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ADDENDUM TO
WESTSIDE SPECIFIC PLAN
ENVIRONMENTAL IMPACT REPORT
A. Introduction
On August 3, 2010, the City Council of National City adopted the Westside
Specific Plan and certified the environmental impact report (EIR). The EIR
addresses the potential environmental impacts and provides a mitigation,
monitoring and reporting program for the Westside Specific Plan and a project
specific transit oriented development (TOD).
The Westside Specific Plan is a detailed plan for a 100-acre neighborhood
located within the incorporated limits of National City; bounded by West Plaza
Boulevard to the north. Interstate 5 to the west, West 24th Street/Mile of Cars
Way to the south, and Roosevelt Avenue to the east (Figure 1). The purpose of
the Westside Specific Plan is to reestablish the area as a "safe, healthy, and
vibrant neighborhood where people engage in community life." The plan provides
for retention and expansion of residential uses and amortizing industrial uses that
are determined to be polluting and hazardous to the health and well being of
local residents. The EIR addresses the potential environmental effects of plan
implementation.
Additionally, the EIR (State Clearinghouse No. 2008071092) addresses a project
specificl4-acre infill transit -oriented affordable housing project (Figure 2)
(referred to as TOD project) and analyzes potential impacts associated with the
development. The TOD project is located in the southern portion of the 100-acre
Westside neighborhood; bounded by West 19th Street to the north, Hoover
Avenue to the east, West 22nd Street to the south, and Wilson Avenue to the
west (Figure 1). The 14-acre site is segmented by Paradise Creek, undeveloped
and parks west of the creek and the City's public works yard and related
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buildings and a prior storage bus yard (referred to as the ille site) to the east of
the creek.
The Westside Specific Plan EIR (WSPEIR) acknowledged that the TOD project
site contained hazardous materials. The TOD project site is considered a
"brownfield" for environmental purposes (EIR pp4-25). Impact discussion
included recognizing that the site contains contaminated soils and hazardous
materials and would require removal and transportation of these materials off -site
to an appropriate location. The potential exposure to workers, residents, or the
environment was considered a significant hazard, yet impacts would be less than
significant with the mitigation measures incorporated in the Westside Specific
Plan EIR.
Since the certification of the EIR, steps have been conducted to remove
hazardous materials on the TOD site in order to develop the site for multi -family
residential uses as planned. A work program was prepared for the TOD site
consistent with the project described in the EIR and with mitigation efforts
contained in the EIR. At the time the EIR was prepared the proposed
remediation actions were described in general terms and these remediation
steps have not changed. However, there are technical details that have been
identified through the preparation of a Property Mitigation Plan (PMP) prepared
for the site that are discussed in this Addendum. The purpose of this Addendum
is to ensure that the remedial actions of the work program contained in the PMP
are consistent with the EIR and additional environmental review would not reveal
any additional impacts or mitigation measures.
CEQA Guidelines:
Section 15164 of the CEQA Guidelines provides the authority for preparing an
Addendum to a certified EIR or adopted Negative Declaration. Specifically,
Section 15164 states the following:
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"(a) The lead agency or responsible agency shall prepare an addendum to a
certified EIR if some changes or additions are necessary but none described in
Section 15162 calling for preparation of a subsequent EIR.
(b) An addendum to an adopted negative declaration may be prepared if one
or more changes or additions are necessary or none of the conditions described
in section 15162 calling for the preparation of a subsequent EIR or negative
declaration.
(c) An addendum need not be circulated for public review but can be included
in the Final EIR or adopted negative declaration.
(d) The decision -making body shall consider the addendum with the final EIR
or negative declaration prior to making a decision on the project.
(e) A brief explanation of the decision not to prepare a subsequent EIR
pursuant to Section 15162 should be included in an addendum to an EIR, the
lead agency's findings on the project, or elsewhere in the record. The explanation
must be supported by substantial evidence.
According to Section 15162, once the EIR has been certified, a lead agency
need not prepare a subsequent EIR unless "on the basis of substantial evident in
Tight of the whole record one or more of the following:
(1)
Substantial changes are proposed in the project which will require major
revisions of the previous EIR or negative declaration due to the
involvement of new significant environmental effects or a substantial
increase in the severity of previously identified significant effect.
(2) Substantial changes occur with respect to the circumstances under which
the project is undertaken which will require major revisions of the previous
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(3)
EIR or Negative Declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified significant effects; or
New information of substantial importance, which was not known and
could not have been known with the exercise of reasonable diligence at
the time the previous FIR was certified as complete or the Negative
Declaration was adopted, shows any of the following:
A) The project will have one or more significant effects not discussed
in the EIR or negative declaration
B) Significant effects previously examined will be substantially more
severe than shown in the previous EIR.
