IV. Environmental Impact Analysis E. Hazards and Hazardous Materials

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1 IV. Environmental Impact Analysis E. Hazards and Hazardous Materials 1. Introduction This section provides an analysis of potential impacts that would occur relative to hazards and hazardous materials due to implementation of the project. The analysis is based largely on a Phase I Environmental Site Assessment (Phase I report) prepared for the project site by Artemis Environmental Consulting, Inc., provided in Appendix F of this Draft EIR. 2. Environmental Setting a. Regulatory Framework (1) Hazardous Materials Management The use and storage of hazardous materials are subject to local, State, and Federal regulations. At the local level, the Los Angeles Fire Department (LAFD) monitors the storage of hazardous materials for compliance with local requirements. Specifically, businesses and facilities which store more than threshold quantities of hazardous materials as defined in Division 20, Chapter 6.95 of the California Health and Safety Code are required to file an Accidental Risk Prevention Program with the LAFD. This program includes information such as emergency contacts, phone numbers, facility information, chemical inventory, and hazardous materials handling and storage locations. In addition, employees and employees of contractors that handle hazardous wastes or are potentially exposed to hazardous wastes are required under Federal Occupational Safety and Health Administration (OSHA) (29 C.F.R ) and State OSHA (Cal-OSHA) regulations to be trained and certified to handle hazardous materials. The Department of Toxic Substances Control (DTSC) regulates hazardous waste, cleans up existing contamination, and looks for ways to reduce the hazardous waste produced in California. The DTSC operates programs to accomplish the following: (1) deal with the aftermath of improper hazardous waste management by overseeing site cleanups; (2) prevent releases of hazardous waste by ensuring that those who generate, handle, Page IV.E-1

2 transport, store, and dispose of wastes do so properly; and (3) evaluate soil, water, and air samples taken at sites. The storage of hazardous materials in underground storage tanks (USTs) is regulated by the State Water Resources Control Board (SWRCB), which has delegated authority to the Regional Water Quality Control Board (RWQCB) and typically on the local level, to the fire department. The LAFD administers and enforces Federal and State laws and local ordinances for USTs at the project site. Plans for the construction/installation, modification, upgrade, and removal of USTs are reviewed by LAFD Inspectors. (2) Asbestos Containing Materials Asbestos, which is made up of microscopic fibers, is a naturally occurring mineral. Asbestos has unique qualities which include its strength; resistance to fire and chemical corrosion; poor conduction of heat, noise, and electricity; and low cost. Asbestos has been widely used in the building industry for a variety of uses, including acoustic and thermal insulation and fireproofing. It is often found in ceiling and floor tiles, linoleum, and pipes, as well as on structural beams and asphalt. Despite its useful qualities, asbestos is associated with lung diseases caused by inhalation of airborne asbestos fibers. Asbestos becomes a hazard if the fibers separate and become airborne. The Federal Environmental Protection Agency (USEPA) has enacted strict requirements on the use, handling, and disposal of asbestos containing materials (ACM) under the Toxic Substances Control Act (TSCA) (40 CFR 763). These regulations include the phase out of friable asbestos and ACM in new construction materials beginning in Thus, any building, structure, surface asphalt driveway, or parking lot constructed prior to 1979 could potentially contain ACM. The USEPA has also established National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR 61 Part M) that govern the use, removal, and disposal of ACM as a hazardous air pollutant. The NESHAP regulations mandate the removal of friable ACM before a building is demolished and includes notification requirements prior to demolition. Responsibility for implementing these requirements has been delegated to the State of California, which in turn has delegated the responsibility to the South Coast Air Quality Management District (SCAQMD). California classifies ACM as hazardous waste if it is friable and contains one percent or more asbestos (CCR, Title 22, Section ). Non-friable bulk asbestos-containing waste is considered non-hazardous regardless of its asbestos content and is not subject to regulation under CCR, Title 22. The California EPA s (Cal-EPA) Department of Toxic Substances Control (DTSC) regulates the packaging, on-site accumulation, transportation, Page IV.E-2

