4.5 HAZARDS AND HAZARDOUS MATERIALS Introduction Environmental Setting

Transcription

1 4.5 HAZARDS AND HAZARDOUS MATERIALS Introduction This section describes the potential adverse impacts on human health and the environment due to exposure to hazards that could result from development of the proposed City of Citrus Heights City Hall and Medical Office Building Project (proposed project). The hazards evaluated in this section are associated with potential exposure to hazardous materials that may be present at the project sites as well as those used, generated, stored, or transported in or immediately adjacent to the project area during project construction and operation. No comments were received in response to the Notice of Preparation (NOP) pertaining to hazards. The NOP and the comment letters received in response to the NOP are included in Appendix A to this Draft Environmental Impact Report (EIR). The primary sources reviewed during preparation of this section include the Phase I Environmental Site Assessment (ESA) of the Northwest Corner of Greenback Land and Fountain Square Site by Cardno ATC, July 25, 2013; a Phase I ESA of the Stock Ranch Condominiums by ENGEO, August 30, 2005; and the Stock Ranch Parcel Report Review. Geotechnical Report and Environmental Site Assessment Review by ENGEO, September 22, These reports are included in Appendix G to this Draft EIR Environmental Setting Disturbance and use of hazardous materials during construction and use of hazardous materials during project operation could affect residents, workers, and visitors within and adjacent to the proposed project. These conditions can pose a risk of exposure to people or the environment due to accidental releases, such as spills, or as a result of soil or groundwater contamination related to past uses. Transportation of hazardous materials through or near the project site could also pose hazards. As defined in the California Health and Safety Code Section 25501, hazardous material means any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant hazard to human health and safety, or to the environment, if released into the workplace or the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous waste, and any material that a handler or the administering agency has a reasonable basis for believing would be injurious to the health and safety of persons, or harmful to the environment if released into the workplace or the environment. Hazardous materials can be categorized as non-radioactive hazardous chemical materials, radioactive materials, and biohazardous materials. For non-radioactive hazardous chemical December

2 materials, the above definition is typically adequate. Radioactive and biohazardous materials are further defined as follows: Radioactive materials contain atoms with unstable nuclei that spontaneously emit ionizing radiation to increase their stability. Biohazardous materials include materials containing certain infectious agents (microorganisms, bacteria, molds, parasites, viruses) that normally cause or significantly contribute to increased human mortality or organisms capable of being communicated by invading and multiplying in body tissues. Types of hazardous materials found in medical facilities may include chemotherapy reagents and other pharmaceuticals; chemicals used to sterilize equipment; formaldehyde for specimen preservation; and solvents, oxidizers, corrosives, and stains used in clinical laboratories. Radioactive materials generally contain radioactive atoms; however, x-ray equipment (which does not involve any radioactive substances) is also regulated as radioactive material. Hazardous waste is a subset of hazardous materials. For the purposes of this EIR, the definition of hazardous waste is taken from California Health and Safety Code Section and California Code of Regulations (CCR), Title 22 Section Hazardous wastes are wastes that, because of their quantity, concentration, or physical, chemical, or infectious characteristics, may either cause, or significantly contribute to, an increase in mortality or an increase in serious illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed. Hazardous wastes can generally be grouped into three categories: hazardous chemical waste, radioactive waste, and medical waste. These three categories are further defined below: Hazardous chemical wastes are generally residuals of hazardous chemicals applied to various uses. Hazardous chemical waste can include residuals from mercury, photography liquids, photography solids, flammable liquids, aerosols, and laboratory solvents and chemicals. Radioactive wastes are radioactive materials that are discarded (including wastes in storage) or abandoned. Medical waste includes both biohazardous wastes (byproducts of biohazardous materials) and sharps (devices capable of cutting or piercing, such as hypodermic needles, razor blades, and broken glass) resulting from the diagnosis, treatment, or immunization of human beings, or research pertaining to these activities. December

