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Brentwood School Education Master Plan IV.F-1 Draft EIR December 2015

IV.F HAZARDS AND HAZARDOUS MATERIALS

A. INTRODUCTION

This section evaluates potential human health and environmental impacts that could result from hazardous conditions and/or the known and likely presence of hazards and hazardous materials on the East or West Campuses. The information contained in this section is derived from Phase I Environmental Site Assessments (ESAs) prepared by Applied Environmental Technologies, Inc. (AET), dated July 25, 2008, and updated April 26, 2013, for each of the Campuses. The ESAs and Updates are included in Appendix IV.F, Phase I Environmental Site Assessments.

B. METHODOLOGY

The Phase I Environmental Site Assessments for the Brentwood School’s East Campus and the West Campus included a review of on-site conditions. This Assessment included a review of historical aerial photographs; City of Los Angeles building permit and Certificate of Occupancy records; information derived from searches of environmental databases for storage and spills of hazardous materials in the area; and a site reconnaissance to observe the existing physical conditions. An evaluation was made as to whether the on-site conditions, including the age of existing structures, would pose a health hazard during the demolition or construction operations. The School’s operations involving the use, storage, and transport of hazardous materials was also evaluated. Potential impacts from hazardous materials as a result of Project implementation was determined by applying the thresholds contained in the City of Los Angeles’s L.A. CEQA Thresholds Guide.1

C. EXISTING CONDITIONS

1. Hazardous Materials

Hazardous material refers to both hazardous substances and hazardous waste. A material is identified as hazardous if it appears on a list of hazardous materials prepared by a federal, State, or local regulatory agency or if it has characteristics defined as hazardous by such an agency. Hazardous materials and hazardous waste are materials that, because of their quantity, concentration, or physical and chemical characteristics, may cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness.

1 City of Los Angeles’s L.A. CEQA Thresholds Guide (December 2006).

IV.F Hazards and Hazardous Materials


Hazardous materials may also pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed, or otherwise managed. Hazardous waste would also include those materials described in Title 22, Division 4.5, Chapter 11, of the California Code of Regulations. The US Environmental Protection Agency (USEPA) defines the term “solid waste” to include many types of discarded materials, including any gaseous, liquid, semiliquid, or solid material that is discarded or has served its intended purpose, unless the material is specifically excluded from regulation. Such materials are considered waste whether they are discarded, reused, recycled, or reclaimed. In summary, the USEPA classifies a material as hazardous if it has one or more of the following characteristics at specific thresholds: ignitability, corrosivity, reactivity, and/or toxicity.2

2. Potential for Hazardous Materials at the Site

Existing Hazardous Materials and Handling

The East Campus and West Campus Phase I ESAs include a review of past and present land use practices and evaluate the presence or likely presence of hazardous substances or petroleum products that have been discharged on or within the Project site, thereby potentially impacting soil, groundwater, or surface waters. The Phase I ESAs also include a review of historical uses of the site, site field reconnaissance, and a review of database records for any known contamination at the site and surrounding properties. As part of the updates, AET updated the record of the site’s history and hazardous materials databases search and conducted additional site reconnaissance.

The East Campus is located on varying topographic elevations, with buildings and grounds located on the arroyo floor and the banks of the arroyo. The City of Los Angeles surveyed benchmark of 472.44 above mean sea level (amsl) is used for the East Campus. As provided in Section IV.E, Geology, the groundwater was measured between 15 and 22 feet below the surface; however, groundwater has been observed breaching the surface near the School’s track and field on the Veterans Administration (VA) property during heavy rain periods.

2 For more detail about the classification of hazardous materials, see the Comprehensive Environmental Response, Compensation and Liability Act of 1980, United States Code (USC), tit. 42, secs. 9601, et seq.; the Resource Conservation and Recovery Act, USC, tit. 42, secs. 6902, et seq.; the Federal Clean Water Act, USC, tit. 33, secs. 1251, et seq.; the Toxic Substances Control Act, USC, tit. 15, secs. 1601, et seq.; the Occupational Safety and Health Act, USC, tit. 29, secs. 651, et seq.; the California Hazardous Waste Control Act, California Health and Safety Code, secs. 25100, et seq.; the California Toxic Substances Control Act, California Health and Safety Code, secs. 25300, et seq.; the Porter-Cologne Water Quality Control Act, California Water Code, secs. 13000, et seq.; the Safe Drinking Water and Toxic Enforcement Act, California Health and Safety Code, secs. 25249.5, et seq.; as currently in force or as later amended, and all rules and regulations promulgated thereunder.



The West Campus is in the Westgate Heights area of the Santa Monica Mountains at approximately 438 feet amsl. Groundwater measurements at properties in the immediate vicinity (i.e., one-eighth mile) indicated that groundwater is expected to be approximately 100 feet below the surface near the West Campus. General topographic relief of the area (including both East and West Campuses) is toward the southeast, and the groundwater gradient is to the south.

A number of existing operations on the Campuses regularly transport, use, and/or dispose of small quantities of hazardous materials used for cleaning and for education purposes (e.g., in science labs). All hazardous materials stored, used, transported, and disposed of for these purposes are inventoried in compliance with federal and State regulations by the Brentwood School Operations. The Campuses’ maintenance crews store minor amounts of chemicals typical of school building cleaning and general maintenance, such as typical household cleaning chemicals, detergents, bleaches, minor amounts of interior or exterior paints, etc. Chemicals stored for ongoing maintenance are purchased in today’s market and meet current environmental standards; for example, none of the paint used on the Campuses for current maintenance contains lead. No visible paint on buildings contains lead. There may, from time to time, also be a limited amount of chemicals used for landscape maintenance, such as fertilizers or pesticides. On the East Campus, hazardous materials chemicals may include pool chemicals (e.g., cleaning chemicals, chlorine) for maintenance of the Caruso Watt Aquatic Center pool. To maintain Project amenities on a regular basis, grounds-keeping staff may store these items on site.

