HAZARDS AND HAZARDOUS MATERIALS

Transcription

1 IV.E HAZARDS AND HAZARDOUS MATERIALS 1. INTRODUCTION This section addresses the Project s potential environmental impacts related to hazards and hazardous materials, including analysis of surrounding uses that may be hazardous to the Project site. Where potentially significant impacts are identified, mitigation measures are recommended to reduce such impacts to less than significant levels. 2. METHODOLOGY a. Phase I ESA The information contained in this section is derived from a Phase I Environmental Site Assessment (ESA), dated January 17, 2007, performed by URS Corporation. A copy of the Phase I ESA is provided in Appendix IV.E of this environmental impact report (EIR). 1 The Phase I ESA identifies the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The methodologies for analysis of the potential for hazards and hazardous materials to be present or created by the proposed Project are described below. The report was prepared in general accordance with the American Society for Testing and Materials. Reconnaissance Survey: A reconnaissance of the Project site was conducted to make visual observations of existing site conditions and activities, noting physical evidence of potential contamination or possible sources of contamination. In addition, a drive-by survey of the area within 0.25 mile of the site was conducted to observe types of general land uses in the vicinity of the Project site. Database List Search: A review of the federal, state, and local database of known or potentially hazardous waste sites or landfills, and sites currently under investigation for environmental violations was conducted. The database was provided by Environmental Data Resources, Inc., (EDR) of Milford, Connecticut. The agency list and search radii results (EDR Report) are provided in Appendix B of the Phase 1 ESA. 1 URS Corporation, Phase I Environmental Site Assessment, 649 West Adams Boulevard, Los Angeles, California 90007, January 17, Los Angeles Department of City Planning IV.E-1 Figueroa and Adams Student Housing Project Draft EIR

2 Conducted Inquiries: Inquiries were conducted in person, by telephone, or in writing to the appropriate regulatory agencies for information regarding environmental permits, violations or incidents, and/or the status of enforcement actions at the Project site. Site-specific information that was not observed was obtained from Brother Wiedemer, of Saint Vincent s Roman Catholic Church. Document and Map Review: A review of pertinent, available documents and maps regarding local physiographic and hydrogeologic conditions in the site vicinity, including the potential presence of wetlands, floodplains, coastal zones, aquifer recharge areas, and nearby environmentally sensitive sites, was conducted. Research Historical Land Use: A review of available historical aerial photographs and Sanborn maps of the site and vicinity was reviewed for evidence of previous site activities and development that would suggest the potential presence of hazardous substances at the site. Archival U.S. Geological Survey Maps: Review and interpretation of archival U.S. Geological Survey (USGS) topographic maps of the site and the area within 0.5 mile of the Project site was conducted for information regarding historical land use potentially involving the manufacture, generation, use, storage and/or disposal of hazardous substances. Title Records: A review of available title records was conducted for the Project site. 3. REGULATORY FRAMEWORK a. Federal Regulations Applicable federal regulations include the United States Environmental Protection Agency s (EPA s) recommended action level, which establishes a threshold for naturally occurring radon, and the US EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), which regulate the use, removal, and disposal of asbestos-containing material (ACM) and are implemented by the South Coast Air Quality Management District (SCAQMD) and the Occupational Safety and Health Act (OSHA), which sets standards for safe exposure limits of chemicals to which construction workers are exposed. 2 Additional OSHA guidelines require that specific health and safety plans be implemented during construction for given chemical exposure risks. OSHA regulates methane gas and lead exposure. 2 These regulations are not applicable to the proposed Project, as the Project site is currently developed with a parking lot and no demolition of existing structures is proposed. Nonetheless, they are included in order to provide an overview of regulations typically applicable to development projects. Los Angeles Department of City Planning IV.E-2 Figueroa and Adams Student Housing Project Draft EIR

