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SFUND RECORDS CTR99399

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IX

75 Hawthorne StreetSan Francisco, CA 94105

ACTION MEMORANDUM

DATE: 26 Sept 2001

SUBJECT: Request for Approval of a Removal Action at Sunland Chemical and HarringtonTools Sites, Glendale, CA

6

FROM: Robert M. Mandel, OSC /(Atf^ W**J\JEmergency Response Office (SFD-6) '

TO: Keith Takata, DirectorSuperfund Division (SFD-1)

I. PURPOSE

The purpose of this Action Memo is to request and document approval of the proposedremoval actions described herein for the Sunland Chemical and Harrington Tools Sites, locatedin Glendale, CA.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPLCategory of Removal: Time-CriticalCERCLIS ID: CAD983566431SITE ID: Harrington Tools Site ID: TBD

Sunland Chemical Site ID: HNState Notification: DTSC

A. Site Description

1. Removal Site evaluationThe U.S. Department of Transportation's John A. Volpe National Transportation

Systems (Volpe) Center has an Interagency Agreement (LAG) with the U.S. EnvironmentalProtection Agency (EPA) Region 9 for environmental engineering and related support. TheVolpe Center, its contractor CDM Federal Programs Corporation (CDM Federal), and CDMFederal's subcontractor Pacific Environmental Services, Inc. (PES), have been requested by EPARegion 9 to conduct focused removal assessments (RAs) at eight locations (i.e., Libby Sistersites). These locations are eight of the twenty-one locations that have been identified as havingreceived ore or vermiculite from Libby, Montana (MT), according to U.S. Geological Survey(USGS) and/or Bureau of Mines publications. Each of the sites has performed either small batchexfoliation, used vermiculite as part of a manufacturing process, or sold vermiculite.

This RA addressed a former W.R. Grace & Company (W.R. Grace) facilitylocated at 5440 West San Fernando Road in Glendale, California. Sunland Chemical andResearch Corp. (Sunland) and Harrington Tools (Harrington) currently own this property. For thepurpose of Action Memorandum, the facility includes both the Sunland property (located at 5440A-C West San Fernando Road) and the entire Harrington property (located at 5420, 5430, and5440 West San Fernando Road). All work for this assessment was conducted in accordance withRevision 1 of the Sampling and Analysis Plan (SAP) for the Libby Sister Sites (Asbestos Project)— Emergency Response and Preliminary Assessment Support (CDM Federal 2001).

The only potential contaminant of concern being investigated at these sites isasbestos, specifically amphibole asbestos (tremolite/actinolite) associated with vermiculite minedfrom Libby, MT. Asbestos fibers are odorless and tasteless and vary in length, structure, andchemical composition. It is believed the toxicity varies with the mineralogy and morphology ofasbestos, however exposure to any type of asbestos can be fatal. Amphibole (tremolite/actinolite)asbestos, the form found at Libby, is considered by many to be the most toxic.

Human health risk from asbestos is primarily due to inhalation exposure toairborne fibers. The objectives of this RA were to determine if any potential sources oftremolite/actinolite asbestos are present at the site and to determine whether any potential sources(vermiculite product, ore, waste, etc.) had been transported offsite either for disposal, privateuses by employees, or direct sale to the public.

Potential sources are likely to be related to contamination from the processing ofLibby ore or vermiculite. Potential sources were investigated by sampling various media (soil,waste/product, ambient air, and dust inside buildings); gathering and verifying current andhistorical information on the site; and documenting any observed evidence of vermiculite productor waste.

2. Physical locationThe sites are located at 5420, 5430, and 5440 West San Fernando Rd., Glendale,

CA.

3. Site characteristicsThe Sites are located on the east side of West San Fernando Road. They are

situated in a mixed commercial, industrial, and residential area. Doran Street borders the Sites tothe north; the Southern Pacific Railroad borders the Sites to the east and industrial properties arelocated to the south and west of the site. Residential and commercial developments are locatedfurther east approximately one-quarter mile from the Sites.

The Sites are comprised of a long, relatively narrow lot on the east side of WestSan Fernando Road (see Figure 2-1). Chain-link fencing is installed around the Sites' perimeter.The Sites are bordered by industrial developments across West San Fernando Road to the westand southwest; Doran Street and Highway 134 to the north; the Southern Pacific Railroad (theRailroad) and San Fernando Road to the east; and a small area of vacant land and CaliforniaAvenue to the south.

