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defines this as "trace" amounts. He advised that if he finds elevated levels of radioactivity he compares it to the natural levels. He stated that if it is just a fraction of the natural levels or it is comparable to the natural levels, then he considers it safe. If it is much larger than the natural radioactivity, then a remediation or risk assessment is needed. There are lots of options for remediation, but it depends on future use. The remediation for residential future use would be different from commemial/industrial future use, and park use could also be different. He advised that remediation usually involves removal (identify the extent of the contamination, excavate it, package it, and send it to one of the three radioactive disposal sites in the westem United States). He noted that remediation could also mean "treatment-in-place" where the soil is treated, the mixture is put back in the ground, and the soil remains on the site, but that this is rare and is appropriate under certain circumstances. He advised that he suspects that there are small amounts of contamination on the Bernal property and under those circumstances further investigation is done to determine if the contamination is from plutonium or cesium, or some other radioactive isotope, because each one has its own pathway through the environment and its own risks. In response to a question from Chairperson Kumaran, Mr. Cehn advised that he did not visit the site nor did he do any testing of the site. Commissioner Sullivan asked if Mr. Cehn knew the number of garments washed, the level of contamination, and the number of years the laundry was operating. Mr. Cehn noted that State Department records indicated a large number of garments, but he does not recall the actual number. He also noted that a lot of the garments were clean, and the garments ranged from being clean (with no radioactivity) to being very contaminated with radioactivity. Mr. Cehn advised that the laundry did a good job of removing the radioactivity and that +99% of it was in the wasterooms and shipped to the disposal sites. Mr. Cehn reported that the water quality tests were done in a lab at the laundry and a back-up lab off-site, where the test results were confirmed. In response to a question from Commissioner Sullivan regarding when Federal law requires testing of a site like the Bernal property, Mr. Cehn stated that when the contamination is not at the facility that was licensed, it becomes a little "fuzzy," but generally the regulators determine if the situation is bad enough for them to get involved right away. It is a judgment call. Sometimes the State will call in an emergency clean-up contractor, but the law does not address the immediacy of the testing or identification of the real problem. Commissioner Kameny inquired as to the timeframe and cost to study the Bernal property site. Mr. Cehn responded that it would depend on the extent of the sludge ponds (the larger the sludge ponds, the longer it takes). He noted that it would involve soil sampling, laboratory analysis, and walking the site with sensitive detectors. He advised that the sampling is often done in conjunction with chemical analysis. Mr. Cehn noted that he does not see any public health risk in waiting to conduct the testing. Anne Holbrough of GeoMatrics Consultants, stated that her firm specializes in environmental site assessment and investigations, and remediations, should they be necessary. She advised that the process part of this EIR is fairly standard compared to the way other EIR's are done for large properties, where there are a lot of options for how the property will be developed and there are a lot of opportunities for PLANNING COMMISSION MINUTES Page 4 July 16, 1999