Methane Gas

Naturally occurring methane gas is known to occur in areas within Los Angeles and the surrounding region. Methane is a chemical compound that is the main component of natural gas, making up about 87 percent by volume. Natural methane is both colorless and odorless in its natural state. Although methane is nontoxic, it is flammable and can become explosive if mixed in the air in a high enough concentration. Methane also displaces air and therefore can become an asphyxiant under very high concentrations. If the concentration of methane is between 5 and 15 percent, the primary safety risk posed by methane is a risk of fire or explosion. Methane has the potential to migrate into buildings through porous surfaces or cracks in concrete floor slabs, unsealed conduits or utility trenches, unsealed dewatering sumps, and other small openings common in building construction. Because methane is a volatile gas, small sparks could cause it to ignite.



Large areas of Los Angeles must comply with new methane mitigation standards. Regulations on construction in these areas are required to prevent hazardous conditions from naturally occurring methane gas. The City of Los Angeles conducted soil testing throughout the City and mapped pockets of highly concentrated methane. These areas are identified as “Methane Zones.” Methane Zones are the highest risk zones and are surrounded by lesser-risk “Methane Buffer Zones” established by the City. According to the Methane and Methane Buffer Zones map (dated March 31, 2004), which was prepared by the City of Los Angeles Bureau of Engineering, the East and West Campuses are not located within a Methane Zone or Methane Buffer Zone.

Historical Land Uses

Aerial Photograph Review

Historical aerial photographs and topographic maps of the Project site and vicinity were reviewed to ascertain historical land uses of the site. The Project site topography contours have been altered by prior grading activities that include development of the on-site buildings and facilities, construction of the nearby roads, commercial uses, and residential uses that may have deposited soil on the East and West Campuses.

East Campus

The East Campus aerial photographs reviewed date from 1928, 1938, 1947, 1956, 1965, 1976, 1989, 1994, and 2002. At the time of the 1928 aerial photograph, the East Campus was vacant, with scattered residences and small orchards in the area. The 1938 aerial photograph indicates the East Campus contained a small building near the northwest corner and that the surrounding area had subsequently undergone significant residential development. The 1947 aerial photograph shows that grading activity was conducted on the Campus. By 1956, numerous structures began to appear on the Campus site, and commercial buildings to the south and west (west of Sunset Boulevard) of the Campus were constructed. By 1965, the parking lot southeast of the Campus near the commercial buildings (Brentwood Village) was constructed. In 1979, additional structures had been built on the Campus. No significant changes are noted between 1989 and 1994, except for the addition of a small parking lot (the North Parking Lot). The 2002 aerial photograph shows the addition of the athletic fields, tennis courts, and the middle gymnasium building.



West Campus

Because aerial photographs flown for the area encompassed both Campuses, the West Campus aerial photographs reviewed are for the same years as for the East Campus. They include: 1928, 1938, 1947, 1956, 1965, 1976, 1989, 1994, and 2002 along with similarities for descriptions of surrounding land uses. Based on the 1928 aerial photograph, the West Campus was vacant with scattered residences and small orchards in the area. The 1938 aerial photograph indicates that the West Campus contained a small building near the northeast corner and that the surrounding area had undergone significant residential development. The 1947 aerial photograph shows a new structure near the western property boundary. By 1956, additional structures began to appear on the Campus. At that time, residential development surrounded the Campus with the exception of the St. Martin of Tours Catholic Church and Elementary School buildings, which were constructed east of the Campus. The 1965, 1976, 1989, and 1994 aerial photographs show no significant changes occurring during this time frame. The 2002 aerial photograph shows a new building.

City of Los Angeles Building Department Records Review

East Campus

The City of Los Angeles has a history of building permits for the East Campus that indicates the ages of structures and past activities. The earliest record is a Certificate of Occupancy issued in 1948, which was followed by subsequent Certificates of Occupancy issued in 1949, 1950, 1954, 1956, 1990, 1997, 2002, and 2005. Numerous permits have also been issued for building alterations and repairs.

The Certificates of Occupancy for 1997, 1990, 2002, and 2005 were reviewed. Certificates issued prior to 1956 are no longer available. The 1997 Certificate of Occupancy was obtained by Brentwood School for the conversion of a classroom to an exercise and storage room. Certificates were issued in 2002 for a second-story addition to the existing Multipurpose Room/Bookstore and for the enclosing of a portion of this building to create a storage room. Certificates issued in 2005 were for the conversion of a storage structure into the Middle School Art Gallery and snack bar area, and for a second-story addition to an existing structure (the Student Life Center above the Cafeteria).

West Campus

The City of Los Angeles has a history of building permits for the West Campus that indicates the ages of structures and past activities. This parcel was initially developed by 1923 with a single-



family house that has evolved into the Admission Building.3 Since that time, numerous building remodeling and building repair permits have been issued for the Campus. In 1948, a Certificate of Occupancy was issued for the Marymount School, which had acquired the site in 1945. In 1984, a one-story workshop building was added. In 1995, a Certificate of Occupancy was issued for an increased classroom occupancy number for the existing three-story school building. In March 2000, a permit for a two-story Arts and Athletics Center, including a subterranean parking garage, was issued. In June 2001, permits were issued to add a second story to an existing one-story classroom building to be used as the music room.