3 b. State Regulations Gas and Oil Wells/Underground Storage Tanks The Division of Oil, Gas, and Geothermal Resources (DOGGR) enforces regulations regarding the permitting, establishment, completion, and abandonment/re-abandonment of gas and oil wells. If oil or gas wells are located on the Project site, proper abandonment is required by DOGGR. Hazardous Waste The California State Hazardous Waste Control Law (HWCL) establishes regulations for hazardous waste, and the Cal/EPA, Department of Toxic Substances Control (DTSC) administers the state hazardous waste program. Asbestos and Lead Cal/OSHA regulates lead exposure during construction activities as well as airborne contaminants such as lead, asbestos, and soil gases. Employers must implement an Injury and Illness Prevention Program (IIPP), which is a safety program to protect workers from workplace hazards, such as those involved in the demolition/renovation of existing buildings and construction of new buildings. The SCAQMD regulates emissions of asbestos during demolition and renovation activities through specific removal, handling, and clean-up procedures (Rule 1403, Asbestos Emissions from Renovation/Demolition Activities. 3 c. Local Regulations Methane Chapter IX, Article 1, Division 71, Section of the Los Angeles Municipal Code lays out the Los Angeles Methane Seepage Regulations for buildings and paved areas located in either a Methane Zone or Methane Buffer Zone. The City of Los Angeles methane seepage regulations provide requirements for buildings and paving in areas classified as a Methane Zone or Methane Buffer Zone. 4 The City has adopted specific testing protocols and design standards related to building in these zones. For projects within these zones, the City regulations require that a methane gas investigation be conducted to determine the appropriate Site Design Level. Five Design Levels are identified under the City methane 3 These regulations are not applicable to the proposed Project, as the Project site is currently developed with a parking lot and no demolition of existing structures is proposed. Nonetheless, they are included in order to provide an overview of regulations typically applicable to development projects. 4 The City of Los Angeles Municipal Code, Section Los Angeles Department of City Planning IV.E-3 Figueroa and Adams Student Housing Project Draft EIR

4 seepage regulations. Site Design Level is determined by the Design Methane Concentration, the highest concentration of methane gas, and the Design Methane Pressure, the highest pressure of methane gas, as determined by site testing. Table IV.E-1 specifies the minimum methane mitigation systems, such as the passive, active, and miscellaneous systems, depending on the concentration and pressure of the methane present at the site. Table IV.E-1 Building Methane Mitigation Regulations Site Design Level Level I Level II Level III Level IV Level V Design Methane Concentration (ppmv) ,000 1,001-5,000 5,001-12,500 >12,500 Design Methane Pressure (inches of All 2 >2 2 >2 2 >2 2 >2 water pressure) Pressures De-watering System 1 X X X X X X X X X Perforated Horizontal X X X X X X X X X Pipes Gravel Blanket Thickness Under Impervious Membrane Gravel Thickness Surrounding Perforated Horizontal Pipes Vent Risers X X X X X X X X X Impervious Membrane X X X X X X X X X Passive System Active System Misc. System Sub-Slab Vent System Sub-Slab System Lowest Occupied Space System Pressure Sensors Below Impervious Membrane X X Mechanical X X Extraction System 2 Gas Detection X X X X X X X System 3 Mechanical X X X X X X X Ventilation 3, 4, 5 Alarm System X X X X X X X Control Panel X X X X X X X Trench Dam X X X X X X X X X Conduit or Cable Seal Fitting X X X X X X X X X Additional Vent Risers 6 X Source: X = Indicates a Required Mitigation Component 1 See Section for exception. 2 The Mechanical Extraction System shall be capable of providing an equivalent of a complete change of air every 20 minutes of the total volume of the Gravel Blanket. 3 See Section for Narrow Buildings. 4 The Mechanical Ventilation systems shall be capable of providing an equivalent of one complete change of the lowest occupied space air every 15 minutes. 5 Vent opening complying with Section may be used in lieu of mechanical ventilation. 6 The total quantity of installed Vent Risers shall be increased to double the rate for the Passive System. Los Angeles Department of City Planning IV.E-4 Figueroa and Adams Student Housing Project Draft EIR

