square yard for
remediation of 128,500 square yards of truck and industrial
yards, 4,600 square yards of the Sainte Claire Landfill, and
342,000 square yards of residential yards, qardens, business,
vacant lots, and landfills. Yearly maintenance is estimated at
$233,000 for inspection, repair/replacement of 5 percent of the
soil cover, repair/revegetation of 10 percent of the soil cover,
and associated site monitorinq cost during maintenance. The cost
for re-evaluation at 5 year intervals for 30 years is $90,000.
23
-------
The present worth cost of Alternative No.4 is estimated at
$53,563,000, or an equivalent unit cost of $48/square yards for
paving of 128,500 square yards of truck and industrial yards, and
4,600 square yards of the Sainte Claire Landfill, and covering
673,000 square yards of residential yards, gardens, businesses,
and landfills. Approximately $26,500,000 (55 percent) of this
cost is for off-site disposal of debris. Yearly maintenance is
estimated at $316,300. The 5 year re-evaluation is estimated at
$90,000 over a 30 year period.
8.
State Accentance
Several state agencies reviewed the Feasibility Study and
submitted no technical comments on the alternatives. The
California Department of Health Services (DHS) rejected alterna-
tive 1. DHS has no objection to alternatives 2, 3, and 4 if all
the requirements in the California Environmental Quality Act
(CEQA) are complied with; DHS considers that CEQA is a relevant
and appropriate requirement if any remedial action other than the
no-action alternative (alternative 1) is selected. As a result,
DHS has stated that it is unable to concur with this ROD at this
time. EPA does not consider CEQA to be an ARAR. .
. 9 .
Communitv Acceptance
Community sentiments vary widely, but there is general sup-
port for reducing dust generated by industrial yards. Many Com-
munity members have expressed concern that the truck yards and
truck traffic are a primary source of the problem. Alternatives
2, 3, and 4 address these concerns. However, there appears to be
little support for more widespread action on. private property
throughout the community (Alternatives 3 and 4). Many comments
received during the comment period were concerned with the cost
of remediation and who would be financially responsible for those
costs.
x.
The Selected Remedv
The selected remedy is Alternative No.2. This alternative
involves (1) paving of truck and industrial yards after sampling
to determine extent of necessary paving; (2) monthly wet sweeping
of Alviso streets; (3) removal of asbestos waste debris (cement
pipes, etc); (4) cover inspections and deed restrictions on
landfills; and (5) routine maintenance and monitoring. This al-
ternative was selected because it addresses the primary sources
of airborne asbestos (i.e., unpaved truck yards with significant
traffic: exposed debris containing asbestos: and streets with as-
bestos dust) in the most cost-effective manner. Paving will be
required on areas receiving heavy vehicular traffic that are
24
-------
I ~-
found to contain greater than
of asbestos released into the
the vicinity of state street,
tion in health risk.
1% asbestos by PLM. The quantity
air would be reduced, especially in
resulting in a correspondingreduc-
Although the risk reduction for the other remedial action
alternatives may be somewhat greater, the risk reduction was not
considered significant when compared to significantly greater
costs for Alternatives No.3 and No.4. Alternative No.2 is
readily implementable in a shorter period of time compared to
other alternatives, and short-term effectiveness can be assured
through dust control during remediation. Lonq-term effectiveness
can be assured through maintenance of cover and institutional.
controls. None of the actions are truly permanent because the
contaminants will either be covered in place or hauled to an ap-
propriate off-site landfi~l. The remedy will require re-
evaluation every five years to ensure adequate protectiveness.
Although the California Department of Health Services has not
concurred with this ROD, DHS has raised no technical objections
to the selected remedy. (See IX.a, above.)
XI.
Statutorv Determinations
, -
The selected remedy will comply with the requirements of
Section 121 of CERCLA. The selected remedy will be protective of
human health and the environment through containment and removal
of the major sources of airborne asbestos within the community.
Implementation of the alternative will not pose unacceptable
short-term risks.
