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Mr. Tom Canales <br /> September 30, 2013 <br /> Page 2 <br /> Exposure Pathways <br /> Additionally, you raised the issue of whether the PEA report considered the effect of <br /> fires as an alternate exposure pathway. The PEA report did not consider fires <br /> specifically as an alternate exposure pathway; but it did explore inhalation (airborne <br /> particulates) as a pathway. The PEA report analyzed a hypothetical situation where <br /> humans were exposed via inhalation to airborne particulates from the Site over the <br /> course of 24 hours and determined that the likely health risk to neighboring residents of <br /> the Site would be below regulatory screening levels at which regulatory action would be <br /> required. This is due to anticipated short, intermittent exposure duration and relatively <br /> low chemical concentrations present in the soil of the Site. Based on this analysis, <br /> DTSC does not think it is necessary to consider fires separately as an exposure <br /> pathway. <br /> Weed Abatement and Site Security <br /> DTSC contracted for weed abatement three times between 2009 and 2011 in order to <br /> gain access for investigation and remediation activities at the Site. However, DTSC has <br /> not found it necessary to contract for weed control since completion of the PEA. <br /> The fence and warning signs that DTSC required are intended to prevent accidental <br /> exposure to contaminated soil. DTSC repaired the fence multiple times from 2009 to <br /> 2012. In a recent letter, DTSC reminded the Site owner of his responsibility to maintain <br /> the fence and directed him to perform repair work on breaches in the fence. DTSC has <br /> issued the owner a follow up letter pertaining to Site security. Currently, DTSC is <br /> reviewing its regulatory authority to determine if additional actions against the owner <br /> can be taken. Regardless of the condition of the fence, if vagrants move onto the <br /> property, and the owner does not deter their residency, the fence will do little to <br /> discourage them. Although DTSC may not have specific authority to deter trespassing <br /> on private property, local ordinances may require the owner to maintain the fence and <br /> prohibit trespassers. In short, the Site owner and local authorities may have the most <br /> effective means to intervene and prevent trespassing. <br /> Cleanup of the Site <br /> Finally, you asked when the Site would be completely cleaned up. As stated above, <br /> enough cleanup has occurred, to date, to reduce any risk to public health and the <br /> environment off-site. However, the Site would have to undergo further remediation to <br /> protect onsite residents and workers if it were to be developed. The current owner <br /> claims he does not have the funds to conduct the longer-term cleanup and has <br /> indicated to DTSC that he would like to sell the Site. DTSC hopes that the next owner <br /> will have the funds to conduct a thorough remediation. <br />