4. ENVIRONMENTAL IMPACT ANALYSIS F. HAZARDS AND HAZARDOUS MATERIALS

Transcription

1 4. ENVIRONMENTAL IMPACT ANALYSIS F. HAZARDS AND HAZARDOUS MATERIALS INTRODUCTION The section includes information from the following, which are included as Appendix G to this Draft EIR: G-1 Phase I Environmental Site Assessment, EMS, Inc., July G-2 Phase II Environmental Site Assessment Report, EMS, Inc., March 11, ENVIRONMENTAL SETTING Regulatory Framework A variety of laws and regulations governing the management and control of hazardous substances have been established at the federal, state, and local levels to protect the environment. Hazardous Materials and Waste Management The use and storage of hazardous materials and wastes are governed by various federal, state, and local regulations whose jurisdictions and responsibilities sometimes overlap. Federal The Federal Resource Conservation and Recovery Act (RCRA) (Title 40 of the Code of Federal Regulations [CFR]) gives the U.S. Environmental Protection Agency (USEPA) the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste by "large-quantity generators" (1,000 kilograms/month or more). Under RCRA regulations, hazardous wastes must be tracked from the time of generation to the point of disposal. At a minimum, each generator of hazardous waste must register and obtain a hazardous waste activity identification number. If hazardous wastes are stored for more than 90 days or treated or disposed at a facility, any treatment, storage, or disposal unit must be permitted under RCRA. Additionally, all hazardous waste transporters are required to be permitted and must have an identification number. RCRA allows individual states to develop their own program for the regulation of hazardous waste, as long as it is at least as stringent as RCRA. The Federal Occupational Safety and Health Act of 1970, which is implemented by the Federal Occupational Safety and Health Administration (OSHA), contains provisions with respect to hazardous materials handling. Federal OSHA requirements, as set forth in Title 29 of the Code of CFR, are designed to promote worker safety, worker training, and a worker s right to-know. OSHA has delegated the authority to administer OSHA regulations to the State of California. Page 4.F-1

2 Title 49 of the CFR specifies additional requirements and regulations with respect to the transport of hazardous materials. 1 Title 49 of the CFR requires that every employee who transports hazardous materials receive training to recognize and identify hazardous materials and become familiar with hazardous materials requirements. Drivers are also required to be trained in function and commodity specific requirements. In addition, vehicles transporting certain types or quantities of hazardous materials must display placards (warning) signs. As previously indicated, transporters of hazardous wastes must be permitted and have an identification number. State At the state level, authority for the statewide administration and enforcement of RCRA rests with the California EPA s (Cal-EPA) Department of Toxic Substances Control (DTSC). While the DTSC has primary State responsibility in regulating the generation, storage and disposal of hazardous materials, DTSC may further delegate enforcement authority to local jurisdictions. In addition, the DTSC is responsible and/or provides oversight for contamination cleanup, and administers state-wide hazardous waste reduction programs. 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, 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 Cal EPA s 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 local fire department. The California OSHA (Cal-OSHA) program is administered and enforced by the Division of Occupational Safety and Health (DOSH). Cal-OSHA is very similar to the Federal OSHA program. For example, both programs contain rules and procedures related to exposure to hazardous materials during demolition and construction activities. In addition, Cal-OSHA requires employers to implement a comprehensive, written Injury and Illness Prevention Program (IIPP). An IIPP is an employee safety program for potential workplace hazards, including those associated with hazardous materials. The Hazardous Waste Source Reduction and Management Review Act of 1989 require generators of 12,000 kilograms/year of typical/operational hazardous waste to conduct an evaluation of their waste streams every four years and to select and implement viable source reductions alternatives. This Act does not apply to non-typical hazardous waste (such as asbestos and polychlorinated biphenyls). The California Vehicle Code also states that every motor carrier transporting hazardous materials (for which the display of hazardous materials placards are required or in excess of 500 pounds, transported for a fee, which would require placarding if shipped in greater amounts in the same manner) must have a Hazardous Materials Transportation License issued by the California Highway Patrol. 1 Title 49 of the CFR contains the regulations set forth by the Hazardous Materials Transportation Act of Page 4.F-2

