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Kitty Walker <br />Page 2 <br />(3) the amount of potential exposure to residents from the <br />release of hazardous substances which is determined by the <br />frequency, duration and route (inhalation, dermal or <br />ingestion) of exposure and; <br />(4) the likelihood that residents would be adversely affected <br />from exposure to hazardous substances. <br />For a more detailed discussion of the risk assessment process and <br />procedures, please refer to the Environmental Protection Agency <br />Superfund Exposure Assessment Manual, the Environmental <br />Protection Agency Superfund Public Health Evaluation Manual, and <br />the California Site Mitigation Decision Tree. <br />We have reviewed the documents you provided us and other <br />pertinent information available to the Department. We provide <br />the following recommendations and comments regarding the scope of <br />future studies that would address potential impacts of hazardous <br />waste on the proposed development. <br />Further investigation of possible hazardous waste disposal at Air <br />Products and Chemicals, Inc. is needed. The Environmental <br />Protection Agency (EPA) conducted a Preliminary Assessment in <br />1980 which provides limited information about hazardous waste <br />disposal at the site. EPA is the lead agency for hazardous <br />waste investigations at the site and has scheduled a second <br />Preliminary Assessment for September, 1989. Potential risk to <br />future subdivision residents cannot be assessed without detailed <br />information describing the nature and extent of possible <br />contamination at the site. If a significant disposal of <br />hazardous waste is found at Air Products and Chemicals, Inc., the <br />owner of the proposed subdivision site would be subject to border <br />zone property requirements under Health and Safety Code Section <br />25220 et seq. In this case, a risk assessment may be needed to <br />determine potential risk to the proposed subdivision. <br />The J.R. Simplot Company property was formerly owned by <br />Occidental Chemical Company (Oxychem) and is listed as a <br />hazardous waste site under the Expenditure Plan for the Hazardous <br />Substance Cleanup Bond Act of 1984. All major cleanup phases at <br />the site have been completed although contaminated ground water <br />is currently being treated at the site as part of long-term <br />operation and maintenance activities. We are concerned about the <br />possible effect of increased ground water pumping within the <br />vicinity which may affect the water gradient control being <br />maintained at the Oxychem site. Contaminated ground water may <br />migrate farther offsite if gradient control is lost. Except for <br />this concern, we have no reason to believe that remediation <br />activities at the Oxychem site pose an existing or future health <br />risk to the proposed subdivision. Construction of wells at the <br />