Oil and Gas Development Records Review

The Munger Map Book: California-Alaska Oil and Gas Fields (2003 edition) assesses the presence of known active or abandoned oil and gas wells. No boundaries of oil or gas fields or wells were found to have been operated either on site or within 1 mile of the Campuses.

Polychlorinated Biphenyls (PCBs)

Transformers are typically installed to increase or decrease the voltage on a given circuit. Typical sources of PCBs include electrical transformer cooling oils, fluorescent light fixture ballasts, and hydraulic oil. PCBs are a probable human carcinogen that was widely used in many industrial and commercial applications because of their non-flammability, chemical stability, high boiling point, and electrical insulating properties.

In 1976, the USEPA banned the manufacture and sale of PCB-containing transformers. Prior to this date, transformers were frequently filled with a dielectric fluid containing PCB-laden oil. By 1985, the USEPA required commercial property owners with transformers containing more than 500 parts per million (ppm) PCBs to register the transformer with the local fire department, provide exterior labeling, and remove combustible materials within 5.0 meters of the transformer.4

Because many of the structures were constructed after 1976 and ongoing maintenance to the School Campuses is conducted to meet current standards, it is unlikely that PCBs would be present in the dielectric fluid of the transformer.

3 As discussed in Section IV.D, Historic Resources, the exact date of construction of this building is unclear. 4 40 Code of Federal Regulations 761.30: Fire Rule



Site Reconnaissance

Site reconnaissance for the East and West Campuses was conducted on July 15, 2008, and on April 24, 2013, by AET staff. The purpose of the field reconnaissance was to observe existing site conditions and ascertain the presence of physical evidence that indicates the presence of recognized environmentally hazardous conditions on the site. The site was inspected for the presence of visual and/or olfactory indications of contamination, distressed vegetation, petroleum-hydrocarbon staining, waste drums, illegal dumping, or improper waste storage or handling. During the site reconnaissance, AET staff found no evidence of above- or belowground storage tanks (USTs), pits, ponds, stained soil or asphalt, or stressed vegetation, petroleum-hydrocarbon staining, hazardous waste, waste drums, or improper storage of hazardous/regulated waste.

Existing Structures

East Campus

Founded in 1972, Brentwood School acquired the East Campus property from the Brentwood Military Academy, which had existed on the Project site since 1930. Historical photographs from 1932 show that the North Quad, Temple Hall, and the South Quad had been constructed. Temple Hall has been renovated a number of times over the years. In years 1982 through 1984, construction of the Gymnasium and Middle Division Building was completed; and, in years 1987 through 1990, construction of the five-story Science/Library/Theater (SLT) Building was completed. The Middle School Gymnasium Building was constructed between 1982 and 1984. The SLT Building was completed in 1990 as an expansion of the South Quad. In 2005, the Student Life Center remodel within the South Quad was completed, and the Caruso Watt Aquatics Center (pool) was completed in 2008.

West Campus

In 1994, Brentwood School purchased the West Campus site. The Main Classroom Building dates back to the 1940s. It was the original classroom building of the Catholic elementary school that preceded Brentwood School. The Arts and Athletics Center building, which accommodates parking on its lower level and a multipurpose room on the upper level, was completed in the early 1990s. On the Saltair Avenue side of the Campus are eight small structures, most of which are one-story modular buildings. The Admissions Building dates to the 1920s.



Based on the original date of construction of several of the on-site buildings, there is a potential that asbestos-containing materials (ACMs) may have been used in their construction and remain present. Asbestos, a naturally occurring fibrous material that has been mined for its useful thermal properties and tensile strength, was used in many commercial products, particularly building materials, manufactured from the 1940s until the 1970s. The ACM scan included building materials such as spray acoustic ceilings, acoustic tiles, various plasters, duct wrap, paper backing of linoleum, non-bituminous roofing felt, wallboard, joint compound (joint mud), and thermal insulation for pipes and boilers. Material that contains asbestos and is friable can become a health hazard. Friable materials can be crumbled, pulverized, or reduced to powder by hand pressure when dry. ACMs become a health hazard if they are disturbed. Intact asbestos fibers imbedded within construction materials and components are inert and do not pose a health hazard; however, once they are disturbed, through physical contact or building renovation and demolition activities, asbestos fibers may be rendered airborne and can enter the lungs. If inhaled, asbestos fibers can result in serious health problems.

Use of asbestos in the manufacturing of these building materials was banned by 1978, although some products remained on the shelf and were used in the construction of buildings and homes for several years thereafter. Some non-friable ACMs can become regulated asbestos-containing materials (RACMs) if pulverized during demolition activities.5 In general, buildings constructed prior to 1980 have the greatest potential to contain ACMs. Several of the existing buildings on both the East and West Campuses were built prior to 1978. Therefore, the potential for ACMs is considered high.

Asbestos is a known carcinogen and there is no known threshold level of exposure at which adverse health effects are not anticipated. The USEPA has identified asbestos as a hazardous air pollutant pursuant to Section 112 of the Federal Clean Air Act, Code of Federal Regulations, Title 40, CFR Sec. 61.01. Additionally, the California Air Resources Board (CARB) has identified asbestos as a toxic air contaminant (TAC) in the California Health and Safety Code, Section 39657.

