United States Department of the Interior NATIONAL PARK SERVICE NATIONAL RECREATION AREA UNITED STATES NATIONAL PARK SERVICE INTERIOR REGIONS 8, 9, 10 and 12 IN REPLY REFER TO:

1.A.1 SAMO

Memorandum

To: Stan Austin, Director Interior Region 8, 9, 10, and 12

From: Superintendent, Santa Monica Mountains National Recreation Area

Through: Stephen J. Mitchell, PE, Operations/Environmental Programs Branch Chief, Interior Region 8, 9, 10, and 12

Subject: Approval for CERCLA Time-Critical Removal Action for the Burned Building Sites Emergency Clean Up, Santa Monica Mountains National Recreation Area

1.0 PURPOSE AND AUTHORITY

Terraphase Engineering Inc. (Terraphase) has prepared this Time Critical Removal Action (TCRA) memorandum on behalf of Lead Builders, Inc. and the National Park Service (NPS) for a proposed removal of burned debris from the in the Santa Monica Mountains National Recreation Area, California (SAMO; the Site, Figure 1).

The purpose of this Time Critical Removal Action (TCRA) Memorandum is to document the decision by the NPS to conduct a TCRA to mitigate human and ecological exposure to burned building debris and ash resulting from the Woolsey Fire in 2018 in the SAMO in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. 906 et seq. The President has delegated authority under CERCLA Section 104 to the Secretary of the United States Department of the Interior (DOI) by Executive Order 12580, 52 Fed. Reg. 2923 (1987), as amended by Executive Order 13016, 61 Fed. Reg. 45871 (1996), to respond to the release or substantial threat of a release of hazardous substances from properties under the jurisdiction, custody or control of the DOI.

The NPS Pacific West Regional Director has CERCLA Section 104 response authority for the Site to undertake CERCLA response actions, including removal actions, under 42 U.S.C. 906 et seq.

The TRCA will include excavation, removal of ash and burned debris from the Site and proper disposal of the ash and burned debris at an approved disposal facility.

2.0 SITE CONDITIONS AND BACKGROUND

The following sections provide an overview of the Site, including the removal Site evaluation, physical location, Site characteristics, and the potential for a release or substantial threat of a release to the environment.

2.1 Site Description

2.1.1 Removal Site Evaluation

The Site is located in the SAMO and is comprised of the following nine areas where removal action activities will occur: Paramount Ranch, Peter Strauss Ranch, Rocky Oaks, Cooper Brown, Arroyo Sequit, Circle X Ranch, Morrison Ranch, Miller Property, and Dragon Property (Figures 2 through 9).

Site sampling activities are focused on the debris from 32 former structures that were burned during the November 2018 Woolsey Fire (Figures 2 through 9). The NPS completed an assessment of the Site following the Woolsey Fire and determined that the nine areas contained fire related debris, including: vegetation, ash, remnant structures, concrete, metal, trees that prohibit work performance, stumps, household hazardous waste, hazardous and toxic waste, electronic waste, small motorized equipment (lawn mowers, gas- powered carts, chain saws, etc.), and white goods (washers, dryers, refrigerators, etc. (NPS 2019)). Samples of ash from the building debris were collected according to the Sampling and Analysis Plan (Terraphase 2020a) and analyzed to characterize debris for removal. Based on the results of the preliminary ash sampling, there is a possibility that soil beneath some of the remnant structures may be impacted by fire-related debris. After debris removal, post-removal soil samples will be collected beneath the footprints of burned structures to quantify the extent to which contaminants from burned structures affected soil.

2.1.2 Physical Location

The Site is located in the SAMO in and Ventura Counties, California and consists of 182,440 acres of land. The NPS controls 23,620 acres of the SAMO and the California State Park system controls 42,000 acres. The rest of the SAMO is controlled by local agency parks, university study reserves, and private property conservation easements.