3 and disposal of asbestos when it is a hazardous waste. In California, any facility known to contain asbestos is required to have a written asbestos management plan (also known as an Operations and Maintenance Program [O&M Program]). The SCAQMD implements the NESHAP through its Rule 1403, Asbestos Emissions from Renovation/Demolition Activities. Rule 1403 regulates asbestos as a toxic material and controls the emissions of asbestos from demolition and renovation activities by specifying agency notifications, appropriate removal procedures, and handling and cleanup procedures. Rule 1403 applies to owners and operators involved in the demolition or renovation of ACM-containing structures, asbestos storage facilities, and waste disposal sites. Rule 1403 regulations require that the following actions be taken: (1) a survey of the facility prior to issuance of a permit by SCAQMD; (2) notification of SCAQMD prior to construction activity; (3) asbestos removal in accordance with prescribed procedures; (4) placement of collected asbestos in leak-tight containers or wrapping; and (5) proper disposal. In addition, the Federal and State OSHA programs regulate asbestos as it relates to employee safety. The Federal OSHA Worker Exposure Rule for Asbestos (29 CFR and ) requires certain actions on the part of any employer whose employees are potentially exposed to asbestos fiber levels above the permissible exposure limit (0.2 fibers per cubic centimeter of air [f/cc], averaged over an 8-hour day). Under Cal- OSHA, if employees are exposed to a time-weighted average of 0.1 f/cc over an 8-hour period, employers must begin compliance activities such as notification, employee training, air monitoring and, in some cases, medical surveillance. In addition to these regulations, contractors involved in asbestos surveys and removal are required to be certified by Cal- OSHA. As well, the California Connelly Act (AB 3713; Health and Safety Code sec et seq.) establishes notification requirements for all owners and employees working within any pre-1979 building known to contain ACM. The notification requirements of the Connelly Act are enforced by Cal-OSHA. (3) Lead-Based Paint Lead is a naturally occurring element and heavy metal that was widely used as a major ingredient in most interior and exterior oil-based paints prior to Lead compounds continued to be used as corrosion inhibitors, pigments, and drying agents from the early 1950s to 1972, when the Consumer Products Safety Commission specified limits on lead content in such products. The most common paths of lead exposure in humans are through ingestion and inhalation. Lead-based paint (LBP) is of concern both as a source of exposure and as a major contributor to lead in interior dust and exterior soil. Page IV.E-3

4 While adults can be affected by excessive exposure to lead, the primary concern is the adverse health effects on children. If not detected early, children with high levels of lead can suffer from damage to the brain and nervous system; behavior and learning problems such as hyperactivity, slowed growth, and hearing problems; and headaches. Adults can suffer from lead-related effects such as reproductive problems (in both men and women), high blood pressure and hypertension, nerve disorders, memory and concentration problems, and muscle and joint pain. The demolition of buildings containing LBPs is subject to a comprehensive set of California regulatory requirements that are designed to assure the safe handling and disposal of these materials. Cal-OSHA has established limits of exposure to lead contained in dusts and fumes through CCR, Title 8, Section , which provides for exposure limits, exposure monitoring, and respiratory protection, and mandates good working practices by workers exposed to lead, particularly since demolition workers are at greatest risk of adverse health exposure. Lead-contaminated debris and other wastes must also be managed and disposed of in accordance with applicable provisions of the California Health and Safety Code. (4) Methane Gas Chapter IX, Article 1, Division 71, Section of the Los Angeles Municipal Code (LAMC), also known as the Los Angeles Methane Seepage Regulations, provides requirements for buildings and paved areas located in a classified methane zone or methane buffer zone. Requirements for new construction within such zones include installing a barrier (i.e., a membrane shield) between the building and underlying earth, installing a vent system(s) beneath the barrier and/or within the building, and installing a gas (methane) detection system. As discussed above, the project site is not located in a methane zone or methane buffer zone. (5) Airport Safety Provisions The Federal Aviation Administration (FAA) has established an advisory circular with regard to safety concerns associated with the construction of high-rise buildings since such buildings may present a hazard to aircraft operations. 1 This requirement is in effect for buildings with a height of or over 200 feet above ground level (AGL). 2 In this regard, 1 2 FAA Advisory Circular 150/ (September 30, 2000). Ibid. Page IV.E-4