3 The management of medical wastes is further governed by regulations of the Medical Waste Management Act. Under these regulations, medical waste generators are required to be registered. Furthermore, all medical waste transporters doing business in California must report information regarding business ownership, location, vehicles, and clients to the California Department of Public Health (CDPH). Only medical waste transporters listed with CDPH are allowed to transport medical waste. All medical waste transporters must carry paperwork issued by CDPH in each vehicle while transporting medical waste. Asbestos-Containing Materials The Federal EPA has enacted strict requirements on the use, handling, and disposal of asbestos-containing materials (ACM) under the Toxic Substances Control Act (TSCA). 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 Federal EPA has also established National Emission Standards for Hazardous Air Pollutants (NESHAP) 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. Non-friable bulk asbestos-containing waste is considered non-hazardous regardless of its asbestos content and is not subject to regulation. The Cal-EPA DTSC regulates the packaging, on-site accumulation, transportation, 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 clean-up 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. Lead-Based Paint The demolition of buildings containing lead-based paints (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, 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 Page 4.F-3

4 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. Phase I ESA Current Uses of the Property The Project Site consists of an equipment rental yard known as A-1 Coast Rentals and contains a large number of vehicles, equipment, and maintenance areas used in support of the rental of construction equipment. The vehicles include large semi-tractor trailer trucks with flat beds used for delivery of rental equipment, forklifts, scissor lifts, cranes, temporary fencing, portable toilets, and temporary electrical poles. The Project Site contains a 2,000-gallon, above-ground diesel tank, a 500-gallon, above-ground gasoline tank, and two high-pressure propane tanks, all used to dispense fuel for rental equipment and support vehicles. The equipment maintenance area is used for changing of vehicle oils and lubricants, equipment repairs, and washing. Wastewater from equipment cleaning drains to an underground clarifier located inside one of the maintenance bays. Finally, the Project Site contains an area where sewage from serviced portable toilets is flushed into the sanitary sewer system and the tanker trucks carrying the sewage are washed and rinsed. Past Uses of the Property According to the Phase I Environmental Site Assessment (ESA), included in Appendix G-1 of this Draft EIR, the Project Site was vacant land in the early 1900s. By 1928, the Site was occupied by one building, which appears to be a residence. A second building was added on the eastern side of the Site by 1947, when the Site was also being used for agriculture or as a nursery. The Site remained a nursery until 1972, when the present day equipment rental yard occupied the northern half of the property, while the southern half remained a nursery. In the late 1970s or early 1980s, the entire property was converted to an equipment yard. Past and Current Uses of Adjoining Properties According to the Phase I ESA, the adjoining properties on the northern and eastern sides were residences or mixed-use commercial properties. The current Shell gas station located in the L of the property at the northeast corner of Crenshaw Boulevard and Lomita Boulevard appeared in the early 1960s. To the west across Crenshaw Boulevard, there has been a petroleum above-ground tank farm from the early 1920s to the present. The developed area to the south has consisted of mixed-use commercial properties. Records Review As part of the Phase I ESA, EMS retained Environmental Data Resources, Inc. (EDR) to perform a search of reasonably ascertainable information from databases for facilities with environmental records within the Project Site vicinity. The information sources utilized by EDR included publicly available databases compiled by federal, state, tribal and local governmental agencies and proprietary databases available through EDR. The databases searched provide information on facilities with records including, but not Page 4.F-4