2.1.3 Site Characteristics

In November of 2018, the Woolsey Fire destroyed 21,000 acres (88%) of NPS land within the Site, including 269 known archaeological sites, two cultural landscapes and 32 historical buildings. The structures were largely completely burned during the Woolsey Fire of 2018. Debris from the burned buildings consists of ash and burned construction materials and remains in place at each area. The nine project areas where structures were destroyed in the Woolsey Fire and which are the subject of this TCRA are shown on Figure 1. The locations of each of the nine project areas are as follows:

1. Paramount Ranch (see Figure 6. Circle X Ranch (see Figure 6) 2) - 12896 Yerba Buena Rd - 2903 Cornell Rd Malibu, CA 90265

2 Agoura Hills, CA 91301 - 34.109734°, -118.937229° - 34.115508°, -118.756145°

2. Peter Strauss Ranch (see Figure 7. Morrison Ranch (see Figure 7) 3) - Near Cheeseboro Canyon Rd at - 30000 Mulholland Hwy Cheeseboro Rd Agoura Hills, CA 91301 Agoura Hills, CA 91301 - 34.113496°, -118.779316° - 34.154874°, -118.727014°

3. Rocky Oaks (see Figure 4) 8. Miller Property (see Figure 8) - 107 Kanan Dume Rd - 2200 Latigo Canyon Rd Malibu, CA 90265 Malibu, CA 90265 - 34.098123°, -118.813196° - 34.074250°, -118.784160°

4. Cooper/Brown (see Figure 4) 9. Dragon Property (see Figure 9) - 31915 Mulholland Hwy - Near Trancas Canyon Rd at Edison Malibu, CA 90265 Rd - 34.097067°, -118.815981° Malibu, CA 90265 - 34.050842°, -118.852780° 5. Arroyo Sequit (see Figure 5) - 34138 Mulholland Hwy Malibu, CA 90265 - 34.086259°, -118.890645°

The following sections provide additional details for each area.

Paramount Ranch Paramount Ranch and features burned in the Woolsey Fire are shown on Figure 2. The land was purchased by Paramount Studios in 1927 and, prior to the Woolsey Fire, was used as a movie set where numerous television shows and movies were filmed. Paramount Ranch was open to the public for tours of the property, private events, and contains hiking trails. A total of ten structures were burned in the Woolsey Fire including the freight building, private quarters 107, the mercantile building, the pavilion, the saloon, the horse barn, the jail, the restroom, the hotel, and the telegraph office (Figure 2). In 1956, the owner of Paramount Ranch built a road-racing track adjacent to Medea Creek. The track was 2 miles in length and featured 11 turns and a bridge and underpass in the northern section of the course. The racetrack bridge was the eleventh feature burned in the Woolsey Fire.

Peter Strauss Ranch Peter Strauss Ranch and the features burned in the Woolsey Fire are shown on Figure 3. Peter Strauss Ranch was first owned by automobile manufacturer Henry Miller and used as a weekend retreat. In 1926, Miller built the stone ranch rouse, look-out tower, and aviary. The property was sold in the mid-1930s to developers Warren Shobert and Arthur Edison who turned the property into a recreational amusement park called Lake Enchanto. The property was sold to actor Peter Strauss in 1976, who turned the property

3 into a private estate. The land was sold to the Santa Monica Mountains Conservancy in 1983 and later to the NPS in 1987. The ranch contains hiking trails, a swimming pool in the Lake Enchanto dam, and previously allowed access to the stone ranch house. The ranch house was burned in the Woolsey Fire.

Rocky Oaks Rocky Oaks and the features burned in the Woolsey Fire are shown on Figure 4. This area was originally part of the Rocky Oaks Ranch, established in the 1920s by Albert and Anna Bradenberger. The area is maintained by the NPS and contains hiking trails and a seasonal man-made pond. Features destroyed in the Woolsey Fire include the Quarters 102 House, the Museum Building, a vault restroom, and a chicken coup.

Cooper/Brown The Cooper/Brown area and features burned in the Woolsey Fire are shown on Figure 4. The area contained the Bradenberger-Brown house, or the Cooper/Brown house, constructed by Albert and Anna Bradenberger in the 1940s.

Arroyo Sequit The Arroyo Sequit area and features burned in the Woolsey Fire are shown on Figure 5. It was purchased by Richard Mason and Mabel Kelch in the 1920s and sold to the State of California in 1985, following a large wildfire in the area. The NPS acquired the land in 1991. Arroyo Sequit contained a picnic area for visitor use and a wood frame ranch house used as a ranger residence. Features destroyed in the Woolsey Fire include the Quarters 113 house, the survey office, the vault restroom, and the pump house.

