3.11 HAZARDOUS MATERIALS
Introduction
This section provides an analysis of the potential for the Proposed Project to result in exposure of
persons or the environment to hazardous materials. Although the Project Site at 301 Industrial Road is
not included on the list (Cortese List) of hazardous materials sites compiled pursuant to California
Government Code Section 65962.5, the site was formerly used for the manufacturing of
semiconductors, circuits, and other computer related materials. A number of volatile organic
compounds (VOCs) have been identified in the soil and groundwater at the site. This section focuses
on the potential environmental impacts associated with the potential disturbance of hazardous materials
and hazardous wastes present on the Project Site, as well as potential future use and disposal of
hazardous materials and hazardous wastes on the site. Specific topics include the types of hazardous
materials that would be handled and hazardous wastes that would be generated, the regulatory setting
applicable to such activities, and applicable health and safety policies and procedures.
In response to the NOP for this CEQA review (see Section 1, Introduction), comments on the Proposed
Project were received from the Department of Toxic Substances Control (DTSC), requesting testing to
determine whether hazardous substances are present at levels which would need to be addressed before
development, as well as a discussion of potential air and health impacts associated with excavation
activities, identification of any local standards which may be exceeded by excavation activities
including dust levels and noise, and risk of upset should there be an accident at the site. These
concerns are addressed within this section. Please refer to Section 3.5, Air Quality, for further
discussion of air quality issues.
Existing Conditions
Classification of Hazardous Materials
The term “hazardous material” is defined in different ways for different regulatory programs. For
purposes of this EIR, the definition of “hazardous material” is the same as that in California Health and
Safety Code Section 25501:
any material that, because of its quantity, concentration, or physical or chemical characteristics,
poses a significant present or potential hazard to human health and safety or to the environment
if released into the workplace or the environment.
Hazardous materials can be categorized as hazardous non-radioactive chemical materials, radioactive
materials, and biohazardous materials. For hazardous non-radioactive chemicals, the above definition
is typically adequate. Radioactive and biohazardous materials are further defined as follows:
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Radioactive materials contain atoms with unstable nuclei that spontaneously emit ionizing
radiation to increase their stability.
•
Biohazardous materials include materials containing certain infectious agents (microorganisms,
bacteria, molds, parasites, viruses) that normally cause or significantly contribute to increased
human mortality or organisms capable of being communicated by invading and multiplying in
body tissues.
“Hazardous waste” is a subset of hazardous materials. For the purposes of this EIR, the definition of
hazardous waste is essentially the same as that in California Health and Safety Code Section 25517, and
in California Code of Regulations, Title 22 Section 66261.2:
Hazardous wastes are wastes that, because of their quantity, concentration, or physical,
chemical, or infectious characteristics, may either cause, or significantly contribute to, an
increase in mortality or an increase in serious illness, or pose a substantial present or potential
hazard to human health or the environment when improperly treated, stored, transported,
disposed of, or otherwise managed.
Hazardous wastes can generally be grouped into three categories, including hazardous chemical waste,
radioactive waste, and medical waste. These three categories are further defined below:
•
Hazardous chemical wastes are generally residuals of hazardous chemicals applied to various
uses. Hazardous chemical waste can include residuals from mercury, photography liquids,
photography solids, flammable liquids, aerosols, and laboratory solvents and chemicals.
•
Radioactive wastes are radioactive materials that are discarded (including wastes in storage) or
abandoned.
•
Medical waste includes both biohazardous wastes (byproducts of biohazardous materials) and
sharps (devices capable of cutting or piercing, such as hypodermic needles, razor blades, and
broken glass) resulting from the diagnosis, treatment, or immunization of human beings, or
research pertaining to these activities.
As described in this EIR, public health concerns associated with the Proposed Project generally fall
into four categories:
•
3.11-2
Hazardous Materials. Hazardous materials include hazardous non-radioactive chemicals and
products that may be harmful if improperly released to the environment or improperly handled
by people. These include a broad spectrum of products, including pesticides, petroleum fuel
products, paints and other coatings, and common household materials such as cleansers and
other cleaning products. Hazardous materials also include radioactive materials, biohazardous
and medical materials. Types of hazardous materials found in medical facilities include
chemotherapy reagents and other pharmaceuticals; chemicals used to sterilize equipment;
formaldehyde for specimen preservation; and solvents, oxidizers, corrosives, and stains used in
clinical laboratories. Facilities maintenance activities require various common hazardous
materials, including cleaners (which may include solvents and corrosives, in addition to soaps
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and detergents); paints; pesticides and herbicides; fuels (e.g., diesel); and oils and lubricants.
Radioactive materials generally contain radioactive atoms; however, x-ray equipment (which
does not involve any radioactive substances) is also regulated as radioactive material.
•
Hazardous Waste. Hazardous wastes are produced when hazardous materials are used or
discarded, and may be produced by manufacturing or other processes. These include used oil
products, containers of hazardous materials that are ready to be disposed, and spent solvents or
other materials from manufacturing, coating, or other hazardous materials handling activities.
Medical waste includes both biohazardous wastes (byproducts of biohazardous materials, such
as pathological specimens, surgical specimens, human tissues, bulk blood and blood products,
blood specimens, and body fluids) and sharps (devices capable of cutting or piercing, such as
hypodermic needles, razor blades, and broken glass) resulting from the diagnosis, treatment, or
immunization of human beings, or research pertaining to theses activities.
•
Contaminated Soil and Groundwater. Contaminated soil and groundwater usually results
from land uses that previously released hazardous materials or hazardous wastes into the soil,
groundwater, or sewer systems. Leaking underground storage tanks (USTs) and sumps are
common causes of such contaminated conditions, as are historic industrial activities that
routinely spilled or disposed of hazardous materials or hazardous wastes into the soil or
groundwater. Section 2, Project Description, describes the current and historical sources of
soil and groundwater contamination on the Project Site.
•
Hazardous Building Components. Examples of hazardous building components include
asbestos-containing materials (ACMs), electric transformers containing polychlorinated
biphenyls (PCBs), USTs and aboveground storage tanks (ASTs), and lead-based paint.
Applicable federal, state, and local legal requirements exist that relate to the safe maintenance
and removal of these materials.
Historic and Current Use and Storage of Hazardous Materials
Hazardous materials have been handled and stored by industries and businesses on the Project Site.
Activities associated with these hazardous materials have varied; however, industrial and businessrelated hazardous materials use, in general, is relatively unpredictable. Common hazardous materials
include oils (e.g., motor oil and hydraulic oil), fuels (e.g., gasoline and diesel), paints (both latex and
oil-based), solvents (e.g., degreasers, paint thinners, and aerosol propellants), acids and bases (such as
many cleaners), disinfectants, metals (e.g., thermometers, batteries, and photography chemicals), and
pesticides. Other hazardous materials, such as acetone, methanol, methane, and metals have been
known to occur on and/or near the Project Site.
The site is located in a light industrial area, and is bounded by the PG&E Regional Maintenance
Facility to the north, to the east by US 101, to the south by a designated Landmark Site that is
currently undeveloped and used for storage rental space, and to the west by retail and office buildings
occupied by ceramics, printing, and carpet businesses. To the west, beyond these retail and office
buildings, is a single-family residential neighborhood. In most circumstances, the potential risks posed
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by hazardous materials use and storage are primarily local and, therefore, limited to the immediate
vicinity of such use.
The 301 Industrial Road site is and has been used for the manufacturing of electron power tubes,
special purpose tubes, and semiconductors made of circuits and chips. A number of VOCs have been
identified in the soil and groundwater on the site. Other hazardous materials identified on site are in
various stages of remediation, as described below. The main hazardous wastes known at the site and
their cleanup status are as follows:
1
2
3
4
•
Acetone (CH3COCH3) - A colorless, inflammable, volatile liquid used as a paint remover and
as a solvent for certain oils and other organic compounds. On this site, acetone was used as a
cleanup solvent from coating operations. In June 1981, the EIMAC division of Varian, the
then-owner of the site, reported that 500 to 600 gallons of waste acetone containing barium
carbonate and methanol-rhodamine dye had been disposed of in a “dry well,” or solvent pit, at
the site. Because the solvent pit was unlined, any waste placed in the solvent pit was
considered by the DTSC to be released into the environment. A May 1984 report by Metcalf
and Eddy stated that organic chemical odors and dye stains were detected on fill soil during
excavation of a test pit in 1982.1 However, no odors or stains were observed in either fill soil
or bay mud in test wells, only 50 to 60 feet away from the suspected source. On August 15,
1985, DTSC approved closure of the solvent pit after Varian completed the approved sampling
plan and soil remediation activities, which included excavating contaminated soil and disposing
of it offsite.2
•
Methanol (CH3OH) - A colorless, volatile, inflammable, poisonous liquid obtained by the
destructive distillation of wood and used in organic synthesis, as a fuel, and in the manufacture
of formaldehyde, smokeless powders, and paints. On this site, methanol was used in the
etching of zirconium, in dewatering of metal parts, and as an anti-tarnish for parts. Two
USTs, used to store methanol, were maintained on site by EIMAC. A May 1984 report by
Metcalf and Eddy described their investigation of contamination resulting from a methanol
leak of these USTs.3 They concluded that the methanol contamination was generally confined
to the sandy backfill immediately around the two tanks in an area less than 5,000 square feet.
There was no apparent migration beyond 30 feet from the USTs due to the poor hydraulic
conductivity of the fill material. As there was no apparent migration, the impacted soil and
groundwater was removed and disposed off site. Kennedy/Jenks/Chilton Engineers certified
completion of the methanol UST remediation in March 1985.4 In 1987, Varian reported to
DTSC that it had completed the approved soil and groundwater remedial measures for both
Metcalf & Eddy Engineers, Report of Field Investigations – Volatile Organic Chemicals, EIMAC Division of
Varian Associates, May 5, 1984.
California Environmental Protection Agency, Department of Toxic Substances Control, RCRA Facility
Assessment for Varian Power Grid Tube Products, June 1, 1994.
Metcalf & Eddy Engineers, Report of Field Investigations – Methanol, EIMAC Division of Varian
Associates, May 5, 1984.
Kennedy/Jenks Engineers, Final Report on the Soil and Groundwater Contamination Assessment at Varian –
EIMAC’s Former Methanol Storage Area, March 13, 1985.
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tanks. In addition, the requisite sampling of monitoring wells was completed for one year
after the achievement of the remediation level in the extracted groundwater.5 The emptied
tanks were filled with concrete and closed in place.6
5
6
7
8
9
10
11
12
13
•
Methane (CH4) - A gaseous hydrocarbon of the paraffin, or methane, series. It is colorless,
odorless, and inflammable, and is formed by the decomposition of vegetable matter or
produced artificially. Methane is used as a fuel and for illumination purposes. Kennedy and
Jenks described the location and extent of methane contamination at the site in a March 1985
report and recommended “in-situ” remediation.7 Following completion of extensive soil and
groundwater investigations at the site in response to the DTSC’s Resource Conservation and
Recovery Act (RCRA) Facility Assessment,8 Closure Certification Approval was granted by
DTSC on December 31, 1997 that approved closure of all identified areas of concern (Sheds
A, B, and C) with respect to methane contamination.9
•
Metals – Metals used on this site include nickel strip solution, electroless nickel 755,
electroless nickel 797, silver strip solution, nickel chloride solution, chloroplatenic acid,
potassium ferricyanide, silver cyanide, gold cyanide, chromium, cadmium, copper, iron,
cobalt, tungsten, molybdenum, and aluminum. These metals were used for metal cleaning and
metal plating operations. Metcalf and Eddy investigated metal concentrations in soils in the
area of the former evaporation ponds and reported their findings in a May 1984 report.10 They
recommended excavation of the soil and proper disposal. Montgomery Watson in their
February 1996 report stated, “The extent of nickel in soil and groundwater was investigated
near the Former Ceramics Plating Facility and along the Buried Slough. Nickel was detected
in soil samples at concentrations similar to background levels.”11 Following completion of
extensive soil and groundwater investigations at the site in response to DTSC’s RCRA Facility
Assessment,12 a Closure Certification Approval was granted by DTSC on December 31, 1997
that approved closure of all identified areas of concern with respect to metal concentrations in
soils.13
California Environmental Protection Agency, Department of Toxic Substances Control, 1994, op. cit.
