United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-89/035
July 1989
Superfund
Record of Decision
Atlas Asbestos Mine, CA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R09-89/035
3. Recipient** Acceuion No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Atlas Asbestos Mine, CA
First Remedial Action
5. Report D*te
07/19/89
7. Author(»)
8. Performing Orgtnizrton Rept No.
«. Performing Organization Nuna and Minn
10. ProjecVTMk/Work Unh No.
11. Contract(C) or Gr*nt(G) No.
(C)
(0)
12. Sponsoring OrgtnlzMJon Nun* and Addre**
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Riport & Period Covered
800/000
14.
IS. Supplementary No«n
18. Abatract (Limit: 200 word*)
The Atlas Asbestos Mine site is in Fresno County, California, and is being remediated
concurrently with the Coalinga Asbestos Mine site. This Record of Decision (ROD) does
not address the mines, but rather a separate area in the city of Coalinga, where
asbestos, from the Atlas-Coalinga mines, was deposited to await handling and shipment.
'his 107-acre site has been designated as the first operable unit for the Atlas Asbestos
line and the Coalinga Asbestos Mine sites. From the 1960s to the mid-1970s extensive
asbestos mining and milling took place in areas near the site, and until 1980 the site
operated as an asbestos milling, manufacturing, storage, and transportation center. The
site consists of four distinct areas: (1) the warehouse which was once a mining waste
distribution center and which currently houses 1,600 cubic yards of mining waste; (2) a
storage yard which contains asbestos-contaminated stacked pipes; (3) a shipping yard
which was used as an asbestos distribution center by the Atlas Asbestos Company; and (4)
the U.S. Asbestos Company which currently stores piles of asbestos-contaminated mining
waste. In 1980 a State inspection revealed elevated levels of asbestos in the nearby
aqueduct which suggested that the Atlas Asbestos Mine and Coalinga Asbestos Mine sites
were probable asbestos sources. Subsequent sampling programs, conducted between 1983 and
1987, revealed that surface water and air also contained elevated levels of asbestos. As
a result of these findings, EPA issued an Administrative Order (See Attached Sheet)
17. Document Analytic a, Descriptor*
Record of Decision - Atlas Asbestos Mine, CA
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: metals (nickel), other inorganics (asbestos, mining wastes)
b. Menttfiera/Opon-BidedTMina
c. COSAT1 Held/Group
Avallabilty Statement
19. Secivtty Clue (Thl» Report)
None
20. Security due fThle Page)
None
21. No. of Page*
116
22. Price
(See ANSI-Z39.18)
SM Instruction* on R» wnw
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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an organizational hlerachy. Display the name of the organization exactly as It should appear In Government Indexes such as
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11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
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16. Abstract Include a brief (200 words or less) factual summary of the most significant Information contained In the report. If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific and precise to be used as Index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use Identifiers for project names, code names, equipment designators, etc. Use open-
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A GPO: 1983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
(4-77)
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EPA/ROD/R09-89/035
Atlas Asbestos Mine, CA
First Remedial Action
16. Abstract (continued)
to a major landowner, Southern Pacific Transportation Company (SPTC), requiring SPTC to
conduct an additional remedial investigation and a feasibility study and to perform
interim measures to stabilize the site. Because airborne emissions of asbestos pose the
greatest threat to neighboring residents, this remedial response will limit the amount
of asbestos and nickel released from the soil and emitted into the air. The primary
contaminants of concern affecting the soil and debris are metals including nickel, and
other inorganics including asbestos and mining wastes.
The selected remedial action for this site includes excavating and consolidating 14,500
cubic yards of asbestos, chromium, and nickel-contaminated soil and building debris;
constructing an underground waste management unit (WMU) to contain and dispose of
contaminated soil and waste onsite; capping the WMU area; regrading the excavated area;
decontaminating debris; monitoring soil moisture content, ground water, air, and
personnel;and implementing institutional controls. The estimated present worth cost for
this action ranges between $1,500,000 to $2,500,000, which includes annual O&M costs of
$35,000.
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CITY OF COALING* OPERABLE UNIT
OF THE
ATLAS MINE AND JOHNS-MANVILLE COALINOA ASBESTOS MINE AND MILL
NPL SITES
RECORD OF DECISION
United States Environmental Protection Agency
Region IX - San Francisco, California
July 19, 1989
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TABLE OF CONTENTS
SECTION PAGE
Record of Decision
Declaration Statement i
Statement of Basis and Purpose i
Assessment of the Site i
Description of the Selected Remedy ii
Statutory Determinations iii
Decision Summary 1
1.0 Site Location and Description 1
2.0 Site History 3
3.0 Enforcement 4
4.0 Community Relations 5
5.0 Scope and Role of the Operable Unit 5
6.0 Site Characteristics 6
7.0 Summary of Site Risks 7
8.0 Description of Alternatives 9
9.0 Comparative Analysis of Alternatives 11
10.0 Applicable or Relevant and Appropriate
Requirements 16
11.0 The Selected Remedy 20
12.0 Documentation of Significant Changes 23
13.0 Statutory Determinations • 23
Administrative Record Index
Responsiveness Summary
I Introduction 1
II Overview of the ROD and Critical Community Concerns 2
III Summary of Public Comments Received and Agency Response 3
A. Comments by Members of the Coal inga City ..Council .„. 3
B. Comments by the Interested Public 11
C. Comments by Potentially Responsible Parties 12
Appendix 1:. Review of Asbestos Analytical Techniques
Appendix 2: Central Valley RWQCB Memorandum, April 7, 1989
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RECORD OT DECISION
DECLARATION
SITE NAME AND LOCATION
City of Coalinga Operable Unit
Fresno County, California
STATEMENT OF BASIS AND PURPOSE
This Record of Decision ("ROD11) presents the selected remedial
action for the City of Coalinga Operable Unit, in Fresno County,
California. The remedy was selected pursuant to the Comprehen-
sive Environmental Response, Compensation, and Liability Act, as
amended by the Superfund Amendments and Reauthorization Act, 42
U.S.C. Section 9601 et. sea.. ("CERCLA") and in accordance with
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 C.F.R. Section 300 et. seg.. ("NCP"). This decision is
based on the Administrative Record for this Operable Unit. The
attached index identifies the items that comprise the Administra-
tive Record.
The state of California has concurred in the selection of this
remedy. See Administrative Record Doc. # 1066.
THE SITE
The response action selected in this ROD addresses actual or
threatened releases of hazardous substances from the City of
Coalinga Operable Unit that may present an imminent and substan-
tial endangerment to public health, welfare, or the environment.
During remedial investigations for the Atlas Mine Superfund Site
and the Johns-Manville Coalinga Mill Superfund Site (the "Atlas-
Coal inga Superfund Sites" or the "Mine and Mill Sites"), it was
discovered that asbestos had been transported from the mines and
mills to an area within the City of Coalinga for eventual han-
dling and shipment. Soil sampling confirmed the presence of un-
controlled hot spots of asbestos and nickel contamination over
the 107 acre area in Coalinga (the "Site"). An outline of the
Site can be found at Figure LA.
On August 24, 1987 the Environmental Protection Agency ("EPA")
issued Order No. 87-04 to the Southern Pacific Transportation
Company ("SPTC") pursuant to CERCLA Section 106. Order No. 87-04
required SPTC to take emergency containment actions at the Site
to reduce the threat to public health from nickel and asbestos
dust that could enter the air from contaminated soils. Pursuant
i
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Areas at the Site, including warehouses, storage yards and ship-
ping yards, contain asbestos-bearing soils, equipment and waste
piles. Analysis of soil and waste pile samples using polarized
light microscopy ("PLM") shows the asbestos levels ranging from
one area percent (the detection limit) to as high as 98 area per-
cent. Chromite ore waste and soil samples were also analyzed for
heavy metals. These analyses indicated that the Soluble
Threshold Limit Concentration ("STLC") for the heavy metal
nickel, as specified in Title 22 of the California Administrative
Code, was exceeded in some of the samples that tested positive
for asbestos.
Asbestos and nickel are hazardous substances as defined in 42
U.S.C. § 9601(14) and as listed in 40 C.F.R. § 302.4. Asbestos
is a known human carcinogen and has been shown to cause lung can-
cer and mesothelioaa. Asbestos also causes other lung diseases,
such as asbestosis. Nickel is a potential human carcinogen that
can affect the lungs, nasal cavities, and skin. If asbestos and
nickel remain uncontrolled at the Site, the potential for human
exposure to asbestos and nickel and the resulting increased risk
to human health, primarily through the inhalation pathway, will
remain.
EPA is undertaking additional Remedial Investigations/Feasibility
Studies ("RI/FS") to evaluate remedial action alternatives for
the Mine and Kill Superfund Sites and will select remedies for
those Sites in separate Record of Decision documents.
DESCRIPTION OF THE SELTCTF0 REMEDY
The remedial action selected for the Site in this ROD is contain-
ment of the asbestos- and nickel-contaminated materials in an un-
derground vault. This remedy entails:
1) The removal and consolidation of the asbestos- and
nickel-contaminated soils at this Site that: (a) exceed one area
percent asbestos using polarized light microscopy ("PLM"), (b)
display the light-grey coloring characteristics of asbestos con-
taminated soils and/or (c) contain nickel at levels in excess .of....
background. Areas displaying light-grey coloring will be
remediated until no light grey color is visible and only light
brown soil remains, by visible inspection; confirmation will be
by 1 area percent PLM.
2) Removal and consolidation of waste materials and equip-
ment that exceed the levels set forth in paragraph 1, immediately
above.
3) Decontamination of buildings to less than or equal to
one percent by PLM.
ii
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4) Construction of an underground, on-site Waste Management
Unit to bury permanently the consolidated contaminated substances
under an impermeable cap. The impermeable cap will consist of a
compacted soil foundation layer overlain by an impermeable clay
mat, covered by a second soil layer.
5) Use of strict dust control measures to limit the release
of asbestos fibers from the Site during the Remedial Action work.
6) Confirmation sampling to ensure achievement of the
clean-up standards.
7) Ground-water monitoring and continuous monitoring of
soil moisture content using neutron probes.
8) Regrading of areas where contaminated soils have been
removed .
9) Placement of deed restrictions on the Site property
where the Waste Management Unit and soil cover exist, to prevent
the disturbance of the cap and possible release of asbestos
fibers or nickel contaminants.
The permanent burial of material contaminated with asbestos and
nickel in the Waste Management Unit will minimize the release of
asbestos and nickel, thus providing long-term protection of human
health and the environment. The estimated cost of the selected
remedial action is $2,500,000.
Operation and maintenance activities will be required to ensure
the effectiveness of the response action. These activities in-
clude: (1) quarterly visual inspections to ensure the integrity
of the cap for three years with annual visual inspections there-
after, and (2) any repair work necessary to maintain the in-
tegrity of the cap, including maintenance of vegetation, 3)
ground water monitoring well(s), and 4) monitoring of soil mois-
ture content using neutron probes. In the event of a natural
event such as a flood or earthquake, all repairs necessary to
contain the hazardous substances will be made. EPA will perform
a review of the remedial action pursuant to CERCLA Section
STATUTORY DETERMINATIONS
Pursuant to CERCLA Section 121, 42 U.S.C. § 9621, and in accor-
dance with the.NCP, the selected remedy for the City of Coalinga
Operable Unit: (1) is protective of human health, welfare, and
the environment; (2) meets the applicable and relevant and ap-
propriate environmental requirements; and (3) is cost effective.
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this
Site. Treatment of the asbestos contamination in the City of
Coalinga Operable Unit was determined to be impracticable based
on effectiveness, technical feasibility, implementability and
iii
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cost factors. The reasons for this determination are further
elaborated herein, and a thorough discussion of these factors nay
be found in the Operable Unit Feasibility Study for this Site.
While treatment to reduce permanently and significantly the
mobility, toxicity and volume was found to be impracticable, the
remedy is designed to protect the public and environment on a
permanent basis through continued monitoring and, if necessary,
maintenance.
This remedy will result in hazardous substances remaining on Site
above health-based levels. Pursuant to CERCLA Section 121, 42
U.S.C. Section 9621, EPA will conduct a review at five year in-
tervals, beginning after commencement of remedial action, to en-
sure that the remedy continues to provide adequate protection of
human health and the environment.
, .
C^D
* R
Daniel w. McGovern Date
egional Administrator
EPA Region IX
iv
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RECORD 0V DECISION
DECISION SUMMARY
1.0 SITE LOCATION AND DESCRIPTION
The City of Coalinga is located in Pleasant Valley near the con-
fluence of two intermittent streams, Warthan Creek and Los Gatos
Creek, which are part of the Arroyo Pasajero Drainage Basin. The
Arroyo Pasajero watershed and adjacent Cantua Creek watershed are
located on the western margin of the central San Joaquin Valley
in an area that includes the foothills of the Southern Diablo
Range Mountains to the west and a system of coalescing alluvial
fans (including the Arroyo Pasajero fan and Cantua fan) to the
east. Approximately 20 miles northwest of Coalinga, in the
Diablo Range, is the New Idria Formation. This elliptically
shaped rock formation covers approximately 48 square miles and is
the largest known serpentine deposit in the Coalinga region. The
southeastern third of the New Idria Serpentine Mass (or New Idria
Formation) has been the locus of significant mining and surface
mineral exploration. These activities have included successful
exploration and mining for chromite ore and chrysotile asbestos
ore as well as for other serpentine related minerals. Cattle
ranching and oil exploration and production are the other main
natural resource activities in the Coalinga area.
In September, 1984, an asbestos mine located in the New Idria
Formation and a mill located immediately southeast of the Forma-
tion were listed on the Superfund National Priorities List as the
Atlas Mine and Superfund Site and the Johns-Manville Coalinga As-
bestos Mill Superfund Site (the "Atlas-Coalinga Sites" or the
"Mine and Mill Sites"), respectively. During investigation of
these Mine and Mill Sites, it was discovered that asbestos had
been transported from the mines and mills to an area within the
City of Coalinga for eventual handling and shipment. Soil sam-
pling confirmed the presence of uncontrolled hot spots of asbes-
tos and nickel contamination over a 107 acre area (the "Site") in
the City of Coalinga, California.
The Site is located in a mixed use, industrial and residential
area. The Site boundary extends approximately one mile from
Fourth Street on the northern end of Coalinga to its southern
border, near the intersection of Lucille Avenue and Highway 198.
The east-west borders are between Glenn and Forest Streets in the
northern section, fanning out to Highway 198 for the western bor-
der and approximately 900 feet in an easterly direction for the
eastern border. Figure 1A is an outline of the Site boundaries;
Figure IB shows the location of the Site in relation to the Mine
and Mill Sites.
The contaminated areas at the Site connected to the Atlas Mine
Site are at the northern end of the Site, while the contaminated
areas connected to the Johns-Manville Mill Site are at the
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EXPLANATION:
• STATION NAME(DWR STATION NUMBER)
(1867-00)
SCALE
0 2000 4000 FEET
CONTOUR INTERVAL * 20 FEET
FIGURE IA
SITE LOCATION
COALINGA SITE
REFERENCE-
US6S 7.5 MINUTE TOPOGRAPHIC
MAP OF COALINGA, CALIFORNIA
QUADRANGLE. DATED I956
PHOTOREVtSED I979
SCALE' 1=24000
"Do Not Seal* This O
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LEMOORE
NAVAL
AIR STATION
I* >. I i _^^^—••**• »w
,->^te^ SITE
/ ^.-^^^^
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ARROYOPASAJERO
DRAINAGE BASIN
BOUNDARY
LEGEND
Sn.l
REFERENCE
DRAWING BY
WOODWARD-CLYDE CONSULTANTS
FIGURE 1B
COALINGA SITE
PROJECT HAUE
SITE LOCATION
IN RELATION TO MINE SITES
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southern edge of this large site. This cleanup could have
proceeded as two separate Operable Units; however, due to the
need to proceed expeditiously, EPA decided to combine the cleanup
into one Site cleanup, designated an Operable Unit for each of
the two National Priority List Mining and Mill Sites.
The Coalinga area is semi-arid and is characterized by moderately
low precipitation and relatively high rates of evaporation. The
mean annual precipitation and evaporation are estimated to be
189.6 millimeters (7.46 inches) and 2,253 millimeters (88.7
inches), respectively. (These values were calculated from periods
of record exceeding 15 years). The Pleasant Valley area is un-
derlain by unconsolidated sediments that range in thickness from
less than 100 feet to several thousand feet. The sediments un-
derlying the Site consist of interbedded gravels, sands, silts
and clays. These sediments have markedly different hydraulic
conductivities and porosities. The depth to ground water in
Coalinga is approximately 100 to 150 feet and the ground water is
used primarily for irrigation. Since at least 1951, the water
quality of the aquifer in Pleasant Valley has been poor. The
sulfate concentrations in the ground water in all reported wells
near Coalinga have exceeded the Maximum Contaminant Levels
("MCLs") under the Safe Drinking Water Act by as much as six
times the recommended concentrations. Based on the Department of
Water Resources' records of mineral analyses of ground water for
the period from 1978 to 1985, the water quality of four selected
wells in the Pleasant Valley area shows moderate to high sodium-
sulfate concentrations. The total major anion concentrations
range from 1,100 to 2,600 parts per million ("ppm") with a mean
of 1,700 ppm. Sulfate concentrations in the ground water range
from 660 to 1,900 ppm, with a mean of 1,300 ppm. The percentage
of sodium concentration relative to the major anion concentration
ranges from 45 to 53 percent with a mean of 49 percent. Vir-
tually all of the drinking water for Coalinga is drawn from the
California Aqueduct.
Description of Contaminated Structures and Areas
The Site has been divided into the following four areas, based on
existing structures and geography (see figure 3):
1) The Marmac Warehouse: The warehouse is located on Elm
Avenue (Highway 198) in the southwest section of Coalinga. This
area was a chromite ore distribution center and currently houses
approximately 1,600 cubic yards of chromite ore waste and other
materials contaminated with asbestos.
2) The Storage Yard: This yard is located approximately
one mile south of the Marmac Warehouse on Elm Avenue on the east
side of the road. The storage yard contains stacked pipes that
are contaminated with asbestos.
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EXPLANATION
I I 0* ANALYTICAL MtULTt
COHTIOUOU* AMD OIHATtK THAU 1«
VISUAL IITINT O» CONTAMINATION
HM COMFOMTI OHIO*
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3) The Atlas Shipping Yard: This yard is located in the
vicinity of Glenn Avenue and 6th Street. It was used as an as-
bestos distribution center by the Atlas Asbestos Company.
4) The U.S. Asbestos Company: This area is located at the
southern border of the Site and encompasses approximately nine
acres. Piles of raw asbestos ore are located in this area.
Because of the close proximity of residential areas to the piles
of asbestos-containing material, it is important that the
remediation proceed as soon as possible.
2.0 SITE HISTORY
In the mid-1950's, an investigation by the California Division of
Mines and Geology indicated that the serpentine matrix of the New
Idria formation was chrysotile asbestos. Subsequent investiga-
tion in the southeastern third of the New Idria Formation
demonstrated that the asbestos ore could be mined and milled to
produce a marketable short-fiber asbestos product. From 1959
through 1962, the Coalinga and Los Gates Creek areas experienced
an intensive land rush for asbestos mining claims. From the
1960's through the mid-1970's, extensive asbestos mining and
milling operations were conducted in the Coalinga and Los Gatos
Creek areas. From 1955 to 1980, the Site was the locus of mill-
ing, manufacturing, storage and transportation of asbestos-mining
materials from the Mine and Mill Sites.
Discovery of the Problem in coallncra
In early 1980, the Metropolitan Water District ("MWD") of
Southern California detected elevated levels of asbestos in water
samples from the California Aqueduct. An extensive sampling
program along the Aqueduct, conducted by the MWD in August
through September of 1980, suggested that the Atlas Mine and the
Johns-Manville Mill Sites were probable sources of asbestos in
the California Aqueduct. Asbestos levels of up to 2500 million
fibers per liter ("MFL") were measured.
On October 17, 1980, the Central Valley Regional Water Quality
Control Board ("CVRWQCB") and the California Department of Health
Services ("DHS") inspected the Atlas Mine and the Johns-Manville
Mill to determine if waste discharges from these facilities were
in compliance with state regulations. The CVRWQCB concluded that
additional corrective measures should be taken to prevent mine-
and mill-generated asbestos from entering the drainage basins.
In March of 1983, the CVRWQCB collected four surface water
samples during a period of high run-off in the Arroyo Pasajero
watershed. Asbestos fiber concentrations in these samples ranged
from 80,000 to 240,000 MFL. On June 14, 1983 the risks repre-
sented by the Atlas Mine and the Johns-Manville Coalinga Asbestos
Mill were rated using the Hazard Ranking System. The Mining and
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Mill Sites were approved for listing on the National Priorities
List in September, 1984. Remedial Investigation/Feasibility
Studies ("RI/FSs") are ongoing at both of these Sites.
During an airborne asbestos sampling program in 1986 and 1987
conducted as part of the Remedial Investigation and designed to
measure airborne emissions from the Mining and Mill Sites, high
asbestos readings were measured in the City of Coalinga. Based
on this data, a study was initiated to look for possible sources
of asbestos in Coalinga. On June 17 and 18, 1987, EPA conducted
a limited sampling and analytical program in Coalinga. This
study showed chrysotile asbestos occurrence from less than one
(1) percent to fifty (50) percent in the area of the Site. Fur-
ther investigation revealed that a major landowner in the con-
taminated area was Southern Pacific Transportation Company
("SPTC"). In August of 1987, EPA issued an administrative order
pursuant to CERCLA Section 106 (Order No. 87-04) to SPTC, requir-
ing SPTC to conduct a Remedial Investigation at the Site (i.e.,
an intensive sampling program to identify and quantify sources of
mining waste contamination). As a result of the Remedial Inves-
tigation, areas contaminated with residual asbestos ore waste
have been found throughout, the Site. SPTC was also ordered to
prepare an Operable Unite Feasibility Study ("OUFS") to develop
and evaluate remedial alternatives for the Site. EPA released
the OUFS and information concerning EPA's proposed plan for
cleanup of the Site on February 9, 1989.
In response to Order No. 87-04, SPTC also performed interim
measures to stabilize the waste materials during the more
detailed investigation. These tasks included: i) limiting ac-
cess to contaminated areas with fencing, ii) posting warning
signs, iii) spraying biodegradable sealant to control dust emis-
sions, and iv) covering waste ore piles with plastic sheeting.
These interim measures were performed in the fall of 1987; a
second spraying of sealant took place in the spring of 1988 and a
third spraying took place in June of 1989.
3.0 ENFORCEMENT ' ' "
In the spring of 1988, general notice letters were sent to
several Potentially Responsible Parties ("PRPs"), notifying them
of their potential liability for the cleanup of the Site. On
February 22, 1989, EPA issued notices of negotiations to the PRPs
for the City of Coalinga Operable Unit asking for good faith of-
fers. Due to the significant risk to the public health and the
environment posed by uncontained hazardous waste in Coalinga, and
the immediacy of the threat, EPA determined pursuant to CERCLA
Section 122 that clean-up should be completed as soon as pos-
sible, and that the discretionary special notice procedures in
CERCLA Section 122 should not be invoked. Therefore, PRPs were
given 21 days to respond to EPA's request for good faith offers.
Negotiations to sign a consent decree are in progress. On May
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10, 1989, a general notice letter was sent to the City of
Coalinga notifying the municipality of its possible liability in
this matter.
4.0 COMMUNITY RELATIONS
The public comment period for the OUFS and the proposed plan
opened on February 9, 1989 and closed on March 24, 1989. A
public meeting was held on February 22, 1989 at the Coalinga City
Council Chambers and was attended by approximately sixty people.
Prior to the beginning of the public comment period, EPA pub-
lished a notice in the Fresno Bee and the Coalinga Weekly
Courier. The notice briefly described the proposed plan and an-
nounced the public comment period and the public meeting. The
notice also announced the availability of the proposed plan and
the OUFS for review at the information repository established at
the Coalinga Public Library.
A fact sheet describing the proposed plan was delivered to the
information repository. Copies of the fact sheet were mailed to
the EPA general mailing list for the Atlas Mine and Johns-
Manville Coalinga Asbestos Mill Sites, which included ap-
proximately 300 members of the general public, elected officials
and media representatives. Since June, 1987, EPA personnel have
met periodically with members of the Coalinga City Council.
Several different persons designated by the City Council to be
the Council's contact with EPA have been kept informed about the
investigation's status.
EPA has prepared the attached responsiveness summary, which
provides responses to the comments submitted in writing during
the public comment period, as well as responses to comments made
by attendees at the February 22, 1989 public meeting.
5.0 SCOPE A^l? RPI.-E. OF THE OPERABLE
The contamination at the Site represents the first operable unit
of the Atlas Mine Site and of the Johns-Manville Coalinga Asbes-
tos Mill Sites. The principal threat posed by uncontained as-
bestos close to residential areas comes from airborne emissions.
The purpose of this response is to limit current and future air-
borne emissions from the asbestos- and nickel-contaminated soils.
The remedial action selected in this ROD addresses a problem
specific to a populated area. Asbestos piles in Coalinga are to
be removed, consolidated and permanently buried so that airborne
emissions of asbestos fibers are minimized. The remediation
strategy for this Site is necessarily different from the remedia-
tion strategy being considered for the Mine and Mill Sites.
Those Sites contain large piles of asbestos ore tailings situated
in sparsely populated areas and surrounded by very rich sources
of naturally occurring chrysotile asbestos. These different
situations require consideration of different factors. The RI/FS
for the Atlas Mine Site and Phase 1 of the Johns-Manville
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Coalinga Asbestos Mill Site (sampling and data collection) were
initiated in July of 1985. The RI/FS for the work remaining on
the RI as well as for the complete FS for the Johns-Manville
Coalinga Asbestos Mill Site was initiated in November of 1986.
The major goal of both RIs is to identify the sources, extent,
pathways and receptors of the contaminants and to characterize
the nature and extent of the public health and environmental
problems presented by the contamination. Major components of the
Remedial Investigation Reports include detailed soil, water and
air sampling, geological and geotechnical studies and watershed
modeling. The Feasibility Studies for these Sites, which will
evaluate the necessity for and proposed extent of remedial ac-
tion, are expected to be completed in the fall of 1989.
6.0 SITE CHARACTERISTICS
Elevated asbestos levels in the air in Coalinga were first dis-
covered during the regional airborne asbestos sampling of 1986
and 1987. The detailed soil sampling performed by SPTC in the
site area found levels of asbestos ranging from less than one
area percent to as high as 98 area percent (found in raw asbestos
ore piles). The composite soil samples were analyzed using
Polarized Light Microscopy ("PLM") as described in Interim Method
for the determination of Asbestos in Bulk Insulation Samples
(EPA-600/M4-82-020). The less than one percent results are those
in which the contaminant was present, but was below the level at
which the concentration could be determined.