5 Federal Aviation Regulations (FAR) Part 77, Objects Affecting Navigable Airspace, establishes minimum standards to ensure air safety by regulating the construction or alteration of buildings or structures that may affect airport operations. 3 The FAA requires that Form , Notice of Proposed Construction or Alteration, be filed with the FAA regional office prior to construction of buildings that are 200 feet or greater in height from the grading terrain. In addition, generally any structure that exceeds an overall height of 200 feet AGL should be marked and/or lighted. 4 However, the determination is made by FAA and depends on terrain features, weather patterns, geographic location, number of structures, and overall building design layout. 5 The FAA does not have jurisdiction to approve a proposed project; rather, the FAA provides a written finding to the project applicant that the project represents one of three options: (1) not a problem with respect to air navigation; (2) is an obstruction, but not a hazard to air navigation; or (3) is a hazard to air navigation. This finding is advisory to the applicant and to local zoning jurisdictions. In addition, the FAA will review the proposed project to be certain that it does not create: (1) electromagnetic interference with air navigation facilities; (2) lighting effects; or (3) smoke that would interfere with aircraft in flight. b. Existing Conditions The project site is comprised of six parcels totaling 68.8 acres and is currently occupied by apartment buildings and accessory structures within a planned development originally built in Specifically, the project site includes a total of 256 buildings (153 residential buildings, 98 garage structures, and five non-residential buildings) that provide 1,187 dwelling units and ancillary structures for parking, laundry, and other related uses. Approximately 9.5 acres of the site are comprised of dispersed public open space areas that include lawns and mature trees, with the largest open space area (The Mall), which is an open space/drainage channel running from east to west, with a perpendicular section bisecting the channel from north to south located within the central portion of the site. In addition to the contiguous open space there are approximately 9.71 acres of interstitial open space composed of bits and pieces of open space formed by the gaps between buildings or courtyards within buildings. In some cases these spaces have grass or FAR. 14 C.F.R. Part 77 (2001). FAA Advisory Circular AC 70/7460-1K (August 1, 2000). Ibid. Page IV.E-5

6 plantings, and in some cases theses spaces are comprised of dirt surfaces. While some of these areas are grassy, because they are small, irregularly shaped, and often tightly sandwiched between buildings, roads, and parking lots, they do not significantly contribute to the open space at the project site. There are another approximately acres of unfenced yard space which are composed of the areas between the façades of each building and the adjacent asphalt pathways. In addition, there are another 3.5 acres of private yards that were originally either interstitial open space or common open space that have been claimed by individual units as private open space through the use of fencing. (1) Hazardous Materials Database Site Listing and Surrounding Properties As part of the Phase I report, various local, State, and Federal environmental agency databases were reviewed to ascertain whether the project site or any properties within a determined radius are known to contain hazardous materials, contaminated surface water or groundwater, or leaking underground storage tanks (LUSTs). The project site is listed on the State Hazardous Waste Information System (HAZNET) database, presumably for the disposal of lead waste from an extensive lead abatement program conducted on-site in 1999 (discussed further below). The project site is also listed on the State Department of Health Services database in association with a DTSC Hazardous Waste Tracking System report for the project site, indicating that a Cal-EPA identification number was issued to the site. That identification number was also likely assigned to the property during the lead abatement program in 1999 and has been inactive since then. 6 Consequently, there is no presence of engineering or industrial control measures (e.g., special building liners, treatment facilities, use restrictions) designed to manage or eliminate hazardous substances on-site. Several properties located within the vicinity of the project site are also listed on various regulatory databases, including the Federal Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) list; Federal CERCLIS No Further Remedial Action Planned (NFRAP) list; Federal Resource Conservation and Recovery Act Corrective Action Sites (RCRA CORRACT) sites; Federal RCRA Treatment, Storage, and Disposal (TSD) facilities list; Federal RCRA generators list; State Equivalent National Priorities List (NPL) list; State Equivalent CERCLIS list; State Landfill and/or Solid Waste Disposal Sites list; State LUST list; State Registered Underground Storage Tank (UST) list; and State Voluntary Cleanup Sites. The properties 6 Artemis Environmental Consulting, Inc., Phase I Environmental Site Assessment of Wyvernwood Apartments, 2901 East Olympic Boulevard, Los Angeles, California, May 12, Page IV.E-6