California Environmental Protection Agency, Department of Toxic Substances Control, Ibid.
Kennedy/Jenks Engineers, Final Report on the Soil and Groundwater Contamination Assessment at Varian –
EIMAC’s Former Methanol Storage Area, March 13, 1985.
California Environmental Protection Agency, Department of Toxic Substances Control, 1994, op. cit.
California Environmental Protection Agency, Department of Toxic Substances Control, Closure Certification
Approval for Communications & Power Industries, Inc., EIMAC Division, 301 Industrial Way, San Carlos,
EPA ID No. CAD 009 438 300, December 31, 1997.
Metcalf & Eddy Engineers, Report of Field Investigations – Metal Concentrations in Soils, EIMAC Division
of Varian Associates, May 5, 1984.
Montgomery Watson, op. cit.
California Environmental Protection Agency, Department of Toxic Substances Control, 1994, op. cit.
California Environmental Protection Agency, Department of Toxic Substances Control, 1997, op. cit.
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14
15
16
17
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Diesel - There was an apparent spill of diesel oil at the site in June 1991. According to a
January 14, 1993 letter from Varian’s Environmental Engineer to the County of San Mateo
Health Services Agency, the soils directly affected by the spill were removed to a depth of
four feet bgs.14
•
Acid and Sodium Hydroxide (NaOH) - An on-site industrial wastewater treatment facility
treated wastewater produced on-site. The system treated plating process wastewater, including
acid waste rinse water containing dissolved metals and cyanides. The acid waste rinse waters
were used in cleaning and plating operations. Treated wastewater was discharged to the
municipal sewer system. The wastewater treatment facility consisted of a neutralization tank,
two settling pools, two concentrated acid storage tanks, and a 30 percent sodium hydroxide
tank for neutralizing and removing metals from wastewater. From 1976 to 1982, sludge
generated by the wastewater treatment facility was stored in three evaporation ponds. The
ponds were replaced in 1982 by a sludge thickening tank and a filter press. Contaminated soil
in the evaporation pond area was excavated and disposed off site as documented in a report by
Kennedy/Jenks in October 1985.15 Following completion of extensive soil and groundwater
investigations at the site in response to DTSC’s RCRA Facility Assessment,16 Closure
Certification Approval was granted by DTSC on December 31, 1997 that approved closure of
all identified areas of concern with respect to acid and sodium hydroxide, including the former
wastewater treatment area and evaporation ponds.17
•
Volatile Organic Compounds (VOCs)/Halogenated-Volatile Organic Compounds
(HVOCs) - A “chemical kitchen” where industrial chemicals were formulated and mixed was
operated at the site from 1960 to 1991. The former chemical kitchen at the site was an area
where various metal cleaning and plating operation occurred. Quantities of unidentified
chemicals were stored in drums at a location known as the former Building 2 drum storage
area. The former Building 2 drum storage area was used to store drums of waste generated by
the Machine Shop. The wastes managed included solvents, coolants, scrap metals, and waste
oil. The VOCs found in the vicinity of the former chemical kitchen and former Building 2
drum storage area in the soil and groundwater include trichloroethylene (TCE), used in metal
degreasing and as a paint remover; perchloroethylene (PCE), used in dry cleaning and metal
degreasing; vinyl chloride, used to create polyvinyl chloride (PVC) and TCE; cis-1,
2-dichloroethylene (DCE), used as a solvent for waxes, resins, and acetylcellulose, in the
extraction of rubber, as a refrigerant, and as a chemical intermediate for making chlorinated
compounds; 1,1-Dichloroethane (DCA), used to make other chemicals, in degreasing, and in
dissolving substances such as paint, varnish, and finish removers; and 1,1,1-trichloroethane
Denise Kato, Environmental Engineer, Corporate Environmental Affairs, Varian, letter to Sabrina Mih,
County of San Mateo Department of Health Services, January 14,1993.
Kennedy/Jenks Engineers, Assessment of Chemicals in Soil at the Former Temporary Wastewater Treatment
Plant Site, October 1, 1985.
California Environmental Protection Agency, Department of Toxic Substances Control, 1994, op. cit.
California Environmental Protection Agency, Department of Toxic Substances Control, 1997, op. cit.
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(TCA), used as a solvent in many common products such as glue, paint, industrial degreasers,
and aerosol sprays. At the Project Site, VOC-producing compounds were used in the metal
cleaning and plating operations and were managed in waste storage areas.
The former Building 2 drum storage area was closed without any government agency oversight
to ensure compliance with government standards.18 Therefore, DTSC’s 1994 RCRA Facility
Assessment recommended that the area be included in the RCRA Facility Investigation. In a
February 1996 report, Montgomery Watson noted that the extent of HVOCs in the soil and
groundwater was limited to the immediate vicinity of the historical source, which has been
removed, and that further remediation of HVOCs at the site was not appropriate because no
migration of constituents was occurring in soil or groundwater and concentrations of the
immobile constituents would continue to decrease due to biodegradation.
DTSC’s 1994 RCRA Facility Assessment recommended allowing the closure of the former
chemical kitchen to proceed under the supervision of the San Mateo County Department of
Health Services (SMCDHS). In an August 1996 report, Montgomery Watson recommended
that this portion of the site be returned to manufacturing space without active remediation and
that the concrete floor therein should not be removed.19 In December 1996, following a letter
from the California Environmental Protection Agency (Cal/EPA)/Regional Water Quality
Control Board (RWQCB) recommending closure of the chemical kitchen portion of the site,
this area was conditionally closed based on industrial cleanup goals, with no further action
necessary until the land use changes and/or the building is demolished.20 This 1996 letter also
confirmed that all possible VOC sources (storage and processing units) in the former chemical
kitchen area had been removed.21 Elevated levels of VOCs above Environmental Screening
Levels (ESLs) acceptable for “Unrestricted Uses” are present in soil and groundwater in the
vicinity of the former chemical kitchen. As the site is above the “Unrestricted Uses” ESLs
standard set by the RWQCB, the Project Site would not be suitable for use by sensitive
receptors including hospitals and skilled nursing and medical facilities, until the Project Site is
cleaned up to meet the “Unrestricted Uses” ESLs standard.
18
19
20
21
“Facility closure” means that part of site closure and stabilization that is undertaken when no more hazardous
materials are to be brought into the facility. Facility closure includes any needed decontamination of the site
and structures, removal of equipment that is no longer needed, dismantlement and removal of unneeded
structures or conversion of those structures to other uses, and stabilization of the facility to prepare it for
institutional control and to provide reasonable assurance that it would remain stable and would not need
ongoing active maintenance.
Montgomery Watson, Human Health Risk Assessment. Former Building 2, Drum Storage Area, August 1,
1996.
Cal/EPA RWQCB, Former Varian Power Grid Tube Products Facility, December 24, 1996.
Cal/EPA RWQCB, Ibid.
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Required Remediation
In a January 1993 report, Canonie Environmental concluded that there were very low concentrations of
VOCs remaining at the Project Site, at acceptable levels for industrial uses.22 However, further
remedial action would be warranted for on-site uses such as the “Unrestricted Uses” listed above. On
June 25, 2004, a Remedial Action Plan (RAP) was submitted to the RWQCB for approval of the
cleanup goals in order to redevelop the site as a medical facility.23 An addendum to the RAP was
prepared on August 25, 2004. On August 31, 2004, RWQCB approved the RAP, including the
addendum. As required under state law, prior to construction of the proposed facility the site will be
clean of hazardous waste to a minimum “Unrestricted Uses” standard, which would be suitable for the
proposed PAMF-SCC facility. Remediation activities which are included in the RAP include
excavation and off-site disposal of contaminated soils at a properly licensed facility; treatment of
contaminated groundwater to the approved regulatory clean-up levels; and use of bioremediation
technologies, if necessary to stimulate naturally occurring microorganisms to break down some
chemicals into non-toxic substances. A description of the approved remediation activities is included in
Section 2.5, Proposed Changes to Site, of this document.
Applicable Plans and Regulations
Hazardous materials handling and hazardous waste management are subject to laws and regulations at
all levels of government as summarized below. The County of San Mateo Health Services Agency
(CSMHSA) and the South County Fire Authority (SCFA) implement and enforce state and federal laws
regarding hazardous materials management and emergency planning. The California Office of
Statewide Health Planning and Development (OSHPD), the San Carlos Building Department (SCBD),
and SCFA implement and enforce state laws regarding building and fire safety. The California
Division of Occupational Safety and Health (Cal/OSHA) and the U.S. Occupational Safety and Health
Administration (OSHA) implement and enforce state and federal laws regarding worker safety. DTSC
implements and enforces federal and state laws regarding hazardous waste handling. The Radiologic
Health Branch of the California Department of Health Services (CDHS) implements and enforces state
and federal laws regarding radioactive materials management. The CDHS Medical Waste Management
Program and CSMHSA implement and enforce state laws regarding medical waste handling. The U.S.
Department of Transportation (DOT), the U.S. Postal Service (USPS), the Environmental Protection
Agency (EPA), the California Highway Patrol (CHP), the California Department of Transportation
(Caltrans), and the DTSC implement and enforce state and federal laws regarding hazardous materials
transportation. BAAQMD, Cal/OSHA, and DTSC implement and enforce state and federal laws
regarding hazardous building components. RWQCB oversees the groundwater protection program
throughout the County.
22
23
Canonie Environmental, Soils and Groundwater Assessment, Varian – San Carlos, January 8, 1993.
Northgate Environmental Management, Inc., Remedial Action Plan, 301 Industrial Way, San Carlos,
California, June 16, 2004.
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Hazardous Materials Management and Emergency Planning. State and federal laws require that
hazardous materials be properly handled, used, stored, and disposed of, and, in the event that such
materials are accidentally released, that appropriate measures are taken to prevent or to mitigate injury
to human health or the environment. California’s Hazardous Materials Release Response Plans and
Inventory Law, sometimes called the “Business Plan Act,” aims to minimize the potential for accidents
involving hazardous materials and to facilitate an appropriate response to possible hazardous materials
emergencies. Businesses, including hospitals, that use hazardous materials in quantities that exceed the
state-established threshold quantities of 55 gallons for liquids, 500 pounds for solids, and 200 cubic feet
at standard temperature and pressure for compressed gases, are required by law to create a Hazardous
Materials Business Plan (HMBP). In San Mateo County, any amount of radioactive materials used or
handled by a business requires an HMBP. The HMBP requires inventories of those materials to be
provided to designated emergency response agencies, a diagram illustrating where the materials are
stored on site, an emergency response plan, and annual training for the employees’ safe use of the
materials and safety procedures in the event of a release or threatened release of a hazardous material.
CSMHA requires a HMBP addendum which must include a spill prevention plan, an emergency
response plan, a description of equipment type and location, employee training plan, and a closure
plan. HMBPs and addendums are kept on file with CSMHSA and SCFA. This information must be
updated within 30 days of a substantial change in operations.
Businesses that handle certain very hazardous substances over state threshold quantities, itemized in
Appendix D, must also undertake a systematic analysis of their operations, study the potential
consequences of possible worst-case accidents, and prepare a Risk Management Plan (RMP) to reduce
apparent risks, as required by state and federal regulation in the California Accidental Release
Prevention (CalARP) Program. These laws are implemented locally by CSMHSA and by SCFA,
which also enforces certain fire code regulations pertaining to hazardous materials storage.
