Reasons for Exemption
The Project consists of specific 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)].
The existence of lead in the soil that exceeded safe levels for residences was unknown prior to the testing done in the aftermath of the fire. Lead, the primary contaminant, was detected above its screening criteria in soil within and outside of the burn scar after debris removal was completed. Lead was found at concentrations of up to 3,500 mg/kg in those areas, which exceeds California’s residential screening level of 80 milligrams mg/kg and the commercial screening level of 500 mg/kg. Eating soil with high levels of lead or breathing high levels of lead dust can cause lead poisoning, which can damage the brain, kidneys, liver, and other organs. Children less than six years old and pregnant women are at higher risk. Lead poisoning can affect children’s growth, learning and behavior.
As a result of the fires, many of the properties have been vacant since August 2021. Property owners have submitted plans to the County to rebuild and move back to their homes and businesses in Greenville. Residents that return to their homes, construction workers, and owners, workers, and patrons of commercial properties may ingest, inhale, and have dermal contact with bare or manually disturbed soils containing elevated concentrations of lead. Modes of contact are expected to include inhaling dust during dry times of the year when it is blown about by the wind. Year-round exposure can occur when people walk through contaminated soil and carry it into their home, vehicle, or business where it can accumulate or when working or playing in the soil where ingestion can also occur. The potential for human exposure has created an urgent need to remove the lead-impacted soils during and after the re-construction of the Greenville community to avoid imminent exposure by workers and occupants.
The lead-contaminated soil could further impact the surrounding environment. Due to the mountainous terrain and high elevations, the naturally occurring accumulation of snow poses a risk of migration of on-site contaminants into the local creek and river systems, which would impact much larger downstream populations, including possibly municipal wells and drinking water systems drawing from these local watersheds. Cleanup of the Site could prevent future spread outside the Site.