5 Mitigation requirements under the three systems included in Table IV.E-3 are defined below: 5 Alarm System: a group of interacting elements consisting of components and circuits arranged to monitor and annunciate the status of gas concentration levels or supervisory signal-initiating devices and to initiate the appropriate response to those signals. Cable or Conduit Seal Fitting: an approved fitting provided in a cable or conduit system to prevent the passage of gases, vapors or flames through electrical cable or conduit. De-watering System: a permanent water removal system, consisting of perforated pipes, gravel, sump pumps and pits, designed to permanently maintain the ground water level 1 foot below the sub-slab vent system. Gas Detection System: one or more electrical devices that measure the methane gas concentration and communicate the information to the occupants, building management, central station or alarm company with audible or visual signals. Gravel Blanket: a layer of gravel, sand or approved material designed to transmit gas to the vent riser without obstructing the venting system. Impervious Membrane: a continuous gas barrier made of material approved by the Department of Building and Safety and installed beneath a building for the purpose of impeding methane migration to the interior of the building. Mechanical Extraction System: a system operated by a machine which is designed to remove methane gas from below the impervious membrane through the use of fans, blowers or other powered devices. Mechanical Ventilation: a fan, blower or other similar group of interacting elements operated by a machine within the building, which introduce and/or remove air from an enclosed space. Perforated Horizontal Pipe: an approved pipe which contains a series of small holes or narrow openings placed equidistant along the length of the approved pipe, which is placed horizontally beneath the foundation of a building, for the purpose of venting accumulated methane gas and preventing the development of elevated gas pressures or for drainage of ground water to an approved location. Pressure Sensor: a device that measures and communicates surrounding gas pressure to an alarm or control system. Single Station Gas Detector: a device consisting of electrical components capable of measuring methane gas concentration and initiating an alarm. Trench Dam: an approved subsurface barrier installed within a furrow or ditch adjacent to the foundation of a building, for the purpose of preventing the migration of methane gas beneath that foundation; and Vent Riser: an approved pipe, which is placed vertically with joints and fittings connected to Perforated Horizontal Pipes to convey and discharge the gas to the atmosphere. 5 The City of Los Angeles Municipal Code, Section Los Angeles Department of City Planning IV.E-5 Figueroa and Adams Student Housing Project Draft EIR

6 Hazardous Materials The Los Angeles Fire Department regulates hazardous materials for the City of Los Angeles by issuing permits for hazardous materials handling and administering sections of the Los Angeles City Fire Code applicable to hazardous materials. 4. EXISTING CONDITIONS The Project site consists of an asphalt-paved parking lot developed in 1948 with a small garden in the western portion of the site. No structures are present on the Project site. a. Physical Setting Topography The Project site lies at an approximate elevation of 206 feet above mean sea level (MSL) with a local topographic gradient to the south-southwest. Surface Water No surface water bodies were observed on or adjacent to the Project site. The nearest surface water is the Los Angeles River, which is located approximately 2.75 miles to the east of the Project site. Based on information contained in the EDR Radius Map report, the Project site is not located within a mapped 100- or 500-year Federal Emergency Management Agency (FEMA) flood zone. There is no evidence of a current or historical wetland habitat at the Project site, and no federal wetland areas were identified within 1 mile of the Project site. Geology and Soils The Project site is located within the central block of the Los Angeles Basin, which is included in the Transverse Ranges geomorphic province. The site is within an area defined as the Downey Plain, a broad synclinal sag about 10 to 14 miles wide. The Downey Plain is an area of Recent alluvial deposition formed by the Los Angeles and Rio Hondo San Gabriel River systems. Based on a review of the United States Department of Agriculture (USDA), Soil Conservation Service, Soil Survey of Los Angeles County, California (United States Department of Agriculture, Soil Conservation Service, September 1969), the Project site is underlain by soils primarily classified as the Hanford association. Soils of this association occur on gently sloping alluvial fans. Hanford soils are over 60 inches Los Angeles Department of City Planning IV.E-6 Figueroa and Adams Student Housing Project Draft EIR

7 deep, are well drained, and have moderately rapid subsoil permeability. They have pale-brown coarse sandy loam surface layers about 8 inches thick underlain by light yellowish-brown coarse sandy loam and gravelly loamy coarse sand substratum. Typically, they are slightly acid to mildly alkaline throughout, but occasionally are calcareous in the lower part. Thin layers of coarser material may occur below 40 inches. Hydrogeology Pertinent maps and readily available literature was reviewed for information on the surface water and groundwater hydrology of the Project site. The Project site is located within the Los Angeles Forebay Area and is underlain by Recent alluvium of the Downey Plain. The known water-bearing sediments extend to a depth of approximately 1,600 feet and include Recent alluvium, the Lakewood Formation, and the San Pedro Formation. Based on the Seismic Hazard Evaluation of the Los Angeles 7.5-Minute Quadrangle prepared by California Department of Conservation, Division of Mines and Geology, groundwater is expected at a depth greater than 60 feet below ground surface and flows to the southwest. b. Historical Information Information regarding the history of the Project site was obtained from historic Sanborn Fire Insurance maps, historic USGS topographic maps, historic aerial photographs, EDR Proprietary Historical Database review, and user-provided information. These sources all reflect the following history of the site and vicinity. According to review of available historical data, the Project site was originally developed with a two-story residential building with an associated outbuilding sometime prior to 1894, with a historical address of 2437 South Figueroa Street. Between 1894 and 1922, large residential properties occupied the surrounding parcels. By 1950, the residence and outbuilding were no longer present on the Project site. By 1966, residential properties located to the west of the site were collectively labeled as Mt. Saint Mary s Downtown Campus in the Sanborn map. No historical data gaps were identified during the review of historical uses of the Project site. c. Phase I ESA Findings Site Reconnaissance On December 20, 2006, a reconnaissance of the Project site was conducted. The reconnaissance consisted of the observation and documentation of existing site conditions accessible by foot and nature of the Los Angeles Department of City Planning IV.E-7 Figueroa and Adams Student Housing Project Draft EIR