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The Sites are developed with five structures. This former W.R. Grace facility(5440 West San Fernando Road) has been subdivided into two parcels. The northern parcel isowned by Sunland Chemical and Research Corp. (Sunland) whose address is 5440A-C West SanFernando Road. The southern parcel is owned by Harrington Tools (Harrington) whose addressesare 5420, 5430, and 5440 West San Fernando Road.

Sunland owns the two northern buildings on the Sites. One is a multi-tenant metalbuilding; the other is an open canopy structure. A storage shed and a planter are located along theeastern portion of the site. The remaining areas on this parcel are mostly paved. The onlyunpaved (soil) areas located on the Sunland property are a small area at the northeast corner and aplanter and small area near the storage shed along the eastern portion of the Sunland property.

Sunland leases the multi-tenant building to the following three tenants: GlendaleCarburetors, a carburetor repair facility (Unit A); Transgas, a facility that sells propane heaters(Unit B); and Action Forklift, a forklift repair operation (Unit C). Sunland's offices are locatedacross West San Fernando Road from the Site. Sunland's operations (across from the Site)include blending and packaging corrosives for various industries. Sunland uses this Site forstorage and parking. Sunland moved onto the Site (the former W.R. Grace property)approximately 15 years ago and then bought the property from Harrington in 1991.

Harrington owns and occupies the three metal buildings on the south end of theformer W.R. Grace property. Harrington manufactures and distributes hand tools for the buildingtrade. The building at 5440 West San Fernando Road is comprised of an office area and awarehouse (Warehouse building). The building at 5430 West San Fernando Road (Plasticsbuilding) is used for plastic molding. This building has a small office area and a largermanufacturing area. Two silos were installed by Harrington outside the southern wall of thisbuilding. They are reported to contain plastic pellets for the manufacturing operations. Tools aremanufactured in the third building at 5420 West San Fernando Road (the Tool/Die building).This building is divided into an office area and a manufacturing area. A storage yard area islocated outside the southern wall of the Tool/Die building. Emphasys International leases thisstorage area from Harrington.

The Harrington property is mostly paved. The only unpaved (soil) areas arelocated along the eastern wall of the Office/Warehouse building, a planter outside the northernwall of the Tool/Die building, and the area along a former railroad spur that runs along theeastern end of the site. Most of the railroad spur has been paved over. In addition, a ramp islocated adjacent to the former railroad spur east of the Warehouse building.

Harrington leased the Plastics building from the Railroad in 1970 and theTool/Die building in 1980. In 1989, Harrington purchased the entire facility from the Railroadand subsequently sold the northern parcel to Sunland in 1991.

4. Release or threatened release into the environment of ahazardous substance, or pollutant or contaminant

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The amphibole asbestos found at all of the locations discussed in this ActionMemorandum is a hazardous substance as defined by Section 101 of CERCLA In general, theEPA has clear and compelling evidence that exposure to the Libby amphibole asbestos can resultin direct health effects. The Site Administrative Record for the Libby, Montana site containsmany academic papers discussing the hazards associated with amphibole asbestos in general, andLibby amphibole asbestos in particular. There are a number of papers, investigations, andmemoranda developed by WR Grace, the owner and operator of the Libby Asbestos Site inLibby, Montana, that document the widespread occurrence of asbestos related disease among itsworkers, both in Libby (41 % of Grace Libby workers with a ten year work history are reported ashaving asbestosis) and around the country (28% of the Grace workers handling Libby vermiculitearound the country are reported as having asbestosis, e.g. see E.S. Wood, 1977, or E. Lovick,1969).

In the Summer of 2000, the Agency for Toxic Substances and Disease Registry(ATSDR) undertook a massive asbestos health screening program involving over 6,000 peoplewho may have been exposed to amphibole asbestos in or around Libby. The report ofpreliminary findings from this study showed the widespread occurrence of lung abnormalities,not only among former Grace employees, but among their families, and the population at large inLibby. ATSDR also published a study on the mortality from asbestosis in Libby, Montana, datedDecember 12, 2000. This study found, among other things, that the reported mortality fromasbestosis in Libby was 60 times the national average. Because of the breadth and depth of theinformation about amphibole morbidity and mortality, a more detailed discussion of these riskwill not be done within this Action Memorandum.

