IV. ENVIRONMENTAL IMPACT ANALYSIS E. HAZARDS AND HAZARDOUS MATERIALS

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1 IV. ENVIRONMENTAL IMPACT ANALYSIS E. HAZARDS AND HAZARDOUS MATERIALS INTRODUCTION This section evaluates potential impacts related to hazards and hazardous materials associated with development of the Proposed Project. It discusses whether the Proposed Project would create a significant hazard to the public or the environment due to its proximity to hazardous conditions and/or hazardous materials. This analysis is based on the findings of the Phase I Environmental Site Assessment of Playa Del Oro Parcel 5, prepared by EMG, dated December 1, 2006 and the Phase I Environmental Assessment Report for Furama Hotel and Adjoining Properties, at Corner of Manchester Avenue and Lincoln Boulevard, Los Angeles, CA 90045, prepared by EMG, dated August 18, These reports are included as Appendix E to this Draft EIR. ENVIRONMENTAL SETTING Existing Uses The project site is approximately 3.03 acres (131,943 square feet) and is located at 7270 through 7298 West Manchester Avenue and 8624 Rayford Drive. The project site is located west of Lincoln Boulevard and the Playa Del Oro construction site, north of single-family residential uses, and east of Rayford Drive. The western portion of the project site is currently developed with three existing structures which contain eight separate commercial uses, totaling 24,000 square feet, including: Re/Max Realty, Sunflower Health Food Store, a Pilates/yoga studio, ADA Creation (a gift shop), a karate/martial arts studio, All Cities Real Estate, an automotive repair center, and Graphaids art supply store. The eastern portion of the project site is currently vacant. 1 Surrounding Uses The project site and immediate vicinity slope gently downward to the southeast while areas to the west of the project site slope downward to the west and areas north of the project site slope downward to the north. These areas are developed with single- and multi-family residential, retail, commercial, educational, public facilities, and religious uses. 1 In 2004, City Council adopted a Mitigated Negative Declaration ( MND ) for the Playa del Oro mixed-use development, a portion of which has recently been constructed on the property that adjoins the project site. A portion of the Playa del Oro development originally included a 134-unit multi-family residential building on the westerly end of the Playa del Oro site (the eastern portion of the current project site), which will no longer be constructed. In lieu of constructing the previously-approved, vested, and mitigated 134-unit building, the Applicant proposes to construct the Proposed Project. See section III. Project Description, for a description of the Proposed Project. Page IV.E-1

2 Sensitive Receptors Surrounding uses that would be considered sensitive receptors with respect to hazardous material exposure include the residential uses located north, south, and west of the project site, the churches located north across Manchester Avenue from the project site and west across Rayford Drive from the project site, the Loyola Village Elementary School located approximately 178 feet south of the project site, and the Westchester Recreation Center located approximately 0.2 miles east of the project site. Historic Use of the Project Site Summary of Site History The project site was developed with three small residential structures sometime between 1938 and 1953 according to an aerial photograph taken in 1938 showing no development and an aerial photograph taken in 1953 showing the three small residential developments. By 1963, the project site was developed with a single retail-type building and associated surface parking lot. By 1981, an on-site vehicle repair station had been developed. In 1997, the western portion of the project site had been improved with a retail-type building that closely resembles the current improvements. Until 2007, the eastern portion of the project site was developed with buildings associated with the former Furama Hotel. Historical Aerial Photographs Historical photographs between the years 1938 and 2004 were used to ascertain the historical use of the project site. A 1938 photograph shows the project site as farmland and completely undeveloped. By 1953, the project site is improved with what appear to be three residential structures. In 1963, the project site had been redeveloped and improved with one retail-style building and an associated parking area. Aerial photographs taken in 1972 and 1985 identify the same retail-type buildings that currently exist on the western portion of the project site. By 1997, the western portion of the project site had remained developed with retail-style buildings resembling the current on-site uses, and the eastern portion of the project site was developed with buildings associated with the former Furama Hotel. See Figure II-5 for an aerial photograph depicting the existing on-site uses. Previous Investigations A previous environmental assessment dated August 18 th, 2000 was identified for the entire block containing the project site and the commercial uses extending southeast to Loyola Boulevard. The environmental assessment does not identify any reported incidents of leakage or contamination regarding the underground storage tanks (USTs) used by the on-site auto mechanic or by the former hardware store. In addition to the improvements described above, the August 2000 Phase I identifies a possible former service station located at the southeast corner of the intersection of Manchester Avenue and Rayford Drive, at 7298 West Manchester Avenue, that was in operation until The on-site gasoline tanks were removed in However, there was some concern expressed regarding the nearby Carriage Cleaners located along Lincoln Boulevard. A Phase II, Subsurface Investigation, was conducted for the Re/Max and former service station property located on-site and the Carriage Cleaners property located off-site on November 19, Analysis of existing soils indicated no detectable levels of gasoline- Page IV.E-2