8 neighboring property development within 0.25 mile of the site. Site-specific information that was not observed was obtained from personnel at the adjacent Saint Vincent s Church. The Project site consists of an approximately 1.67 acre parcel developed with an approximately 47,250-square-foot asphalt-paved parking lot and landscaped areas developed in approximately A small grass-covered yard is present in the western portion of the site and is separated from the parking lot by a fence that restricts public access. Hazardous Substances No hazardous substances were observed being used, stored, or disposed of at the Project site. No evidence of leaks or spills from hazardous materials was observed. Storage Tanks No aboveground storage tanks (ASTs) or underground storage tanks (USTs) were reported or observed on the Project site. Polychlorinated Biphenyls No transformers or other potentially polychlorinated biphenyl- (PCB) containing equipment were observed on site during the site reconnaissance. Waste Disposal No solid waste is generated at the site. No evidence or indications of hazardous materials or refuse dumping was observed on site. Wetlands, Floodplains, Coastal Zone The Project site is not located within either a FEMA identified 100- or 500-year flood zone. No wetlands were visible on or adjacent to the Project site. The Project site is not located within a coastal zone. Drums/Other Chemical Containers No drums or chemical containers were observed on site during the site reconnaissance. Los Angeles Department of City Planning IV.E-8 Figueroa and Adams Student Housing Project Draft EIR

9 Dumping Evidence of unauthorized dumping of chemicals or substances was not observed during the site reconnaissance. Pits, Ponds, Lagoons, Septic Systems, Cisterns, Sumps, Drains, and Clarifiers Pits, ponds, lagoons, septic systems, cisterns, and sumps, drains, and clarifiers were not observed at the Project site during site reconnaissance. Storm water is directed off site via sheet runoff to Figueroa Street located adjacent to the east of the site. Pesticide Use Use and storage of pesticides was not observed at the Project site. Staining and Discolored Soil No staining or discolored soils were observed on site during the site reconnaissance. Stressed Vegetation Stressed vegetation was not observed on-site during the site reconnaissance. Unusual Odors No unusual odors were noted during the site reconnaissance. Asbestos No buildings or structures were located on site at the time of the site reconnaissance. Consequently, no suspect asbestos-containing material (ACM) was observed. Lead-Based Paint No buildings or structures were located on-site at the time of the site reconnaissance. Consequently, no potential lead based paint was observed. Oil Wells Monitoring, water supply, and/or oil or gas production wells were not observed on site. A review of the Munger Map Book of California and Alaska Oil Fields (2003) indicates that the Project site is located Los Angeles Department of City Planning IV.E-9 Figueroa and Adams Student Housing Project Draft EIR

10 within the boundary of the Las Cienegas Oil Field. A cluster of 21 oil and/or gas wells is located approximately mile northwest of the site. According to production logs available for review online through the California Department of Conservation DOGGR Web site, nine of the 21 wells are active. Based on the cross gradient location of wells and the lack of reported spills or releases, the oil wells are not considered an environmental concern for the Project site. Site Vicinity and Adjacent Properties Observation and evaluation of adjoining properties were limited to features and conditions that were visible from public rights-of-way. No indication of the use or storage of hazardous materials was noted during the site survey of adjacent structures and businesses. Radon The United States Environmental Protection Agency (U.S. EPA) survey of indoor radon concentrations listed the radon zone designation for Los Angeles County, California, as Zone 2. Zone 2 areas are predicted to have an average indoor radon screening potential between 2.0 picocuries per liter of air (pci/l) and 4.0 pci/l for the general area of the Project site. The U.S. EPA action level for radon is 4.0 pci/l. Therefore, further assessment for radon at the site is unwarranted. Database List Search As previously noted, EDR was contracted to conduct a search for facilities listed by regulatory agencies as potentially having environmental concerns. The search included a 1-mile radius of the Project site to assess whether activities on or near the Project site have the potential to create recognized environmental conditions (RECs) at the Project site. The complete list of databases reviewed is provided in the EDR Database Report, included as Appendix B to the Phase 1 ESA. Pertinent findings of the agency database reviews are summarized below. Project Site and Adjacent Properties Based on a review of the database report, neither the Project site nor immediately adjacent properties were identified in the findings. Sites in the Vicinity of Project A review of the EDR Database Report revealed 17 unique sites as having potential or known environmental concerns. URS Corporation determined that the facilities do not present a concern to the Los Angeles Department of City Planning IV.E-10 Figueroa and Adams Student Housing Project Draft EIR