7 listed on these databases include a pumping service (a controversial former dumpsite that became the first State Superfund site in Los Angeles), various gas stations, metal manufacturers, packaging supply facilities, and asphalt plants. Due to the distance of these properties from the project site, their specific location (e.g., across the Golden State/ Santa Ana Freeway [I-5] or Pomona Freeway [SR-60]), their cross- or down-gradient direction relative to the project site, and/or their current status (e.g., no further remedial action planned, case closed, etc.), none are expected to present a hazard to the project site. 7 For detailed information regarding these listings, please refer to the Phase I report in Appendix F of this Draft EIR. (2) Hazardous Materials Management (a) Hazardous Substances Use No significant quantities of hazardous substances were noted on-site at the time of the Phase I inspection. Small quantities of hazardous substances including gasoline, paint, cleaners, and various janitorial/maintenance supplies were located in a storage shed located behind the leasing office. Such substances are considered typical of residential developments. (b) Aboveground and Underground Storage Tanks The project site is not known to contain any aboveground or underground storage tanks. As such, no further analysis of this issue is necessary. (c) Asbestos Containing Materials Testing for asbestos was not conducted as part of the Phase I report for the project site. However, as described above, asbestos was widely utilized in the building industry prior to 1979 for a variety of uses, including acoustic and thermal insulation and fireproofing. As such, given the age of the existing buildings on-site, it is likely that asbestos is present in some of the building materials. 7 Artemis Environmental Consulting, Inc., Phase I Environmental Site Assessment of Wyvernwood Apartments, 2901 East Olympic Boulevard, Los Angeles, California, May 12, Page IV.E-7

8 (d) Lead-Based Paint As discussed above, lead was widely used as a major ingredient in paints prior to 1950 and other materials until An extensive lead abatement program was conducted on-site from late 1998 through 1999, and all building interiors were made lead-free, while building exteriors were made lead-safe, in accordance with a work plan established with the County of Los Angeles Department of Health Services. 8 Additional lead-based paint sampling was not conducted as part of the recent Phase I report for the project site. However, due to the age of the structures and the known former presence of lead on-site, it is possible that trace amounts of lead remain. (3) Methane Gas The project site is not located within a City-designated methane zone or methane buffer zone. 9 Furthermore, according to Division of Oil, Gas, and Geothermal Resources (DOGGR) records, no oil wells are located directly on the project site. As such, no further analysis of this issue is necessary. c. Historical Uses of the Project Site The project site was generally undeveloped until 1939, when the current residential development was constructed. Several additional residential and ancillary buildings were added in the 1950s and 1960s, with no substantial changes to the site since. As indicated in the Phase I report, based on a review of historic aerial photographs of the project site dated from between 1928 and 2005, there was no visual evidence of any environmental concerns, nor were any recognized environmental conditions identified. The Phase I report concluded that no further environmental investigation was necessary. d. Sensitive Receptors The surrounding project vicinity is highly urbanized and includes a varied mix of residential, commercial, industrial, and institutional uses. Surrounding uses north of the site that are considered sensitive to hazards consist of single-family residences. These residential uses extend northward to the I-5 Freeway, which forms a physical boundary of 8 9 Barr & Clark, Renovation/Abatement Plan, Wyvernwood Gardens Apartments, July 13, Department of Public Works, LAMC, Methane Ordinance Map A City Ordinance No. 175,790. February 4, Page IV.E-8

