iv. environmental impact analysis e. hazards and hazardous

City of Los Angeles USC Development Plan SCH. No. 2009011101 May 2010

Page IV.E-1 WORKING DRAFT - Not for Public Review

IV. Environmental Impact Analysis E. Hazards and Hazardous Materials

1. Introduction

This section of the Draft EIR analyzes the proposed Project’s potential impacts with regard to hazards and hazardous materials. The analysis includes an evaluation of the potential hazards associated with past and current uses of the site; the use, storage, and disposal of hazardous materials; the potential presence of asbestos containing materials and lead-based paint; and conditions relative to portions of the Project site being located within a City-designated Methane Zone or Methane Buffer Zone. The analysis is based on several Phase I Environmental Site Assessments (ESAs) prepared by Converse Consultants and Winzler & Kelly Consulting Engineers (see the summary reports provided in Appendix E) 1 and a Methane Report prepared by GeoKinetics (see Appendix F).,2

2. Environmental Setting

a. Prior Uses of the Project Site

Current and past land uses within the Project site were identified with regard to their potential to present concerns relative to the presence of hazards and/or the handling of hazardous materials. These concerns are classified as Recognized Environmental Conditions (REC), which are defined in Section 1.1.1 of the American Society of Testing

1 The following Phase I Reports are referenced in this section: Phase I ESA Report, 3440 South Hope Street, Converse Consultants, June 9, 2009; Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009; Phase I ESA Report, USC Fuel Station, Portion of 3401 South Grand Avenue, Converse Consultants, September 15, 2009; Phase I ESA Report, Century and La Sorbonne Apartments, 3115 South Orchard Avenue & 1170 West 31st Street, Converse Consultants, May 18, 2009; Phase I ESA, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants, May 18, 2009; Phase I ESA, University Village, 821 and 971 West Jefferson Boulevard & 3301 South Hoover Street, Converse Consultants, May 21, 2009; and Phase I ESA, 3434 S. Grand Avenue, Winzler & Kelly Consulting Engineers, October 30, 2002; These complete Phase I Reports are herein incorporated by reference and are on file with the City of Los Angeles Department of City Planning.

2 The summary reports include the Phase I ESA – Mitigation Measures Memorandum, prepared by Converse Consultants, December 15, 2009 and the Regulatory Database for Campus Boundaries – Mitigation Measures Memorandum, prepared by Converse Consultants, March 24, 2010.

IV.E. Hazards and Hazardous Materials



and Materials (ASTM) Standard Practice as the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, past release, or material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water or surface water of the property. In order to differentiate between conditions relating to current and prior uses, conditions relating to prior uses are classified as Historical Recognized Environmental Conditions (HREC).

(1) Subarea 1

The University of Southern California was formally opened in 1880. Throughout the years, the University Park Campus has been developed with a variety of educational, office, and residential uses. While portions of the University Park Campus have been redeveloped over the years, this area has been developed with University-serving uses for several decades.

Land use maps and records indicate that portions of Subarea 1 to the east of Figueroa Street and north of Exposition Boulevard were previously developed with a variety of residential, commercial and industrial uses, including gasoline stations and auto repair shops.3 Recently, much of this area was redeveloped as the USC Galen Center and Athletic Pavilion. In addition, as described in the Regulatory Database for Campus Boundaries – Mitigation Measures Memorandum prepared by Converse Consultants in March 2010 and included as Appendix E, Converse Consultants obtained and reviewed a regulatory database from Environmental Data (EDR) resources for Subarea 1. The database indicates that approximately 16 historical drycleaner sites and 14 historical auto stations were located in the vicinity of Subarea 1 between the years 1924 and 1942. Please refer to Appendix F of this EIR for a list of these identified sites and their locations.

(2) Subarea 2

Within or near Subarea 2, a total of four properties were identified that exhibit characteristics of interest with regard to the presence of hazards and/or the handling of hazardous materials. The attributes that contribute to this classification for each of the four properties are described separately below.

3 USC Galen Center and Athletic Pavilion Environmental Impact Report, City of Los Angeles, December 2003.




The USC East Library property located at 3440 South Hope Street was developed with a residential dwelling on the northern portion of the property from as early as 1907 until as late as 1922. In 1928, a four-story printing factory was constructed on the property. From 1928 to as late as 1946, this building was used as a newspaper publishing and printing factory. From as early as 1950 to as late as 1981, records indicate that this building was occupied by the California National Guard Armory and included an elevator and loading area. During this same time, an Army Ordnance Maintenance Depot was located to the north adjacent to the property. From the late 1970s to the mid-1980s, the building on the property housed local administrative offices and workshops of the California Conservation Corps. The building has been used as library storage since the mid-1980s. A railroad spur was located to the east adjacent to the property from as early as 1928 to as late as 1988. Based on this information, the following prior uses of this property are HRECs:

Prior use of the property as a newspaper publishing and printing factory due to the past use of solvents, dyes and paints;

Prior use of the property as an armory based on the possible storage, use, and generation of hazardous substances containing metals, solvents, and total petroleum hydrocarbons (TPH);

The use of hydraulic-powered elevators at the property;

The prior presence of a railroad spur to the east, adjacent to the property due to the possibility of previous spills and the use of chemicals; and

The prior use of a property, located adjacent to the north boundary of Subarea 2, as the Army Ordnance Maintenance Depot based on the possible storage, use, and generation of hazardous substances containing metals, solvents, and TPH.4

The USC office building and vehicle maintenance yard property located at 3500 South Hope Street was previously developed with three residential properties (3616, 3620, 3620½, and 3622 South Hope Street) which were located at the southwest corner of the property and date back to as early as 1907. From 1922 to 1928, these dwellings were present and addressed as 3516, 3520, and 3522 South Hope Street. In 1937 and 1942, an automotive repair shop was located south adjacent to the property at 3600 South Hope Avenue. In 1946, the southwest region of the property was developed with a dwelling, several garages, and two stores (3518, 3520, and 3522 South Hope Street). From 1952 to 1954, these structures were removed and a storage building (3520 South Hope Street) was developed in their place. In addition, two additional dwellings with garages and a spotlight

4 Phase I ESA Report, 3440 South Hope Street, Converse Consultants, June 9, 2009.




manufacturer (3501, 3503, and 3507 South Grand Avenue and 300 and 318 West 35th Street) occupied the southeast corner of the property from 1922 to 1928. By 1928, a four-story office/commercial building (3500 South Hope Street) was added to the northern portion of the property. In 1933, the building was occupied by a tire company/ manufacturer. As early as 1934 through 1983, this office/commercial building was identified as the Department of Motor Vehicles (DMV). By 1957, this building was expanded generally to the south. A contiguous canopy/inspecting shed was installed in 1935. Also from 1928 to as late as 1988, a railroad spur extending from the adjacent railway to the south intersected the property center in a general north-south direction. Two carports were present in this general area from 1957 to 1988. By 2004, three temporary structures and a liquid propane gas (LPG) tank were centrally located on the property. The east half of the property had no mapped use in 1928. From 1946 until the present, this area was used as a public parking lot/private vehicle parking. Based on this information, the following prior uses of this property are HRECs:

Prior use of the property as a tire manufacturer and spotlight manufacturer;

The prior presence of a railroad spur traversing through the center of the property due to the possibility of previous spills and the use of chemicals;

The south adjacent railroad right-of-way to the south due to the possibility of previous spills and the use of chemicals; and

The prior automobile repair shop at 3600 South Hope Avenue.5

The USC fuel station property located at 3401 South Grand Avenue was part of a larger lot occupied by residential dwellings and a corral. Therefore, the property may have had some agricultural/livestock use. As early as 1922, a structure identified as a contractor’s supplies storage was located on the property. By 1928, the property was occupied by a multi-story (between four and six) commercial building later identified in 1950 as the loading dock for the May Company department warehouse store. In 1960, a permit was issued for the installation of an Underground Storage Tank (UST) for the May Company. The loading dock structure was present until as late as 1988. By 1995, the property was a vacant lot. In 2001, construction began on the fuel station currently located on the property, which included the installation of three 20,000-gallon fuel USTs, associated piping, dispensers, and a fuel station attendant building. The 2001 construction activities also included the excavation of a UST and the demolition of a concrete wall. While the prior use of the property for agricultural/livestock use is a HREC, the potential for

5 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009.




environmental impact from this past use appears to be low due to the passage of time and subsequent redevelopment of the property.6 Additional information regarding the fuel station currently located on this property is provided in Section IV.E.2.b, below.

The property located at 3434 South Grand Avenue was developed as the Redondo Railway Company yard from 1894 until 1922. From 1922 to 1950, the property was developed with two residential units and a paper mache and plaster company on the southeast side of the site. From 1950 to 1966, the property was developed with several industrial/commercial uses including the Beverly Dairies Ice Cream Factory, an art and plaster company, an automotive transmission rebuilding company, a woodworking company, and the Talbery Corporation (a maker of decorative displays). From 1966 to 2007, the site was developed with commercial/warehousing uses before being redeveloped into its current use by USC.7

(3) Subarea 3

Within or near Subarea 3, a total of five properties were identified that exhibit characteristics of interest with regard to the presence of hazards and/or the handling of hazardous materials. The attributes that contribute to this classification for each of the five properties are described separately below.