3 related hydrocarbons (BTEX or MTBE) beneath the Re/Max property and the concentrations of metal reported were at background levels. Relatively low concentrations of diesel range hydrocarbons were reported in three of 12 soil samples collected from beneath the auto mechanic. These concentrations ranged from below laboratory reporting limits to 17 parts per million, which is below the guidance level set in the California Leaking Underground Fuel Tank (LUFT) Manual. At the Carriage Cleaners site, no reportable concentrations of perc (tetrachloroethene), the dry cleaning solvent, were reported in the soils near the cleaners. The soil sample analysis provides supporting evidence that neither a UST nor a dry cleaning release occurred at or near the project site prior to Project Site Reconnaissance Site reconnaissance was conducted October 9, The following paragraphs describe the conditions at the project site as reported in the technical report. Topography and Drainage The project site is located at an elevation of approximately 155 feet above mean sea level (msl) with a two to five percent slope trending southeast. 2 Drainage from the site is via sheetflow into the adjacent streets and towards localized area drains and the nearby Playa Del Oro construction site. Storage Tanks Based on the August 2000 Phase I prepared for the block containing the project site and immediate commercial area, a total of three USTs were historically and are currently operating on-site. The first of the three storage tanks was associated with the former service station located on-site. Though it is unknown what the exact capacity of the storage tank was, the Facility Inventory Database for underground storage tanks (CA FID UST database) listing for this UST indicates that the facility is inactive. Further, a letter from the Los Angeles Fire Department (LAFD) dated September 1989 indicates that the UST had been removed, and based on the information provided to LAFD, no further action was required. The second storage tank identified was a 7,500-gallon capacity tank installed in 1964 for use at the former Gerald s Hardware Store. This UST was listed on several UST databases; however, no additional information is provided regarding the construction, use, or current status of the UST and the Gerald s Hardware Store site. The last of the three storage tanks is currently in use by the existing on-site auto mechanic and has a capacity of 7,500 gallons. This storage tank was installed in 1989 and is utilized to store the used motor oil generated during vehicle maintenance. There have been no reported leaks or spills related to this storage tank and this use is not listed on any database which reports spills, incidents, or releases. Laboratory analysis of soil samples collected during a 2001 Phase II subsurface assessment indicated no detectable levels of gasoline-related hydrocarbons (including BTEX or MTBE) in soils beneath the auto mechanic or adjacent to the in-use waste oil storage tank. The concentrations of metal on-site were within background levels. Also, relatively low concentrations of 2 United States Department of the Interior, Geological Survey, Venice Quadrangle, California, Los Angeles Co., 7.5 Minute Series (Topographic), 1964, Photo Revised 1981, map. Page IV.E-3