The selected remedy will comply with all ARARs identified
and described in Section VII.
The selected remedy will be cost effective. It achieves a
significant reduction in risk at the least cost. Risk reduction
of other alternatives was not significantly greater than the
selected remedy, but other alternatives were significantly more
costly.
The selected remedy is consistent with the statutory
preference for selecting remedies that permanently and sig-
nificantly reduce the toxicity, mobility or volume of the hazard-
ous substances through treatment. The selected remedy is
primarily a containment plan and as such does not employ treat-
ment or resource recovery technologies, because treatment tech-
nologies that result in permanent destruction or alteration of
asbestos are not practicable. Asbestos is a natural fibrous
mineral that receives its toxicity due to the form of the fiber.
Although reduction in mobility will be achieved through covering
and removal of source area, the form of the fiber will not be al-
25 .
-------
tered. Reduction in toxicity can only be achieved through
destruction or alteration of the fibers. "Destruction/alteration
is not technically feasible given the large area of contaminated
soil and is extremely costly (e.g., energy costs for
vitrification). Recovery of asbestos from soils is not ap-
propriate for technological and practical reasons. Asbestos is
naturally occurring and because of reduced commercial use, has
limited recovery or financial value.
The selected remedy is in compliance with the statutory man-
date to utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum ex-
tent practicable, since no such technologies are practicable for
asbestos. Through placement of cover over asbestos-contaminated
soils and the maintenance of the cover, emissions of fibers will
be prevented and public health protection achieved.
26
-------
APPENDIX I
I.
Asbestos AnalYtical Techniaues
There are three commonly accepted analYtical techniques used
to measure asbestos. They are:
1) Phase Contrast Microscopy. ("PCM") : An optical technique
useful in examining minute dust particles.
2) Polarized Light Microscopy ("PLM"): An optical technique
that uses polarized light to identify minerals.
3 ) Transmission Electron Microscopy ("TEM"): A technique using
an electron microscope to achieve extremely high resolution of
asbestos fibers too small to be resolved using optical methods.
A brief description, including the advantages and disad-
vantages of each technique, is presented below.
A.
Phase Contrast Microscocy
Phase contrast microscopy ("PCM") is a optical microscopy
technique 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. 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
method is better suited to analysis of work place air than am-
bient air because in the work place one may expect a higher frac-
tion of asbestos fibers to total particulates.
The PCM technique has three major limitations concerning its
use in the ambient environment. The technique cannot detect
fibers with diameters of less than 0.2 micrometers. Many fibers
in the environment are much smaller than this. Also, PCM can
not distinguish between asbestos fibers and other types of
fibers. Therefore, in the environment, 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 un-
suitable for measurement of asbestos fibers in ambient atmos-
pheres.
27
-------
B. Polarized Light MicroscoDv
Polarized Light Microscopy (npLMn) is the EPA-approved tech-
nique for analysis for bulk insulation samples. The PLM tech-
nique is relatively quick (1/2 hour/sample) and can be used 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 counting procedures for PLM analysis, the
point counting method and the field comparison method. The point
counting method uses a superimposed grid with 100 points. The
operator counts the points where asbestos is present. The point
\ count method 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 num-
ber of positive points. The following format is used for deter-
mination: .
Area percent ~ a/n
where:
a = number of
n - number of
(100)
points with asbestos fibers present
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., 1 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 done by visual
estimate (field comparison) or point counting is qualitative
or at best, semi-quantitive; concentration is expressed as
the ratio of asbestos to non-asbestos particles or percent
by area.
o Small fiber identification is difficult because certain
optical properties (birefringence and the angle of extinc-
tion) are hard to determine in small fibers.
o The thinnest fibers that can be observed are ap-
proximately 0.4 micrometers in diameter: fibers this small,
cannot usually be identified by mineral type. Sample
preparation methods (grinding) may reduce size of struc-
tures.