3 Existing Land Uses On the Fountain Square site, the proposed location for the Medical Office Building, there are five structures and an event kiosk that were constructed between 1977 and These structures would be demolished to accommodate the new Medical Office Building. The remaining portions of the property are improved with asphalt-paved parking lots. The proposed City Hall location, the Stock site, is currently undeveloped and supports with nonnative grasses, a few mature trees, a drainage ditch, and a wetland. Sensitive Receptors Sensitive receptors are those areas that typically contain populations that could be particularly sensitive to hazardous materials released by activities related to a proposed project. Populations that could be particularly sensitive to hazardous materials include people who are elderly, sick, or young, as well as endangered or threatened species. Thus, sensitive receptors are typically identified as including land uses such as residential areas, nursing homes, hospitals, medical centers, schools, day care centers, wildlife refuges, wetlands, water bodies, and other important habitat. For the City Hall and Medical Office Building project, activities with a potential to release hazardous materials include demolition of the existing buildings at the Fountain Square site and general project construction. Residential land uses are the primary sensitive receptor in the vicinity. Residential neighborhoods are located adjacent to the west and south of the Fountain Square site and to the west and north of the Stock site. In addition senior apartments are adjacent to the east of the Stock site. Other land uses where people may be present in the area include the Sam s Club shopping center, Van Maren Park, the U.S. Post Office, and the Citrus Heights Community Center. Phase I ESA Fountain Square Site Cardno ATC prepared a Phase I ESA for the Fountain Square site and no environmental conditions were identified as present on the site, with the exception of potential asbestoscontaining material (ACM) and lead-based paint (LBP) in buildings proposed for demolition. According to asbestos project reports provided by the Sacramento Metropolitan Air Quality Management District, a total of 2,820 square feet of ACM was removed from the basement and kitchen areas of the building located at 6237 Fountain Square Drive in 2002, 2003, and Additionally, the Phase I ESA reported known ACM within the vinyl flooring mastic in the existing building at 6229 Fountain Square Drive. December

4 According to the Phase I ESA, the property historically consisted of undeveloped and/or agricultural land until the site was developed as a plant nursery starting in Based on the potential historical agricultural usage of the property as well as the nursery use of the site, pesticides and/or herbicides may have been used on the property and near-surface soils may have at one time contained these compounds. However, due to the extensive on-site grading and reworking of the near-surface soils the potential historical agricultural usage of the property is not considered to represent an environmental concern (Cardno ATC 2013). Additionally, Cardno ATC identified a property located 300 feet to the southeast of the proposed project site that is listed within the state s leaking underground storage tank database due to a release of gasoline reported in November Cardno ATC reported that this release was limited to the soil, and all impacted soil was removed from the site. The facility received case closure status from the Sacramento County (County) Local Oversight Program in Based on the limited release (soil impact only) and the current regulatory status, Cardno ATC determined that the facility is not considered to represent a recognized environmental condition to the property at this time Phase 1 ESA Stock Site A Phase I ESA was prepared for the Stock site in 2005 by ENGEO. The conclusions of the 2005 Phase 1 analysis were confirmed based on a site reconnaissance and follow up data review completed by ENGEO in No hazardous substances or conditions have been identified at the project site and the site is not affected by any off-site releases of hazardous materials Regulatory Setting Hazardous materials handling and hazardous waste management are subject to laws and regulations at all levels of government as summarized below. State and federal laws require that hazardous materials be properly handled, used, stored, and disposed of, and, in the event that such materials are accidentally released, that appropriate measures are taken to prevent or to mitigate injury to human health or the environment. California s Hazardous Materials Release Response Plans and Inventory Law, sometimes called the Business Plan Act, aims to minimize the potential for accidents involving hazardous materials and to facilitate an appropriate response to possible hazardous materials emergencies. Businesses, including medical facilities, that use hazardous materials in quantities that exceed the state-established threshold quantities of 55 gallons for liquids, 500 pounds for solids, and 200 cubic feet at standard temperature and pressure for compressed gases, are required by law to create a hazardous materials business plan (HMBP). The HMBP provides information to the local emergency response agency regarding the types and quantities of hazardous materials stored at a facility and provides detailed emergency planning and response procedures in the event of a hazardous materials release. In the December