11 Project site because they do not meet URS Corporations criteria for further evaluating the potential impact of a listed off-site facility, as summarized below: The listed off-site facility is not adjacent to the Project site; or, the listed off-site facility is not documented or assumed to be hydrogeologically upgradient and a likely pathway does not exist for environmentally mobile contaminants to reach the site; or, contaminants from the listed off-site facility can not reach the site through other pathways (i.e., surface runoff); and, The off-site facility is not listed on one of the following databases: Federal National Priorities List (NPL); Federal CORRACTS (a list of handlers with Resource Conversation and Recovery Act [RCRA] Corrective Action Activity); Federal Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS); Federal Emergency Response Notification System (ERNS); State SPL; State SCL; State Leaking Underground Storage Tank (LUST); State Deed Restrictions; State Toxic Pits; Landfill (excluding transfer stations); or, The facility does not adjoin the Project site and is not listed as a RCRA large-quantity hazardous waste generator, a CERCLIS NFRAP (CERCLIS No Further Remedial Action Planned) site, or an underground story tank (UST) operator; or The facility is not a known or suspected concern based on URS experience or observations made during the site reconnaissance. (i.e., dry-cleaning operations that may or may not be listed as RCRA-SQG [RCRA Small Quantity Generator] or a non-adjacent UST site that appears to have a remediation system in place). Regulatory Contacts The following agencies were contacted and indicated that they did not have records suggesting the presence of hazardous materials at the Project site: California Environmental Protection Agency (Cal/EPA), Department of Toxic Substances Control (DTSC), Glendale Office DTSC, Cypress Office California Regional Water Quality Control Board, Los Angeles Region (LARWQCB), SLIC Unit LARWQCB, UST Unit LARWQCB, SLIC Unit LARWQCB, NPDES Unit LARWQCB, Stormwater Unit South Coast Air Quality Management District (SCAQMD) Office of the California State Fire Marshal (CSFM) Los Angeles Department of City Planning IV.E-11 Figueroa and Adams Student Housing Project Draft EIR

12 Los Angeles County Department of Health Services, Public Health Investigation (PHI) Los Angeles City Department of Public Works, Bureau of Sanitation Districts, Industrial Waste Management Division (IWMD) Los Angeles City Fire Department (LAFD), Hazardous Materials Records LAFD, Underground Tank Plan Check Unit d. Methane The Project site lies within a City Methane Zone, as shown on Figure IV.E-1, Methane Zone Boundary. Methane gas naturally occurs in areas of subterranean petroleum deposits, such as oil fields. Subsurface concentrations of methane gas can result in seepage of the gas to the surface and into buildings through basements. Methane gas is non-toxic, odorless, colorless, and highly flammable at certain concentrations. At high concentrations methane can act as an asphyxiant. 6 e. Emergency Response Plan The City of Los Angeles Emergency Operations Organization coordinates among emergency service organizations and government agencies to manage the critical resources necessary in the time of emergency. The Emergency Operations Organization is made up of many operational divisions. The Public Works Division and the Fire Suppression and Rescue Division are responsible for preventing and responding to emergencies involving hazardous materials Citywide. 7 Individual emergency response and evacuation plans are required by state law for businesses that use specified hazardous materials or involve the threat of a potential release of a hazardous material. 8 Figueroa Boulevard in the vicinity of the Project site is a selected disaster route, according to the City of Los Angeles General Plan. 9 6 An asphyxiant is a substance, such as a toxic gas, that induces asphyxia. Asphyxia is the extreme condition caused by lack of oxygen and excess of carbon dioxide in the blood, produced by interference with respiration or insufficient oxygen in the air. Source: Dictionary.com Unabridged (v 1.1). Retrieved May 12, 2009, from and /asphyxia. 7 Emergency Preparedness Department of the City of Los Angeles, Emergency Operations Master Plan and Procedures, March City of Los Angeles, Environmental Affairs Department, L.A. CEQA Thresholds Guide, City of Los Angeles, General Plan, Safety Element, Exhibit H, Critical Faculties and Lifeline Systems in the City of Los Angeles, Web site accessed April 2, Los Angeles Department of City Planning IV.E-12 Figueroa and Adams Student Housing Project Draft EIR