9 the project vicinity, with residential uses also located further to the north, along with five educational facilities (Soto Street Elementary School, Santa Isabel School, Bishop Mora Salesian High School, Sunrise Elementary School, and Plaza de la Raza Child Development Center). Sensitive uses immediately east of the project site include Dacotah Street Combination Children s Center, Dena Elementary School, Costello Senior Citizen Center, and the Lou Costello Recreational Center, while further to the east are a series of multi-family residential buildings operated by the Housing Authority of the City of Los Angeles in a development referred to as Estrada Courts. Dense residential uses also extend further to the east, adding to the urban environment. Immediately southwest of the project site are the Carmen Lomas Garza Primary Center (Garza PC) and a park/recreation center. 3. Environmental Impacts a. Methodology To assist in evaluating the potential impacts associated with hazards and hazardous materials that could occur as a result of construction and/or operation of the project, a Phase I assessment was conducted at the project site. The Phase I report is intended to identify recognized environmental conditions in connection with the project site. The term recognized environmental conditions, as defined in ASTM Standard Practice E , means the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. 10 Based on the results of the Phase I assessment, the potential for construction and/or operation of the project to result in significant impacts associated with hazards and hazardous materials was evaluated. Hazards impacts associated with emergency response and evacuations are discussed in Section IV.J.2, Fire Protection, of this Draft EIR. 10 Artemis Environmental Consulting, Inc., Phase I Environmental Site Assessment of Wyvernwood Apartments, 2901 East Olympic Boulevard, Los Angeles, California, May 12, Page IV.E-9

10 b. Significance Thresholds Appendix G of the CEQA Guidelines provides sample questions that address impacts with regard to hazards and hazardous materials. These questions are as follows: Would the project: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it create a significant hazard to the public or the environment? For a project located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? In the context of these questions, the CEQA Thresholds Guide states that the determination of significance with regard to impacts associated with risk of upset/emergency preparedness and human health hazards shall be made on a case-bycase basis, considering the following factors: (1) Risk of Upset/Emergency Preparedness Compliance with the regulatory framework; Page IV.E-10

11 The probable frequency and severity of consequences to people or property as a result of a potential accidental release or explosion of a hazardous substance; The degree to which the project may require a new, or interfere with an existing, emergency response or evacuation plan, and the severity of the consequences; and The degree to which project design will reduce the frequency or severity of a potential accidental release or explosion of a hazardous substance. (2) Human Health Hazards Compliance with the regulatory framework for the health hazard; The probable frequency and severity of consequences to people from exposure to the health hazard; and The degree to which project design would reduce the frequency of exposure or severity of consequences of exposure to the health hazard. Based on these factors, the project would be considered to have a significant risk of upset/emergency preparedness or human health hazard impact if: The project does not comply with applicable regulations regarding the handling and storage of hazardous materials; The project would expose persons to substantial risk resulting from the release of hazardous materials or from exposure to a health hazard in excess of regulatory standards; or The project would consistently increase interference with existing emergency response capacity to the project area over existing conditions. c. Project Design Features All hazardous materials on the project site would be acquired, handled, used, stored, and disposed of in accordance with all applicable federal, State, and local requirements. Monitoring of the Applicant's hazardous materials management would be conducted by the Los Angeles Fire Department, and other applicable regulatory authorities, as appropriate. Likewise, the disposal of on-site generated hazardous waste would occur in accordance with all applicable regulations. Page IV.E-11