Based on the original date of construction of the on-site buildings, there is also the potential for the presence of paints and coatings with detectable or elevated concentrations of lead. Coatings containing any detectable lead are regulated through the California Code of Regulations, Title 8, Section 1532.1, Lead in Construction. Building components and fixtures

5 RACM is any material that contains greater than 1 percent asbestos and is friable.



with a potential for lead-containing coatings include but are not limited to walls; windows; doors; window and door jambs; railings; poles; parking lot striping; and heating, ventilation, and air conditioning (HVAC) equipment. There is no lead in the paint on play equipment. Lead is a naturally occurring element that can result in poisoning when consumed or inhaled. Lead poisoning can cause anemia and damage to the brain and nervous system, particularly in children. Deterioration, damage, and disturbance of paints and coatings containing lead can result in hazardous exposure. Applicable regulations pertaining to the removal or disturbance of lead-containing paints and coatings are described in the Regulatory Framework section, which follows.

Database Records Review for the Project Site and Neighboring Properties

A government database report, prepared by Environmental Data Resources (EDR) of available federal, State, and county agency databases was reviewed to identify government-regulated properties having known recognized environmental conditions and potential environmental concerns near the Project site. The radii for each database search were selected in accordance with American Society for Testing and Materials (ASTM) Standards for Environmental Site Assessments. A description of the databases researched and a map illustrating the locations of the listed properties for both the East and West Campuses are included in the EDR Report, which is appended to the Phase I ESA and Phase I ESA Updates provided in Appendix IV.F.

East Campus

The East Campus property is identified on the Haznet database list (facility and manifest data). The Haznet hazardous waste information system contains data that is extracted from the copies of hazardous waste manifests received each year by the California Department of Toxic Substances Control (DTSC). According to the data report, the East Campus recycles and disposes of photochemical and photoprocessing waste, metal sludge, and other organic solids. Being listed on Haznet does not imply an environmental concern, but that the Project site has been properly permitted and hazardous wastes properly documented. No violations or environmental concerns were noted as these chemicals are typical activities for educational practices and Project site maintenance.

There are seven properties within one-eighth mile of the East Campus that were listed in the EDR report as Underground Storage Tank (UST), EDR Historical Auto Station, drycleaners, Resource Conservation and Recovery Act–Small Quantity Generator (RCRA-SQG), Facility Index System/Facility Registry System (FINDS), Haznet, emissions inventory data (EMI), Hazardous Waste and Substance Sites List (Cortese List), and leaking underground storage tank (LUST).



These lists do not imply violations, only that the site is properly permitted. However, two properties are known to have a subsurface hazardous materials impact. Five properties did not record any violations. These lists are explained in more detail in the following paragraphs.

Permitted Underground Storage Tank (UST): The permitted UST records contain a listing of all historical and permitted underground storage containers for hazardous materials usage. This database is maintained by the State Water Resources Control Board (SWRCB).

Resource Conservation and Recovery Act (RCRA), United States Code, Title 42, Sections 6901 et seq. Small Quantity Generator (RCRA-SQG): The RCRAInfo database includes selected information on sites that generate, store, treat, or dispose of hazardous waste as defined by RCRA. Conditionally exempt small quantity generators (CESQGs) generate less than 100 kilograms (kg) of hazardous waste, or less than 1 kg of acutely hazardous waste per month. Small quantity generators (SQGs) generate between 100 kg and 1,000 kg of hazardous waste per month.

Facility Index System (FINDS): FINDS contains facility information and also references other sources that contain more detail.

Hazardous Waste and Substance Sites (Cortese): This database from the California Environmental Protection Agency (CalEPA) identifies historic and current public drinking water wells with detectable levels of contamination, hazardous substance facilities selected for remedial action, facilities with known toxic material identified through the abandoned site assessment program, sites with USTs having a reportable release, and all solid waste disposal facilities from which there is known migration.

Leaking Underground Storage Tank (LUST): Records contain an inventory of reported LUST incidents. This database is maintained by the SWRCB.

The two properties that had recorded violations are a Chevron Station located at 110 S. Barrington Avenue approximately 0.10 mile south of the East Campus and a Texaco Service Station located at 115 S. Barrington Avenue approximately 0.12 mile south of the Campus. The Chevron Station is recorded as having had a leak or spilled gasoline into the subsurface soils and groundwater. However, this case was closed by the Los Angeles Regional Water Quality Control Board in 1997. The Texaco Service Station site is in on-going remediation for soil and groundwater contamination. This property is to the south and down gradient from the East Campus and is currently vacant. As such, this site does not affect the Campus.



West Campus

The West Campus property is identified on the Haznet database list. The Haznet hazardous waste information system contains data that is extracted from the copies of hazardous waste manifests received each year by the California DTSC. According to the data report, the West Campus is identified as having disposed of asbestos-containing waste. Again, being listed on HAZNET does not imply an environmental concern, but that the Project site has been properly permitted and hazardous wastes have been properly documented. No violations or environmental concerns were noted.

There is one property within one-eighth mile of the West Campus that was listed in the EDR report as EDR Historical Auto Station from 1933 and is listed as a gasoline and oil service station. The former station area is located downstream (south/southwest) of the Campus. As such, this site does not affect the Campus.

D. REGULATORY FRAMEWORK

1. Federal

Superfund Amendments and Reauthorization Act (United States Code, Title 42, Sections 11001, et seq.)

The Superfund Amendments and Reauthorization Act (SARA) amended the Comprehensive Environmental Response, Compensation, and Liability Act6 (CERCLA) on October 17, 1986. SARA reflected the USEPA’s experience in administering the complex Superfund program during its first 6 years and made several important changes and additions to the program. SARA also required the USEPA to revise the Hazard Ranking System to ensure that it accurately assessed the relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites that may be placed on the National Priorities List.

Resource Conservation and Recovery Act (United States Code, Title 42, Sections 6901, et seq.)