13 Project Site Project Site Pacific Ocean Legend: Methane Zone Methane Buffer Zone Council District Boundary n APPROXIMATE SCALE IN MILES SOURCE: City of Los Angeles, Bereau of Engineering, Department of Public Works March 2004 FIGURE IV.E-1 Methane Zone Boundary /08

14 5. ENVIRONMENTAL IMPACT ANALYSIS a. Significance Criteria In accordance with Appendix G of the California Environmental Quality Act (CEQA) Guidelines, a project would have a significant impact related to hazards and hazardous materials 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 and accident conditions involving the release of hazardous materials into the environment; emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school; be located on a site, which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would create a significant hazard to the public or the environment; impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, for a project located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, result in a safety hazard for people residing or working in the project area; for a project within the vicinity of a private airstrip, result in a safety hazard for people residing or working in the project area or; 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. The last three thresholds contained in Appendix G of the State CEQA Guidelines were determined in the Initial Study prepared for the Project to be less than significant and no further analysis is required. Therefore, these thresholds are discussed in Section VII, Effects Found Not to be Significant. The Initial Study is provided in Appendix I, Notice of Preparation (NOP), Initial Study, Public Comments on the NOP/IS, and Scoping Meeting Materials. The following factors are set forth in the City of Los Angeles L.A. CEQA Thresholds Guide for consideration on a case-by-case basis in making a determination of significance. Los Angeles Department of City Planning IV.E-14 Figueroa and Adams Student Housing Project Draft EIR

15 Risk of Upset/Emergency Preparedness HAZ-1 Compliance with the regulatory framework. HAZ-2 The probable frequency and severity of consequences to people or property as a result of a potential accidental release or explosion of a hazardous substance. HAZ-3 The degree to which project design will reduce the frequency or severity of a potential accidental release or explosion of a hazardous substance. HAZ-4 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. Human Health Hazards Impacts would also be considered significant to human health if the Project would create a health hazard by introducing a hazard or disturbing, removing or disposing of a hazard found on site or locate people adjacent to a health hazard. 10 HAZ-5 The regulatory framework for the health hazard. HAZ-6 The probable frequency and severity of consequences to people from exposure to the health hazard. HAZ-7 The degree to which project design would reduce the frequency of exposure or severity of consequences of exposure to the health hazard. Based on these factors, the Project would have a significant impact if it would expose people or structures to substantial research resulting from the release of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards. The City s thresholds are inclusive of those provided in Appendix G of the State CEQA Guidelines. In addition, the City s thresholds provide more specific guidance for evaluating impacts. Therefore, the City s thresholds are used in the following analysis. 10 City of Los Angeles, Environmental Affairs Department, L.A. CEQA Thresholds Guide, 2006, F.2-2 F.2-3. Los Angeles Department of City Planning IV.E-15 Figueroa and Adams Student Housing Project Draft EIR

16 b. Project Impacts Risk of Upset/Emergency Preparedness HAZ-1 Compliance with the regulatory framework. HAZ-2 The probable frequency and severity of consequences to people or property as a result of a potential accidental release or explosion of a hazardous substance. HAZ-3 The degree to which project design will reduce the frequency or severity of a potential accidental release or explosion of a hazardous substance. Federal regulations for hazardous materials include the NESHAP, which regulates the use, removal, and disposal of ACM and are implemented by SCAQMD and OSHA. State regulatory agencies include DOGGR, Cal/EPA, DTSC, Cal/OSHA, and the SCAQMD. DOGGR enforces regulations regarding the permitting, establishment, completion, and abandonment/re-abandonment of gas and oil wells. DTSC administers the state hazardous waste program established by HWCL. SCAQMD regulates emissions of asbestos during demolition and renovation activities through specific removal, handling, and clean-up procedures. These regulations are not applicable to the proposed Project, as the Project site is currently developed with a parking lot and no demolition of existing structures that could contain hazardous materials is proposed. Locally, the LAFD issues permits for hazardous materials handling and administers sections of the Los Angeles City Fire Code applicable to hazardous materials. Construction Impacts Methane Gas The Project site is within a City Methane Zone, as shown on Figure IV.E-1, associated with the Downtown Los Angeles oil field. Because methane gas is highly flammable at certain concentrations, construction activities can potentially ignite methane gas and cause an explosion. Since the Project site is located within a City-defined Methane Zone, the impact of methane to the Project site is considered potentially significant. The Project would be required to comply with the Los Angeles Methane Seepage Regulations for buildings and paved areas located in either a Methane Zone or Methane Buffer Zone, which would reduce potentially significant impacts to a less than significant level. Nonetheless, Mitigation Measure MM-HAZ-1 is required to ensure compliance with the Los Angeles Methane Seepage Regulations for buildings and paved areas located in either a Methane Zone or Methane Buffer Zone. Los Angeles Department of City Planning IV.E-16 Figueroa and Adams Student Housing Project Draft EIR