5 event that a facility stores quantities of a specific acutely hazardous material above the thresholds set forth by the California code, facilities are also required to prepare a risk management plan and a California accidental release plan, which provides information on the potential impact zone in the event of a worst-case release and requires plans and programs designed to minimize the probability of an accidental release and to mitigate potential impacts. The County Office of Emergency Services (OES) and the Sacramento Metropolitan Fire District (Metro Fire) implement and enforce federal, state, and local laws regarding hazardous materials management and emergency planning. The County s Environmental Management Department (EMD) is the Certified Unified Program Agency (CUPA) for the County and the City of Citrus Heights (City). Under the CUPA program, administration of the following six hazardous materials programs is consolidated under the County EMD: 1. Hazardous Materials Inventory and Business Plan Program (California Health and Safety Code, Chapter 6.95) 2. Hazardous Waste Generator 3. On-Site Hazardous Waste Treatment (Tiered Permitting) Programs 4. Underground Storage Tank Program (California Health and Safety Code, Chapter 6.7) 5. Aboveground Storage Tank Spill Prevention Control and Countermeasure Plan Program (California Health and Safety Code, Chapter 6.67) 6. California Accidental Release Prevention Program Many other local, state, and federal agencies contribute to management of hazards and hazardous materials. The California Office of Statewide Health Planning and Development, the Citrus Heights Building Division, and Metro Fire implement and enforce state laws regarding building and fire safety. The California and federal Occupational Safety and Health Administration (Cal/OSHA and OSHA) implement and enforce state and federal laws regarding worker safety. California Department of Toxic Substances Control (DTSC) implements and enforces federal and state laws regarding hazardous waste handling. The Radiologic Health Branch of the California Department of Health Services implements and enforces state and federal laws regarding radioactive materials management. The County EMD implements and enforces state laws regarding medical waste handling. The County EMD is responsible for implementing the Medical Waste Management Act, California Health and Safety Code, Section The Medical Waste Management Act regulates the generation, handling, storage, treatment, and disposal of medical waste. The U.S. Department of Transportation, the U.S. Postal Service, the U.S. Environmental Protection Agency (EPA), the California Highway Patrol (CHP), the California Department of Transportation (Caltrans), and the DTSC implement and enforce State and federal laws regarding hazardous materials transportation. Sacramento Metropolitan Air December

6 Quality Management District, Cal/OSHA, and DTSC implement and enforce state and federal laws regarding hazardous building components. The Central Valley Regional Water Quality Control Board (CVRWQCB) oversees the groundwater protection program throughout the County. Federal Regulations Several federal agencies regulate hazardous materials. These include the EPA, OSHA, and the U.S. Department of Transportation. Applicable federal regulations are contained primarily in Titles 10, 29, 40 and 49 of the Code of Federal Regulations (CFR). Title 40 of the CFR addresses emergency planning and notification, hazardous material management plans, soil and water pollution remediation and reporting, and community right-to-know reporting. Investigation and/or cleanup of soil contamination are subject to standards set forth in Title 40. Title 49 applies to motor carriers that transport hazardous materials and regulates proper handling and use of placards to identify the hazardous qualities of materials being transported. Hazardous Materials Handling and Transport At the federal level, the principal agency regulating the generation, transport, and disposal of hazardous wastes is the EPA, under the authority of the Resource Conservation and Recovery Act (RCRA). RCRA is an all-encompassing federal regulatory program regarding the generation, transportation, treatment, storage, and disposal of hazardous wastes. The Hazardous and Solid Waste Amendments of 1984 amended the RCRA to prohibit the use of certain techniques to dispose of various hazardous substances. The EPA has delegated RCRA authority to the State of California. This authority is administered by the California DTSC. The federal Emergency Planning and Community Right-to-Know Act of 1986 (42 U.S.C ) is Title III of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which is commonly referred to as Superfund and is administered by the EPA. The Emergency Planning and Community Right-to-Know Act imposes hazardous materials planning requirements to help protect local communities in the event of accidental release of hazardous substances. Worker Safety Requirements OSHA is responsible at the federal level for ensuring worker safety. OSHA sets federal standards for implementing workplace training, exposure limits, and safety procedures for the handling of hazardous substances and hazardous materials (as well as other hazards). OSHA also establishes criteria by which each state can implement its own health and safety program. December

