FAXED: JUNE 9, 2006
June 9, 2006
Ms. Joan Wolff
City of Fullerton
Development Services Department
330 West Commonwealth Avenue
Fullerton, CA 92832
Dear Ms. Wolff:
Revised Draft Environmental Impact Report (RDEIR) for
West Coyote Hills Specific Plan and Robert E. Ward Nature Preserve
Fullerton: March 2006
The South Coast Air Quality Management District (SCAQMD) appreciates the opportunity to comment on the above-mentioned document. The following comments are meant as guidance for the Lead Agency and should be incorporated in the Final Environmental Impact Report.
SCAQMD staff is concerned that the lead agency has not fully accounted for the air quality impacts of the proposed project. SCAQMD staff is concerned that the lead agency is planning on building homes on a former oil and gas site that has not yet been remediated. The RDEIR identifies 84 former well sites, 22 historical sites, 21 tank settings and 25 stockpiles where an estimated 77,000 cubic yards of soil contamination exceeds residential cleanup guidelines. The RDEIR references a Remedial Action Plan, however, it is unclear how the proposed site will be remediated and the potential air quality impacts if large amounts of contaminated soil will be trucked off site as part of the soil remediation, and the potential VOC emissions from the decontamination before construction can begin. In addition, SCAQMD staff is concerned that the health risk assessment did not state the potential health risk to surrounding residents during remediation. SCAQMD staff recommends that the proposed project’s emissions be revised to accurately reflect the proposed project’s full air quality impacts in the Final EIR.
Please find attached additional comments regarding the proposed project. Pursuant to Public Resources Code Section 21092.5, please provide the SCAQMD staff with written responses to all comments contained herein prior to the certification of the Final Environmental Impact Report. SCAQMD staff is available to work with the Lead Agency to address these issues and any other questions that may arise. Please call me at (909) 396-3105 if you have any questions regarding these comments.
Sincerely,
Susan Nakamura
Planning and Rules Manager
Toxics Rulemaking and CEQA Analysis
Attachment
SN: CB
SBC060407-02
Control Number
Revised Draft Environmental Impact Report (DEIR) for
The West Coyote Hills Specific Plan and
Robert E. Ward Nature Preserve: March 2006
Soil Contamination Emission Estimates and Health Risk Assessment: On page 4.9-5 of the DEIR, it is stated that an estimated 32,000 cubic yards of crude oil and or metals-impacted soils above Orange County Health Care Agency, Environmental Health Division (OCHCA) cleanup guidelines were identified at 84 former oil well sites. Furthermore, an estimated 25,000 cubic yards of impacted soil at 22 sites within the property were identified above OCHCA residential cleanup guidelines during the supplemental Phase II investigation. Also, 8,500 cubic yards of impacted soil exceeding OCHCA residential cleanup standards were located at the 21 tank setting locations. Impacted soil noted during the investigation ranges from shallow oil road material/weathered crude to crude oil spills extending to a depth of approximately 21 feet below ground surface.
Discussion on the exact nature of the remediation activity does not appear to be included in the Draft EIR. A description of the remedial activity should be included in the Final EIR. The description should include the size of the area disturbed, the types and number of construction equipment required, the number of trucks required to haul contaminated soil, etc. The amount of soil disturbed and contaminates emitted should be presented in the Final EIR. Emissions (VOC) from the soil remediation activities and those (VOC, NOX and PM10) from the trucking of the treated or contaminated soil off-site for disposal are notably missing in Tables 4.4-6 and 4.4-7 of the DEIR and should be accounted for in the Final EIR. The Final EIR should also include calculations that demonstrate that the impacts to off-site receptors would be de minimis.