5 limited to, the following potential environmental concerns: Resource Conservation and Recovery Act Small and Large Quantity Hazardous Waste Generators (RCRA-SQGs and RCRALQGs); the Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS); registered above-ground storage tanks (ASTs); registered underground storage tanks (USTs); historical USTs (HIST USTs); leaking USTs (LUSTs); non-tank spills of hazardous materials; active and inactive landfills; and facilities engaged in the investigation and cleanup of known releases of hazardous materials. EDR s regulatory agency database search included searches for liens and AULs from the following four EPA databases: Federal Superfund Liens (NPL LIENS); CERCLA Lien Information (LIEN2); Engineering Controls Sites (US ENG CONTROLS); and Sites with Institutional Controls (US INST CONTROLS). EDR s regulatory agency database search also included a search of the DTSC s Deed Restriction Listing (DEED) and Lien Holder (LIENS) databases. Finally, EMS retained EDR to perform an environmental lien search for the Project Site. The records search indicates that the Project Site is not identified on any of the environmental databases that would indicate any historic or current environmental violations and EDR s environmental lien search found no environmental liens or AULs for the Project Site s parcel number of The Project Site was identified on a number of databases owning to the past use of the Site. Specifically, the Site was identified on CA LUST, RCRA-SQG, FINDS, CA HAZNET, CA RGA LUST, HIST CORTESE, LA CO. SITE MITIGATION, CA SWEEPS UST, and CA LOS ANGELES CO. HMS. Additionally, the Site was identified has having a leaking UST (gasoline tank) that was removed and the case was closed with the RWQCB. The case was opened with the RWQCB on December 12, 1991, and the case was completed with a case closed designation on July 15, The Project Site is also listed as a small quantity generator of hazardous materials generating more than 100 and less than 1,000 kilograms of hazardous waste during any calendar month. The Site also has had numerous air quality permits with the AQMD for emissions of Total Organic Hydrocarbon Gases, Carbon Monoxide emissions, Nitrogen Oxides and Sulphur Oxides. Finally, the Site was identified on the HAZNET site as having a landfill or surface impoundment that will be closed as a landfill to include onsite treatment and/or stabilization. Therefore, the Project Site, being considered a small quantity generator and having a landfill or surface impoundment that will be closed as a landfill, are Recognized Environmental Conditions to the Site. Numerous additional environmental records were identified for facilities in the surrounding area. Due to the distance and direction from the Project Site, and the nature of the information presented in the Phase I, most of these records do not appear to represent a potential environmental concern to the Site with the exception of the Shell gasoline station located adjacent to the Site and the Union Oil (UNOCAL) Torrance petroleum above-ground tank farm west of the Site across Crenshaw Boulevard. Specifically, the adjacent Shell station appears in a number of EDR lists regarding a past gasoline spill and remediation that was performed at the Site. The Site was remediated and received a case closure status on March 5, The UNOCAL Torrance Tank Farm is located immediately across Crenshaw Boulevard to the west of the Project Site. The tank farm appears in the EDR CA SLIC list. The tank farm is described as having Page 4.F-5

6 reported a leak of TPH (Total Petroleum Hydrocarbons) on June 16, 1965, to the RWQCB. The RWQCB lists the status as completed and case closed. The RCRA-SQG, FINDS, and CA HAZNET lists along with the EDR US Hist Cleaners list includes listings for historic dry cleaners near the Site. There are two dry cleaners identified that are located within 380 feet of the Site. The lists identify Delta Cleaners at Crenshaw Boulevard and Plaza Cleaners located at Crenshaw Boulevard. It should be noted that both dry cleaners are not listed as having any known violations recorded. The EDR Report also lists at least 20 additional sites within a quarter-mile of the Site that are either historic dry cleaners, auto service stations, RCRA hazardous waste generators, or current registered UST operators. However, based on information in the Phase I ESA, and their location and historic site use, these additional sites do not pose an environmental concern to the Project Site. Overall, the results of the Standard Environmental Records Sources revealed the following: The former presence of a historical gasoline underground storage tank on the Site is considered a Historical Recognized Environmental Condition to the Site. The Site being considered a small quantity generator and having a landfill or surface impoundment that will be closed as a landfill are Recognized Environmental Conditions to the Site. The presence of the adjacent Shell gasoline station and its historic cleanup is considered a Historical Recognized Environmental Condition to the Site. The presence of the UNOCAL Torrance Tank Farm and its historic cleanup is considered a Historical Recognized Environmental Condition to the Site. City Directory and Building Permit Reports The Phase I ESA provided a historical city directory search for the Site and nearby properties. The City Directory Abstract did not identify any environmental concerns with the following exceptions. The Site appears to have had a business known as Mike s Auto Wrecking in 1954 at 2444 Lomita Boulevard. At 2457 Lomita Boulevard, Miyamoto Tropical Bowl Nursery occupied the Site from 1957 to Nurseries are considered sites with an environmental concern stemming from the past use of pesticides. Also, from 1975 to 2013, A-1 Coast Rentals occupied the Site at the address of and Crenshaw Boulevard. The presence of historic auto wrecking services and nursery represent a Historic Recognized Environmental Condition to the Project Site. The Phase I ESA also provided a building permit report for the Site and adjacent properties. The Building Permit Report provides municipal building permit records from local municipal governments. The building permit report supplied by EMS did not list any permits for the Site. Permits listed for sites in the vicinity are mostly for repairs and upgrades to items such as plumbing, electrical, and HVAC systems. Thus, the building permit report did not reveal any recognized environmental conditions to the Site. Page 4.F-6