7 State Regulations California Building Code and California Fire Code Prior to issuance of building permits and during occupancy of the proposed project, the City s Building Division and Metro Fire would be responsible for reviewing plans for facilities proposing to use hazardous materials to ensure that applicable California Building Code and California Fire Code standards are included in project design. These standards address, among other elements, proper storage and secondary containment for hazardous materials and fire-safe construction and materials. Use of appropriate design features would help reduce the potential for accidental releases of hazardous materials that could affect occupants or require emergency response services. Hazardous Materials Handling The California Environmental Protection Agency (CalEPA) and the OES establish regulations governing the use of hazardous materials in California. Within CalEPA, DTSC has primary regulatory responsibility for hazardous waste management. Enforcement of regulations can be delegated to local jurisdictions that enter into agreements with DTSC for the generation, transport, and disposal of hazardous materials under the authority of the Hazardous Waste Control Law. Along with the DTSC, the RWQCB is responsible for implementing regulations pertaining to management of soil and groundwater investigation and cleanup. The project site is within the jurisdiction of the CVRWQCB. The RWQCB s regulations are contained in Title 27 of the CCR. The DTSC, CVRWQCB, and/or a local agency (e.g., Sacramento County EMD as the CUPA, as discussed below) typically oversee investigation and cleanup of contaminated sites. The CHP and Caltrans are the enforcement agencies for hazardous materials transportation regulations. Hazardous materials and waste transporters are responsible for complying with all applicable packaging, labeling, and shipping regulations. California Vehicle Code Section regulates the transport of hazardous materials. Emergency Response to Hazardous Materials Incidents California has developed an emergency response plan to coordinate emergency services provided by federal and state agencies, local governments, and private agencies. Response to hazardous material incidents is one part of this plan. The plan is managed by the California OES, which coordinates the responses of other agencies, including CalEPA, CHP, California Department of Fish and Wildlife, CVRWQCB, and Metro Fire. December

8 Medical Waste Handling The California Department of Health Services Medical Waste Management Program enforces the California Medical Waste Management Act and related regulations. Medical facilities that generate 200 or more pounds per month of medical waste in any month of a 12-month period are required to implement a Medical Waste Management Plan, which acts as the Medical Waste Facility Permit application. A Medical Waste Management Plan must be filed with the County EMD, the enforcement and permitting agency, on forms provided by the County EMD. The plan must contain, at a minimum, the name, address, and type of business generating hazardous waste; the type and estimated monthly quantity of medical waste generated; the type and capacity of medical waste treatment facilities used on site; the name and address of the registered hazardous waste hauling service; the name and address of the off-site medical waste treatment facility; an emergency action plan complying with California Department of Health Services regulations; and a statement certifying that the information provided is complete and accurate. The Medical Waste Management Plan is enforced through an annual certification completed by the medical waste generator and through annual inspections by Metro Fire and/or the County EMD. Medical waste and its disposal are generally regulated in the same manner as hazardous waste, except that special provisions apply to storage, disinfection, containment, and transportation. Medical waste must be stored in closed red bags marked biohazard and, when transported for disposal, placed inside hard-walled containers with lids. The law imposes a cradle-to-grave tracking system and a calibration and monitoring system for on-site treatment. Facilities that treat medical waste on site must obtain a medical waste facility On-Site Treatment Facility permit from the County EMD, which may condition the handling or treatment of medical waste to protect public health and safety. Permitted facilities are subject to annual audits and are required to submit a Generator Registration Application (Form DHS 8550). Local Regulations Sacramento County The Environmental Compliance Division of the County s EMD administers the CUPA elements in the County. The County OES provides emergency planning and response services in response to large-scale incidents and disasters. The County OES is responsible for alerting and notifying appropriate agencies when disaster strikes, coordinating all agencies that respond, ensuring that resources are available and mobilized in times of disaster, developing plans and procedures in response to and recovery from disasters, and developing and providing preparedness materials for the public. December