12 d. Analysis of Project Impacts (1) Historical Uses of the Project Site As discussed above, the project site was generally undeveloped until 1939, when the current residential development was constructed, with limited additional residential construction in the 1950s and 1960s. Given the history of the property for multi-family residential purposes, there have been no historical uses of the project site that would have led to the release of hazardous substances on-site. Further, no recognized environmental conditions were identified on-site in the Phase I report. As such, impacts with respect to historical uses of the site would be less than significant. (2) Hazardous Materials Management (a) Hazardous Substances Use Construction of the project would involve the temporary use of potentially hazardous materials, including paints, adhesives, surface coatings, cleaning agents, fuels, and oils. However, all potentially hazardous materials would be used, stored, and disposed of in accordance with manufacturers instructions and handled in compliance with applicable standards and regulations. Any associated risk would be adequately reduced to a less than significant level through compliance with these standards and regulations. Additionally, any emissions from the use of such materials would be minimal and localized to the project site. With regard to potentially hazardous conditions presently existing on the site, no significant quantities of hazardous substances were noted on-site at the time of the Phase I inspection. Furthermore, no evidence of hazardous environmental conditions was observed on the site. As such, the potential to uncover contaminated soils or groundwater beneath the site during project construction (particularly during grading and excavation activities) is considered low. Since construction of the project would comply with applicable regulations and would not expose persons to substantial risk resulting from the release of hazardous materials or exposure to health hazards in excess of regulatory standards, impacts associated with the potential release of hazardous substances during construction of the proposed project would be less than significant. Similar to existing conditions, operation of the project would involve the limited use of potentially hazardous materials typical of those used in residential and commercial developments, including cleaning agents, paints, pesticides, and other materials used for landscaping. All potentially hazardous materials would be used, stored, and disposed of in accordance with manufacturers specifications and handled in compliance with applicable Page IV.E-12

13 standards and regulations. Any risks associated with these materials would be adequately reduced to a less than significant level through compliance with these standards and regulations. Therefore, as the project would comply with applicable regulations and would not expose persons to substantial risk resulting from the release of hazardous materials or exposure to health hazards in excess of regulatory standards, impacts associated with the use of these hazardous substances during operation of the proposed project would be less than significant. (b) Asbestos-Containing Materials Because all of the existing buildings located on the project site were constructed prior to 1979, it is likely that asbestos is present in some of the building materials. As part of the project, all existing buildings and structures would be removed. The demolition of these buildings would have the potential to release asbestos fibers into the atmosphere if they are not properly stabilized or removed prior to demolition. The removal of asbestos is regulated by SCAQMD Rule 1403; therefore, any asbestos found on-site would be removed by a certified asbestos containment contractor in accordance with applicable regulations prior to demolition. With adherence to applicable regulatory requirements, impacts related to asbestos would be reduced to a less than significant level. Implementation of Mitigation Measure E-1 below would ensure that impacts would be less than significant. (c) Lead-Based Paint As discussed above, a lead abatement program was conducted on-site from late 1998 through 1999, during which all building interiors were made lead-free, and building exteriors were made lead-safe. However, due to the age of the structures and the known former presence of lead on-site, it is possible that trace amounts of lead remain. Since project construction would involve the removal of all existing buildings and structures on-site, demolition activities may have the potential for limited lead exposure. Compliance with applicable procedural requirements and regulations regarding proper removal and disposal of any lead-based paint found on-site, if present, would reduce impacts to a less than significant level. Mitigation Measure E-2 is proposed below to ensure compliance such that impacts remain less than significant. (3) Airport Safety Provisions As described previously, the FAA s FAR Part 77 regulations establish minimum standards to ensure air safety by regulating the construction or alteration of buildings or structures that may affect airport operations. Specific requirements apply to buildings of 200 feet in height or greater, as determined by the FAA depending on site-specific conditions. While the majority of new buildings to be developed as part of the project would Page IV.E-13

