20160802 Late Correspondence
City Council (CC)
20160802 Late Correspondence
11/13/2018 9:29:59 AM
11/12/2018 9:11:05 PM
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From: Howard B. Spielman <br />To: Michal Haynes <br />Cc: Tom Frazier; Terry T. Tao <br />Subject: Re: Fwd: Procedure 5 Guidelines and Rule 1403 Notification <br />Date: Friday, July 8, 2016 12:23:47 PM <br />Attachments: hbs.ona <br />Mr. Haynes: <br />SCAQMD's insistence that a Procedure 5 is necessary is puzzling. This presumes <br />that you have concluded there is a need for clean up of ACM, particularly since you <br />apparently no longer feel further assessment is warranted. Discussions with your <br />agency have revolved around whether ACM could be expected to be present in the <br />top 3 feet or even as deep as 15 feet. I need to express to you my professional <br />reservations about your Notice to Comply and this email to which I am responding. <br />As you already know, on November 20, 2015 ALTA Engineering collected 7 hand <br />auger borings ranging from approximately 0.5 to one foot below ground surface. <br />Three were collected from the northern portion of the site, three from the southern <br />portion and one from the center of a soil stockpile at the west end of the site. No <br />asbestos was detected in any of these soil samples. On October 29 and November <br />20, 2015 ALTA collected 15 samples of what appeared to be construction debris from <br />the surface. Only 3 of these were determined to contain asbestos and only one of <br />those, the paper backing of a small piece of sheet vinyl, was friable. <br />On July 1, 2016 the plastic sheet covering was removed and replaced. During this <br />activity I collected 7 site perimeter air samples and walked the entire surface. During <br />the walk I collected 9 samples of observable debris, effectively removing all <br />remaining such debris from the site. The prevailing southerly to northerly breeze <br />persisted throughout the day. The PCM analyses of all of the air samples were non - <br />detect for airborne fibers. The PLM analyses of all of the debris samples were non - <br />detect for asbestos. <br />The above facts represent the only objective information of which I am aware <br />regarding any potential ACM contamination of the site. The weight of evidence <br />strongly suggests that the soil is not ACM nor is there any remaining surface debris <br />that contains asbestos. <br />As an environmental health professional I cannot in good conscience ask my client to <br />spend very substantial amounts of education dollars to further evaluate this site for <br />asbestos contamination or to remediate a site that would appear not to need an <br />asbestos cleanup or removal, and likewise not to need plastic covering and perimeter <br />warning signage and demarkation. <br />So what I need to know is what do you know that I don't know. What information or data do <br />you have and are willing to share that would have justified your issuing the Notice to Comply? <br />Until I can acquire such knowledge that might change my o inion I need to advi <br />in accordance with the knowledge I currently have. RECEIVED FROM <br />AND MADE A PART OF THEIR CO D AT � E <br />COUNCIL MEETING OF <br />n OFFICE OF THE CITY CLERK <br />co �,vnG CARLA MORREALE, CITY CLERK <br />
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