7 Site Reconnaissance According to the Phase I ESA, EMS visited the Project Site on June 22, During the reconnaissance, a 2,000-gallon above-ground diesel tank, a 500-gallon above-ground gasoline tank, and two high pressure propane tanks, all used to dispense fuel for rental equipment and support vehicles were observed at the Project Site. Inspection of the above-ground tank and associated spill containment revealed evidence of numerous spills of diesel fuel within the containment. However, the above-ground tank does not seem to be leaking. The above-ground gasoline tank had only a small secondary containment tank but no obvious spills or leaks were noted. During the reconnaissance, the previous property owner indicated that an underground gasoline storage tank (UST) had been removed in the early 1990s and that the oversight agency had granted closure on the UST. However, it is unknown where on the Project Site the UST had been located. The equipment area, used for changing of vehicle oils and lubricants, equipment repairs, and washing was observed. Used batteries were stored on a wooden pallet near the above-ground water oil tank. A fire proof cabinet included small amounts of spray cleaners and lubricants. Material Safety Data Sheets (MSDS) were located in a binder that was clearly marked and hanging on a post in the equipment maintenance area. Waste oil, motor oil, transmission oil, lube oil, and hydraulic oil were contained in the above-ground tanks within secondary equipment. Wastewater from equipment cleaning and power washing drains to an underground clarifier located inside one of the maintenance bays. According to the previous property owner, the clarifier is pumped out once a year. Finally, the Site contains an area where sewage from serviced portable toilets is flushed into the sanitary sewer system and the tanker trucks carrying the sewage are washed and rinsed. During the reconnaissance, it was observed that the concrete surrounding the area is badly degraded and etched. The previous property owner indicated that she no longer dumped the tanker trucks into the on-site sewer, but prefers to have them emptied at the local dump. In summary, the Site inspection did not reveal the presence of recognized environmental conditions except for the following: The presence of the above-ground diesel and gasoline tanks are a Recognized Environmental Condition concerning the Site. The unknown location of the historic UST is a Historic Recognized Environmental Condition concerning the Site. The use and storage of oils, lubricants, waste oils and filters and batteries are a Recognized Environmental Condition concerning the Site. The use of an underground clarifier for wastewater from equipment washing is a Recognized Environmental Condition concerning the Site. Page 4.F-7

8 The past dumping of sewage waste at the Site is a Recognized Environmental Condition concerning the Site Hazardous Substances in Connection with Identified Uses Potentially hazardous substances being used at the Site include the use and dispensing of diesel fuel, gasoline, propane, lube oils, motor oils, waste oils and batteries. Other Hazardous Substance Containers and Unidentified Substance Containers There were no hazardous substances (not in connection with identified uses) or unidentified substance containers observed on-site during the Site inspection. Storage Tanks There are a number of storage tanks on the property including one 2000-gallon above-ground diesel tank, one 500-gallon above-ground gasoline tank, two above-ground propane storage tanks, and above-ground storage tanks for waste oil, lube oil, motor oil, transmission oil, and hydraulic oil. Polychlorinated Biphenyls (PCBs) There were no equipment or structures observed that would contain PCBs during the Site inspection. Solid Waste Disposal Trash bins were noted by EMS at the Site and the Site has disposed of sewage waste in the past in large volumes down the sanitary sewer. Physical Setting Analysis, if Migrating Substances are an Issue There are no known plumes of hazardous materials originating from properties adjacent to the Site. Asbestos Containing Material (ACM) The current buildings appear to have been constructed sometime in the 1970 s. Due to the age of the buildings, the Site buildings may contain potential asbestos-containing materials in building materials. Radon Accumulation Potential The National Radon Database has been developed by the USEPA and is a compilation of the EPA/State Residential Radon Survey and the National Residential Radon Survey. Based on this information, EMS noted no potential environmental concerns due to radon. Page 4.F-8

