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Mr. Timothy Crandall january 6, 1988 Page Two development of the area dependent upon this water supply would call for the exercise of every caution in disposing of potentially hazardous substances in. an overlying landfill. I have discussed Farm Bureau's concerns with you previously. Although I appre- ciate the diligence with which you have researched this issue, our concerns have not been laid to rest by the results. I understand from our conversations that very little evidence exists regarding the effects of ingesting asbestos fibers, and that what evidence there is was not developed by research specifically testing the safety of oral asbestos intake, but was reported as an incidental by-product of other research. 'There is apparently, however, good evidence that asbestos fibers delivered in solu- tion are taken up by borly tissues, and will accumulate in the gastrointestinal tract. In view of the known high car_cinoqenic/toxic effect of airborne asbes- tos fibers taken up by lung tissue, it would appear to be prudent to do all that is possible to prevent exposure to water-borne asbestos fibers until the possibility of similar carcinogenic/toxic effects on gastrointestinal tissue or other internal organs has been conclusively negated by research directed spe- cifically to that end. You have assured me that, even assuming asbestos fibers present a health hazard if ingested, available filtration data indicate that the natural strata under- lying the proposed MVs will safely prevent movement of the buried fibers into the groundwater. However, I understand that no research has be`n done spe- cifically directed at filtration of water laden with concentrated. asbestos waste. It appears to me that a natural clay layer containing spaces approxi- mately 2 microns in diameter between particles, does not offer a secure barrier to particles averaging .1 micron in diameter, especially when, as here, the clay layer may contain natural sand and gravel lenses. In summary, we believe that there is good cause for concern that the shallow groundwater underlying the Forward , Tncorporated site may be contaminated by asbestos fibers under the pro-,used -:Ian for the disposal of asbestos waste at 1W "Y' and "H." We therefore shall contest these Tentative Waste Discharge Requirements and request that these, Rcquirejnents be placed on the contested calendar , January 29, 1988. Yours very truly, C j� r 2 CAROLYN S. RICHARDSON Associate Counsel CSR:ms cc: Clifford Van Till, President San Joaquin Farm Bureau Fe6cration Robert Cabral, Secretary San Joaquin Farm Bureau Federation Michael J. P•Zachado