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Attachment 14 – Attachment 5 of Pamela Sihvola and LA Wood Letter June 7, 2005

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Page 1: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

Attachment 14 – Attachment 5 of Pamela Sihvola and LA Wood Letter June 7, 2005

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Submitted to:

Karen Nelson Project Officer

U.S. Environmental rotecti~n Agency

Contract No. 68-

Prepared by:

Karen Johnson

Date:

San Francisco, California 94104 Tel. (415) 981-281 1, Fax: (415) 981-0801 recycled papel

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Facility (NaLF).

ation on the site and its

environs to assess the threat(s),

NSI, EPA decided that no

Page 4: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

eling activities con

um and tritiated water vapor,

ient air samples collected on an

concentrations that exceed E A's cancer risk screening concentration (see Tables 3-1 and 3-2).

to groundwater, surface water, soil, and soil water both

boundaries and off site (2).

requested that EPA re-evaluate its previous C

ith particular emphasis on radioactive tritium emissions and contami-

's request for re-evaluation was based on the following data an

assumptions:

Analytical data from several media, including soil water, plant-

transpired water, rainwater, and organically bound in

Consideration of the NTL emissions as continuous rather than

historic releases

Us ublic access to contaminated areas

Use of groundwater for

a3 osure to tritium-contaminated rainwater

p9 tritium in the food chain

@3 itiu

e

Page 5: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

ese items are provide

ections 3.1.5 and

gathered as recently as December 1997.

areas-The Soil Exposure Pathway evaluation in this

report recognizes that the eucalyptus grove between the Lawrence Hall of Science (LEIS) and

L is used for public recreation.

ater as a source sater-The HRS evaluates only specific

groundwater uses associated with human demands, i-e., human drinking water supply, irrigation

of commercial food or forage crops (5-acre minimum), commercial livestock watering, an

ingredient in commercial food preparation, commercial aquaculture supply, or supply for a major

or designated water recreation area (excluding drinking water). In addition, the FIRS

Groundwater Pathway only evaluates releases and targets associated with aquifers, which are

defined in EPA's S Guidance Manual (November 1992) as "rock or sediment that is saturated

and sufficiently permeable to yield economically significant quantities of water to wells or

springs." Soil water within 2 feet of the ground surface can be evaluated as a source of

contamination for the HRS Soil Exposure Pathway (see Section 4.4.3, Soil Exposure and Air

athway Conclusions).

S, the ambient air

cument the release and migration of tritiu

samples, not rainwater samples, to ocument a release to

propriate background concentrations or enchmarks to which the values can be

red; therefore, the ambient air samples, not the rai

ection 4.4.3, Soil and Air athway Conclusions.

ile organically bound

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s-Section 4.3.3, Surface athway Conclusions,

itium contamination in water collected y the hydraugers as part o

he storm drain system is not considered a containment for the hydrauger water,

athway for release into the creeks draining L

-Although the potential exposure of Korean paper

mill workers to tritium in the eucalyptus trees that are removed from L E is a valid concern, the

S evaluates releases or potential releases to the environment, which is defined in CERCLA

Section 10 1 (8) as surface water, groundwater, drinking water supply, land surface or subsurface

strata, or ambient air within the United States or under t e jurisdiction of the United States.

During the reevaluation of LBL, the C TW provided EPA additional data and requested

at they be reviewed and included in the re-evaluation (30,3 1). All of the data received by

were reviewed as part of this re-evaluation. here appropriate, the ave been included in

Sections 3 or 4 of this report.

Page 7: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

Station ID

ENV-3

ENV-6g4

ENV- 13A

ENV- 13B

ENV- 13C

ENV- 13D

ENV-LHS

ENV-MRI

No. of Samples

Reported I

Key:

1 Results were not reported if data did not meet quality assurance standards. Excess moisture in the sample prevented the concentrations in some s~rnples from being adequately quantified.

2 Cancer-Risk Screening Concentration (CRSC) for tritium in air is 50 pCifm3. 3 The sampling frequency changed from weekly to monthly in August and September 1995, so fewer samples were

collected in 1996. 4 Station 69A was replaced with Station 69 in October 1996. NS Station was not part of monitoring network in 19%.