The Century Apartments and La Sorbonne Apartments property located at 3115 South Orchard Avenue and 1170 West 31st Street, respectively, was used for residential purposes from as early as 1900 to the present. In 1900, the property was developed with single-family residential uses. Several residential uses on this property in 1900 and 1907 included windmills with associated water tanks. By 1922, multi-family residential uses were developed on the property, with the number of these uses continuing to increase over the following decades. As early as 1914, a public garage (Wilson Garage Co.) was present at the southwest corner of the property (1153 West Jefferson Boulevard). This garage was present until as late as 1970. Building permits indicated that a “tankhole” was backfilled in 1969. A gas station was present at the southeast corner of the property (1071 West Jefferson Boulevard) prior to 1935 until as late as 1970. Other commercial properties (stores, salvage warehouse, hotel, used furniture shop) were depicted on the property from as early as 1946 until as late as 1968. A gas and oil station was located to the south, adjacent to the property, from 1950 to 1966. The redevelopment of the property began in 1964, with the development

6 Phase I ESA Report, USC Fuel Station, Portion of 3401 South Grand Avenue, Converse Consultants, September 15, 2009.

7 Phase I ESA Report, 3434 S. Grand Avenue, Winzler & Kelly Consulting Engineers, October 30, 2002.




of an apartment building now known as La Sorbonne. The two apartment buildings and recreation building now known as Century Apartments were built in 1977. Based on this information, the following prior uses of this property are HRECs:

Prior use of the property as a gas station and public garage with a tank due to the potential hazardous materials and subsurface features;

Two sites previously occupied by historical drycleaners, located adjacent to the west boundary of Subarea 3, as such sites often do experience a chemical release that can migrate to adjacent and off-site properties. However, based upon the redevelopment of the west adjacent properties and the property itself as well as depth to groundwater, it appears there is a low potential for environmental concern;8 and

The gas station located to the south, adjacent to the property, from 1950 to 1966. However, due to the redevelopment of this adjacent site, its downgradient location relative to the property, and depth to groundwater, it appears there is a low potential for environmental concern with regard to this property.9

The Cardinal Garden Apartments property located at 3131 McClintock Avenue has been primarily occupied by residential uses starting as early as 1900 until the present. The property was mostly developed with single-family residential dwellings in 1900. At that time, two residential properties were observed with windmills with water tanks. As early as 1907 until as late as 1942, a City of Los Angeles fire station was present on the southern portion of the property. It is unknown if the fire station had any USTs. An Edison Electric substation was also present on the property from 1907 until 1970. By 1922, multi-family residential units were developed on the property and have remained until the present. Property lots which fronted onto West 32nd Street had been redeveloped as commercial properties by 1946, including roofing storage, office space, paint, and storage. The Los Angeles School of Optometry was identified in this commercial area from 1960 to 1970. The property was redeveloped in 1975 as an apartment complex with an associated parking lot. Notable past adjacent uses include gas stations to the south (1922 to 1953) and west (1946 until as late as 1975) of the property. Based on this information, the following prior uses of this property are HRECs:

8 Phase I ESA Report, Century and La Sorbonne Apartments, 3115 South Orchard Avenue & 1170 West 31st Street, Converse Consultants, May 18, 2009.

9 Ibid.




Prior use of the property as an Edison Electric substation. However, it is unlikely that the substation would pose a significant environmental concern since the property has been mass graded and redeveloped;

Prior use of the property as a fire station due to the possible former presence of USTs;

Prior use of the property for roofing storage and ‘paint’ due to the possible presence of hazardous materials associated with these types of businesses; and

Prior gas stations and drycleaners within the vicinity of the property.10

The University Village property consisted of single-family residential uses and land with no mapped use (likely undeveloped or agricultural uses) as early as 1900. Three of these residential properties included windmills with water tanks. The property was occupied heavily by residential dwellings (single- and multi-family) from 1900 to 1970. As early as 1900, the property was horizontally intersected by West 31st Street and West 32nd Street. West 33rd Street and South Hoover Street also crossed the property from 1907 to 1970. Commercial uses were developed on the property as early as 1907 and continued to increase in density over the following decades. The commercial properties were limited to the lots which fronted South Hoover Street/Boulevard (east boundary of the property) and West Jefferson Boulevard (southern boundary of the property). The following are the most notable prior commercial/light industrial uses on this property:

Auto painting shops:

o 3123 South Hoover Street/Boulevard (1922)

o 3315-3317 South Hoover Street/Boulevard (1922)

Auto repair shops:

o 829 West Jefferson Boulevard/3326 South Hoover Street (1954 to 1960)

o 935 West Jefferson Boulevard (as early as 1915 to 1960)

Cabinetry shop:

o 917 West Jefferson Boulevard (1922)

10 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants, May 18, 2009.




Gas and oil stations:

o 3201-3227 South Hoover Street/Boulevard (1950 to 1968) (including auto painting and repair)

o 3301 South Hoover Boulevard (1950 to 1970)

o 3303½ South Hoover Boulevard (expanding later to 3306 South Hoover Street) (1950 to 1970)

Paper warehouse and printer:

o 979-987 West Jefferson Boulevard (1950 to 1970)

Smoke House:

o 905 West Jefferson Boulevard (1955)

By 1946, the reconfiguration of South Hoover Boulevard, which forked to also become South Hoover Street, was noted at the southern end of the property. Construction of Fire Station No. 15 at 915 West Jefferson Boulevard began in 1949. As discussed in detail below, Fire Station No. 15 is a registered UST site with a closed Leaking Underground Storage Tank (LUST) case due to a 1,000 gallon diesel UST that was removed from this property in 1999. As early as 1971, individual lots occupied by residential or commercial buildings were demolished and graded in order to redevelop the property as a retail commercial/shopping plaza, with the exception of Fire Station No. 15. As early as 1972, the property was redeveloped with 10 commercial buildings and associated parking lots. By 1995, an eleventh building was added on the property at the northeast corner.11 Based on this information, the following prior uses of this property are HRECs:

Prior use of the property as a drycleaners, auto painting, auto repair, cabinetry shop, gas stations, paper warehouse/printer, and smoke house due to the possible presence of hazardous materials associated with these types of businesses; and

The former UST located on the property at Fire Station No. 15 and associated LUST case.12

11 Phase I ESA Report, University Village, 821 and 971 West Jefferson Boulevard & 3301 South Hoover Street, Converse Consultants, May 21, 2009.

12 Ibid.




b. Existing Conditions

(1) Hazardous Materials Database Site Listing

As part of the Phase I Reports, Environmental Data Resources (EDR) reports of standard environmental record sources were prepared. The EDR reports involved queries into various local, State, and Federal environmental agency databases to ascertain whether the Project site or any properties within a determined radius are listed due to environmental concerns.

(a) Subarea 1

Within Subarea 1, the University Park Campus was identified as a large quantity generator of hazardous waste, as described in greater detail below under Use, Storage, and Disposal of Hazardous Materials. As no violations from the University Park Campus have been reported, no environmental conditions of concern relative to hazardous materials are anticipated. The University Park Campus was also identified as the site of an accidental release for the spilling of a trace amount of Pyridine, an organic compound that is used as a solvent, on March 30, 1991. According to the site, no waterways were affected and releases into air, land, water, ground, and facility releases did not occur. Thus, due to the type of regulatory listing and the fact that no waterways or soil was impacted, the potential environmental impact from this listing is considered low. In addition, a gas station at 3584 South Figueroa Street was identified as a small quantity generator of hazardous wastes. However, the Phase I ESA Report concludes that the potential for environmental impact from this small quantity generator is low because of the type of regulatory listing and that no violations have been recorded at this location.13

Several locations within Subarea 1 were also identified as UST sites including multiple locations within the University Park Campus. Specifically, based on the EDR database search reviewed by Converse Consultants, 17 registered UST sites have been mapped as being located within the Campus. In addition, based on information from the database search, one property along Vermont Avenue that may be outside the Campus was listed as an “unnamed” LUST site and last reported as “leak being confirmed.” In addition, the property located at 669 West 34th Street within Subarea 1 was indicated as a HAZNET site due to the disposal of asbestos-containing waste to a landfill. Another property at McClintock Avenue and West 34th Street was listed as an EMI site as it was

13 USC Galen Center and Athletic Pavilion Environmental Impact Report, City of Los Angeles, December 2003.




identified as an emissions source in 2006. Finally, 3607 Trousdale Parkway was listed as a NPDES site.

Several adjacent and off-site locations of concern were also identified by the EDR report. However, due to the type of regulatory listings, type of resource (i.e., soil) affected, location of the property with respect to the direction of regional groundwater flow, distance from the Project site, status of the case, remedial efforts being directed by a regulatory agency, and/or identification of potential responsible parties, there appears to be a low potential for environmental concern from these locations.

(b) Subarea 2

Within Subarea 2, neither the USC East Library property nor the four-story office building and USC vehicle (bus) maintenance yard were identified in any of the databases serviced by the EDR Report. The USC fuel station was identified as a hazardous waste generator. However, only one event of hazardous waste disposal was reported.14 The USC building at 3434 Grand Avenue, which was previously a garment manufacturing and warehouse facility, is listed as an active facility with stormwater and having disposed of asbestos-containing waste to a landfill. However, due to the type of regulatory listing and given that the site has been recently renovated, there appears to be a low potential for environmental concern at this location.15

The property within Subarea 2 at 3447 South Grand Avenue is listed for a spill or complaint that was reported as abated on January 29, 199116; a prior and active UST site; an emission source of toxic and criteria pollutants in 1987; and disposing hazardous waste to a recycler. This property’s listing as a prior and active UST site is considered a REC.17

Also within Subarea 2 is a property located at 400 West Exposition Boulevard that is listed for an acid spill on February 26, 2006. However, due to the involvement of a regulatory agency in remedial efforts, there appears to be a low potential for environmental concern at this location.18 The property located at 3600 South Hope Street is listed as auto


15 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009. 16 Phase I ESA Report, 3440 South Hope Street, Converse Consultants, June 9, 2009. 17 Phase I ESA Report, USC Fuel Station, Portion of 3401 South Grand Avenue, Converse Consultants,

September 15, 2009. 18 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009.




station due to its use as an automobile repair shop in 1937 and 1942. As discussed above, due to the type of regulatory listing, this property is considered a HREC.19

In addition, the following adjacent site was also listed in the EDR Report:

USC, 3600 South Grand Avenue – This property is located off-site to the south, adjacent to Subarea 2, and is listed as a prior and active UST site. As such, this site is identified as a REC.20

Several additional adjacent and off-site locations of concern were also identified by the EDR report within a one mile radius of the Project site. However, due to the type of regulatory listings, type of resource (i.e., soil) affected, location of the property with respect to the direction of regional groundwater flow, distance from the Project site, status of the case, remedial efforts being directed by a regulatory agency, and/or identification of potential responsible parties, there appears to be a low potential for environmental concern from these locations.