4 diesel range hydrocarbons were reported in three of the 12 soil samples ranging between below laboratory reporting limits to 17 parts per million, below the guidance levels set forth in the California LUFT Manual. No above-ground storage tanks (ASTs) were observed during site reconnaissance and no records of past ASTs were reported for the project site. Polychlorinated Biphenyls Polychlorinated biphenyls (PCBs) are mixtures of chlorinated compounds which can exist as vapor, oily liquids, or solids. PCBs have been used as coolants and lubricants in transformers and other electrical equipment because they do not burn easily and are good insulators. When PCBs leak into the air, water, and soil, they can result in skin rashes and liver damage to humans. PCBs are also probable human carcinogens. In 1977, the U.S. government banned production of PCBs. One exterior pad-mounted transformer was identified as serving the project site. This transformer is owned and maintained by the Los Angeles Department of Water and Power (LADWP) and is considered non-pcb containing based upon the recent date(s) of installation. Four vehicle hydraulic lifts associated with the on-site auto mechanic were also encountered. Because PCB hydraulic fluid has not been manufactured since 1977 and these lifts were installed post-1977, PCB-containing hydraulic fluid is not likely to be encountered in this equipment. Finally, it is not known whether fluorescent light ballasts are present within the structures. Older light ballasts associated with this type of light fixture were typically manufactured with fluids containing PCBs. Newer light ballasts (post 1969) were typically manufactured free of PCBs and will generally be labeled No PCBs. Asbestos-Containing Materials Asbestos-containing materials (ACMs) are materials that contain asbestos, a naturally-occurring fibrous mineral that has been mined for its useful thermal properties and tensile strength. When left intact and undisturbed, these materials do not pose a health risk to building occupants. There is, however, potential for exposure when ACMs become damaged to the extent that asbestos fibers become airborne and are inhaled. These airborne fibers are carcinogenic and can cause lung disease. The age of a building is directly related to its potential for containing elevated levels of ACMs. Asbestos was utilized routinely in many building materials until The Environmental Protection Agency (EPA) recommends a proactive in-place management program be implemented wherever ACMs are found in a building; ACMs that are not damaged may remain in place. The EPA also recommends that damaged ACMs be removed, repaired, encapsulated, or enclosed. Prior to any renovation or demolition activities, the EPA recommends that all ACMs be removed from a project site. During site reconnaissance, two suspect ACMs were identified: 12 x 12 resilient floor tile/mastic and roofing material. The floor tile/mastic was not tested for asbestos content because it was in good condition, and thus did not necessitate sampling. The roofing material was not tested for asbestos content because it too was in good condition and sampling had the potential to void an existing warranty. However, the U.S. EPA identifies both materials as suspect ACMs regardless of installation date in its Page IV.E-4

5 publication Managing Asbestos in Place (the Green Book ). The suspect designation necessitates sampling prior to any repair, renovation, or demolition activities that may disturb these materials. Lead-Based Paint Lead-based paint (LBP), which can result in lead poisoning when consumed or inhaled, was widely used in the past to coat and decorate buildings. Lead poisoning can cause anemia and damage to the brain and nervous system, particularly in children. Like ACMs, LBP generally does not pose a health risk to building occupants when left undisturbed; however, deterioration, damage, or disturbance will result in hazardous exposure. In 1978, the use of LBP was federally banned by the Consumer Product Safety Commission. Therefore, buildings, built before 1978 are likely to contain LBP, as well as buildings built shortly thereafter, as the phase-out of LBP was gradual. According to the Phase I environmental assessment prepared for the project site, lead based paint usage was not sought because no residences exist on the project site. However, a previous LBP analysis was prepared by ACS Associates dated June 2, The analysis conducted at least two wipe samples from on-site structures. Specifically, two lead wipe samples were collected from the Re-Max structure (west conference room and southeast meeting room). Results of the wipes indicated that the lead samples were below the Federal Standards and no further work or assessment was recommended. Containers of Hazardous or Unidentified Substances Upon site reconnaissance, between five and ten five-gallon paint cans were identified on-site and located specifically in the electrical room of the Re-Max building. In addition, between five and ten one-gallon parts washing solvent containers were encountered on-site and are located in the auto mechanic structure. This product generates a waste that is either hazardous or regulated. Further, approximately 20 oil canisters were encountered on-site in the auto mechanic structure. Used oil filters are disposed of in two 55-gallon drums, and the liquid drains into floor drains which are connected to a clarifier and UST. Also encountered were approximately 20 one-gallon antifreeze containers located in the auto mechanic structure. The use of antifreeze generates waste that is either hazardous or regulated. Solid Waste Disposal Commercial waste from the on-site businesses and tenants appears to be the only solid waste generated. This waste is collected in dumpsters and picked up by the municipal trash service. Radon A California State Radon Survey has been conducted by the Department of Health Services (DHS) in conjunction with the United States Environmental Protection Agency (EPA). The California survey is part of an ongoing program by the EPA to measure levels of radon in all states in the country. In this report, California was organized into nine sampling regions using general geology, climate, and existing radon distribution knowledge. The geographically distributed results were later weighted for population distribution by the EPA. The project site is located in the City of Los Angeles, within Los Angeles County. The results of the survey indicate that 98 percent of all homes in the region have radon Page IV.E-5