The RCRA gives the USEPA the authority to control hazardous waste from the “cradle to grave.” This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. The RCRA also set forth a framework for the management of nonhazardous wastes.

6 United States Code, tit. 42, sec. 9601, et seq.



The RCRA enables the USEPA to regulate underground tanks storing petroleum and other hazardous substances, including but not limited to, rehabilitation of contaminated soils resulting from environmental releases. The California Department of Toxic Substance Control implements RCRA in California via Unified Program Agencies. The City of Los Angeles Fire Department (LAFD) is the Certified Unified Program Agency (CUPA) responsible for administering the RCRA. The City contracts with the Los Angeles County Fire Department to administer the hazardous materials waste component of the Unified Program through its Health Hazardous Materials Division (HHMD).

National Emission Standards for Hazardous Air Pollutants (NESHAPs)

In cases where the presence of ACMs and lead-based paints is likely, State and federal standards are applicable. The USEPA’s Guidance Document 340/1-92-013, A Guide to Normal Demolition Practices under the Asbestos NESHAPs, should be referred to prior to the initiation of a demolition project.

Lead Exposure in Construction Interim Final Rule

Regulations on lead apply to all construction work in which lead is present in any amount.7

Construction work is defined as work involving construction, demolition, alteration, repair, painting, or decorating. The regulations require employers to implement stringent employee protection provisions, such as respiratory protection, biological monitoring (blood lead levels), training, and hygiene facilities prior to establishing exposure levels. Once an employer has conducted an initial exposure assessment, and depending on the results of the assessment, necessary changes can be made in the level of personal protective equipment, and the frequency of air and biological monitoring (blood lead levels) can be altered.

2. State

California Office of Emergency Services

The California Office of Emergency Services coordinates the emergency response to an accidental release of acutely/extremely hazardous materials.

7 Code of Federal Regulations, tit. 29, pt. 1926.62; California Code of Regulations, tit. 8, sec. 1532.1.



California Department of Toxic Substance Control

The California Department of Toxic Substance Control implements RCRA in California via Unified Program Agencies. The hazardous waste regulations are governed with by the California Code of Regulations, Title 22, Division 4.5.

Safe Drinking Water and Toxic Enforcement Act (Proposition 65)

The Safe Drinking Water and Toxic Enforcement Act, better known as Proposition 65, was passed into law by the voters of California in 1986. This Act was developed to improve public health by reducing the incidence of cancer and adverse reproductive outcomes that might result from exposure to potentially hazardous chemicals. To carry out this mission, Proposition 65 requires the creation of a list of chemicals and substances, and the levels at which they are believed to have the potential to cause cancer or deleterious reproductive effects in humans. The law also restricts discharges of these listed chemicals into known drinking water sources at levels above regulatory concern. Finally, in what is its main effect, the Act requires that a clear and understandable warning must be given prior to a known and intentional exposure to a listed substance. The Campuses are subject to the provisions of Proposition 65 due to the potential for exposure of persons to Proposition 65 listed chemicals.

California Department of Conservation, Division of Oil, Gas, and Geothermal Resources

The California Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR), regulates wells and the underground storage of natural gas and oil. The State requires the monitoring of gas storage fields by facility operators to ensure their safe operation and that no damage to health, property, or natural resources occurs.8 The State conducts quarterly and annual site inspections for technical and safety purposes, including testing and inspection of safety devices.9

California Occupational Safety and Health Act (Cal/OSHA)

The California Occupational Safety and Health Act (Cal/OSHA) was enacted in 1973 to protect workers and the public from safety hazards and to enforce California laws and regulations pertaining to workplace safety and health. Workplace safety is the prime responsibility of Cal/OSHA whether protecting workers who may handle hazardous material at an industrial site

8 Ibid., tit. 14, sec. 1724.10. 9 Ibid., tit. 14, sec. 1724.4.



or protecting certified personnel responsible for remediation of hazardous substances. California Code of Regulations, Title 8, Sections 337–340 require employers to monitor worker exposure levels to listed hazardous materials and to notify workers of exposure. Regulations stipulate the requirements for injury and illness prevention programs, proper equipment and use procedures, medical exams and training requirements, and reporting requirements.

3. Local

Los Angeles City Fire Code, Division 8

The lead agency regulating hazardous materials for the City of Los Angeles is the Los Angeles Fire Department. The Fire Department issues permits for hazardous materials handling, enforces the Waters Bill, as described previously, and administers the applicable sections of the Los Angeles City Fire Code, including Division 8, Hazardous Materials Disclosures. Businesses that store hazardous waste or hazardous materials must submit a Certificate of Disclosure to the Fire Department. The City of Los Angeles in conjunction with the County of Los Angeles Fire Department HHMD administers the following programs: the Hazardous Waste Generator Program; the Hazardous Materials Release Response Plans and Inventory Program; the California Accidental Release Prevention Program (Cal-ARP); the Aboveground Storage Tank Program; and the Underground Storage Tank Program.

South Coast Air Quality Management District

The South Coast Air Quality Management District (SCAQMD) regulates asbestos through Rule 1403, Asbestos Emissions from Renovation/Demolition Activities.10 Rule 1403 regulates asbestos as a toxic material and controls the emissions of asbestos from demolition and renovation activities by specifying agency notifications, appropriate removal procedures, and handling and cleanup procedures. Rule 1403 applies to owners and operators involved in the demolition or renovation of asbestos-containing structures, asbestos storage facilities, and waste disposal sites. SCAQMD also regulates volatile organic compound emissions from contaminated soil through Rule 1166, Volatile Organic Compound Emissions from Decontamination of Soil.11 Rule 1166 sets requirements to control the emission of volatile

10 Air Quality Management District (AQMD) Rule 1403, adopted by the SCAQMD on October 6, 1989, establishes survey, notification, and work practice requirements to prevent asbestos emissions from emanating during building renovation and demolition activities. AQMD Rule 1403 incorporates the requirements of the federal asbestos requirements found in National Emission Standards for Hazardous Air Pollutants (NESHAP) found in the Code of Federal Regulations, tit. 40, pt. 61, subpt. M.