C) Mitigation measures or alternatives previously found not be feasible
would be feasible, and would substantially reduce one or more
significant effects of the project proponents decline to adopt the
mitigation measure or alternative; or
D) Mitigation measures or alternatives which are considerable different
from those analyzed in the previous EIR would substantially reduce
one or more significant effects on the environment, but the project
proponents decline to adopt the mitigation measure or alternative.
CEQA Guidelines §15162
The PMP provides a more comprehensive work program than the work program
identified in the EIR. The details of the work program are the subject of this
addendum, which will be reviewed and approved by the Department of Toxic
Substance Control (DTSC) and the San Diego County Department of
Environmental Health (DEH). The removal of hazardous materials was
anticipated in the EIR and already discussed in concept. The PMP details are not
"new information of substantial importance" that would result in new or greater
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impacts not discussed in the EIR, but rather technical details requiring
explanation and confirmation as explained in this Addendum.
Property Mitigation Plan (PMP)
The Mitigation, Monitoring, and Reporting Program of the EIR specify that a work
plan for any remediation of the removal of hazardous materials be prepared. On
March 23, 2102, a Property Mitigation Plan (PMP) for the Transit Oriented
Development Area was prepared by E2ManageTech for the City of National City.
The PMP describes the TOD site and the community outreach conducted during
the preparation and adoption of the TOD plan within the Westside Specific Plan
and EIR. The PMP provides a detailed description of the level of effort conducted
to identify, monitor, dispose, remove, and remediate the hazardous materials.
Phase I and Phase II assessments were completed on both the 4.5 acre public
works yard, 2100 Hoover Avenue, 1.25 Illes site, 2020 Hoover Avenue, and
Phase I for parcels on the west side of the creek, referred to as the Park Side
Area (Figure 3). The PMP provides a Work Plan for additional remediation as
necessary for the Isles site and Park Side Area. The Work Plan is consistent with
the Work Plan identified in the EIR, MM HAZ-2.
The purpose of this PMP is to provide summary -level background information
regarding historic land -use activities within the Project Area, summarize
ESA/investigation studies that have been completed, identify and describe the
COC-impacted areas, and provide a Conceptual Site Model to present a
roadmap for remediation the COC impacted areas within the Project Area.
The objectives of the PMP are to:
• Present and evaluate existing conditions at previously identified Areas of
Concern (ADCs) within the Project Area.
• Establish appropriate removal action objectives for protection of human
health and the environment.
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• Present cleanup approaches for AOCs that warrant removal actions.
The PMP is consistent with the anticipated plan analyzed in the EIR. In
describing the remedial action to be performed on the TOD site, the EIR states:
"The TOD project would require earthwork on soils east and west of Paradise
Creek that have been identified as brownfield sites. The redevelopment of
existing contaminated sites would create a significant hazard to the public or
environment through the reasonable foreseeable upset and accident conditions
involving the release of hazardous materials in the environment. Therefore,
earthwork activities could potentially release hazardous materials in to the
surrounding environment. Impact would be significant. Mitigation measures are
proposed as part of the Westside Specific Plan. Program EIR, as describe in
Section 3.9 "Hazards and Hazardous materials (MM HAZ-1, MM HAZ-2, and MM
HAZ-3) that would reduce this impact. Moreover, additional mitigation measures
may be identified once project specific details are finalized.
These statements demonstrate that the work plan detailed in the PMP was fully
contemplated in the EIR and thoroughly analyzed below. As required by CEQA
subsection (e) substantial evidence supporting the lead agency's decision not to
prepare a subsequent EIR pursuant to Section 15162 as a result of the details
identified in the PMP is provided in Section C, Environmental impact Analysis.
The environmental analysis presented in Section C evaluates the potential
impacts of the changes specifically in light of the environmental findings in the
previously certified EIR. This evaluation demonstrates that technical information
contained in the PMP would not create new or greater environmental impacts
than those identified in the previous EIR, and as such, a subsequent EIR to
address this new information is not required.
B. Environmental Site Assessments (PMP Summary)
As discussed in the PMP, Two Phase I Environmental Site Assessments were
completed for the subject areas included in the WI-TOD development area.
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Specifically, a Phase I ESA was completed for the parcels that comprise 2100
Hoover Avenue and 2020 Hoover Avenue in February 2009 and January 2010,
respectively. In 2013, two additional Phase I ESAs were completed for the same
properties; however, the project areas for these most recent Phase I ESAs were
defined by development phases (i.e., Parcel 1 and Parcel 2) for the WI-TOD
project area.