During the course of the proposed PAMF-SCC’s patient care and facility maintenance operations, the
facility would use various materials, some of which pose potential hazards. For example, clinical
laboratories use potentially hazardous chemicals to analyze patient blood and urine samples.
Radioactive materials are used to treat certain kinds of cancer. Various patient diagnosis and treatment
activities involve potentially biohazardous materials (infectious agents). Hazardous materials use often
results in byproducts that must be handled and disposed of as hazardous wastes.
The Proposed Project could increase hazardous materials use and hazardous waste generation due to
increased site activity and development, and the range and volume of hazardous materials currently on
the site would change due to the operation of the proposed PAMF-SCC facility. Typically, a hospital
will have quantities of hazardous materials that trigger the need for an HMBP. Hospitals also generally
have radioactive materials which alone would require the facility to complete an HMBP based on San
Mateo County requirements. This requirement ensures that Proposed Project-related use of hazardous
materials by PAMF-SCC would be within acceptable risk levels and, therefore, that PAMF-SCC would
not use or produce hazardous materials in a manner that poses substantial hazards to people or to the
environment.
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Building and Fire Safety. OSHPD enforces the 2001 California Building Code, 2003 Life Safety
Code, and 2001 California Fire Code. SCBD and SCFA also enforce the California Building Code and
California Fire Code, respectively. These laws specify management practices for flammable materials,
including packaging and containment requirements. They also set forth appropriate construction
standards (e.g., fire separations and fire suppression systems) depending on building occupancy
classifications. OSHPD, SCBD, and SCFA review proposed building design plans to ensure
compliance with the Uniform Building Code and California Fire Code requirements.
Worker Safety. Occupational safety standards exist in federal and state laws to minimize worker
safety risks from both physical and chemical hazards in the workplace. Cal/OSHA is responsible for
developing and enforcing workplace safety standards and assuring worker safety in the handling and
use of hazardous materials. Among other requirements, Cal/OSHA obligates many businesses to
prepare injury and illness prevention plans and chemical hygiene plans. Cal/OSHA’s Hazard
Communication Standard requires that workers be informed of the hazards associated with the
materials they handle. For example, manufacturers are to appropriately label containers and employers
are to make material safety data sheets available in the workplace and properly train workers in the use
of hazardous materials.
OSHA’s Bloodborne Pathogens Standard mandates the use of universal precautions in the handling of
human blood and certain body fluids in the workplace. Each employer with employees who have
potential occupational exposure to bloodborne pathogens must annually review and update their
Exposure Control Plan. The Exposure Control Plan must implement precautions including providing
handwashing facilities; forbidding bending, recapping, or removing contaminated needles or sharps;
providing regulation of sharps disposal containers; forbidding the storage or consumption of
food/drink, the application of cosmetics, or smoking in work areas where there is a likelihood of
occupational exposure; prohibiting mouth suctioning of blood; transporting biohazardous materials
according to regulation; provision of personal protective equipment at no cost to employees, including
gloves, masks, eye protection, gowns, aprons, and other protective equipment; clean and sanitary
maintenance of facilities; provision of the hepatitis B vaccine to employees with risk of occupational
exposure; labeling of all containers holding regulated waste; and ensuring all employees participate in
occupational exposure training. All of these safety standards and practices regarding workplace safety
are contained in and implemented by individual businesses through their HMBPs and Addenda, as
described above.
Hazardous Waste Handling. DTSC is authorized to enforce hazardous waste laws and regulations in
California. Requirements place responsibility for proper hazardous waste disposal on hazardous waste
generators for the lifetime of the hazardous waste, commonly referred to as cradle-to-grave.
All hazardous waste generators must certify that, at a minimum, they make a good faith effort to
minimize their waste and use the waste management methods required by law. Hazardous waste laws
and regulations are enforced locally by the CSMHSA.
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Radioactive Materials Management. The Radiologic Health Branch of the CDHS administers the
federal and state radiation control laws and regulations that govern the storage, use, and transportation
of radioactive materials and the disposal of radioactive wastes. The Radiologic Health Branch licenses
institutions that use radioactive materials and radiation-producing equipment, such as x-ray equipment.
In order to maintain their licenses, institutions such as the proposed PAMF-SCC facility must meet
training and radiation safety requirements and be subject to routine inspections.
Medical Waste Handling. The CDHS Medical Waste Management Program enforces the California
Medical Waste Management Act and related regulations. Medical facilities that generate 200 or more
pounds per month of medical waste in any month of a 12-month period are required to implement a
Medical Waste Management Plan, which acts as the Medical Waste Facility Permit application. A
Medical Waste Management Plan must be filed with CSMHSA, the enforcement and permitting
agency, on forms provided by CSMHSA, containing but not limited to the name, address, and type of
business of the waste generator; the type and estimated monthly quantity of medical waste generated;
the type and capacity of medical waste treatment facilities used onsite; the name and address of the
registered hazardous waste hauling service; the name and address of the offsite medical waste treatment
facility; an emergency action plan complying with CDHS regulations; and a statement certifying that
the information provided is complete and accurate. The Medical Waste Management Plan is enforced
through an annual certification completed by the medical waste generator and through annual
inspections by CSMHSA.
Medical waste and its disposal is generally regulated in the same manner as hazardous waste, except
that special provisions apply to storage, disinfection, containment, and transportation. Medical waste
must be stored in closed red bags marked “biohazard” and, when transported for disposal, placed
inside hard-walled containers with lids. The law imposes a cradle-to-grave tracking system and a
calibration and monitoring system for onsite treatment. Facilities that treat medical waste onsite must
obtain from CSMHSA a medical waste facility On-site Treatment Facility permit, subject to annual
audits, and submit a Generator Registration Application (form DHS 8550). The medical waste facility
On-site Treatment Facility permit application must contain but is not limited to the permit application
form (DHS 8667); the capacity and time per operational cycle; the operations schedule; the amount of
medical waste expected to be handled during the permit period; the process to be used to treat medical
waste; the type of waste to be treated; measures which would prevent unauthorized waste from being
treated at the facility; description of radiation detection devices; a facility site plan depicting medical
waste treatment locations; a map of the vicinity; a disclosure statement; a description of security
procedures; the general operation plan; the emergency action plan; the training plan; the closure plan;
and a description of the monitoring equipment and schedule. The permit is valid for 5 years, at which
point it can be renewed. The CSMHSA shall issue a medical waste facility On-site Treatment Facility
permit upon evaluation, inspection, or records review of the application. The permit is issued within
180 days if the application is in substantial compliance with the California Medical Waste Management
Act. CSMHSA may prohibit or condition the handling or treatment of medical waste to protect public
health and safety.
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Hazardous Materials Transportation. DOT has developed regulations pertaining to the transport of
hazardous materials and hazardous wastes by all modes of transportation. Typical hospital operations
could include hazardous materials transport by mail. USPS has developed additional regulations for
the transport of hazardous materials by mail. DOT regulations specify packaging requirements for
different types of materials. EPA has also promulgated regulations for the transport of hazardous
wastes. These more stringent requirements include tracking shipments with manifests to ensure that
wastes are delivered to their intended destinations. In California, CHP, Caltrans, and DTSC enforce
federal hazardous materials transportation requirements.
Hazardous Building Components. Structural building components sometimes contain hazardous
materials such as asbestos, PCBs, lead, and mercury. Demolition of buildings containing such
materials could disturb these materials and thus expose workers, the public, and the environment to
hazardous materials. These materials are subject to regulatory oversight, as described below.
Asbestos. Asbestos is regulated as a hazardous air pollutant and as a potential worker safety hazard.
BAAQMD’s Regulation 11 and Cal/OSHA regulations restrict asbestos emissions from demolition and
renovation activities and specify safe work practices to minimize the potential for release of asbestos
fibers. These regulations prohibit emissions of asbestos from asbestos-related manufacturing,
demolition, or construction activities; require medical examinations and monitoring of employees
engaged in activities that could disturb asbestos; specify precautions and safe work practices that must
be followed to minimize the potential for release of asbestos fibers; and require notice to federal and
local government agencies prior to beginning renovation or demolition that could disturb asbestos.
California requires licensing and certification through Cal/OSHA of contractors who conduct asbestos
abatement activities.
PCBs. DTSC has classified PCBs as a hazardous waste when concentrations exceed 5 parts per million
(ppm) in liquids or 50 ppm in non-liquids. Fluorescent light ballasts may contain PCBs, and if so, they
are regulated as hazardous waste and must be transported and disposed of as hazardous waste. Ballasts
manufactured after January 1, 1978 should not contain PCBs and are required to have a label clearly
stating that PCBs are not present.
Lead. Cal/OSHA standards establish a maximum safe exposure level for types of construction work
where lead exposure may occur, including demolition of structures where materials containing lead are
present; removal or encapsulation of materials containing lead; and new construction, alteration,
repair, or renovation of structures with materials containing lead. Inspection, testing, and removal of
lead-containing building materials must be performed by state-certified contractors who are required to
comply with applicable health and safety and hazardous materials regulations. Typically, building
materials with only lead-based paint attached are not considered hazardous waste unless the paint is
chemically or physically removed from the building debris.
Mercury. Spent fluorescent light tubes, thermostats, and other electrical equipment contain heavy
metals that, if disposed of in landfills, can leach into soil or groundwater. Lighting tubes typically
contain concentrations of mercury that may exceed regulatory thresholds for hazardous waste and, as
such, must be managed in accordance with hazardous waste regulations. Elemental mercury also can
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be found in many electrical switches which also must be managed in accordance with hazardous waste
regulations.
Impacts and Mitigation Measures
Standards of Significance
For purposes of this EIR, the Proposed Project would be considered to result in a significant hazardous
materials impact if it were to:
•
Create a significant hazard to the public or the environment through the routine transport, use,
or disposal of hazardous materials;
•
Create a significant hazard to the public or the environment through reasonably foreseeable
upset or accident conditions involving the release of hazardous materials into the environment;
•
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, it would create a significant hazard to
the public or the environment;
•
Be 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, and would result in a safety hazard for
people residing or working in the project area;
•
Be located within the vicinity of a private airstrip, and would 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 related to hazardous material spill response; or
•
Expose people or structures to a significant risk of loss, injury, or death involving wildland
fires, including where wildlands are adjacent to urbanized areas or where residences are
intermixed with wildlands.
Methodology for Analysis
To assess the potential for the Proposed Project to involve the use, production, or disposal of materials
in a manner that poses substantial hazards to people, or to animal or plant populations, the following
analysis considers the pathways through which exposure to hazards could potentially occur, and
evaluates the controls that probably would be placed on each of these pathways. Exposure pathways
that would be controlled sufficiently to pose no substantial hazards are considered less-than-significant
health and safety issues.
Exposure pathways are means by which hazardous substances move through the environment from a
source to a point of contact with people. A complete exposure pathway must have four parts: (1) a
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source of contamination, (2) a mechanism for transport of a substance from the source to the air,
surface water, groundwater or soil, (3) a point where people come in contact with contaminated air,
surface water, groundwater or soil, and (4) a route of entry into the body. Routes of entry can be
eating or drinking contaminated materials, breathing contaminated air, or absorbing contaminants
through the skin. Risks can be assessed when an exposure pathway is complete. If any part of an
exposure pathway is absent, the pathway is said to be incomplete and no exposure or risk is possible.
In some cases, although a pathway is complete, the likelihood that exposure will occur is very small.
Exposure pathways can exist under many different circumstances. Toxic substances can be released
from a facility or source of contamination during normal, everyday operations or through leaks, spills,
fires, or other accidents. Once released, contaminants can move or be transported through the
environment by various means.