11 AQMD Rule 1166, adopted by the SCAQMD on August 5, 1988.



organic compounds from excavating, grading, handling, and treating soil contaminated with volatile organic compounds as a result of leakage from storage or transfer operations, accidental spillage, or other deposition.

E. ENVIRONMENTAL IMPACT ANALYSIS

1. Significance Criteria

The L.A. CEQA Thresholds Guide requires the hazards analysis to address the following areas of study: (1) risk of upset/emergency preparedness; and (2) human health hazards.

1. Risk of Upset/Emergency Preparedness. The determination of significance shall be made on a case-by-case basis, considering the following factors:

• The regulatory framework;

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

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

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

2. Human Health Hazards. The determination of significance shall be made on a case-by-case basis, considering the following factors:

• The regulatory framework for the health hazard;

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

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

Based on these criteria, the Project would have a significant impact if it will:

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

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous chemicals into the environment.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school.



d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code, Section 65962.5 and, as a result, would create a significant hazard to the public or the environment.

e) Interfere with an existing emergency response or evacuation plan.

2. Regulatory Compliance Measures

The following measures would be required as a matter of compliance with existing regulations:

RCM HAZ-1: All hazardous materials and wastes on the Project site shall be acquired, handled, used, stored, and disposed of in accordance with all applicable federal, State, and local requirements.

RCM HAZ-2: Existing design and construction requirements and management practices shall continue at the Project site in accordance with applicable federal, State, and local regulations related to asbestos/asbestos-containing materials (ACMs), and lead-based paint.

RCM HAZ-3: In accordance with applicable federal, State, and local regulations, the design, construction, and maintenance of new development associated with the Project shall not include features that would use or expose persons to polychlorinated biphenyls (PCBs).

RCM HAZ-4: In the event that hazardous materials are encountered during grading and/or excavation activities anywhere on the Project site, earthwork shall be temporarily suspended to coordinate investigation/remediation efforts with oversight of the LAFD. An appropriately qualified environmental professional shall provide oversight and project monitoring to ensure the health and safety of all workers.

RCM HAZ-5: Prior to issuance of a demolition permit or building permit for the remodeling of any building, an asbestos survey and remediation report(s) shall be conducted on all structures to be demolished, removed, or remodeled (including modular buildings), and all asbestos removal shall be performed by an experienced, State-licensed, Cal/OSHA- and South Coast Air Quality Management District (SCAQMD)–registered asbestos contractor. All work shall take place under the guidance of an independent, California-certified asbestos consultant. The consultant shall be responsible for reviewing the Project drawings, designing engineering controls used to control airborne asbestos contamination, visually



inspecting engineering controls, and monitoring ambient air to determine airborne fiber levels.

RCM HAZ-6 Prior to issuance of a demolition permit or building permit for the remodeling of any building, a lead survey and remediation plan shall be approved and completed for all structures (including modular buildings) to be demolished, remodeled, or removed. Testing shall include a profile of waste characteristics for disposal in accordance with all local regulations. The lead surveys and remediation shall be conducted in accordance with all federal and State OSHA regulations, with remediation plans that outline specific work practices for handling lead. Any lead-containing paint shall be removed according to State and federal standards prior to demolition.

RCM HAZ-7 Electrical transformers, hydraulic elevator equipment, light ballasts, and other equipment suspected to contain PCBs shall be inspected for the presence of PCBs prior to any disturbance or removal. All equipment found to contain PCBs shall be removed and disposed in accordance with all applicable local, State, and federal regulations, including but not limited to CCR Title 22 and USEPA 40 CFR. In addition, a thorough assessment of any stained areas for the potential impact of PCBs and/or hydraulic oil is recommended. If impacted soil is identified, it shall be properly characterized, removed, and disposed of by a licensed hazardous materials contractor.

3. Project Impacts

Exposure to Hazardous Materials during Construction and Demolition

Demolition and renovation of the Project would involve the removal of approximately 72,541 square feet of existing facilities (43,660 square feet from the East Campus and 28,881 square feet from the West Campus). Each Campus would be graded for each building or ground improvements as required, with an estimated 43,25012 cubic yards of earthen material exported from the East Campus and an estimated 17,450 cubic yards of earthen material exported from the West Campus. Should the School construct a regulation-size football field in place of the Middle School Athletic Field, there would be an additional 5,500 cubic yards of soil exported from the East Campus.

12 The total would be 48,750 cubic yards if the School elects to construct a regulation-size Middle School Athletic Field.



On the East Campus, Temple Hall would be expanded by 960 square feet to accommodate additional administrative office space, and other interior renovations and minor modifications would be included. Renovations of other existing buildings would include interior renovations with modifications of space within the Science/Library/Theater Building, the North Quad, and the South Quad. The Middle School Gymnasium Building will be completely demolished. The Michael D. Pratt Academic Village is a modern modular set of buildings that will be removed in parts, with relatively minor demolition activity.

On the West Campus, demolition activities will include removing the parking lot near Saltair Avenue, the admissions building, and the classroom building. The child care, science, art, and music buildings, and community room buildings are modular and will be removed in pieces and will involve a relatively minor amount of demolition. The Arts and Athletics Center will undergo remodeling within the existing structure.