Figures 2 and 3 show the areas within the Site where asbestos
contamination was detected. The total affected area is ap-
proximately 11 acres and the depth of contamination ranges from
several inches to several feet. Asbestos ore waste was iden-
tified in a one half acre area adjacent to the Coalinga Machine
Company. Samples from this asbestos ore waste ranged from two
(2) area percent asbestos to 80 area percent using PLM. Ap-
proximately 500 feet south of Polk street is an area of ap-
proximately one and one half acres with recorded asbestos levels
ranging from one area percent to 46 area percent. On the
southern border of the Site is an area of approximately nine
acres where piles of raw asbestos ore were identified. One
sample from this area measured 98 area percent asbestos. The
fenced area around the Marmac Warehouse contains broken pieces of
asbestos-containing paneling. Several piles of suspected
chromite ore waste are present within the warehouse. The
suspected chromite ore vaste in the Marnac Warehouse was sampled
and analyzed for heavy metals and asbestos contamination. Three
samples were analyzed for asbestos and the 17 metals listed in
Title 22 of the California Administrative Code. The Title 22 To-
tal Threshold Limit Concentration ("TTLC") for asbestos was ex-
ceeded in all samples; the Soluble Threshold Limit Concentration
("STLC") for nickel was exceeded in all samples. Additional
samples from asbestos-contaminated areas throughout the Site were
analyzed to see if a correlation existed between asbestos content
and elevated levels of nickel. These analyses indicate that
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Southern Pacific Transportation Co. Page 6
WMU Design Report
at any one measuring point within the vadose zone beneath the WMU,
the following response will be initiated:
1. The RWQCB will be notified of test results and the
elevated area will be retested.
2. After consulting with the RWQCB, a decision will be made
as to whether this is an anomalous reading or if a real
increase in moisture content has been detected. In the
event that the detected increase is real, the following
steps will be taken:
(a) A qualitative assessment of the monitored area will
be performed to determine the areal and vertical
extent of migration. This assessment will consist
of a detailed review of all data collected from the
vadose zone monitoring network, background data
established at the beginning of monitoring, and a
review of the geotechnical and geochemical
characteristics of the suspected soils.
(b) A drilling and soil sampling program will be
designed to collect soil Samples from the affected
areas and laboratory analyses will be performed.
(c) Laboratory analyses will be performed on archived
materials from the same location as the elevated
moisture readings.
(d) Results of the laboratory analyses will be compared
for indications of contamination.
(e) Should the continued neutron probe monitoring still
indicate elevated moisture contents, a soil-pore
liquid sampler will be installed. In addition,
soil-pore liquid. samplers will be installed away
from the suspect area to provide background data,
if the background soils contain sufficient moisture.
3. Upon installation of a soil-pore liquid sampler, samples
will be collected for analyses on a quarterly basis and
compared to background samples for indications of
contamination.
4. If the RWQCB determines that the results of pore fluid
sampling indicate contaminant migration which might
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Southern Pacific Transportation Co. Page 7
WMU Design Report
endanger groundwater, a monitoring plan, consisting of
one upgradient and two dovngradient wells, will be
submitted to the RWQCB within 90 days.
Comments and Recommendations:
Upon review of the report, I have no objections to SPTC proceeding
with the proposed project provided the following items are
addressed.
1. Upon completion of the WMU, a report detailing
construction should be submitted for our review. The WMU
should be inspected by staff prior to its use.
2. Schedule for construction and closure of the WMU, along
with a schedule for deposition of waste into the unit,
should be provided so staff can schedule periodic
inspections.
3. Although groundwater monitoring may be minimized in favor
of vadose zone monitoring, a specific groundwater
monitoring plan including well placement and construction
details will need to be prepared, approved and thereafter
implemented. SPTC will also need to develop a
groundwater sampling program.
4. The design report does not indicate that all results from
vadose zone monitoring will be submitted to our office.
The report only indicates that the RWQCB will be
contacted if a significant change in moisture content is
observed. Results of all monitoring data will be
required as soon as they are made available to SPTC.
I recommend that we request SPTC to address the comments and
recommendations, as outlined above, prior to construction of the
WMU. If modifications are made to this design, these changes will
also need to be submitted for our review.
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samples which contain greater than one percent asbestos are posi-
tively correlated with samples that exceed the STLC for soluble
nickel. Nickel is a by-product of asbestos milling processes and
is likely to be associated with asbestos ore waste.
Asbestos is a generic term referring to two groups of naturally-
occurring hydrated silicate minerals having a fibrous crystalline
structure. The asbestos mineral found in the New Idria Serpentine
Mass is chrysotile, a fibrous mineral with an elongated, needle-
like structure. Chrysotile is a short-fiber asbestos mineral.
Asbestos fibers are widely used for their high tensile strength
and flexibility and for their noncombustible, nonconducting, and
chemical-resistant properties. The fibers have been used in in-
sulation, brake linings, floor tile, plastics, cement pipe, paper
products, textiles, and building products.
7.0 SUMMARY OF SITE RISKS
Asbestos is the primary contaminant of concern at the Site.
Major sources of asbestos at the Site are contaminated soils and '
piles of raw asbestos ore waste. Low levels of soluble nickel in
some of the asbestos tailings are of secondary concern.
Asbestos is one of the few known human carcinogens. Asbestos ex-
posure can also cause other lung diseases, such as asbestosis.
EPA considers carcinogens to be non-threshold in nature, that is,
any amount of a human carcinogen in the environment represents a
cancer risk to the exposed population. Asbestos has been the
subject of numerous epidemiological studies. Exposure to asbes-
tos has been positively linked to asbestosis, lung cancer, and
mesothelioma. Also associated with asbestos exposure in some
studies are cancers of the larynx, pharynx, gastrointestinal
tract, kidney, and ovary, as well as respiratory diseases such as
pneumonia. A full discussion of the health effects of asbestos
is found in the EPA document Airborne Asbestos Health Assessment
Update. June 1986.
Analytical results from air sampling conducted in August, 1986,
March, 1987 and September-October 1987, as well as results of
soil sampling conducted as part of the OUFS, form the database
that were used to qualitatively assess the health risks in
Coalinga. Further details of health risks in the Coalinga area
related to asbestos are included in the risk assessment chapter
in the Remedial Investigations for the Mine and Mill Sites.
There are two general routes of exposure to asbestos at the Site:
inhalation and ingestion. Inhalation is the exposure pathway of
greatest concern to human health because this pathway has been
positively linked to cancer in humans. While not of primary im-
portance, ingestion exposure to asbestos may also be associated
with an increased risk of cancer. These ingestion exposures in-
clude direct ingestion of soil contaminated with asbestos and in-
direct ingestion of asbestos which has been inhaled.
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8
Individuals may inhale asbestos fibers which are present in am-
bient air and asbestos fibers which are entrained into the air as
a result of specific activities. Ambient concentrations of as-
bestos were detected in both on-site and off-site areas by the
air monitoring conducted in 1986 and 1987. Soil disturbing ac-
tivities such as children playing in or bicycle riding on
asbestos-contaminated soils can resuspend asbestos fibers into
the air. Vehicular traffic on unpaved areas containing asbestos
contaminated soils such as truck yards and vacant lots can
entrain significant amounts of asbestos into the air. Asbestos
fibers stirred up by truck traffic may be inhaled by truck yard
personnel and by persons living downwind from the Site. Soil
concentrations of asbestos in the Site range from a geometric
mean of less than one area percent to 98 area percent.
Experiments conducted by the California Department of Health
^Services ("DHS") in 1985 clearly show that a pickup truck driving
on unpaved asbestos contaminated soil can produce asbestos dust
concentrations in the air that pose a potential health risk to an
individual at or nearby the activity. A detailed discussion of
this experiment is included in the Remedial Investigation Report
for the South Bay Asbestos Site, Alviso, California, 1988. The
South Bay Asbestos Site Remedial Investigation Report has been
included in the Administrative Record for this Site.
When evaluating risk from asbestos in the environment, there are
sources of uncertainty associated with asbestos measurement that
make quantifying, the risk difficult- One of these sources of un-
certainty is the difficulty of obtaining accurate and precise
measurements of asbestos concentrations in soil, air, and water.
For example, all risk assessments require an accurate and precise
measurement of contaminant concentration. When a gaseous or
soluble chemical is the contaminant of concern, the measurement
of only one parameter, concentration, is sufficient to establish
how much of that contaminant is present in a given sample.
However it is infinitely more complex to measure the concentra-
tion of oarticulates accurately and precisely, especially fibrous
particulates, because many more parameters must be accounted for.
When measuring spherical particles the following parameters must
be measured: i) the overall particle size distribution; ii) the
concentration of each individual size category; and iii) the
change in concentration of each size category in different parts
of a dust cloud. When measuring fibrous particulates such as as-
bestos, the parameters become exponentially more complex. The
length and diameter of each particle must be measured along with
the distribution of complex shapes (such as bundles, clusters and
matrices). The concentration of each different shape must be es-
tablished, along with the settling velocity of different fiber
shapes. Finally, there is a human component to asbestos
analysis. Because all of the sampling methods for asbestos in-
volve an individual, using an optical or electron microscope,
identifying and counting miniscule asbestos fibers, the relative
experience and fatigue of the person doing the counting can in-
fluence the ultimate accuracy and precision of a given analysis.
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Many of the epidemiological studies which established the link
between the inhalation of asbestos and cancer used phase contrast
microscopy ("PCM") techniques to measure asbestos concentration.
However, PCM is considered inadequate for the analysis of a short
fiber mineral such as chrysotile. Many of these studies were
done before transmission electron microscopy ("TEM") techniques
were available. Most studies today use TEM as the "state of the
art" analytical technique for measuring airborne asbestos con-
centrations. In the City of Coalinga, the ambient air samples
were measured using TEM while the soil samples were measure using
polarized light microscopy ("PLM"). Limited TEM analyses of the
soils samples were used for confirmation. To use TEM data in
quantitative risk assessments, one must convert TEM data to PCM
Equivalent ("PCME") data using a conversion factor. There are a
variety of ways to perform this conversion; whenever conversions
of this type are done, the ability to describe risks quantita-
tively with accuracy is diminished. The Agency must make risk
management decisions despite the fact that the science of risk
assessment and techniques for measuring asbestos concentrations
continue to evolve.
EPA has determined that, because asbestos is a known human car-
cinogen with no acceptable known threshold level for environmen-
tal exposure, and the potential for release of asbestos from the
Site is high, a significant health risk exists. While a quan-
titative risk assessment is not possible because of the analyti-
cal problems associated with the measurement of asbestos, a
clean-up goal of less than or equal to 1 area percent by PLM is
consistent with CERCLA's requirements and with past Agency deci-
sions regarding asbestos clean-up levels at other Superfund
sites. See Appendix 1 for further discussion of this clean-up
level. The adverse human health effects from exposure to asbes-
tos are extremely serious. Therefore, remedial action is war-
ranted to mitigate the exposure to a carcinogen that is present
as a result of human activity.
8.0 DESCRIPTION OF ALTERNATIVES
EPA evaluated potential remedial action alternatives for the City
of Coalinga Operable Unit in accordance with CERCLA Section 121,
the National Contingency Plan ("NCP"), (in particular, 40 C.F.R.
Section 300.68), and the Interim Guidance on Superfund Selection
of Remedy. December 24, 1986 (OSWER Directive No. 9355.0-19).
The first step in evaluating potential remedial action alterna-
tives was to determine, based upon Site characteristics, what set
of response actions and associated technologies would be con-
sidered for the Site from among all possible alternatives. An
example of this preliminary determination (or "scoping") was the
elimination of biological treatment from further consideration
because biological processes capable of detoxifying asbestos con-
taminated soil do not exist. Section 2.1 of the OUFS discusses
the scoping process in more detail.
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10
The next step in the selection of remedy process was assembling
the remaining technologies and/or disposal options into general
remedial action alternatives. Pursuant to OSWER Directive No.
9355.0-19, remedial action alternatives are to be developed rang-
ing from those that would eliminate the need for long-term
management (including monitoring) at the Site to alternatives in-
volving treatment that would permanently reduce the mobility,
toxicity or volume of the hazardous substances(s) as their prin-
cipal element. In addition, containment options involving little
or no treatment and a no action alternative are to be developed.
The remedial action alternatives developed in the OUFS were:
— No Action
— Fencing of the Contaminated Areas
'-- Capping
a) Soil
b) Asphalt
c) Soil-Cement
d) Gunite
e) Multi-Layer
— On-Site Disposal
— Treatment by Chemical Fixation
a) Plant Processing
b) Area Mixing
— Thermal Vitrification
— Removal and Off-Site Disposal
The No Action alternative serves as'a basis for comparison in
analysis of the other remedial action alternatives under con-
sideration. Fencing of the contaminated area is an access
restriction alternative involving no treatment. Capping would re-
quire long term management. On-site disposal would reduce the
need for long tern Management at the Site. Off-site disposal
would eliminate the need for long term management and monitoring
at the Site (although monitoring and long term management would
be required at the off-site disposal site). Chemical Fixation
and Thermal Vitrification involve treatment as their principal
element.
After the initial screening, the most promising of these alterna-
tives were analyzed in greater detail in Section 2.1.2 of the
OUFS. The five remedial alternatives that were fully analyzed
are described in the following paragraphs:
Alternative 1; No action
This action would involve no action to treat, contain, or remove
contaminated soil, equipment, or structures. Multimedia monitor-
ing would be performed at a minimum of every five years to aid in
a reassessment of the no action alternative.
Alternative 2; Off—Site Disposal at a Mine Site Near Coalinoa
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11
This alternative would involve decontamination of the buildings
and disposal of all asbestos ore wastes and other mining wastes
at an abandoned mine near Coalinga.
Alternative 3; Covering Waste with One Foot of Asbestos-Free
Soil
This alternative would involve decontamination of the buildings,
off-site disposal in an approved facility of waste mining
materials stored in the Marmac Warehouse, and covering all areas
of the Site that tested positive for asbestos ore waste with one
foot of asbestos-free soil.
Alternative 4; Off-site Disposal of Waste in an Approved
Landfill
This alternative would involve decontamination of the buildings,
and disposal of all asbestos ore wastes and other mining material
at an approved off-site landfill.
Alternative 5; Construction of an On-Site Waste Management Unit
This alternative would involve decontamination of the buildings,
and construction of an on-site waste management unit ("WMU"). All
asbestos ore wastes and other mining material would be collected
and disposed of in the WMU. The material in the WMU would be
capped in accordance with the California Administrative Code,
Title 23, Chapter 3, subchapter 15. The conceptual design of the
WMU is included in the Design Report, found in the Administrative
Record (Doc. I 624).
9.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides an explanation of the criteria used to
select the remedy, and an analysis of the five remedial action
alternatives in light of those criteria, highlighting the ad-
vantages and disadvantages of each of the alternatives.
Criteria
The alternatives were evaluated based on the nine key criteria
which directly relate, to the factors that CERCLA Section
121(b)((1)(A-G) mandates that the Agency assess in selecting a
remedy. These criteria are:
(1) overall protection of human health and the
environment,
(2) short term effectiveness in protecting human
health and the environment,
(3) long-term effectiveness and permanence in
protecting human health and the environment,
(4) compliance with ARARs (ARARs are detailed in Section
10.0),
(5) Use of treatment to achieve a reduction in the
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12
toxicity,mobility or volume of the contaminants
(6) implementability,
(7) state acceptance,
(8) community acceptance, and
(9) cost.
Because there is no feasible treatment technology for asbestos
containing mining materials, criterion number five is not
directly relevant to a choice among alternatives. However, the
alternatives were compared with respect to their ability to mini-
mize the mobility (through the air or ground water pathways) of
the asbestos-containing material. Criterion number six, im-
plementability, is also not a factor in choosing among alterna-
tives. Implementability is the technical and administrative
feasibility of a remedy as well as the availability of services
and materials to carry out the remedy. All five alternatives are
equally implementable. For these reasons, neither of these
criteria are included in the following comparison of alterna-
tives.
Alternative 1 - No action Alternative
This alternative vould not reduce present or future exposure to
hazardous substances at the Site, and thus would not be protec-
tive of human health and the environment. The risk to human
health and the environment vould not be addressed. Although this
is the least expensive alternative, it would not achieve com-
pliance with ARARs and would not provide a permanent solution.
Alternative 2 - Removal of Wastes to the Mine Bites
The environmental and public health protection provided by this
alternative is better than the no action alternative but less
than alternatives four or five. Environmental degradation is ex-
pected to increase over time. Increased exposure to the con-
taminants would occur during implementation; engineering controls
would be implemented during the collection of contaminated soils
that would minimize this potential for exposure. Transportation
and off-loading operations at the abandoned mine site would
result in additional exposure as compared to on-site disposal.
The lengthy amount of time needed to implement this alternative
would also result to increased risk because of the period of no
action at the Site. Contrary to the OUFS' conclusion that this
alternative would satisfy all ARARs, this alternative would not
meet the requirements of California Administrative Code, Title 22
with respect to Class B Mining Wastes); it would also not meet
the NESHAP requirements at 40 C.F.R. § 61.153. This alternative
is expected to meet with community approval based on the
community's express desire to have the wastes removed from the
City. State perception of this alternative is expected to be
negative.
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13
The cost of this alternative is extremely high. Costs would in-
clude the extension and/or repair of roads and utilities to the
chosen mine site. The cost for this alternative is estimated at
$7 to $9 million and is the highest of all alternatives con-
sidered. The schedule to implement this alternative is estimated
at one to two years due to the need for road construction.
The human health risk during implementation of this alternative
would be moderately high. As in alternative 2, engineering con-
trols would be implemented that would minimize the exposure
during movement of mining wastes. Long term protectiveness of
human health and the environment would be less than that achieved
with alternatives 2, 4 or 5 because the asbestos ore waste would
remain under the clean soil cover and could be disturbed by human
activity or natural processes, such as an earthquake.
This alternative would meet federal ARARs for the disposal of as-
bestos waste but would not meet State ARARs for disposal of a
class B mining waste. The Site would require long term operation
and maintenance of a more significant nature than that required
by any of the other alternatives. This alternative includes
leaving hazardous material on-site. Therefore, review of the
remedial action at five year intervals would be required pursuant
to CERCLA Section 121(c), 42 U.S.C. § 9621(c). Also, deed
restrictions would be placed on a large portion of Coalinga, thus
limiting future land use.
Alternative 3 is the least costly of the alternatives which
provide active remediation. The estimated cost is between
$600,000.00 and $800,000.00. Alternative 3 could be implemented
in approximately four months. This alternative would negatively
impact the future development in Coalinga and would leave a high
public health risk in the town.
Alternative 4 - Removal of Waste to an Off-Site Landfill
This alternative would provide adequate protection of human
health and the environment. Short term risk to human health and
the environment would be moderate and would occur during the on-
site operations, transport of the contaminated material, and
placement in the new disposal location. During these operations,
engineering controls would be implemented to minimize this risk.
This alternative would achieve compliance with all ARARs. This
alternative received favorable consideration by the community.
State perception of this alternative is expected to be negative
because valuable landfill space would be occupied.
The cost of this alternative would be high. The estimated cost
is $5.5 million, with the majority of this cost being the cost of
disposing of the material in the off-site landfill. This alter-
native could be implemented in four to six months.
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14
Alternative 5 - Disposal of Material in an On-8ita Landfill
This alternative would provide adequate protection of human
health and the environment. Exposure would occur during movement
of the wastes on-site. The short term risk to public health and
the environment from this exposure route is less than that ex-
pected with Alternative 4, because contaminated materials will be
transported a shorter distance (to the WMU site). Engineering
controls would be implemented to minimize any short term risk.
This alternative would achieve compliance with all ARARs. Long
term operation and maintenance would be required, as would a
review at five year intervals pursuant to CERCLA Section 121(c),
42 U.S.C. § 9621(c).
This alternative raised community concerns over the location and
visual impact of the WMU. To alleviate these concerns, EPA will
require modification of the WMU specifications to reduce the
height of the WMU crown to as close to grade level as is techni-
cally feasible.
The cost for this alternative is approximately $1.5 to 2.5 mil-
lion. This alternative could be implemented in approximately
four to six months.
Further Discussion of Specific Criteria
The following discussion provides a more-detailed analysis of
several of the comparative aspects of the five alternatives.
Overall Protection of Human Health and the Environment
Alternatives 4 and 5 provide the most protection of human health
and the environment of all the alternatives. Alternatives 4 and
5 are essentially equal in their overall protection of human
health and the environment, except that alternative 4 involves
somewhat greater exposure during implementation. While there is
no feasible treatment technology for asbestos-containing mining
materials, alternatives 4 and 5 reduce mobility of asbestos
fibers by eliminating entrainment into the air of asbestos laden
soils and dust. Alternatives 2 and 3 are not as protective of
human health and the environment in that environmental degrada-
tion may increase over time. Alternative 2 would remove the
threat to Coalinga in the short term, but would exacerbate the
overall regional public health and environmental risks because
the mine site would receive uncontained mining waste piles. Al-
ternative 3 would leave areas containing asbestos-contaminated
soils more readily subject to disturbance by human activities as
well as natural disasters (such as an earthquake). Alternative 1
provides no protection to human health or the environment.
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15
Compliance with ARARS
Alternatives 4 and 5 would achieve compliance with ARARs. Alter-
natives 2 and 3 would violate the State of California ARARs for
disposal of a class B mining waste; Alternative 2 would violate
the NESHAP ARAR found at 40 C.F.R. § 61.153.
Long-term Effectiveness and Permanence
Alternatives 4 and 5 have the greatest ability to maintain reli-
able protection of human health and the environment over time,
once clean-up goals have been met. The disposal of the asbestos
ore wastes and other mining waste materials in an approved
landfill or waste management unit is the best way to ensure that
asbestos fibers are not released into the air, ground water or
surface water pathways. Alternative 5 will achieve long-term ef-
fectiveness and permanence as long as the cap integrity is main-
tained.
Alternative 2 would not be as effective as alternatives 4 and 5
in the long term because, in moving the material from a populated
area to a more remote area, future releases of the material from
the remote area are not mitigated. The long term effectiveness
of alternative 3 is less than that of alternatives 2, 4 and 5 be-
cause human activity or a natural disaster could more easily dis-
turb the material.
Short Term Effectiveness
Alternative 1, No Action, would have the least short term impact
because it would not generate additional dust or impact on com-
munity life, provided access to the Site was restricted. Alter-
native 3 will generate less dust than Alternatives 2, 4 and 5 be-
cause the consolidation and removal in Alternative 3 would be
restricted to the Marmac Warehouse. Alternative 2 and 4 will be
less effective in the short term than Alternatives 3 and 5 be-
cause the transportation and off-loading operations at the off-
site locations could have an adverse impact on the health of site
personnel. Alternatives 2, 3 and 4 will disrupt traffic to some
extent because they involve trucking the waste material off-site.
Alternative 5 will have somewhat less impact on traffic in
Coalinga. All of the alternatives, other than No Action, will
create some-noise during removal and construction which may be
bothersome in the short term.
Community Acceptance
The community would like the clean-up to proceed as quickly as
possible and would like the contaminants to be removed from the
Coalinga city limits. Alternative 4 received the most community
acceptance.
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16
With respect to Alternative 5, community members expressed con-
cern over the location of a WMU within the city limits, par-
ticularly if the WMU is not at or close to ground level. The
Coalinga City Council expressed concern over the technical suf-
ficiency of the WMU design. The City Council also prefers the
location of the WMU to be within the right-of-way of a future
road. EPA and State officials re-examined the WMU proposal in
light of these concerns and decided to alter the design
specifications for the WMU to require that the cap be as close to
ground level as is technically feasible. This was done in order
to minimize potential impacts on local development plans. The
re-examination also confirmed that the WMU meets all regulatory
specifications. The WMU is located in an area identified as a
future right-of-way; however, the boundaries of the WMU would ex-
tend beyond the width of the right-of-way as currently designed.
EPA is not requiring that the WMU be designed to conform to cur-
rent right-of-way plans; however, EPA is not putting restrictions
on land use in the WMU area that would preclude the area being
used as a road or a parking structure.
The community is not in favor of Alternative 3 because it would
remove too much land from future development. Community accept-
ance of Alternative 2 is expected to be favorable based on the
community's express desire to have the hazardous substances
removed from the City.
The attached Responsiveness Summary attached addresses more
specific concerns raised by members of the public during the
public comment period.
10.0 APPLICABLE or RELEVANT and APPROPRIATE REQUIREMENTS (ARARsl
Under Section 121(d)(l) of CERCLA, 42 U.S.C. § (d)(l), remedial
actions must attain a degree of clean-up which assures protection
of human health and the environment. Additionally, remedial ac-
tions that leave.any hazardous substance, pollutant, or con-
taminant on-site must meet a level or standard of control that at
least attains standards, requirements, limitations, or criteria
that are "applicable or relevant and appropriate" under the cir-
cumstances of the release. These requirements, known as "ARARs",
may be waived in certain instances, as stated in Section
121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
"Applicable" requirements are those clean-up standards, stan-
dards of control and other substantive environmental protection
requirements, criteria, or limitations promulgated under federal
or state law that specifically address a hazardous substance,
pollutant or contaminant, remedial action, location, or other
circumstance at a CERCLA site. "Relevant and appropriate" re-
quirements are clean-up standards, standards of control and other
substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law that, while
not "applicable" to a hazardous substance, pollutant, con-
taminant, remedial action, location, or other circumstance at a
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17
CERCLA site, address problems or situations sufficiently similar
to those encountered at the CERCLA site that their use is well-
suited to the particular site. For example, requirements may be
relevant and appropriate if they would be "applicable11 but for
jurisdictional restrictions associated with the requirement. See
the National Contingency Plan, 40 C.F.R. Section 300.6, 1986).
The determination of which requirements are "relevant and ap-
propriate" is somewhat flexible. EPA and the State may look to
the type of remedial actions contemplated, the hazardous sub-
stances present, the waste characteristics, the physical charac-
teristics of the site, and other appropriate factors. It is pos-
sible for only part of a requirement to be considered relevant
and appropriate. Additionally, only substantive requirements
need be followed. If no ARAR covers a particular situation, or
if an ARAR is not sufficient to protect human health or the en-
vironment, then non-promulgated standards, criteria, guidance,
and advisories must be used to provide a protective remedy.
Types of ARARs
There are three types of ARARs. The first type includes
"contaminant specific" requirements. These ARARs set limits on
concentrations of specific hazardous substance, pollutants, and
contaminants in the environment. Examples of this type of ARAR
are ambient water quality criteria and drinking water standards.
The second type of ARAR includes location-specific requirements
that set restrictions on certain types of activities based on
site characteristics. These include restriction on activities in
wetlands, floodplains, and historic sites. The third type of
ARAR includes action-specific requirements. These are
technology-based restrictions which are triggered by the type of
action under consideration. Examples of action-specific ARARs
are Resource Conservation and Recovery Act ("RCRA") regulations
for waste treatment, storage, and disposal.