At the Sunland/Harrington Sites, nine soil samples (including the duplicate)contain between 2 and 7 percent tremolite/actinolite asbestos and a trace level to 2 percent ofchrysotile asbestos. These samples represent soils along the eastern wall of the Warehousebuilding and along the former rail spur and soils near the ramp along the Warehouse building andthe plastics building (see Table 4-1).

Table 4-1Results of Soil and Product Sample AnalysisSunland Chemical and Research Corp. and Harrington Tools(Former W.R. Grace Facility) in Glendale, California

Sample IndexIdentification

Sample IdentificationCode

SampleType

Sample Location

AsbestosCone. (%

byVolume)

Type ofAsbestos

Soil Samples

PA1 -00042

PA1 -00043

PA1 -00044

PA1 -00045

PA1 -00046

LSS-C ALA-SO-S01 -0-02

LSS-CALA-SO-S02-0-02

LSS-CALA-SO-S03-0-02

LSS-CALA-SO-S04-0-02

LSS-CALA-SO-S05-Q-02

Comp

Comp

Grab

Grab

Comp

NW Corner of Sunland

Along east side of SunlandCanopy building.Near storage shed on SunlandIn planter along east fence onSunland property.Outside east wall of Warehousebuildinc.

TraceTrace

Trace

Trace

ND

Trace7%

ChrysotileTrem-Act

Trem-Act

Trem-Act

ND

ChrysotileTrem-Act

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PA1 -00047

PA1 -00048

PA1 -00049

PA1 -00050

PA1 -00051

PA1 -00052

PA1 -00053

PA1 -00054

PA1 -00055

PA1 -00056

LSS-CALA-SO-S06-0-02

LSS-CALA-SO-S07-0-02

LSS-CALA-SO-S08-0-02

LSS-CALA-SO-S09-0-02

LSS-CALA-SO-S09-0-02

LSS-CALA-SO-S10-0-02

LSS-CALA-SO-S1 1-0-02

LSS-CALA-SO-S12-0-02

LSS-C ALA-SO-S 1 3-0-02

LSS-CALA-SO-S 14-0-02

Comp

Comp

Grab

Grab

Grab

Comp

Grab

Comp

Comp

Grab

Soil area along east side ofWarehouse building.Soil outside east fence of SunlandBuilding.Under ramp outside the east fencenear the Warehouse bldg.Along asphalt over former railspur south of the Warehouse.Duplicate of sample PA1 -00050.

Along asphalt over the formerrail-spur outside east fence.Under asphalt over the former railspur outside east fence.Outside fence along old trackparallel to Building 3 (Plastics').Outside fence in line with theTool/Die buildingIn a planter outside north wall ofTool/Die building.

Product Samples

PA1 -0037

PA1-0057

LSS-CALA-WP-B02-1-00

LSS-CALA-WP-B02-2-00

Grab

Grab

Attic space above offices inWarehouse building.Spray-applied plaster on officeceiling in Warehouse building.

2%

3%

2%5%

2%

4%

7%

4%

2%

ND

Trace

Trace

7%

Trem-Act

Trem-Act

ChrysotileTrem-Act

Trem-Act

Trem-Act

Trem-Act

Trem-Act

Trem-Act

ND

Trem-Act

Trem-Act

Chrysotile

Note: AH soil samples were analyzed by Polarized Light Microscopy (PLM).

Legend:Cone. = ConcentrationTrace = Less than 1 percent asbestos by visual estimateND = Non-detect; no asbestos detected in the soil sampleTrem-Act = Tremolite/actinolite asbestosComp = Composite sample

All four of the microvacuum samples were found to contain varying concentrationsof actinolite-tremolite and chrysotile asbestos structures. The highest concentration (3,471,238s/cm2 trernolite/actinolite with 357,333 s/cm2 chrysotile structures) was obtained in Sample PA1-0039 from the warehouse storage area inside Harrington's Warehouse building. These resultsindicate that asbestos was airborne in the past. Should these surfaces containing asbestos bedisturbed, the airborne asbestos fibers will expose workers (see Table 4-2).