(c) Subarea 3

Within Subarea 3, the Cardinal Apartments, the Century and La Sorbonne Apartments properties were not identified in any of the databases reviewed as part of the EDR Report.21,22 The University Village Property was identified in the environmental databases of the EDR Report for the following locations:

Kivett Birdest (Kivett Henry), 3301 South Hoover Street – a prior gas and oil service station;

Cravens Schillinger, 3221 South Hoover Street – a prior gas and oil service station;

Crossroads Cleaners, 3131 Hoover Street – a small quantity generator of hazardous waste;

19 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009. 20 Phase I ESA Report, USC Fuel Station, Portion of 3401 South Grand Avenue, Converse Consultants,

September 15, 2009. 21 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants,

May 18, 2009. 22 Phase I ESA Report, Century and La Sorbonne Apartments, 3115 South Orchard Avenue & 1170 West

31st Street, Converse Consultants, May 18, 2009.




Vecchione Felix, 3118 South Hoover Street – a prior adjacent dry cleaner. As drycleaner sites often do experience a chemical release which migrates to adjacent and off-site properties, this adjacent use is a HREC;23

Fotomat Corp L5800, 3165 Hoover Street – a small quantity generator of hazardous waste with no reported violations; and

Los Angeles Fire Station No. 15, 915 West Jefferson Boulevard – a small quantity generator of hazardous waste and a registered active UST site.

Based on a review of records for Fire Station No. 15, there is a closed LUST case. The case involved the removal of a 1,000 gallon diesel fuel steel tank which was installed in 1950. Reports indicate that the UST was removed from September 30, 1999 through November 11, 1999; and a no further action letter dated August 16, 2000 was issued by the LAFD. A follow-up Phase II Environmental Site Investigation was prepared in July 2002 and involved soil borings and laboratory testing to address the residual hydrocarbons found beneath the fuel dispenser during the UST removal. The Phase II concluded that no future investigation was warranted for the site.

In addition to these adjacent properties, other adjacent and off-site locations of concern were also identified by the EDR report within a one mile radius of the Project site. However, due to the type of regulatory listings, type of resource (i.e., soil) affected, location of the property with respect to the direction of regional groundwater flow, distance from the Project site, status of the case, remedial efforts being directed by a regulatory agency, and/or identification of potential responsible parties, there appears to be a low potential for environmental concern.24

(2) Use, Storage, and Disposal of Hazardous Materials

(a) Subarea 1

The majority of Subarea 1 constitutes the generally recognized core Campus area. Subarea 1 also includes a small portion located south of Exposition Boulevard and east of Figueroa Boulevard. The University currently uses, stores, and disposes of a variety of


24 Ibid.




hazardous materials for research, teaching, and medical treatment purposes on the Campus. These hazardous materials include, but are not limited to:

Solvents, acids, and other chemical solutions which may be toxic, flammable, reactive, or corrosive chemicals;

Biohazardous materials (i.e., infectious agents);

Carcinogens for medical research;

Radioactive materials and wastes;

Compressed gases; and

Mercury and other heavy metals.

In addition, various other hazardous materials are used in Campus maintenance and construction activities such as grounds keeping, building maintenance, utility improvements, and vehicle maintenance. These hazardous materials include:

Cleaning solvents, disinfectants, degreasers, and bleach;

Paints and paint thinners;

Building finishers and polishes;

Adhesives and sealers;

Fuel, oil, and lubricants for vehicles and equipment; and

Pesticides and herbicides.

All hazardous materials on the Campus are used, stored, and disposed of in accordance with applicable regulations. Furthermore, as further discussed below, many of the hazardous materials are strictly regulated by the USC Department of Environmental Health and Safety. The University requires that all hazardous materials are inventoried. Additionally, those working with hazardous materials are required to undertake proper precautions and protective measures, including training and use of protective clothing (e.g., laboratory coats, gloves, and safety goggles).

(b) Subarea 2

Subarea 2 includes ancillary University support uses including administrative office uses, warehouse and storage, and library uses. In addition, Subarea 2 includes a USC parking structure as well as a maintenance yard with a fuel station for USC tram/bus




vehicles. In Subarea 2, hazardous materials are used, stored, and/or disposed of for operation, grounds keeping, building maintenance, utility improvements, and vehicle maintenance.

During the site reconnaissance for the East Library property at 3440 South Hope Street, hazardous materials observed on the property included cleaning solvents and film strips. In addition, oil stains were observed on and around equipment for two hydraulic-powered elevators located on the roof. The use of these hydraulic powered elevators with observed oil staining is a REC.25

Three 20,000 gallon USTs are currently located within the USC fuel station at 3401 South Grand Avenue. These USTs contain unleaded (87 and 91) gasoline and biodiesel fuel and are connected to a Veeder Root Monitoring System that is inspected annually. While conducting site reconnaissance for the property, hazardous materials observed on-site included cleaning supplies, gas storage containers, a 55 gallon metal drum of wastewater pumped from the UST’s overflow area, and a 55 gallon poly drum of sand and spill kit equipment. Light oil stains were also observed throughout the property on concrete pavement and are likely due to routine vehicle parking during fueling. The property’s current use as a fuel station is a REC.26

During the site reconnaissance for the USC tram/vehicle maintenance yard property at 3500 South Hope Street, the following hazardous materials were observed:27

Two aboveground storage tanks (ASTs) of motor oil (120 gallons) and automatic transmission fluid (75 gallons);

Two ASTs storing used antifreeze (110 gallons) and used oil (130-140 gallons);

Two 55 gallon metal drums of power steering fluid;

Two 55 gallon metal drums of automatic transmission fluid;

Two 55 gallon drums of used oil and coolant;

One 25 gallon drum containing chassis grease;

Four 55 gallon metal drums of coolant/antifreeze;

25 Phase I ESA Report, 3440 South Hope Street, Converse Consultants, June 9, 2009. 26 Phase I ESA Report, USC Fuel Station, Portion of 3401 South Grand Avenue, Converse Consultants,

September 15, 2009. 27 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009.




Liquid propane gas (LPG) tank (2,000 gallon);

Used rags;

Car batteries;

Aerosol cans of enamel, starting fluid, brake finishing treatment, break parts cleaner, and windshield washing fluid; and

Containers of lubricant, petroleum pump oil, and hydraulic jack oil.

In addition, oil staining was observed on and around equipment for the office building’s hydraulic-powered elevator, the vehicle maintenance building near the AST storage area, and the asphalt-paved portion of the lot used for vehicle parking. The use, storage, and generation of hazardous substances and petroleum products, the use of hydraulic powered equipment, and the property’s current use as a vehicle maintenance yard are RECs.28

Other properties within Subarea 2 (e.g., parking garage, the building at 3434 Grand Avenue) may also utilize additional hazardous such as fuel/oil, cleaning solvents, pesticides for landscaping, toners and printing chemicals.

(c) Subarea 3

Subarea 3 includes the Cardinal Garden Apartments, Century Apartments and La Sorbonne Apartments, and the University Village. Hazardous materials used, stored, and/or disposed of in Subarea 3 are typical of those found in most residential and commercial uses. Efforts to standardize cleaning materials for all off-Campus maintenance are currently ongoing.29

During the site reconnaissance for the Cardinal Garden Apartments property, commercial quantities of cleaning products and maintenance equipment were located in a storage shed on-site.30 In addition, individual residential units are likely to store and use common household cleaning products.

28 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009. 29 Phase I ESA Report, Century and La Sorbonne Apartments, 3115 South Orchard Avenue & 1170 West

31st Street, Converse Consultants, May 18, 2009. 30 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants,

May 18, 2009.




During the site reconnaissance for the Century Apartments and La Sorbonne Apartments property, observations included 5 gallon containers of latex paint and containers of paint stripper, degreaser, bleach, disinfectant, glass cleaner, and other cleaning products in varying quantities in several of the storage rooms at the Century Apartments.31 Additionally, individual residential units are likely to store and use common household cleaning products.

With regard to the University Village property, the site reconnaissance found the use, storage, and/or disposal of the following hazardous materials:32

Spray paint, WD-40, and wax at a bicycle shop;

Jet black leather dye at a shoe store;

Water-based dyes and CR-39 Nu-Trailzer at an optometry office;

Acetones brought in as needed at a nail salon;

Toner at a graphics shop;

Medical waste and gypsum from the USC School of Dentistry;

Photo-developing chemicals at a photo shop;

Hair dyes, styling products, etc at a hair salon;

Retail detergent, cleansers, disinfectant, bleach and other cleaning supplies at the grocery store. Also, utilized at the property are a hydraulic powered lift and dry-type transformer. Three stage grease traps were also observed;

Bleach, cleansers, floor finish, glass cleaner, disinfectant, polish at a janitorial store;

One metal 55-gallon drum of kerosene, one metal 55 gallon drum of waste oil, and one 55 gallon drum for solvents within secondary containment at Fire Station No. 15; and






Grease bins of approximately 100-gallons at fast-food restaurants and University Village food court.