Subsequent to completing the 2010 Phase I ESAs for both properties (i.e., 2100
and 2020 Hoover Avenue) a Property Mitigation Plan (PMP) was prepared and
submitted to the Department of Toxic Substances Control (DTSC) and the
County of San Diego Department of Environmental Health (DEH) for review and
approval. The PMP was prepared in compliance with the Environmental
Oversight Agreement Number 11-T1032 between the DTSC and the City of
National City. The PMP was also prepared in compliance with the California
Health and Safety Code Sections 25323.1 and 25356.1 as well as the California
Environmental Protection Agency (Cal -EPA) DTSC guidance memorandum titled
Removal Action Work Plans — Senate Bill 1706 dated September 23, 1998.
The PMP was partially approved by the DTSC and DEH in May 2012 and July
2012, respectively. The partial approval allowed the City to proceed with site
assessment/investigation related activities described in the PMP. Full approval
will allow for the City to proceed with removal actions after appropriate California
Environmental Quality Act (CEQA) actions have been completed with respect to
the clean-up actions described in the PMP.
The PMP describes the existing environmental contamination associated with
eight (8) Areas of Concern (AOCs) (Figure 3), establishes removal action
objectives for protection of human health and the environment, and presents
cleanup approaches for AOCs that warrant removal actions at the proposed
Transit Oriented Development (TOD). The AOCs consist of eight separate
locations where further investigation and/or mitigation will be required during the
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construction phase of the proposed affordable housing redevelopment project.
The chemicals of concern include the following: petroleum hydrocarbons from
former leaking underground vehicle lifts; petroleum hydrocarbons and volatile
organic compounds (VOCs) from former leaking underground storage tanks
(USTs); diesel fuel and VOCs from UST and oil/water separator (OWS) features;
VOCs, polychlorinated biphenyls (PCBs), organ chlorine pesticides (OCPs), lead,
and semi -volatile organic compounds (SVOCs); lead, antimony, arsenic, Aroclor
1254, Aroclor 1260, and chlordane in surfciai soil; and, VOCs in soil gas.
Supplemental investigations are recommended for AOCs for which the extent of
contamination is not adequately defined by prior environmental site
investigations. As such, the objective of the recommended supplemental
investigation actions is to augment data that were collected in prior investigations
and delineate the horizontal and vertical extent of contamination. Recommended
actions resulting from the supplemental investigations will be based on
anticipated land -use within the TOD project area and the potential for future
residents or occupants to be exposed to chemicals of potential concern.
The overall goal of the removal actions recommended for each AOC is to
manage or eliminate the potential for future residents, construction workers, site
visitors, and/or biological receptors to be exposed to COCs above acceptable
thresholds. Thus, the primary goal is to close the AOCs located on the east side
(ADCs -01, -02, -03, -04, and -08) of Paradise Creek based on unrestricted [and
use thresholds. However, if it is more economical to close an AOC using a
remediation alternative that would result in a deed restriction, these alternate
remediation alternatives will be considered. Because the City intends to
renovate the property located on the west side of Paradise Creek for active and
passive park purposes and does not plan on building residential homes in this
area, the City plans on closing these AOCs (ADCs -05, -06, and -07) based on
the intended land use.
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During the proposed site investigation and cleanup activities, decisions for
additional investigation and/or cleanup activities will be based on a comparison of
the analytical data with published health screening goals including but not limited
to California Human Health Screening Levels (CHHSLs) and Environmental
Protection Agency (EPA) Region 9 Regional Screening Levels. Soil analytical
data will be compared with residential land -use screening levels associated with
the above referenced health risk standards.
Potential risks to human health associated with soil, soil gas, and groundwater
samples collected from the eastem half of the TOD Project Area will be
evaluated in accordance with the DTSC's Guidance for the Evaluation and
Mitigation of Subsurface Vapor Intrusion to Indoor Air (October, 2011). As such,
a human health risk assessment will be completed using site -specific data and
pa ram eters.
Immediately upon receiving the analytical data associated with the supplemental
site investigation activities for each of the AOCs, a site -specific health risk
assessment will be completed in consideration of the proposed functional use
activity. The results of the risk assessment will be presented in a brief
Supplemental Site Investigation Memorandum (SSIM) with recommendations for
further characterization, delineation, removal action, and/or closure.