Page 3-4 of the Human Health Risk Assessment (HHRA) in Appendix 14.10 states that the impacts to off-site residents from contaminated soil during excavation is de minimis, because remedial activities will comply with the permitted use of wetted soils and air monitoring during remediation. Page 4.9-5 of the Draft EIR lists estimates of the amount of contaminated soil. Page 4.9-11 states that remedial activities on the western and eastern portions of the proposed project site will be necessary for development. This statement appears to imply that excavation specifically for remediation would be required. Specific amounts of contaminated soil are presented on page 4.9-5 of the Draft EIR, but it is unclear if all of the contamination presented would be removed/remediated. The amount of soil that would be disturbed for remediation does not appear to be clearly presented, nor the amount of contamination in the soil.
SCAQMD Applicable Rules: In Section 4.4.3 – Standards and Conditions, the lead agency discusses the SCAQMD Rules, namely 403, 431.1, 431.2, 1108 and 1113 that the proposed project will be subject to. The lead agency fails to mention two other SCAQMD Rules that will apply to the proposed project. These two rules are Rule 1150 – Excavation of Landfill Sites, and Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil. These should be included in the discussion in Section 4.4.3 of the Final EIR.
Construction Overlapping Phases Emissions: Table 3-4 on page 3-22 of the DEIR shows there will be considerable overlap of activities during project construction. Emissions from these overlapping activities do not appear to be accounted for in the construction emissions tables. This should be corrected in the Final EIR. The URBEMIS output printout shows that construction will begin January 2005. The proposed project is already a year and a half old. This should also be corrected in the model run in order to accurately reflect projected emissions from the proposed project.
Localized Impacts: Consistent with the SCAQMD’s environmental justice program and policies, the SCAQMD recommends that the lead agency also evaluate localized air quality impacts to nearby sensitive receptors, i.e., the residential communities surrounding the proposed project site. SCAQMD staff recommends that for this project and for future projects, the lead agency undertake the localized analysis to ensure that all feasible measures are implemented to protect the health of nearby sensitive receptors. The methodology for conducting the localized significance thresholds analysis can be found on the SCAQMD website at: www.aqmd.gov/ceqa/handbook/LST/LST.html.
CO Hotspots: The Air Quality Analysis states that the CO hotspots analysis was completed according to the CALTRANS Transportation Project-Level Carbon Monoxide Protocol (CO Protocol), Revised December 1997, UCD-ITS-RR-97-21. However, the CO analysis appears to deviate from the CO Protocol. Figure F-3 in Appendix B of the CO Protocol illustrates how dedicated left-turn movements should be represented in CALINE4. The dedicated left-turn link endpoint should be located at the center of the adjacent turn link, and extend as far back as the link representing the through movement. The left-turn link end point is located before the intersection and does not extend to the though movement link. The Final EIR should include CALINE4 modeling with left turn links represented correctly.
Diesel Exhaust Health Risk Assessment: Health risk from construction diesel exhaust particulate was estimated based on 33.6 pounds per day from Phase I over 36 months and 41.30 pounds of construction diesel PM10 from Phase II as presented in the URBEMIS2002 files. Appendix I “Diesel Particulate Predictions” states that Phase I would result in the highest rate of diesel particulate emissions. Both Appendix I and the Draft EIR state that less acreage would be graded per day under Phase I (38.3 acres) than Phase II (89.2 acres). The lead agency needs to provide additional information to clarify how grading more acres in Phase II as compared with Phase I will produce less PM10 emissions. These inconsistencies should be explained or corrected in the Final EIR.
Diesel particulate traps and exhaust gas recirculation were used as mitigation for cancer risk from diesel particulate exhaust from construction equipment. The SCAQMD encourages the lead agency to implement all feasible mitigation measures including diesel particulate traps and exhaust gas recirculation. However, while non-CARB approved alternative fuels and control technology may reduce emissions and benefit air quality, SCAQMD staff would only recognize emission reductions from CARB-verified alternative fuels and control technology.
Mitigating Soil Remediation Odors: To reduce potential odors that may be generated during soil remediation, SCAQMD staff recommends that the project proponent install a weather monitoring station to identify levels of temperature, humidity, wind speed and wind direction leading to offsite odor complaints as part of the proposed project’s odor management plan.