The current use, storage, and disposal of these various hazardous materials are a REC. However, no indications of leaking or staining from these substances was observed on the property.33

(3) Underground Storage Tanks

(a) Subarea 1

As discussed above, several locations within Subarea 1 were identified as UST sites including multiple locations within the University Park Campus. One LUST site was also mapped as being located within the Campus; however, based on the database search this site may be located off-site or adjacent to the Campus.

Several USTs formally located beneath Subarea 1 east of Figueroa Street and north of Exposition Boulevard were removed in 1973, 1988, and 1989. LAFD files noted that these tanks showed no visible signs of leakage and appeared to be in good condition. In addition, soil samples collected from these excavations demonstrate that no contaminants above acceptable regulatory limits were detected in any of the samples.34

(b) Subarea 2

No information regarding USC’s East Library or the four-story office building and USC vehicle (bus) maintenance yard was on file with the Los Angeles Regional Water Quality Control Board (RWQCB) UST or Site Clean-Up Unit.35,36 In addition, the City of Los Angeles Fire Prevention Department UST Division indicates that there are no USTs on the property at 3434 Grand Avenue, and no USTs were observed on-site.37


34 USC Galen Center and Athletic Pavilion Environmental Impact Report, City of Los Angeles, December 2003. 35 Phase I ESA Report, 3440 South Hope Street, Converse Consultants, June 9, 2009. 36 Phase I ESA Report, 3500 South Hope Street, Converse Consultants, June 9, 2009. 37 Draft Phase I ESA Report, 3434 S. Grand Avenue, Winzler & Kelly Consulting Engineers, October 30, 2002.




It is likely that a UST was located on the USC fuel station property when it was developed as a loading dock for a May Company department warehouse store. While installation, excavation, and demolition activities associated with the development of the existing USC fuel station in 2001 may have resulted in the removal of this UST, it is still considered a REC.38

Three 20,000 gallon USTs are currently located within the USC fuel station property. These USTs contain unleaded (87 and 91) gasoline and biodiesel fuel and are connected to a Veeder Root Monitoring System that is inspected annually. According to property personnel, no significant oil spills or leaks have occurred at this property. In addition, the most recent Designated UST Operator Monthly Visual Inspection Checklist performed on July 1, 2009, indicated that the UST system was free from water, debris, and hazardous substances; sensors were properly located; and both paperwork and facility employee training was complete and up-to-date.39

(c) Subarea 3

No information regarding the Century Apartments or the La Sorbonne Apartments was on file with the Los Angeles RWQCB UST Unit.40

The Cardinal Garden Apartments property was previously developed as a LAFD fire station from as early as 1907 until as late as 1942. It is unknown if USTs ever existed at this property while it was a fire station. The possible former presence of USTs on this property is a HREC.41

As previously described, an EDR report identified Fire Station No. 15 within the University Village property as a registered UST site with a closed LUST case due to a 1,000 gallon diesel UST that was removed from this property in 1999. A no further action letter dated August 16, 2000 was issued by the LAFD. In addition, a follow-up Phase II Environmental Site Investigation prepared in July 2002 concluded that no future investigation


39 Ibid. 40 Phase I ESA Report, Century and La Sorbonne Apartments, 3115 South Orchard Avenue & 1170 West 31st

Street, Converse Consultants, May 18, 2009. 41 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants,

May 18, 2009.




was warranted for the site. Nonetheless, the former UST located on the property at Fire Station No. 15 is a REC.42

(4) Asbestos Containing Materials

Asbestos is a naturally occurring mineral made up of microscopic fibers. Asbestos has unique qualities which include its strength, fire resistance, resistance to chemical corrosion, poor conduction of heat, noise, and electricity, and low cost. Asbestos was widely used in the building industry starting in the late 1800s and up until the late 1970s for a variety of uses, including acoustic and thermal insulation and fireproofing, and is often found in ceiling and floor tiles, linoleum, pipes, structural beams, and asphalt. Despite its useful qualities, asbestos becomes a hazard if the fibers separate and become airborne. Inhalation of airborne asbestos fibers could cause lung diseases. Any building, structure, surface asphalt driveway, or parking lot constructed prior to 1979 could contain asbestos or asbestos containing materials (ACM).

Testing for asbestos was not conducted as part of the Phase I reports for the Project site. However, as described above, asbestos was widely utilized in the building industry prior to 1979 for a variety of uses, including acoustic and thermal insulation and fireproofing. While some buildings, such as building at 3434 Grand Avenue and the Galen Athletic Center, have been renovated or newly constructed in recent years, given the age of many existing buildings on-site, it is likely that asbestos is present in some of the building materials.

(5) Lead-Based Paint

Lead is a naturally occurring element and heavy metal that was widely used as a major ingredient in most interior and exterior oil-based paints prior to 1950. Lead compounds continued to be used as corrosion inhibitors, pigments, and drying agents from the early 1950s to 1972, when the Consumer Products Safety Commission specified limits on lead content in such products. While adults can be affected by excessive exposure to lead, the primary concern is the adverse health effects on children. The most common paths of lead exposure in humans are through ingestion and inhalation. Lead-based paint is of concern both as a source of exposure and as a major contributor to lead in interior dust and exterior soil.





Testing for lead-based paint was not conducted as part of the Phase I reports for the Project site. However, as described above, lead compounds were widely utilized in the building industry prior to 1972 for a variety of uses. While some buildings, such as the building at 3434 Grand Avenue and the Galen Athletic Center, have been renovated or newly constructed in recent years, given the age of many existing buildings on-site, it is likely that lead-based paint is present in some of the building materials.

(6) Oil and Gas

Methane is a colorless, odorless natural gas. Although methane is not toxic, it is highly combustible and potentially explosive at concentrations above 55,000 parts per million (ppm) in the presence of oxygen. Methane typically can be found at oil fields, oil wells, and landfills. Methane has the potential to migrate into buildings through physical pathways that include cracks in concrete floor slabs, unsealed conduits or utility trenches, unsealed dewatering sumps, and other small openings common in building construction. Methane gas can also reach the surface through natural geologic features which may facilitate vertical, lateral, or oblique migration. The geologic features that can serve as potential pathways include porous and permeable formations, fault zones, and aquifers. The accumulation of methane below the ground due to pavement and structures can result in elevated concentrations, creating an explosion risk. The City of Los Angeles has established methane zones, which indicate a high risk for methane exposure, and methane buffer zones, which indicate a lower risk for methane exposure. As discussed further below, new developments occurring in a methane zone or methane buffer zone are subject to requirements for methane testing and mitigation.

Portions of the Project site are located in a methane zone or a methane buffer zone as shown in Appendix F. Previous methane gas investigations have been conducted on the Project site as part of past development projects. A total of 79 methane gas probes were installed on the USC Campus as part of previous investigations. Laboratory results of all 79 gas probes indicated methane concentrations below detection limits.43

As part of a recent methane gas investigation for Subareas 1 and 3 of the Project site, a total of 82 additional subsurface gas probes were taken in August 2008. Methane gas was detected in seven of the 82 gas probes. Of the seven, five are located in Subarea 3 (four to the east of McClintock Street on the University Village property and one to the west on the Cardinal Gardens Apartments property) and two are located in

43 USC Campus Wide Methane Gas Investigation, GeoKinetics, August 20, 2009. (Available in Appendix F of this Draft EIR)




Subarea 1 on the USC University Park Campus. A gas probe in Subarea 1 and a gas probe in Subarea 3 showed extremely high methane concentrations of 990,000 ppm and 980,000 ppm, respectively. These concentrations are anomalous as elevated levels of methane were not detected in other probes in the vicinity. Upon further investigation, it was determined that these unusually high concentrations of methane were due to gas leaks from utility lines. After these gas leaks were repaired, methane concentrations decreased at all locations below the explosive level from 990,000 ppm to non-detectable levels in the Subarea 1 probe and from 980,000 ppm to 2,000 ppm and 16,000 ppm to 5,000 ppm in two Subarea 3 probes. After accounting for the elevated methane readings caused by the now repaired gas line leaks, detectable levels of what may be naturally occurring methane were found in two of the 161 gas probes that have been installed and monitored, but both below the explosive level.44 The Project site’s location within a methane zone is a REC.45,46,47

The University Village, Cardinal Gardens Apartments, La Sorbonne Apartments, and Century Apartments properties are located within the Las Cienegas Oil Field. Three oil wells were identified within the University Village property. The wells were denoted as dry and between 3,700 and 4,800 feet bgs. The oil wells were plugged and abandoned between 1963 and 1966.48 Another oil well was identified within the southwestern corner of the Cardinal Gardens property. This well was drilled to a total depth of 4,829 feet bgs. A well abandonment report was filed for this well on December 16, 1963 and was cement plugged at a reported depth of 490 feet. As this was not a producing well, it is not considered a REC. However, it may need to be re-abandoned according to present day Division of Oil, Gas, and Geothermal Resources (DOGGR) guidelines.49

44 USC Campus Wide Methane Gas Investigation, GeoKinetics, August 20, 2009. (Available in Appendix F of this Draft EIR)


46 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants, May 18, 2009.


48 Ibid. 49 Phase I ESA Report, Cardinal Garden Apartments, 3131 McClintock Avenue, Converse Consultants,

May 18, 2009.




c. Regulatory Framework

(1) 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.

(a) Federal

The Federal Resource Conservation and Recovery Act (RCRA) (Title 40 of the Code of Federal Regulations [CFR], Parts 238 – 282) 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 EPA has delegated RCRA enforcement to the State of California.