Removal action implementation includes actions at AOCs-01, 05 and 08. At
AOC-01 elevated concentrations of TPI 1 were detected in soil samples collected
in the vicinity of the former hydraulic lifts. It is estimated that approximately 200
cubic yards (cy) of TPH-impacted soil would be transported offsite for disposal at
this location. At AOC-05, stockpiled soil is reported to consist of historically
disposed street sweeping waste. it is estimated that approximately 3,300 cy
(approximately 4,600 tons) of stockpiled soil exists. Based on the calculated
volume of stockpiled soil, it is estimated that approximately 230 truckloads would
be required to haul the stockpiled soil. The results of characterization of the soil
stockpiles will indicate whether the stockpiled soils will be disposed of as non-
hazardous, California non-RCRA hazardous, or RCRA hazardous, The
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excavated soil will be transported via roll -off bin hauling trucks, end -dump or
bottom -dump trucks. At AOC-04, soil that was determined to contain VOCs
above the cleanup goals will be removed and transported off site for disposal at
an appropriate facility. It is estimated that less than 10 cy of impacted soil will be
removed. It is planned that the minor excavation at AOC-08 will be conducted
concurrent with the excavation conducted with AOC-01. After all of the impacted
soils have been removed from the AOCs described above, a representative
number of confirmation soil samples will be collected from the bottom and
sidewalls of the excavation. Each of the confirmation soil samples will be
analyzed for chemicals of concern to confirm that a sufficient volume of impacted
soil has been removed and that chemicals of concern do not exist at
concentrations above the cleanup goals.
In consideration of the redevelopment schedule, it is anticipated if additional
removal actions that may be warranted for AOC-02, 03, 06, and 07 may include
soil excavation of installation of a vapor barrier. The decision for the appropriate
removal action will be described in a Technical Memorandum that will be
prepared after each of these AOCs is further investigated. The Technical
Memorandum will be submitted to the DTSC for its review and approval.
Upon completion of all field activities described in the PMP, all the data and
Technical Memoranda prepared will be organized into a PMP Completion Report
that will be submitted to DTSC for its review and approval that all the work has
been completed to its satisfaction.
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C. Environmental Analysis
The information below addresses each of the environmental issues previously
analyzed within the Westside Specific Plan/TOD EIR: Traffic, Circulation, and
Parking, Air Quality, Noise, Cultural Resources, Biological Resources,
Community Character and Aesthetics, Land Use, Population and Housing,
Hazards and Hazardous Materials, and I itiiities aril Pi ub !ir Ser►iices. All of the
prior mitigation measures included in the certified EIR would continue to apply to
the removal of hazardous materials. The conclusions described below are
provided as a reference for each environmental issue area identified in the EIR
for the purpose of describing how the proposed changes (refer to Section B TOD
Environmental Site Assessments would not effect the conclusion of the EIR.
Aesthetics
There are no scenic vistas located on the project site or in the immediate vicinity.
Although the TOD project entails redeveloping a 14-ace site with a transit
oriented infill affordable housing development, it would be consistent with the
uses surrounding the site. The TOD project would not adversely affect a scenic
vista and would ultimately improve the scenic quality and visual resources
available within the project area. Because the proposed removal of hazardous
materials was discussed in the EIR and no changes to the project are proposed,
there would be no impacts.
Air Quality
The EIR concluded that the demolition, excavation and grading, and hauling of
debris would create emissions of dusts, fumes, equipment exhaust, and other air
contaminants. Mitigation measures were described in Section 3.2 Air Quality
(MM AQ-1a) that would reduce impacts.
MM AQ-f a Hauling — Cover all haul trucks hauling dirt, sand, soil or other loose
materials or maintain a two foot freeboard. (Air Quality pp ES-9).
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The additional measures are identified in the PMP as follows:
Air Monitoring: Fugitive dust control measures will be implemented at
each excavation area to mitigate dust migration outside the work area (exclusion
zone) and offsite so that there is limited potential for exposure to residents in the
neighborhood. To mitigate dust migration outside the exclusion zone, light
spraying of the active excavation areas with potable water will be conducted
throughout the removal action activities. Dust mitigation will be conducted such
that fugitive dust cannot be visually observed downwind of the excavation or
stockpile area. If dust is observed, the quantity and/or frequency of misting will
be increased until fugitive dust cannot be visually observed downwind of the work
area.
A Miniram dust monitor or equivalent instrument will be utilized whenever visible
dust levels are generated or at least every 2 hours to confirm that total dust
levels are at or below the action level of 0.25 milligrams per cubic meter (mg/m3).
The action level is one-half of the permissible exposure limit (PEL) for chlordane
as published by the Occupational Safety and Health Administration (OSHA). All
measurements will be documented in the field logbook.
Dust Control Plan: Dust suppression will be accomplished by lightly
spraying or misting the work areas with water. Water mist may also be used on
the soil stockpile, in the transport trucks, and on the onsite truck routes. The
volume of water added to suppress dust will not exceed the moisture -holding
capacity of the soil. In addition, after the soil is loaded into the transport trucks,
the soil will be covered with tarps that are adequately secured to ensure that soil
cannot spill out of the truck during transport to the disposal facility.