9 Lead Based Paint The current buildings appear to have been constructed sometime in the early 1970 s. Due to the age of the building, the Site building may contain lead based paint on the exterior wrought iron fencing. Phase I ESA Conclusions The Phase I ESA revealed no evidence of Recognized Environmental Conditions, Historical Recognized Environmental Conditions, Controlled Recognized Environmental Conditions or De Minimis Conditions in connection with the Project Site with the following exceptions: The Site was identified as having a leaking UST (gasoline tank) that was removed and the case was closed with the RWQCB. The case was opened with the RWQCB on December 12, 1991, and the case was completed with a case closed designation on July 15, Therefore, the former presence of a historical gasoline UST is considered a Historical Recognized Environmental Condition to the Site. The Site is also listed as a small quantity generator of hazardous materials generating more than 100 and less than 1,000 kilograms of hazardous waste during any calendar month. The Site was identified on the HAZNET database as having a landfill or subsurface impoundment that will be closed as a landfill to include on-site treatment and/or stabilization. No further information was readily ascertainable regarding the surface impoundment. Therefore, the Site being considered a small quantity generator and having a landfill or surface impoundment that will be closed as a landfill are Recognized Environmental Conditions to the Site. The adjacent Shell station appears in a number of EDR lists regarding a past gasoline spill and remediation that was performed at the Site. Shell Station # located at 2477 Lomita Boulevard reported a leak of gasoline on July 5, 1988, with the RWQCB. The site was remediated and received a case closure status on March 5, The presence of the Shell gasoline station and its historic cleanup is considered a Historical Recognized Environmental Condition to the Site. The UNOCAL Torrance Tank Farm is located immediately across Crenshaw Boulevard to the west of the Project Site. The tank farm appears in the EDR CA SLIC list. The tank farm is described as having reported a leak of TPH on June 16, 1965, to the RWQCB. The RWQCB lists the status as completed and case closed. The presence of the UNOCAL Torrance Tank Farm and its historic cleanup is considered a Historical Recognized Environmental Condition to the Site. The Site appears to have had a business known as Mike s Auto Wrecking in 1954 at 2444 Lomita Boulevard. At 2457 Lomita Boulevard, Miyamoto Tropical Bowl Nursery occupied the Site from 1957 to Nurseries are considered sites with an environmental concern stemming from the past use of pesticides. From 1975 to 2013, A-1 Coast Rentals occupied the Site at the addresses of and Crenshaw Boulevard. The presence of a historic auto wrecking service and nursery and represent a Historical Recognized Environmental Condition to the Site. Page 4.F-9

10 In addition, the Site reconnaissance conducted as part of the Phase I ESA revealed the following Recognized Environmental Conditions: The presence of the above-ground diesel and gasoline tanks are a Recognized Environmental Condition to the Site. The unknown location of the historic UST is a Historical Recognized Environmental Condition to the Site. The use and storage of oils, lubricants, waste oils and filters, and batteries are a Recognized Environmental Condition to the Site. The use of an underground clarifier for wastewater from equipment washing is a Recognized Environmental Condition to the Site. The past dumping of sewage waste at the Site is a Recognized Environmental Condition to the Site. Finally, based on the historic use of petroleum products at the Project Site and in the immediate vicinity of the Site, a vapor encroachment condition (VEC) cannot be ruled out. Phase II ESA Soil Sampling Based on the findings of the Phase I ESA, EMS prepared a Phase II ESA, which is included as Appendix G-2 to this Draft EIR. On February 22-24, 2016, EMS installed 21 borings to a depth of 15 feet at the Site and collected soil and soil vapor samples. The borings were located in areas that were determined in the Phase I ESA to be suspect areas for potential subsurface contamination. Soil samples were collected from the borings at 5, 10 and 15 feet, were screened in the field for potential contaminants, and transported to a State of California Certified Laboratory for chemical analysis. Soil vapor probes were installed in each of the borings at depths of 5 and 15 feet. None of the soil gas or soil results exceeded their respective health risk based screening levels. In addition, volatile organic compounds were not detected above reporting limits in any of the soil samples chosen for analysis by EMS. ENVIRONMENTAL IMPACTS Thresholds of Significance Appendix G of the CEQA Guidelines In accordance with Appendix G of the CEQA Guidelines, the Project could have a potentially significant impact upon hazards and hazardous materials if it were to result in one or more of the following: (a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; Page 4.F-10

11 (b) 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; (c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; (d) 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 create a significant hazard to the public or the environment; (e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two 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; (f) 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; (g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; and (h) 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. As is discussed in the Initial Study (see Appendix A to this Draft EIR) and in Section 4.A., Impacts Found to be Less than Significant, of this Draft EIR, the Project does not have the potential to result in any significant impact with respect to issue (h). Therefore, this issue is not analyzed in this section. Transport, Use, and Disposal of Hazardous Materials Construction Construction of the Project would involve the temporary transport, use, or disposal of potentially hazardous materials, including paints, adhesives, surface coatings, cleaning agents, fuels, and oils. All of these materials would be used in a short-term nature during construction activities. All potentially hazardous materials would be used and stored in accordance with manufacturers instructions and handled in compliance with applicable standards and regulations, which would ensure that impacts would be less than significant. Additionally, any emissions from the use of such materials would be minimal and localized to the Project Site. 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 Project would be less than significant. Page 4.F-11