Mitigating Project Emissions: Given the magnitude of the construction emissions and considering that construction of the proposed project will take approximately five years to complete, SCAQMD staff is concerned that the lead agency has not proposed enough measures to reduce the project’s construction air quality impacts. Furthermore, since the air basin is currently designated as non-attainment for both the federal and state ozone, carbon monoxide and particulate matter standards, it is important that the lead agency ensure the implementation of any measures that would help reduce any of the criteria pollutants. SCAQMD staff therefore recommends the following measures for consideration by the lead agency for implementation where applicable or feasible:
Measures to Reduce NOX or Construction Equipment Emissions
· For all construction equipment, such as tractors, loaders and graders, require the use of alternative clean fuel such as electric or compressed natural gas-powered equipment with oxidation catalysts and particulate traps instead of gasoline- or diesel-powered engines. However, where diesel equipment has to be used because there are no practical alternatives, require the use of low-sulfur diesel, as defined in SCAQMD Rule 431.2, i.e., diesel with sulfur content of 15 ppm by weight or less. The low-sulfur diesel has the potential to reduce NOX emissions by 50 percent.
· Require the use of aqueous or emulsified diesel fuel for all construction equipment. Aqueous diesel formulations have received interim verification by the California Air Resources Board (CARB) and show a reduction of 16 percent in NOX and 60 percent in PM10 from diesel exhaust. Information on aqueous diesel fuel formulations can be found at: http://www.arb.ca.gov/diesel/FAQ.htm#6
· Maintain equipment and vehicle engines in good condition and in proper tune as per manufacturers’ specifications.
· Restrict idling emissions by using auxiliary power units and electrification.
· Enforce truck parking restrictions.
· Redirect truck route to avoid residential areas or schools.
· Appoint a construction relations officer to act as a community liaison concerning on-site construction activity and all emissions/congestion related matters. Post a publicly visible sign with name of contact person and telephone number for dust, odor or noise complaints.
Measures to Reduce Construction PM10 Emissions:
· Trucks hauling dirt, sand, gravel or soil are to be covered in accordance with Section 23114 of the California Vehicle Code.
· Pave parking areas and construction access roads to the main roads to avoid dirt being carried on to the roadway.
· Enclose, cover or apply soil binders to exposed piles, i.e., gravel, sand or dirt.
· Sweep nearby or adjacent streets at the end of the day if visible soil material is carried over from construction site.
· Install wheel washers where vehicles enter and exit unpaved roads, or wash off tires of vehicles and any equipment leaving construction site.
· Suspend all grading and excavating operations when wind speeds exceed 25 miles per hour.
· Reduce area graded to no more than 14 acres per day.
Measures to Reduce CO Emissions:
· Improve traffic flow through signal synchronization.
· Provide temporary traffic controls (e.g., flag person) during construction period to ensure smooth traffic flows.
· Consolidate and schedule construction material deliveries to off-peak hours.
· Reroute construction trucks away from congested streets.
· Provide dedicated turn lanes for efficient movement of construction trucks, equipment and also for general traffic.
· Add extra lanes and provide intersection signalization to ensure smooth flow of traffic.
· Provide a shuttle service for construction workers to and from food establishments during lunch hour or arrange for mobile caterers to come to the project site during lunch break.
Measures to Reduce Long-Term Emissions in Residential and Commercial areas
· Install solar panels on roof to supply electricity for air conditioning.
· Use double-paned windows to reduce thermal loss.
· Install central water heating systems to reduce energy consumption, and
· Use light-colored roof materials to deflect heat from buildings and conserve energy.
· Install energy-efficient appliances to reduce energy consumption.
· Install automatic lighting on/off controls and energy-efficient lighting.
· Install energy-efficient street lighting.
· Landscape with appropriate drought-tolerant species to reduce energy and water consumption.
· Provide shade trees in residential and public areas to reduce building heating/cooling needs.
· Construct pedestrian and transit-friendly facilities, such as wider sidewalks, bus stops with passenger benches and shelters, bikeways or lanes.
· Install electrical outlets at the front and back of the residences and buildings to facilitate the use of electric landscape maintenance equipment.