General Construction and Demolition

During building construction, hazardous materials such as fuels, paints, solvents, and concrete additives could be used. These hazardous materials require proper management and disposal. Improper management of any resultant hazardous wastes could increase the opportunity for hazardous materials to be released into soils and surface water runoff. Spills and leaks associated with construction-related substances such as coatings, soils, lubricants, paints, cleaning agents, and other fluids on the Campus sites would increase the potential for contamination and are general sources of potential short-term construction-related storm water pollution associated with Project implementation. The potential for construction materials to cause contamination will be reduced through the implementation of a stormwater pollution prevention plan (SWPPP), as provided in Section IV.G, Hydrology and Water Quality. Workplace safety is the prime responsibility of Cal/OSHA, whether protecting workers who may handle hazardous material at an industrial site or protecting certified personnel responsible for remediation of hazardous substances.

The demolition and construction activity would result in disturbances to underlying soils. In most cases, the soil disturbance will be minimal in preparing building pads and replacing existing concrete or asphalt surfaces. In some instances, there may be more extensive soils excavation, such as the subsurface Saltair parking lot on the West Campus or other soils that must be excavated and recompacted to meet geotechnical requirements on either Campus. Although no records of soil contamination are on file and no contamination has been observed during Phase I ESA investigations, it is possible that hazardous materials (not previously known)



could be uncovered during soil movement or subsurface excavations. Uncovering hazards materials could result in them becoming airborne or exposing construction workers or other people during the Campus long-term operations. In the event hazardous materials are discovered, earthwork would need to be suspended to assess the hazardous materials and to conduct any needed remediation efforts. Regulatory Compliance Measures, as described previously and required for the Project, would minimize the potential for exposure during earthwork. Therefore, the potential to uncover unknown hazardous materials is less than significant.

Asbestos-Containing Materials

Demolition of existing structures and remodels that require partial demolition could result in the release of ACMs. On the East Campus, the Project will include renovations to Temple Hall, the SLT Building, the North Quad and South Quad, the cafeteria, and the Student Life Center, and the demolition of the Middle School Gymnasium Building. On the West Campus, the Project will include demolition of the Main Classroom Building and the Admissions Building. Given the ages of the some of the structures, dating back to the 1920s, 1940s, and 1950s, these buildings could contain asbestos. Demolition may expose ACMs that may have been used in its construction including, but not limited to, drywall wall systems, vinyl flooring materials, flooring mastics, thermal insulation and acoustic materials, acoustic ceiling materials, stucco, window putty, piping, pipe fittings, and roofing materials. Federal and State regulations govern the renovation and demolition of structures where ACMs are present. All demolition that could result in the release of ACMs must be conducted according to federal and State standards.

The National Emission Standards for Hazardous Air Pollutants (NESHAP) mandates that building owners conduct an asbestos survey to determine the presence of ACMs prior to the commencement of any remedial work, including demolition. Regardless of the date of the building construction and because of potential unknown renovations, SCAQMD Rule 1403 (d)(1)(A) requires an asbestos survey report prior to demolition to determine and verify the absence or presence of asbestos. If ACMs are found, the abatement of asbestos would be required prior to any demolition activities. Given that these structures are surveyed for ACMs and their removal or stabilization is provided for pursuant to applicable regulations, demolition of these structures would result in a less than significant impact associated with the potential release and/or improper disposal of ACMs.



Lead Exposure

Similar to the potential for ACMs, older building materials commonly included lead-based paints or other coating substances. Since several buildings will undergo renovations and demolition, there is the potential for demolition workers or handlers of the resultant debris to be exposed to lead that may be within any lead-based building materials. Building components and fixtures with a potential for lead-containing coatings include but are not limited to walls, windows, doors, window/door jambs, railings, poles, parking lot striping, and HVAC equipment. If surfaces with these lead-based paints are improperly disturbed, removed, or disposed of, construction workers could be exposed to lead in unsafe concentrations. OSHA regulations are in place to ensure that these materials are safely removed prior to or during demolition and renovation activities. Since these structures must be surveyed for lead-based paints and their removal or stabilization is provided for pursuant to applicable regulations, the demolition of these structures would result in a less than significant impact associated with potential release and/or improperly disposal of building components coated with lead-based substances.

Polychlorinated Biphenyls

Removal of any equipment containing PCBs could result in potential release into the environment and exposure of construction workers and nearby building occupants to this substance. Since there are elevators on site constructed before 1984, there is a small possibility that hydraulic fluids for elevators may contain PCBs if the fluids have not been completely flushed since approximately 1984, although unlikely.13 Ongoing, elevator maintenance would test for PCBs and ensure the fluids meet current standards that prohibit PCBs. Also, there may be subsurface electrical circuits that could pose an electrocution hazard to construction workers. Removal, if required, would comply with local, State and federal regulations. In addition, no new electrical systems installed as part of the Project would contain PCBs. Therefore, the Project would not expose people to substantial risk resulting from the release or explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards associated with PCBs. Therefore, no significant human exposure to PCBs is anticipated from operation of the Project.

13 USDA, Forest Service, Technology and Development, “Is there a problem with hydraulic fluid?” http://www.fs.fed.us/eng/toolbox/haz/haz24.htm. Accessed December 19, 2014.