ARAB; Identification Process
ARARs must be identified on a site-specific basis from informa-
tion about specific chemicals at the site, specific features of
the site location, and actions that are being considered as
remedies.
ARARs identified for the Operable Unit address emission of asbes-
tos fibers from contaminated soils, inhalation of asbestos
fibers, and disposal of asbestos contaminated soils. In addi-
tion, ARARs for disposal of mining waste containing soluble
nickel were also identified.
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18
Contaminant-Specific ARARs For Asbestos;
1. Toxic Substances Control Act fTSCA)
EPA has promulgated several rules under TSCA to regulate asbestos
in the environment. The most significant of these were promul-
gated pursuant to the Asbestos Hazard Emergency Response Act
("AHERA"), which was enacted as Title II of TSCA. Under the
AHERA, EPA issued regulations related to the inspection and
management of friable asbestos in schools (52 C.F.R. § 42826
(1987)). This regulation utilizes PUf as a measurement technique
for detecting asbestos; the use of this measurement technique for
asbestos is relevant and appropriate to the cleanup of the
Coalinga Site.
2. Clean Air Act. National Emission Standard for Hazardous Air
Pollutants fNESHAPsl
Asbestos was first designated as a hazardous air pollutant under
the Clean Air Act in 1971. The National Emission Standard for
Hazardous Air Pollutants ("NESHAPs") for asbestos found at 40
C.F.R. §61.152 and 40 C.F.R. § 61.156 are ARARs for the im-
plementation of the remedy at this Site. 40 C.F.R. § 61.153 is
an ARAR for the completion of the remedy at the Site.
Location-Specific ARARs:
Because the Site is located in an area that contains endangered
species (i.e., the kit fox and the blunt-nosed leopard lizard),
the following requirements are ARARs for the Site:
1. The Endangered Species Act of 1973. 16 U.S.C. S 1536falf-fd^
Generally, when a project potentially impacts an endangered
species or critical habitat, activities carried out by Federal
agencies should not jeopardize the continued existence of an en-
dangered species or cause adverse modifications of critical
habitat.
2. USFWS Mitigation Policy TFR 7644-7663. Vol 46. No. 15. January
19811.
This policy is triggered in accordance with the Fish and Wildlife
Act of 1956, Fish and Wildlife Coordination Act, Watershed
Protection and Flood Prevention Act and the National Environmen-
tal Policy Act. The mitigation policy defines resource
categories and establishes mitigation goals and guidelines for
each. Guidelines to achieve the goal include avoiding or mini-
mizing habitat loss, immediate rectification or reduction of
habitat loss or replacement of habitat in kind.
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19
Action Specific ARARs;
1. Occupational Safety and Health Administration f"OSHA")
OSHA has set a permissible exposure limit ("PEL") for all asbes-
tos fibers at 0.2 fiber per cc for occupationally exposed workers
(51 C.F.R. § 22612 (1986)). While this standard was meant for
occupational exposure (8 hours per day, 40 hours per week, 52
weeks per year) and not for continuous ambient exposure, it
provides an upper threshold for evaluating permissible ambient
exposure limits. In other words, a concentration of .2 PCM
fibers per cc of respirable air or less is not permissible for
ambient exposure, since this requirement is relevant and ap-
propriate for exposure during the cleanup of this Site.
Contaminant—Specific ARARS for Soluble Heavy Metals;
1. California Administrative Code. Title 22
Title 22, Chapter 30, Section 66740 (a) of the California Ad-
ministrative Code lists "...wastes which shall be classifiable as
special wastes pursuant to Section 66744 provided they meet the
criteria and requirements of Section 66742". The California
State Water Quality Control Board ("SWQCB") has classified
nickel-containing wastes such as those at the Site as Class B
mining wastes, as described in Title 23, Chapter 3, subchapter
15, Section 2571(b)(2). Under California regulations (Title 23,
Subchapter 15) a Class B mining waste must be disposed of in a
capped landfill. This requirement is an ARAR for the Site.
Location Specific ARARs for Soluble Heavy Metals;
1. California Administrative Code
Pursuant to Title 23, Chapter 3, Subchapter 15, Article 7, Sec-
tion 2570(b), a mining waste pile, including a waste management
unit, may be exempted from the liners and leachate collection and
removal system requirements of Article 7, Section 2572, if it can
be demonstrated that leachate will not form in or escape from the
waste management unit ("WMU"). Section 2570(c) allows the RWQCB
to exempt a Group B mining waste management unit from these liner
and leachate requirements of Article 7 if a comprehensive
hydrogeologic'investigation demonstrates that:
" (1) there are only very minor amounts of groundwater underly-
ing the area; or
(2) the discharge is in compliance with the applicable water
quality control plan; and
(3) either natural conditions or containment structures will
prevent lateral hydraulic interconnection with natural geologic
materials containing ground water suitable for agricultural,
domestic or municipal beneficial uses. There is no detectable
vertical hydraulic interconnection between the natural geologic
materials underlying the unit and natural geologic materials con-
taining such ground water." Article 7, Section 2570(c).
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20
The WMU for this site is appropriately exempted from these liner
and leachate provisions on the basis that the requirements of Ar-
ticle 1, Section 2570 (c)(l), and alternatively, the requirements
of (2) and (3) / are met. See the memorandum from the California
Central Valley Regional Water Quality Control Board ("CVRWQCB") ,
dated April 7 , 1989, Administrative Record Doc. I 1075, attached
as Appendix 2 to this ROD, and hereby incorporated by reference.
The requirements of this Appendix 2 must be met for full im-
plementation of this ROD.
The Class B mining waste regulations found at Title 23, Chapter
3, Subchapter 15, Section 2571, (b) (2) (A) of the California Ad-
ministrative Code are satisfied by either (1) removal of the as-
bestos ore waste and other mining waste to a capped landfill or
(2) burial of the asbestos ore waste and other mining waste in an
on-site WMU. Cap requirements are outlined in Title 23, Chapter
3, Subchapter 15. If the waste is stored in an on-site WMU, the
regulations require that a groundwater monitoring be located at
the point (s) of compliance. Title 23, Chapter 3, Subchapter 15,
Section 2553.
11.0 Tflfli! gFjHjg'PSD REMEDY
Alternative 5, disposal of the asbestos ore waste and other min-
ing waste in an on-site waste management unit ("WMU"), is the
selected remedy for the City of Coalinga Operable Unit. This in-
cludes collection and on-site disposal of all asbestos ore waste
and other mining waste material as well as decontamination of all
buildings, structures and other equipment at the Site. The ex-
cavated areas will be regraded with clean material, containing
less than or equal to one area percent asbestos by PLM. The WMU
will be constructed in accordance with California Administrative
Code, Title 23, Chapter 3, Subchapter 15; the WMU is exempt from
the liner and leachate collection requirements of Article 7 of
this Subchapter. - - — --• ......... ..... •..„ ......... -,,,...
The wastes are asbestos with some soluble nickel. Asbestos is
insoluble and thus poses does not pose a significant threat to
the groundwater. Any leachate movement through the unsaturated
zone to the ground water will be very slow and is unlikely to
carry asbestos in suspension. The waste does not generate acid
and therefore leachate containing soluble nickel is not likely to
be produced. In addition, the ground water in the Coalinga area
is not potable. All of the drinking water used by the City of
Coalinga is taken from the California Aqueduct.
All contaminated soils and other similar materials will be
cleaned up to less than or equal to one area percent asbestos by
PLM and to at or below background for nickel. A positive cor-
relation between the presence of asbestos and nickel has been es-
tablished at the Site. As the asbestos-contaminated areas are
being remediated, the nickel-contaminated areas will also be
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21
remediated. The contaminated soils and other materials occupy an
area of approximately 11 acres and total approximately 14,500
cubic yards.
A major feature of the selected remedy is the construction of the
WMU. The WMU will measure approximately 225 feet square, have a
capacity of 25,000 cubic yards and will be designed and con-
structed to comply with all ARARs. The final cover or cap will
consist of the following (from bottom to top):
— A two foot foundation layer of compacted clean material
that contains less than or equal to 1 area percent asbestos by
PLM.
— A one quarter inch impermeable bentonite mat with a per-
meability of less than 10 E -6 cm/sec.
— A protective soil cover that contains less than or equal
to one area percent asbestos by PLM and is at least one foot in
thickness.
— Either a four inch asphalt concrete paving or a
vegetated cover.
The design will include two neutron probe access tubes to detect
increases in moisture content due to leachate migration. In ad-
dition, ground water monitoring well(s) will be required within
one quarter mile of the perimeter of the WMU.
The WMU will be constructed to prevent the ponding of water on
the cap. The cap will be situated as close to grade level as is
feasible. Strict asbestos/dust control measures will be imple-
mented during the entire construction of the WMU and the collec-
tion and consolidation of the asbestos ore waste and other mining
material. These activities will comply with the NESHAPs ARARs.
In addition, ambient air sampling (with associated meteorological
monitoring) and personnel monitoring will be conducted during
construction and removal activities to fulfill the following ob-
jectives:
1) Ensure that asbestos/dust control measures are effective
in containing fugitive contaminant emissions,
2) Ensure that the remedial activity is not affecting the
surrounding community through the spread of fugitive asbestos
fibers, and
3) Document exposure levels of site personnel work ac-
tivities to determine compliance with appropriate levels of
protection for workers.
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22
A verification sampling plan will be instituted to confirm that
the cleanup levels have been achieved for the soil and other
materials. The building structures will also be sampled to
verify removal of asbestos from contaminated surfaces.
Operation and maintenance activities will be required to ensure
the effectiveness of the WMU. These activities include: (1)
quarterly visual inspections to ensure the integrity of the cap
for three years, with annual visual inspections thereafter, (2)
any repair work necessary to maintain the integrity of the cap,
including maintenance of the vegetation, (3) groundvater monitor-
ing, and (4) monitoring of soil moisture content using neutron
probes. EPA will review the remedial actions effectiveness at
five year intervals, pursuant to CERCLA Section 121(c), 42 U.S.C.
S 9621(c).
The chromite ore waste ("chromite waste") in the Marmac Warehouse
will be disposed of in the WMU unless the chromite waste has been
removed from the site by October 16, 1989, pursuant to an EPA ap-
proved plan. Any draft plan for removal and disposition of the
chromite waste must be submitted to EPA by August 15, 1989 and
must include:
1. an adequate health and safety plan that protects on-site
personnel;
2. a work plan that provides for the safe removal of the
chromite waste material from the Marmac Warehouse and transport
to a bona fide recycling/reprocessing facility for recycling
and/or reprocessing;
3. adequate documentation from a bona fide
recycler/reprocessor that the chromite waste will be handled
properly upon receipt at the recycling/reprocessing facility.
This documentation must include, but is not limited to: a) copies
of all necessary permits, b) details of process to be used to ex-
tract the chromium, and c) details of how any asbestos-
contaminated residue will be disposed of; and
4. Provisions for compliance with all applicable laws _
regarding transport of hazardous substances
A final plan must have received EPA approval by September 15,
1989. . .
The WMU design and associated monitoring activities will be in
accordance with the recommendations provided in the CVRWQCB
memorandum of April 7, 1989, attached as appendix 2. In
addition, a geologist registered by the State of California
will observe the excavation of the WMU area to ensure that no
geologic faults occur in the area of the WMU.
Using a conservative estimate of $2.5 million, the cost for dis-
posal in the WMU is estimated at $170 per cubic yard, assuming
14,500 cubic yards of contaminated material. Operation and
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23
maintenance costs are estimated at $35, 000/year. Total present
worth cost for the selected alternative is between 1.5 and 2.5
million dollars.
12.0 DOCUMENTATION of SIGNIFICANT CHANGES
The selected alternative for the Site is construction of an on-
site WMU and accompanying measures, as detailed in Section 11.0,
above. At this time no significant changes from the proposed
plan have occurred.
13.0 STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
minimizing exposure to asbestos- and nickel -contaminated
materials. The selected remedy also provides for clean-up to the
AHERA levels for asbestos abatement and to levels at or below
background levels for nickel. Proper operation and maintenance
practices will ensure the integrity of the WMU. Strict dust con-
trol procedures will be followed during construction. Proper
health and safety measures, including ambient air monitoring and
personnel monitoring during implementation, will ensure that the
health of on-site workers and the local population is protected.
Cost-Effectiveness
The selected remedy is cost-effective in that it provides overall
effectiveness commensurate to its costs. The estimated costs of
the selected remedy are less than half the costs associated with
the removal of the waste to an off -site landfill (Alternative 4) ,
and yet the selected remedy and Alternative 4 are similar in
terms of the level of public health and environmental protection
provided, except that off -site disposal would involve somewhat
greater exposure risk during implementation.
Compliance with ARARs
The selected remedy will comply with all ARARs. Identified ARARs
are presented below.
Action-specific ARARs
OSHA requirements for permissible exposure limit (PEL) in 51
C.F.R. 22612 (1986), which specify a PEL for all asbestos
fibers at 0.2 fibers per cubic centimeter for occupationally
exposed workers.
Contaminant-specific ARARs
PLM measurement technique for asbestos, pursuant to AHERA
regulations.
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24
NESHAP requirements found at in 40 C.F.R. § 61.152, 40
C.F.R. § 61.153, and 40 C.F.R.
§ 61.156.
Title 22, Chapter 30, Section 66740(a) of the California
Administrative Code, which classifies the nickel-bearing
waste as a special waste.
Title 23, Chapter 3, Subchapter 15, Article 7, Section
2571(b)(2), which classifies the waste as a class B min-
ing waste. Under Subchapter 15, class B mining wastes
must be disposed of in a capped landfill. The WMU is
exempt (pursuant to Section 2570) from the liner and
leachate requirements found in Article 7 of this Sub-
chapter.
Location-specific ARARs
Endangered Species Act of 1973, 16 U.S.C. § 1536 4(a) -
(d), regarding endangered species and critical habitat.
USFWS Mitigation Policy establishes guidelines for mini-
mizing habitat loss (FR 7644-7663 Volume 46 number 15
January 1981).
Utilization of Permanent Solutions to the Maximum Extent Prac-
ticable
Currently there is no known permanent treatment or resource tech-
nology which would control release of asbestos from the soil at
the Site. Chemical fixation and thermal vitrification were al-
ternatives identified in the Feasibility Study but they were
eliminated from further consideration due to difficulties as-
sociated with implementation, uncertain long term effectiveness
and very high cost. Of those alternatives that are protective of
human health and the environment and comply with ARARs, EPA has
determined, and the State has concurred, that the selected remedy
provides the best balance of the various factors that CERCLA re-
quires be considered in remedy selection.
The selected remedy is preferable to off-site disposal with
respect to short term effectiveness and cost. Since the selected
remedy and the off-site disposal alternative are reasonably com-
parable with respect to protection of public health and the en-
vironment, long term effectiveness, ARARs compliance, and im-
plementability, the major tradeoffs that provide a basis for this
selection decision are short term effectiveness, community ac-
ceptance, state acceptance, and cost. The selected remedy has
better short term effectiveness, is more acceptable to the state,
and can be performed at less cost than the other alternatives; it
also can be performed in a relatively short time frame compared
to some of the alternatives. It is therefore determined to be
the most appropriate solution for the contaminated soils at the
City of Coalinga Operable Unit.
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25
Preference for Treatment as a Principal Element
Currently there is no proven treatment technology that would per-
manently and significantly reduce the mobility, toxicity or
volume of asbestos. Since no effective treatment method exists
for asbestos, the statutory preference for this type of treatment
as a principle element of the remedy cannot be satisfied. Al-
though several treatment technologies were investigated during
the feasibility study, it was determined that no technology
presently exists that would result in a permanent and significant
decrease in the toxicity, mobility or volume of asbestos. Alter-
native 5 was found to represent the best method for addressing
the threats posed by the Site, talcing into account all of the
statutory requirements and preferences.
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CITY OF COALINGA
ADMINISTRATIVE RECORD INDEX
•
This index is arranged using the following subject categories.
Within each category the documents are arranged by the document
number found in the Index.
01.
0100.15
0100.20
0100.25
05.
0500.01
0500.10
0500.20
0500.25
0500.30
14.
1401.01
1401.05
1401.15
1401.20
1401.25
1401.30
1401.35
1401.40
1401.45
1401.50
1401.52
1401.55
1401.57
1401.60
70.
7000.01
7000.15
7000.20
7000.50
7500.00
80.
Site Identification
Background
Notification/Site Discovery
PA/SI (Preliminary Assessment/Site Investigation)
Reports
PRP (Potentially Responsible Party) Documents
Correspondence
Records of Communication
PRP-Generated Reports and Data
104(e) Letters
General Notice and Special Notice Letters
RI/FS (Remedial investigation/Feasibility Study)
Correspondence
Internal Memos
Work Plan
Sampling & Analysis Plan
Health and Safety Plan
Site Access Letters/Orders/Litigation
Compliance Monitoring and Enforcement
Sampling and Analysis Data
Data Validation Reports
RI/FS Reports
Comments on RI/FS Reports
Health BisJc/Endangerment Assessments
Environmental Studies
ARAR Information- —- •-
Community Involvement
Correspondence
Community Relations Plan (CRP)
Fact Sheets, Press Releases, Public Notices, Site
Histories
Relocation and Evacuation
Congressional Correspondence
FOIA (Freedom of Information Act) Requests and
Responses
8000.25 Exemption Claims
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DIRECTORY OF NAMES
NAME
James T. Allen
Bruce Angiolillo
Greg Baker
Lowell Baker
G. Dale Barnhill
A.R. Battennan
Robert K. Behrens
Richard E. Blubaugh
Phil Bobel
Randy BoItin
R.E. Bolton
Ronald Bowmann
Charles W. Bridges
Claude Bridges
Wayne Broome
Kevin Browne
Garry J. Burdett
Gary Carozza
Joseph P. Carullo
Chris Chalfan
Earl Chambers
E.J. Chatfield
John D. Clarke
Tony Coelho
David L. Coffin
Kathleen Conway
Philip M. Cook
Robert C. Cooper
Joseph Cotruvo
Frank M. Covington
Darrel S. Cowan
Floyd Crable (Crabell)
John E. Craighead
Greg Czajkowski
J. David Dean
Jennifer (Jenny) Decker
Michele Denner
John DeVaney
Kelley J. Donham
Steve Drew
A.J. Eyraud
Gary Fairbanks
Melanie Field
James Gideon
Rick Gooch
AFFILIATION
California Dept. of Health Services
Simpson, Thatcher & Bartlett
US Environmental Protection Agency
Westside Trucking Co.
International Technology Corp.
US Environmental Protection Agency
Law Offices of Mclnturff, Behrens &
Snyder
Atlas Minerals
US Environmental Protection Agency
McCrone Env. Serv.
Institute of Occupation Medicine
Union Carbide
Law Offices of Bridges & Bridges
California Minerals Corp.
Kern County Land Co.
Cape Industries Ltd.
Occupational Medicine & Hygiene
Laboratory
Fresno Dept. of Health Services
Santa re Energy Co.
California Regional Water Quality
Control Board - Central Valley
Region
Mannac Resources Co.
Ontario Research Foundation
Asbury Oil Co.
US House of Representatives
US Environmental Protection Agency
US Environmental Protection Agency
US Environmental Protection Agency
University of California, Berkeley
US Environmental Protection Agency
US Environmental Protection Agency
Stanford University
Mannac Resources Co.
University of Vermont
US Environmental Protection Agency
Woodward-Clyde
US Environmental Protection Agency
US Environmental Protection Agency
Atlas Asbestos
University of Iowa
US Environmental Protection Agency
Asbury Transportation Co.
PG&E
US Environmental Protection Agency
Engineering Control Technology
Branch, DPSE
Southern Pacific Transportation Co.
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Directory - Page 2
Michael R. Gray
Richard A. Griesemer
Konrad (Conrad) Harper
Donald Harvey
C.F. Harwood
Don Hawkins
Stephen B. Hayward
R. Nicholas Hazlewood
Edward Heine
Martha Hennly
Bruce A. Hollett
Dave Howe11
Larry Hunter
Scott Huntsman
Dan Button
Carla J. Irvine
Walter John
Eve Johnson
Richard Johnson
Sue Johnson
Jeanine Jones
Marty J. Kanarek
G.M. Kay
Sean Kennedy
Steve Kerdoon
Ronald D. Kill
Robert (Bob) King
Kent Kitchingman
John Kraemer
Donna LaBar
Myron Levin
Nancy Lindsay
Morton Lipman
David Long
Gail Louis „...
Jeffrey A. Lybarger
Kevin Maroff
Gary M. Marsh
Richard Martyn
Leland J. McCabe
Daniel McGovern
Michael J. McGuire
O.K. McNear
James R. Millette
L.L. Mitchell
Irving Moore
Kino Hospital
US Environmental Protection Agency
Atlas Asbestos
Woodward-Clyde
IIT Research Institute
Agency for Toxic Substances and
Disease Registry
California Dept. of Health Services
International Technology Corp.
Vinnell Mining & Milling Corp.
California Dept. of Health Services
US Dept. of Health & Human Services
Bureau of Land Management
Marmac Resources Co.
Woodward-Clyde
Camp Dresser & McKee
Shield & Smith
California Dept. of Health Services
Jacobs Engineering
California Bureau of Land
Management
Jacobs Engineering
California Dept. of Health Services
University of Wisconsin
Canada Ministry of the Environment
Ecology & Environment
Asbnry Oil Co.
13S Environmental Protection Agency
City of Coalinga
US Environmental Protection Agency
PG&E
CH2M Hill
LA Times
US Environmental Protection Agency
New York University
Southern Pacific Transportation Co.
US Environmental Protection Agency
Agency for Toxic Substances and
Disease Registry
Southern Pacific Transportation Co.
University of Pittsburgh
US Environmental Protection Agency
US Environmental Protection Agency/
Health Effects Research Laboratory
US Environmental Protection Agency
Metropolitan Water District of
Southern California
Southern Pacific Transportation Co.
US Environmental Protection Agency/
Health Effects Research Laboratory
US General Services Administration
Wheeler Properties
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Ruben Moreno
Penelope Morton
Brooke T. Mossman
G.L. Murdoch
William J. Nicholson
George Nokes
David Noyes
Lalita D. Palekar
Kusum J. Patel-Manalik
L.w. (Wayne) Pepple
Bob Perkins
Kent E. Pinkerton
Thomas J. Powers
Dean Prettyman
Kenneth B. Prindie
Malcolm Ross
Lee Quick
Michael C. Richards
Charles E. Robinson
Dennis M. Robinson
George M.C. Robinson
Susan Robinson
D. Scott Rohlfs
T.C. (Thomas) Sager
Roland A. Sanford
Marvin A. Schneiderman
Eunice E. Sigurdson
Stewart Simpson
Bhawan Singh
David M. Smith
M.R. Smolen
David B. Stanton
Mearl F. Stanton
Eric B. Steele
Edward L. Strohbehn
David Suder
Keith TaJcata
Lee M. Thomas
V. Timbrell
Richard G. Tisch
P. Toft
Ida To1liver
Mark Unruh
Al Vargas
Richard B. Von Wald
Jon K. Wactor
Lonnie Wass
Geoff Watkins
Mr. Weavers
California Regional Water Quality
Control Board - Central Valley
Region
University of Minnesota
University of Vermont
Southern Pacific Transportaion Co.
City University of New York
California Fish & Game Commission
Johns-Manviiie Corporation
Northrup Services, Inc.
Technocrats Inc.
Southern Pacific Transportation Co.
RTI
Duke University
US Environmental Protection Agency
Asbury Transportation Company
Schell & Delamer
US Geological Survey
Interstate Towing Services
Camp Dresser & McKee
Lerine-Fricke
International Technology Corp.
Western Technologies Inc.
Federal Emergency Management System
City of Coalinga
Santa Fe Pacific Realty Corp.
Woodward-Clyde
Clement Associates
Minnesota Dept. of Health
US Environmental Protection Agency
Universite de Montreal
Los Alamos National Lab
Union Carbide
Tenneco West
California Dept. of Health Services
National Bureau of Standards
McCutcheon, Doyle, Brown & Enerson
Woodward-Clyde
US Environmental Protection Agency
OS Environmental Protection Agency
"Llandough Hospital
Union Carbide
Canadian Dept. of National Health
and Welfare
US Environmental Protection Agency
International Technology Corp.
Ecology & Environment
Johns-Manville Corporation
US Environmental Protection Agency
California Regional Water Quality
Control Board
Jacobs Engineering
Atlas Corporation
-------
Directory - Page 4
L.R. White Mobile Home Service
Bill Wick US Environmental Protection Agency
Robert D. Willey International Technology Corp.
John Wise US Environmental Protection Agency
Richard s. Woodhill Connecticut State Dept. of Health
Leonard 0. Yamamoto International Technology Corp.
Terry F. Yosie US Environmental Protection Agency
Jeff Zelikson us Environmental Protection Agency
Amy Zimpfer US Environmental Protection Agency
R.A. ZisJcind Science Applications, Inc.
Ralph D. Zumvalde California Dept. of Health Services
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
0100.15
0100.15
0100.15
1
Attas and Johns-Manville Coaling* Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT DESCRIPTION FROM TO
NUMBER SUBJECT
566 Review: Asbestos Exposure Morton Lippman
Indices
567 Asbestos Exposure Indices Morton Ltppnan
573 Long-term Health Effects on David N. Smith
DOCUMENT
DATE
7/18/87
2/88
10/28/86
Hamsters and Rats
0100.15 574 Health Effects of Asbestos
w/letter
Richard A. Criesemer Lee N. Thomas
7/30/85
0100.15 575 Update of SAB Activities
u/memo
Kathleen Conuay
Lee M. Thomas
6/12/85
0100.15 576 Major Issues Associated with
Health Effects of Asbestos
Science Advisory
Board
no date
0100.15 577 Semi-quantitative
Determination of Asbestiform
P.M. Cook
no date
0100.15 578
0100.15
0100.15
579
580
Inhalation of Fibrous Dust* V. Timbrel!
(Annals NYAS)
Reserve Mining £nd» Lake
Dumping
Asbestos in Drinking Water - A P. Toft
Canadian View
12/31/65
no date
no date
0100.15 581 Adverse Health Effects of
Arsenic and Asbestos
no date
0100.15 582 Environmental Effects of
Of<:road Vehicles
Robert H. Uebb
no date
0100.15 583 Asbestos: Properties,
Applications * Hazards, vol. 2
0100.15 584 In vitro Approaches for
Determining Mechanisms of
Toxicity
0100.15 585 Critical Review of
Epidemiologic Studies
S.S. Chissick
Brooke T. Mossman
Gary N. Marsh
no date
no date
10/13/82
-------
Page No.