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 Federal Regulations (CFR) Section 1910, et. seq., 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.

Title 49 of the CFR specifies additional requirements and regulations with respect to the transport of hazardous materials.50 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,

50 Title 49 of the CFR contains the regulations set forth by the Hazardous Materials Transportation Act of 1975.




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.

(b) 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 USTs is regulated by Cal EPA’s State Water Resources Control Board (SWRCB), which has delegated authority to the RWQCB and typically on the local level, to the local fire department.

The California OSHA program (Cal-OSHA; codified in the California Code of Regulations, Title 8, or 8 CCR generally and in the Labor Code secs. 6300-6719) 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 (Health and Safety Code Sections 25244.12-25244.24) requires 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 (Title 13 of the CCR) 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.

The transport of hazardous waste materials (including medical wastes) is further governed by the California Health and Safety Code (Section 25163) and Title 22, Chapter 13, of the CCR. Specifically, Section 25163 of the Health and Safety Code requires transporters of hazardous waste to hold a valid registration issued by the DTSC in his/her possession while transporting hazardous waste. Additionally, Title 22, Chapter 13 of the CCR includes a number of requirements, which include but are not limited to the following:

Transporters shall not transport hazardous waste without first receiving an identification number and a registration certificate from DTSC.

Registration as a hazardous waste transporter expires annually, on the last day of the month in which the registration was issued.

To be registered as a hazardous waste transporter, an application must be submitted.

Hazardous waste shall not be accepted for transport without a Uniform Hazardous Waste Manifest that has been properly completed and signed by generator and transporter.

Hazardous waste shall be delivered to authorized facilities only.

The management of medical wastes is further governed by regulations of the Medical Waste Management Act (California Health and Safety Code Sections 117600 – 118360). 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.

(c) Local

At the local level, the Los Angeles Fire Department (LAFD) monitors the storage of hazardous materials in the City for compliance with local requirements. Specifically, businesses and facilities which store more than threshold quantities of hazardous materials as defined in Chapter 6.95 of the California Health and Safety Code are required to file an Accidental Risk Prevention Program with the LAFD. This program includes information such as emergency contacts, phone numbers, facility information, chemical inventory, and




hazardous materials handling and storage locations. The LAFD also has delegated authority to administer and enforce Federal and State laws and local ordinances for USTs. Plans for the construction/installation, modification, upgrade, and removal of USTs are reviewed by LAFD Inspectors.


USTs are regulated under Subtitle I of RCRA and its implementing regulations (40 CFR 280), which establish construction standards for new UST installations (those installed after December 22, 1988), as well as standards for upgrading existing USTs and associated piping. After 1998, all non-conforming tanks were required to be either upgraded or closed.

The State regulates USTs pursuant to Health and Safety Code, Division 20, Chapter 6.7, and CCR Title 23, Division 3, Chapter 16 and Chapter 18. The State’s UST program regulations include, among others, permitting USTs, installation of leak detection systems and/or monitoring of USTs for leakage, UST closure requirements, release reporting/corrective action, and enforcement. Oversight of the statewide UST program is assigned to the SWRCB (23 CCR sec. 2610 et seq.), which has delegated authority to the RWQCB and typically on the local level, to the fire department. The LAFD administers and enforces Federal and State laws and local ordinances for USTs at the Project site. Plans for the construction/installation, modification, upgrade, and removal of USTs are reviewed by LAFD Inspectors.


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) (40 CFR 763). These regulations include the phase out of friable asbestos and ACM in new construction materials beginning in 1979. 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) (40 CFR 61 Part M) that govern the use, removal, and disposal of ACM as a hazardous air pollutant. The NESHAP regulations mandate the removal of friable ACM before a building is demolished and includes notification requirements prior to demolition. Responsibility for implementing these requirements has been delegated to the State of California, which in turn has delegated the responsibility to the South Coast Air Quality Management District (SCAQMD).




California classifies ACM as hazardous waste if it is friable and contains one percent or more asbestos (CCR, Title 22, Section 66261.24). Non-friable bulk asbestos-containing waste is considered non-hazardous regardless of its asbestos content and is not subject to regulation under CCR, Title 22. The Cal-EPA Department of Toxic Substances Control (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.

In addition, the Federal and State OSHA programs regulate asbestos as it relates to employee safety. The Federal OSHA Worker Exposure Rule for Asbestos (29 CFR 1910.1001 and 1926.1101) requires certain actions on the part of any employer whose employees are potentially exposed to asbestos fiber levels above the permissible exposure limit (0.2 fibers per cubic centimeter of air [f/cc], averaged over an 8-hour day). Under Cal-OSHA, if employees are exposed to a time-weighted average of 0.1 f/cc over an 8-hour period, employers must begin compliance activities such as notification, employee training, air monitoring and, in some cases, medical surveillance. In addition to these regulations, contractors involved in asbestos surveys and removal are required to be certified by Cal-OSHA. As well, the California Connelly Act (AB 3713; Health and Safety Code sec. 25915 et seq.) establishes notification requirements for all owners and employees working within any pre-1979 building known to contain ACM. The notification requirements of the Connelly Act are enforced by Cal-OSHA.


While adults can be affected by excessive exposure to lead, the primary concern is the adverse health effects on children. If not detected early, children with high levels of lead can suffer from damage to the brain and nervous system; behavior and learning problems such as hyperactivity, slowed growth, hearing problems; and headaches. Adults can suffer from lead-related effects such as reproductive problems (in both men and




women), high blood pressure and hypertension, nerve disorders, memory and concentration problems, and muscle and joint pain.

The demolition of buildings containing LBPs is subject to a comprehensive set of California regulatory requirements that are designed to assure the safe handling and disposal of these materials. Cal-OSHA has established limits of exposure to lead contained in dusts and fumes through CCR, Title 8, Section 1532.1, which provides for exposure limits, exposure monitoring, and respiratory protection, and mandates good working practices by workers exposed to lead, particularly since demolition workers are at greatest risk of adverse health exposure. Lead-contaminated debris and other wastes must also be managed and disposed of in accordance with applicable provisions of the California Health and Safety Code.

(5) Oil and Gas

Chapter IX, Article 1, Division 71, Section 91.7103 of the Los Angeles Municipal Code (LAMC), also known as the Los Angeles Methane Seepage Regulations, sets forth minimum requirements to control methane for buildings and paved areas that are located in a City-designated methane zone or a methane buffer zone. Requirements for new construction within such zones may include site testing for methane gas, installing a barrier (i.e., a membrane shield) between the building and underlying earth, installing a vent system(s) beneath the barrier and/or within the building, and installing a gas (methane) detection system. As discussed above, portions of the Project site are located in a methane zone and methane buffer zone.

Worker exposure to methane is regulated by OSHA under 29 CFR §1910.146. This section regulates worker exposure to a “hazardous atmosphere” within confined spaces where the presence of flammable gas vapor or mist is in excess of 10 percent of the lower explosive limit. Cal-OSHA regulates worker exposure to airborne contaminants (such as hydrogen sulfide) during construction under Title 8, Section 5155, Airborne Contaminants, which establishes which compounds are considered a health risk, the exposure limits associated with such compounds, protective equipment, workplace monitoring, and medical surveillance required for compliance.

Section 3200, et seq., of the Public Resources Code regulates the permitting, establishment, completion, and abandonment/re-abandonment of gas and oil wells. DOGGR is the state agency with primary responsibility for the enforcement of these regulations. DOGGR is also the state agency responsible for conducting construction site plan review for development proposed in proximity to gas or oil wells. In the event wells or casings are found during excavation and grading activities, proper abandonment may be required by DOGGR under CCR Title 14.




(6) USC Department of Environmental Health and Safety

The USC Department of Environmental Health and Safety (EH&S) is responsible for developing and implementing environmental health and safety programs for the University. Programs under the auspices of EH&S that relate to hazardous materials address chemical safety, biological safety, radiation safety, laser safety, and industrial hygiene. These programs are described in greater detail as follows:

(a) Chemical Safety

To address chemical safety at USC’s facilities, USC has prepared a Chemical Hygiene Plan. The purpose of the Chemical Hygiene Plan is to provide procedural guidelines for prudent work practices in the handling, storage, and use of chemicals in the laboratory and to protect laboratory workers from the potential health hazards of the chemicals they encounter in the workplace.51 The plan applies to all employees and volunteers who routinely handle hazardous chemicals in USC-owned laboratories. An on-line Chemical Inventory Program is also in place at USC’s facilities. All USC researchers and staff who use and store hazardous materials must keep an inventory of hazardous materials (excluding inert compressed gas cylinders). Researchers are assigned an on-line chemical inventory account and are required to update the account annually or when substantial changes in chemical volume or type occur.52 USC also has a Chemical Waste Management Manual, which sets forth University guidelines concerning the management and disposal of chemical hazardous waste (excluding biological/medical wastes and radioactive wastes that are addressed separately below) at University facilities.53 The Chemical Waste Management Manual includes employee and safety training guidelines, hazardous waste disposal procedures, sewer disposal guidelines, and guidelines for wastes requiring special processing. The EH&S also publishes chemical-specific safety guidelines that address Acrylamide, Ethidium Bromide, Sodium Azide, Bromo-Deoxyuridine, Hydrofluoric Acid, and Sodium Cyanide.54 Carcinogens are also addressed by the USC Carcinogen Program. The purpose of the Carcinogen Program is to minimize exposure of University personnel to carcinogens, and to meet regulatory requirements

51 University of Southern California, Department of Environmental Health & Safety, Chemical Hygiene Plan, http://capsnet.usc.edu/LabSafety/ChemicalSafety/ChemicalHygienePlan.cfm; accessed June 8, 2009.