Table 4-2Results of Microvacuum Dust Sample AnalysisSunland Chemical and Research Corp. and Harrington(Former W.R. Grace Facility) in Glendale, California

Sample IndexIdentification

PA1-0038

PA1-0039

Sample IdentificationCode

LSS-CALA-DU-B02-1 -00

LSS-CALA-DU-B02-2-00

SampleType

Comp

Comp

Sample Location

Three window sills inoffice area of WarehousebuildingThree wall beams inWarehouse building

Number ofAsbestos

StructuresDetected

962

6828

Type ofAsbestos

Trem-ActChrysotile

Trem-ActChrvsotile

AsbestosCone.(s/cm2)

5,74379,124

3,471,238357.333

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PA1-0040

PA1-0041

PA1-0060

PA1-0061

LSS-CALA-DU-B03-1 -00

LSS-CALA-DU-B04-1 -00

LSS-FALA-DU-B04-2-00

LSS-FALA-DU-B04-3-00

Comp

Comp

Blank

Blank

Three wall beams inPlastics buildingWindow sill, shelve, andwall beam in Tool/Diebuilding

Blank

Blank

27

111

1

ND

Trem-ActCbrvsotile

Trem-ActChrysotile

Chrysolite

ND

10,21035,733

5,10556,152

32

ND

Note: All microvacuum dust samples were analyzed by ISO Method 10312.

Legend:Cone. = Concentrations/cm2 = Structures per square centimeterComp = CompositeTrem-Act = Tremolite/actrnolite asbestosND = Non-detect; no asbestos structures detected

Reference: Reservoirs Environmental Services, Inc. Job Number KES-75743-1R

5. NPL statusThis facility is not on the NPL.

B. Other Actions to Date

1. Previous actionsThere have been no previous response actions taken.

2. Current actionsCurrently, there are no response actions underway at the Sites.

C. State and Local Authorities's Roles

1. State and local actions to dateThere have been no State or Local actions.

2. Potential for continued State/local responseAt this time, neither the State or local authorities have expressed a desire to conduct

response actions at the Sites due to limited resources.

m. THREATS TO PUBLIC HEALTH OR WELFARE OF THE ENVIRONMENT,AND STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health, or Welfare of the EnvironmentAdverse effects from exposure have been documented among Grace workers in Libby,

and around the country. There has also been a clear pathology associated with the secondaryexposures. The medical screening conducted by ATSDR last summer clearly documents theoccurrence of significant lung abnormalities among family members of former Grace employees.Likewise, the ATSDR screening also found significant rates of lung abnormalities among peoplewith "recreational" contact with various vermiculite materials that contain the amphiboleasbestos. Overall, the preliminary results of medical screening program to date show that 19 to

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37% of tested participants had visible pleura! abnormalities! Unfortunately, 73% of theparticipants who showed lung abnormalities were not associated with W.R. Grace mining orprocessing activities. Excluding the former miners and their immediate family, the overallabnormality rate was 12 to 24%.

There is evidence that Grace workers suffered high rates of asbestos related disease attheir processing plants across the country, not just in Libby. Although investigations are in theearly stages, evidence suggests that the family members of those workers, and those livingaround these plants, have also been adversely impacted. There already exists a documented caseof an individual who as a child played in a stockpile of Libby vermiculite in Minneapolis,Minnesota who died from an asbestos related disease at the age of 43, clearly linked to the Libbyamphibole asbestos.

In December 2000, ATSDR published the results from a standardized mortality studybased on a review of a subset of death certificates from the Libby area from 1979 to 1998.Among the studies findings were the following:

-Mortality from asbestosis was approximately 40 to 60 times higher than expected.-Mortality from mesothelioma, a rare type of cancer associated with asbestos exposurealso appeared elevated.

The above discussed information, along with the host of other information has led theEPA to make the following general conclusions: l)Whenever materials associated with Libbyvermiculite can be found in bulk, there will most likely be associated with it high concentrationsof amphibole asbestos; 2) The amphibole asbestos found in the Libby vermiculite is highlytoxic; 3) The amphibole asbestos associated with the Libby vermiculite readily producesrespirable fibers when disturbed; and 4) Any time when there exists a condition such that therewill be people in or around the amphibole asbestos there is a high probability for exposure, andthis probability presents an unacceptable risk to public health.

With this information for background, the following is a discussion on the criteria usedto determine the need for a Removal Action found in the National Contingency Plan at 40 CFR300.415(b)(2) that relate to the conditions now found at the Sunland Chemical and HarringtonTools Sites, Glendale, CA. The evaluation of these factors clearly demonstrates that theconditions at the Site may present an imminent and substantial threat to human health and theenvironment and meet the criteria for initiating a Removal Action under Section 300.415(b)(2) ofthe NCP.