02/28/89
Attas and Johns-Manvilie Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUHENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 586 Characteristic Values for
Asbestos
no date
0100.15 587 Electron Microscopy t X-ray
Applications: Chapter 11
0100.15 588 Membrane-filter
Direct-transfer Technique for
Analysis
0100.15 589 Asbestos in the Mom
Philip A. Russell
Garry J. Burdett
US Consumer Product
Safety Commission
no date
no date
no date
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
590
591
592
593
594
596
597
Asbestos Fact Book
Asbestos in Schools
Methodology for the Analysis
of Asbestos in Soils
Asbestos in Buildings
Asbestos in Drinking Water
Region 9 Asbestos News
Itr re: Asbestos Exposure at
Federal Building I Courthouse
EPA
Stephen B. Hayuard
EPA
Kevin Browne
EPA
Kenneth N. .... . L.L. Mitchell
Vallingford
5/86
no date
no date
7/85
no date
6/87
8/6/84
0100.15 599 ASTDR Policy on Health
• Assessments
5/87
0100.15 601 Superfund Public Health
Evaluation Manual
EPA
10/86
0100.15 602 EPA: National Revised Primary
Drinking Water Reg.
0100.15 627 Strategy for Asbestos Hazard
Identification
Federal Register,
vol. 48. no. 194
ICF/Clement
Associates
10/5/83
Camp Dresser t McKee 9/18/87
0100.15 628 Technical Support Doe: Public
Hearing to Consider the
Adoption of a Reg. Amend.
CA Air Resources
Board
2/10/86
-------
Page Ho.
02/28/89
Atlas and Johns-Manville Coating* Superfund Sites
City of Coatinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 629 Ambient Water Quality
Criteria; Asbestos
EPA
1978
0100.15 630 Interim Method for the
Determination of Asbestos In
Bulk Insulation Samples
0100.15 631 Federal Register v. 50, no.
219: Asbestos
UP EPA
12/82
11/13/85
0100.15 632 Mem re: mx for Asbestos in
Drinking Water
0100.15 633 Groundwater Newsletter v. 12,
no. 20 (Oct. 31, 1983)
M/letter
Frw* M. Covington
Ronald D. Kill
John Wise
Richard Martyn
11/15/83
12/1/83
0100.15 634 EPA: 40 CFff Pt. 61 National
Emission Standard* for
Hazardous Air Pollutants..
Final Rule
Federal Register,
vol. 49, no. 67
4/5/84
0100.15 635 Reports on Health Effects of
Asbestos M/letter
Joseph A. Cotruvo
Terry F. Vosie
4/22/85
0100.15 636 Technical Comments re: Health
Effects of Asbestos u/letter
Richard A. Griesener
Lee M. Thomas
7/30/85
0100.15 637 EPA Environmental News I Fact
Sheet on Asbestos
EPA
1/16/86
0100.15 638 EPA: 40 CFR Pt. 763: Asbestos,
Proposed Mining X Import
• Restrictions t Proposed
Manufacturing Importation t
Processing Prohibitions
Federal Register,
vol. 51, no. 19
1/29/86
0100.15 639 Asbestos Waste Management
Guidance
EPA
no date
0100.15 640 EPA: Water Quality Criteria
Documents. Availability
0100.15 665 Importance of Wind-blown Oust
in Risk Assessment
Federal Register,
vol. 45. no. 231
EPA
11/28/80
1/88
-------
Page No.
02/28/69
Atlas and Johns-HanviUe Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 666 Application of TEN to Ambient
Monitoring M/letter
Bruce A. Hollett
Melanie Field
2/1/88
0100.15 667 fP* Study of
Asbestos-containing Material*
EPA
2/88
0100.15 668 Taxi logical Profile for
Nickel. Draft
ATSDR
1/16/88
0100.15 669 Microscopical Innovations for
Asbestos Analysis
John Gustav Delly
4/87
0100.15 670 Asbestifor* Fibers:
Nonoccupatlonat Health Risks
0100.15 671 Asbestos in Buildings:
Technical Bulletin
National Research
Council
EPA
8/1/84
5/88
0100.15 672 Airborne Levels of Mineral
Fibre
William J. Nicholson
no date
0100.15 673 Environmental Asbestos:
Problems Associated with PIN
Soil Analysis
Jennifer A. Decker
no date
0100.15 708 Minerals and Health: The
Asbestoc Problem
Malcolm Ross
no date
0100.15
0100.15
709
710
Asbestos: Toward a Perspective H. Wesley Peirce
CooMercial Laboratories with
Polarized Li^it Microscope
Research Triangle
Institute
1985
8/87
0100.15 711 Ban of Consumer Patching
Compounds
0100.15 712 Chrysotile Asbestos in a
California Recreation Area
16 CFR Chapter 11
Science, vol. 206
1/1/85
11/9/79
0100.15 713 EPA: 40 CFR Pt 763:
Asbestos-containing Materials
in Schools, Final rule and
Notice
Federal Register,
vol. 52, no. 210
10/30/87
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
Atlas and Johns-ManvHte Coatinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 714 OSHA, 29CFR Pt. 1910 and 1926
Occupational Exposure to
Asbestos... Final Rules
0100.15 715 Asbestos in Water Supplies of
the U.S.
0100.15 716 Asbestos (OEM)
0100.15 717 Fact Sheet: Asbestos in
Drinking Water
0100.15 734 Ltr re: Occurrences of Special
Animals and Plants
0100.15 735 Map: California Natural
Diversity Data Base
0100.15 834 Properties of Fine Particles
Which Govern Their Biological
Activity
0100.15 835 Asbestos
0100.15 836 Ltr re: Comnents on Asbestos
Abatement Techniques
0100.15 837 Asbestos
0100.15 838 Filter Blank Contamination in
Asbestos Abatement
0100.15 839 Characterization of Three
Types of Chrysotile Asbestos
0100.15 840 Correlation of In Vitro And
Vivo Methods
0100.15 841 Asbestos Analysis Case History
0100.15 842 Asbestos Analysis Case History
0100.15 843 Asbestos Standards
Federal Register.
vol. 51, no. 119
James R. Nlllette
Pamela S. Zurer/CKN
Stephen (illegible)/
CA Dept. of Fish and
Game
CA Dept. of Fish and
Game
Penelope Morton
Bunker Hill SCR
Ralph 0. Zumualde
Thomas J. Powers
Kent E. Pinkerton
David L. Coffin
Michael J. McGuire
Michael J. NcGuire
National Bureau of
Standards
Donna La Bar
James Gideon
6/20/86
no date
3/4/85
3/1/83
11/8/83
10/83
1/85
no date
4/24/85
7/10/85
4/24/86
1983
1983
9/82
12/8/81
10/1/80
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
jx0100.15
0100.15
0100.15
0100.15-
0100.15
0100.15
0100.15
0100.15
0100.15
0100.15
6
DOCUMENT
NUMBER
844
845
846
847
848
849
850
851
852
- 855
854
855
856
857
858
859
Atlas and Johns-Manvi U« Coaling* Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Concentration i Size of
Asbestos in Water
Chrysotile Asbestos in •
California Recreational Area
Exposure to Asbestos fro*
Drinking Water in the U.S.
Decontaminating Lake Superior
of Asbestos Fibers
Symposium on Fugitive
Emissions
Experimental Determination of
the Nuifcer 1 Size of Asbestos
Fibers
Asbestiform Amphibote Minerals
Asbestos in Drinking Water
Serpentine Flows on Joaquin
Ridge
Miner*! 1 Water Resources of • •
California
California Asbestos Industry
Ambient Mr Concentrations of
Asbestos Fibers
Dredging to Reduce Asbestos
Concentrations
Accuracy of Transmission
Electron Microscopy
Field Monitoring of Chrysotile
Asbestos
Membrane- f ilter. Direct
FROM TO
James R. Mfllette
W.C. Cooper
James R. Millette
Richard P. Schmitt
Research Corp. of
New England
Walter John
Philip M. Cook
C.M. Kay
Carrel S. Cowan
Salem J. Rice
Bhauan Singh
Jeanine Jones
Eric B. Steel
Steven B. Hayward
Garry J. Burdett
DOCUMENT
DATE
2/80
11/9/79
8/79
5/77
5//17/76
1/76
9/74
9/74
9/70
1966
9/63
3/5/84
2/87
1/85
3/84
1983
Transfer Technique for the
Analysis of Asbestos
-------
Page No. 7
02/28/89
DOCUMENT DOCUMENT
CATEGORY NUMBER
0100.15 860
0100.15 861
0100.15 881
0100.15 882
0100.15 886
0100.15 887
0100.15 898
0100.15 904
0100.15 908
0100.15 909
Atlas and Johns-Manville Coaling* Superfund Si
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Measurement of Asbestos Fibre
concentrations
Asbestos in California Water.
Draft
Major Issues with Health
Effects of Asbestos w/letter
Memo: Site Characterization
Ltr re: City Construction
Article: Asbestos
Fact Sheet: Asbestos
Substitute Materials I
Producers
Environmental News Fact Sheet
Clipping: Cleanup at New
England Asbestos Dump Shows
Costs Can Offset Health...
Article re: Asbestos
FROM
Eric J. Chatfield
Stephen B. Hayvard
EPA - Science
Advisory Board
Chris Chalfany
Robert Hi (ley
BM; Environmental
Reporter
Western Institute
for Occupational t
Environmental
Sciences
EPA
rayaond Josef*
Environmental
Engineering News
0100.15 922 Clipping: Asbestos in the
Western San Joaquin Valley
0100.15 923 Clipping: 19&7 California
Mining Review
0100.15 924 Environmental News Fact Sheet
re: Phase Out Asbestos Use
0100.15 989 Draft Excerpt re: Asbestos
Analytical Methods
Jeanine Jones/
California Geology
California Geology/
John Burnett
EPA
Charles E. Robinson
TO
RUben Moreno
L.W. Pepple
DOCUMENT
DATE
5/83
7/83
no date
8/29/88
5/2/88
11/9/84
1981
Jennifer Decker
10/11/85
9/13/83
7/84
7/88
10/88
1/23/86
8/11/88
0100.15
998
Percent by Area Diagrams
Randy Boltin
Jennie Decker
8/9/88
-------
Page No.
02/28/89
Atlas and Johns-Manvilie Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 1001
Cancer and Asbestos in
Drinking Water
West Coast Cancer
Foundation
3/27/80
0100.15 1002
0100.15 1004
Airborne Asbestos Health
Assessment Update
0100.15 1003 Chronic Hazard Advisory Panel
Characterization t Control of
Asbestos Emissions
EPA
US Consumer Product
Safety Commission
C.F. Harwood
6/86
7/83
9/74
0100.15 1006
0100.15
1007
Determinants of Cancer and
Cardiovascular Disease
Mortality
Study of the Problem of
Asbestos in Water
R.A. Ziskind
American Water Works
Association
no date
9/74
0100.15 1008
0100.15 1009
0100.15
Health Aspects of Asbestos in
Drinking Water
Exposure to Asbestos Fibers in
Water Distribution Systems
Robert C. Cooper
Richard S. WoodbUt
1010 Some Aspects on the Oasi merry Freidrich Pott
6/75
5/8/77
12/78
0100.15
0100.15
0100.15
0100.15
0100.15
1011
1012
1013
1014
1015
WT inv wars iimyBi UK rvtvnKT* ....... — , . — .,- f-, ..-..„.. .. .
Asbestos: Warning, Dangerous
to Health
Ingested Mineral Fibers Philip M. Cook
Health Effects 1 Prevalence of Lei and J. NcCabe
Asbestos Fibers
Asbestos: Expedience, Exposure Michael R. Cray
C Human Experience
Preparation of Extrapulmonary Philip M. Cook
12/78
4/79
6/24/79
no date
12/14/7-
Tissues
0100.15 1016
Effects of Long-term Ingest ion
of Asbestos
Kelley J. Donham
1980
-------
Page No.
02/28/89
Atlas and Johns-Nanvilte Coatings Superfund Sftes
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 1017 Evidence of Migration of
Ingested Asbestos
0100.15 1018 Asbestos in Drinking Water I
Cancer Incidence
Kusun J.
Patel-Manalik
Marty S. Kanarek
1980
1980
0100.15 1019 Pathological Effects of
Prolonged Asbesras Ingestion
R.E. Bolton
1982
0100.15 1020 Cancer Causing Chemicals
Asbestos
1981
0100.15 1021 Assessment of Risks Posed by
Exposure
0100.15 1022 Cancer Morbidity
Investigations
Marvin A.
Schneideman
Eunice E. Slgurdson
4/81
1981
0100.15 1023 Deternination of Mineral Fiber
Concentrations in Fish
A.R. Batternan
4/24/81
0100.15 1024 Mineral Fiber Contamination of Philip M. Cook
Western Lake Superior
0100.15 1025 Policy Problems Associated Michael Sheehan
with Waterborne Asbestos
1/6/81
4/81
0100.15 1026 Relation «* Particle Dimension
to Carcinogenic!IT
Mearl F. Stanton
11/81
0100.15 1027 Interpretation of the
Carcinogenicity of Anocfte
0100.15 1028 Pathogenesis of
Asbestos-Associated Diseases
Philip N. Cook
John E. Craighead
2/17/82
6/17/82
0100.15 1029 Public Health Aspects of Water
Supplies
0100.15 1030 Short and Thin Mineral Fibers
0100.15 1031 Asbestos Drinking Water: A
Status Report
CA Dept. of Water
Resources
E.J. Chatfield
Joseph A. Cotruno
12/31/82
no date
1983
-------
Page No. 10
02/28/89
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
Atlas and Johns-Marrvi lie Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0100.15 1032 Drinking Uater and Health,
vol. 5
0100.15 1033 In Vitro Effects of Mineral
Fibers
0100.15 1034 Review of Published Studies on
Gut Penetration
0100.15 1035 Bibliographies from Online
Computer Databases
0100.15 1036 SuMary: Workshop on Ingested
Asbestos
0100.15 1037 Groundwater Newsletter
0100.15 1038 Groundwater News
0100.20 . 608 Reconaissance Report: Soil i
Air Sampling Strategy
0100.20 609 Memo re: Retaining FIT
Contractors for Sampling Event
u/aap and Photos
0100.20 - 611 MMO re: Sail Sampling Plan. ™.
w/attached Memo
0100.20 612 List of Sample Locations
0100.20 652 CERCLA Soil Sampling Plan
0100.20 654 Soil Sampling Plan Approval
0100.25 603 4 Aerial Photos, 2 Photos of
Building
0100.25 605 Aerial Photo
0100.25 653 Sample Documentation Report
National Research
Council
Lalita D. Palekar
Philip M. Cook
Al V»rga» I Sean
Jenny Decker
Stewart Siopson t
Gres Czajkouskf
Sean Kerned?
Stewart Simpson and
Greg Czajkowski
Jennifer Decker
fcny Zinpfer
. Jennifer Decker... .,
EPA
Jennifer Decker
Ecology I
Environment
EPA
1983
1983
1983
8/4/83
10/13/83
10/31/83
2/84
5/6/87
4/13/87
6/12/87
7/7/87
6/5/87
6/12/87
no date
no date
9/7/87
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
11
DOCUMENT
NUMBER
651
661
754
756
761
762
764
765
766
767
768
769
770
771
772
Atlas and Johns-Manville Coalings Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Atlas and Coalinga PRP Nailing
List
Ltr re: Asbestos Cleanup
Ltr re: Other PRP's. Attached:
9/14/87 Letter
Ltr re: Advice Regarding
Pi-ariniflus Status
Ltr re: Request for Further
Information
Ltr re: Request for
Information • Wheeler
Properties
Ltr res Property Ownership
Ltr re: Responsibility for
Asbestos Removal
Ltr re: Asbury Transportation
Co. Liability
Ltr re: California Minerals
Corp.
Ltr re: Potential Liability
Ltr re: Kern County Land Co.
Ltr re: Uestside Trucking
Ltr re: Marmac
Ltr re: Willingness to
FROM
David W. Long
David W. Long
Jennifer Decker
David B. Stanton
Dorothy G.
Bunce/Reno, NV
Bob J* ttvnpton
John W. Johns
Dean Prettyman
Claude W. Bridges
Richard E. Blubaugh
David 8. Stanton
Henry T. Leckman
Carla J. Irvine
Richard E. Blubaugh
TO
Scott Rahlfs/City
Manager
EPA
Carl* J. Irvine
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
DOCUMENT
DATE
no date
5/4/88
12/28/87
9/20/88
11/1/88
7/5/88
7/7/88
6/30/88
6/21/88
6/21/88
6/24/88
5/23/88
6/29/88
8/9/88
7/22/88
Participate in Response
Activities
0500.01
773 Ltr re: Notice Letter
David 8. Stanton
Jennifer Decker
7/19/88
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
12
DOCUMENT
NUMBER
77*
775
797
805
943
944
945
Atlas and Johns-Manvi Ue Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Notice Letter
Ltr re: Transport of Material
Ltr r«: Other PRP's
Ltr re: Response to 106(a)
Regarding Ownership
Response to Notice Letter
Ltr re: Notice Letter
Ltr re: Extension of Response
FROM TO
Robert K. Behrens Jennifer Decker
John 0. Clarke
David V. Long EPA
David W. Long EPA
Claude V. Bridges Jennifer Decker
John W. John* Jennifer Decker
David E. Noyes Jennifer Decker
DOCUMENT
DATE
8/9/88
5/27/88
9/14/87
8/28/87
6/21/88
6/30/88
5/16/88
Date
0500.01 946 Ltr re: Participation in David E. Noyes
Response Activities
0500.01 947 Ltr re: Correction to Previous David E. Noyes
Letter
Jennifer Decker
Jennifer Decker
6/23/88
7/8/88
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.01
0500.10
948
949
950
951
952
953
992
728
te«pons« to tot ice Letter
Ltr re: Briefing Meeting
Response to Notice Letter
Ltr re: Briefing
Response to Notice Letter
Response to EPA Letter of
6/13/88
Ltr re: Potential Liability
Telecommunication re:
Bob J. Hampton/
Coalinga, Ca
Philip L. Fitzwater
David E. Noyes
George M. C.
Robinson
David B. Station
Dean Prettyman
Richard E. Blubaugh
David Long
Jennifer Decker
Jennifer Decker
Jennifer Decker-
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Bill Wick
7/7/88
8/26/88
7/7/88
9/22/88
6/20/88
6/21/88
6/24/88
8/26/87
0500.10
729
Compliance w/Section 106 Order
Telecomnunication re:
Compliance w/Section 106 Order
Lewis Mitani
David Long
8/26/87
-------
Page No. 13
02/28/89
Atlas and Johns-Manvilte Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
0500.20 619 Ltr re: Answer to 104 Letter
u/insurance Policies, Maps,
Property Ownership Recs
0500.20 620 Ltr with Accompanying Maps,
Figures re: EPA Request for
Information
David V. Long
Richard Blubaugh
Jeff Zelikson
Jennifer Decker
4/29/88
6/3/88
0500.20 808 Ltr re: Financial i Insurance
Coverage Information
w/attaehnents
Richard E. Blubeugh
Jennifer Decker
5/5/82
0500.20 833 Ltr: Response t« 104(e) Letter
w/support Documents
0500.20 862 Ltr re: Request for
Information I Real Estate
Purchase Contract
Kenneth B. Prindle
Bob J. Hampton
EPA
Jennifer Decker
5/6/88
4/19/88
0500.20 863 Response to 104(e) Letter
w/exhibit A
Claude W. Bridges
Jennifer Decker
4/19/88
0500.20
0500.20
0500.20
0500.20
0500.20
0500.20
0500.20
0500.20
865
866
867
868
869
871
872
873
Response to 104(e) Letter
Response* to 104(e) Letter
u/ annual Report I Transmittal
Letter
Response to 104(e) Letter
Response to 104{e) Letter
Response to 104(e) Letter
Response to 104(e) Letter
Response to 104(e) Letter
Ltr re: Request for
John W. Johns
David E. Noyes
Lee Quick
Lowell Baker
A.J. Eyraud
David B. Stanton
David B. Stanton
T.C. Sager
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jeff Zelikson
4/29/88
6/22/88
4/18/88
4/25/88
4/6/88
5/23/88
4/8/88
5/10/88
Information u/amoal Report
0500.20 874 Ltr re: Request for
Information
Richard C. Tisch
Jennifer Decker
5/16/88
-------
Page Ho.
03/09/89
DOCUMENT
CATEGORY
0500.20
0500.20
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
0500.25
14
DOCUMENT
NUMBER
875
1041
641
757
758
776
777
778
779
780
781
782
783
784
785
786
790
791
792
815
Atlas and Johns-Manville Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Denial of Connection
with Coalinga Asbestos
Ltr re: Respopnse to 104(e)
Letter
Certified Nail Receipt
H/letter and Envelope
Ltr re: Section 104 PRP
Responses
Ltr re: PRP 104(e) Responses
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(*> Letter - ........
W Letter
• 104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
104(e) Letter
FROM
Joseph P. Cerullo
Dorothy G. Bunce/
Reno, NV
Jennifer Decker
Sue Johnson
Eve Johnson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
J*ff Zelikson.*.
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
TO
Jennifer Decker
Jennifer Decker
Robert Hanpton
David Long
Kevin Maroff
David U. Long
Floyd Crable
Wayne Broom
Ronald Bownann
Charles Squire
Lowell Baker
Edward Heine ... ,,.
Claude Bridges
Richard Johnson
A I Eyraud
Steve Kerdoon
Lee Quick
Robert Hampton
John Johns
Weavers
DOCUMENT
DATE
4/19/88
7/5/88
4/6/88
8/4/88
8/4/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
3/18/88
5/2/88
3/18/88
3/18/88
3/18/88
3/18/88
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
0500.25
0500.25
0500.25
0500.25
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
15
DOCUMENT
NUMBER
824
830
831
939
759
804
806
820
821
822
823
954
955
956
957
958
959
960
Atlas and Johns-Manvi lie Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
104(e) Letter
104(e) Letter
104(e) Letter
Ltr re: Correction to Previous
Letter
Signed Order Directing SPTC to
Take Action
Ltr re: SPTt Copt twice
Comments by SPTC on EPA Order
87-04
Ltr re: Potential Liability to
the Site
Ltr re: Potential Liability to
the Site
Ltr re: Potential Liability to
the Site
Ltr re: Potential Liability to
the Site
Ltr re: Potential Liability
Ltr re: Potential Liability
.Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability 7
FROM
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jennifer Decker
EPA
Dffrid U. Long
David U. Long
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jett Zellksan
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
TO
Richard B. Von Uald
Earl Chanbers
Irving Noore
Robert Hampton
O.K. NcNear
EPA
Edward Heine
Earl Chanters
Weavers
Wayne Broome
A. Eyraud
Edward Heine
Charles Squire/
Burbank, CA
Wayne Broome
John Johns
Lowell Baker
Irving Moore
DOCUMENT
DATE
3/18/88
3/18/88
5/12/88
5/24/88
8/21/87
8/27/87
9/4/87
4/28/88
4/28/88
4/28/88
4/28/88
6/13/88
6/13/88
6/13/88
6/13/88
6/13/88
6/13/88
6/13/88
-------
Page Ho. 16
02/28/89
DOCUMENT DOCUMENT
CATEGORY NUMBER
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30
0500.30 .
U01.01
U01.01
1401.01
1401.01
1401.01
1401.01
961
962
963
964
965
966
967
968
969
970
971
972
973
974
559
561
570
571
572
613
Atlas and Johns-Kanvi Ue Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr r»: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Potential Liability
Ltr re: Removal Action
Conducted By SPTC
Ltr re: R«vf«u of Hazardous
Substance Containment Report
Cover Itr: RI/FS Documents
Cover Itr: RI/FS Document
Cover Itr: RI/FS Documents
Ltr re: Project Coordinator
FROM
Jeff Zelikson
Jeff Zetikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikcon
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jeff Zelfkson
Jeff Zelikson
Jeff Zelikson
Jeff Zelikson
Jennifer Decker
Jeff Zelikson
Jennifer Decker
Jennifer Decker
Jennifer Decker
Jennifer A. Decker
TO
Richard 6. Tisch
David Noyea
Mr. Weaver
Irving Moor*
E. Heine
Earl Chanters
Uayne Broome
David Noyea
Lee Quick
Robert Hampton
Claude Bridges
Mr. Weavers
Claude Bridges
Earl Chambers
L.W. Pepple
L.U. Pepple
Gary Carozza
Martha Hemly
Lormie Wass
L.W. Pepple
DOCUMENT
DATE
6/23/88
6/23/88
6/23/88
6/23/88
6/23/88
6/23/88
6/23/88
6/13/88
6/13/88
6/13/88
6/13/88
6/13/88
6/23/88
6/13/88
9/26/88
9/27/88
no date
9/16/87
3/1/87
8/31/87
Position
1401.01 614 Revised Comment* on Hazardous
Substence Containment Plan
w/letter
Jennifer A. Decker
L.W. Pepple
9/15/87
-------
Page No. 17
02/28/89
DOCUMENT DOCUMENT
CATEGORY NUMBER
1401.01 615
U01.01 616
U01.01 617
1401.01 658
1401.01 659
1401.01 660
1401.01 664
1401.01 690
1401.01 737
1401.01 738
1401.01 795
Atlas and Johns-Manville Coalings Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION FROM TO
SUBJECT
Ltr re: Sample Community Jennifer Decker L.W. Pepple
Relations Fact Sheet
Transmittal Ltr: Sample Jennifer Decker L.W. Pepple
Documentation Reports
Ltr re: Sutniuion of EPA't Jennifer Decker L.U. Pepple
Final Review of Analytical
Data
Cover letter: Airborne Jennifer Decker L.U. Pepple
Asbestos Sampling Data Report
Ltr re: Conduct a Biota Survey Robert D. Uilley Jennifer Decker
I Construct an On- site Vault
Ltr re: Field Trip to Collect Robert D. Willey Jennifer Decker
Data
Landfill Design with Fax Cover Leonard 0. Yamamoto ATEC Environmental
Page Consultants
Cover Letter for RI/FS Jennifer Decker Jeanine Jones
Documents
Ltr re: Airborne Asbestos Jeanine Jones Jennifer A. Decker
Sampling Data Report
Memo: Risk Assessment • Jeanine Jones Jennifer A. Decker
Procedures w/letter
Ltr re: Addendum to IT/SPTC Robert D. Uilley EPA
DOCUMENT
DATE
9/15/87
9/17/87
12/8/87
7/11/88
2/19/88
5/10/88
8/16/88
9/16/87
1/27/88
10/26/87
12/8/87
Hazardous Substance
• • Containment Plan
1401.01 796 Meeting Notes: Comments on
Field Investigation Report
1401.01 799 Ltr re: Events on Site
w/distribution List
L.U. Pepple
G.L. Hurdock
EPA
EPA
9/8/87
9/24/87
1401.01 800 Ltr re: Hazardous Substance
Containment Plan Addendum II
Robert 0. Uilley
EPA
1/15/87
-------
Page No.
