Reasons for Exemption
This project consists of removal actions necessary to prevent or mitigate an emergency, determined by DTSC to be “an imminent or substantial endangerment to the public health or welfare or to the environment, because of the release or a threatened release of a hazardous substance…” (Health and Safety Code section 25358.3(a))
Releases of hazardous substances are threatened to occur from increasingly frequent and severe precipitation events in the Ventura County area. Additionally, because the shooting range clay pigeon debris which remains at the site burned in a previous fire, it is brittle and more vulnerable to rapid disintegration and transport via surface water runoff. The remaining lead shot may also be acutely toxic to granivorous bird specifies, which use grit to help digest their food and may mistake shot for pebbles and ingest them. Lastly, recreators eager to utilize the Sage Ranch Park Loop Trail frequently trespass onto closed portions of the trail, resulting in potential exposure to hazardous substances at the site.
In light of the above, DTSC has determined that future releases of hazardous substances from the Site are threatened to occur in light of predicted changes to regional weather patterns due to climate change and the risk of deferring action through another rainy season is unacceptable. If the rainy season starts before the cleanup is completed, best management practices (BMPs) will be used to prevent migration of contaminated soils. Given DTSC’s determination that an imminent and substantial endangerment to human health and the environment exists, this removal action is exempt under the Emergency provisions of the California Environmental Quality Act.