17 Gas and Oil Wells / Underground Storage Tanks The Phase I ESA determined that oil wells are not a threat to the site because of the location of the nearest oil wells and the cross gradient location of the oil wells. According to the Phase I ESA prepared for the Project site, the site has not been affected by oil and gas production; therefore, the likelihood that contamination is present within the soil is low. No ASTs or USTs were reported or observed on the Project site. For these reasons, potential impacts related to gas and oil wells and underground storage tanks would be less than significant. Hazardous Materials As discussed in the Setting, the Phase I ESA did not identify any other hazards on the Project site that would have the potential to result in harm to people, the environment, or property as a result of a potential accidental release or explosion. No known hazardous substances, ACM, and/or lead-based paint were identified on the Project site. The Project site was not identified as a contaminated site in the records search. The Project site is not within 1 mile of a federal Superfund property is not located within 1 mile of a significant impact-causing site listed on the EDR report. Regulatory agency records review did indicate hazardous sites in the vicinity as discussed above, but these sites did not meet the criteria for causing potential impacts to the Project site. Additionally, review of local agency records did not indicate any hazards associated with the Project site and no environmental concerns were identified on historical aerial photographs. During a reconnaissance of the Project site, no conditions were observed that would be expected to impact the Project site or surrounding land uses with respect to hazards and/or hazardous materials. Impacts would, therefore, be less than significant. Asbestos/Lead No structures containing asbestos or lead are located on site and the potential for soil contamination is low. No asbestos- or lead-containing structures are proposed as part of the Project. Therefore, implementation of the proposed Project would not result in potential accidental release or explosions on the Project site as a result of the presence of hazardous substances, and impacts would be less than significant. Therefore, for the reasons discussed above, the risk of upset related to compliance with the regulatory framework would be less than significant. Los Angeles Department of City Planning IV.E-17 Figueroa and Adams Student Housing Project Draft EIR

18 Operational Impacts Hazardous Materials During Project operation, typical household chemicals such as cleaning solvents would be used in the Project residences and for landscaping and building maintenance purposes. However, these products do not pose a substantial risk to people or property and are not likely to result in explosion or cause harm to humans or the environment. The potential for operational impacts related to hazards and the use of hazardous substances would, therefore, be less than significant. Asbestos/Lead No asbestos- or lead-containing structures are proposed as part of the Project. Therefore, implementation of the proposed Project would not result in potential accidental release or explosions on the Project site as a result of the presence of hazardous substances, and impacts would be, therefore, less than significant. HAZ-4 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. As part of the proposed Project, an approximately 25-foot side-yard/fire department access lane would be provided along the southern property line. A proposed easement for an approximately 20-foot-wide secondary emergency access road to the Project site would extend southerly from the site to Adams Boulevard, through the St. Vincent s Church property, between the rectory building and utility building. A portion of the planned easement is currently occupied by a gated 10-foot-wide concrete driveway that provides access from Adams Boulevard to a parking area at the rear of the rectory. Mitigation Measure MM-FIRE-4, provided in Section IV.J.4, Fire Protection and Emergency Medical Services, requires that the secondary access road be constructed according to the requirements of the LAFD. Because the provision of emergency access to the site would meet the standards of the LAFD, the potential impact related to emergency response or evacuation plans would be less than significant According to the City of Los Angeles General Plan, Safety Element, Exhibit H, Critical Facilities and Lifeline Systems in the City of Los Angeles, Figueroa Boulevard in the vicinity of the Project site is a selected disaster route. 11 Construction of the Project may result in temporary partial obstruction to Figueroa Street or Adams Boulevard. As such, impacts would be potentially significant, absent mitigation. Mitigation provided in Section IV.K, Transportation, requires that prior to the issuance of 11 City of Los Angeles, General Plan, Safety Element, Exhibit H, Critical Faculties and Lifeline Systems in the City of Los Angeles, Web site accessed April 2, Los Angeles Department of City Planning IV.E-18 Figueroa and Adams Student Housing Project Draft EIR