02/28/89
MOMENT
CATEGORY
1401.01
1401.01
1401.01
1401.01
1401.01
1401.01
1401.01
1401.05
1401.05
1401.15
1401.15
1401.15
1401.20
1401.20
18
DOCUMENT
NUMBER
802
807
897
982
986
1039
1040
703
747
*1«
794
1005
704
809
Atlas and Johns-Hanville Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
FAX Cover Itr: Senate Bill
2572
Cover Itr: Hazardous
substance* Containment Plan
Chain of Title of SP
Right-of-way w/lettar
Ifr re: Planning of (timer Air
Stapling Plan
Transmittal Ur: Expended Air
SAP
Inspection Report
w/Transmittal Letter
Inspection teport
u/transflrittal Letter
Emergency Response Action
Surma ry uith 2 Photos
Memo: SPTC & Machine Shop Are*
Hazardous Substance
Containment Plan w/ letter.
Draft
• Ltr: Cements on Hazardous
substance Containment Plan
Draft: Hazardous Substance
Removal Plan
Memo re: Re-analysis of
Coalinga soil sample
Standard Operating Procedures
FROM TO
Bob Ui I ley Jenny Decker
David U. Long EPA
Gary Fairbanks Jenny Decker
Scott R. Huntsman Jennifer Decker
Michael C. Richards Nancy Lindsay
Ruben Moreno Dave Houell
Ruben Moreno Thomas Sager
Brad Shipley Jennifer Decker
Jennifer Decker Greg Baker
Dennis Robinson EPA
Dennis M. Robinson EPA
ATEC Environmental
Consultants
Sean Kennedy Kent Kitchingman
Dennis Robinson Jennifer Decker
DOCUMENT
DATE
9/11/87
9/4/87
3/4/88
2/23/87
8/17/87
7/29/88
7/29/88
6/6/88
4/25/88
9/18/87
9/28/87
12/88
11/3/87
9/11/87
of Asbestos Soil Samples
w/attachments
1401.20
976 Quality Assurance Project Plan Roland A. Sanford
5/8/86
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
Atlas and Johns-Manville Coalings Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
.DATE
1401.20 977 Air Monitoring Sampling Plan. J. David Dean
Drift
1401.20 978 Draft Air Sanpling t Analysis Woodward-Clyde
Plan
HOI.20 979 Ltr re: Equipment for Air J. David Dean
Sampling
1401.20
1401.20
1401.20
1401.20
1401.20
980
981
984
985
987
Adddendun to Draft Air SAP
Draft Equipment List
Ltr re: Additional Airborne
Asbestos Data
Memo: Approval of SAP
Expanded Air Sanpling t
Woodward-Clyde
David Suder
A I Vargas
Woodward-Clyde
Analysis Project Plan
1401.20 988 Memo: Addendt* to Air Sampling AI Vargas
Plan
1401.20 990 Memo: Revision of Air David Suder
Monitoring Program
Dan Hutton
Jennifer Decker
Donald Harvey
8/19/85
1/15/86
10/1/85
11/20/85
no date
Jennifer Decker 5/27/87
Kent M. Cftchingman 9/21/87
8/17/87
7/22/87
7/29/86
1401.20
1401.20
1401.20
1401.25
1401.25
1401.30
1401.30
991
996
997
595
70S
674
760
Memo: Amended Air SAP w/ letter
Outline of Expanded Air
Sampling Program u/letter
Amendments to Air SAP
Interim Health t Safety
Guidelines for EPA Asbestos
Inspectors
Site Safety Plan
Ltr re: Permission for EPA to
take Soil Samples
Ltr re: Permission to Take
Soil Samples
Scott R. Huntsman Jennifer Decker
Scott Huntsman • Jennifer Decker
Scott Huntsman Jennifer Decker
EPA
Geoff Uatkin Jennifer Decker
EPA
Jennifer Decker Keith Scrivener/
Coalinga
7/15/87
5/12/87
3/5/87
5/87
11/25/87
12/14/88
12/14/88
-------
Page No.
02/28/89
DOCUMENT
CATEGORY
1401.30
1*01 .50
1401.35
1401.35
1401.35
1401.40
1401.40
1401.45
1401.50
1401.50
1401.50
1401.50
1401.50
20
DOCUMENT
NUMBER
935
936
691
706
707
999
1000
675
622
623
624
625
626
Atlas and Johns-Manvi lie Coaling* Superfund Sites
City of Coalings Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Request to Sample Soil
Ltr re: Request to Sample Data
Attachment* to Oversight of
Responsible Party Activities
Oversight of Responsible Party
Activities
Cover letter: Oversight of
Responsible Parties
Meteorological Data Report
Airborne Asbestos Sampling
Data Report
Duality Assurance Report
u/ letter
Site Characterization
Hazardous Substance
Comafmient Report
Design Report: Asbestos Waste
Management Unit w/transmittal
Letter
Hazardous Substance
Containment Report, vol. I
Hazardous Substance
Containment Report, vol. II of
FROM TO
Jennifer Decker Keith Scrivner
Jennifer Decker Robert Hampton
Jacobs Engineering EPA
Jacobs Engineering EPA
Sue Johnson Jennifer Decker
Woodward-Clyde
Consultants
Woodward-Clyde
Consultants
X
Mark Unruh
IT Corporation
G. Dale Barnhill Ruben Moreno
ATEC Environmental
Consultants
ATEC Env.
Consultants
DOCUMENT
DATE
12/14/88
12/14/88
12/87
12/87
12/21/87
1/15/88
6/3/88
9/15/88
8/88
1/8/88
1/89
8/88
8/88
II
1401.50 798 Draft Hazardous Substance SPTC
Containment Plan
1401.50 801 Revised Hazardous Substance SPTC
Containment Plan
9/18/87
9/28/87
-------
Page No.
07/26/89
21
Atlas and Johns-ManvUle Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
1401.50 1042 FS Report: OUFS/Hazardous
Substance Remedial Plan
ATEC Environmental
Consultants
02/89
1401.52 600 Ltr re: Cements on SPTC
Hazardous Substance
Containment Plan
Jennifer Decker
L.U. Pepple
2/22/88
1401.55 686 Mean: Public Health Assessment Jennifer Decker
from ATSOR and Couunity
Meeting
1401.55 687 Men: Thank You for the Jeff Zelikson
Presentation
Don Hawkins
4/22/87
Jeffrey A. Lybarger 5/22/87
1401.55 688 Memo: Update on Com.
Relations and Request for
Epideniological Study
1401.55 736 Ltr re: Public Health Issues
1401.55 876 Review: Draft Evaluation of
Potential Relative Risks
Associated uith Airborne...
Amy Zimpfer
Jeffrey A Lybarger 9/11/87
James T. Allen
Office of Health
Assessment
Keith Takata
Don Haukins
7/2/87
4/30/87
1401.55 877 >evS«M: Dnrft Evaluation of
Potential Relative Risks
Associated with Airborne...
Office of Health
ATSOR
5/4/87
1401.55
1401.55
1401.55
1401.55
878
879
880
885
Ltr re: Epideniological Study
Memo: Epidemiological Study
Request
. Preliminary Health Assessment
u/ letter
Health Consultation Memorandun
u/attachments
Gail Louis
Lybarger
ATSDR/Von A linen
Office of Health
Assessment
Don Haukins
ATSOR Region 9
EPA/Clifford
Don Haukins
11/5/87
12/11/87
11/3/88
4/22/87
1401.57 621 Endangered Species Survey IT Corp
u/cover Letter
4/88
1401.57
656
Ltr re: Biota Survey
Greg Baker
Gail Kabetich
2/5/88
-------
Page No.
07/26/89
DOCUMENT
CATEGORY
1401.57
1401.57
1401.60
1401.60
1401.60
1401.60
1401.60
1401.60
1401.60
1401.60
7000.01 "
22
DOCUMENT
NUMBER
883
884
568
569
689
692
693
732
733
739
678
Atlas and Johns-Manville Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Endangered Species.
U/attachnents
Ltr re: Endangered Species
Ltr: Design and Construction
of a Waste Disposal Unit
Ltr: Request Guidance to
Design a Disposal Unit
Ltr: Detailed Identification
of CA ARAR
SF Transportation Company
Letter
Menu re: ARAR's
Memo re: ARARS
Report: Identification of
asbestos with letter
Mailing List v/tetter -
FROM TO
George Nokes Robert King
Dept. of Fish * EPA
Wildlife
Retort 0. Willey J. Zellkson
R. Nichols Hazeluood Lonnie Uass
Phil Bobel Janes Allen
Ruben Moreno R. Nicholas
Hazeluood
Jeanine Jones Jennifer Decker
James T. Allen PhU Bobel
Ruben Moreno Mark Unruh
Janes T. Allen Keith Takata
Tory. Peterson t - CA Oept.of water -
Sugaser Resources
DOCUMENT
DATE
6/8/87
2/29/88
4/12/88
4/11/88
4/18/88
5/24/88
5/4/88
5/11/88
8/29/88
8/21/87
6/25/85
7000.01 679 Ltr re: Neighborhood Health
• Problen
Rose Hess
Gall Louis
7/22/M
7000.01 680 Ltr re: Citizen Concerns w/EPA
Response
7000.01
896
Motte
the Site
Ltr re: Lack of Cleanup at the
Site
D. Scott Rohlfs
Jennifer Decker
David Long
4/5/88
7000.01
7000.01
7000.01
681
682
683
FOIA Request
FOIA Request
Ltr re: Citizen Concerns About
Robert Hernando
Nona Chew
Vincent Motte
Gail Louis
Ida Tol liver
Jennifer Decker
8/24/87
2/7/88
1/8/88
4/13/88
-------
Page No.
07/26/89
DOCUMENT
CATEGORY
7000.01
7000.01
7000.01
7000.01
7000.01
7000.01
7000.01
7000.01
7000.01
7000.01
7000.15
7000.20
7000.20
7000.20
7000.20
7000.20
7000.20
23
DOCUMENT
NUMBER
925
926
927
928
929
930
931
932
933
934
676
888
889
890
892
893
894
Atlas and Johns-HanvUle Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Ltr re: Asbestos i Health
Transmittal Ltr: RI/FS Work
Plan
Mailing List and Thank You
Notes
Ltr re: Correspondence u/Santa
Fe Pacific Realty Corp.
Ltr re: Meeting to Develop CRP
Ltr re: Transmittal of Reports
Ltr re: Information Repos.
Update
Ltr re: Information Repos.
Update
Transmittal Ltr: CBP
Ltr re: City Council Meeting
Revised Draft CRP
Clipping.- EPA and Other
Studies Asbestos
Clipping: County Plans
• Asbestos Tests
tupping: Costa Will Visit
Arenal
Clipping: Asbestos Plant Opens
Clipping: Residents Receive
EPA Letter
Clipping: EPA Studying
FROM TO
Steve Drew Henry
Lecknn/Coa I i nga
Scott Huntsman Myron Levin
Steve Drew Distribution
Nichele Oeranr Myron Levin
Gail Louis Scrivner
Gaft Louis Bob King/Coal inga
Gail Louis Kay Anthony
Gail Louis Kay Anthony
Gail Louis "People"
Gail Louis Vincent Motte
WCC
UP I
Hoi lister Free-Lance
Fresno Bee
Mineral Information
Service
Coalinga Record
Coalinga Record
DOCUMENT
DATE
3/21/84
9/16/86
3/1/84
9/15/86
no date
11/30/88
11/30/88
4/14/88
3/18/88
1/20/88
3/88
1/29/85
11/14/83
5/10/83
12/64
7/22/87
11/18/87
Coalinga Asbestos Situation
-------
Page No.
07/26/89
24
Attas and Johns-Manville CoaUnga Superfund Sites
City of Coaling* Operable Unit
ADMINISTRATIVE RECORD INDEX
DOCUMENT
CATEGORY
DOCUMENT
NUMBER
DESCRIPTION
SUBJECT
FROM
TO
DOCUMENT
DATE
7000.20 895 Clipping: Crowd Rupture,
Coalinga Earthquake of 1983
7000.20 899 Clipping: Huron Chief Responds
to Hiring Controversy Story
7000.20 900 Clipping: Asbeston Fibers
Found in Drinking Water
Supplies
7000.20 901 Clipping: Local Meet to
Explore Asbestos Fiber Cleanup
7000.20 902 Clipping: Public Is Excluded
from Environmental Agency
Meeting Here
H.C. Junkin/Hart
Coalinga Courier
Steve Anthony/
Nollister Free-lance
8/83
11/17/87
no date
no date
no date
7000.20 903 Clipping: Proposal for Clear
Creek Area Outlined
Fresno Bee
10/30/85
7000.20 905 Clipping: Asbestos Found in
Streams
Russell dealings/
Fresno Bee
9/7/85
7000.20
7000.20
7000.20
7000.20
7000.20
7000.20
7000.20
7000.20
907
910
911
912
914
915
916
917
Clipping: Asbestos in Aqueduct Robert Jones/LA
Worries State Times
Environmental New Fact Sheet
Fact Sheet: Coalinga Asbestos
' Superfund Update: RI/FS EPA
Meeting Packet w/agenda EPA
Asbestos Fact Sheet
Meeting Overhead Slides
Press Release: City of EPA
2/9/84
••"• ' ' 4/85 '
7/16/85
6/87
1/7/88
no date
no date
Ann Zawila/KFO Radio 1/30/89
7000.20
918
Coalinga Proposed Plan
Superfund Update: Expected
Schedule for Removal
EPA
4/88
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Page No.
07/26/89
DOCUMENT
CATEGORY
7000.20
7000.20
7000.20
7000.50
7000.50
7000.50
7000.50
7000.50
7000.50
7000.50
7500.00
25
DOCUMENT
NUMBER
919
920
921
657
662
663
684
685
741
743
677
Atlas and Johns-Nanville Coalinga Superfund Sites
City of Coalinga Operable Unit
ADMINISTRATIVE RECORD INDEX
DESCRIPTION
SUBJECT
Clipping: Asbestos From Sludge
Used in Fertilizers Nay Be
Collecting on Farmland
Clipping: Family Stick With
Asbestos-ridden Hone
Clipping: Asbestos Can Cause
Cancer fay Transporting DMA
Ltr re: Request for Velocatlon
Funds
Ltr re: Relocate Mobile Home
Estimate to Remove Mobile Hone
Ltr re: Ownership Certificate
for Ruth Goolsby's Trailer
Ltr re: Moving Ruth Goolsby's
Trailer
ROC re: Ruby Goolsby's trailer
ROC Re: Ruth Goolsby's Trailer
Ltr: Explain the Delay of Site
FROM TO
AMI Kuaar Naj/Wall
Street Journal
San Joae Mercury
News
San Jose Mercury
News
Susan Robinson Jennifer Decker
G.L. Murdock Ruby Goolsby
L.R. White Ruby Goolsby
Gail Lewis David W. Long
Gail Lewis David W. Long
US EPA Carolyn HcFarland
Gail Louis Susan Robinson
Daniel NcGovern Tony Coelho
DOCUMENT
DATE
11/9/88
11/1/88
11/1/88
no date
10/11/88
8/15/88
4/12/88
9/23/88
3/15/88
4/6/88
9/13/88
Cleanup w/attachments
8000.25
755
Ltr re: Confidentiality Claiai
Jeff Zelikson
Carla J. Irvine
9/28/88
-------
Page Ho.
07/19/89
Atlas and Johns-Nanville Coaling* Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No. 1
DATE
AR
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
01/01/84
AR1
Roger Scholl
James Stratta
Editors
Coalinga California Earthquake of
May 2, 1983 - Reconnaissance Rpt
(Docunent Date 1/84)
08/21/87 AR2
02/22/88
05/06/88
AR3
AR4
06/16/88 ARS
01/30/89 AR6
02/01/89 AR7
Jenny Decker
Environmental
Protection Agency,
Region IX. S.F.
Sue Johnson
Jacobs Enginerins
Group Inc.
Earl Chambers
Maraac Resources
Company
Jenny Decker
Environmental
Protection Agency,
Region W, S.F.
Hark Unruh
International
Technology
Corporation. ......
Nark Group
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Lee Quick
Interstate Towing
Scott Roblfe
Coaling* City
Manager
Communication Strategy - 106
Order SPTC 87-04
Cements on IT Corp's Hazardous
Substance Containment Rpt w/TL to
Jenny Decker 3/15/88
Ltr: Response to 104(e> Ltr -
General Overview of Operations,
Confirming Extension to Submit
Further Information
ROC: Notice Ltr, Addresses Nixed Up
Ltr: Conments on Design Rpt For
Asbestos Waste Management Unit
Proposed Specifications For Nanac
Warehouse Chromite Ore Body Removal
and Transportation (Docunent Date
2/89)
02/01/89
ARS
02/10/89
AR9
Environmental
Protection Agency,
Region IX, S.F.
Sue Johnson
Jacobs Enginering
Croup Inc.
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Fact Sheet - Asbestos Cleanup in
Coalinga (Document Date 2/89)
Ltr: Comments on Asbestos Waste
Management Unit u/Attachments
-------
Page No.
07/19/89
DATE
AR *
Atlas and Johns-Manville Coalings Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Statement No. 1
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
02/13/89
ARID
02/17/89 AR11
02/22/89
AR12
02/24/89 AR13
02/24/89 ARK
03/01/89 AR1S
Carla Feldoan
Shield I Saith,
Representing Narwac
Resources Company
Greg Baker
Environmental
Protection Agency.
Region IX, S.F.
Environmental
Protection Agency,
Region IX, S.F.
Barry Lee
Oinkelspiel. Donovan
I Reder,
Representing Atlas
Minerals, Division
of Atlas Corporation
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Blair King
Assistant City
Hanager of Coalinga
Dan Neer
Environmental
Protection Agency,
Regie* IX, S.F.
Dan NcGovern
EnvironMntal
Protection Agency,
Region IX, S.F.
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Carla Feldman
Jerry Andes
Shield t Smith,
Representing Manaac
Resources Company
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
ROC: Special Notice Ltr, Chromite
Ore in Warehouse
Mean: Briefing on City of Coalinga
OU Superfund ROD
Transcription of Community Meeting
Asbestos Cleanup Proposed Plan
w/Agenda
Ltr: Atlas Request for Extensions
COC: Marmac Warehouse Clean-up
Ltr: Confirming Extension of Public
Review and Comnent Period
03/01/89 AR16
03/07/89
AR17
Paul Oezurick
Graham I James
Dan Meer
Environmental
Protection Agency.
Region IX. S.F.
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Richard Tisch
Union Carbide
Ltr: Concern with the Nuifcer of PRPs
Participating
ROC: Follow-Up to Notice Ltr
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Page No. 3
07/19/89
Atlas and Johns-Manville Coalinga Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No. 1
DATE Aft
AUTHOR
RECIPIENT
DESCRIPTIOM/SU8JECT
03/08/89 AR18
Sue Johnson
Jacobs Enginering
Group Inc.
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Ltr: Comments on Proposed
Specifications For Nar«ac Warehouse
Chromite Removal
03/09/89 AR19
Dan Neer
Environmental
Protection Agency,
Region IX, S.F.
California Regional
Water Quality
Control Board •
Central Valley
Aegion
ROC: OUFS • Water Board Will
Consider Easing Slope Restriction on
Landfill
03/13/89 ARM
Sue Johnson
Jacobs Enginering
Group Inc.
Jenny Decker
Cnrirormntml
'Protection Agency,
Region IX, S.F.
Ltr: Comments on Proposed
Specifications for Mannac Warehouse
Chromite Removal
03/1S/89 AR21
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Meeting Agenda. List of Attendees,
and Notes Re City Council Concerns
with WMU/OUFS
03/16/89 AR22
03/17/89 AR23
John local's
Shield I Smith,
lepresenting Harmsc
•esvurce* Company
Jenny Decker
et al
EnvircnmentaX
Protection Agency,
Region IX, S.F.
Decker
Jon Wactor
Environmental
Protection Agency,
Region IX, S.F.
Ruben Moreno
Michael Mangold
California Regional
Vater Quality
Control Board -
Central Valley
Region
Ltr: Cements of Marmac to OUFS/HSRP
ROC: Conference Call - WMJ Design
Specs
03/17/89 AR2«
03/21/89 AR25
John Zikoponlos
Western Technologies
Greg Baker
Environmental
Protection Agency,
Region IX, S.F.
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Scott Rohlfs
Coalinga City
Manager
ROC: Comments on OUFS
ROC: Latest on Asbestos Cleanup -
City Council Position on Proposed
Plan
-------
Page No. 4
07/19/89
Atlas and Johns-Hanville Coalinga Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No. 1
DATE
AR
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
03/23/89
AR26
03/23/89 AR27
03/23/89 AR28
03/24/89 AR29
03/24/89 AR30
04/01/89 AR31
04/07/89 AR32
04/13/89 AR33
Keith Scrivner
Mayor of Coalinga
Jenny Decker
Environmental
Protection Agency,
Region IX, S.F.
Conard Harper
Simpson Thacher I
Sartl«tt,
Representing Atlas
Minerals. Division
of Atlas Corporation
Robert Thompson
Graham & James
Phillip Fitzwater
Harding Lawson
Associates,
Representing Vinnell
Mining I Minerals
Corporation
Environmental
Protection Agency,
Region W. S.f.
Michael Mangold
California Regional
Uater Quality
Control Board -
Central Valley
Region
Ed Cargile
California
Department of Health
Sevices
Jenny Decker
Environmental
Protection Agency.
Region IX, S.F.
Bob U!U«r
ATEC Environmental
Consultants
Jon Uactor
Environmental
Protection Agency,
IX, S.f.
Environmental
Protection Agency,
Region IX. S.F.
Environmental
Protection Agency,
Region IX, S.F.
Ruben Moreno
California Regional
Uater Quality
Control Board -
Central Valley
Region
Dan Meer
Environmental
Protection Agency,
Region IX. S.F.
Ltr: Official Response to EPA
Cleamav Plan
ROC: Putting UMU Under • Road
Ltr: Consents t Questions on
Proposed Asbestos Containment Plan
in the City of Coalinga
Ltr: Comments on OUFS on Behalf of
Vinnell Mining
Ltr: Technical Review Comments on
OUFS Hazardous Substance Remedial
Plan on Behalf of Vinnell Mining
Preparation of a US EPA Region 9
Sample Plan for EPA-Lead Superfund
Projects (Document date 4/89)
Memo: Review of Design Rpt Asbestos
waste Management Unit w/TL to L U
Pepple 4/7/89
ROC: Proposed Plan Technically
Sound, Must Re-evaluate if Location
Moved
-------
Page Ho.
07/19/89
DATE
AR f
Atlas and Johns-Nanville Coalinga Superfund Site
City of Coaling* Operable Unit
Administrative Record File Index
Supplement No. 1
AUTHOR
RECIPIENT
OESCRIPTION/SUBJECT
04/19/89
AR34
OS/03/89 AR35
05/03/89 AX36
OS/10/89
AR37
05/19/89 ARM
OS/22/89
AR39
05/25/89
ARM)
06/OS/89 AR41
Dan Neer
Environmental
Protection Agency,
Region IX, S.F.
Oan New
Environmental
Protection Agency,
Region IX. S.F.
Oan Neer
Environmental
Protection Agency,
Region IX, S.F.
Jerry Clifford
Environmental
Protection Agency,
Region IX, S.F.
Dan Neer
Environmental
Protection Agency,
Region IX, S.F.
COT la F*Ufaan
Shield t Smith,
Representing Nat-mac
Resources Company
Laurie VilUams.
Environmental
Protection Agency,
Region IX. S.F.
Oan Neer
Environmental
Protection Agency,
Region IX. S.F.
Bob Uilley
ATEC Environmental
Consultants
Alan Jacobean
CMllnf* Public
Works Dep»itment
Ed Cargile
California
Department of Health
Sevices
Scott Rohlfs
Coalinga City
Nanager
Scott Rohlfs
Coaling* City
Manager
Oan Neer
Environmental
Protection Agency,
Region H. S.F.
John Loomis
Shield t Smith,
Representing Narmac
Resources Company
Michael Mangold
California Regional
Uater Quality
Control Board •
Central Valley
Region
ROC: City Will Not Agree to Liner
ROC: Asbestos Rocks Found at Sisk
Fountain
Ltr: Transmittal of Proposed Plan I
Request for Comments
Ltr; General Notice M/Certified Nail
Receipt, Pomestic Return Receipt and
Concurrences
ROC: Coalinga's Reaction to General
Notice Ltr
Ltr: Inquiry into Status of Plan
Submitted on Behalf of Harmac for
Removal of Chromfte
Ltr: Comments en Maniac's Proposed
Cleanup Plan «/Appendix A • Detailed
Comments
ROC: STLC and TTLC For Nickel at
Coalinga OU
06/08/89 AR42
Oan Meer
Environmental
Protection Agency,
Region IX, S.F.
Ed Cargile
California
Department of Health
Sevices
ROC: DHS Concurrence with Proposed
Plan
-------
Page No.
07/19/89
Atlas and Johns-Manville Coalinga Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No. 1
DATE
AR *
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
06/09/89 AR43
Dan Neer
Environmental
Protection Agency,
Region IX, S.F.
Leonard Yanamoto
International
Technology
Corporation
ROC: Earthquake Stability of the UMU
in Coalinga
06/12/89 ARU
06/13/89
AR45
OanNeer
Environmental
Protection Agency,
Region IX, S.F.
Dan Neer
Environmental
Protection Agency,
Region IX, S.F.
Leonard Yamamoto
International
Technology
Corporation
Bill Marshall
California Regional
Uater Quality
Control Board
ROC: Details of UMU Design, Left
Message For Yamamoto
ROC: Grade Requirements on Landfill
Caps
06/14/89
AR46
06/14/89 AR47
06/27/89 AR48
Bob UiI ley
ATEC Environmental
Consultants
Dan Meer
Environmental
Protection Agency,
Region IX, S.F.
Anthony Landis
California
Department of Health
Sevices
Dan Meer
Environmental
Protection Agency,
Region IX, S.F.
Ed Carglle .
California
Department of Health
Sevices
Dan Meer
Environmental
Protection Agency,
Region IX, S.F.
ROC: Spraying in Coalinga, Changes
to OUFS
ROC: Clean-Up Level For Nickel
Ltr: Concurrence on Proposed Plan
06/30/89 AR49
Environmental
Protection Agency.
Washington B.C.