28
. ~
-------
1 -
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.
samples may still contain asbestos in quantities below the
PLM detection limit.
o No standardized sample preparation method currently ex-
ists, which may cause widely varying analytical results be-
tween laboratories.
Using PLM to identify asbestos in soils can be difficult be-
cause 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
undisturbed insulating materials. Asbestos fibers may also be
dispersed by wind and by seasonal flooding. Therefore,'a sizable
fraction of the asbestos fibers in soil could be below optical
resolution. The EPA method for analysis of bulk insulation has
been used as the de facto method for analyzing asbestos in soils,
as no other approved method exists.
c.
Transmission Electron MicroscoDY
Transmission electron microscopy (liTEM") is the most power-
ful analytical method available for measuring asbestos. TEM has
been used for air, water, or soil analysis. It is the preferred
instrumental technique for measuring asbestos in ambient atmos-
phere since it incorporates the most powerful combinations of
identification methods. TEM analysis uses electron microscopy,
at magnifications of 10,000 to 50,000 times, to detect asbestos
structures as thin as 0.2 nanometers in diameter. This is suffi-
cient to identify the thinnest asbestos fibrils under most cir-
cumstances. The transmission electron microscope allows the
operator to locate very small fibers. Two mineral identification
tools, Selected Area Electron Diffraction ("SAED") and Energy
Dispersive X-ray Analyzer ("EDXA") can then be utilized to iden-
tify 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 inter-laboratory data. Sample preparation methods
are not standard among workers, making the comparison of
results between sites or laboratories very difficult or
meaningless.
o
Analysis requires a minimum of 6 to 8 hours over 2 to 3
29
-------
days. Highly skilled analysts are required and large dif-
ferences in results can occur due to operator variance. .
o TEN analysis is extremely expensive, over 20 times the
per sample cost of optical methods.
o TEN analysis is performed on much smaller sample than PLM
so that obtaining homogeneity during sample preparation is
more critical.
o Typically, total structures are counted. Sample prepara-
tion (i.e., grinding) destroys the structure size distribu-
. tion.
Both PLM and TEM sample preparation alters the soil matrix.
This is siqnificant because the sample is dispersed into very
fine particles before it is put onto a filter for analysis.
Since asbestos occurs in clusters and bundles as well as fibers,
the sample. preparation process (in the case of. soil) can destroy
the structure 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 con-
verted to weight percent, using .data on length, width, and den-
sity. This conversion to mass is necessary due to the sample
preparation grinding process, which artificially increases the
fiber count. How the TEN weight percent compares with air emis-
sions and risk tables has not been standardized by government or
industry. Therefore, interpretation of soil data results rela-
tive to air samples and/or risk charts is very difficult, at
best.
II.
Problems with Usinq 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 success-
fully. Asbestos researchers have not agreed upon which attributes
of asbestos 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 carcinogenic, 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 fiber 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
30
-------
asbestos may partially dissolve in weakly acidic environments,
facilitating fiber clearance from the lung. However. EPA's view
is that all asbestos mineral tvoes are equally carcinogenic.
To compound the problem, analysis of ambient samples for as-
bestos is much more difficult than occupational or work place
samples, because the concentration of asbestos in the environment
may be much lower. Asbestos fibers found in ambient air may be
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. For
this reason clean up levels have been established using-the best
available analytical methods. The following discussion sum-
marizes the rationale behind choosing the one area percent by PLM
clean up level.
III. Clean UP Goals for the South Bav Asbestos Area Site
Problems with asbestos analytical techniques make estab-
lishing health-based clean up levels very difficult. As men-
tioned above, the clean up level of one area percent by PLM has
been chosen because it is the best available analytical tech-
nique. This is further evidenced by the fact that EPA chose
this method (PLM) for use in the Asbestos Hazard Emergency
Response Act ("AHERA"). AHERA specifies that the EPA approved
PLM method be used to measure asbestos levels in bulk insulation
samples. EPA has promulgated the one area percent clean up level
for the South Bay Asbestos Area site 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.
31
------- |