Exposure to Hazardous Materials Generated in the Project Vicinity

Facilities with Hazardous Materials

The East and West Campuses are located near properties that have been identified as hazardous materials sites. A Phase I ESA was conducted for each Campus. The reports determined that neighboring properties within a one-eighth-mile radius identified hazardous materials sites (described previously) that do not represent an environmental concern to the Project site. The determination is based on the reported operations at the facilities, the regulatory status of hazardous materials incidents at the facility (e.g., closed case), the distance between the facility and the site, or the hydrogeologically cross-gradient location. In addition, site reconnaissance revealed neither the presence of improperly stored hazardous chemicals nor any evidence of spills. Therefore, on-site impacts related to nearby hazardous materials sites are considered less than significant.

Methane Gas

As discussed previously, according to the Methane and Methane Buffer Zones map prepared by the City of Los Angeles Bureau of Engineering, the Project site is not located within a City-designated methane buffer zone. Based on the City’s mapping, potential impacts relative to methane gas during construction or operation of the Project are not expected, and methane mitigation measures to prevent the seepage of methane into the structures are not necessary. Should methane gas be discovered, the Project would be required to comply with Cal/OSHA requirements, the City’s methane seepage regulations, and the specifications of the Los Angeles Department of Building and Safety (LADBS). Impacts from methane gas would be less than significant.

New Uses Involving the Use, Storage, or Disposal of Hazardous Materials

Implementation of the Project could expose people to the risk of upset involving the use, storage, or disposal of hazardous materials. A number of existing operations on both Campuses regularly transport, use, and/or dispose of small amounts of hazardous materials used for education and cleaning purposes. Hazardous materials to be used and stored on the East and West Campuses are limited to those typically associated with general maintenance of the School grounds and for educational purposes, such as science applications. These chemicals are considered hazardous if spilled into the environment or ingested. Brentwood School Operations oversees the transport, use, and/or disposal of the existing hazardous materials used and generated on Campus, and all waste is transported by certified hazardous waste haulers. Implementation of the Project would not introduce new hazardous materials onto either the



East or West Campus, but quantities of existing hazardous materials on the East Campus could incrementally increase as the Campus population increases with additional academic, administrative, and athletic facilities. Brentwood School Operations maintain Unified Program forms, which include an inventory of chemicals, the amounts, and storage. These forms are routinely inspected by the LAFD. Any increases in chemicals will be inventoried as part of the Unified Program and would be subject to the regulatory existing programs, policies, and procedures related to hazards and materials safety. In the event of a real or potential release, the emergency procedure for hazardous materials spills and releases would be employed. This procedure requires notification to the LAFD and CalEPA. Given that any increases in transport, use, storage, and disposal of hazardous materials would be minimal and would be regulated under health and safety plans, potential impacts would be less than significant.

Emergency Response and Evacuation

The Brentwood School maintains a Hazardous Materials Business Plan (HMBP) in accordance with the City of Los Angeles HHMD. These documents provide procedures addressing any releases of hazardous materials or hazardous waste. The HMBP identifies the staff responsible for notifying the LAFD in the event of an accidental release, the staff responsible for release response, and emergency medical facilities and describes alarm systems, evacuation procedures, and preventative measures. Should a hazardous waste incident occur on site, on-site personnel would respond pursuant to the HMBP and, depending on the type and location of the spill, the City or County Fire departments would respond.

In the event of a spill, fire, or other emergency, emergency vehicle access to the East and West Campuses would continue to be provided as it occurs now. For the East Campus, emergency access and evacuation routes include the two entrances along Barrington Place. The Campus provides both primary and secondary access to allow for incoming emergency response vehicles to enter at the same time that occupants of the School can exit. In addition, should emergency response be necessary immediately near the portion of the Campus near Layton Drive, emergency vehicles can park along Layton Drive, and pedestrian access or exits can be directed through the gated entry near Temple Hall. A new emergency access only gate would be added adjacent to the Middle School Athletic Field to provide emergency access to the field and adjoining areas. Furthermore, as discussed in detail in Section IV.J, Transportation and Circulation, impacts on access points to the East Campus site would be less than significant. At the West Campus, emergency vehicles and response personnel would be able to access the grounds and buildings from Saltair Avenue and Bundy Drive.



Within each of the Campuses, emergency access would be provided by setbacks between buildings and wide landscaped pedestrian plazas and athletic fields. At the time of building permit application, the LAFD would review the site plans to ensure that emergency response access and evacuation is adequate and meets both Fire Code and Building Code standards. Thus, the Project would result in less than significant impacts on emergency response and evacuation.

4. Cumulative Impacts

A cumulative hazards impact would occur if any related projects identified in Section III, Environmental Setting and Related Projects that would be located near the Project would contribute to a cumulative risk of release of a hazardous substance into the environment or a cumulative increase in the transport, use, or disposal of hazardous materials. As shown in Figure III-1, Related Projects Map, in Section III, Environmental Setting and Related Projects, the majority of related projects propose residential, retail, office, or civic (e.g., school, fire station) uses. No related projects would require the routine transport, use, or disposal of hazardous materials in quantities that could pose a significant safety risk. Furthermore, all related projects must comply with federal, State, and local procedures for the safe removal and remediation of any hazardous substances. Additionally, because all related projects are located within existing emergency response service areas with adequate roadway access, no related projects would require a new emergency response or evacuation plan, or would interfere with an existing emergency response or evacuation plan. Because the Project is also located within the area currently served by emergency response services and thus access is available to the Project, and because environmental safety impacts of the Project would be unique to the site and less than significant, the Project would not contribute to a cumulative impact in conjunction with related projects. As a result, the Project’s cumulative hazards impact would be less than significant.

5. Mitigation Measures

Through compliance with Regulatory Compliance Measures, impacts would be less than significant. No mitigation measures are required.

6. Residual Impacts

Project-specific impacts and the Project’s contribution to cumulative impacts with respect to hazardous materials would be less than significant.

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