The soil stockpile location will be situated in an area shielded from the prevailing
wind, where practical, and covered with plastic. For dust -control purposes,
efforts will be made to minimize the soil drop height from excavator's bucket onto
the soil pile and/or into the transport trucks. if adequate room is available, the
excavator will be positioned to load or stockpile soil from the upwind side. If
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sustained wind speeds exceed 15 miles per hour (mph) for a period of 15
minutes, excavation activities will cease until the wind speed is below 15 mph.
Biological Resources
The TOD project is bisected by Paradise Creek, a tributary to San Diego Bay
runs diagonally through the project area. A wetland delineation of Paradise Creek
was conducted during the preparation of the EIR. Narrow banks of coastal salt
mafsh habitat occur on either side of the open creek water. The area west of
Paradise Creek is proposed for a park, just south of the existing Paradise Creek
Educational Park. The Westside Specific Plan and EIR requires that all
development be set back from the creek to ensure that impacts to the creek and
the associated riparian habitat would not occur. The project proposed to restore
and enhance areas within and adjacent to Paradise Creek.
Implementation of the TOD project, including the removal of hazardous materials
would be subject to all existing laws, policies, and ordinances related to water
quality, including complying with construction and permanent BMPs, NPDES,
and stormwater requirements. Impacts on Paradise Creek would be regulated by
the US Army Corps of Engineers, California Department of Fish and Game, and
the Regional Water Quality Control Board. In the undeveloped areas of the TOD
project area, mitigation measures include conducting focused studies prior to
issuance of any grading, building, or other construction permit. Because no
additional development would occur on site due to proposed technical changes
as compared what was previously analyzed in the EIR, these impacts would not
change and have been adequately addressed in the ER.
Cultural Resources
The previous EIR concluded that project impacts to historic, architectural
resources and human remains could have the potential to cause substantial
through grading activities of the TOD project. Pre -historic archaeological
resources and paleontological resources could be damaged or destroyed, and
project impacts to archaeological and paleontological resources could be
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potentially significant. The EIR included mitigation measures to reduce these
impacts to a Tess -than -significant level. Since the mitigation measure described
below would apply to any grading activities, the proposed changes would have
no affect on such resources, and the previously identified impact would remain
the same.
impact CUL-2 The Presence of Paradise Creek would have been attractive
to prehistoric populations, and temporary campsites and/or resource extraction
sites would be expected near this water course and generally within the plan
area. (Cultural Resources ES-18)
MM CUL-2 Archaeological Letter Report. Prior to future project
approvals and the issuance of nay construction permits including but not limited
to a grading permit, future construction shall obtain a qualified archaeologist to
conduct a pedestrian survey and records search to determine potential for the
plan area containing significant archaeological resources. (Cultural Resources
ES-18)
Impact CUL-3 Specific projects that would excavate more than 10 feet
deep or disturb more than 1,000 cubic yards of matrix would be considered to
have a potentially significant adverse impact of paleontogical resources. (Cultural
Resources pp ES-19)
MM CUL-3 Paleontological Letter Report. Prior to future project
approvals and the issuance of any construction permits including but not limited
to a grading permit, future construction projects within the Westside Specific plan
proposing a cut depth greater than 10 feet and 1,000 cubic yards shall obtain a
qualified paleontologist to review the propose construction and grading
information to determine the project would have a moderate to high potential of
encountering paleontological resources. (Cultural Resources pp ES-19)
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Geology and Soils
Lands east and west side of Paradise Creek, namely the City's Public Works
Yard and an outdoor storage area, are known to contain hazardous materials
and have both been identified as brownfields. A substantial amount of polluted
runoff could impact the stormwater drainage system should stormwater flow
through the site during development activities. However, the project would be
required to implement or comply with each of the following: BMPs addressed in a
SWMP; WDRs including an erosion control plan and a SWPPP; and the NPDES
General Permit enforced through local regulations from the City. Compliance with
these discharge and permit requirements would ensure that the TOD project
would not create or contribute runoff water that would exceed the capacity of
stormwater drainage systems or create additional sources of polluted runoff.
Because no additional development would occur on site due to proposed
changes as compared what was previously analyzed in the EIR, these impacts
would not change and have been adequately addressed in the EIR.
Hazards & Hazardous Materials
The previous EIR concluded that the TOD project site includes two parcels of
disturbed land that have had to address hazardous environmental issues. These
two sites are discussed above in Section B TOD Environmental Site
Assessments. The TOD project would require earthwork on soils east and west
of Paradise reek that have been identified as brownfield sites. The
redevelopment of existing contaminated sites could create a significant hazard to
the public or environment through the reasonable foreseeable upset and accident
conditions involving the release of hazardous materials into the environment.