Environmental Analysis
As described in Section 3.1, for each impact, a level of significance is determined and is reported in
the impact statement. Conclusions of significance are defined as follows: significant (S), potentially
significant (PS), less than significant (LTS), and no impact (NI). If the mitigation measures would not
diminish potentially significant or significant effects to a less than significant level, the impacts are
classified as significant unavoidable effects (SU). For this section, HM refers to hazardous materials.
HM-1. Exposure from Hazardous Materials Use, Storage, and Handling. The Proposed Project could
increase hazardous materials use, storage, and handling on the Project Site, thereby
increasing risks of human and environmental exposure to hazardous materials. However,
existing health and safety programs limit the potential for exposure to hazardous materials by
workers, other individuals on site, the community, and the environment so that this potential
for exposure would be less than significant. (LTS)
The hazards posed by chemicals, radioactive materials, and biohazardous materials vary.
Some chemicals can pose physical hazards (e.g., chemical burns) or health hazards (e.g.,
poisoning), including potential acute or chronic illnesses. The properties and health effects of
different chemicals are unique to each chemical and depend on the extent to which an
individual is exposed. The types and amounts of hazardous chemicals anticipated by PAMF to
be present at the PAMF-SCC site are shown in Table 3.11-1. Exposure to excessive levels of
radiation, whether from radiation-producing equipment or radioactive materials, can result in
headaches, skin burns, or chronic illness, including cancer. Exposure to biohazardous
materials can cause a range of illnesses, depending on the infectious agent encountered. Some
infections can result in short-term discomfort (e.g., mild symptoms that can easily be treated
or go away by themselves), while others can result in serious acute effects (e.g., dangerous
disruptions of life functions). Some chronic diseases may or may not be curable or treatable.
Some diseases may be communicable. In all of the above cases, the risks posed by the
hazardous materials depend on the potential for exposure. The potential for exposure by
workers and other individuals on site and by the larger community and the environment is less
than significant, as explained below.
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Table 3.11-1
Estimated Maximum Amounts of Hazardous Chemicals at PAMF-SCC
Maximum Amount on Site
Type of Material
Examples
Solids
(pounds)
Liquids
(gallons)
Gases
(cubic feet)
Inert Compressed Gases and
Cryogenic Liquids
liquid nitrogen, compressed air,
helium, nitrous oxide, argon
200
-
37,000
Flammable Compressed Gases and
Liquids
spray paint and other aerosols,
acetylene, propane
-
<55
<200
Flammable Liquids
gasoline, isopropanol, acetone, ether,
other solvents
-
<55
-
Combustible Materials
hydraulic oil, motor oil, diesel fuel
-
18,000
-
Oxidizers
liquid oxygen, oxygen
-
9,000
3,200
Corrosive Materials
lead acid batteries, cycloexylamine formula 48, chloromethoyisothiazolin
1,100
200
-
Toxic Materials
zep formula 300, freon 12 and 22,
glutaraldehyde
55
3,800
-
Carcinogens
chloroform, formalin
-
150
-
Irritants
sodium, nitrate formula 12-L,
sodium bisulfate, radiator coolant
-
280
-
Source: PAMF, August 2005.
Notes:
a. Some chemicals fall into more than one category; therefore, the columns presented here cannot be added to derive actual
totals.
b. This table provides a reasonable rough estimate of the materials that will be located at PAMF-SCC; however, due to the
continuing advancements in technology, the list of needed chemicals and quantities may change in the time between this
estimate and the opening of PAMF-SCC.
Workers and Other Individuals On Site. The potential for long-term exposure for persons
at the Project Site to hazardous materials from contamination of the soil and groundwater
would be mitigated through implementation of the RAP that has been approved by the
RWQCB. The remediation activities included in the RAP are summarized in Section 2.5,
Proposed Changes to Site. Essentially, the RAP requires cleanup of the Project Site to a
minimum “Unrestricted Uses” ESLs standard prior to occupation by a hospital or medical
facility. As the Proposed Project would be required to meet these standards before occupation,
there would be minimal risk for individuals on site from exposure to existing on-site
contamination.
Following occupation of the Project Site, exposure to hazardous materials by physicians, staff,
patients, and visitors could occur through activities associated with hazardous materials
handling, storage, and accidental release. The effects of hazardous materials handling and
storage would generally be limited to the immediate area where the materials would be
located, because this is where exposure would be most likely. The routes through which
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PAMF-SCC employees or others in the immediate vicinity could be exposed include
inhalation, ingestion, contact, injection, and other accidents. Control measures to reduce or
prevent exposure to hazardous chemical materials and radioactive materials currently exist
explicitly in federal and state laws to minimize worker safety risks. Control measures to
reduce or prevent exposure to biohazardous materials are incorporated in California law by
reference in Sections 25115, 25117, and 25316 of the California Health and Safety Code.
Examples of control measures to reduce the risk of exposure of on-site workers and other
individuals are presented in Table 3.11-2. These examples of control measures are consistent
with occupational safety standards and standard industry practices. They respond to the
materials and wastes handling regulations enforced by county, state, and federal agencies
through required reporting procedures and site inspections (see Applicable Plans and
Regulations, above). PAMF would be required by law to comply with the control measures
established in the approved HMBPs and Addenda, RMPs, license to handle radiological
materials, and Medical Waste Facility Permit.
The standard industry practices are established by guidelines from agencies such as the
National Research Council and the U.S. Department of Health and Human Services Public
Health Service, National Institutes of Health, and Centers for Disease Control. The guidelines
are often indirectly required by laws and regulations that incorporate them by reference. The
protective equipment and training required by law to be provided to PAMF-SCC staff would
further reduce potential exposure. The occupational exposure training and personal protective
equipment required by OSHA’s Bloodborne Pathogens Standard, the training required by the
California Medical Waste Management Act, and the training required by California’s
Hazardous Materials Release Response Plans and Inventory Law all limit the exposure
pathway for individuals on or near the Project Site. Compliance with the regulations and
industry standards would protect workers and other individuals on site from exposure to
hazardous materials.
CSMHSA regulates the management of hazardous materials, including its storage and use.
CSMHSA inspects hazardous material sites and performs oversight functions pursuant to the
State Health and Safety Code, Division 20. The State Health and Safety Code defines
hazardous materials, establishes threshold quantities for regulation, and lists businesses that are
exempt from state requirements. All businesses, including hospitals, which use or store
quantities that exceed the state’s thresholds are required to file an HMBP with CSMHSA and
SCFA. Also, in San Mateo County, an HMBP is required for sites that involve the use or
handling of any quantity of radioactive material. As shown in Table 3.11-1, PAMF’s
estimates of hazardous chemicals that would be stored at the PAMF-SCC site would be above
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Table 3.11-2
Exposure Pathways and Controls – Workers and Other Individuals on Site
Exposure Pathway
Inhalation
(breathing a hazardous substance)
Examples of Control Measures
•
•
•
•
Ingestion
(swallowing a hazardous substance)
•
•
•
•
Contact
(absorbing a hazardous substance
through the skin or eyes)
•
•
•
•
•
Injection
(puncturing or cutting the skin with
a contaminated object)
•
Other Accidents
•
•
•
•
•
•
•
Working with volatile materials in fume hoodsa
Working with potentially aerosol-suspended biohazardous materials
in biosafety cabinetsb
Keeping containers closed when not in use
Wearing face masks or respirators, as necessary
Not eating or drinking near hazardous materials
Not storing food in refrigerators used for hazardous materials
Not smoking near hazardous materials
Washing hands and work areas
Wearing protective clothing and shoes, as necessary
Wearing eye protection (glasses or goggles), as necessary
Wearing gloves, as necessary
Washing hands and work areas
Working with radioactive materials behind shields
Participating in awareness training
Keeping sharps (e.g. needles, knifes, scissors) in puncture-resistant
containers
Participating in emergency response trainingc
Maintaining emergency equipment (e.g., safety showers, emergency
eye washes, first aid kits)
Providing appropriate lips on shelves where hazardous materials are
stored and other restraints where necessaryd
Segregating incompatible hazardous materials and storing flammable
materials in fire-rated cabinets
Providing secondary containment for hazardous materials that are not
in use
Calling the South County Fire Authority and its Hazardous Materials
Emergency Response Team, if necessary
Source: EIP Associates, 2004.
Notes:
a. Fume hoods are cabinets with front-opening (usually sliding) glass doors connected to overhead exhaust fans that draw
air from the room through the cabinet and expel it into the atmosphere through rooftop stacks.
b. Biosafety cabinets look similar to fume hoods. They filter aerosols and remove particles from the air, but do not
necessarily exhaust the filtered air to the outdoors.
c. Training content and methods as required and described by California’s Hazardous Materials Release Response Plans
and Inventory Law, Cal/OSHA’s Communication Standard, OSHA’s Bloodborne Pathogens Standard, the licensing
requirements of the Radiological Health Branch of the CDHS, the Medical Waste Management Act, and any other
applicable laws or regulations.
d. All containers shall be stored using restraining wire or cord, or restraining edges, when open shelving is used.
the state’s established threshold quantities of 55 gallons for liquids, 500 pound for solids, and
200 cubic feet for compressed gases; therefore, the PAMF-SCC site would be required to
prepare, submit, and comply with an HMBP. Compliance with the Business Plan Act would
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ensure that the project-related use of hazardous materials would be within acceptable risk
levels because of the inventory, reporting, training, and emergency response plan requirements
associated with the HMBP and oversight by the CSMHSA. Therefore, the project-related
activities would not use or produce hazardous materials in a manner that poses substantial
hazards to workers and other individuals on site.
Community and Environment. For the most part, the health and safety procedures that
protect workers and other individuals in the immediate vicinity of hazardous materials would
also protect the more distant community and environment. The pathways through which the
community or the environment (e.g., local air quality and biota) could be exposed to
hazardous materials include air emissions, transport of hazardous materials to or from the site,
waste disposal, human contact, and accidents. Table 3.11-3 lists some of the primary means
PAMF would use to protect the community and the environment from exposure to hazardous
materials, as required by law, such as California’s Hazardous Materials Release Response
Plans and Inventory Law, the 2001 California Building Code, the 2003 Life Safety Code, the
2001 California Fire Code, RWQCB’s groundwater protection program, Cal/OSHA’s Hazard
Communication Standard, OSHA’s Bloodborne Pathogen Standard, hazardous waste laws and
regulations, radiation control laws and regulations, the California Medical Waste Management
Act, the DOT hazardous materials transportation regulations, the USPS hazardous materials
transportation regulations, the EPA hazardous materials transportation regulations, and the
BAAQMD and Cal/OSHA regulations restricting asbestos emissions and specifying safe work
practices, as described above in the Applicable Plans and Regulations section.
The proposed PAMF-SCC facility could increase hazardous materials storage on the Project
Site, thereby increasing risks of human and environmental exposure to hazardous materials.
Table 3.11-1 provides PAMF’s estimate of the quantities of hazardous chemicals that would be
stored at PAMF-SCC, based on hazardous chemical storage at a similar Sutter medical facility.
Based on common practice in the medical field, it is expected that storage of gases and liquids
would generally be in small, individual containers of about 5 gallons or less except for diesel
fuel storage tanks and compressed gas cylinders. As a result, the quantities anticipated at the
PAMF-SCC site are sufficiently small that they would fall well below the federal and state
CalARP regulated state threshold quantities, listed in Appendix D, that would trigger the
requirements for a Risk Management Plan. The proposed PAMF-SCC would not be expected
to increase the use of these materials to the point that would exceed the threshold quantities
identified in Section 112(r)(5) of the federal Clean Air Act (40 CFR section 68.130). Thus, the
Proposed Project would not transport, use, store, handle, or dispose of hazardous materials in a
manner that poses substantial hazards to the community or the environment. There would also
be no significant hazard to the public or environment through reasonably foreseeable upset or
accident conditions involving the release of hazardous materials into the environment at the
PAMF-SCC site.