12 Operation The Project would include the development of residential land uses, which would involve the limited use of hazardous materials. Specifically, operation of the residential uses would involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents, paints, and pesticides for landscaping. With implementation of hazardous waste reduction efforts on-site, as well as the proper treatment and disposal of such wastes at licensed resource recovery facilities, the Project would not generate significant amounts of hazardous wastes. The transport of hazardous materials and wastes (i.e., paints, cleaning agents, landscaping pesticides, etc.) would occur in accordance with federal and state regulations, including RCRA, Title 49 of the CFR, the California Vehicle Code, and the California Health and Safety Code. In accordance with such regulations, the transport of hazardous materials and wastes would only occur with transporters who have received training and appropriate licensing. Additionally, hazardous waste transporters would be required to complete and carry with him/her a hazardous waste manifest. Placarding of vehicles carrying hazardous materials would also occur in accordance with Title 49 of the CFR. Therefore, there would be no impact to the transport of hazardous materials. Finally, implementation of the Project could incrementally decrease the transport of hazardous materials and wastes to/from the Project Site when compared to existing conditions. Overall, based on compliance with federal, state, and local regulations, the transport of hazardous materials and wastes during Project construction and operation would not create a hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Therefore, impacts related to the transport, use, or dispoal of hazardous materials would be less than significant. Upset Conditions Involving the Release of Hazardous Materials Asbestos-Containing Material (ACM) Due to the age of the Site buildings, there is a potential that ACMs are present. The identified suspect ACMs would need to be sampled to confirm the presence or absence of asbestos prior to any renovation or demolition activities to prevent potential exposure to workers and/or building occupants. Asbestos removal is controlled by federal regulations and the SCAQMD. In general, asbestos removal is a low risk operation. When following asbestos-related regulations, the possibility of exposure to airborne asbestos fibers from asbestos removal projects is limited. In accordance with the EPA s NESHAP regulation and the SCAQMD, all materials, which are identified as ACMs, would be removed by a trained and licensed asbestos abatement contractor. Prior to issuance of any demolition permit, the applicant would provide a letter to the Los Angeles County Department of Building and Safety from a qualified asbestos abatement consultant that no ACMs are found to be present. If ACMs are found to be present, they would be abated in compliance with SCAQMD Rule 1403, as well as other State and federal rules and regulations, including CAL-OSHA Asbestos for the Construction Industry Standard, EPA rules and regulations, and industry standards. Page 4.F-12

13 Provided that the removal and disposal of ACMs from the Project Site follows the various required guidelines described above (which are formally provided as Mitigation Measure F-1), hazardous materials impacts relative to exposure of workers and others to asbestos would be less than significant. Lead-Based Paint (LBP) While all painted surfaces were observed in good condition, due to the age of the structures, there is a potential for LBP to be present. Demolition of the existing structures on the Project Site could therefore release LBP containing materials present in the structure into the environment. Exposure of workers and others to LBP during demolition of the Project Site structures would be a potentially significant impact. In order to ensure minimal exposure to workers and others, LBP found in the buildings shall be removed and disposed of as recommended by a qualified Department of Health Services lead consultant and in accordance with applicable federal, state, and local regulations. Regulations that would be followed during demolition include Construction Safety Orders (pertaining to lead) from Title 8 of the California Code of Regulations, and lead exposure guidelines provided by the U.S. Department of Housing and Urban Development (HUD). Provided that abatement rules and regulations are followed as necessary (which is formally required as Mitigation Measure F-2), hazardous materials impacts to sensitive receptors and workers caused by exposure to lead-paint would be less than significant. Storage Tanks As discussed above, several above-ground storage tanks are currently located at the Project Site. Specifically, a 2,000-gallon above-ground diesel tank, one 500-gallon above-ground gasoline tank, two above-ground propone tanks, and above-ground storage tanks for waste oil, lube oil, motor oil, transmission oil, and hydraulic oil were observed at the Project Site. Additionally, an underground storage tank with an unknown location was also divulged in the Phase I ESA. Environmental impacts may result from the potential soil and/or groundwater contamination from any ASTs or USTs. The Project would be required to comply with existing EPA regulations related to the safe removal of ASTs and USTs. Specifically, the ASTs and USTs shall be decommissioned or removed as determined by the County of Los Angeles Fire Department, Health and Hazardous Materials Division. Compliance with existing regulations would ensure that impacts related to ASTs and USTs are less than significant. Soil Management While the results of the Phase II ESA indicate that none of the soil gas or soil samples exceeded their respective health risk based screening levels, EMS recommends that a Soil Management Plan (SMP) be developed for the Site and used during Site demolition and grading (as listed in Mitigation Measure F-3). The SMP should specify the process for identifying, segregating, profiling and disposing of any stained/strong odor soil. The SMP should also specify the process for removal and cleanup of the clarifier. Based on the soil gas and soil results, EMS recommends that the clarifier, waste oil, and diesel tanks be removed according to local regulations and any soil that appears to be stained or has a strong odor to be segregated for proper profiling and disposal. A representative sample of the stained/strong odor soil should be collected and analyzed to confirm it is not hazardous and should be disposed in a proper Page 4.F-13