Therefore, eaerthwork activities could potentially release hazardous materials
into the surrounding environment. impact would be significant. Mitigation
measures included in the EIR are listed below that would reduce this impact.
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Threshold HAZ-1 Businesses or properties which use, transport, store, and
dispose of hazardous materials exist within the plan area. However, existing laws
and regulations enforced by federal, state, and local agencies ensure such
businesses and properties abide by all safety laws. Because compliance with
these laws and regulations is mandatory, impact associated with the transport
use or disposal of hazardous materials would be less than significant. (Hazards
and Hazardous Materials pp ES-29)
Impact HAZ-1: Future redevelopment within the project area permitted by
the proposed project on adjacent to or nearby property with known or suspected
contaminated soils, soil gas, and/or groundwater would result I a significant
impact on workers and nearby receptors (e.g. residents and employees of other
businesses) during construction activities. Impacts related to Threshold HAZ-2
would be significant. (Hazards and Hazardous Materials pp ES-31)
MM HAZ-1: Phase I Environmental Site Assessment. Prior to future
project approvals, a Phase I Environmental Site Assessment IESA) shall be
completed for the project site proposed for redevelopment if the site has
historically used or stored hazardous materials or if the site is within 1,000 feet of
a site that has historically used or stored hazardous materials. (See specific MM,
pp ES-30)
MM HAZ-2: Phase 11 Environmental Site Assessment. If mitigation
measure MM HAZ-1 requires a Phase 11 ESA, the Phase 11 ESA shall include, but
not be limited o the following:
A work plan that includes the number and locations of proposed
soil/monitoring wells, sampling intervals, drilling and sampling methods,
analytical methods, sampling rationale, site geohydrology, field screening
methods, quality control/quality assurance, and reporting methods. Where
appropriate the work plan is approved by a regulatory agency such as the DTSC,
RWQCB, or County HMD.
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A site -specific health and safety plan signed by a certified Industrial
Hygienist.
Necessary permits for encroachment, boring completion, and well
installation.
Sampling program (fieldwork) in accordance with the work plan and
health and safety plan. Heldwork is completed under the supervision of State of
California registered geologist
Hazardous materials testing through a state -certified laboratory.
Documentation including a description of filed procedures, boring logs/well
construction diagrams, tabulations of analytical results, cross -sections, an
evaluation of the levels and extent of contaminants found, and conclusions and
recommendations regarding the environmental conditions of the site and the
need for further assessment. A remedial action plan will be developed as
determined necessary by the Principal Investigator. Contaminated groundwater
will generally be handled through the NPDES/dewatering process.
Disposal process including transport by a state -certified hazardous
material hauler to a state -certified disposal or recycling facility licensed to accept
and treat the identified type of waste. (Hazard and Hazardous Materials pp ES-
31)
MM HAZ-3: Compliant with Local, State, and Federal Laws and Regulations
(Phase Ill). In the event hazardous materials are determined to be present, the
property owner, developer, or responsible party shall be required to contact the
local CUPA or applicable regulatory agency to oversee the remediation of the
property in compliance with all applicable local, county, state, and federal laws.
The property owner, developer, or responsible party shall be responsible for
funding or securing funding for the site remediation and shall provide proof to the
City that the site contaminants have been properly removed in compliance with
all applicable laws and regulations prior to project development. (Hazard and
Hazardous Materials pp ES-31).
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In addition, the PMP Addendum indicates that a vapor barrier and Land Use
Covenant may also be considered as an additional mitigation measure based on
results of confirmation sampling. If a vapor barrier is implemented, it will be
developed in accordance with a detailed Operations and Maintenance (O&M)
Plan. To ensure long term effectiveness, an O&M Agreement will be set up
between DTSC and the City of National City. A Land Use Covenant limiting
portions of the WI-TOD for open space use, to specific design elements, or to
ensure the effectiveness of a vapor barrier may also be implemented as
mitigation measure.
The PMP provides for specific transportation plan for offsite disposal described
below:
It is anticipated that approximately 55 transport truckloads for AOC-01 and 255
truckloads will be needed to haul the impacted soil to an offsite disposal facility.
The estimate is based on an average soil weight of 1.4 tons per cy and each
truckload transporting approximately 18 cy. if necessary, the CDC will obtain an
EPA ID number for the site or its designee will sign all manifests and/or bills of
lading. A brief discussion of the transportation plan to be implemented during
remediation activities is provided below.