1. Actual or potential exposure to hazardous substances or pollutants orcontaminants by nearby populations or the food chainPotential exposure to hazardous substances by workers and nearby populations could

result from the amphibole asbestos onsite. If the asbestos is disturbed by natural or man-causedactivities it could migrate offsite.

2. Actual or potential contamination of drinking water suppliesThis is not an issue at these Sites.

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3. Hazardous substances or pollutants or contaminants in drums, barrels,tanks, or other bulk storage containers, that may pose a threat of releaseThis is not an issue at these Sites.

4. High levels of hazardous substances or pollutants or contaminants in soils ator near the surface, that may migrateThe outdoor soil contamination is currently unstable and subject to migrating offsite if

disturbed.5. Weather conditions that may cause hazardous substances or pollutants orcontaminants to migrate or be releasedWind or rain could cause offsite migration of the asbestos outdoors at these Sites.

6. Threat of fire or explosionThis is not an issue at these Sites.

7. Availability of other appropriate Federal or State response mechanisms torespond to the releaseOther Agencies lack the authority and resources to respond to these Sites.

B. Threats to the EnvironmentIf the asbestos-contaminated soils migrate offsite they will expose the public to this

dangerous carcinogen.

IV. ENDANGERMENT DETERMINATIONActual or threatened releases of airborne asbestos from these sites, if not addressed by

implementing the response action selected in this Action Memorandum, present an imminent andsubstantial endangerment to public health, or welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action descriptionSoil containing elevated asbestos concentrations will be removed to a depth of one

foot below the surface, the excavation will be back-filled with clean soil, and capped withconcrete or asphalt. Upward-facing horizontal surfaces in buildings where microvacuum samplescontained greater than 10,000 s/cm2, will be microvacuumed to remove any surface asbestos-containing dust. All asbestos will be transported offsite to an approved treatment, storage, ordisposal facility. This will remove the threat of public exposure to the asbestos and eliminate anypathways for migration.

2. Contribution to remedial performanceNot applicable at this time.

3. Description of alternative technologiesAlternative technologies have not been considered at this time.

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4. Applicable or relevant and appropriate requirements (ARARs)Federal ARARs: Offsite Disposal Rule, RCRAState ARARs: None known at this time.

6. Project scheduleThe removal action is expected to begin shortly after the effective date of the

Administrative Order(s) on Consent or Unilateral Administrative Order. .

B. Estimated CostsBecause this removal actions is expected to be undertaken by the responsible parties

pursuant to an Administrative Order on Consent, a detailed cost estimate has not been prepared.Should it become likely that EPA will conduct the removal action, an amended ActionMemorandum will be submitted detailing response costs.

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYEDOR NOT TAKEN

Due to the current lack of response to potentially dangerous concentrations of asbestos atthese sites, any delay in the response will result in continuing human exposure to asbestos.

VII. OUTSTANDING POLICY ISSUES

Pursuant to EPA Guidance on Non-NPL Removal Actions Involving NationallySignificant or Precedent -Setting Issues (OSWER Directive 9360.0-19), dated March 3, 1989,removals involving asbestos as the principal contaminant of concern require Headquarters'Director of the Office of Emergency and Remedial Response consultation and concurrence inorder to promote national consistency within the Superfund removal program. EPA Region 9 hasconsulted with the Office of Emergency and Remedial Response and worked closely withHeadquarters as well as other regional emergency removal response offices during theassessment and investigation of asbestos contaminated vermiculite ore originating from theLibby, Montana Site. Further, Region 9 has consulted with Region 8 when developing actionlevels and the scope of work for the Sunland and Harrington Sites discussed herein. Region 9has received Headquarters' concurrence.

VIE. ENFORCEMENTSee Attachment.

IX. RECOMMENDATIONThis decision document represents the selected removal action for the Sunland Chemical

and Harrington Tools Sites, developed in accordance with CERCLA as amended, and is notinconsistent with the NCP.

Conditions at the Sites meet the NCP section 300.415(b)(2) criteria for a removal. It isrecommended that you approve the proposed removal action. No project ceiling is beingrequested at this time, and no extramural funds are expected to be required. EPA oversight costsare expected to be less than $10,000.

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Approval Signature Date

Keith Takata, DirectorSuperfund Division

Disapproval Signature Date

Keith Takata, DirectorSuperfund Division

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