Circle X Ranch Circle X Ranch and the features burned in the Woolsey Fire are shown on Figure 6. The site was a former Boy Scout Camp created by the Exchange Club of Los Angeles and the Boney Ridge Country Club in 1949. In 1951, the Boy Scouts of America (BSA) signed a 99-year lease with the Circle X Ranch foundation, and in 1979, the foundation deeded the land to the BSA. In 1987, the NPS bought the land from the BSA and the NPS has managed an on-site campground since 1989. There are several hiking trails open to the public at the Circle X Ranch. Features destroyed in the Woolsey Fire include the basketball court and vault toilets A and B.

Morrison Ranch Morrison Ranch and the features burned in the Woolsey Fire are shown on Figure 7. The property was purchased by John W. Morrison in 1904 and was used as a cattle ranch. Morrison Ranch was acquired by the NPS in 1999. Features destroyed in the Woolsey Fire include the Morrison Ranch house, the chicken coup, and the corral area.

Miller Property The Miller Property and features burned in the Woolsey Fire are shown on Figure 8. The property is a recent purchase of the NPS. The Miller Property, formerly a roofed area which covered recreational vehicles, was burned in the Woolsey Fire.

Dragon Property

4 The Dragon Property and features burned in the Woolsey Fire are shown on Figure 9. The property is a recent purchase of the NPS. The structures destroyed during the Woolsey Fire include an Air Stream trailer, a school bus called the Life Estate, and a pump house.

2.1.4 Release or Substantial Threat of Release into the Environment of a Hazardous Substance, or Pollutant or Contaminant

The objective of the TCRA is to remove ash and debris from the Woolsey Fire, thereby removing specific contaminants of concern (COCs), as defined by §101(33) of CERCLA. These COCs are metals and dioxins and furans, which were identified in ash following implementation of the Sampling and Analysis Plan (Terraphase 2020a). Asbestos and PCBs were also chemicals of potential concern (COPCs) but were not detected in initial ash samples. The COCs present in ash may have been released to soil underlying the ash and debris at each of the nine sites. Following implementation of the fire debris and ash removal action, soil samples will be collected to assess if underlying soil has been impacted and if detected concentrations exceed the preliminary remedial goals presented in Table 1. A description of the derivation of the remedial goals is presented in Appendix A.

As described in the Sampling and Analysis Plan (Terraphase 2020a) groundwater is not expected to be impacted by Site COCs and groundwater sampling is not currently planned.

2.1.5 National Priorities List (NPL) Status

The Site is not listed or proposed for listing on the National Priorities List (NPL).

2.2 Previous and Current Actions to Date

Following the fire, the NPS installed fences around debris at six sites in public areas (Paramount Ranch, Peter Strauss Ranch, Rocky Oaks, Cooper Brown, Arroyo Sequit, and Circle X). The purpose of installing fences at these sites is to separate the public from interacting with potentially dangerous debris and to minimize the spread of debris offsite.

The Sampling and Analysis Plan (Terraphase 2020a) was implemented in January 2020. The initial phase of work included collection of background soil samples at six areas and samples of ash at all nine areas. The ash data were used to preliminarily quantify risks at the Site and identify preliminary remedial goals. The background soil data were compared to the preliminary remedial goals to ensure that remedial goals were not below background.

No previous Site soil data was collected prior to implementation of the Sampling and Analysis Plan (Terraphase 2020a).

2.3 State and Local Authorities Role and Actions to Date

The NPS is the lead agency for the Site. No State or local actions have been performed on the Site to date.

5 3.0 THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT AND STATUTORY AND REGULATORY AUTHORITIES

As a result of the Woolsey Fire, many structures were burned at the nine areas resulting in ash and burned debris on the ground surface at each area. Sampling of the ash revealed detected concentrations of metals, dioxins, and furans. These chemicals may have impacted soil below the fire debris and ash at the nine areas and may pose an unacceptable risk to human and/or ecological receptors.

In accordance with the 1990 National Contingency Plan (NCP), the following threats must be considered in determining the appropriateness of a removal action (40 CFR §300.415[b][2]):

• Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances, pollutants, or contaminants.

• Actual or potential contamination of drinking water supplies or sensitive ecosystems.

• Hazardous substances, pollutants, or contaminants in drums, barrels, tanks, or other bulk storage containers.