Soil Loading: Waste soil will be loaded onto transport trailers using
a loader or backhoe. During the loading activities, a water mist will be used to
suppress dust. A designated, full-time flag person will direct truck traffic during
entry and exit at the site. Entry and exit points will be delineated to warn
pedestrians of the truck traffic. Proposed entry and exit points are shown on
Figure 8-3 of the PMP. A truck log will be maintained and will include the trailer
number and company affiliation, the date and time that the truck leaves the site,
the approximate volume of each load, and the hazardous or non -hazardous
waste manifest number. In addition, materials will leave the site with the
Addendum 18 February. 2014
Westside Specific Plan EIR
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appropriate paperwork (e.g., Bill of Lading or Uniform Hazardous Waste
Manifest).
Heavy equipment operation will be restricted to the hours of 7:00 a.m. to 5:00
p.m. on weekdays and 8:00 am. to 5:00 p.m. on weekends. To the extent
possible, truck traffic will be timed to avoid rush hour, with trucks scheduled to
leave the site between the hours of 8:00 a.m. and 3:00 p.m.
Destination of Solt: The results of characterization of the soil stockpiles
will indicate whether the stockpiled soils will be disposed of as non -hazardous,
California non-RCRA hazardous, or RCRA hazardous. if the soil is categorized
as non -hazardous waste, it will be disposed of at the following location:
Otay Landfill
1700 Maxwell Drive
Chula Vista, California
Soil samples analyses may indicate that the soil is California non-RCRA
hazardous. This type of waste is characterized by a total concentrations that is
greater than or equal to its Total Threshold Limit Concentration (TTLC) or soluble
concentrations (when extracted by the Waste Extraction Test) that is greater than
or equal to its STLC. California non RCRA hazardous soil will disposed of at the
following location:
Copper Mountain Landfill
34854 East County 12th Street
Wellton, Arizona 85356
If analyses indicate that soil is RCRA hazardous (soluble constituent result is
greater than its TCLP concentration), excavated soils will be disposed of at the
following location:
Ecology Landfill
U.S. Highway 95
Beatty, Nevada
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19
February. 2014
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Soil Transportation Mode: The excavated soil will be transported via roll -
off bin hauling trucks, end -dump or bottom -dump trucks. It is estimated that each
truck will have a capacity to haul between 10 and 20 tons of material. While the
soil is being loaded into the trucks, dust suppression will be performed by lightly
spraying or misting the work areas with water. Water mist may also be used on
soil placed in the transport trucks. After the soil is loaded into the transport
trucks, the soil will be covered with a tarp to ensure that no soil spills from the
trucks during transport to the disposal facility. If the soil is being transported as
non-RCRA or RCRA hazardous waste, the transport company will be required to
provide proof of valid certification to transport hazardous soillmaterials prior to
transporting the soil.
Before leaving the site, each truck driver will be instructed to notify the Removal
Action Contractor's Site Manager. Each truck driver will be provided with the
cellular phone number for the RA contractor's Site Manager. It will be the
responsibility of the RA contractor's Site Manager to notify DTSC of any
unforeseen incidents. in addition, there are call boxes located along the
freeways that will be traveled to reach the disposal facilities. These call boxes
are situated at roadside locations along the truck route to be used to report
roadside incidents. Each truck driver will be instructed to report any roadside
emergency using the call box system or cellular phone. In the event of an
accidental release, the Highway Patrol and local emergency response personnel
will be contacted.
Once at the disposal facilities, each truck will be weighed before offloading its
payload. Copies of waste manifests will be provided to the RA contractor after all
the impacted soil has been shipped from the Site and delivered to the
appropriate disposal facility.
Truck Transportation Routes:
The anticipated travel time to disposal facilities are:
Otay Landfill is approximately 20 minutes (one-way).
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Westside Specific Plan EIR
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Copper Mountain Landfill is approximately 3 hours (one-way).
U.S. Ecology facility is approximately 7 to 8 hours (one-way).
Given the network of freeways within the San Diego area, there are alternate
routes that could be taken to the disposal facilities, if traffic conditions warrant. In
addition, given the characteristics of the soil being transported, there are no
apparent restrictions that would preclude the trucks from following these routes to
the disposal facilities. The route from the TOD project to the freeway is outlined
in the PMP Addendum.
Hydrology and Water Quality
Lands east and west side of Paradise Creek, namely the City's Public Works
Yard and an outdoor storage area, are known to contain hazardous materials
and have both been identified as brownfields. A substantial amount of polluted
runoff could impact the stormwater drainage system should stormwater flow
through the site during development activities. However, the project would be
required to implement or comply with each of the following: BMPs addressed in a
SWMP; WDRs including an erosion control plan and a SWPPP; and the NPDES
General Permit enforced through local regulations from the City. Compliance with
these discharge and permit requirements would ensure that the TOD project
would not create or contribute runoff water that would exceed the capacity of
stormwater drainage systems or create additional sources of polluted runoff.
