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In August 1986, Cal EPA DTSC conducted sampling at the Equinoa property, confirming the presence of chrysotile asbestos on-site (4). On July 6, 1987, Cal EPA DTSC issued a Notice of Violation and Schedule of Compliance to the RP requiring that immediate dust control measures be taken (12). On March 28, 1988 Cal EPA DTSC requested EPA assistance in mitigating the Equinoa site, on the basis of the risk of airborne exposure to the surrounding community, since the RP had not responded to the order requiring the implementation of dust control measures (13). On April 6, 1988 the EPA TAT conducted a site assessment at the Equinoa property, collecting surface and subsurface soil samples. The TAT sampling confirmed the presence of chrysotile asbestos on-site at up to 70 percent levels, and the widespread presence of subsurface asbestos contamination to a depth of approximately 4 feet (3). The TAT PA also confirmed previous Cal EPA DTSC reports that the RP had failed to comply with county and state orders to implement dust control measures and limit site access (3). In May 1988 Cal EPA DTSC contracted to apply a soil sealant to the friable waste piles on- site to mitigate the immediate threat posed by the site, due to the failure of the RP (Malcolm Equinoa) to comply with its earlier order to implement dust control measures + (4, 12). On May 18, 1988, EPA issued a CERCLA 104(e) order to Malcolm Equinoa to obtain information regarding the operation of the site (14). A 104(e) order was also issued to the Manville Corporation on the same day (15). Manville was not able to respond fully to the questions posed regarding quantities of waste disposed of at the Equinoa site and other operational issues, citing loss/non-existence of records partly resulting from Manville's chapter 11 bankruptcy filing in August 1982, and partly due to the divestment of the pipe division during the same year (8). URS personnel could not locate the response from Malcolm Equina. In August 1988 the U.S. EPA Field Investigation Team (FIT) contractor, ICF Kaiser, reviewed the Cal EPA DTSC PA report dated October 1987 and recommended an emergency removal action due to the high potential for direct contact by the public and on-site farm workers (1). In May1989, the U.S. EPA issued CERCLA 106 Order number 89-09 to the new title holders of the Equinoa property, Lyon Communities (2). This order required the RP (Lyon Communities) to "submit a workplan and schedule of work for the*permanent mitigation of the hazards posed by the presence of asbestos at the site" (2). Work eventually commenced on the site in 1990, with the demolition of the on-site residence and the removal of the non-asbestos debris from the property. The French Camp site URS Consultants, Inc. Page 8