14 manner. This is also recommended for the soil beneath the concrete pad in the southeast portion of the property. With implementation of Mitigation Measure F-3, impacts with respect to potentially contaminated soil would be less than significant. Hazardous Emissions within One-Quarter Mile of School There are two schools located on the St. Mark s Church property (the First Lutheran Early Childhood Center and the Volunteers of America Head Start preschool), which would be located within one-quarter mile of the Project Site. In addition, Lomita Elementary School is the nearest public school and is located approximately 0.5-mile from the Project Site. The Project includes development of the Project Site with multi-family residential land uses, which would use common types of cleaning products, paint, etc. The Project would not require the transport, use, or disposal of hazardous that would pose a significant hazard to the public or environment. In addition, as discussed above, there is the potential to encounter ACM, LBP, and soils in need of management during demolition and construction. However, implementation of Mitigation Measures F-1 through F-3, provided at the end of this section, would ensure that these impacts are less than significant. Thus, the Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school, and impacts would be less than significant. Hazardous Materials Site List California Government Code Section requires various state agencies to compile lists of hazardous waste disposal facilities, unauthorized release from underground storage tanks, contaminated drinking water wells, and solid waste facilities from which there is known migration of hazardous waste and submit such information to the Secretary for Environmental Protection on at least an annual basis. As discussed above, the Project Site was identified on a number of databases owning to the past use of the Site. Specifically, the Site was identified on CA LUST, RCRA-SQG, FINDS, CA HAZNET, CA RGA LUST, HIST CORTESE, LA CO. SITE MITIGATION, CA SWEEPS UST, and CA LOS ANGELES CO. HMS. Additionally, the Site was identified has having a leaking UST (gasoline tank) that was removed and the case was closed with the RWQCB. The case was opened with the RWQCB on December 12, 1991, and the case was completed with a case closed designation on July 15, In addition, the Project Site is listed as a small quantity generator of hazardous materials generating more than 100 and less than 1,000 kilograms of hazardous waste during any calendar month. The Site was also identified on the HAZNET site as having a landfill or surface impoundment that will be closed as a landfill to include on-site treatment and/or stabilization. However, these environmental concerns that resulted in listing on various environmental databases have already been discussed above, and with implementation of Mitigation Measure F-3, the impacts would be less than significant. Airport Hazards A significant impact may occur if a project is located within two miles of a public airport, and subject to a safety hazard or within the vicinity of a private airstrip. Although the Project Site is located approximately 0.5-mile from the Torrance Airport, there are intervening land uses and infrastructure, including the Crossroads Shopping Center and Lomita Boulevard, between the Project Site and the Page 4.F-14