Page 8: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

mined more inhrmation was needed

&-... -m See Page 6

FROM PAGE 3

ation..

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Attachment 15 – Attachment 6 of Pamela Sihvola and LA Wood Letter June 7, 2005

Page 10: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

0: st ies: ,

Page 11: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of

(1) All hazard0 te facilities subject to corrective action pursuant to Section 251 87.5 of the Health and Code.

order zone property pursuant to Article of Division 20 of the Health and Safe

rnent of Toxic Substances Control pursuant to Section on hazardous waste disposals on public land.

(4) A!! sites listed pursuant to Section 25356 of the Health and Safety Code. (5) All sites included in the Abandoned Site Assessment Program. (6) A list of all public drinking water wells which contain detectable levels or organic contaminants

and which are subject to water analysis pursuant to Section 4026.2 or 4026.3 of the Heaith and Safety Code.

(B) The State ater Resources Control Board shall compile and update as appropriate, but at least annually, and shall submit to the California Environmental Protection Agency, a list of all of the 1

. - . + .

. .- following: 3 (1) All underground storage tanks for which an unauthorized release report is filed pursuant to

Section 25295 of the Health and Safety Code. (2) All solid waste disposal facilities from which there is a migration of hazardous waste and for

which California Regional Water Quality Control Board has notified the State Department of Toxic Substances Control pursuant to subdivision (e) of Section 13273 of the Water Code.

(3) A11 cease an desist orders issued after January 1,4986, pursuant to Section 13301 of the ater Code, which concern the discharge of wastes which are hazardous materials.

(C) The local enforcement agency, as designated pursuant to Section 18051 of Title 1 of the California Administrafive Cod hall compile as appropriate, but at least annually, and shaH submit to the , California Integrated ste Management Board, a list of at1 solid waste d there is a known mig n of hazardous waste. The California Integrated shall compile the local lists into a stat ich shall be submitted to the Cali

rotection Agency and shall be av e to any person who requests the information.

rotection Agency shall consolidate the information submitted pursuant to this section and distribute it in a timely fashion to each city and county in which sites on the lists are located.

ccepts as complete an application for a n y development project which will be applicant shall consult the lists sent to the appropriate city or coun . .; I 4,. ., , t i e 'acal age:;c.: ind: . ' 1; v;b.ctfier the project ii. - :r,ate;t q ~ '

s ~ncluded on any of the lists c piled pursuant to this section. If the site is included on a list, the list shall be specified on the stat

( his section shall become operative on July 1, 1987.

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I C I T Y L I S T 0 4 / 1 5 / 9 8

DTSC F A C I L I T Y INVENTORY DATA BASE PAGE 45

HAZARDOUS WASTE AND SUBSTANCES S I T E S L I S T SORT B Y C I T Y , S T N A

ASHBY ASHBY ASHBY ASHBY ASHBY ASHBY ASHBY ASHBY BANCROFT BANCROFT

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S E R V I C E S T A T I O N I G H T ' S AUTOMOTIVE

BRIDGEWAY S E R V I C E CHEVRON . WEATHERFORD BMW TEXACO SUPER 7 MACBETH HARDWARE COMPANY P A C I F I C B E L L E N G I N E E R I N G S C I E N C E D A V L I N P A I N T COMPANY TRANSAMERICA DEVAUAL CA DHS LABRATORY F A C I L I T Y CHEVRON KALMAR PROPERTY CLEAR COMM

ACAULAY FOUNDRY LECTROTCOATING I N C - P L A

S T A N ANDERSON S E R V I C E CARDUCCI PROPERTY P A C I F I C S T E E L C A S T I N G A H THOMPSON . CASE ENGINEERS A D M I R A L M O V I N G SYSTE TOLTEC PROPERTY,