• High levels of hazardous substances, pollutants, or contaminants in soils largely at or near the surface that may migrate.

• Weather conditions that may cause hazardous substances, pollutants, or contaminants to migrate or be released.

• Threat of fire or explosion.

• The availability of other appropriate federal or state response mechanisms to respond to the release.

• Other situations or factors that may pose threats to public health and/or welfare or to the environment.

The factors that may apply to the Site are:

• Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances, pollutants, or contaminants.

• High levels of hazardous substances, pollutants, or contaminants in soils largely at or near the surface that may migrate.

Data gathered from the initial ash and background soil sampling indicates that metals, dioxins, and furans are present in the ash. The ash may also have impacted soil underlying the fire debris and may present an actual or potential for unacceptable risk to human and ecological receptors.

6

Potential Site contamination is largely concentrated near the surface of the Site and may migrate, if not removed. The removal action associated with this TCRA should be completed outside of the rainy season (December through March) to prevent migration of contaminated ash and surface soils and potential exposure to sensitive receptors.

4.0 ENDANGERMENT DETERMINATION

A release or substantial threat of a release of hazardous substances at the Site, if not addressed by a response action proposed in this TCRA memorandum, could pose a threat to public health and the environment. This TCRA is necessary in order to abate, prevent, mitigate, or eliminate the potential threat posed by the release or substantial threat of a release posed by the fire debris and ash at the Site.

5.0 PROPOSED ACTIONS AND ESTIMATED COSTS

This section describes the proposed actions to remove fire debris and ash from the Site and the estimated costs to complete the work. As part of the TCRA, ash and burned debris from each area will be removed and disposed of at an approved disposal facility. As described in the Sampling and Analysis Plan (Terraphase 2020a), post removal soil samples will be collected to ascertain if COCs in the fire debris and ash have impacted soil at the Site. The post-removal soil data will be compared to preliminary remedial goals that were calculated as part of this TCRA. The preliminary remedial goals are presented in Table 1. This section also contains a discussion of applicable or relevant and appropriate requirements (ARARs).

5.1 Description of Proposed Action

The selected action for the Site includes removal of fire debris and ash and restoration of the Site to a natural condition. The selected action at the Site will consist of the following:

- Removal of ash and debris and a limited amount of soil from the nine areas where structures were destroyed by the Woolsey Fire; some sites, if necessary, may also require removal of some concrete footings and/or foundations;

- Load, transport, and properly dispose of ash and debris at an approved disposal facility;

- Collect confirmation soil samples at each of the nine areas at the Site;

- Excavate and dispose of contaminated soil, if necessary;

- And, backfill, if necessary, to restore areas, post soil removal.

According to NPS estimates, approximately 315 tons of ash and debris are planned to be removed from the Site for disposal. The areas delineated for removal are based on visual evidence of ash and debris. The ash and debris will be directly loaded into trucks for transport and disposal at an approved facility. During removal and hauling, appropriate erosion control measures shall be implemented to minimize erosion

7 from exposed soils. Following removal, confirmation soil samples will be collected to verify that soils remaining are at or below the established remedial goals (Appendix A).

The removal action will be conducted in accordance with Occupational Safety and Health Administration (OSHA) health and safety protocols for working with hazardous substances. In addition, the work will be conducted in accordance with the Stormwater Pollution and Prevention Plan (Terraphase 2020b). During the debris and ash removal action, perimeter air monitoring will be conducted in accordance with the Community Air Monitoring Plan (Terraphase 2020c). If the results of air monitoring indicate fugitive dust is leaving any of the areas, dust control measures will be implemented by wetting the ash and debris, as necessary.

5.2 Contribution to Remedial Performance

In evaluating the appropriateness of a TCRA, the NPS must consider whether the removal action would contribute to the efficient performance of any anticipated long-term remedial action with respect to the release concerned [NCP Section 300.41 5(d)] as well as the availability of other federal or state response mechanisms to respond to the release of hazardous substance [NCP Section 300.41 5(b)(2)(vii)]. This TCRA will entail excavation and disposal of burned debris and contaminated soil, if present, at the nine areas, thereby minimizing risks to human health and the environment and mitigating, if not eliminating, the source of the contamination (to be determined by post-remediation confirmation soil sampling). Future response actions at the Site are not expected based upon available information.