15 Torrance Airport. In addition, according to the Safety Element of the General Plan, the Torrance Airport has designated clear zones around the runways to prevent hazards associated with aircraft accidents during landing and take-off. This area does not extend into the City of Lomita. Finally, the Project would comply with the Federal Aviation Administration (FAA) height restriction of 200 feet, based on the Site s location within three miles of an airport. As such, no impact with respect to airport hazards would occur as a result of the Project. Emergency Response or Evacuation Plan Narbonne Avenue, Lomita Boulevard, and Crenshaw Boulevard are designated as emergency evacuation routes within the City of Lomita. While construction of the Project would occur within the property boundaries of the Project Site, temporary pedestrian or vehicular public right-of-way closures along Crenshaw Boulevard or Lomita Boulevard may be necessary during the construction phase for construction staging, equipment access, and pedestrian safety. However, partial lane closures would not significantly affect emergency vehicles, the drivers of which normally have a variety of options for dealing with traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Additionally, if there were partial closures to streets surrounding the Project Site, flagmen would be used to facilitate the traffic flow until such temporary street closures are complete. The implementation of Mitigation Measure L-1 (in Section 4.L, Traffic) requiring the creation of a Construction Traffic Management Plan would ensure that impacts related to emergency response and evacuation routes during Project construction are less than significant. In addition, the Project would create an emergency response plan to ensure that there are emergency exits and evacuation routes for vehicles and pedestrians (provided as Mitigation Measure F-4). Finally, as described in Section 4.L, Traffic, the Project would not result in any significant traffic impacts and therefore would not interfere with roadway operations used in conjunction with an emergency response plan or evacuation plan. As such, impacts would be less than significant. CUMULATIVE IMPACTS While impacts associated with hazards and hazardous materials are typically site-specific 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. However, regardless of the number and location of the related projects, the Project together with the related projects would not create an impact that is cumulatively considerable, as each development project would have to comply with site-specific development standards and state hazardous materials handling and transporting regulations. Compliance with these standards would ensure that the related projects would further the objectives of applicable community and regional plans. As a result, all potentially hazardous materials used by related projects would be stored and disposed of in accordance with manufacturers specifications and handled in compliance with applicable standards and regulations. In addition, the Project itself would have a less than significant impact with implementation of mitigation Page 4.F-15

16 measures. As such, cumulative impacts related to hazards and hazardous materials for the concurrent development of the Project and related projects would be less than significant, and the Project s overall contribution would not be cumulatively considerable. MITIGATION MEASURES F-1 Asbestos-Containing Materials Prior to the issuance of any permit for the demolition of the existing structures, the Applicant shall provide a letter to the Los Angeles County Department of Building and Safety from a qualified asbestos abatement consultant indicating that no ACMs are present in the structures. If ACMs are found to be present, they will need to be abated in compliance with the SCAQMD s Rule 1403, as well as other applicable state and federal rules and regulations. F-2 Lead-Based Paint Prior to the issuance of any permit for the demolition of the existing structures, a lead-based paint survey shall be performed to the written satisfaction of the Los Angeles County Department of Building and Safety. Should lead-based paint materials be identified, standard handling and disposal practices shall be implemented pursuant to OSHA regulations. F-3 Soil Management Plan A Soil Management Plan (SMP) shall be developed for the Site and used during Site demolition and grading. The SMP should specify the process for identifying, segregating, profiling and disposing of any stained/strong odor soil. A technician shall be present on the Project Site during the demolition, excavation, and grading phases to sample and screen any residual contaminants, should they be encountered. Testing to characterize the material shall occur either on-site in a mobile laboratory or off-site in a remote laboratory. Materials shall be identified, segregated, and tracked as to their extent on the Project Site. Any soils containing contaminants at levels of concern shall be either remediated on-site prior to reuse or removed and disposed of in accordance with all applicable laws and regulations, including those promulgated by the California Department of Toxic Substances Control (DTSC). All necessary approvals shall be obtained from the lead enforcement agency including, but not limited to, the Los Angeles County Fire Department, Health and Hazardous Materials Division. The SMP should also specify the process for removal and cleanup of the clarifier. F-4 Emergency Response Plan Prior to the issuance of a building permit, the applicant shall develop an emergency response plan in consultation with the Fire Department. The emergency response plan shall include but not be limited to the following: mapping of emergency exits, evacuation routes for vehicles and pedestrians, location of nearest hospitals, and fire departments. Page 4.F-16

17 LEVEL OF SIGNIFICANCE AFTER MITIGATION Implementation of Mitigation Measure F-1 would ensure that impacts related to asbestos are less than significant. Implementation of Mitigation Measure F-2 would ensure that impacts related to lead-based paint are less than significant. Implementation of Mitigation Measure F-3 would ensure that impacts related to soil management are less than significant. Implementation of Mitigation Measure F-4 would ensure that impacts related to an emergency response plan are less than significant. All other Project-specific and cumulative impacts related to hazards and hazardous materials would be less than significant. Page 4.F-17