6 concentrations below four picocuries/liter of air (pci/l). Due to the low concentrations of radon in the region, it is unlikely the project site would be impacted by the presence of radon. Further, according to the Phase I environmental assessment, radon was not addressed as part of the assessment because no residences exist on-site. Additionally, no prior sampling results were provided for review of previous radon levels. Wells No evidence of monitoring wells was observed at the project site. Methane Gas Methane is generated by the biodegradation of organic matter in the absence of oxygen. Methane is not toxic; however, it is combustible and potentially explosive at concentrations above 53,000 parts per million (ppm) in the presence of oxygen. While non-pressurized methane is normally not problematic, if the gas accumulates to high concentrations and becomes pressurized, detectable levels may enter the interior of a structure through cracks or other penetrations present in floor slabs. The project site is located within a Methane Buffer Zone. 3 Other Conditions of Concern Currently, there are between 20 and 30 used tires on-site located inside the auto mechanic structure. Used tires are considered hazardous waste and are picked up and disposed of by a licensed waste handler. No other evidence of known or observed environmentally sensitive conditions was visible at the site. Regulatory Framework A variety of laws and regulations governing the management and control of hazardous substances has been established at the federal level to protect the environment. These regulations fall under the jurisdiction of the United States EPA and include the following principal laws: The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), or Superfund, creates national policy and procedures to identify and cleanup sites where hazardous substances have been released into the environment and provides the mechanisms by which these remedial actions are financed. Additionally, the Superfund Amendment and Reauthorization Act (SARA), which extended and amended CERCLA, required that due diligence be exercised in the investigation of past and current handling of hazardous substances prior to property sale. 3 City of Los Angeles, Zoning Information and Map Access System (ZIMAS), website: accessed July 2, Page IV.E-6

7 The Resource Conservation and Recovery Act (RCRA) was enacted in 1974 as the first step in regulating the potential health and environmental problems associated with solid hazardous and non-hazardous waste disposal. The Toxic Substances Control Act (TSCA), enacted in 1976, regulates and controls harmful chemicals and toxic substances in commercial use, in particular PCBs. The Federal Insecticide, Fungicide, and Rodenticide Act (as amended) controls the manufacture, use, and disposal of pesticides and herbicides. The Hazardous and Solid Waste Act (HSWA) includes the 1984 amendments to RCRA to address gaps in the area of highly toxic wastes. Title 29 Code of Federal Regulations (CFR), Park 1910 contains the Occupational Safety and Health Administration (OSHA) requirements for workers at hazardous waste sites including emergency response, hazard communication, and personal protective equipment. At the State level, California has developed hazardous waste regulations that are similar to the federal laws, but that are much more stringent in their application. The basic law established in California, similar to RCRA, is the Hazardous Waste Control Law (HWCL). More detailed information concerning the implementation of these requirements is given in Title 22 of California Code of Regulations (CCR), Chapter 230. The HWCL empowers the Department of Toxic Substances Control (DTSC), a division of CAL EPA (formerly part of the Department of Health Services), to administer the State s hazardous waste program and implement the federal program in California. This law includes UST regulation. Other relevant State laws include the following: Proposition 65 focuses on carcinogenic or teratogenic contaminants and implements the State s community-right-to-know program. UST Law that regulates underground storage to prevent groundwater contamination. Porter-Cologne Water Quality Control Act, adopted in 1969, requires the maintenance of the highest reasonable quality o the State s waters. It authorizes the Regional Water Quality Control Board (RWQCB) to supervise cleanup efforts at spill sites that have affected groundwater. The DTSC has the primary responsibility for enforcement and implementation of hazardous waste control laws in the State. However, this responsibility is shared with other State and local government agencies, including the State Water Resources Control Board (SWRCB), RWQCB, and City and County governments. At the local level, the LAFD administers hazardous materials environmental compliance programs within City jurisdiction. These programs include hazardous materials disclosure and business plans, underground storage tank programs, aboveground storage tank spill prevention control and countermeasures, hazardous waste generator programs (administered by Los Angeles County Fire Department), and the California Accidental Release Prevention Program. Page IV.E-7