Draft Fact Sheet: Final Rule Banning
Manufacture, Processing, Importation
1 Distribution in Commerce of Most
Asbestos Products w/Attachment
07/06/89 ARSO
H Josef Herbert
Associated Press -
Article from San
Francisco Examiner
News Clipping: US Bans Almost All
Asbestos
07/07/89 ARS1
Philip Shabecoff
New York Times
News Clipping: EPA to Ban Virtually
All Asbestos Products by '96
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Page No. 7
07/19/89
Atlas and Johns-Hanville Coalinga Superfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Supplement No. 1
DATE
AR
AUTHOR
RECIPIENT
DESCRIPTION/SUBJECT
07/07/89
AR52
San Francisco
Chronicle
Iteus Clipping: Host Uses of Asbestos
to Be Banned by EPA
07/07/89 AR53
07/17/89 ARM
ARSS
/ /
AR56
ARSS
ARS9
ARM
Dan Near
Environmental
Protection Agency,
Region IX, S.f.
Oan Neer
Environmental
Protection Agency.
Region IX. S.f.
Greg Baker
Envirornental
Protection Agency.
Region IX. S.F.
Environmental
Protection Agency.
Region IX, S.F.
/ / AR57 Jenny Decker
Environmental
Protection Agency,
Region IX, S.f.
Envirornental
Protection Agency
Nicholas Walsh
US Department of
Transportation
Diaries *efth
Jacobs Enginering
Group Inc.
Jenny Decker
Nancy Woo
Environmental
Protection Agency,
Region IX, S.f.
Russ dealings
Fresno Bee
ROC: DOT Requirements for Shipping
Hazardous Materials
ROC: Cap Design for Coalinga UHU
Nemo: Analytical Methods Being Used
and Program Consistency
Notice of Public Comment Period I
Public Meeting on Proposed Cleanup
Plan
ROC: City of Coalinga Cleanup •
OUFS/Proposed Plan
List of Guidance Documents
(Documents Available at EPA Region 9
Superfund Records Center)
Toxicity Profile for Asbestos
Bibliography for the Review of Site
Risk
AR61
Oan Meer
Environmental
Protection Agency.
Region IX. S.F.
Review of Site Risk
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Page No. 8
07/19/89
Atlas and Johns-Manville Coalinga Si^xtrfund Site
City of Coalinga Operable Unit
Administrative Record File Index
Sqppleaent No. 1
DATE AR * AUTHOR RECIPIENT DESCRIPTION/SUBJECT
/ / AR62 Draft RI/FS Rpt South Bay Asbestos
Area (Oocunent Available at EPA
Region 9 Staxrfund Records Center)
/ / AR63 Baseline Risk Assessment for the
Atlas Nine StaMrftnd Sit*
-------
CITY 07 COXLINGA OPERABLE UNIT RESPONSIVENESS SUMMARY
POR THE
OPERABLE UNIT FEASIBILITY STUDY AND PROPOSED PLAN
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESPONSE TO COM-
MENTS ON TBS PROPOSED PLAN FOR THE CITY OF COALINOA OPERABLE UNIT
OF THE ATLAS MINE AND JOHHS-MANVILLB COALINGA ASBESTOS MILL 8U-
FERFUND SITES
I. INTRODUCTION
The United States Environmental Protection Agency (EPA) held a
public comment period from February 9 through March 24, 1989 on
EPA's Operable Unit Feasibility Study (OUFS) and Proposed Plan
for the asbestos and nickel contamination at the City of Coalinga
Operable Unit in Coalinga, California. The purpose of the public
comment period was to provide interested parties with the oppor-
tunity to comment on the OUFS and Proposed Plan. During the
public comment period, a public meeting was held in Coalinga on
February 22, 1989 to discuss the results and alternatives
presented in the OUFS. Public concerns and comments on Site ac-
tivities and EPA's preferred clean up plan were formally recorded
for the public record. The OUFS was made available on February
9, 1989; the complete Administrative Record was delivered to the
Coalinga Public Library on February 23, 1989. The original
public comment period was scheduled to close on March 2, 1989.
This abbreviated public comment period was designed to expedite
the clean up process. However, at the public meeting, members of
the community as well as representatives for the Potentially
Responsible Parties (PRPs) requested more time to review the
OUFS and the Administrative Record. EPA then extended the
public comment period to March 24, 1989.
On February 9, 1989, copies of the OUFS were delivered to the
Coalinga Public Library, the designated information repository
for the Atlas Mine and Johns-Manville Coalinga Asbestos Mill Su-
perfund Sites. By February 9, 1989, fact sheets containing EPA's
Proposed Plan had been mailed to all interested parties.
Notification of the upcoming public meeting was published in
Coalinga and Fresno area newspapers.
Section 113(k)(2)(B)(iv) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) requires that
EPA respond to each of the significant comments on EPA's Proposed
Plan. This responsiveness summary provides a review and summary
of community concerns about the Site and significant public com-
ments on the OUFS and the Proposed Plan. In addition to sum-
marizing significant citizen concerns and questions, the Respon-
siveness Summary presents EPA's responses to those concerns.
-------
II. OVERVIEW OF THE RECORD OF DECISION AND CRITICAL COMMUNITY
CONCERNS
The Agency's selected remedy is the consolidation and burial of
asbestos and nickel contaminated material in an on-site Waste
Management Unit (WMU). Other alternatives fully analyzed in the
OUFS included: i) no action; ii) covering the contaminated waste
in-place with one foot of clean soil; iii) removal of con-
taminated material to an abandoned mine site in the surrounding
mountains; and iv) removal of the contaminated material to an ap-
proved, off-site landfill.
The community favored removal of the contaminated material from
the City and opposed covering the contaminated waste in-place
with one foot of clean soil.
This WMU will have an impermeable cap as required by Title 23,
Subchapter 15 of the California Administrative Code. The
original design included a four percent grade on the WMU. The
four percent grade for drainage meant that the crown of the WMU
would be six to eight feet above ground level. This was greeted
with universal disapproval by the community. The WMU was
described at the public meeting as a "visual blight" or an
"asphalt dome" which would lower property values in the area,
discourage development and negatively impact Coalinga's economy.
With these community concerns in mind, EPA asked the California
Regional Water Quality Control Board (RWQCB) if it would be pos-
sible to reduce the grade of the cap in this case and lower the
cap to as close to ground level as is feasible. The RWQCB agreed
that the crown for this particular WMU could be lowered. The
RWQCB decision was communicated to the Coalinga City Council by
EPA representatives at a City Council meeting on April 6, 1989.
Mr. Ruben Moreno of the RWQCB was present at this meeting.
Another design change made at Coalinga's request was to allow for
the possibility of a vegetated surface.
-------
III. SUMMARY OF PUBLIC COMMENTS RECEIVED AMD AGENCY RESPONSES
This section includes EPA's response to significant public com-
ments on the OUFS and the Proposed Plan received during the
public comment period. The public comments included letters sent
to the EPA and comments/questions presented during the February
22, 1989 public meeting. A complete transcript of the public
meeting has been entered into the Administrative Record.
EPA has categorized the comments and responses to those comments
as follows:
A. Comments made by members of the Coalinga City Council.
B. Comments made by the interested public.
C. Comments made by potentially responsible parties (PRPs).
The comments responded to herein have been summarized or
paraphrased as appropriate.
A. COMMENTS BY MEMBERS OF TEE COALINGA CITY COUNCIL
A.I Letter from the Mayor of Coalinga, Mr. Keith Scrivner, dated
March 23, 1989. Mr. Scrivner's letter reiterates many comments
made by members of the Coalinga City Council at the public meet-
ing, as follows:
A.1.1. Comment; Even though the municipality is the entity on
which EPA's decision regarding the Site will have the greatest
impact, the City of Coalinga has very little influence on that
decision.
A.1.1. Response: Community acceptance is one of nine criteria by
which EPA evaluates a remedy. The modification of the proposed
plan to accommodate the community's concern regarding the height
of the WMU crown and insertion of a flexible requirement for
either a vegetative or asphalt cap are examples of the EPA using
that criterion- in remedy selection.
A.1.2. Comment; The city has not been kept informed of the
project status or been involved with design and engineering deci-
sions regarding the WMU. In the last six months, communication
between the EPA and the Coalinga community has been inadequate.
A.1.2. Response: In an effort to choose a remedy consistent with
community desires and concerns, EPA has communicated and held
meetings with representatives of the City of Coalinga frequently
throughout the project, specifically since July, 1985. The EPA
remedial project manager and community relations coordinator com-
-------
municated with representatives of Coalinga by letter and fact
sheet, and made trips to Coalinga to coordinate the community
relations plan with the community and to update the community on
the project status. The trips to Coalinga included meetings with
City representatives Mr. Bob King and Mr. Bob Semple (both former
city planners of Coalinga). These activities occurred between
July of 1985 and April of 1989. In April of 1988 the Director of
Region IX's Hazardous Waste Management Division, Mr. Jeff Zelik-
son, attended a City Council meeting to discuss the status of the
clean up plan for the City of Coalinga Operable Unit. In Novem-
ber, 1988, representatives of the City of Coalinga, Mr. King (the
City Planner) and Scott Rohlfs (the City Manager) met with a rep-
resentative of ATEC (the consulting firm hired by Southern
Pacific Transportation Company (SPTC) to oversee preparation of
the WMU design plans) to discuss the design and location of an
on-site waste management unit (WMU).
During 1988 several members of the Coaling community and the
Coalinga City Council requested that the clean up be completed as
quickly as possible. EPA representatives attempted to expedite
completion of the proposed plan so that clean up could begin. As
noted above, community concerns and needs have been a factor in
modification of the design of the WMU.
A.1.3. Comment! Members of the Coalinga City Council believed
that the WMU would be located under a road right-of-way. They
believe that such a location would be the best possible one, if
the WMU must be located within the City limits.
A.1.3. Response; EPA found that there was no technical or en-
vironmental basis for requiring the.WMU to be located under a
road right-of-way. EPA determined that the additional cost for
such a WMU was excessive. The ultimate, compatible use for the
land above the WMU remains to be determined.
A.1.4. Comment; With hundreds of square miles of open land in
the area, why does the waste have to be buried within the City
limits?
A.1.4. Response; EPA guidance implicitly recognizes that only a
limited number of alternatives for the remediation of each site
can be studied in depth. EPA guidance requires identification of
one or more alternatives that involve containment with little or
no treatment. Guidance For Conducting Remedial Investigations
and Feasibility Studies Under CERCIA (October 1988), p. 2-9. Be-
cause no feasible treatment exists for asbestos, EPA studied a
total of five alternatives in depth, four of which involved con-
tainment and not treatment. Two of these alternatives involved
taking the waste off-site: (1) disposing of the waste at a per-
mitted landfill and (2) placing the waste in an abandoned mine
approximately 20 miles from the Site. At the time that the al-
ternatives to be studied in depth were selected, it was EPA's un-
-------
derstanding that the community agreed that an on-site WMU was an
acceptable alternative. In response to community input, EPA
decided to study an on-site WMU location as close to the edge of
the City as feasible. In light of the fact that two off-site
containment alternatives were already being studied, EPA did not
elect to study any additional off-site alternatives. The bases
for rejection of the two off -site alternatives studied are
described in the ROD.
A. 1.5. Comment; Mayor Scrivner and members of the City Council
believe that the WMU design should include a liner, to ensure the
maximum protection for the community.
A. 1.5. Response; EPA and the California Regional Water Quality
Control Board (RWQCB) have determined that a liner is not needed
to assure that the WMU effectively protects public health and the
environment. See RWQCB Memorandum, dated April 7, 1989, attached
as Appendix 2 to the ROD. The cap and drainage system for the
unit along with the natural conditions at the Site will provide
adequate protection against migration of contaminants. Asbestos
is not soluble in water and does not migrate once it has been
capped. While the nickel in the material to be buried is solu-
able, EPA and the RWQCB determined that the presence of this
nickel did not justify requiring a liner for the WMU for the fol-
lowing reasons. Coalinga has only approximately seven inches of
rainfall per year. There is no detectable vertical hydraulic in-
terconnection between the natural geologic materials underlying
the proposed unit and the upper aquifer. A detailed
hydrogeologic study of the Site area was performed in August,
1988 by the IT Corporation. This study found that the local
groundwater is very deep in this area (greater than 100 feet) and
that several impermeable clay layers are present between the sur-
face and the water table in the Site vicinity. In addition, the
local ground water in its natural state is not potable. It ex-
ceeds the EPA Drinking Water Regulations and the California
Department of Health Services (DHS) Drinking Water Standards for.
sulfate concentrations. The ground water also exceeds the EPA
Drinking Water Regulations and the California DHS Recommended
Drinking Water Standards for chloride concentrations. As a
result this, grpundwater could not be used for drinking water
without substantial treatment.
As an additional safeguard, the Proposed Plan includes monitoring
for moisture using neutron probes. Any failure of the cap and/or
drainage system will be indicated by moisture detected by the
probes and will alert EPA to the necessity of repairing the cap
and/or altering the drainage system.
The plan as proposed meets all applicable or relevant and ap-
propriate federal and State requirements (ARARs) . Federal
regulations require asbestos waste to be capped but do not re-
quire asbestos to be placed in a lined vault or a lined landfill
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(40 C.F.R. Sections 61.153 and 61.156). Asbestos ore waste that
is contaminated with nickel has been classified as a class B min-
ing waste by the State of California. Title 23, Chapter 3, Sub-
chapter 15, Section 2570 (b) of the California Administrative
Code states that N[a] regional board may exempt a mining waste
pile from the liners and leachate collection and removal systems
required in this article if the discharger can clearly
demonstrate to the regional board that the leachate will not form
in or escape from the waste management unit." Section 2570 (c)
provides that regional boards may exempt a mining waste manage-
ment unit from certain requirements if a comprehensive
hydrogeologic investigation demonstrates that Hi) there are only
very minor amounts of ground water in the area; or ii) the dis-
charge is in compliance with the applicable water quality control
plan; and iii) either natural conditions or containment struc-
tures will prevent lateral hydraulic interconnection with ...
municipal beneficial uses." As explained in the Record of Deci-
sion (ROD) and the RWQCB's Memorandum of April 7, 1989, the WMU
to be built on the Site has been exempted from these liner and
leachate requirements, pursuant to Cal. Admin. Code Tile 23,
Chapter 3, Section 2570.
A.1.6. Comment; An elevated crown on the WMU will have a nega-
tive economic impact on Coalinga because it will be a "visual
blight1* which will discourage development in the Site area.
A.1.6. Response; The Record of Decision has modified the
Proposed Plan to require that the WMU cap be as close to grade
as is feasible. This should minimize any negative visual impact.
A.1.7. Comment; The City of Coalinga questioned whether the City
is a Potentially Responsible Party (PRP). As of March 23, 1989,
the City had not received any formal notification that it was a
PRP.
A.1.7. Response; EPA has notified the City of Coalinga of its
status as a PRP pursuant to Section 107(a) of CERCLA in a general
notice letter dated May 10, 1989.
A.1.8. Comment The City of Coalinga would like any decision
which assigns future liability to ensure that Coalinga does not
inherit liability by default it there are no PRPs in existence at
some time in the future.
A.1.8. Response; EPA will deal with the issue of liability in
the enforcement process. If the City of Coalinga is determined
to be a responsible party, it will be jointly and severally li-
able for all costs associated with the clean up.
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A. 1.9. Cpfwrent* The City is concerned that if land owned by
Coalinga is used by SPTC to stockpile waste material during con
struction of the WMU, the city nay have liability if SPTC sud-
denly quits work in the middle of the project.
A. 1.9. Response; The land owned by the City of Coalinga in the
proposed stockpile area contains raw asbestos waste piles that
contain up to 98 area percent asbestos by PLM. As was noted in
the response to comment A. 1.8 above, if the City of Coalinga is
determined to be a responsible party, it will be jointly and
severally liable for all costs associated with the clean up.
Therefore, Coalinga 's liability will not change if this area is
used to stockpile contaminated soil. The ROD does not specify
where contaminated material is to be stockpiled. That decision
will be part of the remedial design.
A. 1.10. C/TTRTirent* The Mayor and City Council members stated that
EPA has attempted to pressure the City into accepting the
Proposed Plan by suggesting that making changes in the plan might
delay the start of construction. The City representatives indi-
cated that this would penalize the City for making legitimate re-
quests .
A. 1.10. Response; EPA has indicated to the City that making
changes to the Proposed Plan could cause delays in the start of
construction. It was not the Agency's intent, however, to penal-
ize the City in any way, but merely to alert City representatives
to the procedures and delays involved in altering the Plan. The
WMU design in the Record of Decision has been modified to some
extent in accordance with requests by the City. For example, the
modifications requested by Coalinga relating to the above ground
height of the WMU required a specific waiver by the RWQCB. The
process of obtaining this waiver necessarily led to some delay in
initiating clean up.
A. 1.11. Comment; In response to EPA's comment during the public
meeting that the clean up might be delayed by summer heat, the
Mayor noted that work could be performed at night and that summer
heat should not be an excuse to delay the start of the clean up.
A. 1.11. Response ; Delays in the issuance of the Record of Deci-
sion have made it likely that the work on the remedy will begin
in the fall and that summer heat will not be a factor in delaying
the clean up. It should be noted, however, that working with
respirator protection in very hot weather can be dangerous for
on-site workers. In addition, the limited visibility available
when using a respirator may make it dangerous to operate heavy
equipment at night. If the clean up were to be performed during
the summer months, the need for an expedited clean up to protect
public health would have to be balanced against the need to
protect the health and safety of on-site workers.
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8
A. 1.12. qonnnenti The Mayor suggested that because the OUFS was
prepared by a contractor employed by the Southern Pacific
Transportation Company (SPTC), that not all of the feasible al-
ternatives were fully explored. The Mayor was concerned that the
contractor tried to mitigate the economic impact on SPTC, thereby
"casting a considerable cloud on the process."
A.1.12. Response; As required by lav, the OUFS was conducted
under EPA oversight in accordance with EPA regulations and
guidance. Careful oversight by EPA ensured proper preparation of
the OUFS. EPA has determined that the alternatives were ade-
quately evaluated in the OUFS.
A. 1.13. gQTnffl«j»nt« The Mayor requested a fifteen (15) day advance
notice of any final decisions regarding the Site.
A.1.13. Response; EPA does not provide formal notice of the
Record of Decision for public comment. However, EPA has con-
tinued and will continue to communicate with City representatives
on a regular basis concerning the Site and any decisions concern-
ing the Site remedy.
A.2 COMMENTS BY CITY COUNCIL MEMBERS AT TEE PUBLIC MEETING ON
FEBRUARY 22, 1989
A.2.1. Comment; City representatives stated that the City of
Coalinga will need some technical advice from an environmental
attorney or an environmental consultant and that they do not
believe that the City should have to pay for that cost.
A.2.1. Response; If Coalinga decides to hire an attorney or a
consultant, the City will have to bear that cost. There is no
mechanism for EPA to pay that cost. Although EPA does offer
technical assistance grants (TAG) of up to $50,000.00 to com-
munity groups in areas near Superfund sites, the TAG is not
available to municipalities (40 C.F.R. Section 35.4030(a)(4))or
potentially responsible parties (40 C.F.R. Section
34.4030(a)(1)), such as the city.
A.2.2. Comment; The public agencies seem to be more concerned
with protecting endangered species, protecting non-potable ground
water and protecting the health of on-site workers than they are
with protecting the health of the people of Coalinga. It doesn't
seem right that clean-up should be delayed so that more studies
can be done about endangered species when people are breathing
asbestos-laden air.
A.2.2. Response; Under its emergency removal authority
provided by CERCLA Section 106(a), EPA was able to require spray-
ing of salient on the asbestos piles and restrictions on access,
thereby substantially reducing the immediate hazards at the Site.
8
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CERCIA Section 106 authorizes EPA to require such actions quickly
to respond to situations posing an imminent and substantial en-
dangerment. Long term remedial response actions, however, must
meet applicable federal and State requirements, such as the En-
dangered Species Act and the Occupational Health and Safety Act,
in accordance with CERCIA Section 121(d). Compliance with these
applicable or relevant and appropriate laws can require time con-
suming studies and planning.
A.2.3. Comment; Is a 21 day public comment period legal?
A.2.3. Response: CERCIA Section 117 requires a reasonable op-
portunity for public comment on the proposed plan. EPA initially
decided to use a 21 day public comment period in order to ex-
pedite the cleanup process. In response to public concern that
this time period was inadequate, the comment period was extended
for an additional 22 days, for a total public comment period of
43 days.
A.2.4. Comment! What, if any, land use restrictions will be im-
posed on properties adjacent to the WMU?
A.2.4. Response! EPA will require all land use restrictions
necessary to protect the integrity of the cap and drainage system
of the WMU, in order to protect public health and the environ-
ment. Land use restrictions will apply to the area of the cap.
A.2.5. Comment! The public comment period did not allow ade-
quate time to examine documents. The OOFS was not available in
the repository for review when public comment period opened.
A.2.5. Response: As mentioned previously, the public comment
period was extended from March 2, 1989 to March 24, 1989 to allow
additional time to examine the OUFS, the Proposed Plan and the
Administrative Record. Several copies of the OUFS were mailed by
Federal Express to the Coalinga Public Library on February 8,
1989. To the best of EPA's knowledge, the OUFS was available in
the Coalinga Public Library on February 9, 1989 as scheduled. As
noted above, however, the full Administrative Record was not
available at the Coalinga Public Library until February 23, 1989.
A.2.6. Comment: if the City Council categorically rejects the
option of locating the WMU within the City limits, what are the
other options? The City of Coalinga should not be responsible
for the clean up.
A.2.6. Response! Community acceptance is one of nine criteria
on which EPA evaluates alternative remedies under CERCLA. As
discussed above in Response A.1.4 the OUFS for the City of
Coalinga Operable Unit contained detailed evaluations of five al-
ternative remedies. Four of these alternatives did not involve
disposal in an on-site WMU. As was noted in Response A.1.4, the
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10
ROD describes the bases for EPA's determination that an on-site
WMU is the best remedy under the circumstances. If it is deter-
mined that the City of Coalinga is a responsible party, the City
will be jointly and severally liable for the costs associated
with the selected remedy.
A. 2. 7. Comment;; What is the earthquake rating of the vault?
What did the geotechnical studies show about the location of
Holocene faults in relation to the proposed vault location?
A. 2. 7. Response: The WMU is designed to be stable in the event
of the maximum credible earthquake expected in the Coalinga area.
The earthquake experienced in the Coalinga area in May of 1983
had a maximum peak ground acceleration of .54 g. The WMU is
designed to be stable at a ground acceleration greater than or
equal to .7 g. The Holocene faults which were active during the
1983 earthquake were not expressed at the surface in the City of
Coalinga. No holocene faults have been documented at or near the
WMU Site. A geologist registered by the State of California will
be present at the Site during excavation of the WMU area to con-
firm that no faults exist in this area.
A. 2. 8. Comment ; EPA standards for asbestos may change in the
future. If less than or equal to 1 area percent asbestos by PLM
is no longer considered clean in the future, what will happen to
the Site?
A. 2. 8. Response; If new studies of the effects of asbestos
revealed that the health based performance level relied upon in
the ROD was not protective of public health or the environment,
EPA would reevaluate the situation and take appropriate action.
A. 2. 9. Comment ; Is the WMU classified as a Class 1 hazardous
waste landfill? Who owns the land where the WMU is going to be
located? Are SPTC and SPLC the same company?
A. 2. 9. Response ; The WMU is not classified as a Class 1 haz-
ardous waste landfill and the waste at the Site is not a Class 1
waste. SPTC owns the property where the WMU will be located.
SPTC and SPLC were previously part of the same company; they are
currently separate corporate entities.
A. 2. 10. Comment ; The closing of Polk Street and the transport
of contaminated material to the WMU area must be done using
strict asbestos handling protocol.
A. 2. 10. Response; EPA will oversee every phase of WMU con-
struction and transport of contaminated material. State and
federal regulations regarding transport of asbestos contaminated
material will be complied with when material is transported to
the stockpile area. This includes wetting down the material,
covering the trucks, and ensuring that no spillage occurs. The
10
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11
route that the trucks take while transporting the contaminated
material is a detail of the plan that will be resolved during the
design phase.
A. 2. 11. comfflen.V City Council members want to ensure that
drainage off of the WMU is carefully controlled to avoid flooding
problems .
A. 2. 11. Response: EPA will insure that the design of the WMU
includes adequate drainage.
A. 2. 12. C
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12
B.2. Response ; Asbestos and nickel are measured by different
methods using different units on different scales. Asbestos is
measured using a variety of different units depending on the
medium being sampled (i.e. air, soil, water, insulation material,
etc.). Nickel is measured in milligrams (mg) per liter or mg.
per kilogram. In addition, while sampling performed at the Site
has found a range of levels of each contaminant, there has been
no measurement of the total volume of either contaminant at the
Site. As a result, a direct comparison of the amount of asbestos
and nickel waste present is not possible.
B.3. Cftfrcqnt ; Who pays for the EPA time on this Site and the
cost of operation and maintenance?
B.3. Response i As noted above, EPA will deal with the issue of
liability in the enforcement process. Those PRPs who are deter-
mined to be liable for the clean up will be responsible for all
costs associated with remediation of the Site, including EPA's
costs and operation and maintenance costs.
B.4. Comment ; The New Idria Serpentine Mass, one of the largest
asbestos deposits in the world, is located near Coalinga in the
mountains. Asbestos from this formation washes down throughout
the whole area, so isn't there greater than one percent asbestos
all over the place in Coalinga?
B.4. Response; Naturally occurring asbestos is present in the
Coalinga area. EPA is not able to address any hazard which may
be posed by this naturally occurring material and is limited to
cleaning up asbestos which is present at the Site as a result of
human activities. EPA has determined that the large volume of
asbestos that is present at the Site was deposited there as a
result of the milling, mining and transport of asbestos. The
Operable Unit Site was a major shipping depot for asbestos. As-
bestos ore and other mining materials were brought in from the
mines to Coalinga and then shipped out by train and truck. EPA
has determined that the high concentrations of asbestos at the
Site are the result of improper disposal and handling of asbestos
containing material during these activities. These facts bring
the substances at the Site within the purview of CERCLA and a
clean up of the asbestos at the Site to health based levels is
therefore appropriate.
B.5. Comment : Is the chromite ore in the Marmac warehouse ad-
dressed in the clean up plan? Is the chromite ore considered a
mining waste? The chromite ore should be considered a resource
and not a waste.
B.5. Response; The Proposed Plan provides that the chromite ore
in the Marmac warehouse will be disposed of in the HMU unless a
plan for its recycling or reprocessing is approved by September
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15, 1989 and the material is removed for recycling or reprocess-
ing by October 16, 1989. Analysis of the chromite ore indicate
that the chromium content is too low for it to be considered a
hazardous waste by the State of California. However, because the
chromite ore is contaminated with asbestos at levels exceeding
one area percent by PLM, it is a hazardous substance under
CERCLA.
B.6. pQ^nrent* One community member suggested that the waste be
put in the pit at the Granite Rock Company quarry.