19 demolition permits, the applicant prepare a Construction Traffic Management Plan for review and approval by the Los Angeles Department of Transportation (LADOT). The Construction Management Plan will be implemented by the construction contractor during Project construction. Complying with all applicable required City codes and regulations would reduce potentially significant impacts related to emergency travel in the vicinity of the Project site to a level of less than significant. Nonetheless, Mitigation Measure MM-HAZ-2 is incorporated to ensure Project compliance with all applicable City codes and regulations pertaining to emergency response and evacuation plans maintained by the City of Los Angeles Fire Department, Police, Department of Public Works, and Department of Building and Safety. Human Health Hazards HAZ-5 Compliance with the regulatory framework for the health hazard. HAZ-6 The probable frequency and severity of consequences to people from exposure to the health hazard. HAZ-7 The degree to which project design would reduce the frequency of exposure or severity of consequences of exposure to the health hazard. As discussed above, federal regulations for hazardous materials include the NESHAP, which regulates the use, removal, and disposal of ACM and is implemented by SCAQMD and OSHA. State regulatory agencies include DOGGR, DTSC, Cal/OSHA, and the SCAQMD. DOGGR enforces regulations regarding the permitting, establishment, completion, and abandonment/re-abandonment of gas and oil wells. DTSC administers the state hazardous waste program established by HWCL. SCAQMD regulates emissions of asbestos during demolition and renovation activities through specific removal, handling and clean-up procedures. These regulations are not applicable to the proposed Project, as the Project site is currently developed with a parking lot and no demolition of existing structures containing hazardous materials is proposed. The LAFD issues permits for hazardous materials handling and administers sections of the Los Angeles City Fire Code applicable to hazardous materials. The Phase I ESA did not identify any potential health hazards to humans, the environment, or the Project site. The Project site does not contain buildings that have ACM or lead-based paint (LBP), is not identified as a contaminated site according to a records search, is not within 1 mile of a federal Superfund property, is not impacted by oil and gas production, and is not located within 1 mile of a significant impact-causing site listed on the EDR report. Additionally, review of local agency records did not indicate any hazards and no environmental concerns were identified on historical aerial photographs. During the site visit, no Los Angeles Department of City Planning IV.E-19 Figueroa and Adams Student Housing Project Draft EIR

20 conditions were observed that would be expected to expose the Project site or residents of the site to health hazards. The Project would be required to comply with the regulatory framework pertaining to human health hazards and, therefore, impacts would be less than significant. Nonetheless, it is required that Mitigation Measure MM-HAZ-1 be implemented to ensure compliance with the applicable regulations related to methane, as discussed above. During Project operation, typical household chemicals like cleaning solvents would be used in the Project residences and for landscaping and building maintenance purposes. However, these products do not pose a substantial health risk to people or property. The potential for impacts to human health related to hazards and the use of hazardous substances would be less than significant. c. Cumulative Impacts A cumulative hazards impact would occur if any related projects identified in Section III, General Description of Environmental Setting, and located within the vicinity of the proposed Project, would contribute to a cumulative release of a hazardous substance into the environment or a cumulative increase in the transport, use or disposal of hazardous materials. Each of the related projects would require evaluation for potential threats to public safety related to hazards and hazardous materials. As shown in Table III-1, the majority of related projects propose residential, retail, office, or civic (i.e., school or university) uses. With the possible exception of Related Project No. 7, the medical center/clinic, no related projects, including those within the immediate vicinity of the Project site, would require the routine transport, use or disposal of hazardous materials that could pose a significant safety risk. Furthermore, all related projects must comply with federal, state, and local procedures for the safe removal and remediation of any hazardous substances. As a result, the Proposed Project would not contribute to a significant cumulative hazards impact. d. Mitigation Measures MM-HAZ-1 Prior to issuance of a building permit, the applicant shall comply with the City Methane Seepage Regulations, Section et seq. of Los Angeles Municipal Code. MM-HAZ-2 The applicant shall comply with all applicable City codes and regulations pertaining to emergency response and evacuation plans maintained by the City of Los Angeles Fire Department, Police Department, Department of Public Works, Department of Building and Safety, and Department of Transportation. Los Angeles Department of City Planning IV.E-20 Figueroa and Adams Student Housing Project Draft EIR

21 e. Adverse Effects With implementation of Mitigation Measures MM-HAZ-1 and MM-HAZ-2, potential impacts related to hazards and hazardous materials would be less than significant. Los Angeles Department of City Planning IV.E-21 Figueroa and Adams Student Housing Project Draft EIR