WELL CAMERON PROPERTY R E A L E S T A T E S E R V I C E S

U C BERKELEY CLAREMONT C O N T I N E N T A L GAR A L T A B A T E S H O S P I T A L DON AUTO C L I N I C COLLEGE CLEANERS R I P S T E E N PROPERTY LAWRENCE BERKELEY L A B B U I LAWRENCE BERKELEY L A B A L S LAWRENCE BERKELEY L A B B U I LAWRENCE BERKELEY L A B B U I LAWRENCE BERKELEY L A B B U I LAWRENCE BERKELEY L A B B U I LONGFELLOW M I D D L E SCHOOL JACKSON PROPERTY GOSS ROSS DOYLE TRUST S H E L L HOTEL DURANT URBAN D E S I G N S H E R R I C K H O S P I T A L A L T A B A T F A C I L I T Y 21203-1 CHEVRON SOUTHLAND S I T E NO 17296 GREEN V A L L E Y P L A N T R E N T A L 1 RENTAL

L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K A L T N K L T N K L T N K A L T N K A L T N K A L T N K A L T N K L T N K C A L S L T N K A L T N K A L T N K A L T N K A L T N K A L T N K

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Attachment 16 – Attachment 7 of Pamela Sihvola and LA Wood Letter June 7, 2005

Page 14: Attachment 14 – Attachment 5 - 7 of Pamela …...te as appropriate, but at leas ency (CalIEPA), Departrn agemental a list of all of (1) All hazard0 te facilities subject to corrective

IDAY, jANUARY 12, 2001

Facilities in California that handled beryllium or radioactive materials include:

WASHINGTON - The govern- ment identified the hundreds of mills, foundries and factories that did nuclear weapons work during she Cold War in a step yesterday award identifying workers who might qualif'y for compensation be- cause they were made sick by their jobs.

an effort to document every facility that handled the deadly metal beryl-

lium or radioactive materials. David Michaels, the Ehergy De-

partment's top health crifficial, cau- tioned that some of the sites played very minor roles in the! history of weapons production.

For example, while P Ylallinckrodt Chemical Co. in St. Lo1 5s processed thousands of tons of u ranium, Star Cutter Corp. in Farmil Igton, Mich., only had five pieces o f uranium on site for one day while testing a spe- cial saw.

But Energy Secretary Bill Rich- ardson urged sick workers who were employed at the facilities to contact the government.

"The burden of proof is on the government, not t h e worker. We will be open and candid this time, not like in the past ," he said.

The list includes 317 sites that employed 600,OOQ people in 37 states, the Distri, ct of Columbia, _

BILL RICHARDSON Energy secretary

Puerto Rico and the Marshall 1s- lands. Some were government- owned, but most were private com- panies that did business for the En- ergy Department or the Atomic En- ergy Commission.

Ailing workers and the families of many dead workers spent years- pushing the government to take re- sponsibility for illnesses caused by on-the-job exposure to high levels of radiatinn.

any sick workers complained they could not get adequate care because the substances to which they were exposed were considered classified information.

As recently as President Clinton's first term, the government routinely fought worker compensation claims.

Under a program approved by Congress last year, employees of fa- cilities doing Energy Department work who contracted cancer as a result of radiation exposure, as well

General Atomics, La Jolla

--a-- - Sandia Laboratory, Salton Sea Base, anton imperial County Hunter Douglas Aluminum Corp., Riverside Laboratory for Energy-Related Health Research, Davis . - - - - - - - - Laboratory of Biomedical and Envi- ronmental Sciences, Los Angeles

Source: Department of Energy

as those who contracted a lung dis- '

ease from beryllium or silica: can- receive government-paid medical care plus $150,000. The first checks should go out later this year.

any of the privately owned sites ' not performed work for the

gy Department for decades. .

Still to be decided is how the

compensation prog mine which people got sick because of work done for the government

"This is a very sensitive area," sai ard Miller,

Wolyoke, places where the DOE had no con- -

tract for . . . or a mill didn't roll uranium after a certain date, but the buildings remained contaminated."

A complete list of the weapons plants can be found on the Energy Department's eb site, www. eh.doe.gov. The department's toll-free number is (877) 447-9756.