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Table 3.11-3
Exposure Pathways and Controls – Community and Environment
Exposure Pathway
Examples of Control Measures
Air Emissions
•
Using fume hood ventilation or alternative exhaust systems to dilute
and subsequently disperse outgoing emissionsa
Transport to and from the Site
•
Following packaging requirements specified by the DOT, USPS, and
the CDHS Radiologic Health Branch and Medical Waste Program
Identifying container contents with appropriate labels
Using licensed hazardous waste haulers
Documenting hazardous waste shipments
•
•
•
Waste Disposal
•
•
•
•
•
•
Human Contact
•
•
•
•
•
Accidents
•
•
•
•
•
Training workersb
Segregating wastes
Collecting hazardous waste for appropriate disposal
Diluting and treating wastewater from the site
Labeling trash cans
Following federal and state hazardous waste disposal regulations and
procedures, including those for hazardous waste manifest
documentation
Identifying container contents with appropriate labels
Training workersb
Implementing standard hygiene practices (e.g., wearing protective
clothing and gloves when necessary, leaving protective clothing at
work, and washing hands and work areas)c
Implementing medical surveillance programs to monitor the health of
those who work with certain biohazardous materialsc
Monitoring the exposure of those who work with radioactive
materialsc
Providing emergency response trainingb
Maintaining emergency equipment (e.g., safety showers, emergency
eye washes, first aid kits)
Calling the South County Fire Authority and its Hazardous Materials
Emergency Response Team, if necessary
Plugging floor drains or providing sumps in areas where relatively
large quantities of hazardous waste may be handledd
Conducting facility inspections and preventative maintenance
Source: EIP Associates, 2004.
Notes:
a. Fume hoods are cabinets with front-opening (usually sliding) glass doors connected to overhead exhaust fans that draw
air from the cabinet and expel it into the atmosphere through rooftop stacks.
b. Training content and methods as required and described by California’s Hazardous Materials Release Response Plans
and Inventory Law, Cal/OSHA’s Communication Standard, OSHA’s Bloodborne Pathogens Standard, the licensing
requirements of the Radiological Health Branch of the CDHS, the Medical Waste Management Act, and any other
applicable laws or regulations.
c. These measures would prevent employees from transmitting hazardous materials to the community or into the
environment.
d. Floor drains in generator rooms shall be equipped with removable plugs to prevent spills from entering the wastewater
sewer. A sump located at the loading dock would minimize the potential for a hazardous materials release to the storm
sewers.
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Aside from accidents possibly occurring on site, accidents during hazardous waste transport to
and from the site could expose the community and the environment to risks at some distance
from the PAMF-SCC site. However, transportation accidents are infrequent. According to
the California Department of Transportation, less than 3.12 vehicle accidents occur for every
million vehicle miles traveled on major undivided urban highways.24 The frequency is
substantially less on other types of urban highways. Moreover, DOT, USPS, and the CDHS
Radiologic Health Branch and Medical Waste Program all specify packaging requirements for
hazardous materials and wastes that limit the potential for packages to fail on impact. These
requirements reduce the potential for hazardous materials releases to occur in the unlikely
event of an accident.
Hazardous Materials Use and Storage Summary. The PAMF-SCC would increase the
storage and use of hazardous materials on site. However, regulations such as California’s
Hazardous Materials Release Response Plans and Inventory Law, the 2001 California Building
Code, the 2003 Life Safety Code, the 2001 California Fire Code, RWQCB’s groundwater
protection program, Cal/OSHA’s Hazard Communication Standard, OSHA’s Bloodborne
Pathogen Standard, hazardous waste laws and regulations, radiation control laws and
regulations, the California Medical Waste Management Act, the DOT hazardous materials
transportation regulations, the USPS hazardous materials transportation regulations, the EPA
hazardous materials transportation regulations, and the BAAQMD and Cal/OSHA regulations
restricting asbestos emissions and specifying safe work practices would require that the
controls summarized in Tables 3.11-2 and 3.11-3 be implemented. These mechanisms would
minimize the potential for exposure to adverse health or safety effects. Therefore, the PAMFSCC would not involve the use of materials in a manner that poses any substantial hazards to
people, or to animal or plant populations. Furthermore, PAMF would implement its required
emergency response plan and SCFA would continue to provide emergency response services.
For these reasons, the PAMF-SCC would not result in a significant environmental impact
related to the increased transport, use, storage, and handling of hazardous materials by PAMF
and would not require mitigation.
HM-2. Construction-Related Hazardous Materials Disturbance. Project-related demolition could
disturb hazardous materials in existing building components and thereby cause adverse health
or safety effects. However, existing health and safety programs and the implementation of the
RAP, including the addendum, limit the potential for exposure to hazardous materials by
workers, other individuals on site, the community, and the environment. (LTS)
Development of the PAMF-SCC would require demolition of existing CPI buildings at
301 Industrial Road. Because it was common building practice to use materials with asbestos,
PCBs, lead, and mercury in structures built prior to 1981, demolition of the existing buildings
(which were built prior to 1981) could disturb these hazardous building materials and cause
adverse health or safety effects to construction workers, the public, and/or the environment.
24
California Department of Transportation, 1996 Accident Data on California State Highways (Road Miles,
Travel, Accidents, Accident Rates), 1997.
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If hazardous materials were found upon inspection at levels that require special handling (i.e.,
any building material containing 0.1 percent asbestos, paint that contains more than
5,000 parts per million of lead, or any building materials known or suspected to contain any
amount of PCBs or mercury), the project sponsor must manage these materials as required by
law and according to federal and state regulations and guidelines, including those of DTSC,
BAAQMD, Cal/OSHA, CSMHSA, and any other agency with jurisdiction over these
hazardous materials, as described below.
Asbestos poses health hazards only when inhaled; therefore, friable (easily crumbled) asbestos
is potentially hazardous if not encapsulated. Non-friable asbestos or encapsulated asbestos
does not pose substantial health risks. During building demolition, asbestos fibers (if any are
present) could be disturbed, released into the air, and inhaled by construction workers or the
public unless proper precautions are taken. BAAQMD’s Regulation 11 – Hazardous
Pollutants, Rule 2 – Asbestos Demolition, Renovation, and Manufacturing establishes an
allowable asbestos emissions threshold from asbestos-related demolition or construction
activities, and specifies precautions and safe work practices to be followed in order to
minimize the potential release of asbestos fibers. A detailed written plan or notification of
demolition must be submitted to the Air Pollution Control Officer (APCO) at least 10 business
days before the commencement of demolition. This plan must include contact information for
the person who conducted the asbestos survey and applicable Cal-OSHA certification number;
a description of demolition methods, work practices, and engineering controls; the amount of
regulated-asbestos containing material to be removed; certification that at least one person
trained as required by BAAQMD will supervise the removal described, with the information
posted on the Project Site for inspection by the APCO; the waste transporting service to be
used; and the site where the waste will be disposed. The Air Pollution Control Officer at
BAAQMD enforces the regulation through inspection and testing to determine compliance,
citations for non-compliance, and through identification of misdemeanors requiring fines or jail
sentencing. The purpose of BAAQMD’s Regulation 11 is to control emissions of asbestos to
the atmosphere during demolition, renovation, milling, and manufacturing activities and
establish appropriate waste disposal procedures to safeguard workers, the public, and the
environment from asbestos emissions. In light of the above regulations, potential impacts
associated with asbestos exposure during demolition activities are not expected to be
considerable, and thus public health impacts from this hazardous building material would be
less than significant.
Building components containing PCBs, lead, or mercury also could be found in the buildings
proposed to be demolished on the Project Site. In sufficient concentrations, lead and mercury
are regulated as hazardous wastes. PCBs, mercury, and lead are regulated under the federal
Toxic Substances Control Act of 1976, and Cal/OSHA standards establish a maximum safe
exposure level for types of construction work where lead exposure may occur, as described
earlier in Applicable Plans and Regulations. Adherence to applicable health and safety
requirements for these substances would ensure that potential exposure impacts from these
materials are less than significant.
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If any unidentified hazardous materials were present in the existing buildings when demolition
occurred, these hazardous materials could create worker health hazards or result in
environmental release (or inappropriate disposal) of these hazardous materials. For this
reason, the Proposed Project could involve handling materials in a manner that poses a hazard
to people, or to animal or plant populations, if required hazardous materials surveys and safety
precautions were not undertaken. The approval of the RAP, including the addendum, requires
the use the RWQCB’s Residential ESLs as the Plan’s cleanup goals to allow for “Unrestricted
Uses.” “Robust confirmation sampling and analysis” would be required to demonstrate
satisfaction of the goals. This phrase means the required performance of pre-construction and
ongoing hazardous materials surveys and RWQCB-approved management of any hazardous
materials identified during those surveys or during the actual remediation work. Approval of
the RAP, including the addendum, requires 301 Industrial, LLC to retain a qualified
environmental specialist (e.g., a Registered Environmental Assessor or similarly qualified
individual) to inspect existing buildings proposed to be demolished for the presence of
asbestos, PCBs, mercury, lead, or other hazardous materials and prepare a report of the
findings. 301 Industrial, LLC would be required to submit the report to the City for review
and approval prior to approval for a demolition permit, together with an explanation of how
the Proposed Project would address any issues identified in the report. Recommendations to
handle and dispose of any hazardous materials would be required to be incorporated into the
demolition contract document. Implementation of the RAP, including the addendum, would
ensure that potential exposure impacts from previously unidentified hazardous materials in the
building components would be less than significant.
HM-3. Exposure to Contaminated Soil and/or Groundwater.
Site grading, excavation, and
construction of proposed building foundations could expose construction personnel and the
public to existing contaminated soil and/or groundwater. However, existing health and safety
programs and the implementation of the RAP, including the addendum, limit the potential for
exposure to hazardous materials by workers, other individuals on site, the community, and the
environment. (LTS)
Exposure to hazardous materials could cause various short-term or long-term health effects
specific to each chemical present if of sufficient concentration and duration. Acute effects,
often resulting from a single exposure, could range from major to minor effects, such as
nausea, vomiting, headache, or dizziness. Chronic exposure to hazardous materials could
result in systemic damage or damage to specific organs, such as lungs, liver, or kidneys
(related to exposure to benzene, a known carcinogen and a common additive to petroleum
hydrocarbons).
Construction workers would be at the greatest risk of exposure to
contaminated soil or groundwater, particularly if all hazardous materials in the soil or
groundwater are not identified adequately.
Implementation of the Proposed Project would involve replacement of manufacturing and/or
warehouse uses with a medical building, two above-ground garages, surface parking, a Central
Plant, and a clock tower. A number of VOCs and other hazardous materials have been
3.11-22
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identified in the soil and groundwater at the Project Site; therefore, construction of the
Proposed Project could expose persons to contaminated soils and/or groundwater, if
appropriate hazardous materials safety precautions were not undertaken.
In 1994, the DTSC completed a RCRA Facility Assessment (RFA) for the Project Site. The
RFA identified 24 solid waste management units and 18 areas of concern at the Project Site.
Since the RFA, the removal of contamination and closures of contaminant sources were
determined to be sufficient for the existing industrial/commercial uses; however,
redevelopment of the site as a hospital facility would require additional site remediation to
achieve the RWQCB’s ESLs for “Unrestricted Uses.”
On June 25, 2004, a RAP was submitted to the RWQCB for approval of the cleanup goals in
order to redevelop the site as a medical facility. An addendum to the RAP was prepared on
August 25, 2004. On August 31, 2004, RWQCB approved the RAP, including the addendum.