Because no additional development would occur on site due to proposed
changes as compared what was previously analyzed in the EIR, these impacts
would not change and have been adequately addressed in the EIR.
Land Use and Planning
The previous EIR addressed changes in land use including the TOD
development. The TOD project would be designed to conform to the goals,
objectives and policies of the Westside Specific Plan and the City's General Plan,
Land Use Code and Redevelopment Plan_ The removal of hazardous materials
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Westside Specific Plan EIR
21
February. 2014
P22
was assumed, as part of the project and specific details of the removal would not
affect the proposed land uses, the impacts would remain unchanged.
Mineral Resources
There are no records of previous mining of mineral resources occurring at the
project site. The construction and operation of the TOD project are not likely to
result in the Toss of valuable aggregate mineral resources. The removal of
hazardous materials was assumed as part of the project, and since there are no
identified mineral resources on site, there are no impacts.
Noise
The previous EIR concluded that construction noise levels could exceed noise
thresholds from the closest sensitive receptor. The City's noise ordinance
exempts construction activities from the noise standards during the hours of 7:00
a.m. and 7:00 p.m. Monday through Friday, but limits construction noise levels to
no more than 75 dBA at type 1 residential properties and 85 dBA at type 2
residential/commercial properties. The noise impacts would be temporary in
nature and would cease once the construction was completed. Mitigation
measures contained in the EIR include the following:
MM N01.5 Hours of Construction. Construction operations shall not occur
between 700 p.m. and 7:00 am. Monday though Friday, or at any time on
weekends or holidays. The hours of construction, including noise maintenance
activities and all spoils and material transport, shall be restricted to the periods
and days permitted by the local noise and other applicable ordinance. Noise -
producing construction activity shall comply with, or in special circumstances
obtain exemptions from, local noise control regulations affecting construction
activity. (Noise pp ES-15)
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Population and Housing
The EIR concluded that the TOD project would induce substantial growth yet the
project population growth and housing stock needs was identified in the City's
General Plan. The removal of hazardous material on the project site would have
no affect on the number of units developed at the site or the number of people
generated by the project, and it would further the goals of the City, the impacts
would remain unchanged.
Public Services
The previous EIR concluded that with payment of required developer fees the
proposed project's impacts on public services, police, fire, school, and parks and
recreational services, would be less than significant. Because the proposed
changes would have no affect on the number of units developed at the TOD
project site or the number of people generated by the project, these impacts
related to public services remain unchanged.
Transportation/Traffic
The previous EIR did not address construction traffic impacts because
construction traffic is temporary in nature and does not substantially affect the
level of service of the roadway system. Although the proposed changes provide
more details regarding the remediation of the TOD site, the changes do not affect
construction related traffic associated with the project and construction related
traffic remains temporary in nature and would not substantially affect the level of
service of the roadway system. Since the proposed changes would not affect the
design of the project, the number of units that would be constructed at the project
site, or the amount of traffic generated by the project, these impacts related to
transportation/traffic would remain unchanged.
Utilities and Service Systems
Utilities to the project area, natural gas, electricity, sewer, water, and solid waste
disposal, are supplied by different agencies. The previous EIR concluded the
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Westside Specific Plan EIR
23 February. 2014
P24
project's demand for water and sewer (provided by Sweetwater Authority and the
City's public works department), electric and gas (supplied by SDG&E), and solid
waste (provided by EDCO) could be accommodated to the project site. The
proposed changes to the removal of the hazardous materials on site would not
affect the number of units constructed on site or the demand for utilities and
service systems. `therefore, the impacts would remain unchanged.
Addendum — — 24 February. 2014
Westside Specific Plan EIR
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�r
Property Mitigation Plan Addendum
WI-TOD Project Area
National City, California 91960
Protect
Loca'tlon
Map
Project Number: 11-052-001
Date: May 2011
Figure 1
P26
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Property Mitigation Plan Addendum
WI-TOD Project Area
National City, California 91950
Project Number
13-052-001
Conceptual
Redevelopment
Plan — Second Level
Date:
February 2014
Figure 2
FIGURE 3
AREA OF CONCERN
LOCATION MAP
PROPERTY MITIGATION
PLAN ADDENDUM
WI-TOD PROJECT AREA
NATIONAL Cfl-Y, CA
Legend
TOD Project Area
0 ADC Boundary
E2 ManageTech