52 University of Southern California, Department of Environmental Health & Safety; Chemical Inventory Program; http://capsnet.usc.edu/EHS/documents/ChemicalInventoryProgram.pdf; accessed June 8, 2009.

53 University of Southern California; Chemical Waste Management Manual 4/15/2005; http://capsnet.usc.edu/LabSafety/documents/HWMANUAL_NEW.pdf; accessed June 8, 2009

54 University of Southern California, Department of Environmental Health & Safety; http://capsnet.usc.edu/LabSafety/index.cfm; accessed June 8, 2009.




regarding carcinogens. The Carcinogen Program includes carcinogen safety guidelines, which are applicable to all University employees and students whose responsibilities expose them to USC-regulated carcinogens.

Lastly, USC’s Hazardous Materials Management Program (HMMP) is designed to minimize safety and health hazards in work areas associated with hazardous materials and to comply with regulatory requirements. The HMMP applies to all University faculty, staff, students, visiting scholars, and volunteers whose research, processes, preparations, etc., involve the use and handling of hazardous materials. The HMMP includes chemical safety procedures, biological safety procedures, standard operating procedures, ancillary components (e.g., employee training, employee communication, etc), hazardous waste management procedures, and emergency preparedness and response guidelines.55

Additionally, USC reduces environmental impacts associated with hazardous wastes through the following:

Waste Minimization:

o Used batteries (e.g. lead acid, alkaline, NiCad, etc.) are collected and shipped to a battery recycler. Lead acid and NiCad batteries are recycled; the others are disposed of properly.

o Elemental mercury is collected and recycled through a contractor.

o EH&S supplies safety cans to collect flammable/combustible solvents and halogenated solvents.

o Chemicals that are (a) in their original containers, (b) in good condition, and (c) have not exceeded their expiration date may be recycled through the Chemical Exchange Program. Members of the research community interested in obtaining or donating chemicals may contact EH&S.

Recycling:

o Decommissioned refrigerators are picked up to recycle the Freon from compressors. Refrigerators that were used to store biological materials, chemicals, or radioisotopes must be decontaminated prior to release to pickup.

55 University of Southern California, Department of Environmental Health & Safety; Hazardous Materials Management Program; http://capsnet.usc.edu/LabSafety/ChemicalSafety/HMMP.cfm; accessed June 8, 2009.




o Photographic waste is funneled through a contractor specialized in silver recovery.

o Fluorescent light bulbs (intact and broken) are collected and sent to a recycler. Intact tubes are refitted with new electrodes and a primer gas. Broken tubes are ground down and recycled.

o Retired electronic components (computer monitors, CPUs, printers, etc.) that are still functional are recycled and picked up by the University. Expired components are shipped to a recycler where they are broken down for re-use.

Other:

o Elemental mercury use is highly discouraged unless unavoidable. Digital- and ethanol-based thermometers are suitable, arguably better alternatives to mercury.

(b) Biological Safety

The USC Biosafety Program aims to minimize health risks to employees, students, the public and the environment from potential exposure to biohazardous materials used in research and teaching activities. Biohazardous materials include infectious organisms that can cause disease in humans, or significant environmental or agricultural impact. As part of the Biosafety Program, the University has prepared standard operating procedures for shipping biological material, biological safety cabinets, and biohazard waste disposal. In addition, the Bloodborne Pathogens Program includes bloodborne pathogen training, the USC Exposure Control Plan, the Bloodborne Pathogens Exposure Procedure, Sharps Injury Form, and Hepatitis B Vaccination Program.

The Select Agent Program addresses the use, storage and purchase of organisms listed as Select Agents and High Consequence Livestock Pathogens and Toxins, which are strictly regulated by the United States Department of Health and Human Services and the United States Department of Agriculture. These organisms include bacteria, viruses, toxins, rickettsia and fungi that pose a potential threat to public health or welfare. Approval from the USC Institutional Biosafety Committee is required prior to receipt or use of any Select Agent above an exempt quantity at USC facilities. The Institutional Biosafety Committee approval process includes registration with the Centers for Disease Control and Prevention and/or the Animal and Plant Health Inspection Service. All Select Agents,




including those below the exempt quantity, must be included in the USC Chemical Inventory.56

The Precursor Chemicals Program sets forth regulations for USC researchers who acquire precursor chemicals that are regulated by the Federal Drug Enforcement Administration and California Department of Justice. Researchers are bound by both state law and USC institutional requirements in the management of the precursor chemicals.57

(c) Radiation Safety

USC's Radiation Safety Program operates under a Radioactive Materials License issued by the State of California Radiologic Health Branch. The Radiation Safety Program is designed to ensure compliance with applicable regulations and maintain worker radiation exposures As Low As Reasonably Achievable. As required by regulations and the Radiation Safety Program, University faculty and personnel that would like to work with radioactive material or radiation producing equipment/devices must first obtain a Radioactive Material Use Permit and undergo radiation safety training. In addition, the Radiation Safety Manual describes worker rights and responsibilities along with the University rules for handling radiation sources properly.

(d) Lead Management

The USC Lead Paint Management Program is intended to provide an effective plan to manage and control exposure to lead-based paint throughout the University. Under the Lead Paint Management Program, all maintenance, construction, demolition and renovation activities on University property must be performed in accordance with all applicable lead regulations and with the procedures set forth in the program. The program includes procedures for lead paint maintenance, lead abatement, and pre-abatement.58

56 University of Southern California, Department of Environmental Health & Safety; Select Agent Program; http://capsnet.usc.edu/LabSafety/BioSafety/SelectAgentProgram/index.cfm; accessed June 8, 2009.

57 University of Southern California, Department of Environmental Health & Safety; Precursor Chemicals Program; http://capsnet.usc.edu/EHS/documents/Precursor%20Chemicals%20Program%20-%20(1-9-2008).pdf; accessed June 8, 2009.

58 University of Southern California, Department of Environmental Health & Safety; Lead Management Program 8/18/2004; http://capsnet.usc.edu/EHS/IndustrialHygine/LeadManagement/documents/ LeadPaintManagementProgram.pdf; accessed June 8, 2009.




(e) Asbestos Management

The USC Asbestos Management Program is intended to minimize exposure to airborne asbestos fibers, and provide an effective plan to manage and control known and assumed asbestos containing materials throughout the University. Under the Asbestos Management Program, all maintenance, construction, demolition and renovation activities on University property must be performed in accordance with all applicable asbestos regulations and with the procedures set forth in the program. The program includes procedures for asbestos maintenance, asbestos abatement, and pre-abatement.59

(f) Laser Safety

The USC Laser Safety Program requires that laser users at the University be registered and laser usage logged. The Laser Safety Manual provides guidelines and information about the Laser Safety Program at the University and is designed to ensure the safety of all faculty, staff, students and visitors.60 Laser users must adhere to OSHA and Cal-OSHA regulations that address laser safety.

(g) Emergency Access and Preparedness

The USC Office of Fire Safety & Emergency Planning (FSEP) works closely with the Los Angeles Fire Department (LAFD) to ensure that the Campus is adequately prepared for emergencies.

Specifically, the FSEP continuously maintain lanes of emergency access to all buildings and police them to ensure they are not blocked. On those occasions when blocking a fire lane is unavoidable due to a construction project, the FSEP provides maps of alternate routes to the LAFD.

In addition, with regard to building evacuation plans, the FSEP work with the occupants of every building to educate them on the evacuation plan for their building. The FSEP establish and train a building emergency team in each building, equipped with identifiable emergency vests, to act as floor wardens and evacuation coordinators. Emergency procedures are also posted for each building on the office website so that

59 University of Southern California, Department of Environmental Health & Safety; Asbestos Management Program 3/23/2007; http://capsnet.usc.edu/EHS/IndustrialHygiene/documents/AsbestosManagement Program03232007.pdf; accessed June 9, 2009.

60 University of Southern California, Department of Environmental Health & Safety; Laser Safety Manual; http://capsnet.usc.edu/LabSafety/LaserSafety/LaserSafetyProtocol.cfm; accessed June 9, 2009.




building occupants may access the plans for their building. In addition, special programs are conducted for high-rise and for residential buildings, involving extensive training and evacuation drills. Additionally, USC's Crisis Management Team (which is convened by the senior vice president for administration and includes representatives from the offices of the provost, emergency planning, public safety, student affairs, public relations, information technology services, auxiliary services and facilities management as well as the campus research community and other relevant units) meets every two months to review and update policies and plans related to emergency notification, response, resources and recovery.

The USC Emergency Operations Plan has been developed for use in any major emergency situation affecting a broad area of the University. As stated in the plan, in the event of a major emergency, the Emergency Policy Group (consisting of the University president, the provost, senior vice presidents and other University officers) provides the overall direction for policy and communications. The Emergency Operations Group, including the offices of career and protective services, facilities management, student affairs, auxiliary services, public relations, information technology services and others, is the on-the-ground team convened to immediately secure the safety of USC students, faculty staff and visitors; to determine the nature and extent of damage; to coordinate with deans and vice presidents; and to implement the communications plan with university stakeholders.

The University complies with National Incident Management System (NIMS) standards in all of its emergency-planning efforts. Additional information regarding emergency response at the University and the FSEP is provided in Section IV.J.2, Fire Protection, of this Draft EIR.