B.6. Response; The Granite Rock Company has no connection with
the asbestos waste in the City of Coalinga. It is unlikely that
a company with no liability for the Site would allow contaminated
material to be placed on its land. Further, it would violate
State and federal laws to dispose of the material in such a
fashion. For example, this action would violate Cal. Admin. Code
Title. 23, Chapter 3, Subchapter 15, which requires Class B min-
ing wastes to be disposed of in a WMU with an impermeable cap.
C. COMMENTS MADE BY PRPs IX LITTERS TO EPA AND IN COMMENTS
DURING THE PUBLIC MEETING
C.I. CgrcrnenV The public comment period did not allow the PRPs
adequate time to examine documents, develop a response and/ or
make a good faith offer.
C.I. Response : Eighteen PRPs were notified of their potential
liability in letters from EPA sent in the spring of 1988; the
City of Coalinga was notified of its status as a PRP in a letter
dated May 10, 1989. PRPs were also provided with notice of the
public comment period on the OUFS and Proposed Plan which began
on February 9, 1989, and of the extension of that comment period
until March 24, 1989.
Eighteen PRPs were notified in a letter dated February 22, 1989
that they would have until March 28 to make a good faith offer to
perform the remedial action. While this period is substantially
shorter than the sixty days provided for under the special notice
procedures of CERCLA Section 122 (a), the use of those procedures
is discretionary. In this case, EPA chose not to employ those
procedures because of the immediate nature of the hazard at the
Site. While preliminary steps have been taken to address the
hazard, EPA determined that the clean up of this Site should be
expedited in light of the significant remaining risk to the
public health and the environment.
C.2. Comment ; What are the EPA costs to date on the City of
Coalinga Operable Unit project?
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14
C.2. Response; EPA costs as of February 2, 1989, were in excess
of $89,000.00. This amount does not include costs incurred by
SPTC to conduct the feasibility study and draft the Proposed
Plan.
C.3. Comment; Marmac Resources, Inc. questioned the profes-
sional credibility of IT Corporation (the contractor for SPTC
which performed the feasibility study), inferring that because IT
stands to benefit from high enough readings to require cleanup,
and since its measurements are open to some 'subjective
adjustments', self interest may have been a factor in its
reports.
C.3. Response; All sampling and analyses have been conducted
under strict EPA oversight using Agency procedures, including
quality control/quality assurance and chain of custody proce-
dures .
C.4. Comment; The OUFS does not specifically address the poten-
tial risk to public health and the environment from short fiber
chrysotile asbestos and nickel contaminated soil. No risk as-
sessment was performed and therefore the OUFS cannot be con-
sidered complete. Without a complete OUFS, adequate evaluation
of alternatives cannot be done.
C.4. Response; The ROD and other documents in the Administra-
tive Record analyze the risk at the Site and the ability of the
different remedial alternatives to address this risk. EPA's
guidance explicitly recognizes that the level of effort ap-
propriate to performing a risk assessment at a given site depends
on many factors, including the concentration and identity of sub-
stances, the number of exposure pathways, the likelihood that the
"no action" alternative will be chosen (if it is likely that the
no action alternative will be chosen, a more thorough risk as-
sessment is necessary). Draft RI/FS Guidance, March 1988, at
3-36 to 3-37. Chrysotile asbestos contamination of soils and the
presence of asbestos ore waste and nickel-contaminated waste at
the Site have been confirmed by extensive sampling. Asbestos is
one of the few known human carcinogens. One pathway is of most
concern: inhalation. The uncontained asbestos-contaminated
materials are located very close to a population center; without
remediation the receptor population, which includes young
children, may. be subjected to daily exposure. The OUFS and the
supporting Administrative Record clearly establish that an im-
minent and substantial risk to the public health is present at
the City of Coalinga Operable Unit. Given all of these factors,
it was extremely unlikely that the no action alternative would be
chosen. Considering all relevant factors, the analysis of Site
risk contained in the Administrative Record meets both the terms
and the spirit of EPA's requirements.
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15
Based on extensive experience at numerous other asbestos-
contaminated Sites, EPA determined that accurately quantifying
baseline risks and the reduction in risk at asbestos-contaminated
sites due to various alternatives is beyond the present
capabilities of environmental science. A risk assessment has
been conducted for the Atlas and Johns-Manville Superfund Sites
to fulfill NCP requirements, which is in part applicable to this
operable unit and will be added to the Administrative Record.
However, EPA deemed it inadvisable to unnecessarily delay the
release of the OUFS and Proposed Plan while awaiting the release
of this risk assessment, as it is peripheral to our understanding
of the situation in the City of Coalinga and the best way to ad-
dress it.
C.5. comment; The evidence linking ingestion of asbestos with
adverse human health effects is weak.
C.5. Response; EPA is most concerned about the risk to human
health from inhalation of asbestos at this Site; these risks have
been widely documented. EPA has also concluded that there is
evidence that ingestion of asbestos may also pose a significant
risk to human health. Results of studies investigating the link
between ingestion of asbestos and cancer have been less con-
clusive. However, in a National Toxicology Program (1984) bioas-
say, male rats ingesting intermediate range chrysotile fibers had
a significant increase in benign, epithelial neoplasms in the
large intestine. EPA considers evidence that a substance causes
benign tumors as an indication that the substance is a possible
carcinogen.
C.6. Comment: Marmac Resources commented that cleanup, of the
warehouse area will not solve the airborne asbestos problem in
Coalinga.
C.6. Response; EPA has determined that although there is
naturally occurring asbestos in the Coalinga area, that the as-
bestos in the warehouse area of the Site was deposited there as a
result of human activity. Therefore a clean up of this hazard is
appropriate, as explained in Response B.4. above.
C.7. Comment; Marmac Resources commented that the asbestos in
the warehouse area was brought there by natural environmental
forces or by other PRPs.
C.7. Response; See Response B.4. above regarding human
transport of the asbestos found at the Site. The issue of
transport of asbestos to the site by other PRPs as opposed to
Marmac Resources will be dealt with in the enforcement process
and is irrelevant to EPA's selection of the remedy for the Site.
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16
C.8. Comment t Marmac Resources commented that the chromite ore
in the warehouse area of the Site presents no hazard, or imminent
and substantial endangerment to human beings.
C.8. Response: Testing of the chromite ore revealed that
chromium content was sufficiently low that the presence of that
metal did not pose a hazard. However, sampling also demonstrated
that the chromite ore was contaminated with asbestos. It is the
asbestos content which is the basis for EPA's determination that
the chromite ore must be handled as a hazardous substance.
C.9. CfrW'TrP*! ; Marmac Resources commented that the chromite ore
waste in the warehouse is a strategic mineral which could
properly be classified as an exempt non-hazardous mining waste
and should be excluded from the Proposed Plan.
C.9. Response ; Three companies were contacted by ATEC
(consultants to SPTC) regarding disposal of the chromite ore,
during the Hazardous Substances Containment Study. Analyses of
samples from the chromite ore pile indicated that metal con-
centrations were too low to be of any commercial use. None of
the companies contacted could use the chromite ore. However, the
ROD does allow for the possibility of recycling or reprocessing
of this material. See also Response C.8., above.
C.ll. Comment; Vinnell Mining and Minerals Corporation (VMMC)
stated that the sealing of asbestos contaminated material to tem-
porarily suppress dust on the Site should be considered as a
remedial action alternative.
C.ll. Response; The spraying of biodegradable sealant on the
asbestos-contaminated material was an interim action designed to
reduce airborne asbestos during the detailed Site investigation.
It was not considered as a possible remedial action alternative
for the following reasons. Selection of this remedy would vio-
late ARARs and, therefore, would not comply with CERCLA Section
121. The National Contingency Plan also contains a strong bias
towards long-term solutions. Spraying with a sealant which has
to be reapplied on an annual basis does not meet this criteria.
Second, spraying with sealant to contain the asbestos would also
require significant land use restrictions on large areas
throughout the Site. The community has indicated that it does
not favor a remedy that would result in such land use restric-
tions. .....
C.12. Comment ; VMMC commented that without air monitoring in
Coalinga after the spraying of the sealant, it is not possible to
judge whether the spraying has had the desired effect of reducing
airborne asbestos in the Coalinga railway corridor. If the
sealant spraying has not reduced airborne asbestos, then it fol-
lows that the source of asbestos in Coalinga must be other nearby
or regional sources .
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C.12. Response : As mentioned previously, sealant spraying was a
temporary action to stabilize the asbestos contaminated areas
while evaluating feasible remedial alternatives. Sealant spray-
ing was never intended to be the final remedial action; there-
fore there was no need to conduct post-spraying air monitoring.
Even if such air monitoring had been conducted, it would not
yield conclusive data due to the many environmental variables in-
volved. The ROD includes extensive confirmation soil sampling to
ensure that the clean up meets the specified goals.
C.13. gpmment; Representatives for VMMC believe that the Asbes-
tos Hazard Emergency Response Act (AHERA) has been misapplied.
The OUFS applies the one percent AHERA criterion to all samples
as opposed to bulk samples.
C.13. Response; In the ROD, EPA determined that less than or
equal to 1 percent by PUf is an appropriate, health-based cleanup
level for this Site regardless of the AHERA standard. EPA relies
on the AHERA ARAR only for the use of PUi as an appropriate
method of measuring asbestos area percent. The OUFS was incor-
rect in this regard. The PI* method, as contained in AHERA, is
the only EPA-approved Method for measuring asbestos levels in
bulk samples, i.e. bulk samples of friable insulation materials,
as distinguished from air or water samples.
C.14. Comment; VMMC commented that details of the regional air
modeling should be included in the OUFS or be made available as
separate technical memoranda.
C.14. Response; The regional air modeling is part of the ongoing
Remedial Investigation at the Atlas Mine and Johns-Manville
Coalinga Mill Superfund Sites. Details of this modeling will be
presented in the RI for those Sites. EPA did not rely on the
details of the regional air monitoring in selecting a remedy for
the City of Coalinga Site. ......
C.15. Comment; VMMC commented that the screening of feasible al-
ternatives in the OUFS was incomplete.
C.15. Response; EPA has determined that the OUFS presents a
thorough evaluation of the feasible alternatives. The alterna-
tives and the factors used to evaluate them are described in the
ROD. See also Response A. 1.4.
C.16. Comment; VMMC commented that detailed design work on the
WMU has been proceeding before public comments on the OUFS were
received.
C.16. Response; The ROD is a conceptual document that describes
a remedial alternative in general terms. A PRP remains free to
begin design work at their own expense and risk at any point. As
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of the date of ROD signature, no agreement has been entered into
between EPA and any PRP which authorizes work on the remedial
design.
C.17. Cpp^girt ; Atlas Minerals Corporation commented that it was
interested in participating in the process of cleaning up asbes-
tos and nickel contaminated material in Coalinga.
C.17. Response; EPA will deal with the issue of PRP participa-
tion in the clean up process in the enforcement process. Par-
ticipation is not relevant to selection of remedy.
C.18. Cpffnent* Atlas Minerals asked how many PRPs had entered
into Consent Agreements concerning this Site and which ones were
involved in preparation of the OUFS.
C.18. Response; To date no parties have entered into any agree-
ments with with EPA regarding the Site. EPA has sent letters to
eighteen PRPs inviting them to present good faith offers to and
negotiate settlements with EPA. Negotiations are ongoing at this
time. SPTC conducted a Site Characterization and prepared the
OUFS for the Site with EPA oversight, pursuant to an Administra-
tive Order issued to them by EPA.
C.19. Atlas Mineral Division of Atlas Corporation raised the
following questions in a 24 page letter, from Konrad W. Harper of
Simpson Thacher to Jon K. Wactor of EPA, dated March 23, 1989:
C.19. a. Comment ; Do the data, within analytical and sampling er-
ror, demonstrate that the 210 West Glenn Street property cur-
rently is contaminated with asbestos generated by historical
warehouse activities.
C.19. a. Response ; The Administrative Record contains data which
demonstrates that the West Glenn Street property is contaminated
with asbestos in excess of 1 area % and up to 80 area % by PI2f.
The history of the Site indicates that the asbestos contamination
at the Site is a result of human activity, including activity at
the historic Atlas warehouse and distribution center.
C.19.b. Comment ; Is the Glenn Street property posing an unaccep-
table asbestos health risk?
C.19.b. Response; Yes. The high levels of asbestos present on
the property post an unacceptable health risk, especially through
the inhalation pathway. The ROD and other documents in the Ad-
ministrative Record elaborate on the nature of this risk.
C.19.C. Comment ; Is remediation of the Glenn Street property
necessary?
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C.19.C. Response; Yes. Remediation of the contamination at the
property is necessary to protect human health and the environ-
ment.
C.19.d. C9T*W?nt ; Is remediation of the Glenn Street property
cost-effective?
C.19.d. Response; CERCIA Section 121 (a) requires that the
response action be cost-effective. The cost-effectiveness of the
remedy selected for this Site is documented in the ROD and the
Administrative Record.
C.19.e. CQFTrent ; Could the asbestos detected at the Site be as-
bestos wind-blown from other locations or asbestos resulting from
activities at the Site since 1966?
C.19.e. Response; Evidence collected by EPA and contained in the
Administrative Record indicates that it is extremely unlikely
that the asbestos at the Site could have been blown there from
other locations. Samples were taken at the Site with concentra-
tions of asbestos as high as 98 area % by PUf. On the Glenn
Street property concentrations as high as 80 area % by Pllf were
found. Activities subsequent to 1966 may have contributed to
some of the contamination in some parts of the site.
C.19.f. Op™?*? nt ; Why is the WMU designed above grade?
C.19.f. Response; The WMU was originally designed to be above
grade in order to maximize drainage. The ROD requires the WMU to
be constructed to be as close to grade as is feasible.
C.19.g. Comment ; Is the WMU containment structure, as designed,
necessary?
C.l9.g. Response; Yes. Some of the design criteria are required
by ARARs. The technical bases for other design criteria can be
found in the Administrative Record. See correspondence with the
Regional Water Quality Control Board throughout the Administra-
tive Record.
C.l9.h. Comment ; Why is the WMU containment structure not located
in existing rights of way
C.19.h. Response ; See Response A. 1.3.
C.19.i. Comment; Why did EPA not discuss the preferred alterna-
tive prior to the public meeting?
C.19.1. Response; EPA did discuss the preferred alternative (i.e.
the proposed plan) in the fact sheet that it distributed 13 days
prior to the public meeting to all parties who had expressed an
interest in the Site. Furthermore, this alternative was dis-
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cussed in detail with many of the members of the Coalinga City
Counsel, at previous City Counsel meetings, and in meetings with
all known PRPs, including representatives of Atlas, prior to the
start of the public comment period.
C.19.J. Comment; • Why is the public comment period extremely
limited?
C.19.J. Response: The original public comment period was limited
to expedite final clean up of a substantial endangerment to
public health. EPA extended the public comment period to 43
days, which is longer than that provided at many other sites. The
43 day period provided a reasonable opportunity for public com-
ment.
C.19.k. C7ffff?nt; What is meant by the short and long term effec-
tiveness of the preferred alternative as discussed?
C.19.k. Response; The meaning of short and long term effective-
ness of a remedy is discussed in A Guide to Developing Suoerfund
Records of Decision (July 1988) . "Short term effectiveness ad-
dresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be
posed during the construction and implementation period, until
cleanup goals are achieved." P. 3 "Long term effectiveness and
permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup goals have been met." P. 3.
C.19.1. Comment ; What are the current regional and site-specific
human and environmental risks, and can they be quantified?
C.19.1. Response; The risks at the Site and the problems with
quantifying them are accurately are discussed in the ROD, includ-
ing Appendix 1, and the Administrative Record. See also,
Response C.4.
C.19.m. Concient ; After implementing the preferred alternative
plan, what reduction in human and environmental risks would be
realized?
C.19.m. Response: The risks at the Site and the problems with
accurately quantifying any reduction in risk as a result of the
remedy are discussed in the ROD and Administrative Record. The
risk associated with potential exposure to extremely rich asbes-
tos ore waste will be significantly reduced. See also Response
C.4.
C.19.n. Comment ; What environmental and human benefits will be
achieved with the implementation of the preferred alternative?
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C.19.n. Response : The preferred alternative will contain the haz-
ardous substances under an impermeable cap. Human health and the
environment will be protected from further contact with the con-
taminants.
C.19.0. comment: After the preferred alternative is implemented,
what quantifiable and effective reduction in toxicity risk or
mobility of contaminants will be achieved?
C.19.O. Response : See Responses C.19.m and C.19.n, above,
regarding the difficulty of quantifying risks at the Site. The
remedy will not use treatment to reduce toxicity or mobility but
the selected remedy does effectively reduce the mobility of the
contaminants through containment. The risk of exposure to haz-
ardous substances is also effectively reduced by the selected
remedy.
C.19.p. eo^im^n^i What are the itemized costs associated with
implementing each of the evaluated alternatives?
C.19.p. Response; The estimated costs for the evaluated alter-
natives are as follows:
a) no action: negligible
b) Removal of waste to an abandoned mine site: $9 million
c) Soil cover in place: $600,000 to $800,000
d) Disposal at an off-site landfill: $5.5 million
e) Disposal at an on-site landfill: $2.5 million
The high cost of removal of the waste to an abandoned mine site
is due to the cost of building roads to the mine site. The high
cost of disposal at an off-site landfill is a result of the fees
for disposal at such landfills. The cost for disposal at an on-
site landfill is for construction, including labor, and operation
and maintenance. See also, Responses C.19.ccc and C.19.S.
C.19.r. Comment: What are the detailed plans for implementing ...
the preferred alternative?
C.19.r. Response: A conceptual design is included in Design
Report, Asbestos Waste Management Unit, SPTC, Administrative
Record Doc. I 624. Final Design will be approved by EPA in the
future context of this case.
C.19.S. Comment : What criteria were used to estimate the costs
to implement the preferred remediation plan?
C.19.S. Response: Specific criteria included the costs of meet-
ing ARARs, local labor rates, materials for construction of the
WMU, labor rates for workers in level C protection, water rates,
and costs of water trucks and enclosed trucks. Guidance For Con-
ducting Remedial Investigations and Feasibility Studies Under
CERCLA (October, 1988) , Evaluating Cover Systems for Solid and
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Hazardous Wastes (September 1982), SW-867 (EPA-D-03), and Design.
Construction and Maintenance of Cover Systems for Hazardous
Wastes; An Engineering Guidance Document. (EPA 600-2-87—039) .
C.l9.t. cgrcmen.1; • what are the itemized costs for conducting the
technical studies by EPA and SPTCo?
C.19.t. Response ; The itemization of these costs is not
relevant to EPA's selection of the remedy at this Site. The con-
cern of this PRP with respect to specific past costs will be
dealt with in the enforcement context, as is appropriate.
C.19.U. CqmpqnV Atlas states that the literature tends to sup-
port the conclusions that the health risks of short fiber asbes-
tos are less than those of long fiber asbestos and that such
risks are less for chrysotile asbestos than for other forms of
asbestos.
C.19.U. Response: EPA considers short fiber asbestos and long
fiber asbestos to be equally carcinogenic; ample evidence in the
Administrative Record supports this view. EPA disagrees that the
literature supports an opposite view. The recent Asbestos Ban
Rule specifically supports EPA's position in this regard. See Ad-
ministrative Record Document I 1105.
C.19.V. Comment t What are the regional asbestos health issues?
C.19.V. Response: The ROD and documents in the Administrative
Record explain the relationship between the regional health
issues and the Site. The Remedial Investigation for the Atlas
Mine Site further addresses these issues; a complete understand-
ing of all region-wide issues is not necessary to select a remedy
to address the immediate health risk at this Operable Unit.
C.19.W. Comment; What are the asbestos regional and local back-
ground concentration levels?
C.19.W. Response; Background concentration levels vary depend-
ing on proximity to the New Idria Serpentine Mass, meteorological
conditions, human dust generation activities, and other factors.
Regional air monitoring indicated elevated levels of asbestos in
ambient air samples collected in Coalinga compared to background
levels collected in Hanford, California. The detailed data on
these levels are contained in the Administrative Record.
C.19.X. Comment; What health risks are associated with short-
fiber asbestos? Does the chrysotile asbestos found in the
Coalinga region induce an unacceptable health risk? Is the
chrysotile asbestos carcinogenic?
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0.19.x. Response: Asbestos is a known human carcinogen. Al-
though there is substantial disagreement in the scientific com-
munity over which forms of asbestos are the most hazardous and
carcinogenic, EPA has determined, based on the best available
evidence, that the asbestos at the Site presents an imminent and
substantial endangerment to human health and the environment that
requires remediation. See also, Response C.19.U.
C.19.y. Comment; Are short asbestos fibers less of a health
risk than long asbestos fibers, and if so, what health risk has
been introduced by historical warehouse activities in the City of
Coalinga?
C.19.y. Response; See Responses C.19.U and C.19.X. for the
answer to the first part of this question. The apportionment of
responsibility among Potentially Responsible Parties is not
directly relevant to EPA's selection of the remedy. EPA will ad-
dress these enforcement related concerns in the enforcement con-
text. See also, Response C.19.JJJ.
C.19.Z. commit ; what are the historical and current asbestos
health risks in the City of Coalinga?
C.19.Z. Response : See Responses C.19.y, C.19.X, C.19.U, and
C.4, as well as Appendix 1 to the ROD.
C.19.aa. Comment : What exposure and health risks associated with
the asbestos are found within the study area?
C.19.aa. Response: The main pathway of exposure to asbestos at
the Site is through inhalation, although ingestion also repre-
sents some risk. To the best of EPA's knowledge, epidemiological
surveys have not been performed in the Coalinga area.
C.19.bb. comment- Does the preferred remediation plan mitigate
asbestos exposure as well as unacceptable health risks?
C.19.cc. Response: The proposed plan mitigates unacceptable
health risks by mitigating exposure to asbestos.
C.19.dd. Comment: Can a cost-effective remediation plan be
implemented, and can the plan be justified?
C.19.dd. Response: Yes. The proposed plan is fully implement-
able from a technical standpoint. As determined in the ROD, the
plan meets all the requirements of CERCLA and the National Con-
tingency Plan, including cost-effectiveness.
C. 19.ee. comment; What is the background nickel concentration?
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C. 19.ee. Response : Background concentrations of nickel in Han-
ford, California were measured at 70 ppm, using the TTLC Wet Ex-
traction Test. Western soils have been documented to contain 16
ppm nickel. Background levels vary depending on proximity to the
New Idria Serpentine Mass, meteorological conditions, human dust
generation activities, and other factors.
C.19.ff. C?lfflM?nt * Is nickel an environmental health risk in the
City of Coalinga?
C.19.ff. Response; Yes. The major environmental health risk from
nickel in the City of Coalinga is from inhalation of nickel-laden
dust. See also, Toxological Profile for Nickel, Admin. Record
Doc. I 668.
C.l9.gg. Pommft^i is the asbestos contaminated with nickel or
is nickel naturally occurring?
C.19.gg. Response ; Data suggest that the nickel is a by-product
of the asbestos milling process. Chrysotile and nickel both oc-
cur naturally in certain rock formations but their occurrence at
the Site is not natural. Nickel is a "contaminant" within the
meaning of CERCLA Section 101(33).
C.19.hh. Comment; Is nickel elevated because of oil drilling
and production activities in and adjacent to the City of
Coalinga? Are the nickel concentrations related to Coalinga 's
petroleum industry?
C.19.hh. Response; No, it is extremely unlikely that the nickel
detected in the asbestos contaminated material is a result of any
activity related to oil production in Coalinga. If there were a
connection, the nickel would be randomly distributed at the Site
and not concentrated only where the asbestos contaminated
material is present.
C.19.ii. Comment ; Is nickel mobile in the existing environment?
C.19.ii. Response; Unless the impounded waste is contacted with
a low pH liquid, soluble nickel is not expected to be mobile in
the existing environment. However, nickel-laden dust or soil at
the Site can be entrained into the atmosphere if soil or dust is
disturbed. Therefore, nickel is mobile in this media at the
Site.
C.19.JJ. Comment ; Is nickel complexed with minerals (e.g.,
nickel chloride, nickel sulfate) other than asbestos?
C.19.JJ. Response; The Wet Extraction Test in this context does
not indicate the complexing relationship of the nickel but simply
the concentration of the extractable nickel present.
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C.19.kk. Comment; Does the nickel concentration pose an unac-
ceptable human health and environmental risk?
C.19.kk. Response ; Yes.
C.19.11. qonpngnt' If the preferred plan is implemented, will
health risks be cost-effectively reduced?
C.19.11. Response: Yes. CERCLA Section 121 requires that the
selected response action be cost-effective and protective of
public health and the environment. In the ROD, the Regional Ad-
ministrator determined, based on the Administrative Record, that
the selected alternative is a cost-effective means to protect
public health and the environment.
C.19.mm. Comment ; What are the health risk exposures/pathways
related to nickel concentrations?
C.19.mm. Response: At the Site, exposure via ingestion and in-
halation of nickel dust are the exposure pathways of concern.
C.19.nn. CQflmtnt- Are high nickel releases related to chromite
ore warehouse activities?
C.19.nn. Response ; EPA is aware of no evidence that this is the
case.
C.19.00. c?^?nt; was a chemical pathway data analysis per-
formed?
C.19.OO. Response; See Responses A. 1.5, A. 1.6, C.2, and C.4.
C.19.pp. Comment ; Was a contaminant/ leachate water balance
analysis performed which demonstrated percolation through the im-
permeable asbestos? If so, did the results show an unacceptable
human health or environmental risk?
C.19.pp. Response: No, a contaminant/ leachate water balance
analysis was not performed. However, a detailed hydrologic study
was done to assess vertical conductivity between the surface and
the upper aquifer. This included data on
precipitation/ evaporation rates, permeability of individual sub-
surface layers and characteristics of fluid movement in soils.
This study concluded that even without an impermeable cap, the
potential for movement of fluid from the impounded waste to the
upper aquifer was remote. Asbestos is not impermeable. Asbestos
is not soluble in water and is not expected to move out of the
WHU into the subsurface. The concern of the EPA and the RWQCB
with respect to subsurface contamination is the possibility of
movement of soluble nickel in percolated water. The impermeable
cap will prevent water from entering the impounded waste, making
the formation of nickel containing leachate unlikely. Further,
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EPA and RWQCB are confident that the WMU is adequately isolated
from the upper aquifer by several impermeable clay layers in the
subsurface.
C.19.qq. Cj2ifflgn£: What toxicological evaluations have been per-
formed, and what were the conclusions?
C.19.qq. Response; See Response C.4. and the nickel and asbes-
tos toxicity profiles in the Administrative Record.
C.lS.rr. Comment: What design components of the WMU are at-
tributable to the disposal of nickel, and what are the associated
costs?
C.19.rr. Response; The low permeability of the cap and the
neutron probes to detect moisture within the the impounded waste
are design components attributable to the presence of nickel.
The exact costs attributable to these design components cannot be
determined until final design is approved by EPA.