8 Regulatory Agency Search On-Site The project site was listed on four of the environmental databases that were reviewed. These databases include: the California Facility Inventory Database (CA FID), the Underground Storage Tank (UST) database, the Hazardous Waste Information System (HAZNET) database, and the Statewide Environmental Evaluation and Planning System (SWEEPS) database. These databases all provided information about the former and current USTs operated on-site associated with the former service station, the former Gerald s Hardware Store, and the current auto mechanic. Off-Site Three properties in the vicinity of the project site were checked for listing on governmental databases. Two of these properties are listed in more than one database. The following paragraphs provide a brief explanation of the nine databases containing these properties. The Airport Marina Hotel, AMFAC Hotel, and Furama Hotel (which formerly occupied the eastern portion of the project site) are listed on the RCRA-TSD, FINDS, HAZNET, and RCRA-SQG databases. The waste category is listed as an organic small quantity generator with no reported releases or violations. The Loyola Village Elementary School is listed on the Facility Index System (FINDS) database. However, no releases or contamination issues have been reported regarding this location. The Otis College of Art and Design is listed on the HAZNET and Emissions Inventory Data (EMI) databases. The waste category is listed as photo-chemicals and photo-processing waste with no releases, contamination issues, or violations reported. ENVIRONMENTAL IMPACTS Thresholds of Significance In accordance with guidance provided in Appendix G of the State CEQA Guidelines, the Proposed Project could have a potentially significant impact upon hazards and hazardous materials if it were to: (a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; (b) Create a significant hazards to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials in to 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; Page IV.E-8

9 (d) Be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section and, as a result, would it 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, 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, 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; or (h) Expose people or structure 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. Furthermore, as set forth in the L.A. CEQA Thresholds Guide, the determination shall be made on a caseby-case basis, considering the following factors: (a) The regulatory framework; (b) The probable frequency and severity of consequences to people or property as a result of a potential accidental release of explosion of a hazardous substance; (c) 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; (d) The degree to which project design will reduce the frequency or severity of a potential accidental release or explosion of a hazardous substance; (e) The regulatory framework for the health hazard; (f) The probable frequency and severity of consequences to people from exposure to the health hazard; or (g) The degree to which project design would reduce the frequency of exposure or severity of consequences of exposure to the health hazard. Page IV.E-9