3. Environmental Impacts

a. Methodology

To assist in evaluating the potential impacts associated with hazards and hazardous materials that could occur as a result of construction and/or operation of the proposed Project, several Phase I Environmental Site Assessments (ESAs) were prepared by Converse Consultants and Winzler & Kelly Consulting Engineers for the Project site. The Phase I ESAs included review of Sanborn maps and building permits, searches of hazardous materials databases, and site reconnaissance to determine if any RECs exist at the Project site (see the summary reports provided in Appendix E of this Draft EIR). In addition, a Methane Report was prepared by GeoKinetics to investigate methane conditions at the Project site (see Appendix F of this Draft EIR).




b. Significance Thresholds

Appendix G of the CEQA Guidelines provides sample questions that address impacts with regard to hazards and hazardous materials. These questions are as follows:

Would the project:

Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter 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 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

For a project located within an airport land use plan or, where such a plan has not been adopted, within 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?

For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area?

Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

In the context of these questions, the City of Los Angeles CEQA Thresholds Guide states that the determination of significance with regard to impacts associated with risk of upset/emergency preparedness and human health hazards shall be made on a case-by-case basis, considering the following factors:

(1) Risk of Upset/Emergency Preparedness

The regulatory framework;




The probable frequency and severity of consequences to people or property as a result of a potential accidental release or explosion of a hazardous substance;

The degree to which the project may require a new, or interfere with an existing, emergency response or evacuation plan, and the severity of the consequences; and

The degree to which project design will reduce the frequency or severity of a potential accidental release or explosion of a hazardous substance.

(2) Human Health Hazards

The regulatory framework for the health hazard;

The probable frequency and severity of consequences to people from exposure to the health hazard; and

The degree to which project design would reduce the frequency of exposure or severity of consequences of exposure to the health hazard.

Based on these factors a significant impact would occur if the proposed Project were to expose people to a substantial risk resulting from the release or explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards.

c. Project Design Features

During operation of the proposed Project, the USC EH&S would continue to implement environmental health and safety programs for the University. These programs include those addressing chemical safety, biological safety, radiation safety, lead management, asbestos management, laser safety, and industrial hygiene. In addition, all Project activities would occur in accordance with applicable federal, State, and local regulations.

d. Analysis of Proposed Project Impacts

(1) Prior Uses of the Project Site

Given the prior uses of the Project site, hazardous substances were used on portions of the Project site and within the surrounding vicinity. Hazardous substances previously used on-site and within the vicinity include solvents, dyes, paints, and metals. If a release occurred, such hazardous substances may have had the potential to impact the soil beneath the Project site. In addition, the potential exists that subsurface features




associated with previous development on the Project site, such as USTs associated with a prior gas station and Fire Station No. 15, may be present beneath the Project site. It is important to note that the identified on-site locations of hazards and/or hazardous materials have been graded and redeveloped several times, thereby minimizing the potential for environmental concern from previous uses of the Project site. Nonetheless, several HRECs have been identified on-site and within the vicinity of the Project site and are discussed in detail above. Mitigation Measure E-1 would ensure that any contaminated soils encountered during Project construction would be treated or disposed of properly. In addition, Mitigation Measure E-2 would ensure that any USTs uncovered during construction would be removed in accordance with applicable regulations. Therefore, with incorporation of Mitigation Measures E-1 and E-2, impacts regarding prior uses of the Project site would be less than significant.

(2) Hazards Associated with Hazardous Sites Listing

As discussed above, while portions of the Project site are identified in the databases reviewed in the EDR Report, the potential environmental impact from a majority of these listings is considered low due to the type of regulatory listings, involvement of a regulatory agency in remedial efforts, and/or redevelopment of the Project site. However, there are a few locations where this is not the case. Several registered UST sites, one LUST site, and three orphan sites have been mapped as being located within the Campus. The USC fuel station was identified as a hazardous waste generator. However, only one event of hazardous waste disposal was reported.61 In addition, the property located at 3600 South Hope Street within Subarea 2 is considered a HREC due to its prior use as an automobile repair shop in 1937 and 1942. As such, it is possible that contaminated soil or underground features such as USTs exist below this property. Mitigation Measures E-1 and E-2 would be incorporated to ensure that any contaminated soils or USTs that are encountered are treated in accordance with applicable regulations. As such, with incorporation of these mitigation measures, impacts would be reduced to a less than significant level.

The property within Subarea 2 at 3447 South Grand Avenue is listed for a spill or complaint that was reported as abated on January 29, 1991; a prior and active UST site; an emission source of toxic and criteria pollutants in 1987; and disposing hazardous waste to a recycler. This property’s listing as a prior and active UST site is considered a REC.





Through incorporation of Mitigation Measures E-1 and E-2, impacts attributable to past activities at this location would be less than significant.

In addition, the site at 3600 South Grand Avenue, located adjacent to the south boundary of Subarea 2, is listed as a prior and active UST site. As such, this site is identified as a REC. Through incorporation of Mitigation Measures E-1 and E-2, impacts would be less than significant.

Several locations within the University Village property were identified in the EDR Report. These listings include prior gas and oil service stations, small quantity generators of hazardous wastes, a prior dry cleaner, and a registered active UST site. As such, it is possible that contaminated soil or underground features such as USTs exist below this property. Mitigation Measures E-1 and E-2 would be implemented to ensure that any contaminated soils or USTs that are encountered are treated in accordance with applicable regulations. As such, with incorporation of these mitigation measures, impacts would be reduced to a less than significant level.

(3) Use, Storage, and Disposal of Hazardous Materials

Construction of the proposed Project would involve the temporary use of potentially hazardous materials, including paints, adhesives, surface coatings, cleaning agents, fuels, and oils. However, all potentially hazardous materials would be used and stored in accordance with manufacturers’ instructions and handled in compliance with applicable standards and regulations. Any associated risk would be adequately reduced to a less than significant level through compliance with these standards and regulations. Additionally, any emissions from the use of such materials would be minimal and localized to the Project site. Since construction of the proposed Project would comply with applicable regulations and would not expose persons to substantial risk resulting from the release of hazardous materials or exposure to health hazards in excess of regulatory standards, impacts associated with the potential release of hazardous substances during construction of the proposed Project would be less than significant.

The proposed Project is intended to meet the needs of the site populations expected by the University, inclusive of the existing populations and small annual increases in student enrollment, staff, and faculty through 2030. With Project development occurring in phases over a number of years extending to 2030, an increased number of individuals would be potentially exposed to hazardous materials located on the Project site. Any potential impacts that may result would be reduced to a less than significant level via compliance with applicable federal, State, and local regulations as well as the mitigation measures set forth below.




The proposed Project would include the development of academic/university-serving uses and a laboratory school, which could result in additional laboratories and other research facilities that would use and store hazardous materials. While the amount and type of hazardous materials may vary over time with changes in academic research, the general range and type of hazardous materials to be used on the Campus are not expected to substantially change from what is currently used. Operation of the proposed Project’s academic/University uses would continue to involve the use and storage of hazardous materials for laboratory classes, research, building and grounds maintenance, vehicle maintenance, and fine arts.

In addition, the proposed Project would include the development of retail/commercial uses, housing, and hotel/conference uses which would also involve the limited use of hazardous materials. The type and amount of hazardous materials would be similar to those currently used on the Project site and would be typical of those used for residential and commercial developments. 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. Hazardous materials to be used, stored, and disposed of by the proposed Project’s commercial uses would vary depending on the commercial use but could include cleaning solvents, waxes, dyes, toners, paints, bleach, grease, and petroleum products.

All potentially hazardous materials would be used and stored in accordance with manufacturers’ instructions and handled in compliance with applicable federal, State, and local regulations. In addition, USC EH&S would continue to operate and implement the various University safety programs which address chemical safety, biological safety, radiation safety, worker safety, and laser safety. Any associated risk would be adequately minimized through compliance with these regulations and USC EH&S safety programs. Therefore, impacts associated with the use, storage, and disposal of hazardous materials would be less than significant.

Implementation of the proposed Project could potentially generate increased hazardous wastes. Minimal hazardous wastes (e.g., paints, cleaning solvents) could be generated due to operation and maintenance activities for the proposed academic, commercial, and residential uses. The majority of the proposed Project’s hazardous waste stream would be attributable to hazardous wastes generated from the proposed laboratory/academic uses on the Campus. However, continued implementation of the source reduction measures implemented by the University as previously described (e.g., recycling of used batteries, recycling of elemental mercury, etc) would minimize the generation of hazardous waste. With the continued implementation of existing hazardous waste reduction efforts on-site, as well as the continued proper treatment and disposal of such wastes at licensed resource recovery facilities, the proposed Project would not




generate significant amounts of hazardous wastes which could not be disposed of at a hazardous waste landfill.

Other potential environmental impacts related to the increased generation of hazardous waste are associated with potential releases of the materials. Hazardous waste releases may result in potential injury if exposure takes place and, if not mitigated, result in soil and/or groundwater impacts. Compliance with applicable regulations related to the handling, storage and disposal of hazardous waste would ensure that such impacts would be less than significant.

(4) Transport of Hazardous Materials and Waste

As previously described, the transport of hazardous materials and wastes currently occur on the Project site. Specifically, laboratory and research operations associated with the on-site academic/University-serving uses require the transport of hazardous materials to/from the Project site and the transport of hazardous wastes (including medical wastes) from the Project site. Implementation of the proposed Project could incrementally increase the transport of hazardous materials and wastes to/from the Project site. As with current operations, the transport of hazardous materials and wastes would continue to 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. With continued compliance with Federal and State regulations, the transport of hazardous materials and wastes during Project operation would not result in substantial risk resulting from the release or explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore, Project impacts related to the transport of hazardous materials and waste would be less than significant.