C.19.SS. Comment; Atlas comments that a waiver from ARARs
should have been considered, and that more data should have been
collected to justify such a waiver.
C.19.ss. Response; EPA determined that a waiver from ARARs was
not appropriate for this Site. Atlas does not indicate why a
waiver would be appropriate or even what waiver might be ap-
propriate, so EPA is constrained from replying in any more
detail.
C.19.tt. Comment: Why are asbestos and nickel relationships not
adequately discussed?
C.19.tt. Response; The relationship between asbestos and nickel
is adequately discussed in the OUFS for purposes of remedy selec-
tion. A positive correlation between the asbestos contamination
and the presence of nickel at the Site is demonstrated by the
data contained and discussed in the Hazardous Substance Contain-
ment Report which is included in the Administrative Record.
C.19.uu. Comment; In addition to background concentrations,
what are the other sources for nickel levels found in the soils?
C.19.uu. Response; EPA has determined that nickel levels in ex-
cess of background at the Site are a by-product of the asbestos
milling process.
C.19.W. Comment; Will nickel have an impact on drinking water
supplies?
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C.19.W. Response; The City of Coalinga gets its drinking water
from the California Aqueduct; nickel is not expected to impact
drinking water supplies. See Response A. 1.5. However, the
nickel could have a negative impact on other beneficial uses of
the aquifer, including irrigation. See correspondence with the
Regional Water Quality Control Board throughout the Administra-
tive Record.
C.19.ww. Comment; Will nickel have an adverse impact on the
water quality in the uppermost aquifer?
C.lS.ww. Response ; See Responses A. 1.5. and C.19.W.
C.19.xx. £ojsQeji£: What are the cost-effective attributes as-
sociated with the design of the preferred mitigation plan?
C.19.xx. Response; The OUFS and the ROD both describe the
cost-effectiveness of the proposed plan.
C.19.yy. Cqrcmflnt1 What chemical pathways of nickel have been
demonstrated that will result in quantifiable contamination to
the environment and a quantifiable health risk?
C.19.yy. Response; It is unclear what is meant by chemical
pathways of nickel in this context. EPA assumed that the com-
menter meant to refer to exposure pathways. The exposure path-
ways of concern are inhalation of nickel-laden dust and soils,
ingestion of nickel-laden dust and soils, and ingestion of
nickel-laden ground water. The proposed plan will mitigate ex-
posure through all of these potential exposure pathways.
C.19.zz. Comment ; What is the chemical fate of nickel in the
existing environment?
C.l9.zz. Response ; It is unclear what is meant by chemical fate
of nickel in this context. The concerns regarding nickel at this
Site include leaching of soluble nickel into the ground water and
entrainment of nickel contaminated dust and soil into the air.
C.19.aaa. Comment; The Administrative Record does not show
technical comments and acceptance of the RI/FS and OUFS by the
State of California.
C.19.aaa. Response; The State has concurred in the selected
remedy. See Admin. Record Doc. f 1094.
C.19.bbb. Comment ; Atlas comments that the City of Coalinga has
not approved or accepted the preferred containment plan, and al-
leges that "[t]he City of Coalinga, as represented by its
citizenry and public officials at the February 22, 1989 public
meeting, disapproved the EPA administrative and technical
processes used to prepare the preferred containment plan."
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C.19.bbb. Response; Community acceptance of the remedy is not a
threshold or primary balancing criteria, rather it is a modifying
criteria. See A Guide to Developing Superfund records of Deci-
sion (July 1988) page 3. EPA's consideration of community con-
cerns is described in the ROD. The procedures followed by EPA in
selecting the remedy for this Site were in full compliance with
CERCLA Section 117 's requirements regarding public participation.
EPA also consulted with the City throughout the process of study-
ing the Site and selecting a remedy, beyond the minimum require-
ments set forth in Section 117.
C.lS.ccc. CQp^qnt* Atlas alleges that the following information
is "missing" from the RI/FS Administrative Record:
1) Detailed description of the data which define con-
taminant sources and their pathways of migration, as well as
potential sources of contaminants.
2) A risk assessment which determines the contaminants of
concern, their toxicity, potential exposure levels affecting
potential receptors, mechanisms of exposure, and potential ef-
fects .
3) Detailed costs for all evaluated remediation alterna-
tives .
4) Detailed listing of all PRPs and the justification for
including each of them.
5) Detailed itemization of all existing landowners and the
records regarding historical ownership.
6) Detailed itemization of all existing tenants and the
records regarding historical tenancy.
7) Detailed itemization of study costs.
C.19.CCC. Response; For a response to the issues raised by Sub-
parts 1 and 2 of this Comment, see Response C.4. With respect to
Subpart 3 of this Comment, the total cost of each alternative is
what is considered in determining cost-effectiveness, rather than
a detailed cost breakdown. Subparts 4 through 7 of this Comment
are not appropriately raised in this context because they do not
relate to the basis for selection of the remedy at this Site.
The Administrative Record was prepared pursuant to CERCLA Section
113 (k) (2) and contains the information "on which the President
[or the President's delegatee, EPA] will base the selection of
removal actions and on which judicial review of removal actions
will be based." CERCLA Section 113 (k) (2) (A) . The opportunity to
comment, provided pursuant to CERCLA Section 113 (k) (2) (B) (ii) is
an "opportunity to comment and provide information regarding the
plan." The questions raised by this portion of the Comment are
all enforcement related and are more appropriately dealt with in
the enforcement context, not in comments on the proposed plan.
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C.lS.ddd. ?9F*i*y nt ; The only copies of the Administrative Record
readily available to Atlas were located in the EPA Region IX
library and in the public library for the City of Coalinga. At-
las did not receive a copy until March 1989.
C.19.ddd. Response; Pursuant to Section 113(k)(l) of CERCLA, EPA
is required to keep a copy of the Administrative Record at or
near the Site. EPA not only complied with this statutory re-
quirement, but also made a copy of the Administrative Record
available at the EPA Regional Office. Furthermore, EPA staff
supplied copies of many of the principle documents, as well as
much of the relevant information, to Atlas' representatives in
meetings prior to the start of the public comment period.
C.19.eee. CQlintnt* Atlas alleges that EPA "refused access* to
technical data used by EPA, and refers to a Freedom of Informa-
tion Act ("FOIA") they "filed . . . with EPA on July 3, 1988."
Atlas also states that EPA failed to provide it with a copy of
the transcript of the February 22, 1989 public meeting.
C.19.eee. Response ; Atlas granted EPA extensions on the time to
comply with the FOIA request. Also, Atlas has specific rights
under FOIA, including appeal rights, to protect any concerns that
it had or has about Region 9's response to FOIA requests or other
requests for documents. Furthermore, EPA staff supplied copies
of many of the principle documents, as well as much of the
relevant information, to Atlas' representatives in meetings prior
to the start of the public comment period. Without further
elaboration by Atlas regarding its concerns about access to data,
EPA cannot give a more specific response to this comment. EPA
complied with CERCLA Section 117 's requirements regarding par-
ticipation by the public, including Potentially Responsible
Parties. See Responses C.19.ddd., and C.19.J.
C.19.fff. Comment: Atlas alleges that N[t]he technical data
used to generate EPA's . . . RI/FS have been collected over the
last ten years." (page two of Atlas' letter); Atlas comments •
that it was not given an opportunity to participate in EPA's data
collection activities.
C.lS.fff. Response ; It is unclear what document Atlas is refer-
ring to in this comment. The RI/FS for the Atlas Mine Site is
still ongoing. The data for the Operable Unit Feasibility Study
for this Site was generated over the last two years. Not until
the public meeting of March 22, 1989 did Atlas offer to perform
or take part in response actions at the Site. Atlas was notified
of its status as a Potentially Responsible Party in March of
1988. Prior to the PRP search activities, the whereabouts of At-
las were unknown to EPA.
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C.19.ggg. £Qinffl?Tlt - Atlas alleges that it was not given an op-
portunity to participate in the design of a cost-effective
remediation plan.
C.19.ggg. Response; Atlas was notified of its status as a PRP
in March of 1988. At a minimum, Atlas has had an opportunity to
participate in the selection of a cost-effective remedy through
the submission of its 24 page comment letter; this opportunity
was provided pursuant to Section 113 (k) (2) (B) of CERCLA.
C.19.hhh. Comment; Atlas alleges that in the 1980s EPA conducted
an investigation of the asbestos issues in the City of Coalinga
and determined that asbestos must be removed.
C.19.hhh. Response ; This comment misstates the facts. Regional
air monitoring in the Coalinga area in 1986 and 1987 indicated
elevated levels of airborne asbestos in the City of Coalinga.
Based on this information, EPA initiated an investigation in the
City of Coalinga to determine if localized sources were respon-
sible for these elevated ambient air levels. During the course
of this investigation, several hot spots of asbestos contamina-
tion were identified in the area of the Site. EPA did not decide
to do a complete remedy at the Site until this investigation was
completed.
C.19.iii. genimpnfe ; Atlas alleges that asbestos concentrations
are less than 1 area % in most samples for the Glenn Street por-
tion of the Site, and that only one quality assurance sample
showed an asbestos concentration as high as 2 % TEM. Atlas fur-
ther alleged that the initial results showed less that 1 area %
concentration within the immediate area of the Atlas warehouse.
C.19.iii. Response; The detailed Site investigation indicated
that the Glenn Street portion of the Site is contaminated with
asbestos at levels exceeding two area percent and up to 80 area
percent by PLM. These data are included in the Hazardous Sub-
stance Containment Report which is in the Administrative Record.
The levels of asbestos contamination found in the initial Site
investigation were high enough to require further study, which
indicated dangerously high levels of asbestos present. The Glenn
Street Property is the portion of the Site closest to residential
areas.
C.l9.jjj. Comment ; Beginning in the middle of page 21 of their
letter and continuing up to the concluding paragraph on page 24,
Atlas includes a discussion and questions which are entirely en-
forcement related.
C.19.jjj. Response; These comments do not address the bases for
EPA 's remedy select ion. As explained in Response C.19.ccc above,
the purpose of this public comment period is to provide an oppor-
tunity for interested members of the public to comment and
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provide information regarding the proposed plan. See CERCIA Sec-
tion 113 (k)(2)(B)(ii). This is an inappropriate context for a
PRP to seek information regarding enforcement-related topics.
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REVIEW OF ASBESTOS ANALYTICAL METHODS
I. Asbestos Analytical Techniques
There are three commonly accepted analytical methods used to
measure asbestos. They are:
1) Phase Contrast Microscopy ("PCM"): An optical technique
useful in examining minute particles.
2) Polarized Light Microscopy ("PLM"): An optical tech-
nique that uses polarized light to identify minerals.
3) Transmission Electron Microscopy ("TEM"): A technique
using excitation of electrons to achieve extremely high resolu-
tion of asbestos fibers too small to be resolved using optical
methods.
A brief description, including the advantages and disadvantages
of each technique, is presented below.
A. Phase Contrast Microscopy
Phase contrast microscopy ("PCM") is a method of optical micros-
copy that is commonly used to analyze air samples collected in
the work place (e.g. in enclosed spaces). PCM translates dif-
ferences in the phase of light transmitted or reflected by the
object into differences of intensity in the image. The method is
better suited to analysis of work place air than ambient air be-
cause in the work place one encounters a relatively large con-
centration of large bundles of asbestos fibers. Most of the
available medical studies of asbestos diseases have measured as-
bestos using PCM. This is because PCM was the only technique
available when most of the occupational studies were done.
The PCM technique has two major limitations concerning its use in
the ambient environment. The method cannot detect fibers with
diameters of less than 0.2 micrometers. Many fibers in the en-
vironment are much smaller than this. Also, PCM does not distin-
guish between asbestos fibers and other types of fibers. There-
fore, 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 unsuitable for
measurement of asbestos fibers in ambient atmospheres.
The major advantages of PCM are: i) it is relatively inexpensive
and; ii) it is easy to use PCM data to calculate health-based
risk in an occupational environment using the models established
in the older studies.
APPENDIX 1
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B. Polarized Light Microscopy
Polarized Light Microscopy ("PLM") is the EPA-approved method of
analysis for bulk insulation samples. The PLM technique is rela-
tively quick (1/2 hour/sample) and provides a reliable method to:
(1) identify all asbestos types, (2) distinguish between asbestos
and other fibrous and non-fibrous minerals and (3) identify most
non-asbestos components of samples. The resolution capacity of
PLM is 200x to 400x magnification. Another advantage of PLM is
that it can be performed for a relatively low cost.
There are two ways to do PLM analysis, the point counting method
and the field comparison method. The point counting method uses
a superimposed grid (gravicule) with 100 points. The operator
counts the points where asbestos is present. The method (point
count) involves the preparation of eight slides, each of which
can be viewed at 100 possible points, to establish the presence
or absence of asbestos at 50 points on each slide. The result
is recorded and reported as area percent based on the number of
positive points. The following format is used for determination:
Area percent = a/n (100)
where:
a = number of points with asbestos fibers present
n = number of non-empty points counted.
The field comparison method, also called "visual estimation" or
the 2-minute method with the stereobinocular light microscope, is
used to quantify a large sample (e.g., 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 is usually done by visual
estimate (field comparison) or point counting, and is
thus qualitative or at best, semi-quantitive; concentra-
tion is expressed as the ratio of asbestos to non
-asbestos particles or percent by area.
o Small fiber identification is difficult because certain
optical properties (birefringence and the angle of ex-
tinction) are hard to determine in small fibers.
o The smallest fibers that can be observed are ap-
proximately 0.34 micron in diameter; fibers this small,
though observable, cannot usually be identified for
mineral type.
o Highly skilled analysts are required, particularly in
view of the subjective nature of the determinations.
o The quantitative limit of detection is 1 area percent.
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Using PLM to identify asbestos in soils can be difficult because
soils are subjected to erosion and weathering; asbestos bundles
become separated and broken into smaller, possibly sub-optical,
sizes much more quickly than fiber bundles in relatively undis-
turbed insulating materials. Asbestos fibers may also be dis-
persed by wind and by seasonal flooding. Therefore, a sizeable
fraction of the asbestos fibers in soil could be below optical
resolution, on the other handf Pm is the only method of measur-
ing asbestos with an EPA approved methodology for sampling and
analysis. Therefore, it is the one analytical method that can be
adequately controlled in a quality assurance/quality control
plan. Also it is significantly less expensive than TEM analysis.
C. Transmission Electron Microscopy
Transmission electron microscopy ("TEM") is the most powerful
analytical method available for measuring asbestos. TEM can be
used for air, water, or soil analysis. It is the preferred in-
strumental technique for measuring asbestos in ambient atmosphere
since it incorporates the most powerful combinations of iden-
tification methods. TEM analysis uses electron microscopy, at
magnifications of 10,000 to 50,000 times, to detect asbestos to
the single fibril level. Fibers as small as 0.2 nanometers in
diameters can be identified. Besides the transmission electron
microscope, which allows the operator to locate very small
fibers, this technique can also utilize two mineral identifica-
tion tools. These are selected Area Electron Diffraction
("SAED") and Energy Dispersive X-ray Analyzer ("EDXA"). Using
these tools, the operator can identify the mineral type from a
single point on the specimen.
The disadvantages associated with TEM include the following:
o No widely accepted TEM method is available for the
analysis of asbestos in soils, making it difficult to
correlate interlaboratory data. Sample preparation
methods are not standard among workers, making the
comparison of results between sites or laboratories
very difficult or meaningless.
o Analysis requires a minimum of 6 to 8 hours over 2 to 3
days. Highly skilled analysts are required and large
. differences in results can occur due to operator
variance. TEM analysis is extremely expensive, over 20
times the per sample cost of optical methods.
o Sample size is very small. Therefore, data must be
extrapolated to a great extent to adequately
characterize a large site.
o Typically, total fibers are counted. Sample preparation
(i.e., grinding) destroys the fiber size distribution.
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TEM sample preparation alters the soil matrix. This is sig-
nificant because the sample is dispersed into very fine particles
before it is put onto a filter for analysis, since asbestos oc-
curs in clusters and bundles as well as fibers, the sample
preparation process (in the case of soil) can destroy the struc-
ture of those forms and produce a very large number of individual
fibers of small size. Although total fibers are counted as part
of the TEM analysis, these results must be converted to weight
percent, using data on length, width, and density. This conver-
sion to mass is necessary due to the sample preparation grinding
process, which artificially increases the fiber count. How the
TEM weight percent compares with air emissions and risk tables
has not been standardized by government or industry. Therefore,
interpretation of soil data results relative to air samples
and/or risk charts is very difficult, at best.
II. Problems with Using Asbestos Data in Quantifying Risk
Although the role of asbestos as a cause of cancer is clear, the
ways in which fibers cause disease are not well understood, and
this has complicated efforts to measure asbestos successfully.
Asbestos researchers have not agreed upon which attributes of as-
bestos are important to measure to assess risk, including size
and shape of individual fibers, number of fibers, total mass of
fibers, inclusion of asbestos bundles, clusters, and matrix
debris in the fiber count, and asbestos mineralogical type. For
example, most researchers think that longer, thinner asbestos
fibers (those longer than 5 microns in length with an aspect
ratio greater than 3 to 1) are more 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 fibers may play a role in causing dis-
ease. Further, there is disagreement whether mineral type is a
factor in disease causation. Some would argue that chrysotile
asbestos may partially dissolve in weakly acidic environments,
facilitating fiber clearance from the lung. However. EPA's view
is that all asbestos mineral types are equally carcinogenic.
To compound the problem, analysis of ambient samples for asbestos
is much more difficult than occupational or work place samples,
because the concentration of asbestos in the environment is much
lower. Asbestos fibers found in ambient air are typically too
short and thin to be detected by conventional microscopes, and
may be agglomerated with other particulate matter so that they
are masked or hidden. Further, although EPA has attempted to
standardize asbestos analytical techniques, differences in sample
handling, preparation, instrument capabilities, operator
proficiency, and counting procedures make it extremely difficult
to compare results from different laboratories. In short, ac-
curate measurement of asbestos is impeded by many factors,
greatly complicating any estimates of environmental risk. For
this reason clean UP levels have been estajjl
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analytical methods for which an approved methodology
exists. The following discussion summarizes the rationale behind
choosing the one area percent by PLM clean up level.
III. Clean U Goals for the Citv of Coalino rhie unit-.
Problems with asbestos analytical techniques make establishing
health-based clean up levels very difficult. As mentioned above,
the clean up level of one area percent by PLM has been chosen be-
cause it is the best available analytical technique for which
there is an EPA approved protocol. This is further evidenced by
the fact that EPA chose to utilize PLM as an analytical method
under the Asbestos Hazard Emergency Response Act ( "AHERA" ) .
EPA has chosen the one area percent clean up level for the City
of Coalinga Operable Unit because one area percent is the
generally accepted detection limit for asbestos in soil using
PLM. One area percent by PLM has also been used in the past as
an action level in emergency response situations. This level
will provide protection to public health and the environment.
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/Vi e m o r ci n c" u sn
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD 'CENTRAL VALLEY REGION
3614 E. Ashlan SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116
Fresno. CA 93726-6905 State Lease Line: 421 -5116
TO: Ruben Moreno FROM: Michael R. Mangold
Senior Engineer Staff Engineer
_.__ . cirMATiiaF-
DATE: 7 April 1989 SIGNATURE.
SUBJECT: . DESIGN REPORT, ASBESTOS WASTE MANAGEMENT UNIT, SOUTHERN
PACIFIC TRANSPORTATION COMPANY, COALING A, FRESNO COUNTY
I have reviewed the subject design report as prepared by IT
Corporation for Southern Pacific Transportation Company (SPTC) .
SPTC proposes to construct a waste management unit (WMU) for
disposal of Group B mining waste.
Background
SPTC is working with the Environmental Protection Agency (EPA)
under a Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) order for a mining waste site (approximately
107 acres in area) located in the City of Coalinga. Cleanup of the
site will include excavation and removal of an estimated 20,000 ft3
of asbestos ore and contaminated soils. This waste has been
classified as Group B mining waste and will be disposed into an
appropriate waste management unit as delineated in Section 2572,
Title 23 of the California Code of Regulations (Subchapter 15) .
International Technology (IT) Corporation prepared a report
characterizing local hydrology and geology for SPTC to be used as
the basis for design of the proposed asbestos WMU. The report's
objective was to provide information necessary to:
1. Determine whether the wastes . should be disposed of as
Group A or B mining wastes.
2. Provide a basis for design of the disposal facility.
3. Determine the level of monitoring necessary to satisfy
Subchapter 15 requirements.
Following staff's review of the report, the following
determinations were made.
1. The mining waste is classified as Group B waste.
2. Clay liner and leachate collection system may be exempted
for the proposed unit.
APPENDIX 2
, i .1 '•.. ..U f "7,00I
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Southern Pacific Transportation Co. Page 2
WMU Design Report
3. Groundwater monitoring could be minimized in favor of a
vadose zone monitoring network that incorporates neutron
probe technology to detect potential discharges from the
WMU.
4. Excavation of the WMU should be monitored to assure that
the WMU remains in compliance with Subchapter 15 siting
requirements.
Based upon the site characterization and staff's review of
applicable or relevant and appropriate requirements (ARARs), the
following items were requested.
1. A preconstruction report including construction details
and quality assurance and quality control procedures for
the excavation, filling, and capping of the proposed WMU.
2. A water quality monitoring plan for the proposed vadose
zone monitoring network including locations and details
of monitoring points and a plan for implementation of
groundwater monitoring.
To this end, SPTC has submitted this report.
Design
The WMU will have a design capacity of 25,000 ft3. Top surface
area of the WMU will be 272 ft. by 222 ft., with a bottom elevation
of 671.5 ft. or 20 ft. below the existing ground surface. Side
slopes will be constructed at a 3:1 ratio. A 20-foot wide
embankment will be constructed around the unit to raise the top
level of the WMU to adjacent topography following removal of the
contaminated soil in that location. The embankment will have a 2
percent slope to promote runoff away from the WMU.
Closure Plan
Final cover of the landfill will consist of the following (from
bottom to top):
*A two-foot foundation layer consisting of waste materials
or clean fill compacted to 95 percent of maximum dry
density. This layer will be graded at 4 percent slope.
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Southern Pacific Transportation Co. Page 3
WMU Design Report
*A 1/4-inch thick bentonite mat (Claymax, or an equivalent)
placed on top of the foundation layer. The report indicates
that this mat is an engineered alternative to the prescriptive
standard of a one-foot layer of compacted clay having a
permeability of IxlO"6 cm/a or less.
*A minimum of one foot of soil cover placed on top of the mat.
This layer will be compacted to obtain 95% of maximum dry
density.
*A final layer consisting of 4 inches of concrete asphalt
compacted to 92% of the average density of the Maximum
Theoretical Specific Gravity. The report states that grading
will be at 4 percent to facilitate runoff from the WMU;
however, from recent discussions with the EPA, a smaller slope
may be used.
Indications are, the area above the WMU might be used as a parking
lot or as a long-term storage facility.
As mentioned previously, the report indicates the bentonite mat is
an engineered alternative to the prescriptive standard of a layer
of compacted clay. Section 2510 (b) of Subchapter 15 states that,
"unless otherwise specified, alternatives to construction or
prescriptive standards contained in this subchapter may be
considered. Alternatives shall only be approved where the
discharger demonstrate that:
1. The construction or prescriptive standard is not feasible
as provided in subsection (c) of this section.
2. There is a specific engineering alternative that
(A) is consistent with the performance goal
addressed by the particular construction or
prescriptive standard and
(B) affords equivalent protection against water
quality impairment."
Subsection (c) states that, "To establish that compliance with
prescriptive standards in this subchapter is not feasible for the
purposes of subsection (b) of this section, the discharger shall
demonstrate that compliance with a prescriptive standard:
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Southern Pacific Transportation Co. Page 4
WMU Design Report
1. Is unreasonably and unnecessarily burdensome and will
cost substantially more than alternatives which meet the
criteria in subsection (b) of this section; or
2. Is impractical and will not promote attainment of
applicable performance standards.
Feasibility Issue
The report indicates that a compacted clay layer is not practical
for the following reasons:
1. Investigations performed in the area showed that a source
of clay is available at 20 feet below existing grade.
However, costs for obtaining . the clay would be
exorbitant.
2. Cost of obtaining the borrow clay from other sources are
also extremely expensive due to high transportation
costs.
3. Quality of borrow clay from outside sources is
questionable and may not be obtainable within the time
frame of the project.
Engineering Alternative Issue
The consultant believes that the bentonite mat (Claymax) is
consistent with the performance goals addressed by the prescriptive
clay liner and provides equivalent protection against water quality
impairment. The following reasoning was provided to support this
position.
*Permeability tests performed on Claymax by Geoservices Inc.,
(an independent lab) have demonstrated a permeability of
2 x lO'10 cm/a.
*Based on equivalent seepage velocity, Claymax of 1/4-inch
thickness is equal to an infinite thickness of compacted clay
liner with a permeability of 1 x 10"* cm/s.
*Based on equivalent breakthrough time, the 1/4-inch Claymax
is equal to at least 2 feet of compacted clay with a
permeability of 1 x 10"6 cm/s.
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Southern Pacific Transportation Co. Page 5
WMU Design Report
*The Claymax is more flexible than a compacted clay liner and
can handle large deformation without causing cracking.
The report further states that Claymax is manufactured under
controlled conditions and is readily available to the site.
Furthermore, handling and installation of Claymax is easier and
faster than compacted clay.
Information on comparison studies (performed by Geoservices, Inc.)
between Claymax and a compacted clay liner are included in
Appendix F and 6 of the design report.
Vadose Zone Monitoring
Vadose zone monitoring will exist beneath the site to provide an
early detection system for possible migrating contaminants
emanating from the landfill. Neutron probes were selected to
detect any changes in moisture content directly beneath the site.
Vadose zone monitoring will consist of pulling the probes through
two access tubes installed beneath the site. The locations and
spacing of the access tubes are illustrated in Drawing No.2 of the
design report. The tubes will be spaced 85 feet apart and will be
placed 2 feet beneath the bottom of the WMU.
Soils samples will be extracted every 5 feet along the access tube
trenches and will be laboratory tested to determine native moisture
contents prior to actual installation of the tubes. The locations
for the soil samples will coincide with intervals to be used for
monitoring with the neutron probes. Prior to any discharge of
waste into the WMU, background data will be generated by monitoring
with the neutron, probe each week for four weeks. After this data
is obtained, the monitoring frequency vill be decreased to
quarterly for a period of one year. If no significant changes in
the moisture content are observed after a period of one year, the
monitoring frequency will be again decreased to semiannually.
The design report indicates that results from each monitoring event
will be compared with results from previous vadose zone monitoring
and background data. The report states that in the event that a
significant change in moisture content is observed, an assessment
of the situation will be initiated and the Regional Water Quality
Control Board (RWQCB) will be notified. The report further states
that in the event-that moisture content increases above 5 percent
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