10 Project Impacts Routine Transport, Use, or Disposal of Hazardous Materials Construction Construction of the Proposed Project would involve the use of those hazardous materials that are typically necessary for construction of residential development (i.e., paints, building materials, cleaners, fuel for construction equipment, etc.). Therefore, construction of the Proposed Project would involve routine transport, use, and disposal of these types of hazardous materials throughout the duration of construction activities. Furthermore, the transport, use, and disposal of construction-related hazardous materials would occur in conformance with all applicable local, State, and federal regulations governing such activities. For example, the Proposed Project would be required to implement standard best management practices (BMPs) set forth by the City and the Los Angeles Regional Water Quality Control Board (LARWQCB) which would ensure that wastes generated during the construction process are disposed of properly. Therefore, the Proposed Project would not create a significant impact related to routine transport, use, or disposal of hazardous materials during construction. Impacts would be less than significant. Operation Operation of the Proposed Project would involve the transport, use, and disposal of hazardous materials typically associated with residential uses. Hazardous materials commonly used in the operations of residential uses include minimal amounts of solvents and household products used for routine cleaning, maintenance, and landscaping. Therefore, the uses developed under the Proposed Project would not involve the routine transport, use, or disposal of substantial amounts of hazardous materials. Impacts would be less than significant. Storage Tanks The three USTs operating historically and currently on-site associated with the former service station, the former Gerald s Hardware Store, and the current on-site auto mechanic all possess a different status. The UST associated with the former service station was removed from the project site by 1989 while the UST associated with the former Gerald s Hardware Store possess an unknown status, and the UST associated with the on-site mechanic is currently in operation with no reported spills, leaks, or other environmental violations. Upon demolition, the removal of the UST associated with the on-site auto mechanic and any other USTs found on-site (including the UST of unknown status associated with the former Gerald s Hardware Store) would be carried out in accordance with all applicable City, State, and federal requirements. The LAFD would be consulted prior to the removal of storage tanks to ensure that nearby sensitive receptors would not be adversely affected during the removal process and that any contaminated soil is properly handled and disposed of. Mitigation measures are provided below to ensure the safe removal of the existing UST and any additional USTs uncovered during the demolition process and remediation of contaminated soils. With implementation of Mitigation Measures E-1 through E-3, impacts related to storage tanks would be less than significant. Page IV.E-10

11 Polychlorinated Biphenyls As discussed previously, PCBs may be present in any fluorescent light ballast discovered on-site and, although unlikely, in the pad-mounted transformer and hydraulic fluid used in the hydraulic lifts operated by the auto mechanic. Therefore, mitigation measures are provided below to ensure the safe removal of any identified PCBs. With implementation of Mitigation Measure E-4, impacts to PCBs would be less than significant. Asbestos-Containing Materials The possible occurrence of ACM in the resilient floor tile/mastic and roofing material at the project site does not necessarily require any type of remediation; however, any ACM would have to be handled properly in the event buildings or fixtures containing such materials were demolished or remodeled and certain maintenance activities would be advised if ACMs were left in place and the buildings reused. Because all on-site structures would be demolished under the Proposed Project, mitigation measures are provided below to ensure the safe removal of any identified ACMs. With implementation of Mitigation Measure E-5, impacts related to the presence and safe removal of any on-site ACMs would be less than significant. Lead-Based Paint As indicated previously, LBP materials were not sought on-site as the project site is not developed with residential uses. However, a previous LBP analysis identified lead levels below federal standards in the Re-Max portion of the on-site structures. If other sources of LBP are encountered on-site, LBP materials may require special handling and disposal as all on-site structures would be demolished under the Proposed Project. Therefore, mitigation measures are provided below to ensure the safe removal of any identified LBPs. With implementation of Mitigation Measure E-6, impacts related to potential on-site LBP would be less than significant. Methane Gas The project site is located within a City of Los Angeles Methane Buffer Zone. As described previously, methane gas is generated in the area by subterranean sources, including oil production facilities and resources located to the west along the coast. Methane can enter buildings through fissures or cracks in building foundations. Therefore, any future development would be required to comply with the seepage regulations contained in Division 71 of the Los Angeles Municipal Code, which mandates that methane detection systems and other mitigation be required in all new developments in all areas located in a Methane Zone or Methane Buffer Zone. Therefore, with compliance with Division 71 of the Los Angeles Municipal Code and implementation of Mitigation Measure E-7, impacts related to on-site methane contamination would be less than significant. Proximity to a School The project site is located within one-quarter mile of Loyola Village Elementary School. The school is located approximately 200 feet south of and hydraulically down gradient from the project site. Page IV.E-11