Eight locations have been identified in the RAP where remediation is necessary to cleanup the
site for PAMF-SCC.25 The current operator and owner, CPI, will close the facility and
transfer the title to 301 Industrial, LLC for implementation of the RAP, after which the title
will be transferred to PAMF for the construction of the proposed PAMF-SCC facilities.
Worker and public health and safety requirements would apply during remediation activities.
Potential adverse impacts of remediation would be minimized by legally required safety and
hazardous waste handling precautions. For example, DTSC’s hazardous waste laws and
regulations would be enforced locally by the CSMHSA. For hazardous waste workers,
Cal/OSHA regulations mandate an initial 40-hour training course for general site workers and
a 24-hour initial training course for occasional site workers and both require subsequent annual
training review and supervised on-the-job training. Site supervisors would be required by
OSHA to have eight additional hours of initial training. BAAQMD’s Regulation 11 requires a
written demolition plan for the demolition associated with the remediation activities.
301 Industrial, LLC must coordinate implementation of the RAP with the RWQCB both prior
and during implementation. These measures, along with application of cleanup standards
subject to review by responsible agencies, would serve to protect human health and the
environment during site remediation, thus reducing impacts.
Following site remediation, construction workers and the public could be exposed to residual
levels of contamination although the site has been cleaned. In accordance with the RAP
addendum, 301 Industrial, LLC, would conduct a post-remediation risk assessment. The
human health risk assessment would be performed for the entire site to determine whether
there may be health impacts. This assessment may show a residual potential for impacts. In
addition, although there have been numerous investigations to characterize site contamination,
there may be previously unidentified areas of contamination.
25
Northgate Environmental Management, Inc., Ibid.
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As explained in Impact HM-2, above, the approval of the RAP, including the addendum,
requires the use the RWQCB’s Residential ESLs as the Plan’s cleanup goals to allow for
“Unrestricted Uses.” “Robust confirmation sampling and analysis” would be required to
demonstrate satisfaction of the goals. This phrase means the required implementation of
contingency measures to reduce potential exposure during site remediation and construction.
If previously unidentified contamination were discovered, work in the immediate vicinity of
the potentially affected area would be required to be halted. The area would be investigated,
and, if contaminant levels exceed the minimum ESLs for “Unrestricted Uses,” the area would
be remediated consistent with the techniques in the RAP and addendum. The remediation plan
and work would be subject to approval by the RWQCB. 301 Industrial, LLC would perform a
Human Health Risk Assessment following remediation of the area, completed by a Registered
Environmental Assessor, or similarly qualified individual, experienced in health risk
assessments and approved by the RWQCB.
If the results of the assessment indicated residual contaminant levels were not at or below the
minimum ESLs for “Unrestricted Uses,” further actions would be stipulated by the RWQCB
and would be required to be implemented. Three examples of such types of actions are
described below.
•
If it were determined by sample collection and analysis that residual VOCs metals or
other chemicals of concern are present in soil and/or groundwater samples, the
impacted materials would be remediated in accordance with the RAP. Soil containing
chemicals above the remedial goals would be excavated and stockpiled separately from
non-impacted soils throughout the remediation phase. Soils containing chemicals at
concentrations above the remedial goals would be disposed at an appropriate permitted
off-site facility.
•
Alternatively, soil could be treated on site by aeration or biodegradation, in accordance
with BAAQMD regulations and the RAP. Remediation areas that extended into the
saturated zone could be kept open for a period of several days to several weeks, to
provide the opportunity for groundwater to seep into the excavations. Water entering
the excavations would be tested for chemicals of concern, and would be treated as
necessary prior to discharge into the sanitary sewer or storm drain (pursuant to local
agency permit) or hauled to an approved off site facility for treatment or disposal.
•
If elevated levels of hazardous materials were detected in dust over baseline levels,
more effective dust control measures would be implemented, including more frequent
watering of excavated materials, or more frequent covering of material that was
stockpiled at the point of excavation. If levels of detection at the construction site
perimeter did not exceed allowable levels of exposure for construction workers, no
further remediation would be necessary.
Actions similar to those examples listed above may be required by the RWQCB to demonstrate
satisfaction of the goals the ESLs for “Unrestricted Uses,” for the areas of residual
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contamination. Implementation of the RAP, including the addendum, would ensure that
potential exposure impacts from any residual soil or groundwater contamination would be less
than significant.
HM-4. Hazardous Waste Generation and Disposal Resulting in Increased Exposure Risk. The
Proposed Project would increase hazardous waste generation, but, by itself, would not
substantially increase risks of environmental exposure. (LTS)
Proper hazardous waste disposal, regardless of the method selected, often affects the
environment. Hazardous waste landfills generally leak at some point and occasionally fail.
Waste incinerators release toxic air contaminants into the atmosphere and result in ash that
contains unburnable hazardous constituents (such as metals). Most other treatment and
recycling methods result in hazardous residuals that must be disposed of as hazardous waste.
These residuals usually are incinerated or landfilled. For this reason, the generation and
disposal of hazardous waste is considered to be a form of pollution.
The Proposed Project would result in increased hazardous waste generation at the
301 Industrial Road site and thus contribute to the impacts identified above. The Proposed
Project is a new medical operation, rather than a relocation or expansion of an existing
facility. Consequently, estimating the amount of hazardous waste that the Proposed Project
might generate depends on using other medical facilities as models. Because there is no
readily available operational record for an existing facility of the same size on the Peninsula,
recent EIRs were examined for their approaches to hazardous waste generation estimates.
(The existing PAMF facility in Palo Alto offers some insight, but that facility does not include
an Inpatient Hospital.)
The approaches used in two EIRs relied on simple metrics relating the size of the facility, as
square feet of treatment area, and the size of the patient population, as numbers of persons
treated, to the increased generation of hazardous waste.
•
26
The hazardous materials chapter of the Peninsula Medical Center Replacement Project
EIR26 used the projected net increase in developed floor area (17 percent) and the
assumption that hazardous waste generation was correlated with the size of the medical
facility. The EIR projected a 17 percent increase in hazardous waste generation,
including hazardous chemical, radioactive, and medical wastes. Thus, the roughly
6.2 tons of medical waste produced annually at the approximately 498,000 square-foot
existing facility was projected to grow to about 7.3 tons with the completion of the
proposed approximately 582,000 square-foot facility.
City of Burlingame, Peninsula Medical Center Replacement Project Final EIR (consisting of the Draft EIR,
the Revised Draft EIR, the Response to Comments Documents, and the testimony and documentation
submitted by all interested persons), SCH # 2003072005, certified November 15, 2004 by Resolution
No. 105-2004, see Chapter 3.7, Hazardous Materials.
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•
The hazardous materials chapter of the Kaiser Redwood City Hospital EIR27 used the
projected net increase in Kaiser membership (17 percent) and the assumption that
hazardous waste generation was correlated with the number of patients seeking
treatment at the medical facility. The EIR projected hazardous waste generation to
increase from the 6,555 gallons of chemical waste produced annually by the
approximately 819,000-member existing facility to about 7.900 gallons with the
completion of the proposed approximately 957,000-member facility.
The two techniques produced similar results although they were based on different, but
related, parameters. Because the Kaiser project would be more than twice as large as the
Proposed Project, comparison was made to the Peninsula Medical Center Replacement Project.
The 465,825 square feet of medical space in the Proposed Project would be about 20 percent
smaller than corresponding space in the Peninsula Medical Center Replacement Project. Using
the square-footage-to-waste-generation relationship, the Proposed Project would generate an
estimated 5.8 tons of hazardous waste annually. Because the amount of hazardous waste
generation also would be a function of the mix of physicians at the Project Site (an unknown
factor, at present), the calculated figure is considered an approximation.
The regulatory framework described earlier under Applicable Plans and Regulations is
administered by DTSC, DSMHA, the Radiologic Health Branch of the CDHS. The
regulations require the use, storage, handling, transportation, and disposal of hazardous
materials and hazardous wastes be maintained at a level that would ensure interruption of the
exposure pathway between hazardous substances and the environment. PAMF-SCC would be
required to have in place and to maintain “cradle-to-grave” procedures to dispose of hazardous
wastes properly; would need to comply with the federal and state radiation control laws
described above (see Applicable Plans and Regulations); and, because the Project Site
probably would generate 200 or more pounds per month28 of medical waste, would be required
to implement a Medical Waste Management Plan. Compliance with these requirements, would
ensure the exposure pathway would be greatly restricted. Without a complete exposure
pathway, impacts from hazardous waste would be less than significant.
Hazardous Chemical Waste. Exposure of persons at the Project Site resulting from the
handling, storage, and disposal of hazardous chemical waste would be prevented using control
measures such as those listed in Table 3.11-3 for waste disposal. However, the likely effects
of hazardous waste disposal would probably occur far from the Project Site, because there are
no hazardous chemical waste landfills or incinerators located in the San Carlos vicinity.
California’s hazardous chemical waste generators rely heavily on out-of-state treatment and
disposal facilities to meet their disposal needs. No hazardous chemical waste incinerators in
California accept waste from third-party generators.
27
28
City of Redwood City, Kaiser Permanente Redwood City Medical Center Master Plan Draft Environmental
Impact Report, SCH # 2002092050, March 4, 2003, see Chapter 3.7, Hazardous Materials.
5.8 tons of hazardous waste per year divided by 12 months equals an average monthly generation of
0.48 tons (about 967 pounds).
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Radioactive Waste. The Radiologic Health Branch of the CDHS requires dry, long-lived
radioactive waste to be disposed of at a low-level radioactive waste landfill. The availability
of radioactive waste landfills to serve California’s low-level radioactive waste generators is
unreliable. California belongs to the Southwestern Low-Level Radioactive Waste Disposal
Compact, a group of four states that, together, are responsible for disposing of their low-level
radioactive waste. The intent of the Compact is to reduce the amount of low-level radioactive
waste produced in the member states and to provide regional disposal facilities sufficient to
dispose of the low-level radioactive waste generated within the region, including the member
states. The Compact specifies that California will provide a low-level radioactive waste disposal
facility for thirty years from when the facility first accepts low-level radioactive waste for
disposal. Following this period, the state who is the largest major generator of low-level
radioactive waste will host disposal facilities for the next thirty years. Since the early 1980s,
California has attempted to construct a low-level radioactive waste disposal facility at Ward
Valley, California, to serve the four states. In 1999, the Governor’s Advisory Group on LowLevel Radioactive Waste Disposal announced that they “will not consider the Ward Valley site
as part of its mission.”29 For this reason, California must rely on one out-of-state disposal
facility in Barnwell, South Carolina to accept its low-level radioactive waste. South Carolina
decides each year whether it will accept out-of-state radioactive wastes. The use of radioactive
materials at PAMF-SCC would minimally contribute to the demand for radioactive waste
landfills.
The handling of radioactive waste could result in exposure of workers or other individuals at
the Project Site; however, regulations by the CDHS Radiologic Health Branch would protect
workers and other individuals on site from exposure to radioactive waste. Compliance with
these regulations would reduce the potential exposure impacts to less than significant.
Medical Waste. Medical waste includes biohazardous waste and sharps. Currently, all
medical waste generated at the PAMF facility in Palo Alto is collected and hauled off-site by
California Medical Disposal, Inc., a licensed waste handler, three times a week. Treatment of
medical waste at the proposed PAMF facility in San Carlos would similarly occur off-site, and
transport of the waste would likewise be conducted by an authorized hauler, such as California
Medical Disposal, Inc., as required under the California Medical Waste Management Act.