As discussed above, several locations within Subarea 1 were identified as UST sites including multiple locations within the University Park Campus. One LUST site was also mapped as being located within the Campus. In addition, three 20,000 gallon USTs are currently located within the USC fuel station property. It is also likely that a UST was located on the USC fuel station property when it was developed as a loading dock for the May Company department warehouse store, but may have been removed when the site was redeveloped in 2001. While a portion of the Cardinal Gardens Apartments property




was previously developed as a LAFD fire station, it is unknown if USTs ever existed at this property. In addition, Fire Station No. 15 within the University Village property is a registered UST site with a closed LUST case due to a 1,000 gallon diesel UST that was removed from this property in 1999. As such, it is possible that contaminated soil or underground features such as USTs exist below portions of the Project site. Mitigation Measures E-1 and E-2 would be incorporated to ensure that any contaminated soils or USTs that are encountered are treated in accordance with applicable regulations. As such, with incorporation of these mitigation measures, impacts from USTs would be reduced to a less than significant level.


Based on the years of construction for some of the buildings on the Project site, there is a potential that ACM is present on-site. As part of the proposed Project, several existing buildings would be removed. The demolition of these buildings would have the potential to release asbestos fibers into the atmosphere if they are not properly stabilized or removed prior to demolition activities. The removal of asbestos is regulated by SCAQMD Rule 1403; therefore, any asbestos found on-site would be removed by a certified asbestos containment contractor in accordance with applicable regulations prior to demolition. With implementation of Mitigation Measure E-3 below, impacts related to asbestos would be reduced to a less than significant level.


Based on the years of construction for some of the buildings on the Project site, there is a potential that lead-based paint is present on-site. Since Project construction would involve the removal of several existing buildings on-site, demolition activities may have the potential for lead exposure. Therefore, Mitigation Measure E-4 is proposed below to ensure that all procedural requirements and regulations are followed for proper removal and disposal of any lead-based paint found on-site, if present. Thus, impacts would be less than significant with mitigation.

(8) Oil and Gas

As analyzed above, only two of the 161 gas probes that have been installed and monitored indicate detectable levels of what may be naturally occurring methane. Regardless, as portions of the Project site are located in a Methane Zone or Methane Buffer Zone, potentially significant impacts could occur during construction or operation of the Project. Construction of the proposed Project would require excavation of subsurface materials for building foundations, etc. As a result, construction workers could potentially be at risk during excavation activities if gases are present in high concentrations.




Therefore, appropriate precautionary measures should be taken to ensure construction worker safety. Mitigation Measure E-5 below is recommended to ensure that potential methane impacts are reduced to a less than significant level. Given the location of the Project site in a Methane Zone and Methane Buffer Zone, new buildings and paved areas of the proposed Project would be required to comply with the City’s Methane Seepage Regulations and the specifications of the LADBS as described in Mitigation Measure E-6 below.

The Project site survey identified the presence of four abandoned oil wells within Subarea 3. All four of the wells were plugged and abandoned between 1963 and 1966. To the extent that Project construction occurs in proximity to these or any other wells, DOGGR may require the re-abandonment of these wells in accordance with current regulatory requirements. Through this process, any potential significant impacts would be reduced to a less than significant level.

(9) Emergency Access and Preparedness

During Project construction, emergency access for LAFD vehicles within the Project vicinity, as well as within the Project site, could be impacted by Project construction activities. Temporary lane closures, sidewalk closures, and utility line construction, as well as the generation of traffic due to the movement of construction equipment, and hauling of demolition materials could slow or impede emergency access. However, the FSEP would continuously maintain lanes of emergency access to all buildings and police them to ensure they are not blocked. On those occasions when blocking a fire lane is unavoidable due to a construction project, the FSEP would continue to provide maps of alternate routes to the LAFD. In addition, as described in Section IV.J.2, Fire Protection, a Construction Traffic Management Plan would be implemented a to address management of traffic and access during construction. Since primary emergency access to the Project site would remain clear and unobstructed during construction of the proposed Project, construction impacts related to emergency access and preparedness would be less than significant.

During Project operation, the University would continue to implement its emergency preparedness and response procedures. The FSEP would continue to provide educational and training programs with regard to emergency evacuation plans. In addition, the University’s Emergency Operations Plan and individual would continue to be in place and if necessary, would be updated. Thus, with continued support by the FSEP as well as continued implementation of emergency plans and procedures, operational impacts related to emergency plans would be less than significant.

Regarding emergency access to the Project site during Project operation, Section IV.K.1, Transportation and Circulation, of this Draft EIR demonstrates that Project




development would result in significant impacts on access. Although additional traffic generated by the proposed Project could potentially cause delays in emergency response times, with implementation of the University’s Emergency Operations Plan, emergency access to the Project site would be maintained at all times. Thus, the additional traffic would not significantly impact emergency vehicle access or response times.

Based on the above, the proposed Project would not require a new, or interfere with an existing, emergency response or evacuation plan. Project impacts on emergency access and preparedness would be less than significant.

(10) Transfers of Floor Area

The proposed Project would include flexibility to allow for transfers of floor area for academic/University uses and student housing between Subarea 1 and Subarea 3A on a per square foot basis. While transfers of floor area across Subareas would be permitted, the maximum amount of floor area would not exceed 30 percent of the Subarea total for Subarea 1 and 15 percent of the Subarea total for Subarea 3A. In addition, the maximum Project total of 5,230,000 square feet may not be exceeded. Floor area transfers would not result in new impacts with regard to hazards and hazardous materials. Hazardous conditions with regard to the prior uses of the site, hazardous site listing, underground storage tanks, asbestos on the Project site, lead-based paint on the Project site, and oil and gas (including methane zone) are site-specific. Thus, transfers of floor area across the Subareas within the Project site would not affect the assessment of the Project site’s potential hazardous conditions as provided within this Draft EIR section. Additionally, with regard to the use, storage, and disposal of hazardous materials, the types and quantities of hazardous materials used on-site would remain consistent with that analyzed within this Draft EIR section. As such, floor area transfers would not alter the conclusions with regard to hazards and hazardous materials impacts. Should academic/University and student residential floor area be transferred across the Subareas, the resulting impacts would be similar to those evaluated herein.

4. Cumulative Impacts

Cumulative growth in the greater Project area through 2030 includes specific known development projects as well as general ambient growth projected to occur, as described in Section III, Environmental Setting, of this Draft EIR. Some of this growth is anticipated to occur on or around properties in the Project area known to contain hazardous or potentially hazardous conditions, such as hazardous waste generation or handling, or the presence of LUSTs. While impacts associated with hazards and hazardous materials are typically 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. Further, some of the related projects propose industrial uses that may also utilize, handle, store, or generate hazardous materials. However, all future development located within the vicinity of the Project site would be subject to the same local, regional, State, and federal regulations pertaining to hazards and hazardous materials. It is expected that all potentially hazardous materials would be used, stored, and disposed of in accordance with manufacturers’ specifications and handled in compliance with applicable standards and regulations. Any risks associated with these materials would be adequately reduced to a less than significant level through compliance with these standards and regulations. In addition, through the extension of existing programs administered by the Applicant, Project impacts with regard to emergency response or evacuation plans would not be cumulatively considerable. As such, the concurrent development of the proposed Project and related projects would not result in cumulatively significant impacts with regard to hazards and hazardous materials.

5. Mitigation Measures

The following measures are recommended to reduce Project impacts to a less than significant level:

Mitigation Measure E-1: If during construction activities, including demolition, excavation and grading work, discolored or odorous soils are uncovered, construction activities shall be halted until the impacted area can be evaluated. Soil sampling and, if appropriate, soil vapor sampling shall be conducted in accordance with applicable regulatory guidance documents to determine if the contamination, if any, is above regulatory levels or guidelines. Personnel conducting the sampling shall be appropriately trained in accordance with the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER). If contamination is detected above acceptable regulatory levels, remediation activities shall be conducted. The remediation could consist of excavation and disposal of impacted soil; in-situ treatment; and/or vapor extraction. If necessary, remedial efforts shall be conducted under the oversight of regulatory agencies including, but not limited to, the Department of Toxic Substances Control (DTSC); the City of Los Angeles Fire Department (LAFD); and the Regional Water Quality Control Board (RWQCB).

Mitigation Measure E-2: Monitoring and testing of USTs shall be continued in accordance with applicable regulations. If an UST is uncovered




during the construction activities, the UST shall be removed (abandoned) in accordance with LAFD regulations. Soil sampling of the tank excavation shall be completed and if soil contamination is found, the impacted soil shall be remediated (excavated) to acceptable regulatory levels.

Mitigation Measure E-3: Prior to the issuance of demolition permits for individual construction sites within the Project site, the University shall submit verification to the City of Los Angeles Department of Building and Safety that an asbestos survey has been conducted at all existing buildings located on the construction site. If asbestos is found, the University shall follow all procedural requirements and regulations of South Coast Air Quality Management District Rule 1403.

Mitigation Measure E-4: Prior to the issuance of demolition permits for individual construction sites within the Project site, the University shall submit verification to the City of Los Angeles Department of Building and Safety that a lead-based paint survey has been conducted at all existing buildings located on the construction site. If lead-based paint is found, the University shall follow all procedural requirements and regulations for proper removal and disposal of the lead-based paint.

Mitigation Measure E-5: During subsurface excavation activities, including borings, trenching, and grading, Cal-OSHA worker safety measures shall be implemented as required to preclude an exposure to unsafe levels of soil gases, including but not limited to methane.

Mitigation Measure E-6: Prior to issuance of a building permit for a structure located within a Methane Zone or Methane Buffer Zones, the Applicant shall comply with the applicable requirements of the City’s Methane Seepage Regulations as set forth in Section 91.7101, et seq. of the City’s Municipal Code.

6. Level of Significance After Mitigation

With implementation of the mitigation measures, Project-level impacts associated with hazards and hazardous materials would be reduced to a less than significant level. In addition, cumulative impacts associated with hazards and hazardous materials would also be less than significant.

iv. environmental impact analysis e. hazards and hazardous

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