12 Groundwater in the vicinity of the project site trends southeast. Because of the location of the school relative to the project site, an accidental release of hazardous materials resulting in groundwater intrusion could impact Loyola Village Elementary School. However, the construction and operation of the Proposed Project will not include the heavy use, handling, or storage of large amounts of hazardous materials. Further, development of the Proposed Project would result in the complete development of the project site with large areas covered by impermeable surfaces. As such, any accidental release of hazardous materials from the Proposed Project would not likely result in groundwater intrusion that could reach the nearby elementary school. Therefore, it is considered unlikely that an accidental release of hazardous materials would impact Loyola Village Elementary School. Impacts would be less than significant. Hazardous Materials Sites On-Site The only known source for potential soil contamination on-site is derived from the historic and the currently in-use storage tanks. In total, three USTs have been operated on-site. Based on a letter from the LAFD dated to September 1989, the UST associated with the former service station was removed, and based on the information provided to LAFD, no further action was required. As such, on-site soil contamination related to this UST is not known to have occurred. The UST associated with the former Gerald s Hardware Store was listed on several UST databases; however, no additional information is provided regarding the construction, use, or current status of the UST and the Gerald s Hardware Store site. Therefore, it is considered possible that this UST is still located on-site. As such, Mitigation Measures E-1 through E-3 shall be implemented to assess any potential groundwater and soil contamination and ensure that in the event this UST is currently on-site, any necessary remedial activities shall take place prior to site demolition and construction of the Proposed Project. The UST associated with the existing on-site auto mechanic is used for the storage of used motor oil associated with routine operation. There have been no reported leaks or spills related to this storage tank and this use is not listed on any database which reports spills, incidents, or releases. As previously discussed, laboratory analysis of soil samples collected during a 2001 Phase II subsurface assessment indicated no detectable levels of gasoline-related hydrocarbons (including BTEX or MTBE) in soils beneath the auto mechanic or adjacent to the in-use waste oil storage tank. The concentrations of metal on-site were within background levels. Also, relatively low concentrations of diesel range hydrocarbons were reported in three of the 12 soil samples ranging between below laboratory reporting limits to 17 parts per million, below the guidance levels set forth in the California LUFT Manual. However, prior to demolition and construction activities, Mitigation Measures E-1 through E-3 shall be implemented. With the implementation of the included mitigation measures, impacts related to possible on-site soil contamination would be less than significant. Page IV.E-12

13 Off-Site As discussed above, three land uses in the vicinity of the project site were identified in a review of hazardous materials databases. The Airport Marina Hotel, AMFAC Hotel, and Furama Hotel (which formerly occupied a portion of the project site) are listed on the RCRA-TSD, FINDS, HAZNET, and RCRA-SQG databases. The waste category is listed as an organic small quantity generator with no reported releases or violations. In addition, in excess of 13 tons of ACMs waste was removed from the Furama Hotel. The hotel has subsequently been demolished with the exception of the hotel tower, which has completed extensive renovations while the remainder of the area exists as a construction site. Because the database identified waste material that no longer exists at the identified site, there is no potential for these materials to impact the project site or vicinity. The Loyola Village Elementary School is listed on the FINDS database. However, no releases or contamination issues have been reported regarding this location. The Otis College of Art and Design is listed on the HAZNET and EMI databases. The waste category is listed as photo-chemicals and photoprocessing waste with no releases, contamination issues, or violations reported. Because these two identified sites exist hydraulically down gradient from the project site, it is unlikely that any potential release of hazardous materials could impact the project site. Therefore, impacts would be less than significant. Proximity to an Airport The nearest airport to the project site is the Los Angeles International Airport, which is located approximately 0.5 miles to the south. The project site is not located within the boundaries of an airport land use plan and would not result in a safety hazard for people residing or working in the project area. The Proposed Project is also not located in the vicinity of a private airstrip. Therefore, no impact would occur. Emergency Response Plan The project site is located at the southeast corner of Manchester Avenue and Rayford Drive and approximately 0.07 miles west of Lincoln Boulevard, of which Manchester Avenue and Lincoln Boulevard are City-designated selected disaster routes that trend east-west and north-south, respectively. 4 In addition, according to the Safety Element of the General Plan of the City of Los Angeles, a Selected Emergency Facility identified as a City of Los Angeles Maintenance Warehouse is located approximately 0.37 miles southeast of the project site. 5 Despite its proximity to both selected disaster routes and the Selected Emergency Facility, the Proposed Project would not impede access to or from Manchester Avenue or Lincoln Boulevard, or interfere with operation at the nearby City Maintenance Warehouse. The construction and operation of the Proposed Project would not interfere with any other adopted 4 5 City of Los Angeles City Planning Department, Environmental and Public Facilities Maps, Critical Facilities & Lifeline Systems in the City of Los Angeles, September City of Los Angeles General Plan, Safety Element, Exhibit H, Critical Facilities & Lifeline Systems in the City of Los Angeles. Page IV.E-13