Medical waste is generally regulated in the same manner as hazardous waste, except that
special provisions apply to storage, disinfection, containment, and transportation. The law
imposes a cradle-to-grave tracking system and a calibration and monitoring system for on-site
treatment. Medical waste would be stored in closed red bags marked “biohazard” and, when
transported for disposal, placed inside hard-walled containers with lids. Facilities that would
handle medical wastes must obtain permits to do so and would be subject to annual audits.
Compliance with these regulations would reduce the potential exposure impacts to less than
significant.
29
Atkinson, Richard C., Chairman of the Governor’s Advisory Group on Low-Level Radioactive Waste
Disposal, December 1999.
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HM-5. Emit Hazardous Emissions or Handle Hazardous Materials Within One-Quarter Mile of a
School. The Proposed Project is not within one-quarter mile of any existing or proposed
school. (NI)
The proposed PAMF-SCC would not emit hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one-quarter mile of an existing or proposed
school. No existing schools are located within one-quarter mile of the Project Site. The
closest schools to the Project Site are Central Middle School, located approximately 0.8 miles
west of the Proposed Project, Arundel School, located approximately 1 mile west of the
Proposed Project, and San Carlos Charter High School, located approximately 1.4 miles southeast of the Proposed Project. All other schools are located more than 1 mile away. Because
there are no existing or proposed schools within one-quarter mile of the Proposed Project,
there would be no impact.
HM-6. Occur on a Site Included on the Cortese List, a List of Hazardous Materials Sites. The
Proposed Project would not result in construction of facilities on a site included in the Cortese
List. (NI)
The PAMF-SCC site is not listed as a contaminated site under the Cortese List, the DTSC’s
Hazardous Waste and Substance List. Therefore, the Proposed Project would have no impacts
related to exposure of persons to hazardous materials on a site included on the Cortese List, a
list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.
HM-7. Occur on a Site Located Within an Airport Land Use Plan or Within Two Miles of a Public
Airport, and Result in a Safety Hazard. The Proposed Project would be located on a site
within the San Mateo County Comprehensive Airport Land Use Plan, but would not result in a
safety hazard. (LTS)
The Proposed Project would be located within the jurisdiction of the San Mateo
Comprehensive Airport Land Use Plan. A discussion of the Proposed Project’s consistency
with the Airport Land Use Plan can be found in Section 3.2, Land Use and Planning.
The risk to population surrounding the Airport is reflected in the actual accident history in and
around the airport, which can be extrapolated to future conditions. A study of the aviation
safety record of San Carlos Airport, a 160-acre single-runway general aviation airport east of
Highway U.S. 101, was done in 1989 in connection with an EIR being prepared at the time for
the Skyway Motel Project (now Extended Stay America) that is adjacent to the Proposed
Project. The following is a summary of the aviation safety study for the San Carlos Airport:
The analysis was updated from 1989: accident records were obtained from the
National Transportation Safety Board (NTSB) Accident and Database (web site:
www.ntsb.gov/Response2.asp). Events are classified as accidents when damage
occurs to the aircraft requiring repair before the plane can be airborne again.
Since the end of 1989 there have been 27 accidents associated with the San
3.11-28
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Carlos Airport.
operations.
This works out to 2.5 per year, or about 1 per 60,000
All but one of these accidents have been non-fatal. All except four have been on
the airport property and associated with either takeoffs or landings. The vast
majority of these accidents were unusually hard landings, emergency landings, or
landing gear failure. Anecdotally, the airport maintains a ‘scrapbook’ of
accident photographs that illustrates the relatively minor character of most
accidents. The one fatal accident occurred in February 2001 when the pilot of a
Cessna 150J collided with the guy wire of a radio tower about one-fourth mile
from the Airport runway, when coming into land under foggy conditions in the
early morning. The pilot was the only casualty.30
In addition, the Federal Aviation Administration (FAA) regulates air traffic at domestic
airports, including the San Carlos Airport. Federal Aviation Regulations (FARs) define
protection parameters (or imaginary surfaces) around the airport (see FAR Part 77).
City/County Association of Governments of San Mateo County (C/CAG), which acts as the
Airport Land-Use Commission for the County of San Mateo, adopted the Federal Aviation
regulations mentioned above as a part of the C/CAG Airport Land-Use Plan for the San Carlos
Airport.
The FAA requires formal notification for many projects. Developers or other parties that
propose buildings or alterations to buildings greater than 200 feet in height (above grade), or
structures within 10,000 linear feet of the airport that would penetrate a 50:1 plane sloping up
and away from the airport runway, must complete and submit FAA Form 7460-1 to the FAA.
The Airport Land Use Commission implements a state statute to further increase airport and
land-use compatibility in the San Carlos Airport environs. The Commission delegated this
responsibility to its advisory body, the C/CAG Airport Land-Use Committee (or ALUC).
Among other things, the ALUC reviews proposed buildings or building improvements in the
City of San Carlos that could affect air traffic. The ALUC reviews various elements of
planned improvements, including hot-air vents, rooftop antenna or other superstructures,
outside lighting fixtures, building functions that emit smoke, reflective exterior materials and
water features that could attract waterfowl or other birds.
In particular and importantly, the ALUC compares proposed building heights to permitted
horizontal surface elevations in the airspace surrounding the airport (the FAA calls these
horizontal surface elevations “imaginary surfaces”). For most of the properties in East San
Carlos, buildings must be less than 152 feet above mean sea level to ensure safe flights. The
Proposed Project at its tallest point would be about 100 feet above the existing grade at the
entry tower, or a maximum of 108 feet above mean sea level. Therefore, the Proposed Project
would have less-than-significant impacts with respect to aircraft safety concerns.
30
San Carlos Airport Master Plan Update, Airport Modernization Project , Draft Environmental Impact
Report, prepared by County of San Mateo Planning and Building Division, Environmental Services,
June 2002.
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Furthermore, the Proposed Project is within the area subject to the adopted San Mateo County
Airport Land Use Plan for the San Carlos Airport. The Airport Manager, Mark Larson
(Personal Communications 6 June 27, 2003) stated that the Palo Alto Medical Foundation
Complex would be subject to review by the San Mateo County Airport Land Use Commission.
HM-8. Occur on a Site within the Vicinity of a Private Airstrip, and Result in a Safety Hazard. The
Proposed Project would not be located within the vicinity of a private airstrip. (NI)
The Proposed Project would not be located within the vicinity of a private airstrip. Therefore,
the PAMF-SCC would result in no impact to the safety of those working or seeking treatment
at the Project Site because of proximity to a private airstrip.
HM-9. Interference with an Emergency Response and Evacuation Plan. The Proposed Project would
not impair implementation of, or physically interfere with, an adopted emergency response plan
or emergency evacuation plan related to hazardous material spill response. (LTS)
According to the General Plan, the major arterial streets in the vicinity of the Proposed Project
that serve as the principal evacuation routes in the event of an emergency are Industrial Road;
Holly Street; Old County Road (from Brittan Avenue to Bransten Road); Bransten Road; and
Commercial Street. Although the PAMF-SCC construction would involve road improvements
and partial and temporary road obstructions, the road obstructions would be subject to
coordination with and permitting through the City; therefore, impacts to evacuation plans,
which route access through Industrial Road, would be less than significant.
HM-10. Wildland Fire Risk. The Proposed Project would not expose people or structures to a
significant risk of loss, injury, or death involving wildland fires. (NI)
The Proposed Project and the surrounding vicinity are not located within the Wildland Fire
Hazard Zone identified in the San Carlos General Plan and therefore not in an area susceptible
to significant grass, brush, or tree fires. Furthermore, the Proposed Project would be required
to comply with all fire codes and regulations related to emergency services access. The
absence of wildland fire hazards means that the Proposed Project would have no impact on this
public health and safety risk.
Cumulative Analysis
The context for the analysis of cumulative hazards impacts is the City of San Carlos, including all
cumulative growth therein, which includes City-approved projects, foreseeable projects, and the 2003
Draft ESCSP, all of which are listed in Table 3.1-1. The cumulative hazards analysis is focused on the
Project Site vicinity, primarily the east San Carlos area, because the area of impact of the Proposed
Project in the event of hazardous materials spill or release would be nearby properties. Thus, the area
in which impacts of the Proposed Project could cumulate with impacts from other projects also would
be limited to areas relatively close to the Project Site.
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HM-11. Cumulative Hazards. Project-related hazardous materials use would not contribute to
cumulative human and environmental health and safety issues, including hazardous waste
generation and disposal. (LTS)
For significance criteria where the Proposed Project alone would have no impact, the
Proposed Project would not contribute to any cumulative impact in the Project Site vicinity,
both with and without implementation of the 2003 Draft ESCSP (for informational purposes, a
cumulative analysis without implementation of the 2003 Draft ESCSP is provided). The
Proposed Project would not emit hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one-quarter mile of an existing or proposed
school, and therefore would have no impact based on this significance criteria and would not
contribute to a cumulative impact. The Proposed Project would not be on a site included on a
list (Cortese List) of hazardous materials sites compiled pursuant to Government Code Section
65962.5, and therefore would not create a resultant significant hazard to the public or the
environment. therefore, it would have no impact based on this significance criteria, and would
not contribute to a cumulative impact. The Proposed Project would not be in the vicinity of a
private airstrip, and therefore would not create a safety hazard for people residing or working
in the vicinity of the Proposed Project. Consequently, it would have no impact based on this
significance criteria and would not contribute to a cumulative impact. The Proposed Project
would not expose people or structures to a significant risk of loss, injury, or death involving
wildland fires, and would not include areas where wildlands are adjacent to urbanized areas or
where residences are intermixed with wildlands. It would have neither an individual impact
nor would it contribute to a cumulative impact based on this significance criteria.
The health and safety hazards posed by most hazardous materials typically are local in nature.
They generally do not combine in any cumulative sense with the hazards of other projects.
Possible exceptions include potential toxic air contaminant emissions, transportation of
hazardous materials, and waste disposal. The need to respond to hazardous materials
emergencies could increase as a result of cumulative development. Each of these potential
cumulative effects is described below.
Hazardous Materials Use, Storage, and Handling. Development of the Proposed Project,
City-approved projects, other foreseeable projects, and the 2003 Draft ESCSP could increase
the overall quantities of hazardous materials being used, stored, or handled in the vicinity of
the Proposed Project. PAMF-SCC probably would use, store, and handle different hazardous
materials and potentially in greater quantities than are currently used, stored, or handled on the
Project Site under existing conditions, so PAMF-SCC would contribute to cumulative
increases in overall hazardous materials use, storage, and handling. Hazardous materials use,
storage, and handling has the potential to affect workers and other individuals on site, the
community, and the environment. Each project must comply with the laws and regulations
that apply to the use, storage, and handling of hazardous materials, as described in Impact
HM-1. This includes the regulation of hazardous materials management by CSMHSA,
pursuant to the State Health and Safety Code; complying with California’s Hazardous
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Materials Release Response Plans and Inventory Law by filing an HMBP with CSMHSA and
SCFA if a business uses or stores quantities of hazardous materials that exceed the state’s
thresholds; filing a Risk Management Plan if handling certain very hazardous substances in
excess of state thresholds, as required by the CalARP Program and federal law; complying
with the 2001 California Building Code; complying with the 2003 Life Safety Code;
complying with the 2001 California Fire Code; complying with RWQCB’s groundwater
protection program; complying with Cal/OSHA’s Hazard Communication Standard;
complying with OSHA’s Bloodborne Pathogen Standard; and complying with the California
Medical Waste Management Act. All projects that would involve the use, storage, and
handling of hazardous materials would be required to comply with these laws and regulations;
therefore, cumulative impacts related to hazardous materials use, storage, and handling would
be less than significant. In addition, compliance with the laws and regulations governing
hazardous materials use, storage, and handling would render the Proposed Project’s
incremental contribution to cumulative hazardous materials use and disposal less than
cumulatively considerable.