9 Hazardous Materials Emergency Response In accordance with Health and Safety Code Chapter 6.95, Section 25500, the Sacramento County EMD prepared the Area Plan for Emergency Response to Hazardous Materials Incidents in Sacramento County (2012). The plan describes the responsibilities of local, state, and federal agencies during hazardous materials incidents. Preparation of the plan was informed by information in the HMBPs and business emergency response plans required under the emergency response agencies, such as fire department/hazardous materials response teams. In addition, the EMD operates an incident response program to provide on-site technical consultation and assistance to agencies responding to spills or releases of hazardous materials. While Metro Fire is the first responder for the City, Metro Fire has established mutual aid agreements that allow Metro Fire to request services from hazardous materials response teams in the City of Sacramento, other emergency responders throughout Sacramento County, and the City of Roseville Fire Department in the event of a large-scale incident. Metro Fire would also provide assistance to thechp, OES, and other responding agencies as requested in the event of a hazardous materials spill on Interstate 80. City of Citrus Heights General Plan The City s General Plan Community Health Element includes the following goal and policy relating to hazardous materials and public safety and that are applicable to the proposed project. Goal 51: Protect the community s health, safety, natural resources and property from potential risks associated with the use, transport, treatment, and disposal of hazardous materials. Policy 51.1: Provide for the safe use and disposal of hazardous materials and appropriate responses to protect the City in the event of a hazardous materials incident Impacts Thresholds of Significance As evaluated in the Initial Study prepared for this project (and provided in Appendix B to this Draft EIR), the project would have a less-than-significant impact with respect to the following significance criteria: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? December

10 Would the project result in a safety hazard related to the proximity of the site to an airport or private airstrip; impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Would the project expose people or structures to a significant risk of loss, injury, or death involving wildland fires? In addition, the Phase I ESAs prepared for both project sites conclude that both sites are not included on a list of hazardous materials sites compiled pursuant to California Government Code Section The reports further conclude that the sites are not listed as hazardous substance or petroleum product generators and there is no evidence of any current or past usage or storage of hazardous materials on either site. Therefore, the project is considered to have a less-thansignificant impact with respect to the following significance criteria: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section ? The analysis below evaluates potentially significant project impacts related to hazards and hazardous materials based on the following significance criteria, consistent with Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 CCR et seq.), the City s General Plan, and professional judgment. The project would result in a significant impact if it would: 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 or accident conditions involving the release of hazardous materials into the environment. Impact The proposed project could transport, use, or dispose of hazardous materials or result in an accidental release of hazardous materials into the environment. Exposure of construction workers, employees, site users, or neighbors to hazardous materials could occur as a result of improper handling or use of hazardous materials or hazardous wastes during construction or operation of the project, particularly by untrained personnel; transportation accidents; unsound disposal methods; or fire, explosion, or other emergencies. Construction Effects The project proposes to move City Hall from its current location on Fountain Square Drive to a site adjacent to Stock Ranch Road (the Stock site) and construct a Medical Office Building on December

11 the former City Hall site (the Fountain Square site). A Utility Yard consisting of a 4,000-squarefoot building, 5,000 square feet of screened outdoor storage, and secured parking for city vehicles is also proposed. The proposed project would involve construction activities such as site preparation, grading, and construction of the proposed Medical Office Building, City Hall building, Utility Yard building, and associated improvements and amenities. Building demolition would be required on the Fountain Square site. These activities would involve the use of heavy equipment, which would contain fuels and oils, and various other products such as concrete, paints, and adhesives. Use and storage of hazardous materials used in typical construction activities is regulated by a variety of federal, state, and local regulations administered by the California Office of Statewide Health Planning and Development, the Citrus Heights Building Division, Metro Fire, Cal/OSHA, OSHA, and the California DTSC. In addition to the CUPA, Metro Fire would review construction plans when finalized to ensure that proper safety and storage protocols and procedures are in place in the event of an emergency. Metro Fire is available to respond to hazardous materials complaints or emergencies, if any, during project construction. Hazardous materials regulations were established at the state level to ensure compliance with federal regulations to reduce the risk to human health and the environment from the routine use of hazardous substances. These regulations must be implemented by employers and businesses and are monitored by the state (Cal/OSHA in the workplace or DTSC for hazardous waste) and local jurisdictions (County CUPA). Building demolition could result in release of ACM and LBP from some of the existing structures. This could expose construction workers and site neighbors to hazards associated with airborne asbestos and lead. This potentially significant impact would be reduced to a less-thansignificant level by implementation of Mitigation Measure (MM) 4.5-1, which requires predemolition surveys of each building to identify ACM and LBP, and adherence to applicable state and federal regulations, including the EPA s Asbestos National Emissions Standards for Hazardous Air Pollutants and the Cal/OSHA Construction Lead Standard (8 CCR ) during demolition activities and in disposal of contaminated materials. Operational Effects During project operation, hazardous materials use would be associated with use of landscaping products such as fertilizer and pesticides, use of household cleaning products, and various drugs and hazardous materials required in medical office uses. All chemicals would be stored inside the buildings with appropriate containment. Operation of the proposed medical office building would require the use, transport, and handling, as well as disposal, of a variety of hazardous medical materials. However, the use, transport, handling, storage, and disposal of all medical-related hazardous materials are highly regulated by December