14 emergency response plan or emergency evacuation plan. Therefore, impacts would be less than significant. Wildland Fire The project site is within the highly urbanized area of Westchester-Playa Del Rey and is not located within a City-designated Wildland Fire Hazard Area. 6 Thus, no impact with respect to wildland fires would occur. CUMULATIVE IMPACTS Development of the Proposed Project in combination with the 19 related projects has the potential to increase the use, storage, transport, and/or release of hazardous materials. However, Mitigation Measures E-1 through E-7 would reduce the potential impacts associated with the Proposed Project to a less than significant level. With respect to the related projects, each of the related projects would require evaluation for potential threats, including those associated with the release of hazardous materials into the environment, or from exposure to a health hazard, in excess of regulatory standards, exposure of hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school, or the location of a listed hazardous materials site. Because hazardous materials and risk of upset conditions are largely site-specific, this would occur for each individual project affected, in conjunction with development proposals on these properties. Further, local municipalities are required to follow local, State, and federal laws regarding hazardous materials and other hazards. Therefore, with compliance with local, State, and federal laws pertaining to hazards and hazardous materials, cumulatively considerable impacts would be reduced to a less than significant level. MITIGATION MEASURES E-1. E-2. E-3. For USTs currently in use and any found to be present on-site, a qualified UST consultant shall decommission the UST in compliance with the LAFD and other applicable state agencies. Prior to construction, further investigation is required to assess the potential for subsurface groundwater and soil contaminants in the vicinity of the former Gerald s Hardware Store onsite. If contaminated soils are found to be present, a qualified abatement consultant shall abate the soils in compliance with the Department of Building and Safety and other applicable State regulations. Prior to the issuance of a building permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified abatement consultant that no contaminated soils are present on-site. If contaminated soils are found to be present, a 6 City of Los Angeles City Planning Department, Environmental and Public Facilities Maps, Selected Wildland Fire Hazard Areas, September Page IV.E-14

15 qualified abatement consultant shall abate the soils in compliance with the Department of Building and Safety and other applicable State regulations. E-4. E-5. E-6. E-7. Prior to the issuance of the demolition permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified PCB abatement consultant that no PCBs are present on-site. If PCBs are found to be present, a qualified abatement consultant shall abate the site in compliance with the applicable City, State, and federal rules and regulations. All suspect ACMs known to be on-site, as well as any suspect ACMs discovered during future construction activities at the site, shall be sampled and analyzed for asbestos content prior to any disturbance. Prior to the issuance of the demolition permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified asbestos abatement consultant that no ACMs are present in the buildings. If additional ACMs are found to be present, a qualified asbestos abatement consultant shall abate the buildings in compliance with the South Coast Air Quality Management District s Rule 1403 as well as all other State and federal rules and regulations. A LBP survey shall be conducted to determine the existence of any LBP on-site. Any contractor who would disturb lead containing surfaces shall be notified of the hazard and their requirement to comply with the applicable City, State, and federal regulations. Any additional LBP identified shall be abated by a qualified abatement consultant in accordance with all applicable City, State, and federal regulations. Because the project site is located in a City-designated Methane Buffer Zone, the applicant shall be required to comply with Division 71 of the Los Angeles Municipal Code detailing the inclusion of a methane mitigation system. LEVEL OF SIGNIFICANCE AFTER MITIGATION With the implementation of mitigation measures, impacts related to hazards and hazardous materials would be less than significant. Page IV.E-15