5.3 Applicable or Relevant and Appropriate Requirements

The NPS has identified the federal and state ARARs set forth below for this TCRA to advise any contractors working at the Site:

1. The TCRA must be conducted in compliance with the NPS Organic Act of 1916 (codified at 16 U.S.C. §§ 1-3), which requires management of units of the NPS to leave them “unimpaired” for future generations.

2. Treatment, storage, and disposal of waste and excavated soils must comply with all applicable state and federal laws, including applicable provision in the Resource Conservation and Recovery Act [42 U.S.C. §§ 7401-7642; 40 CFR §§ 264 and 265], California Hazardous Waste Control Law and Hazardous Waste Disposal Regulations; Title 22, CCR 66262.1 et seq., provisions governing solid waste disposal in National Parks (codified at 16 U.S.C. §§ 4601-22(c) et. Seq.), and related implementing regulations (codified at 36 CFR Part 6). This project must comply with CERCLA Section 121(d)(3)(“off-site rule”), which requires that hazardous substances, pollutants, and contaminants that must be transferred off-site as a result of CERCLA response activities must be managed at a facility operating in compliance with federal and state laws. The NCP’s “off-site rule” implementation regulations (40 CFR §§ 300.440) define facility acceptability and create procedures for obtaining and reviewing acceptability determinations.

3. California State Water Resources Control Board Construction General Permit Order 2009- 009-DWQ for discharges of storm water associated with construction activity.

8 4. Laws and regulations protecting threatened and endangered species present at the Site, including the Endangered Species Act (e.g., 16. U.S.C. §§ 1531-1544, 50 CFR Part 402).

5. The TCRA is required to avoid, minimize, or mitigate impacts to historic sites or structures and must be conducted in compliance with the National Historic Preservation Act (16. U.S.C. §§ 470f; 36 CFR Parts 60, 63, and 800), the Archeological Resources Protection Act (43 CFR Part 7), the American Indian Religious Freedom Act (42 U.S.C. § 1996), the Native American Graves Protection and Repatriation Act (43 CFR Part 10), and Executive Order 13007.

6. Additionally, the following are other factors to be considered that provide useful standards or policy direction for this TCRA:

. Section 4.1.5 of the 2006 NPS Management Policies provides: “The Service will reestablish natural functions and processes in parks unless otherwise directed by Congress. Impacts on natural systems resulting from human disturbances include the introduction of exotic species; the contamination of air, water, soil; changes to hydrologic patterns and sediment transport; the acceleration of erosion and sedimentation; and the disruption of natural processes. The Service will seek to return such disturbed areas to the natural conditions and processes characteristic of the ecological zone in which the damaged resources are situated. The Service will use the best available technology, within available resources, to restore the biological and physical components of these systems, accelerating both their recovery and the recovery of the landscape and biological community structure and function”. Section 4.8.2.4 of the 2006 NPS Management Policies allows important of off-site soil or soil amendments to restore damaged sites. It provides that, “off-site soil normally will be salvaged soil, not soil removed from pristine sites, unless the use of pristine site soil can be achieved without causing any overall ecosystem impairment. Before using any off-site materials, parks must develop a prescription and select the materials that will be needed to restore the physical, chemical, and biological characteristics of original native soils without introducing exotic species”.

. Section 9.1.3.2 of the 2006 NPS Management Policies requires that, to the maximum extent possible, plantings selected for revegetation will consist of species that are native to the park, and that low water use practices should be employed. This provision also addresses use of fertilizers and other soil amendments.

. NPS Reference Manual #77 offers comprehensive guidance to NPS employees responsible for managing, conserving, and protecting the natural resources found in park units. It addresses management of natural resources (including air; disturbed land; endangered, threatened and rare species; geologic resources; vegetation; etc.), resource uses, and planning (e.g., emergency management and environmental compliance).

. NPS-28: Cultural Resource Management Guidelines addresses park cultural resources management programs, compliance with Section 106 of the National Historic Preservation Act and issues related to archaeological resources, cultural landscapes, structures, museum objects, and ethnographic resources.

9 . The General Management Plan and Environmental Impact Statement (NPS 2002) identifies practicable and appropriate mitigation measures to avoid and/or minimize harm to natural and cultural resources, visitors, and the visitor experience within the Santa Monica Mountains National Recreation Area.