12 federal, state, and local laws and requirements. The services provided at the Medical Office Building would be limited to office visits and minor outpatient procedures. It is not anticipated that the Medical Office Building would require the storage of hazardous materials in quantities that would require preparation of an HMBP. However, it is assumed the Medical Office Building would comply with all County requirements and prepare an HMBP if required. Customary storage and handling precautions would be used by staff at the Medical Office Building, and the project is not expected to result in exposure of individuals at the project site or adjacent uses to substantial risks of hazardous conditions or releases of hazardous materials. The proposed City Hall on the Stock site is not anticipated to result in the use, transport, or handling of any hazardous materials, with the exception of household hazardous materials such as cleaning products and fertilizers and pesticides used in landscape maintenance. Moreover, because the new City Hall site would largely retain the same landscaping and cleaning practices upon relocation to the Stock site from its current location, there would not be any significant increase or change in hazardous material use, transport, or handling at City Hall. Operation of the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, and would not result in reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Implementation of and compliance with existing federal, state, and local laws and requirements that address use (including reporting and disclosure requirements), storage, and transport of hazardous materials and are enforced by the CUPA would reduce impacts associated with the routine use, storage, and transportation of hazardous materials during project operation to a less-than-significant level Cumulative Impacts The cumulative scenario for considering impacts related to the use, handling, storage, and transport of hazardous materials as well as the disposal of hazardous materials or accidental release of hazardous materials assumes the construction of a 32,000-square-foot office building on the remaining portion of the Stock site, as well as buildout of the City s General Plan. This geographic scope is selected because cumulative hazardous effects would occur when hazardous materials releases happen in proximity to one another, resulting in multiple exposures to the same sensitive receptors. Impact The transport, use, or disposal of hazardous materials or accidental releases of hazardous materials into the environment from buildout of the City of Citrus Heights General Plan could expose City residents to hazardous materials. The proposed project, in conjunction with other past, present, and reasonably foreseeable future development within the City of Citrus Heights, would increase the use, transport, and handling of December

13 hazardous materials in the city. The General Plan EIR found that implementation of the City s General Plan policies and state and federal regulations requiring site-specific risk management controls during construction would minimize the potential for hazardous materials releases and provide for emergency response planning. Further the General Plan EIR found that implementation of the General Plan policies along with state and federal regulation would reduce the potential impacts of the routine transportation of hazardous materials in the planning area and accidental release of hazardous materials (City of Citrus Heights 2011). The General Plan EIR concluded that the potential impacts related to routine transport, use, or disposal or accidental release of hazardous materials would be less than significant. Additionally, hazardous materials incidents would typically be site specific and would involve accidental spills or inadvertent releases. The effects of such incidents, then, would not be additive to effects from other similar incidents occurring elsewhere. Associated health and safety risks would generally be limited to those individuals using the materials or to persons in the immediate vicinity of the materials. Thus, the cumulative effects of past, present, and reasonably foreseeable future projects, combined with the proposed project, would be less than significant Mitigation Measures MM A comprehensive survey for the presence of asbestos-containing material (ACM) and lead-based paint (LBP) shall be conducted at the Fountain Square project site prior to any demolition activities. Demolition of buildings containing ACM and/or LBP and disposal of these materials must be conducted in accordance with state and federal regulations, including the U.S. Environmental Protection Agency s (EPA s) Asbestos National Emissions Standards for Hazardous Air Pollutants, the California Occupational Safety and Health Administration s Construction Lead Standard (8 CCR ), and California Department of Toxic Substances Control and EPA requirements for disposal of hazardous waste. Disposal of any ACM and/or LBP found on the site shall be carried out by a contractor trained and qualified to conduct lead- or asbestos-related construction work and in accordance with the appropriate state and federal standards to ensure that these materials are not released into the air in the project vicinity. December

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