14 range in height from two to seven stories (approximately 24 feet to 75 feet), up to three buildings could be as tall as 18 stories (approximately 200 feet), and up to three buildings could be as tall as 24 stories (approximately 260 feet). As such, the project Applicant would file the appropriate forms and include rooftop lighting, as necessary, subject to the approval of the FAA, in order to ensure that the project would not result in significant impacts relative to airport safety. Please refer to Mitigation Measure E-3 below. (4) Emergency Response and Evacuation Plans Please refer to Section IV.J.1, Police Protection, and Section IV.J.2, Fire Protection, of this Draft EIR for an analysis of emergency response and evacuation plans for the project site. As shown therein, with the incorporation of mitigation measures, impacts on emergency vehicle access and response times to the project site would be less than significant. 4. Cumulative Impacts Cumulative growth in the greater project area through 2030 includes specific known development projects as well as general ambient growth projected to occur, as described in Section III, Environmental Setting, of this Draft EIR. Some of this growth is anticipated to occur on or around properties in the project area known to contain hazardous or potentially hazardous conditions, such as hazardous waste generation or handling, or the presence of LUSTs. While impacts associated with hazards and hazardous materials are typically sitespecific and do not cumulatively affect off-site areas, conditions such as contaminated groundwater can affect down-gradient properties. In addition, operation of many of the related projects can reasonably be expected to involve the limited use of potentially hazardous materials typical of those used in residential and commercial developments, including cleaning agents, paints, pesticides, and other materials used for landscaping. Further, some of the related projects propose industrial uses that may also utilize, handle, store, or generate hazardous materials. However, all future development located within the vicinity of the project site would be subject to the same local, regional, State, and federal regulations pertaining to hazards and hazardous materials. Any development sites affected by contaminated soil or groundwater would require removal or remediation in compliance with applicable regulatory controls. It is also expected that all potentially hazardous materials would be used, stored, and disposed of in accordance with manufacturers specifications and handled in compliance with applicable standards and regulations. Any risks associated with these materials would be adequately reduced to a less than significant level through compliance with these standards and regulations. As such, the concurrent development of the project and related projects would not result in cumulatively significant impacts with regard to hazards and hazardous materials. Page IV.E-14

15 5. Project Design Features and Mitigation Measures a. Project Design Features Project Design Feature E-1: All hazardous materials on the project site shall be acquired, handled, used, stored, and disposed of in accordance with all applicable Federal, State and local requirements. Monitoring of the Applicant's hazardous materials management shall be conducted by the Los Angeles Fire Department, and other applicable regulatory authorities, as appropriate. Likewise, the disposal of on-site generated hazardous waste shall occur in accordance with all applicable regulations. b. Mitigation Measures Mitigation Measure E-1: Prior to the issuance of demolition permits, the project Applicant shall submit verification to the Department of Building and Safety that an asbestos survey has been conducted at all buildings included within the demolition permit and located on the project site. If asbestos is not found, no further action is required. If asbestos is found, the project Applicant shall follow all procedural requirements and regulations of South Coast Air Quality Management District Rule Additionally, if asbestos is found, the project Applicant shall submit documentation prior to the issuance of a Certificate of Occupancy that demonstrates all regulatory requirements for asbestos abatement have been fulfilled to the satisfaction of the Department of Building and Safety. Mitigation Measure E-2: Prior to the issuance of demolition permits, the project Applicant shall submit verification to the Department of Building and Safety that a lead-based paint survey has been conducted at all buildings included within the demolition permit and located on the project site. If lead-based paint is not found, no further action is required. If lead-based paint is found, the project Applicant shall follow all procedural requirements and regulations for proper removal and disposal of the lead-based paint. Additionally, if lead-based paint is found, the project Applicant shall submit documentation prior to the issuance of a Certificate of Occupancy that demonstrates all regulatory requirements for leadbased paint removal and disposal have been fulfilled to the satisfaction of the Department of Building and Safety. Mitigation Measure E-3: Prior to the issuance of building permits for buildings that are 200 feet or greater in height from the grading terrain, the Page IV.E-15

16 Applicant shall file a Notice of Proposed Construction or Alteration (Form ) with the Federal Aviation Administration. 6. Level of Significance After Mitigation Potentially significant impacts associated with hazards and hazardous materials would be reduced to less than significant with implementation of the aforementioned mitigation measures and project design feature. Page IV.E-16

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