For informational purposes, a cumulative analysis without implementation of the 2003 Draft
ESCSP is provided here. Without the 2003 Draft ESCSP, some development within east San
Carlos, the project vicinity, would occur, including office and light industrial development at
951-981 Industrial Road, regional retail use at 1133 Industrial Road, and housing and office
developments along the JPB Railroad tracks. Thus, cumulative development without
implementation of the 2003 Draft ESCSP could increase the overall quantities of hazardous
materials being used, stored, or handled in the vicinity of the Proposed Project. The laws and
regulations governing hazardous materials use, storage, and handling described above would
apply to cumulative development without the 2003 Draft ESCSP. Therefore, without
implementation of the 2003 Draft ESCSP, cumulative impacts related to hazardous materials
use, storage, and handling would be less than significant.
Hazardous Materials Transportation. Hazardous materials are transported on virtually all
public roads, particularly because all motor vehicles contain hazardous materials (e.g., fuel,
heavy metals, etc.) in addition to any hazardous cargo that may be on board. The
transportation of hazardous materials is addressed by existing regulatory requirements
including packaging requirements for hazardous materials and wastes established by DOT,
USPS, and EPA to minimize the potential consequences of possible accidents during transport.
The vehicle accident rate in California is relatively low compared to other states and not all
accidents release hazardous materials.31 The transport of hazardous materials from sources
other than the Proposed Project, as well as from the Project Site, would be required to comply
with the regulations for the transport of hazardous materials. Because these regulations are
established to protect the public and environment from potential exposure and accidental
release, compliance with them ensures a less-than-significant cumulative impact from the
transport of hazardous materials. In addition, the Proposed Project’s contribution to hazardous
31
California Department of Transportation, 1996 Accident Data on California State Highways (Road Miles,
Travel, Accidents, Accident Rates), 1997.
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materials transportation would be less than cumulatively considerable, because it would not
represent a substantial increase in the amount of hazardous materials transported and it would
be required to comply with the existing regulations. For these reasons, the cumulative impact
of potential transportation-related accidents would be less than significant.
Because regulations for the transport of hazardous materials would apply to all projects,
related cumulative impacts would also be less than significant without implementation of the
2003 Draft ESCSP.
Construction-Related Hazardous Materials Disturbance. Because it was common building
practice to use materials with asbestos, PCBs, lead, and mercury in structures built prior to
1981, demolition of existing buildings in San Carlos could disturb these hazardous building
materials and cause adverse health or safety effects to construction workers, the public, and/or
the environment, if required hazardous materials safety precautions were not undertaken.
Adherence to applicable laws and regulations for these substances would ensure that potential
exposure impacts from these materials are less than significant, unless they are not identified
adequately prior to demolition. There could be potentially significant cumulative impacts in
San Carlos if the required hazardous materials surveys and proper management of hazardous
materials were not undertaken. As described in Impact HM-2, if any unidentified hazardous
materials were present in the existing buildings at the Project Site when demolition occurred,
these hazardous materials could create worker health hazards or result in environmental release
(or inappropriate disposal) of these hazardous materials. Pre-construction inspection for
asbestos, PCBs, lead, and/or mercury in existing on-site structures that were built prior to
1981 and the implementation of indicated remediation procedures is required by existing
regulations. The Proposed Project and other foreseeable developments would be required to
comply with these regulations and to implement the required procedures to prevent exposure of
persons to these hazardous materials. Consequently, construction-related hazardous materials
disturbance from the Project Site would be rendered less than significant through the required
implementation of the approved RAP, including the addendum. Therefore, the Proposed
Project’s contribution would be less than cumulatively considerable, with or without
implementation of the 2003 Draft ESCSP.
Exposure to Contaminated Soil and/or Groundwater. Site grading, excavation, and
construction of building foundations could expose construction personnel and the public to
existing contaminated soil and/or groundwater, if required hazardous materials safety
precautions were not undertaken. The potential for exposure to construction personnel would
be higher than for the general public, given their access to, and amount of time spent on, the
Project Site. Development in east San Carlos would involve replacement of manufacturing
and/or warehouse uses with residential, laboratory, retail, office, restaurant, or medical use in
all of its growth areas. Previous industrial uses in the growth areas may have created
contaminated soil and/or groundwater. Construction of replacement uses in the growth areas
would have the potential to expose persons to the contaminated soils and/or groundwater.
Cumulative development includes redevelopment of industrial (manufacturing and warehouse)
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sites which may contain contaminated soil and/or groundwater. The conversion of the sites for
sensitive uses, such as residential, would have the potential for long-term exposure risks.
Redevelopment of some industrial sites may expose persons to contaminated soils and/or
groundwater associated with industrial uses. There could be potentially significant cumulative
impacts in San Carlos if the required hazardous materials surveys and proper management of
hazardous materials were not undertaken on sites with contaminated soils and/or groundwater.
The Proposed Project’s incremental contribution to exposure to contaminated soil and
groundwater would be reduced to less than significant through the required implementation of
the approved RAP, including the addendum. Therefore, the Proposed Project’s contribution
would be less than cumulatively considerable.
Without the 2003 Draft ESCSP, some demolition within east San Carlos, the project vicinity,
would occur, including office and light industrial development at 951-981 Industrial Road,
regional retail use at 1133 Industrial Road, and housing and office developments along the JPB
Railroad tracks. There could be potentially significant cumulative impacts in San Carlos if the
required hazardous materials surveys and proper management of hazardous materials were not
undertaken on sites with contaminated soils and/or groundwater. The Proposed Project’s
incremental contribution to exposure to contaminated soil and groundwater would be reduced
to less than significant through the required implementation of the approved RAP, including
the addendum.
Toxic Air Contaminant Emissions. Cumulative development could increase the overall
concentrations of toxic air contaminants (TACs) in the east San Carlos area. Project-related
stationary and mobile emissions sources could contribute to this increase. The Bay Area Air
Quality Management District permitting process would require any stationary source that
would result in a substantial increase in the overall concentrations of TACs to conduct a health
risk assessment and implement appropriate control measures to reduce any associated
significant health risks. Thus, individual projects would be expected to reduce their
incremental contributions to cumulative impacts to less than cumulatively considerable.
As explained in Impact AQ-4 and AQ-6, Toxic Air Contaminants, in Section 3.5, Air Quality,
of this EIR, typical major stationary sources of TACs include industrial facilities, such as
refineries, and commercial facilities, such as dry cleaners. No such facilities would be
constructed at the Project Site nor are they on the list of approved or foreseeable developments
in the City of San Carlos or vicinity. Stationary sources of TACs from medical facilities
would be considered substantial only if sterilizers or medical waste incinerators were to be
installed and used. Plans for the Proposed Project do not include either type of equipment.
The main motor vehicle TAC emission is small-diameter particulate matter from heavy-duty
diesel trucks. The California Air Resources Board’s Air Quality and Land Use Handbook: A
Community Health Perspective (April 2005) identifies distribution centers, warehouses, and
other facilities that accommodate 100 or more diesel trucks per day as major sources of diesel
particulate matter TAC emissions. No such facilities would be constructed at the Project Site
nor are they on the list of approved or foreseeable developments in the City of San Carlos.
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The Proposed Project is expected to attract an average of 34 vehicles per day, of which only
two would be large diesel trucks. Therefore the incremental effects of increases in diesel
particulate emissions caused by implementation of the Proposed Project would be less than
significant, with or without implementation of the 2003 Draft ESCSP.
Given that there would be no impact from stationary sources, and that the contribution from
motor vehicles would be less than significant, TAC emissions would be less than cumulatively
considerable, with or without implementation of the 2003 Draft ESCSP.
Hazardous Waste Disposal. As development occurs in east San Carlos and at the regional
and state levels, more hazardous wastes would be generated. PAMF-SCC would likely
generate more hazardous waste than is generated under existing conditions, so PAMF-SCC
would contribute to cumulative increases in overall hazardous waste generation. The
incremental environmental effects of expected increases in hazardous waste generation and off
site hazardous waste recycling, treatment, and disposal would also contribute to cumulative
effects. Hazardous waste disposal can affect the environment by releasing contaminants to
land, air, and/or water. The cumulative increase in demand would, by itself, have little
observable effect on the levels of existing hazards that waste disposal poses to people, or to
animal or plant populations, either in east San Carlos or elsewhere. However, compliance
with existing laws and regulations governing hazardous waste transport and disposal would
render the cumulative impacts less than significant. Compliance with the same laws and
regulations would also reduce PAMF-SCC’s contribution to cumulative hazardous waste
disposal to less than cumulatively considerable. This conclusion applies to the cumulative
scenarios both with and without the 2003 DRAFT ESCSP.
Airport Safety. All of the projects in east San Carlos, including PAMF-SCC, are within the
jurisdiction of the San Mateo Comprehensive Airport Land Use Plan. The plan specifies the
Federal Aviation Regulations around the airport, and requires any proposed buildings or
alterations greater than 200 feet in height or within 10,000 linear feet of the airport that would
penetrate a 50:1 plane sloping up and away from the airport runway must be reviewed and
approved the ALUC. Compliance with the San Mateo Comprehensive Airport Land Use Plan
would ensure that all buildings, with and without the 2003 Draft ESCSP, would be within the
applicable building elevation requirements; therefore, there would be a less-than-significant
cumulative impact to air navigation hazards. Also, because the PAMF-SCC would be within
the applicable building elevation restriction established by the ALUP, the Proposed Project
would not make a cumulative contribution to air navigation hazards, both with and without the
2003 Draft ESCSP.
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Emergency Response. With or without cumulative development, a major emergency
situation, such as an earthquake, could generate demand for emergency response services in
excess of available resources. Other possible incidents that could create cumulative health and
safety impacts are accidental releases of hazardous materials in San Carlos or accidents along
US 101 involving vehicles transporting hazardous materials or hazardous waste. During an
earthquake, structures containing hazardous materials could be damaged. For earthquakes in
particular, non-structural seismic safety (e.g., the potential for falling containers and shelves
holding hazardous materials) would be of particular concern. Chemical spills and splashes
could harm individuals working in the vicinity of the hazardous materials. Safety requirements
enforced by the OSHPD, SCBD, and SCFA (e.g., securing certain types of containers and
installing lips on shelves where hazardous materials are stored) would serve to minimize such
risks. New construction built to current code requirements would be expected to perform at
least as well as or better than existing commercial/industrial facilities in the affected area.
Regarding hazardous material emergencies, the Proposed Project and other future development
in east San Carlos could combine cumulatively to increase the demand for hazardous material
emergency response services. This increase could force emergency responders to prioritize
among more than one hazardous material incident occurring at the same time. However,
multiple major hazardous material incidents are unlikely to occur simultaneously. SCFA would
provide first response capabilities in the event of any major accidental release of hazardous
materials. Level “A” hazardous materials response services have been provided countywide by
the SCFA since July 1984 through a cooperative service agreement with the CSMHSA.
SCFA, CSMHSA, and the Sheriff's Office of Emergency Services (OES) form the Hazardous
Materials Response Team that responds to hazardous materials emergencies anywhere in
San Mateo County. Emergency equipment includes fire, police, and ambulance vehicles and
equipment as well as OES Support One, a 40-foot-long bus, which contains office space and
communications capability, and OES Support Two, a 1-ton truck chassis with an enclosed
office in back. These vehicles can be immediately dispatched to respond to any emergency in
San Mateo County. Additionally, any roadwork that would occur on City arterials that provide
access/response routes during emergencies would require permitting and coordination with the
City. Therefore, the cumulative impact would be less than significant, both with and without
the 2003 Draft ESCSP. Also, with compliance with existing laws and regulations, the
Proposed Project’s contribution to a cumulative emergency response impact would be less than
cumulatively considerable.
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