5.4 Project Schedule

The removal action is scheduled to be conducted in 2020.

5.5 Estimated Costs

Total costs for the TCRA, including planning documents, contracting, removal action, oversight and sampling are estimated to be $1,618,259. This estimate does not include any cost associated with NPS or other agency oversight. The NPS is exercising its lead agency authority to perform and oversee performance of response actions under CERCLA. The project is funded by NPS.

6.0 EXPECTED CHANGE IN SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Adverse impacts could occur if action should be delayed or not taken at the Site because human and ecological receptors may be exposed to contaminated surface soil and ash via direct contact. In addition, if the action should be delayed or not taken, potential contamination could migrate, potentially resulting in a greater volume of material that would warrant risk management action. This would result in an increase in treatment and/or disposal costs.

7.0 OUTSTANDING POLICY ISSUES

No outstanding policy issues exist for this TCRA.

8.0 RECOMMENDATION

This decision document presents the selected TCRA for the burned building sites located within the SAMO, which was developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP.

Conditions at the Site meet the NCP section 300.415(b) criteria for time-critical removal action and through this document, I am approving the proposed TCRA.

On the basis of the evaluation conducted and the factors outlined in the NCP, the NPS has determined that the release or substantial threat of release of hazardous substances at the Site pose a risk to human health and the environment, and that a TCRA is necessary and appropriate in order to abate, prevent, mitigate or eliminate the threat posed by the release or substantial threat of release of these substances. Because conditions at the Site meet all applicable CERCLA and NCP criteria for undertaking a TCRA, I recommend/concur/approve that the NPS implement the TCRA as proposed herein.

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Recommended: ______Date: ______John Chisum, PE Chief of Maintenance National Park Service, Pacific West Region

Concurred: ______Date: ______David Szymanski Superintendent Santa Monica Mountains National Recreation Area

Concurred: ______Date: ______Stephen J. Mitchell, PE Operations/Environmental Programs Branch Chief National Park Service, Pacific West Region

Approved: ______Date: ______Stan Austin Regional Director National Park Service, Pacific West Region

11 Table 1 Preliminary Remedial Goals Woolsey Fire Cleanup Santa Monica Mountains National Recreation Area, California

Human Ecological- Background Health-Based Based Overall Proposed Threshold Preliminary Preliminary Preliminary Value Remedial Goal Remedial Goal Remedial Goal Chem Group Chemical CASRN (mg/kg) (mg/kg) (mg/kg) (mg/kg) PCBs PCBs (total) 1336-36-3 -- 0.22 0.090 0.090 Metals Antimony 7440-36-0 4.1 100 11 11 Arsenic 7440-38-2 4.6 0.68 22 4.6 Barium 7440-39-3 130 52,000 170 170 Beryllium 7440-41-7 0.56 520 7.9 7.9 Cadmium 7440-43-9 4.6 230 4.7 4.7 Chromium III 16065-83-1 120 290,000 100 120 Chromium VI 18540-29-9 -- 1.4 1.1 1.1 Cobalt 7440-48-4 30 77 41 41 Copper 7440-50-8 31 10,000 140 140 Lead 7439-92-1 45 400 180 180 Manganese 7439-96-5 700 4,200 490 700 Mercury 7439-97-6 0.40 18 0.31 0.40 Molybdenum 7439-98-7 3.8 1,300 16 16 Nickel 7440-02-0 95 5,200 100 100 Selenium 7782-49-2 3.3 1,300 1.2 3.3 Silver 7440-22-4 -- 670 42 42 Thallium 7440-28-0 3.7 -- 0.16 3.7 Vanadium 7440-62-2 78 1,300 38 78 Zinc 7440-66-6 130 77,000 360 360 Dioxins/Furans 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746-01-6 -- 4.8E-06 3.0E-06 3.0E-06 Asbestos Asbestos 1332-21-4 ------Notes: The overall preliminary remediation goal (PRG) is equal to the lower of the human health or ecological risk-based concentrations, unless lower than the background threshold value (BTV). -- No value calculated. Table 1 Preliminary Remedial Goals Woolsey Fire Cleanup Santa Monica Mountains National Recreation Area, California